"Giving claims their broadest reasonable interpretation — instead of a narrower interpretation often used in court proceedings — allows patentees during an IPR to amend ambiguous claims, is consistent with how the USPTO has analyzed unexpired claims in..."

So, how do we equate that consideration regarding e.Digitals IPR circumstance?

The above info you present ...considers, @ the moment, that the PTAB affords "Giving claims their broadest reasonable interpretation — instead of a narrower interpretation often used in court proceedings "

From the response, we have the opposit consideration...

"Petitioners offer claim constructions for the terms “social template,” “social

hierarchy,” and “level of a social hierarchy,” all of which either conflict with

and/or are narrower than constructions found by the Court in the related District

Court case. (See Ex. 2003.) In its Decision granting the present Petition, the (PTAB)

Board concluded, “an express construction [of these terms] is not necessary.”

Owner disagrees with Petitioners’ proposed constructions of these terms, but

asserts a construction of these terms is unnecessary to resolve the issues on this

Petition.

"Solely for purposes of the present action, Owner believes that only the

term “unique social signature” require construction in order to resolve the

outstanding issues on this Petition."

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Considered constructions, if need be, for the PTAB:

Owner:

A. “unique social signature” Mutually agreed construction civil court, e.Digital states now it can rectify the IPR proceedings with a construction...

Petitioner:

B. “social template” Mutually agreed construction civil court,

C. “social hierarchy” Court construed: “an arrangement of persons and/or operations in a series of ordered levels.”

D. “level of [a] social hierarchy” not construed

"Despite offering a construction of “social hierarchy,” Petitioners propose a

separate construction of the term “level of a social hierarchy.” Owner submits that

construction of this term is wholly unnecessary. The term “level” has a plain and

ordinary meaning. Furthermore, the parties competing constructions of the term

“social hierarchy,” regardless of which construction is adopted, each make clear

what would constitute a “level of a social hierarchy” as disclosed by the inventor.

Petitioners’ proposed construction of this term, “a grouping of people that receives

information,” should be rejected for the same reasons set forth above."

Petitioner is trying to back stop the civil courts ruling of “social hierarchy” allowing for operations.

Two of the petitioners constructions should be denied, as they where mutally agreed constructions of the civil case. Going after the word level is a joke, as it would denie a BRI of the term “social hierarchy” by disallowing operations.

doni