Identification Of Significant Claim Terms
The parties hereby identify the following terms, in no particular order, whose
construction will be most significant to the resolution of this case:
1. “social signature”
2. “social hierarchy”
3. “social template”
4. “unique social signature”
5. “sensor value range”
6. “optical sensor”
7. “information”
8. “provide/ provides/ providing differing levels of information”
9. “provided…/ provides/ providing an update”
10. “accurate”
Plaintiff, e.Digital, does not believe construction of any of the above terms will be case or
claim dispositive at this time.
IV. Anticipated Length Of Time Necessary For Claim Construction Hearing
The parties anticipate they will need four (4) hours for the Claim Construction Hearing.
V. Witnesses
Plaintiff may call the inventor, Patrick Nunally, as a witness to testify regarding each of
the disputed terms identified above. Specifically, Mr. Nunally is expected to testify regarding
the technology that underlies the invention of the asserted claims and any parent patents; the
level of ordinary skill in the art; how the relevant claims would be understood by one of ordinary
skill in the art; the meaning of the disputed claim terms, phrases and limitations, and/or any other
opinions or testimony relevant to the Court in construing the terms, phrases and limitations of the
asserted claims of the asserted patents. Plaintiff, e.Digital, reserves the right to introduce
additional testimony from the inventor to rebut Dropcam’s claim construction positions, and any
expert testimony introduced by Dropcam.
Defendants may call Dr. Earl Sacerdoti. Dr. Sacerdoti may testify as to the
understanding of individuals of ordinary skill in the art at the relevant time period for the
Asserted Patents. Specifically, Dr. Sacerdoti may provide testimony regarding background
technology or to demonstrate that Dropcam’s constructions of the proposed claim terms and
phrases are consistent with the meaning of such terms and phrases in the relevant art during the
relevant time period for the Asserted Patents. Such testimony will address both the general
understanding of the relevant terms and phrases in the field of the art as well as the
understanding of such terms and phrases in the context of the specifications and claims of the
Asserted Patents. Dropcam does not plan to bring Dr. Sacerdoti to the claim construction
hearing unless the Court requests his presence in advance. Dropcam further reserves the right to
introduce expert testimony from Dr. Sacerdoti to rebut e.Digital’s claim construction positions,
and any expert testimony introduced by e.Digital.
HANDAL & ASSOCIATES
Dated: May 5, 2015 By: /s/ Gabriel G. Hedrick
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
Dated: May 5, 2015 WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
By: /s/ Stefani E. Shanberg
Stefani E. Shanberg
Attorneys for Defendant
DROPCAM, INC
