EXHIBIT 4 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 1 of 18
1

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

WSOU INVESTMENTS LLC D/B/A 

BRAZOS LICENSING AND 

DEVELOPMENT,

 Plaintiff,

v. 

ZTE CORPORATION, ZTE (USA) INC. 

AND ZTE (TX), INC.,

 Defendants.

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C.A. NO. 6:20-cv-00487-ADA

C.A. NO. 6:20-cv-00488-ADA

C.A. NO. 6:20-cv-00489-ADA

C.A. NO. 6:20-cv-00490-ADA

C.A. NO. 6:20-cv-00491-ADA

C.A. NO. 6:20-cv-00492-ADA

C.A. NO. 6:20-cv-00493-ADA

C.A. NO. 6:20-cv-00494-ADA

C.A. NO. 6:20-cv-00495-ADA

C.A. NO. 6:20-cv-00496-ADA

C.A. NO. 6:20-cv-00497-ADA

DEFENDANTS’ NARROWED CLAIM TERMS AND CONSTRUCTIONS

Pursuant to the Court’s First Amended Scheduling Order (Dkt. No. 45),

1 Defendants ZTE 

Corporation, ZTE (USA) Inc., and ZTE (TX), Inc. (collectively “ZTE”) hereby serves its 

narrowed claim terms and claim constructions to WSOU Investments LLC D/B/A Brazos 

Licensing and Development (“WSOU”) as to the Asserted Claims2 of U.S. Patent No. 8,451,839 

(the “’839 Patent”), U.S. Patent No. 7,489,929 (the “’929 Patent”), U.S. Patent No. 7,487,240 

(the “’240 Patent”), U.S. Patent No. 8,179,960 (the “’960 Patent”), U.S. Patent No. 8,730,905 

(the “’905 Patent”), U.S. Patent No. 8,147,071 (the “’071 Patent”), U.S. Patent No. 9,294,060 

(the “’060 Patent”), U.S. Patent No. 9,185,036 (the “’036 Patent”), U.S. Patent No. 9,258,232 

(the “’232 Patent”), U.S. Patent No. 7,742,534 (the “’534 Patent”), and U.S. Patent No. 

7,203,505 (the “’505 Patent”) (collectively, the “Asserted Patents”).

1 There are 11 pending cases. Citations throughout refer to new WDTX Case Nos. -00487 through -00497, and 

specific citations reference to the docket for WDTX Case No. -00487. 2 The “Asserted Claims” as identified by WSOU in its November 3, 2020 Disclosures of Preliminary Infringement 

Contentions.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 2 of 18
2

Defendants propose the following narrowed claim term constructions3 for the Asserted 

Claims of the Asserted Patents. Defendants also incorporate by reference all claim terms / 

limitations identified in their invalidity contentions as being indefinite under indefinite under 35 

U.S.C. § 112 ¶ 2 (see Invalidity Contentions, Section IX.B as served on January 6, 2021), and as 

lacking enablement and written support under indefinite under 35 U.S.C. § 112 ¶ 1 (see

Invalidity Contentions, Section IX.A as served on January 6, 2021).

Defendants expressly reserve the right to supplement, amend, or otherwise modify their 

list of terms in any way permitted by the Federal Rules of Civil Procedure and this Court’s Local 

Rules and Patent Rules, or in response to Plaintiff WSOU’s identification of terms and elements. 

Defendants provide this disclosure based upon information reasonably known and available to 

Defendants at this time. To the extent that WSOU shows good cause and is permitted to amend 

or supplement its infringement contentions in the future, or otherwise changes or further clarifies 

the positions it has taken in this case (including to add or to change in any way the claim(s) 

currently asserted, or to modify its apparent interpretation of the scope of the claim(s)), 

Defendants reserve the right to respond.

3 Defendants reserve the remaining terms and maintains that they are indefinite, lack support, and/or are invalid 

under 35 U.S.C. §§ 112(a), (b), and (f).

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 3 of 18
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Means-Plus-Function Terms

Asserted 

Claim

Claim Term Preliminary Proposed Construction Extrinsic Evidence 

Support

’505 Claim 

14

“a formatter to format the received 

data into at least one SMS (Short 

Message Service) message”

Governed by 35 U.S.C. § 112(f)

Function: formatting the received data into at least 

one SMS (Short Message Service) message 

Indefinite under 35 U.S.C. § 112(b); specification 

fails to describe it

Structure: none disclosed

None.

’534 Claim 6 “means for selecting a set of subcarriers from the plurality of subcarriers on which user data is to be 

communicated from a transmitter to a 

receiver, said selecting based at least 

in part on at least one of sub-carrier 

quality levels and a threshold 

indication associated with sub-carriers, 

said quality levels communicated from 

the receiver to the transmitter and said 

threshold indication communicated 

from the transmitter to the receiver;”

Governed by 35 U.S.C. § 112(f)

Function: selecting a set of sub-carriers from the 

plurality of sub-carriers on which user data is to be 

communicated from a transmitter to a receiver

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’534 Claims 

1, 6, 13

“means for selecting said set of subcarriers on which said user data is to 

be [received from said transmitter] / 

[transmitted to said receiver]”

Governed by 35 U.S.C. § 112(f)

Function: selecting the set of sub-carriers on which 

the user data is to be received from the transmitter

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 4 of 18
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’534 Claims 

1, 6

“means for determining quality levels 

for sub-carriers”

Governed by 35 U.S.C. § 112(f)

Function: determining quality levels for sub-carriers

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’534 Claim 6 “means for receiving and storing said 

threshold indication from said 

transmitter, said threshold indication 

and said quality levels enabling said 

receiver to deduce said set of subcarriers on which said user data is to 

be received”

Governed by 35 U.S.C. § 112(f)

Function: receiving and storing the threshold 

indication from the transmitter, the threshold 

indication and the quality levels enabling the 

receiver to deduce the set of sub-carriers on which 

the user data is to be received

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’232 Claim 

14 

“instructions for receiving, by a 

controller of the traffic flow control 

system, a backpressure signal, wherein 

the back pressure signal indicates a 

period of congestion”

Governed by 35 U.S.C. § 112(f)

Function: receiving, by a controller of the traffic 

flow control system, a backpressure signal, wherein 

the back pressure signal indicates a period of 

congestion 

Indefinite under 35 U.S.C. § 112(b) 

Structure: none disclosed

None.

’232 Claims 

1, 14

“instructions for execution by a traffic 

flow control system for performing 

flow control on a flow of data packets 

for transmission over a link”

Governed by 35 U.S.C. § 112(f)

Function: execution by a traffic flow control system 

for performing flow control on a flow of data 

packets for transmission over a link 

Indefinite under 35 U.S.C. § 112(b); Structure: none 

disclosed

None.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 5 of 18
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’036 Claims 

1, 12, 23, 24

“congestion condition to enable 

thereby the control of at least one data 

flow in a manner tending to reduce the 

congestion condition”

Governed by 35 U.S.C. § 112(f)

Function: enable thereby the control of at least one 

data flow in a manner tending to reduce the 

congestion condition

Indefinite under 35 U.S.C. § 112(b)

Lacks Written description under 35 U.S.C. § 112(a);

Structure: none disclosed

None.

’240 Claims 

1

“connectivity verification server to 

perform unattended connectivity 

verification jobs”

Governed by 35 U.S.C. § 112(f)

Function: perform unattended connectivity 

verification jobs

Indefinite under 35 U.S.C. § 112(b)

Alternative structure: Managed Object Server as set 

forth in the specification at 7:49-58.

None.

’839 Claim 6 “a first obtainer configured to obtain 

route-related information and a 

predefined using time from said access 

response message, said predefined 

using time indicating the using time of 

said route”

Governed by 35 U.S.C. § 112(f)

Function: obtain route-related information and a 

predefined using time from said access response 

message, said predefined using time indicating the 

using time of said route

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’839 Claim 6 “a route maintainer configured to 

update a route table based on said 

Governed by 35 U.S.C. § 112(f) None.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 6 of 18
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route-related information and said 

predefined using time”

Function: update a route table based on said routerelated information and said predefined using time

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

’839 Claim 8 “a first judger configured to judge 

whether the route table item 

corresponding to said route-related 

information exists in said route table”

Governed by 35 U.S.C. § 112(f)

Function: judge whether the route table item 

corresponding to said route-related information 

exists in said route table

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’839 Claim 8 “a creator configured to create the 

route table item corresponding to said 

route-related information if the first 

judger judges that no route table item 

corresponding to said route-related 

information exists in said route table”

Governed by 35 U.S.C. § 112(f)

Function: create the route table item corresponding 

to said route-related information if the first judger 

judges that no route table item corresponding to said 

route-related information exists in said route table

Indefinite under 35 U.S.C. § 112(b)

Structure: none disclosed

None.

’071 Claim 1 “a processor for providing image data 

signalling to a projector, the image 

data signalling representing an image 

to be projected by the projector”

Governed by 35 U.S.C. § 112(f)

Function: providing image data signalling to a 

projector, the image data signalling representing an 

image to be projected by the projector

Structure: an integrated circuit chip customized for a 

particular use as set forth in the specification at 

4:37-39.

None.

’071 Claim 

14

“computer program code configured 

to, when executed by one or more 

Governed by 35 U.S.C. § 112(f) None.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 7 of 18
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processors, cause an apparatus to 

perform at least: receiving movement 

signalling associated with movement 

of a projector; and providing image 

data signalling to the projector based 

on received movement signalling, 

wherein the movement signalling 

provides an indication of one or more 

movement criterion of the projector, 

the movement criterion representing 

one or more of displacement and 

movement speed of the projector, and 

wherein the processor is configured to 

discriminate a movement criterion and 

to provide associated image data 

signalling to project associated image 

data.”

Function: executing computer program code 

configured to cause an apparatus to perform (1) 

receiving movement signalling associated with 

movement of a projector; and (2) providing image 

data signalling to the projector based on received 

movement signalling, wherein the movement 

signalling provides an indication of one or more 

movement criterion of the projector, the movement 

criterion representing one or more of displacement 

and movement speed of the projector, and wherein 

the processor is configured to discriminate a 

movement criterion and to provide associated image 

data signalling to project associated image data

Indefinite under 35 U.S.C. § 112(b)

Structure: None disclosed

Other Terms

Asserted 

Claim

Claim Term Preliminary Proposed Construction Extrinsic Evidence 

Support

’505 Claim 1 “data synchronization” Bringing a data file of a source device and a data 

file of a target device to the same value.

Wiley-IEEE 

Hargrave’s 

communications 

dictionary

’505 Claims 

1, 23

“formatting” Indefinite under 35 U.S.C. § 112(b)

Lack of Written description under 35 U.S.C. § 

112(a)

Wiley-IEEE 

Electrical and 

Electronics 

Engineering 

Dictionary

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 8 of 18
8

’505 Claim 

14

“formatter to format” Indefinite under 35 U.S.C. § 112(b)

Lack of Written description under 35 U.S.C. § 

112(a)

’505 Claim 

14

“data message receiver” Indefinite under 35 U.S.C. § 112(b)

Lack of Written description under 35 U.S.C. § 

112(a)

’505 Claims 

1, 14, 23

“SMS (Short Message Service)” Cellular based messages of limited size consisting 

of text and numbers.

Wiley-IEEE 

Hargrave’s 

communications 

dictionary (with 

minor modification)

’505 Claims 

1, 14, 23

“remotely located terminal device” A device that is unable to connect via local area 

network to a host device.

Wiley-IEEE 

Electrical and 

Electronics 

Engineering 

Dictionary (with 

minor modification)

’505 Claims 

1, 23

“short-range connection” A connection between terminal devices using 

infrared or Bluetooth connection

’534 Claims 

4, 7

“maximal number of sub-carriers” Indefinite under 35 U.S.C. § 112(b)

’534 Claims 

1, 2, 16

“as a function of said indication and of 

said quality levels”

Arranging the sub-carriers in quality level 

decreasing order and to select the sub-carriers 

starting with the sub-carrier having the highest 

quality level and continuing to select the subcarriers with decreasing quality level until the 

indication related to a threshold is reached.

’534 Claim 5 “calculated at said receiver” Determining at a terminal a quality level for the 

sub-carriers of a multi carrier system.

’534 Claims 

1, 2, 3, 5, 6, 

“quality level” One of a signal-to-interference ratio, a bit error rate, 

or a modulation scheme.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 9 of 18
9

7, 8, 9, 13, 

16, and 17

’929 Claims 

1, 3, 8, 10, 

and 15

“handoff” / “determining if a handoff 

is desired”

Connection to mobile device is handed-over from 

base station to another base station without breaking 

the connection. 

Wiley-IEEE 

Hargrave’s 

communications 

dictionary

’929 Claims 

1, 2, 3, 4, 6, 

9, 11, and 13

“link” / “establishing a new link” / 

“existing link” / “initiating a new 

link” / “releasing the existing link”

A communication link between a base station and a 

mobile station, the communication link including 

one or more communication channels.

’929 Claim 1 “achieving uplink synchronization” Matching a mobile station's clock and data timing to 

the same clock and data timing of a base station.

Wiley-IEEE 

Hargrave’s 

communications 

dictionary (with 

minor modification)

’929 Claim 1 “processed the transmitted active set 

update message”

Updating the active set to replace an existing 

communication link with a new communication 

link.

’929 Claim 8 “measurement reports” Values reported from a mobile station that contain 

information about channel quality. Measurement 

reports assist the network in making handover and 

power control decisions.

E1968A, E6701H, 

E6704A 

GSM/GPRS/EGPRS 

User's Guide 

(keysight.com)

’929 Claim 

11

“buffering bearer traffic” During a handoff process, all data from the mobile 

station is buffered at the mobile station or all data at 

the network side is buffered at the network side 

until the handoff process is complete.

’929 Claim 

14

“characteristic” Indefinite under 35 U.S.C. § 112(b)

’929 Claim 

14

“replacement hysteresis” Indefinite under 35 U.S.C. § 112(b) Optimal Timer 

Settings For The 

Soft Handover 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 10 of 18
10

Algorithm in 

WCDMA | Request 

PDF 

(researchgate.net)

3GPP, ETSI TR 125 

922 v3.2.0 (2000-

06)

’232 Claims 

1, 14

“flow control” Regulate movement of a series of data packets Wiley Electrical and 

Electronics 

Engineering 

Dictionary

’232 Claims 

1, 14

“transmission over a link” Indefinite under § 112(b)

’232 Claims 

1, 14

“backpressure signal” Lacks written description under 35 U.S.C. § 112(a)

’232 Claims 

1, 14

“period of congestion” Lack of written description under 35 U.S.C. § 

112(a)

’232 Claims 

1, 14

“rate limiting” Lack of written description under 35 U.S.C. § 

112(a).

’232 Claims 

1, 14

“content of the backpressure signal” Lack of written description under 35 U.S.C. § 

112(a) 

’036 Claims 

1, 6-10, 12, 

17-21, 23, 24

“data flow” / “to enable thereby the 

control of at least one data flow” / 

“data flow is controlled” / “a data 

flow” / “the data flow”

Indefinite under 35 U.S.C. § 112(b)

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 11 of 18
11

’036 Claims 

1, 3, 12, 14, 

23, 24

“network” / “network node in the 

network” / “network node” / “one or 

more network nodes upstream of the 

congestion condition”

Indefinite under 35 U.S.C. § 112(b).

’036 Claims 

1, 12, 23, 24

“congestion condition” / “indication 

that a congestion condition exists”

Indefinite under 35 U.S.C. § 112(b).

’036 Claims 

1, 12, 23, 24

“in a manner tending to reduce the 

congestion condition” / “the 

congestion may be reduced”

Indefinite under 35 U.S.C. § 112(b)

’036 Claims 

2, 4, 13, 15

“queue” / “queue maximum 

occupancy is exceeded” / “queue 

maximum occupancy”

Indefinite under 35 U.S.C. § 112(b), and/or lacks 

written description under 112(a).

’036 Claims 

7, 8, 9, 18, 

19, 20

“those packets associated with the 

destination address” / “those packets 

associated with only the destination 

address” / “those packets associated 

with the source and destination 

addresses”

Indefinite under 35 U.S.C. § 112(b)

’036 Claims 

1, 12, 23, 24

“end-node associated with the 

congestion condition”

Written description/enablement under 35 U.S.C. § 

112(a)

’240 Claims 

1, 6, 13

“verifying connectivity in the network 

relating to at least Layer-2 and Layer3 objects”

Indefinite under 35 U.S.C. § 112(b)

’240 Claims 

1, 6, 13

“a given containment hierarchy” Indefinite under 35 U.S.C. § 112(b)

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 12 of 18
12

’240 Claims 

1, 6, 13

“the comparison shows that at least 

one of the connectivity verification 

results has reached the specified 

connectivity verification threshold”

Lack of written description under 35 U.S.C. § 

112(a)

’240 Claims 

1, 6, 13

“the containment hierarchy affected 

by the connectivity verification result”

Lack of written description/enablement under 35 

U.S.C. § 112(a)

’240 Claims 

1, 6, 13

“define a connectivity verification 

job” / “defining a connectivity 

verification job”

Specifying connectivity verification parameters 

including the type and the number of connectivity 

verification tests to be performed

’240 Claims 

1, 6, 13

“the connectivity verification result[s] 

associated with the alarm”

Indefinite under 35 U.S.C. § 112(b)

’240 Claims 

1, 6, 10, 13

“user-input specification” Lack of written description / enablement under 35 

U.S.C. § 112(a)

’839 Claims 

1, 3, 6, 8, 11

“route” / “route-related information” Indefinite under 35 U.S.C. § 112(b).

’839 Claims 

1, 6, 11

“using time” Claim 6: Indefinite for lack of antecedent basis 

under 35 U.S.C. § 112(b).

“lease time”

’839 Claims 

1, 6

“said predefined using time 

indicates[ing] a [the] using time of 

said route”

Indefinite under 35 U.S.C. § 112(b).

’060 Claims 

1 and 10

“frequency domain component feature 

of the feature vector”

A group of a plurality of energy levels of the audio 

signal, wherein each of the plurality energy levels 

corresponds to the energy of an overlapping band of 

the audio signal; a value representing a centroid of 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 13 of 18
13

the frequency domain spectrum of the audio signal; 

and a value representing the degree of flatness of 

the frequency domain spectrum.

’060 Claims 

1 and 10

“extracting a feature vector” Indefinite under 35 U.S.C. § 112(b)

’060 Claims 

1 and 10

“time domain component feature of 

the feature vector”

A gradient index based on the sum of the gradient at 

points in the audio signal which result in a change in 

direction of the waveform of the audio signal; a 

ratio of the energy of a frame of the audio signal to 

the energy of a previous frame of the audio signal; 

and a voice activity detector indicating whether a 

frame of the audio signal is classified as active or 

inactive.

’060 Claims 

1 and 10

“the level value is attenuated” Indefinite under 35 U.S.C. § 112(b)

’060 Claims 

1 and 10

“approaches an estimate” Indefinite under 35 U.S.C. § 112(b)

’060 Claims 

1 and 10

“spectral shape parameter” A sub band energy level value or a sub band gain 

factor based on the sub band energy level value.

’905 Claims 

1, 6, 12, 18, 

25, and 26

“transmission opportunity” The interval of time when a particular station is 

permitted to initiate transmissions onto the wireless 

medium. 

IEEE Std 802.11-

2016 (Revision of 

IEEE Std 802.11-

2012)

Wireless 

Communication 

Standards: A Study 

of IEEE 802.11,

802.15, 802.16, 

p.356. Publisher: 

Wiley-IEEE 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 14 of 18
14

Standards 

Association

’905 Claims 

1, 6, 12, 18, 

25, and 26

“transmission period” The period of the transmission opportunity.

’905 Claims 

1, 12, 25

“determined transmission time 

interval”

The interval of the transmission opportunity.

’905 Claims 

5, 15

“during a time interval between data 

transmission intervals during the 

transmission period”

Indefinite under 35 U.S.C. § 112(b)

’905 Claims 

1, 12, 25

“determining to utilize a bandwidth 

greater than that of the first frequency 

band during the transmission period”

Indefinite under 35 U.S.C. § 112(b)

’905 Claims 

5, 16

“at least one frequency channel 

indicator”

Indefinite under 35 U.S.C. § 112(b)

’905 Claims 

9, 21

“causing the transmission of the 

reservation message on each 

frequency band separately”

Indefinite under 35 U.S.C. § 112(b)

’905 Claims 

11, 23

“timing and transmission frequency” Indefinite under 35 U.S.C. § 112(b)

’960 Claims 

1, 2, 3, 9, 10, 

15, 16, 17, 

23, and 24 

“virtual reference” A group of pixels used as reference material for 

encoding portions of the video signal, but that does 

not comprise or represent any portion of the actual 

video sequence to be displayed.

’960 Claims 

1, 9, 15, 23

“an original video signal” A video signal that includes a sequence of video 

frames and is to be encoded.

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 15 of 18
15

’960 Claims 

1, 9, 15, 23

“video frames” A sequence of frames. Wiley-IEEE 

Electrical and 

Electronics 

Engineering 

Dictionary

’960 Claims 

1, 9, 15, 23

“subsequent video display” Generating an encoded video signal from an 

original video signal, the encoded video signal for 

use in subsequent video display of the original video 

signal. 

’960 Claims 

1, 9, 15, 23

“does not represent any portion of any 

individual frame of the original video 

signal”

Data generated based on a portion of a video signal 

but not to be displayed with the video signal.

’960 Claims 

1, 15

“incorporating” / “incorporating said 

encoded virtual reference data” / 

“incorporating into the encoded video 

signal an indication” / “incorporating 

said encoded portions of said original 

video signal”

Forming an encoded dual block by including a 

block of encoded original video signal and a block 

of encoded virtual reference data

’960 Claims 

3, 17

“minimize differences” Indefinite under 35 U.S.C. § 112(b)

’071 Claims 

1, 9, 13, 14

“movement signalling” / “receiv[ing] 

movement signalling associated with 

the movement of the projector” / 

“corresponding movement signalling”

Indefinite under 35 U.S.C. § 112(b)

’071 Claim 9 “a movement sensor configured to 

detect movement of the apparatus 

and/or a projector”

Indefinite under 35 U.S.C. § 112(b)

’071 Claims 

1, 13, 14

“discriminate” / “discriminate a 

movement criterion” / “the processor 

Indefinite under 35 U.S.C. § 112(b)

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 16 of 18
16

is configured to discriminate a 

movement criterion”

’071 Claims 

1, 13, 14

“provide associated image data 

signalling to project associated image 

data”

Indefinite under 35 U.S.C. § 112(b)

’071 Claims 

1, 9, 13, 14

“the processor” / “wherein the 

processor is configured”

Indefinite under 35 U.S.C. § 112(b) 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 17 of 18
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DATED: February 26, 2021 Respectfully submitted,

/s/Lionel M. Lavenue 

Lionel M. Lavenue 

Virginia Bar No. 49,005

lionel.lavenue@finnegan.com 

FINNEGAN, HENDERSON, FARABOW, 

GARRETT & DUNNER, LLP

1875 Explorer Street, Suite 800

Reston, VA 20190

Phone: (571) 203-2700

Fax: (202) 408-4400

ATTORNEY FOR DEFENDANTS

CERTIFICATE OF SERVICE

I hereby certify that all counsel of record, who are deemed to have consented to

electronic service, are being served on February 26, 2021 with a copy of this document via

email.

/s/Lionel M. Lavenue 

Lionel M. Lavenue 

Case 6:20-cv-00487-ADA Document 69-4 Filed 04/09/21 Page 18 of 18