It is a common knowledge that one of the characteristic of the 774 patent is
based upon its very broad application ( Flash as Main Memory ).
In Doc303 , July , 2010 DM legal team very clearly
delineate usingRAM in flash memory as unique part of 774 patent specification with emphasizing
it in a simple diagram and paid major attention to the word " REMOVABLE "
Here i would like sincerely appreciate Mike - Silversurfergreat effort for his
outstanding job for clarification and meaning of patent 774.
Excerpts from Doc 303
The fundamental problem with Defendants’ argument is
that it is based on mis characterizations of the Applicant’s use of the phrase “main memory.” The
Applicant used main memory to refer to the memory for storing sound electrical signals that
have been received and processed (i.e., as another way of describing the “sole memory”
limitation to which the Applicant and Examiner reached agreement during the in-person
interview); not the RAM used for processing the audio signal.
Defendants that flash memory was used in lieu of RAM to process the audio data, the proposed
amendment would not have referred to “received processed sound electrical signal.” In short,
Defendants’ interpretation of “main memory” as RAM memory for processing data simply
cannot be reconciled with this written statement by the Examiner, and even if accepted,
Defendants’ argument creates a claim construction dispute within a claim construction dispute,
i.e., what does main memory mean in the context of the ‘774 Patent?
As
Defendants concede based on their proposed definition of “flash memory module,” the flash
memory module is “removable.” This is clearly the case based on the language in claims 1 and
19 that begins by describing a device for use with removable, interchangeable flash memory and
later describes the features of the flash memory that can be coupled to the socket that receives
the flash memory module. Accordingly, defining the flash memory module limitation as being
removable should be beyond dispute.
