The disputed terms appear in

every independent claim at issue in this case. If any of the claims survive, whether in whole, or even if amended, the Court will still have to construe these terms.

Moreover, to the extent the Patent Trial and Appeal Board has or will

construe any of the terms at issue here, those findings will not be binding on this Court since the PTO construes terms according to their “broadest reasonable interpretation” (“BRI”) and this Court must construe patent terms according to

Philips, i.e., “the meaning that [a] term would have to a person of ordinary skill inthe art in question at the time of the invention.” Compare In re Rambus, ArcSoft has therefore failed to show

and cannot show that the pending IPRs will have any effect on the construction ofthe claim terms at issue in the present case.