A module is a storage device.
Finally, the ‘774 Patent makes clear that the flash memory “module” is referring to a
flash memory “storage device,” as opposed to the flash memory recording medium that is part of
the flash memory “module.” First, claims 1 and 19 of the ‘774 Patent use the terms “module”
and “recording mediums” separately. “Recording medium” is used in the preambles to describe
generally the type of memory to be used -- flash memory. By comparison, “module” is used in
the body of the claim to more specifically describe the memory storage device that stores the
received processed sound electrical signals. As required by the claims, the module is the only
removable memory storage device that receives for storage the processed sound electrical
signals, and is capable of retaining for storage digital information without the need for ongoing
power support. If the patentee had intended “module” to mean “recording medium” as
advocated by Defendants, they could have used identical language throughout Claims 1 and 19.
They did not.
Accordingly, one of ordinary skill in the art would understand module to mean a storage
device as proposed by e.Digital.
