<The SM clearly stated, the IC's didnt conform to local rules. for one! Then how could they have a markman based on that?>

As long we are still saying DDP1101 infringes on this or that claim, what difference does it make with respect to which claims need to be construed? You appear to be insisting that we changed the infringing part of the product or the claims that are infringed on. Perhaps you are correct. I just don't think so.

<The documents were supeonaed after the Markman, therefore they were relevant to IC's for TPL...how could the markman be complete?>

Yes, clearly the Seagate input was relevant to our IC reply. But we should have had that input prior to our responding with the amended ICs. But again, I think it simply either proved or disproved the validity of our theory of infringement. I don't think we would have been allowed to put forth some totally new theory and infringing part as a result of that input.

<The Judge and SM clearly stated, all the Info that TPL gave about its IC's was not sufficient! How can they have a markman ruling based on that?>

Because I do not believe we are changing any theory or infringing parts or which claims are being infringed, only the presentation of the theory. But just my opinion.

Opty