Joint Claim Construction Statement Page | 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. 

GOOGLE LLC,

Defendant.

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CIVIL ACTION 6:20-cv-00571-ADA

CIVIL ACTION 6:20-cv-00572-ADA

CIVIL ACTION 6:20-cv-00573-ADA

CIVIL ACTION 6:20-cv-00574-ADA

CIVIL ACTION 6:20-cv-00575-ADA

CIVIL ACTION 6:20-cv-00576-ADA

CIVIL ACTION 6:20-cv-00577-ADA

CIVIL ACTION 6:20-cv-00578-ADA

CIVIL ACTION 6:20-cv-00579-ADA

CIVIL ACTION 6:20-cv-00580-ADA

CIVIL ACTION 6:20-cv-00581-ADA

CIVIL ACTION 6:20-cv-00582-ADA

CIVIL ACTION 6:20-cv-00583-ADA

CIVIL ACTION 6:20-cv-00584-ADA

CIVIL ACTION 6:20-cv-00585-ADA

JOINT CLAIM CONSTRUCTION STATEMENT

TO THE HONORABLE COURT:

Pursuant to the scheduling orders in these cases, the Parties joint submit this claim 

construction statement. 

I. Brief 1 (-571, -578, -583, and -584 Cases)

-571 Case, United States Patent No. 7,817,858

Neither party contends terms need to be construed

-578 Case, United States Patent No. 9,335,825 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“continuous wave doppler 

radar” (Claims 1 and 19)

(Proposed by Defendant)

Plain and ordinary meaning a Doppler radar that emits an 

uninterrupted electromagnetic 

signal

“at least one memory and the 

computer program code are 

configured, with the at least 

Plain and ordinary meaning; 

35 U.S.C. § 112, ¶6 does not 

apply

Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6.

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 1 of 15
Joint Claim Construction Statement Page | 2

-578 Case, United States Patent No. 9,335,825 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

one processor, to cause the 

apparatus to at least: detect

that an application is being 

started on the apparatus; in 

response to the application 

being started on the 

apparatus, turn on a 

continuous wave doppler 

radar at the apparatus” (Claim 

1)

(Proposed by Defendant)

Function: detect that an 

application is being started on 

the apparatus; in response to 

the application being started 

on the apparatus, turn on a 

continuous wave doppler 

radar at the apparatus

Structure: none; indefinite

-583 Case, United States Patent No. 7,777,728 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“tap direction” (Claims 1, 11, 

16)

(Proposed by Defendant)

Plain and ordinary meaning tap direction that extends 

between the first tap position 

and a second tap position

-584 Case, United States Patent No. 8,803,697 (Disputed)

Neither party contends terms need to be construed

II. Brief 4 (-572, -581, and -582 Cases)

-572 Case, United States Patent No. 8,041,806 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“communication traffic 

exchanged with a 

communication network 

subscriber over an access 

communication link”

(claims 1, 9, 10, 11, 14)

(Proposed by Defendant)

Plain and ordinary meaning the digital information 

traversing a network link 

between a communication 

network subscriber and an 

access network

“access network”

(claims 1, 7, 9, 10, 11, 14)

(Proposed by Defendant)

Plain and ordinary meaning a network that connects a 

communication network 

subscriber to their Internet 

Service Provider (ISP)”

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 2 of 15
Joint Claim Construction Statement Page | 3

-572 Case, United States Patent No. 8,041,806 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“a behavioral information 

collector operable to monitor 

communication traffic 

exchanged with a 

communication network 

subscriber over an access 

communication link”

(claims 1, 9, 10)

(Proposed by Defendant)

Plain and ordinary meaning Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6. 

Function: monitor 

communication traffic 

exchanged with a 

communication network 

subscriber over an access 

communication link

Structure: none; indefinite

“the behavioral information 

collector being configurable 

to collect from any of a 

plurality of types of 

communication traffic in the 

monitored communication 

traffic behavioral information 

indicative of behavior of the 

subscriber in using the access 

communication link”, “the 

behavioral information 

collector operable to . . . 

collect from the monitored 

communication traffic 

behavioral information 

indicative of behavior of the 

subscriber in using the access 

communication link”, and 

“the behavioral information 

collector being configurable 

to collect the behavioral 

information from any of a 

plurality of types of 

communication traffic in the 

monitored communication 

traffic”

(claims 1, 9, 10)

(Proposed by Defendant)

Plain and ordinary meaning Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6. 

Function: collect from any of 

a plurality of types of 

communication traffic in the 

monitored communication 

traffic behavioral information 

indicative of behavior of the 

subscriber in using the access 

communication link

Structure: none; indefinite

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 3 of 15
Joint Claim Construction Statement Page | 4

-581 Case, United States Patent No. 7,304,563 (Agreed)

Claim Term/Phrase Agreed Construction

“maintaining means for maintaining an 

indication of the current time”

(claim 16)

(Proposed by both Parties)

Term is subject to 35 U.S.C. § 112, ¶ 6

Function: maintaining an indication of the 

current time

Structure: a clock, and equivalents thereof. 

’563 patent, 1:49-51, 2:3-4, 3:29-31, 6:39

“storing means for storing in a memory a 

definition of an alert time”

(claim 16)

(Proposed by both Parties)

Term is subject to 35 U.S.C. § 112, ¶ 6

Function: storing in a memory a definition of 

an alert time

Structure: a processor, a memory, and 

equivalents thereof. ’563 patent, 1:51-52, 1:59-

61, 3:43-44, 3:58-60

“signaling means”

(claim 16)

Term is subject to 35 U.S.C. § 112, ¶ 6

Function: locally signal to the user

Structure: loudspeaker, and equivalents 

thereof. ’563 patent, 2:57-58, 4:4-8

-581 Case, United States Patent No. 7,304,563 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“alert”

(claims 1, 12, 16)

(Proposed by Defendant)

Plain and ordinary meaning instructions causing a 

communication terminal to 

perform an action

“alerting unit configured to 

issue an alert”

(claim 1)

(Proposed by Defendant)

Plain and ordinary meaning The recited function is 

identical to the means-plusfunction term in claim 16.

Section 112 ¶ 6 applies.

Function: issuing an alert

Structure: indefinite.

“signaling unit configured to 

locally signal to a user”

(claim 1)

(Proposed by Defendant)

Plain and ordinary meaning The recited function is 

identical to the means-plusfunction term in claim 16.

Section 112 ¶ 6 applies.

Function: locally signal to the 

user.

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 4 of 15
Joint Claim Construction Statement Page | 5

-581 Case, United States Patent No. 7,304,563 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

Structure: loudspeaker, and 

equivalents thereof. ’563 

patent, 2:57-58, 4:4-8

“initiating [a/the] connection 

to the other communication

terminal at a predetermined 

time offset from [signaling 

the user using the signaling 

unit/locally signaling the

users/signaling the user by 

the signaling means]”

(claims 1, 12, 16)

(Proposed by Defendant)

Plain and ordinary meaning initiating a link that allows 

direct communication 

between a mobile 

communication terminal and 

another predefined 

communication terminal at a 

time set apart by a predefined 

interval from the local signal

“the terminal”

(claim 12)

(Proposed by Defendant)

Plain and ordinary meaning Indefinite

“issuing means for issuing an 

alert”

(claim 16)

(Proposed by both Parties)

Function: issuing an alert

Structure: antenna, 

communication engine, and 

loudspeaker, and equivalents 

thereof

Function: issuing an alert

Structure: none; indefinite

-582 Case, United States Patent No. 8,238,681 (Agreed)

Claim Term/Phrase Agreed Construction

“means for executing an autofocus algorithm 

using the assigned focus value masks”

(Proposed by Defendant)

This term is subject to means-plus-function 

treatment under 35 U.S.C. § 112, ¶ 6. 

Function: executing an autofocus algorithm 

using the assigned focus value masks

Structure: See, e.g., 3:7-9; 10:18-22; 10:39-

51; 10:57-63; 11:58-12:3; 8:36-52; 11:41-55

“means for logically separating into a 

plurality of parts at least one sub-window of 

interest of a plurality of sub-windows of 

interest arranged in a grid formation in an 

autofocus window of interest”

(Proposed by Defendant)

This term is subject to means-plus-function 

treatment under 35 U.S.C. § 112, ¶ 6. 

Function: for logically separating into a 

plurality of parts at least one sub-window of 

interest of a plurality of sub-windows of 

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 5 of 15
Joint Claim Construction Statement Page | 6

-582 Case, United States Patent No. 8,238,681 (Agreed)

interest arranged in a grid formation in an 

autofocus window of interest

Structure: See, e.g., processor (3:7-9;10:18-

22; 10:39-51; 10:57-63; 11:58-12:3); 7:36-43; 

10:66-11:2.

-582 Case, United States Patent No. 8,238,681 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“autofocus algorithm” 

(Claims 1, 9, 16, and 24)

(Proposed by Defendant)

node(s) in an active state of 

AAA functionality

instructions to automatically 

adjust a lens to achieve focus

“second part in between the 

first part and the second part” 

(Claims 1, 9, 16, and 24)

(Proposed by Defendant)

Plain and ordinary meaning Indefinite

“means for assigning a focus 

value mask to each of the 

plurality of parts of the at 

least one sub-window” 

(Claim 24)

(Proposed by Defendant)

This term is subject to meansplus-function treatment under 

35 U.S.C. § 112, ¶ 6. 

Function: assigning a focus 

value mask to each of the 

plurality of parts of the at 

least one sub-window

Structure: See, e.g., 

processor (3:7-9; 10:18-22; 

10:39-51; 10:57-63; 11:58-

12:3); 5:10-13; FIG. 3; 8:36-

52; 11:2-4.

This term is subject to meansplus-function treatment under 

35 U.S.C. § 112, ¶ 6. 

Function: assigning a focus 

value mask to each of the 

plurality of parts of the at 

least one sub-window

Structure: none; indefinite 

“a processor configured to ...” 

(Claim 16)

(Proposed by Defendant)

Plain and ordinary meaning The recited functions are 

identical to the means-plusfunction terms in claim 24, 

and thus the only issue is 

whether this term invokes 

Section 112, ¶6

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 6 of 15
Joint Claim Construction Statement Page | 7

III. Brief 3 (-573, -575, -577 and -585 Cases)

-573 Case, United States Patent No. 7,620,967 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“broadcast” / “broadcasting”

(claims 1, 7)

(Proposed by Defendant)

Plain and ordinary meaning Simultaneously 

transmit/transmitting to all 

receivers in a network

-575 Case, United States Patent No. 8,559,928 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“contact information”

(claims 1, 15, 23)

(Proposed by Defendant)

Plain and ordinary meaning Information related to the 

identity of and 

communication with an entity

“tree structure”

(claims 1, 15, 23)

(Proposed by Defendant)

Plain and ordinary meaning A non-linear data structure 

consisting of an ordered set of 

linked nodes in a connected 

graph with a unique root node 

which is not a descendent of 

any other node, and in which 

each non-root node has at 

most one parent node, zero or 

more children nodes, and a 

unique hierarchy value

-577 Case, United States Patent No. 8,751,585 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“a list of actions” and “a 

plurality of actions”

(claims 1, 9, 17)

(Proposed by Defendant)

Plain and ordinary meaning a finite number of selectable 

items each corresponding to 

an executable function

“moving the selected 

electronic message from the 

inbox to the archive location 

after detection of the action 

defined in the archiving rule” 

(claim 1), “to move the 

selected electronic message

from the inbox to the archive 

location after detection of the 

action defined in the 

Plain and ordinary meaning moving the selected 

electronic message from the 

inbox to a different location

in memory corresponding to

the previously defined

archive location after the 

communication system

detects the action defined in

the archiving rule / 

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 7 of 15
Joint Claim Construction Statement Page | 8

-577 Case, United States Patent No. 8,751,585 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

archiving rule” (claim 9), and 

“moving the first electronic 

message from the inbox of 

the electronic mail client 

associated with the user to the 

first storage location 

associated with the first 

archiving rule after the first 

action specified in the first 

archiving rule is detected” 

(claims 1, 9, 17)

(Proposed by Defendant)

to move the selected 

electronic message from the 

inbox to a different location 

in memory corresponding to 

the previously defined 

archive location after the 

communication system 

detects the action defined in 

the archiving rule /

moving the first selected 

electronic message from the 

inbox from the inbox to a 

different location in memory 

corresponding to the 

previously defined first 

storage location after the 

communication system 

detects the action specified in 

the first archiving rule

“client management 

processor configured to 

enable the user to select an 

electronic message from the 

inbox” (claim 9)

(Proposed by Defendant)

Not means-plus-function.

But if Section 112, ¶ 6 

applies, then function is 

agreed and structure is 

message client 2

Section 112, ¶ 6 applies; 

function: to enable

the user to select an electronic 

message from

the inbox; structure: 

indefinite.

“a detection processor 

configured to detect the 

action defined in the 

archiving rule assigned to the 

selected electronic message 

was carried out” (claim 9)

(Proposed by Defendant)

Not means-plus-function.

But if Section 112, ¶ 6 

applies, then function is 

agreed and structure is 

agent(s) 114a-114d

Section 112, ¶ 6 applies; 

function: to detect the

action defined in the 

archiving rule assigned to

the selected electronic 

message was carried

out; structure: indefinite

“a collaborative application 

management processor 

configured to manage 

collaborative applications” 

(claim 9)

(Proposed by Defendant)

Not means-plus-function.

But if Section 112, ¶ 6 

applies, then function

is agreed and structure is 

databases 107, 108,

109, database 110, databases 

111, 112.

Section 112, ¶ 6 applies; 

function to manage 

collaborative applications; 

structure: indefinite.

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 8 of 15
Joint Claim Construction Statement Page | 9

-585 Case, United States Patent No. 8,737,961 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“stationary state” (claims 1 

and 11)

(Proposed by Defendant)

Plain and ordinary meaning Indefinite

“incrementing [of] a count[er] 

for a stationary state” (claims 

1 and 11)

(Proposed by Defendant)

Plain and ordinary meaning incrementing a count 

representing time at a 

stationary state

“determin[e/ing] a primary 

set of stationary states”

(claims 1 and 11)

(Proposed by Defendant)

Plain and ordinary meaning Indefinite

IV. Brief 2 (-574, -576, -579, and -580 cases)

-574 Case, United States Patent No. 8,965,045 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“a pre-emptive user output”

(all claims)

(Proposed by Defendant)

Plain and ordinary meaning an output that facilitates a 

user action to redefine 

available pixels before the 

tracked object is lost

“said processor configured to 

provide a pre-emptive user 

output when the sub-set of 

pixels approaches an edge of 

the set of available pixels”

(claim 1)

(Proposed by Defendant)

Plain and ordinary 

meaning; does not invoke 

35 U.S.C. § 112, ¶ 6; definite

Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6. 

Function: provide a preemptive user output when the 

sub-set of pixels approaches 

an edge of the set of available 

pixels.

Structure: none; indefinite.

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 9 of 15
Joint Claim Construction Statement Page | 10

-576 Case, United States Patent No. 8,595,283 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“a content transfer controller 

configured to determine an 

acceptable activity period by 

monitoring usage of the one 

or more components over a 

particular time duration, and 

wherein the content transfer 

controller is configured to 

determine that an acceptable 

activity period is present 

when the usage of the one or 

more components is 

determined to have been 

below a particular threshold 

level over the particular time 

duration”

(claim 1)

(Proposed by Defendant)

Plain and ordinary meaning Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6. 

Function: determine an 

acceptable activity period by 

monitoring usage of the one 

or more components over a 

particular time duration, and 

determine that an acceptable 

activity period is present 

when the usage of the one or 

more components is 

determined to have been 

below a particular threshold 

level over the particular time 

duration

Structure: none; indefinite

“the content transfer 

controller being arranged: to 

initiate transfer of the 

selected item of content from 

a content provider device 

according to the 

determination of an 

acceptable activity period, to 

receive the selected item of 

content, and to store the 

received item of content on 

memory”

(claim 1)

(Proposed by Defendant)

Plain and ordinary meaning Subject to means-plusfunction treatment under 35 

U.S.C. § 112, ¶ 6. 

Function: initiate transfer of 

the selected item of content 

from a content provider 

device according to the 

determination of an 

acceptable activity period, 

receive the selected item of 

content, and store the 

received item of content on 

memory 

Structure: none (indefinite

“the selected item of content”

(claims 1, 2, 3, 10, 21)

(Proposed by Defendant)

Plain and ordinary meaning the item of content selected 

for transfer by the user via the 

user interface

“an acceptable level of device 

activity”

(claim 21)

Plain and ordinary meaning Indefinite

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 10 of 15
Joint Claim Construction Statement Page | 11

-576 Case, United States Patent No. 8,595,283 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

(Proposed by Defendant)

“monitoring usage of one or 

more components ...over a 

particular time duration”

(claims 1, 10)

(Proposed by Defendant)

Plain and ordinary meaning monitoring the use of one or 

more components . . . 

throughout a limited, noninstantaneous period of time

-579 Case, United States Patent No. 8,640,180 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“client-side compositing of 

media streams”

(all claims)

(Proposed by Defendant)

Plain and ordinary meaning; 

preamble is not limiting

Preamble is limiting

“wherein the compositinginstruction substream 

indicating the area of the 

display screen to display the 

at least one media substream

is an area to display one of 

the on screen display and a 

picture-in-picture”

(claims 8, 21)

(Proposed by Defendant)

Plain and ordinary meaning Indefinite

-580 Case, United States Patent No. 7,946,491 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“the input image” (claims 1, 

13, 25, and 41)

(Proposed by Defendant)

Plain and ordinary meaning the original input image

“performing a correction on 

the input image” (claims 1, 

13, 25, and 41)

Plain and ordinary meaning correcting the content of the 

original input image

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 11 of 15
Joint Claim Construction Statement Page | 12

-580 Case, United States Patent No. 7,946,491 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

(Proposed by Defendant)

“new frame” (claims 1, 13, 

25, and 41)

(Proposed by Defendant)

Plain and ordinary meaning; 

definite

Indefinite

“computer program product 

comprising at least one 

computer-readable storage 

medium having computerreadable program code

portions stored therein, the 

computer-readable program 

code portions comprising ...

a 

first/second/third/fourth/fifth 

executable portion for . . .” 

(claim 13)

(Proposed by Defendant)

plain and ordinary meaning; 

does not invoke 35 U.S.C. § 

112, ¶ 6; definite.

the recited functions are 

identical to the means-plusfunction terms in claim 41, 

thus the only issue is whether 

this term invokes Section 

112, ¶ 6.

“apparatus comprising a 

processor and memory 

including computer program 

code, the memory and the 

computer program code 

configured to, with the 

processor, cause the 

apparatus at least to . . .” 

(claim 25)

(Proposed by Defendant)

plain and ordinary meaning; 

does not invoke 35 U.S.C. § 

112, ¶ 6; definite.

the recited functions are 

identical to the means-plusfunction terms in claim 41, 

thus the only issue is whether 

this term invokes Section 

112, ¶ 6.

“means for processing an 

input image for an attempt to 

decode the input image using 

a current barcode reading 

method, the processing 

including performing a 

correction on the input 

image” (claim 41)

(Proposed by both Parties)

Function: processing an 

input image for an attempt to 

decode the input image using 

a current barcode reading 

method.

Structure: barcode reading 

element 70, processing 

element 72, operation 200

Function: processing an 

input image for an attempt to 

decode the input image using 

a current barcode reading 

method, the processing 

including performing a 

correction on the input image

Structure: 9:58 to 11:23, 

15:25 to 16:52.

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 12 of 15
Joint Claim Construction Statement Page | 13

-580 Case, United States Patent No. 7,946,491 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

“means for determining

whether the processing of the 

input image is successful 

based on a determination as 

to whether the correction is 

completed” (claim 41)

(Proposed by both Parties)

Function: determining 

whether the processing of the 

input image is successful 

based on a determination as 

to whether the correction is 

completed

Structure: processing 

element 72, operations 210-

230

Function: determining 

whether the processing of the 

input image is successful 

based on a determination as 

to whether the correction is 

completed

Structure: none; indefinite 

“means for switching to one 

of a different barcode reading 

method or processing a new 

frame of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being unsuccessful” 

(claim 41)

(Proposed by both Parties)

Function: switching to one of 

a different barcode reading 

method or processing a new 

frame of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being unsuccessful

Structure: processing 

element 72, operations 260-

270

Function: switching to one of 

a different barcode reading 

method or processing a new 

frame of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being unsuccessful

Structure: none; indefinite 

“means for attempting a 

decode of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being successful” 

(claim 41)

(Proposed by both Parties)

Function: attempting a 

decode of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being successful”

Structure: barcode reading 

element 70, processing

element 72, operations 220, 

270

Function: “attempting a 

decode of the input image 

using the current barcode 

reading method in response to 

the processing of the input 

image being successful”

Structure: none; indefinite 

“means for performing a 

switch to the different 

barcode reading method in 

response to a failure of the 

attempt to decode the input 

image using the current 

Function: performing a 

switch to the different 

barcode reading method in 

response to a failure of the 

attempt to decode the input 

Function: performing a 

switch to the different 

barcode reading method in 

response to a failure of the 

attempt to decode the input 

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 13 of 15
Joint Claim Construction Statement Page | 14

-580 Case, United States Patent No. 7,946,491 (Disputed)

Claim Term/Phrase Plaintiff’s Construction Defendant’s Construction

barcode reading method” 

(claim 41)

(Proposed by both Parties)

image using the current 

barcode reading method

Structure: barcode reading 

element 70, processing 

element 72, operations 230, 

270

image using the current 

barcode reading method

Structure: none; indefinite 

Date: March 15, 2020 Respectfully submitted,

By: /s/ James L. Etheridge

James L. Etheridge 

Texas Bar No. 24059147 

Ryan S. Loveless 

Texas Bar No. 24036997 

Brett A. Mangrum 

Texas Bar No. 24065671 

Travis L. Richins 

Texas Bar No. 24061296 

Jeff Huang 

Etheridge Law Group, PLLC 

2600 E. Southlake Blvd., Suite 120 / 324 

Southlake, TX 76092 

Tel.: (817) 470-7249 

Fax: (817) 887-5950 

Jim@EtheridgeLaw.com 

Ryan@EtheridgeLaw.com 

Brett@EtheridgeLaw.com 

Travis@EtheridgeLaw.com 

Jeff@EtheridgeLaw.com 

Mark D. Siegmund

State Bar No. 24117055

mark@waltfairpllc.com

Law Firm of Walt, Fair PLLC.

1508 North Valley Mills Drive 

Waco, Texas 76710

Telephone: (254) 772-6400

Facsimile: (254) 772-6432

Counsel for Plaintiff WSOU Investments, LLC

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 14 of 15
Joint Claim Construction Statement Page | 15

/s/ Michael E. Jones 

Michael E. Jones (Texas Bar No. 10929400)

Patrick C. Clutter (Texas Bar No. 24036374)

Potter Minton, P.C.

110 North College, Suite 500

Tyler, Texas, 75702

+1 (903) 597-8311

+1 (903) 593-0846 facsimile

mikejones@potterminton.com

patrickclutter@potterminton.com

Tharan Gregory Lanier (pro hac vice)

Jones Day

1755 Embarcadero Road

Palo Alto, California, 94303

+1 (650) 739-3939

+1 (650) 739-3900 facsimile

tglanier@jonesday.com 

Matthew S. Warren (pro hac vice)

Jen Kash (pro hac vice)

Warren Lex LLP

2261 Market Street, No. 606

San Francisco, California, 94114

+1 (415) 895-2940

+1 (415) 895-2964 facsimile

matt@warrenlex.com

jen@warrenlex.com

Attorneys for Defendant Google LLC

Case 6:20-cv-00572-ADA Document 38 Filed 03/15/21 Page 15 of 15