Analysis of the Disputed Terms A.

The Preamble is Not Limiting Micron argues that the preamble is limiting. (Doc. No. 43 at 24.) Micron contends that “direct manipulation of contiguous and non-contiguous discrete data segments” islimiting because it appears only in the preamble and “directmanipulation” of data segments is a critical feature of the claim. (Id. at 25-26.) Additionally, Micron asserts that “file system” is limiting because the patentee disclaimed the use of a file allocation table (“FAT”) stored on the primary memory to access data in primary memory. (Id. at 26.) Further, Micron argues that “file system” is limiting because the preamble to the ’445 patent providesthe only basis for the term in several claims of the ’445 patent. (Id. at 26-27.) Plaintiff responds that claim 1 adequately describes “direct manipulation of contiguous and non-contiguous discrete data segments” and, therefore, the phrase merely summarizes the claim. (Doc. No. 45 at 7-8.) e.Digital maintains that “file system” is not limiting because the patentees did not disclaim the use of a FAT stored on the primary memory. (Id. at 8.) Further, e.Digital claims that use of “file system” 1 in the’445 patent’s preamble does not show that “file system” is limiting in the ’108 patent. (Id. at 8-9.) Ultimately, e.Digital contendsthat the limitations of claim 1 of the ’108 patent constitute a self-contained description of the invention. The Court agrees with Plaintiff. The body of claim 1 defines the requisite components of the claimed invention and is thus a self-contained description of the invention. See Symantec, 522 F.3d at - 8 - 13cv2907/13cv2944

• "The Court addresses Micron’s disclaimer argument in the sections construing the 1 terms “a logical link between the previous logical data segment and the new data segment” and “a path sequentially accessing the data segments within the primary memory.”

Without the preamble, the invention remains functionally complete. The preamble simply defines the intended use of the method that is described in the body of the claim. Catalina Mktg., 289 F.3d at 808 (“a preamble is not limiting ‘where a patentee defines a structurally complete invention in the claim body and uses the preamble only to state a purpose or intended use for the invention’”). Accordingly, the preamble of Claim 1 is not limiting.