"Finally, Dropcam’s insistence that a “social template” is a “data structure” does nothing to clarify the meaning of the term. e.Digital does not dispute that the “social template” is a data structure. However, inclusion of the term in the construction of “social template” is more likely to confuse rather than enlighten a lay jury responsible for determining infringement. First, the term is not used anywhere in the specifications. Second, “data structures” are not a commonly understood concept and the term would likely require its own separate construction, which Dropcam has not defined or asked the Court to define at any point to date."

Frank, no matter how you read the arguments of terms considered for construction... the above is an important part.

That, and creating the "data structure" in real time as needed....or lousy time status quo methods also considered in the IP.

e.Digital will utilize its real time methods, however, it has closed the door on arguments regarding status quo methods. I got the feel for that door being closed with the very first Mother ship publishing.

Defendants have no argument over data structure because all the bases are covered to kill that argument.

As you see, defendants are bring us back to square one...where square one has nothing to do with the terms "social signature"; “social template”; "social hierarchy"...etc...

doni