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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

STINGRAY IP SOLUTIONS LLC,

Plaintiff,

v.

VIVINT, INC.,

Defendant.

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CASE NO. 2:23-cv-00503-JRG-RSP

JURY TRIAL DEMANDED

(Lead Case)

STINGRAY IP SOLUTIONS LLC

Plaintiff,

v.

LEEDARSON IOT TECHNOLOGY INC., 

and LEEDARSON LIGHTING CO. LTD.,

Defendants.

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CASE NO. 2:23-cv-00499-JRG-RSP

JURY TRIAL DEMANDED

(Member Case)

EXHIBIT A

PLAINTIFF’S CLAIM CONSTRUCTION CHART

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 1 of 10 PageID

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U.S. Patent No. 7,224,678

Claim Term Plaintiff’s 

Construction

Plaintiff’s Supporting 

Evidence

Defendants’ 

Construction

Claim 51: Preamble: 

“An intrusion detection 

method for a wireless 

local or metropolitan 

area network 

comprising a plurality 

of stations, the method 

comprising”

Preamble is not 

limiting; no 

construction 

necessary.

’678 patent at Abstract; 

1:8-10, 14-17, 47-57; 

2:35-4:8; 5:52-6:7; 

6:8-22, 32-44, 45-60; 

7:17-20, 34-35, 53-55; 

8:1-4, 12-16, 26-28, 

43-53, 62-67; 9:9-12, 

32-34, 41-44, 56-60; 

10:10-12, 19-22, 29-33, 

45-49, 54-67; 16:49-62 

(claim 51); Figs. 11-21.

Any additional 

evidence relied on by 

Defendants.

The preamble is 

limiting.

Claim 51: “generating an 

intrusion alert” 

Plain and ordinary 

meaning.

Alternatively, the 

term “intrusion 

alert” should be 

construed to mean 

“a notification 

indicating 

detection of an 

anomaly or 

abnormal event”

’678 patent at Abstract; 

2:35-4:8; 6:8-22, 32-

44, 45-60; 7:17-20, 34-

35, 53-55; 8:1-4, 12-

16, 26-28, 43-53, 62-

67; 9:9-12, 32-34, 41-

44, 56-60; 10:10-12, 

19-22, 29-33, 45-49; 

16:49-62 (claim 51); 

Figs. 11-21.

US Patent No. 

7,082,117 at Abstract; 

2:29-3:60; 5:65-6:9, 

19-47; 7:3-5; 7:6-33; 

7:41-33; 7:62-64; 8:5-

9, 18-20, 34-44, 52-55; 

8:65-9:1; 9:21-23, 30-

33, 45-48, 57-59; 10:9-

12, 19-22, 37-45.

Any additional 

evidence relied on by 

Defendants.

Generating a 

notification sent by 

the policing node(s) 

upon detecting an 

attempted intrusion

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 2 of 10 PageID

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U.S. Patent No. 7,440,572

Claim Term Plaintiff’s 

Construction

Plaintiff’s Supporting 

Evidence

Defendants’ 

Construction

Claim 1: Preamble: “A 

secure wireless local area 

network (LAN) device 

comprising”

Preamble is not 

limiting; no 

construction 

necessary.

’572 patent at Abstract; 

1:6-2:55; Figs. 1-13.

’126 patent at Abstract; 

1:7-2:3; 2:7-3:2; Figs. 

1-13.

Any additional 

evidence relied on by 

Defendants.

The preamble is 

limiting.

Claim 1: “cryptography 

circuit carried by said 

housing and connected to 

said MAC and said 

wireless transceiver for 

encrypting both address 

and data information for 

transmission by at least 

adding a plurality of 

encrypting bits to both 

the address and the data 

information, and for 

decrypting both the 

address and the data 

information upon 

reception.”

Plain and ordinary 

meaning.

’572 patent at Abstract; 

2:1-19; 2:27-39; 2:52-

56; 3:37-57; 4:14-31; 

5:20-6:55; 6:65-7:35; 

7:1-49; 7:50-64 (claim 

1); Figs. 1-13.

’126 patent at Abstract; 

2:11-3:2; 3:51-63; 

4:28-55; 6:52-67; 7:9-

44; Figs. 1-13.

Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “cryptography 

circuit...upon 

reception” and 

responding to 

Defendants’ 

indefiniteness 

position).

Any additional 

evidence relied on by 

Defendants.

Governed by Pre-AIA

35 U.S.C. 112 

Paragraph 6

Function: encrypting 

both address and data 

information for 

transmission by at 

least adding a 

plurality of

encrypting bits to 

both the address and 

the data information, 

and for decrypting 

both the address and 

the data information 

upon reception

Structure: Indefinite

for lack of 

corresponding 

structure.

Claim 1: “cryptography 

circuit”

Plain and ordinary 

meaning.

’572 patent at Abstract; 

2:1-19, 2:27-39, 2:52-

56; 3:37-57; 4:14-31; 

In the alternative, if 

the Court does not 

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 3 of 10 PageID

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Alternatively, 

“cryptography 

circuit” should be 

construed to mean 

“a circuit capable 

of performing 

cryptography.”

5:20-25; 5:42-6:55; 

6:65-7:35; 7:1-49; 

7:50-64 (claim 1); Figs. 

1-13.

’126 patent at Abstract; 

2:11-3:2; 3:51-63; 

4:12-55; 5:32-6:67; 

7:9-44; Figs. 1-13.

Any additional 

evidence relied on by 

Defendants.

find the above 

governed by Pre-AIA

35 U.S.C. 112 

Paragraph 6:

“Hardware employing 

an algorithm and a

cryptographic key and 

capable of encrypting 

and decrypting both 

address and data 

information for 

transmission”

Claim 1: “encrypting 

both address and data 

information for 

transmission by at least 

adding a plurality of 

encrypting bits to both 

the address and the data 

information”

Plain and ordinary 

meaning.

’572 Patent at Abstract; 

2:7-16, 2:26-35; 2:51-

55; 4:20-30; 5:31-52; 

6:13-17; 6:34-39; 7:12-

16; 7:50-64 (claim 1); 

8:44-56; 9:32-46; 

10:22-36; 11:1-12; 

12:9-13; Figs. 1, 2, 7, 

8. 

’572 File History at 

Nov. 15, 2007 

Remarks at pp. 15-18; 

Feb. 25, 2008, 

Office Action at pp. 2-

7; 

May 23, 2008, 

Remarks at pp. 6-17.

Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “encrypting both 

address and data 

information for 

transmission by at least 

adding a plurality of 

Indefinite

If not indefinite, it 

should be construed 

as:

“encrypting both 

MAC address and 

MAC data 

information by at 

least adding a 

plurality of 

encrypting bits to 

both the address and 

the data information”

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 4 of 10 PageID

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encrypting bits to both 

the address and the 

data information” and 

responding to 

Defendants’ 

construction and 

indefiniteness 

position).

Any additional 

evidence relied on by 

Defendants.

Claim 1: “decrypting 

both the address and the 

data information upon 

reception”

Plain and ordinary 

meaning.

’572 Patent at Abstract; 

2:7-16, 2:51-55; 4:20-

30; 5:31- 41; 6:13-17; 

6:34-39; 7:12-16; 7:50-

64 (claim 1); 8:44-56; 

9:32-46; 10:22- 36; 

11:1-12; 12:9-13; Figs. 

1, 2, 7, 8. 

’572 File History at 

Nov. 15, 2007 

Remarks at pp. 15- 18; 

Feb. 25, 2008, 

Office Action at pp. 2-

7; 

May 23, 2008, 

Remarks at pp. 6-17.

Any additional 

evidence relied on by 

Defendants.

“recovering, upon 

reception, both the 

MAC address and 

the MAC data 

information that was 

encrypted”

Claim 1: “medium 

access controller 

(MAC)/MAC”

Plain and ordinary 

meaning.

’572 patent at Abstract; 

2:1-7, 20-55; 4:14-19, 

31-42; 5:20-25; 6:29-

55; Figs. 7-10.

’126 patent at Abstract; 

2:38-43; 4:28-55; 6:52-

67; Figs. 7-10.

Indefinite

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 5 of 10 PageID

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Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “medium access 

controller 

(MAC)/MAC” and 

responding to 

Defendants’ 

construction and 

indefiniteness 

position).

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 6 of 10 PageID

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U.S. Patent No. 7,441,126 

Claim Term Plaintiff’s 

Proposed 

Construction

Plaintiff’s Supporting 

Evidence

Defendants’ 

Construction

Claim 1: Preamble “A 

secure wireless local 

area network (LAN) 

device comprising:”

Preamble is not 

limiting; no 

construction 

necessary.

’126 patent at Abstract; 

1:7-2:3; 2:7-3:2; Figs. 

1-13.

’572 patent at Abstract; 

1:6-2:55; Figs. 1-13.

Any additional 

evidence relied on by 

Defendants.

The preamble is 

limiting.

Claims 1: “a 

cryptography circuit 

carried by said housing 

and connected to said 

MAC and said wireless 

transceiver”

Plain and ordinary 

meaning.

Alternatively, 

“cryptography 

circuit” should be 

construed to mean 

“a circuit capable 

of performing 

cryptography.”

’126 patent at Abstract; 

2:11-3:2; 3:51-63; 

4:12-55; 5:32-6:67; 

7:9-44; Figs. 1-13.

’572 patent at Abstract; 

2:1-19; 2:27-39;

2:52-56; 3:37-57; 

4:14-31; 5:20-6:55; 

6:65-7:35; 7:1-49; 

7:50-64 (claim 1); 

Figs. 1-13.

Any additional 

evidence relied on by 

Defendants.

“Hardware 

employing an 

algorithm and a 

cryptographic key 

and capable of 

encrypting and 

decrypting both 

address and data 

information for 

transmission”

Claim 1: “media access 

controller (MAC) 

carried by said housing”

Plain and ordinary 

meaning.

’126 patent at Abstract; 

2:38-43; 4:27-55; 6:46-

67; Figs. 1-3, 7-10, 12, 

13; claims 1, 5-6, 11-

12.

’572 patent at Abstract; 

2:1-7, 20-55; 4:14-19, 

31-42; 5:20-25; 6:29-

55; Figs. 1-3, 7-10, 12, 

13, claims 1, 2, 8, 14, 

26, 38, 47

Indefinite

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Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “medium access 

controller 

(MAC)/MAC carried 

by said housing” and 

responding to 

Defendants’ 

construction and 

indefiniteness 

position).

Claim 4: “said security 

information”

“said cryptography 

information”

’126 patent at Abstract; 

1:50-59; 2:34-37; 4:34-

44; 6:11-29; 7:24-29; 

7:59-8:9 (claim 1); 

8:16-21 (claim 3-4); 

Figure 10.

Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “said security 

information” and 

responding to 

Defendants’ 

indefiniteness 

position).

Any additional 

evidence relied on by 

Defendants.

Indefinite

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 8 of 10 PageID

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U.S. Patent No. 7,616,961

Claim Term Plaintiff’s 

Construction

Plaintiff’s Supporting 

Evidence

Defendants’ 

Construction

Claim 1, Preamble: “A 

method for dynamic 

channel allocation in a 

mobile ad hoc network 

comprising a plurality of 

wireless mobile nodes 

and a plurality of 

wireless communication 

links connecting the 

plurality of wireless 

mobile nodes together 

over a plurality of 

separate channels at 

different frequencies, the 

method comprising:” 

Preamble is not 

limiting; no 

construction 

necessary.

’961 patent at 4:18-28; 

6:14-19; 13:37-50; 

15:25-47 (claim 1).

Any additional evidence 

relied on by 

Defendants.

The preamble is 

limiting.

Claim 1: “mobile ad hoc 

network” 

Preamble is not 

limiting; 

Preamble is not 

limiting;

Alternatively, if 

construed: “a 

network, including 

a number of 

geographicallydistributed 

potentially mobile 

nodes wirelessly 

connected by one 

or more radio 

frequency 

channels, which 

lacks fixed 

infrastructure such 

that the nodes must 

self-organize and 

reconfigure as they 

move, join, or 

leave the network”

’961 patent at Abstract; 

1:11-2:9; 2:22-31; 4:18-

28; 5:4-12; 5:19-23; 

6:14-19; 8:15-18; 8:56-

65; 10:5-9, 42-48; 

11:46-48; 13:33-50; 

14:41-45; 15:7-21; 

15:25-47 (claim 1); 

Figs. 1-4.

U.S. Patent No. 

7,082,117 at 1:13-26; 

5:37-41.

U.S. Patent No. 

6,961,310 at 1:11-55; 

5:1-20.

U.S. Patent No. 

7,027,426 at 1:22-45; 

4:4-5:2.

U.S. Patent No. 

6,958,986 at 1:65-67; 

2:1-4;2:15-19; 3:1-7.

“a network, 

including a number 

of geographicallydistributed mobile 

nodes wirelessly 

connected by one or 

more radio 

frequency channels, 

which lacks fixed 

infrastructure such 

that the nodes must 

self-organize and 

reconfigure as they 

move, join, or leave 

the network”

Case 2:23-cv-00503-JRG-RSP Document 51-1 Filed 11/15/24 Page 9 of 10 PageID

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Expert declaration of 

Mr. Patrick Kinney 

(providing testimony 

regarding the definite 

meaning to a person of 

ordinary skill in the art 

of “mobile ad hoc 

network” and 

responding to 

Defendants’ 

construction and 

indefiniteness position).

Any additional evidence 

relied on by 

Defendants.

Claim 1: “each node” Plain and ordinary 

meaning.

Abstract; 2:22-42; 2:56-

67; 3:1-44; 5:4-21; 

8:66-9:14; 10:64-11:8; 

13:33-14:40; 14:41-

15:14; 15:25-47 (claim 

1); Figs. 6-7; 15-18

“At each of the 

wireless mobile 

nodes in the mobile 

ad hoc network”

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