"Filesystem" ....preamble

2. If The Board Finds The Preamble Limiting, “File System” Should Be Accorded Its Plain And Ordinary Meaning.

Petitioners concede that “file system” is a term commonly used in the art. Yet, they nevertheless propose a narrow construction that has no bearing on the merits of their petition. Specifically, Petitioners argue that the patent owners disclaimed the use of a file allocation table (“FAT”), notwithstanding the fact that none of the prior art they cite makes any mention of FAT. Petitioners are simply trying to “back door” a claim construction to support its non-infringement position in the District Court where no such construction is needed to resolve this Petition.

Lots of other good strong stuff, but I laughed when reading this...

doni