[00:00:00] Speaker 04:
Next case is the obverse of the first Samsung Netflix list, 2025-13-78.

[00:00:09] Speaker 04:
Mr. Haslund, have you been seated?

[00:00:18] Speaker 01:
Thank you, and may it please the court.

[00:00:20] Speaker 01:
This appeal is a different animal.

[00:00:21] Speaker 01:
This is claim construction with de novo review.

[00:00:24] Speaker 01:
And there are three key reasons why the board got the claim construction wrong.

[00:00:28] Speaker 01:
First of all, the board disregarded the ordinary meaning of corresponding to a broad term that the board transmuted to is in or is on, depending on where in their opinion you look.

[00:00:42] Speaker 01:
The claim language said a data path corresponding to.

[00:00:47] Speaker 01:
each data signal line.

[00:00:49] Speaker 01:
The board said the data path is in the data signal line or is on the data signal line.

[00:00:57] Speaker 01:
That is not the ordinary meaning of corresponding to, as this court has recognized in other decisions.

[00:01:02] Speaker 02:
When you look at the entire phrase that follows corresponding to, it's corresponding to each data signal time in the respective data strobe signal lines.

[00:01:13] Speaker 02:
Isn't that explicitly singles out a data signal line from data strobe signal lines?

[00:01:21] Speaker 02:
So I'm not clear on why I understand what was wrong with the board's construction of the term.

[00:01:27] Speaker 02:
Corresponding doesn't exist in isolation.

[00:01:31] Speaker 02:
It exists with respect to what follows in the sentence.

[00:01:35] Speaker 01:
And Your Honor, we don't disagree that it has to correspond to each data signal line.

[00:01:40] Speaker 01:
If we look at figure three of the patent, Your Honor, it actually gives you a good view of what's going on there.

[00:01:47] Speaker 01:
And the figure three of the patent would be in the appendix, and that would be at page, oh, there's a lot of figure twos.

[00:01:57] Speaker 01:
It's at page 87 in the appendix, Your Honor.

[00:02:01] Speaker 01:
So if you look at figure three,

[00:02:03] Speaker 01:
You'll see that there's a group of data signal lines.

[00:02:09] Speaker 01:
So I'm looking at the left side of the figure.

[00:02:12] Speaker 01:
You'll see the DQ, DQ0, DQ1, all the way down to a DQ.

[00:02:17] Speaker 01:
And there's a group of them.

[00:02:18] Speaker 01:
And they're shown by approximation.

[00:02:21] Speaker 01:
When it says a data path corresponding to each, it's referring to the fact that there's a group.

[00:02:28] Speaker 01:
It's not a single data signal line operating by itself.

[00:02:32] Speaker 01:
There's a group of data signal lines and a corresponding data strobe line, shown below them, S324.

[00:02:39] Speaker 01:
So corresponding to each is telling us that this is a data path that is functionally related to this group.

[00:02:47] Speaker 01:
If we move to claim 10, we then see that a data path doesn't just hold data signals.

[00:02:55] Speaker 01:
Claim 10 expressly says that you can have a data path that holds a data strobe signal.

[00:03:01] Speaker 01:
And it's a data strobe signal associated with a memory operation.

[00:03:06] Speaker 01:
And that's important because Claim 2 says that the signal, so it's referring to Claim 1.

[00:03:13] Speaker 01:
Claim 2 also a dependent claim.

[00:03:15] Speaker 01:
The signal in Claim 1 is a signal associated with a second memory operation.

[00:03:23] Speaker 01:
So the signal, claim two, that's narrower than claim one, because it's a dependent claim, captures the signals associated with the second memory operation, which we know from claim 10 includes the strode signal.

[00:03:37] Speaker 01:
So when you look at the claims as a whole, there's no question that the datapath should at least be able to handle data strode signals, and the board not only disregarded

[00:03:48] Speaker 01:
the possibility that it would handle data strobe signals, the board actually said that the data path had to be in the data signal line, which frankly makes no sense in this claim, because the claim has the data path in the buffer, and the buffer is recited to be between the data signal lines and the memory modules, which means it's separate from the data signal lines.

[00:04:11] Speaker 01:
But the board said, no, no, it's inside the data signal line.

[00:04:16] Speaker 01:
So there's no way for the board's construction to work in the structure of this claim.

[00:04:21] Speaker 01:
And certainly, when you look at the dependent claims, there's no way for the construction to work with what the data path is supposed to do.

[00:04:30] Speaker 01:
Because element 1F of claim one says the data path includes a delay circuit that delays a signal.

[00:04:40] Speaker 01:
And then, as I pointed out, claims 2 and 10 tell you that signal doesn't have to be the data signal.

[00:04:45] Speaker 01:
If they had wanted to, they could have written a claim that said a data signal path.

[00:04:49] Speaker 02:
Well, I think one of Netflix's response to your claim 10 argument is that the strobe signal carrying data path in claim 10 is an additional data path, not the one referenced in claim 1.

[00:05:03] Speaker 02:
And that seems to me like a perfectly reasonable reading of those two claims.

[00:05:08] Speaker 01:
But they're not taking into account claim 2, Your Honor.

[00:05:10] Speaker 01:
If you look, claim two is dependent on claim one, it refers to the signal.

[00:05:14] Speaker 01:
So it's talking about the signal in claim one that's on that datapath, right?

[00:05:18] Speaker 01:
The claim one datapath.

[00:05:20] Speaker 01:
And it says the signal is a signal associated with the second memory operation, right?

[00:05:26] Speaker 01:
So that's a kind of a broad, it's not really a marcoosh group, right?

[00:05:29] Speaker 01:
But it's a group of signals.

[00:05:31] Speaker 01:
Claim 10 tells us the strobe signal is a signal associated with the second memory operation.

[00:05:37] Speaker 01:
Expressly says that.

[00:05:39] Speaker 01:
So if you read claim one as having an unnamed negative limitation of no stroke signals, then claim two would make no sense, because claim two is dependent.

[00:05:50] Speaker 01:
It's supposed to narrow claim one.

[00:05:51] Speaker 02:
Well, first of all, let me be clear.

[00:05:52] Speaker 02:
Nobody's saying there's no negative limitation.

[00:05:55] Speaker 02:
The board was reading the language in claim one corresponding to, et cetera.

[00:06:01] Speaker 02:
They were saying that's what it covers, not that it disassociates itself from the stroke.

[00:06:07] Speaker 02:
Well, respectively, they're- Which I think is a fair reading, but I'm listening to what you're saying.

[00:06:12] Speaker 01:
I appreciate that, Your Honor.

[00:06:15] Speaker 01:
On various occasions, quite a few, the board expressly says that their construction is no strobe signals.

[00:06:24] Speaker 01:
They say that.

[00:06:25] Speaker 01:
When they're applying the claim, I'll point you to, I believe it's on page 40 of the opinion.

[00:06:30] Speaker 02:
Well, no strobe signals, because it's another way of saying corresponding to something other than strobe signals.

[00:06:36] Speaker 02:
That doesn't compel a negative limitation.

[00:06:40] Speaker 02:
I'm not understanding this negative limitation.

[00:06:42] Speaker 01:
Your Honor, under this court's law, corresponding to is a broad term.

[00:06:46] Speaker 01:
It's not equivalent to.

[00:06:47] Speaker 02:
Yeah, but it's read in the context of the words that follow it.

[00:06:50] Speaker 01:
That's right.

[00:06:51] Speaker 01:
So it needs to correspond to the data signal line.

[00:06:55] Speaker 01:
The patent specification shows the data signal lines and the strobe corresponding to each other.

[00:07:01] Speaker 01:
They work together in this circuit.

[00:07:04] Speaker 01:
So that data strobe signal corresponds to that data signal line.

[00:07:09] Speaker 01:
It means nothing by itself, right?

[00:07:11] Speaker 01:
It's the strobe signal that tells you when to sample the signals on the data signal line.

[00:07:18] Speaker 01:
So it corresponds to those signals on the data signal line.

[00:07:21] Speaker 01:
The strobe signal by itself does you no good.

[00:07:24] Speaker 01:
If it doesn't correspond, it wouldn't have any function in the memory circuit whatsoever.

[00:07:29] Speaker 01:
And that's why the data path that corresponds carries a strobe signal, because that strobe signal corresponds to the memory signal.

[00:07:38] Speaker 01:
So when my memory signal, say it goes high to show what's in my memory cell, the strobe signal tells me, check it at this time.

[00:07:47] Speaker 01:
If the strobe signal wasn't corresponding to the memory signal, we wouldn't know what to check at the point in time we received the strobe signal.

[00:07:54] Speaker 01:
But because it does correspond, because as is undisputed, they are in a tight timing relationship, the strobe signal tells me something very important about the memory, the data signal.

[00:08:08] Speaker 01:
That's why they correspond.

[00:08:10] Speaker 01:
And that's certainly within the Broadcom meaning of correspondence that this court put forward in the Broadcom case.

[00:08:18] Speaker 01:
So to try to say that the data signal is a data path or a data signal path is taking language that's not in the claim and creating a conflict with claims 2 and 10.

[00:08:34] Speaker 01:
The data path cannot be that narrow or 2 and 10 make no sense.

[00:08:39] Speaker 01:
And it would, of course, take corresponding 2 and substitute the words is in.

[00:08:44] Speaker 01:
Because that's what the board did.

[00:08:46] Speaker 01:
The board took corresponding to a data signal line and said, is in the data signal line.

[00:08:55] Speaker 01:
The board did that at page 17, where it says, that is, it is a data path that is in the data signal line.

[00:09:02] Speaker 01:
It did again on page 18.

[00:09:06] Speaker 01:
The data path, as recited in claim one, is in the data signal line.

[00:09:11] Speaker 01:
And then when it was applying the claims on page 40,

[00:09:14] Speaker 01:
It said, a datapath as claimed, that is on a data signal line.

[00:09:21] Speaker 01:
Those are expressions of equivalence, not questions of correspondence, not language showing correspondence.

[00:09:29] Speaker 01:
And that's where the board erred.

[00:09:31] Speaker 01:
All this court would need to do is to instruct the board that it is not equivalent.

[00:09:36] Speaker 01:
Datapath, data signal line are different things in this claim.

[00:09:40] Speaker 01:
there just needs to be correspondence between them and have the board reassess the prior art without requiring that the data path is in the data signal log.

[00:09:50] Speaker 03:
Well, doesn't on appendix page 41, doesn't the board

[00:09:56] Speaker 03:
really use the correspond to language that you seem to be articulating and arguing to us.

[00:10:00] Speaker 03:
I felt like right there in that paragraph, it does use the correspond to language.

[00:10:05] Speaker 03:
And it feels a little bit like you're overly pursing some of these other pages you point us to in terms of you potentially creating an issue with the board's construction.

[00:10:17] Speaker 01:
So Your Honor, the board addressed claim construction earlier in the decision, pages 17 and 18.

[00:10:24] Speaker 01:
And there it tells us what it means by corresponds to.

[00:10:30] Speaker 01:
So on page 17, for example, the board says that it says corresponds to and then says that is, it is a data path that is in the data signal line.

[00:10:43] Speaker 01:
So what we're seeing here is the board saying this is what we mean by corresponds to.

[00:10:49] Speaker 01:
We mean is in.

[00:10:51] Speaker 01:
Later in the opinion,

[00:10:53] Speaker 01:
It uses the corresponds to language, but it's already told us from its claim construction portion what it means.

[00:10:59] Speaker 01:
And the specific point you point to, Judge Cunningham, on page 40, you can see why that's true, right?

[00:11:05] Speaker 01:
Page 41.

[00:11:06] Speaker 01:
Oh, sorry.

[00:11:06] Speaker 01:
Page 41.

[00:11:07] Speaker 01:
You're right.

[00:11:08] Speaker 01:
So I think you're looking perhaps at the last paragraph.

[00:11:11] Speaker 01:
Again, it's discussed.

[00:11:12] Speaker 04:
That's correct.

[00:11:13] Speaker 01:
It says claim one requires that the recited data path correspond to the data signal lines carrying the data signals, which it previously on 17 and 18 says is in.

[00:11:22] Speaker 01:
And then it says not to strobe signal lines carrying strobe signals.

[00:11:27] Speaker 01:
So it has said data path corresponds to means is in.

[00:11:31] Speaker 01:
So it can't have strobe signals, no strobe signals.

[00:11:35] Speaker 01:
And it frankly says no strobe signals on 40, says it again on 42, says it again on 69 to 70.

[00:11:42] Speaker 01:
Every time it applies the data path language, it applies this exclusive view that because the data path is in, or at one point it says is on, the data signal lines, no other signal can be on the data path, especially, importantly, the strobe signals.

[00:12:01] Speaker 04:
Counsel, my signal to you is that you're into your rebuttal time.

[00:12:05] Speaker 04:
You can continue or save it.

[00:12:08] Speaker 01:
Well, if there are no other questions, I'll save it.

[00:12:10] Speaker 01:
But of course, I want to respond to any questions there are.

[00:12:12] Speaker 01:
But I'm happy to sit down, Your Honor, and continue in rebuttal.

[00:12:30] Speaker 00:
Thank you, Your Honors, and may it please the Court.

[00:12:33] Speaker 00:
The Board construed the data path of Claim 1 at Appendix 24 to mean the path that corresponds to data signal lines carrying data signals and not to strobe signal lines carrying strobe signals.

[00:12:46] Speaker 00:
That construction is supported by every level of the Phillips claim construction analysis, and Samsung's contrary arguments fail at every level of the Phillips analysis.

[00:12:58] Speaker 00:
Let's start with the claim language.

[00:13:00] Speaker 00:
The claim recites a buffer that is coupled to a respective set of data strobe signal lines, and then it specifically calls out the data path, quote, corresponding to each data signal line in the respective set of data strobe signal lines.

[00:13:16] Speaker 00:
all agree that data signal lines accommodate only data signals, not strobe signals.

[00:13:21] Speaker 00:
Strobe signals have their own signal lines.

[00:13:25] Speaker 00:
And so the claim is specifying that the data path of interest is the one through which the data signals, not the strobe signals, travel.

[00:13:33] Speaker 00:
Under Samsung's position, the phrase each data signal line

[00:13:38] Speaker 00:
in the corresponding to clause does no work.

[00:13:41] Speaker 00:
It's completely meaningless.

[00:13:43] Speaker 00:
And that is a glaring sign that Samsung's construction is wrong.

[00:13:48] Speaker 00:
Now let's go to other claims.

[00:13:50] Speaker 00:
And in particular, claim 10, which my friend mentioned.

[00:13:53] Speaker 00:
Claim 10 supports our construction, not Samsung's, because it shows that when the patentee meant to call out a data path specifically corresponding to a strobe signal, it did so.

[00:14:04] Speaker 00:
That's what claim 10 does.

[00:14:06] Speaker 00:
Claim 1 doesn't do that.

[00:14:08] Speaker 02:
And what about claim 2?

[00:14:09] Speaker 02:
Because your friend also threw in claim 2.

[00:14:11] Speaker 00:
Claim 2 also supports our construction because claim 2 depends from claim 1 and uses the phrase the data path referring back to claim 1 for antecedent basis.

[00:14:21] Speaker 00:
So that's the data path over which data signals travel.

[00:14:25] Speaker 00:
Claim 10, in contrast, uses a first data path and a second data path.

[00:14:30] Speaker 00:
which makes clear that those are two new data paths, one on which strobe signals travel, one on which data signals travel.

[00:14:37] Speaker 00:
And I want to emphasize one point that I think underlies a lot of Samsung's arguments.

[00:14:45] Speaker 00:
They seem to be fixated on the idea that the phrase data path in isolation could accommodate a data signal or a strobe signal.

[00:14:53] Speaker 00:
That's absolutely true.

[00:14:54] Speaker 00:
The problem is claim one is very specific

[00:14:57] Speaker 00:
the data path it cares about.

[00:14:59] Speaker 00:
It cares about the data path that is the one corresponding to each data signal line in the respective set of data strobe signal lines.

[00:15:08] Speaker 00:
We can now go to the specification.

[00:15:09] Speaker 03:
What is your response to the argument that opposing counsel is making about the is in sort of language

[00:15:18] Speaker 03:
I felt like, in addition to the fact that, as we can see in the actual final run decision, there is a specific claim construction, he seemed to think that the board was making a further definition of the corresponds to.

[00:15:32] Speaker 03:
And I want a direct response to that.

[00:15:33] Speaker 00:
I don't read the board's decision that way and the board in fact explicitly addressed and rejected Samsung's argument that it was conflating data path and data signal line at appendix 17.

[00:15:44] Speaker 00:
What the board was saying is that the data path of interest is the path that data signals travel from inside the buffer

[00:15:54] Speaker 00:
from the data signal line on one side of the buffer to the data signal line that comes out on the other side of the buffer.

[00:16:00] Speaker 00:
And that's consistent throughout the board's entire discussion.

[00:16:02] Speaker 02:
I mean, it's a little bit of an odd statement that the board made on 17 about the data path must be in the data signal line.

[00:16:10] Speaker 02:
But that statement does, in my view, reading the board's decision as entirety doesn't really do anything much to undermine

[00:16:19] Speaker 00:
I agree your honor I think what what the board was saying if you read the discussion in context is that the the data path that we care about and you can you can see this explicitly in figure three which is reproduced and annotated at page thirty four of our red brief the data path that we care about is the one

[00:16:36] Speaker 00:
It's inside the buffer and it's corresponding to a specific data signal line that comes into that buffer and then goes out of that buffer on the other side.

[00:16:45] Speaker 00:
That's what the board was saying.

[00:16:46] Speaker 00:
That's correct.

[00:16:47] Speaker 00:
It's supported by Figure 3.

[00:16:49] Speaker 00:
It's supported by Figure 16 of the patent, which shows the path corresponding to the data signal line in detail.

[00:16:55] Speaker 00:
and specifically depicts a delay circuit on that path.

[00:16:59] Speaker 02:
Who's the person skilled in the art in this case?

[00:17:04] Speaker 02:
I find the technology pretty challenging.

[00:17:07] Speaker 02:
I'm just curious.

[00:17:09] Speaker 00:
The board's definition... Let me find it.

[00:17:16] Speaker 02:
Sorry to take your time.

[00:17:18] Speaker 00:
Oh no, not all your own.

[00:17:24] Speaker 00:
Board adopted a definition that you can find at appendix 8 to 9, which is a person with an advanced degree in electrical or computer engineering and two years work experience in the field of memory module design and operation.

[00:17:41] Speaker 00:
And then it goes on to say that they would have familiarity with industry standards and usual components that are used in these sorts of devices.

[00:17:51] Speaker 00:
And so as I've been discussing the intrinsic evidence uniformly supports our construction.

[00:17:57] Speaker 00:
Samsung, in contrast, doesn't have any intrinsic evidence to commend its construction.

[00:18:03] Speaker 00:
And that may be why Samsung's claim construction arguments in this appeal are kind of upside down.

[00:18:09] Speaker 00:
Samsung leads with cases construing the phrase corresponding to in completely different contexts, and then it pivots to extrinsic evidence about the purpose of strobe signals, which the board addressed and rejected, and only then does it discuss the intrinsic evidence in passing.

[00:18:26] Speaker 00:
So the court can resolve this issue, I think, based on the intrinsic record alone.

[00:18:30] Speaker 00:
The board's decision is completely correct based on the intrinsic record.

[00:18:34] Speaker 00:
If you want to go to extrinsic evidence, the record there is one-sided in our favor, too.

[00:18:39] Speaker 00:
Our expert explained in detail in evidence that the board cited why skilled artisan would read the claim the way the board did.

[00:18:45] Speaker 00:
You can find that at Appendix 7248, paragraph 70.

[00:18:49] Speaker 00:
That begins with paragraph 70, and the discussion goes through paragraph 81.

[00:18:54] Speaker 00:
Samsung doesn't have any contrary expert testimony.

[00:18:57] Speaker 00:
Its expert ignored this issue in his opening declaration, and Samsung didn't submit anything from him in reply.

[00:19:04] Speaker 00:
All Samsung can muster is attorney argument that data and strobe signals have to be tightly correlated.

[00:19:11] Speaker 00:
But as we explained in our briefing, it is undisputed that that correlation is temporal, and the data and the strobe signals travel on separate dedicated signal lines.

[00:19:23] Speaker 00:
And so for all those reasons, the board's construction is correct, and this court should have found.

[00:19:27] Speaker 00:
I'm happy to answer any questions about claim construction or any other issues raised, but since my friend addressed only claim construction, I will cede the balance of my time unless there are questions.

[00:19:39] Speaker 04:
Thank you, Counsel.

[00:19:40] Speaker 04:
Mr. Hawes has some rebuttal time.

[00:19:42] Speaker 01:
Thank you, Your Honor.

[00:19:46] Speaker 01:
Thank you, Your Honor.

[00:19:47] Speaker 01:
We agree that intrinsic evidence is what's critical here.

[00:19:50] Speaker 01:
And what's critical is the structure of the claims.

[00:19:52] Speaker 01:
And so I'd like to just look specifically at the structure of the claims in my last few minutes.

[00:19:56] Speaker 03:
And so do you agree that we only need to reach the intrinsic evidence here?

[00:19:58] Speaker 03:
We don't need to get to that?

[00:20:00] Speaker 01:
We agree.

[00:20:00] Speaker 01:
We believe the intrinsic evidence is.

[00:20:03] Speaker 01:
on all four feet with what's going on here.

[00:20:06] Speaker 01:
So let's look at Claim 1.

[00:20:08] Speaker 01:
We have the corresponding two language.

[00:20:10] Speaker 01:
We've discussed that.

[00:20:11] Speaker 01:
So, I mean, I think we're all in good shape there.

[00:20:14] Speaker 01:
The next part of Claim 1 that's critical, and it's the next part that refers to the data path, is in 1F.

[00:20:19] Speaker 01:
And if you look in our brief where we've got the claim in the front page of our brief, at the bottom of the first page of Claim 1, you'll see the very last line.

[00:20:31] Speaker 01:
It talks about delaying a signal through the data path.

[00:20:37] Speaker 01:
That's the language in 1F.

[00:20:39] Speaker 01:
It's not a data signal through the data path.

[00:20:41] Speaker 01:
It's a signal through the data path.

[00:20:44] Speaker 01:
Obviously, the patentee could have easily said a data signal if they thought this was only about data signals.

[00:20:49] Speaker 01:
They didn't.

[00:20:50] Speaker 01:
But that's further confirmed when you move to claim two.

[00:20:54] Speaker 01:
I 100% agree with my colleague.

[00:20:55] Speaker 01:
Claim two is referring back to the data path.

[00:20:59] Speaker 01:
So claim two is critical in understanding what the data path can include.

[00:21:04] Speaker 01:
And claim two, at the very end, says the signal through the data path is a signal associated with the second memory operation.

[00:21:13] Speaker 01:
Again, that's a very broad, there are a lot of signals associated with the second memory operation.

[00:21:17] Speaker 01:
It is not just the data signal.

[00:21:20] Speaker 01:
So again, the claims are not consistent with the idea that the data path can only carry data signals.

[00:21:27] Speaker 01:
And that is confirmed in Claim 10.

[00:21:30] Speaker 01:
Claim 10 tells us that when Claim 2 says a signal associated with the second memory operation, it's including strobe signals.

[00:21:38] Speaker 01:
And I'm looking here at the very first clause of Claim 10.

[00:21:43] Speaker 01:
In the middle of it, it says a strobe signal associated with the second memory operation.

[00:21:49] Speaker 01:
So we know that when they were drafting these claims, they thought that strobe signals and data signals are both associated with the second memory operation.

[00:21:58] Speaker 01:
We know that those are the types of signals they thought would be in the data path.

[00:22:03] Speaker 01:
And now we get a construction that says, no, no, no, only data signals in the data path.

[00:22:09] Speaker 03:
Do you have any response to the figures that opposing counsel identified to help us overall consider the claim construction on this point?

[00:22:19] Speaker 01:
I mean, I didn't seem to go into them in detail, but in their brief, they do refer to figures.

[00:22:24] Speaker 01:
I believe it's 15 and 16, Your Honor.

[00:22:26] Speaker 03:
In his argument, he just pointed us to figure 16, so you can just find something.

[00:22:30] Speaker 01:
Right, OK.

[00:22:31] Speaker 01:
So in terms of figure 16,

[00:22:35] Speaker 01:
We're talking about specific data paths, not the data path of claim one.

[00:22:39] Speaker 01:
If you look at the description of what's going on in those figures, it's a read data path.

[00:22:44] Speaker 01:
It's a write data path.

[00:22:45] Speaker 01:
These are specific data paths, not the more general data path in claim one, which claim two tells us is associated with all of the signals.

[00:22:53] Speaker 01:
So those figures are about something very different than the data path in claim one.

[00:22:58] Speaker 01:
Claim one is specifically written so that it can handle any memory operation.

[00:23:02] Speaker 01:
I mean, they wrote it broadly for that very reason.

[00:23:05] Speaker 01:
The figures they then point to are specific embodiments, which this court says you don't limit a claim to a specific embodiment.

[00:23:12] Speaker 01:
And there's specific embodiment with specific data paths.

[00:23:15] Speaker 01:
So nothing in that language would suggest under this court's precedent that we should narrow claim one to only include the embodiments of claims 15 and 16.

[00:23:27] Speaker 01:
Instead, this court's precedent says, look at claim one.

[00:23:30] Speaker 01:
in view of dependent claims that tell us at least the signals associated with the second memory operation need to be able to travel on that data path.

[00:23:39] Speaker 01:
And we know just from that that the board was wrong to limit data path to only those data signals.

[00:23:47] Speaker 01:
So hopefully that addresses your question.

[00:23:49] Speaker 01:
Unless you have more questions, I think that's the bottom line here.

[00:23:52] Speaker 01:
A remand with just the board being told it's not just data signals, the claims require that the data path can handle the signals from the second memory operation, including strobe signals, would allow the board to assess the fire art properly and determine whether these claims are valid.

[00:24:09] Speaker 04:
Thank you, Your Honor.

[00:24:09] Speaker 04:
Thank you to both counsel for taking the time.