Handal.."Another difficulty we have with the proposed construction, Dropcam's proposed construction is they are relying on the sensor data to be indicative of a type of activity. And we firmly deny that the sensor data needs to be indicative of a type of activity. That's an importation of a limitation that would be inappropriate in this setting because the specifications are replete with examples where the sensor data doesn't indicate anything about activity.

Sensor data is raw or processed data from the sensors until it's classified. Until it's used in the system, the system doesn't know what that -- what that social signature is. So it would be inappropriate to append to the construction of the term "social signature" indicative of a type of activity.

And this is Claim 15, a dependent claim of the '522 patent. And in this particular claim, the sensor data is used to determine the status of the communication device, not activity. So the proposed construction -- Dropcam's proposed construction would be wholly inconsistent with this claim of the '522 patent.

And that's our position."

doni