Instead, Samsung’s argument
focuses on the other accused products for which the Zoran processor was incorrectly identified.
In fact, the 17 asserted claims do not require any specific processor (no less a Zoran
COACH processor, TI processor, Fujitsu processor or any other manufacturer’s processor) and
only mention the word “processor” once -- “control circuitry includes a Digital Support
Processor (DSP).” (See U.S. Patent No. 5,491,774 (the “‘774 Patent”) at claim 11). The specific
brand of processor used in the accused products is simply not relevant to the claims or e.Digital’s
theory of infringement.
e.Digitals initial contribution pointed to the Zoran entity, Samsung is now trying to pigion hole that entity only, noting deficiencies in e.Digitals initial contentions.
The next move...wait for a ruling on the Zoran issue....and how the patent reads.
Samsung’s Motion should be denied to the extent that it is contrary to the relief to which
e.Digital consented at the March 4 meet-and-confer as provided in e.Digital’s proposed order.
doni
