Letgo, where soon the Micron IPR should be put to rest.

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Where all of the 108 defendants have now had the time to read Purcells response. Basically saying, the matters of reclamation, ware leveling and file management have to be a fully contained and managed process...consolidated to one process.

For e.Digital "file system" consolidates ALL.

In other words, you can not have a 1st level of Logical file management of data , a 2nd separate level of background reclamation of memory, which involves moving raw data, on and off the memory.... through a RAM process.

The Logically managed data and the RAW data have to be combined into singular process in order to fit the claim terms challenged by petitioner.. If the prior art moves data on and off,@ either level, it is considered a BAN type memory process as fully explained in the 445 patent.

doni