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ANTON HANDAL (Bar No. 113812)
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
H
ANDAL & ASSOCIATES
750 B Street, Suite 2510
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff and Counter-Defendant
e.Digital Corporation
Additional counsel listed on last page
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
IN RE: EDIGITAL CASES Case Nos.:
13-cv-2907-H-BGS
13-cv-2944-H-BGS
AMENDED JOINT HEARING
STATEMENT
[PATENT LOCAL RULE 4.2]
Judge: Hon. Marilyn L. Huff
Ctrm: 15A (Annex)
Hearing: February 19, 2015
Time: 9:00 a.m.
Pursuant to Patent Local Rule (“Patent L.R.”) 4.2, the Court’s August 5,
2014 Consolidated Scheduling Order (“Scheduling Order”), and in light of
discussions between the parties to focus issues before the Court, Plaintiff and
Counter-Defendant e.Digital Corporation (“Plaintiff” or “e.Digital”) and
Defendants and
Counterclaimants Micron Consumer Products Group, Inc., d/b/a
Lexar; and, Micron Technology, Inc.
(collectively, “Defendants”) submit this
Amended Joint Hearing Statement.
HANDAL & ASSOCIATES
750 B STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
I. MOST SIGNIFICANT DISPUTED CLAIM TERMS FOR
CONSTRUCTION
As required under Patent L.R. 4.2.a, the parties jointly identify the following
claim terms of the asserted U.S. Patent No. 5,839,108 (“the ’108 patent”) whose
constructions are believed to be most significant to the resolution of this case, and
whose constructions are believed by one or more parties to be claim dispositive.
1
Claim Term or Phrase Patent Believed
Dispositive?
primary memory ’108 Y
Preamble ’108 Y
file system ’108 Y
creating the primary memory from a non-volatile,
long term storage medium, wherein the primary
memory comprises a plurality of blocks in which
the data segments are to be stored
’108 N
a logical link between the previous logical data
segment and the new data segment
’108 Y
a path for sequentially accessing the data
segments within the primary memory
’108 Y
data storage format ’108 N
Pursuant to Patent L.R. 4.2.b, the Amended Joint Claim Construction Chart,
attached as Appendix A, contains each party’s currently proposed constructions of
the disputed claim terms and phrases together with an identification of intrinsic and
extrinsic evidence proffered by the parties in support of their constructions. Each
party reserves the right to refer to the evidence proffered by the other. Pursuant to
Patent L.R. 4.2.c, an Amended Joint Claim Construction Worksheet is attached as
Appendix B.
II. ANTICIPATED LENGTH OF CLAIM CONSTRUCTION HEARING
The parties anticipate that the claim construction hearing will require
1
For the sake of clarity and as set forth in the attached Joint Claim Construction Chart (Exhibit A),
e.Digital does not assert that any of the claims proposed for construction are dispositive except to the extent the
court finds any such term indefinite.
HANDAL & ASSOCIATES
750 B STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
approximately three (3) hours, if that is feasible based on the Court’s schedule.
III. WITNESSES
Neither party intends to call any witnesses at the claim construction hearing.
IV. ORDER OF PRESENTATION AT CLAIM CONSTRUCTION
HEARING
The parties have agreed that they will present their arguments on a term-byterm
basis at the hearing, with the party seeking construction presenting first for
each such term.
HANDAL & ASSOCIATES
Dated: January 12, 2015 By:
/s/ Gabriel G. Hedrick
Anton N. Handal
Gabriel G. Hedrick
Pamela C. Chalk
Attorneys for Plaintiff
e.Digital Corporation
/s/ Matthew A. Ferry
Randall E. Kay (State Bar No. 149369)
rekay@jonesday.com
Matthew A. Ferry (State Bar No. 279236)
mferry@jonesday.com
JONES DAY
12265 El Camino Real, Suite 300
San Diego, CA 92130
Tel: 858.314.1200
Fax: 858.314.1500
Frank P. Coté (State Bar No. 204529)
fcote@jonesday.com
JONES DAY
3161 Michelson Blvd., Suite 800
Irvine, CA 92612
Tel: 949.851.3939
Fax: 949.553.3939
Attorneys for Micron Technology, Inc.; and
Micron Consumer Products Group, Inc.,
d/b/a Lexar
Case 3:13-cv-02907-H-BGS Document 39 Filed 01/12/15 Page 3 of 5
ATTESTATION OF E-FILED SIGNATURE
Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative
Policies and Procedures Manual, I, Gabriel G. Hedrick, attest that the above
signatories have read and approved the foregoing and consent to its filing in this
action.
By /s/
Gabriel G. Hedrick
Gabriel G. Hedrick
-4-
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