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And on Page 1 of the '522 patent -- and for reference, the '522 patent is the parent of the patents that are asserted in this case. The patents all share a virtual identical set of

specifications. They all descend from the '522.

THE COURT: Am I correct that all of the raw or

processed data in the first portion of this claim term has to originate from sensors? It can't just be from anywhere, right?


MR. HANDAL: It could be from anywhere,

And this is Claim 15, a dependent claim of the '522


patent. And in this particular claim, the sensor data is used to determine the status of the communication device, not activity. So the proposed construction -- Dropcam's proposed activity. So the proposed construction -- Dropcam's proposed construction would be wholly inconsistent with this claim of the '522 patent.


And that's our position.


THE COURT: Thank you.



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