Free Claim Construction Statement - District Court of California - California

Case 5:06-cv-01839-PVT

Document 76

Filed 02/16/2007

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KARL J. KRAMER (CA SBN 136433) ELLEN S. REINSTEIN (CA SBN 227833) ERIKA L. LABIT (CA SBN 234919) MORRISON & FOERSTER LLP 755 Page Mill Road Palo Alto, California 94304-1018 Telephone: (650) 813-5600 Facsimile: (650) 494-0792 [email protected] Attorneys for Defendant SYNAPTICS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

ELANTECH DEVICES CORPORATION, a corporation existing under the laws of Taiwan, R.O.C., Plaintiff, v. SYNAPTICS, INC., a Delaware corporation; AVERATEC, INC., a California corporation; and PROSTAR COMPUTER, INC., a California corporation, Defendants.

Case No.

C06-01839 CRB

SYNAPTICS' REQUESTED TERMS FOR CLAIM CONSTRUCTION PURSUANT TO THE COURT'S FEBRUARY 14, 2007 ORDER

19 AND RELATED COUNTERCLAIMS 20 21 22 23 24 25 26 27 28 This Court issued an Order on February 14, 2007 requiring that "[e]ach party is directed to advise the Court in writing, on or before noon on Friday, February 16, 2007, of the four terms or phrases that the party most wants the Court to construe." Synaptics, Inc. ("Synaptics") hereby responds to the Court's February 14, 2007 Order. Synaptics, Inc. requests that the Court construe the following portion of the asserted claim 1 of United States Patent No. 5,825,352 ("the `352 Patent"): "scanning the touch sensor to (a) identify a first maxima in a signal corresponding to a first finger, (b) identify a minima following the first maxima, (c) identify a second maxima in a signal corresponding to a second
SYNPATICS' REQUESTED TERMS FOR CLAIM CONST. PURSUANT TO 2/14/07 ORDER CASE NO. C06-01839 CRB

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finger following said minima." This language is repeated verbatim in claim 18 of the `352 Patent, except that claim 18 includes the word "and" before "(c)". These claim words include the four claim terms numbered 15(a), 16, 17, and 18 in the attached 3rd Amended Joint Claim Construction Chart and set forth below.
CLAIM TERM SYNAPTICS' CONSTRUCTION ELANTECH'S CONSTRUCTION

15(a) "scanning the touch sensor" 16. "scanning the touch sensor to . . . identify a first maxima in a signal corresponding to a first finger" ('352) 17. "scanning the touch sensor to . . . identify a minima following the first maxima" ('352) 18. "scanning the touch sensor to . . . identify a second maxima in a signal corresponding to a second finger following said minima" ('352)

"measuring the traces in the touch sensor and assigning them to a sequence corresponding to their physical order on the touch sensor." "measuring the trace values of the touch sensor corresponding to a first finger and determining the point at which the measured values cease to increase and begin to decrease" "measuring the trace values of the touch sensor following, in scan order, after the first maxima and determining the point at which the measured values cease to decrease and begin to increase" "measuring the trace values corresponding to a second finger following, in scan order, said minima and determining the point at which the measured values cease to decrease and begin to increase"

"examining information associated with the touch sensor" "identify a first peak value in a finger profile obtained from scanning the touch sensor"

"identify the lowest value in the finger profile that occurs after the first peak value, and before another peak value is identified" "after identifying the lowest value in the finger profile, identify a second peak value in the finger profile"

Resolution of all these four claim terms will materially advance the progress of the litigation. Consequently, Synaptics requests that the Court first construe those terms. Dated: February 16, 2007 KARL J. KRAMER ELLEN S. REINSTEIN ERIKA L. LABIT MORRISON & FOERSTER LLP

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By:

s/Karl J. Kramer Karl J. Kramer Attorneys for Defendant SYNAPTICS, INC. 2

SYNPATICS' REQUESTED TERMS FOR CLAIM CONST. PURSUANT TO 2/14/07 ORDER CASE NO. C06-01839 CRB

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3rd AMENDED JOINT CLAIM CONSTRUCTION CHART
Claim Terms
1. "tap gesture" ('931/'591) 2. "X and Y position information" ('931/'591) 3. "initiating a first signal to the host indicating the occurrence of said gesture" ('591) 4. "terminating said first signal" ('591) 5. "sending a second signal to said host indicating said second gesture" ('591) 6. "initiating a drag gesture signal to the host indicating the occurrence of a gesture" ('591) 7. "maintaining said drag gesture signal" ('591) 8. "repeatedly sending X and Y position information to said host for the duration of said second presence" ('591) 9. "initiating a signal to the host indicating the occurrence of said tap gesture" ('931) 10. "maintaining said signal for a predetermined period of time" ('931) 11. "detecting in which of at least one corner of the touchsensor pad said tap gesture occurred" ('931) 12. "data packet processor" ('052) 13. "incrementally move" ('411)

Synaptics Claim Construction Disclosure

Elantech Claim Construction Disclosure

"a quick tap of the finger on the pad, of short duration and involving little or no X or Y finger motion, that is presented to the host as a brief click of the mouse button" "information about the horizontal and vertical positioning of an object on a touch sensor"

"initiating transmission of a first set of data to a host that indicates that a tap gesture has occurred on the touch-sensor pad"

"outputting to the host a high state of a signal that has a low and a high state, and the high signal state represents that a double tap gesture will potentially occur on the touch-sensor pad" "changing the state of the signal from the high signal state to the low signal state" "changing the state of the signal from a low signal state to a high signal state for a predetermined period of time, and sending the high signal state to the host which interprets the termination of the first signal and the existence of a second high signal state as being a double tap gesture" "outputting to a host a high state of a signal that has a low and high state, and the high signal state represents that a drag gesture will potentially occur on the touch-sensor pad" "continuously outputting the high signal state"

"terminating the previous signal" "sending a second set of data to a host that indicates that a second tap gesture has occurred on the touch-sensor pad"

"initiating transmission of a first set of data to a host that indicates that a gesture has occurred on the touch-sensor pad"

"to continue, retain, or repeat the drag gesture signal"

"after the second presence is detected, repeatedly sending information about the horizontal and vertical positioning of an object on a touch sensor to a host while the second presence continues"

"initiating the transmission of a set of data to a host that indicates that a tap gesture has occurred on the touch-sensor pad" "to continue, retain, or repeat the signal for a period of time that was determined before"

"detecting that a tap gesture has occurred in at least one corner, the identity of which is distinguished in some way from other corners of the touch-sensor pad"

"outputting to the host a high state of a signal that has a low and a high state, where the high signal state represents that a tap gesture occurred on the touch-sensor pad" "continuously outputting the high state of the signal only for a predetermined time period (i.e., changing the signal state from high to low at the end of the predetermined time period)" "after detecting the occurrence of the tap gesture, separately detecting in which of at least one corner of the touch-sensor pad the tap gesture occurred"

"hardware and/or program code, for example, software executed on a central processing unit, that examines data packets" "to move in increments"

"software for processing data packets and sending messages" movement defined by the second component of Equations 12 and 13 in the '411 patent, namely, S(Xcur ­Xcenter) and S(Ycur - Ycenter)

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3rd AMENDED JOINT CLAIM CONSTRUCTION CHART
14. "operative coupling" ('352) 15(a) "scanning the touch sensor" 15(b) "means for scanning the touch sensor . . ." ('352) "finger-induced electrical effect" "measuring the traces in the touch sensor and "examining information associated with the touch assigning them to a sequence corresponding to sensor" their physical order on the touch sensor." 112 ¶6 Claimed Function "scanning the touch sensor to (a) identify a first maxima in a signal corresponding to a first finger, (b) identify a minima following the first maxima, and (c) identify a second maxima in a signal corresponding to a second finger following said minima," as those terms are defined below 112 ¶6 Corresponding Structures analog multiplexor 45, capacitance measuring circuit 70, analog to digital converter 80, microcontroller 60 "measuring the trace values of the touch sensor "identify a first peak value in a finger profile corresponding to a first finger and determining obtained from scanning the touch sensor" the point at which the measured values cease to increase and begin to decrease"

16. "scanning the touch sensor to . . . identify a first maxima in a signal corresponding to a first finger" ('352) 17. "scanning the touch sensor to . . . identify a minima following the first maxima" ('352) 18. "scanning the touch sensor to . . . identify a second maxima in a signal corresponding to a second finger following said minima" ('352) 19(a) "providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" ('352) 19(b) "means for providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" ('352)

"measuring the trace values of the touch sensor following, in scan order, after the first maxima and determining the point at which the measured values cease to decrease and begin to increase" "measuring the trace values corresponding to a second finger following, in scan order, said minima and determining the point at which the measured values cease to decrease and begin to increase"

"identify the lowest value in the finger profile that occurs after the first peak value, and before another peak value is identified"

"after identifying the lowest value in the finger profile, identify a second peak value in the finger profile"

No further construction necessary since ordinary meaning is sufficient.

112 ¶6 Claimed Function "providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" 112 ¶6 Corresponding Structure 112 ¶6 Corresponding Structure None microcontroller 60

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