Thanks Silver.
Finally , defendants argue that e.DIGITALS construction is unclear with respect to what memory is being tested, i.e.,the flash memory in the ROM.
The answer to the question is self - evident from the claim that states " A method of testing the integrity of memory on a removable flash memory
recording medium chip ".................... In light of this statement in the claim , one of ordinary skill in the art would clearly understand that the memory
integrity test is a test of flash memory not ROM.
Defendant argument is a red herring for the drawing attention away from the other deficiencies in their proposed construction.