Sorry to dredge this back up from the so far in the past, but it's what the current issue is all about. See especially Evidence 3, Fig 2.

As SS, Doni, and others have pointed out, some form of ROM or RAM (Microprocessor #21) is necessary to process the analog sound received from the Mic into digital format so that it can be saved and stored. Thus, whether ROM or RAM is used is irrelevant, as they are functionaly equivalent.

This microprocessor, be it ROM or RAM, digitizes and compresses the received sound so that it can be stored in the flash memory, which is the sole memory identified in the diagram. Yes, bot ROM and RAM are technically speaking, memory, but this patent does not not consider them as memory, but as processors. This is made clear, as Flash memory is the sole receiver of the received processed sound.

Clearly the processor cannot be considered memory in this specified sense, since it is doing the processing.

Hope I'm not flogging a dead horse here, but if we can get this basic point out there and keep repeating it while showing the diagram, we have an outstanding chance.

— Chuck