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MR. KEVILLE: In the first tier of importance we have
the flash memory term and the sole memory of the received
processed sound electrical signals.
And in the second patent, the '737 patent, the
activating memory integrity test term. Those would be what we
call the tier 1 terms.
The tier 2 terms would be the record/playback device
term. The memory control circuitry term. The switch means
term. And that's it for the second tier.
And in the third tier, the write protect circuitry
term. And the term interchangeable.
THE COURT: Thank you.
MR. KEVILLE: You're welcome.
MR. JAMESON: Your Honor, may I make one clarifying
comment?
THE COURT: Sure.
MR. JAMESON: We basically agree with what Mr. Keville
just presented to the Court with just one clarifying comment
that with respect to that sole memory term that's in tier 1.
THE COURT: Uh-huh.
MR. JAMESON: e.Digital has proposed that the entire
flash memory module phrase be construed as a single phrase.
They broke it into component parts.
THE COURT: I understand that.
MR. JAMESON: Thank you.
THE COURT: Thank you.
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