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template the user wants to use to process the detected social signature. This is not a “circular
definition” as argued by Dropcam.
Dropcam appears to equate the term “error” as used in the Nunchi patents with
“mistake.” It argues that “the presence of an error within the social signature merely prompts an
analysis of the accuracy of the social template.” (Dropcam Responsive Brief at 25:8-11.) First,
the training claims and embodiments do not speak in terms of errors within the social signature.
An “error” merely refers to a social signature value outside the range assigned to the social
template. (See, e.g., Ex. E at claim 15; Ex. A at 17:15-43; 18:63-19:58.) This is not a mistake
and Dropcam’s proposed construction is therefore unduly narrow.
In the context of the “baby sleeping” embodiment, the specification states, “where the
social signature indicates that the baby is now awake and crying, the social template would be
changed to allow information on the new status of the baby, but likely maintain a do-not-disturb
social template.” (Ex. A at 17:57-61.) This, along with the other embodiments cited in the
Opening Brief, do not support a conclusion that a social template necessarily contains any sort of
error or mistake. At best, they merely suggest that the user wants to change how the social
signature is processed. e.Digital’s proposed construction embodies this concept and should be
adopted by the Court.
Dropcam further argues, “At no point do the claims or the specification state that the
‘determined social template,’ whether ‘accurate’ or ‘not accurate,’ must prevent the social
template from being processed.” (Dropcam Responsive Brief at 25:20-27.) However, this is not
e.Digital’s proposed construction. “Capable of desired processing” does not mean that a social
template cannot be processed; as the training embodiments make clear, it simply means that the
template is not be processed in the manner desired by the user.
II. CONCLUSION
Based on the foregoing, e.Digital respectfully requests that Dropcam’s proposed
constructions be rejected and that the Court adopt e.Digital’s proposed constructions as set forth
above.
definition” as argued by Dropcam.
Dropcam appears to equate the term “error” as used in the Nunchi patents with
“mistake.” It argues that “the presence of an error within the social signature merely prompts an
analysis of the accuracy of the social template.” (Dropcam Responsive Brief at 25:8-11.) First,
the training claims and embodiments do not speak in terms of errors within the social signature.
An “error” merely refers to a social signature value outside the range assigned to the social
template. (See, e.g., Ex. E at claim 15; Ex. A at 17:15-43; 18:63-19:58.) This is not a mistake
and Dropcam’s proposed construction is therefore unduly narrow.
In the context of the “baby sleeping” embodiment, the specification states, “where the
social signature indicates that the baby is now awake and crying, the social template would be
changed to allow information on the new status of the baby, but likely maintain a do-not-disturb
social template.” (Ex. A at 17:57-61.) This, along with the other embodiments cited in the
Opening Brief, do not support a conclusion that a social template necessarily contains any sort of
error or mistake. At best, they merely suggest that the user wants to change how the social
signature is processed. e.Digital’s proposed construction embodies this concept and should be
adopted by the Court.
Dropcam further argues, “At no point do the claims or the specification state that the
‘determined social template,’ whether ‘accurate’ or ‘not accurate,’ must prevent the social
template from being processed.” (Dropcam Responsive Brief at 25:20-27.) However, this is not
e.Digital’s proposed construction. “Capable of desired processing” does not mean that a social
template cannot be processed; as the training embodiments make clear, it simply means that the
template is not be processed in the manner desired by the user.
II. CONCLUSION
Based on the foregoing, e.Digital respectfully requests that Dropcam’s proposed
constructions be rejected and that the Court adopt e.Digital’s proposed constructions as set forth
above.
Respectfully submitted.
HANDAL & ASSOCIATES
Dated: July 1, 2015 By: /s/ Gabriel G. Hedrick
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
HANDAL & ASSOCIATES
Dated: July 1, 2015 By: /s/ Gabriel G. Hedrick
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
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