First of all, not everyone may have read what you refer to. Second it does address that issue.

<Respondents asserted that the expert report only provided conclusory assertions regarding infringement under the Respondents' and Staff's proposed construction of the claim terms. Respondents asserted that good cause existed to grant the motion based on their reliance and Complainants' expert's failure to address Respondents' and Staff's proposed constructions.>

What do you think the above is referring to?

The expert report lacked any basis for the conclusions that there is infringement under Respondents or Staff's construction of "entire." We know it is the "entire" construction from our argument against leave to file SD.

By not including infringement arguments beyond opinion for Respondents and Staffs constructions, the respondents are claiming there is no infringement under those constructions.

What is not clear?

Opty