Re Flash memory is the " SOLE MEMORY " & RAM
Likewise, it is clear that the Examiner understood Applicant’s references to main
memory as storage memory as evidenced by her statement in the Examiner Interview Summary:
“the flash memory is the sole memory to store the received processed sound electrical signal.”
(See Examiner Interview Summary Record dated July 17, 1995, attached as Exhibit B to Exh. 4
(Norris Decl.)). The Examiner’s statement conveys the understanding that the flash memory is
the sole memory that stores the already received and processed sound electrical signals; as
opposed to the sole memory for both processing and storage. If the Patent Examiner agreed with
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?
(Excerpts from Doc 303)
