UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, v. APPLE INC. Defendant. Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED APPLE INC. Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. REVISED JOINT CLAIM CONSTRUCTION CHART PURSUANT TO PATENT LOCAL RULE 4-5(d) Case 6:08-cv-00088-LED Document 175 Filed 01/26/10 Page 1 of 54U.S. Patent No. 6,006,227 Claim Language U.S. Patent No. 6,006,227 Term # Term Mirror Worlds, LLC’s Proposed Claim Construction Apple Inc.’s Proposed Claim Construction Court’s Construction Claim 1. A computer system which organizes each data unit received by or generated by the computer system, comprising: 11 “data unit” '227-1, 13, and 25 “a collection of data of significance to the user that the user considers as a unit.” “an item of information of significance to the user that the user considers as a unit (e.g., an email, picture, voice mail, software program, reminder or calendar item)” 1 “stream” '227-1, 13, 25; '313-1; '427-1, 20-24, 25, 37-39 In the ’227, ’313 and ’427 patents: “a time-ordered collection of data units, or documents, unbounded in number, in which the time associated with a data unit can be in the past, present or future, and the location of file storage is transparent to the user” “a time-ordered sequence of documents that functions as a diary of a person or an entity’s electronic life and that is designed to have three main portions: past, present and future” means for generating a main stream of data units and at least one substream, the main stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; 2-1 “main stream” '227-1, 13, 25; and '313-2 “a stream of each data unit, or document, received by or generated by the computer system” “a stream which stores every data unit, or document, received by or generated by the computer system” Case 6:08-cv-00088-LED Document 175 Filed 01/26/10 Page 2 of 54- 3 - Claim Language U.S. Patent No. 6,006,227 Term # Term Mirror Worlds, LLC’s Proposed Claim Construction Apple Inc.’s Proposed Claim Construction Court’s Construction 3 “substream” '227-1, 13, 25; '313-2 and 11 “a subset of data units, or documents, yielded by a filter on a stream, the filter identifying certain documents within the stream” “a stream that is a subset of data units, or documents, yielded by a filter on a stream, the filter identifying certain documents within the stream” 10-4 “means for generating a main stream of data units...the main stream for receiving each data unit received by or generated by the computer system” '227-1 and 25 Mirror Worlds asserts that sufficient structure is recited in the element “means for generating” to take this element outside the constraints of 35 U.S.C. § 112, ¶ 6. “a main stream of data units ... for receiving each data unit received by or generated by the computer system” If, however, the court determines that 35 U.S.C. § 112, ¶ 6 applies to the “means for generating,” then: The recited function is generating a main stream of data units. The corresponding structure is computer hardware and executable code implementing a main stream of data units, and equivalents thereof. This is a means-plus-function limitation subject to § 112(6). The recited function is generating a main stream of data units...the main stream for receiving each data unit received by or generated by the computer system. The corresponding structure is computer hardware and software that creates a main stream by linking every existing document in a computer system according to the uniquely identifying timestamp in the document’s chronological indicator using a data structure that can be examined and to the extent possible manipulated by many processes simultaneously, and that supports the block-at-the-end operation (and structural equivalents). 10-5 “means for Mirror Worlds asserts that This is a means-plus-function Case 6:08-cv-00088-LED Document 175 Filed 01/26/10 Page 3 of 54- 4 - Claim Language U.S. Patent No. 6,006,227 Term # Term Mirror Worlds, LLC’s Proposed Claim Construction Apple Inc.’s Proposed Claim Construction Court’s Construction generating … at least one substream” '227-1 and 25 sufficient structure is recited in the element “means for generating” to take this element outside the constraints of 35 U.S.C. § 112, ¶ 6. “at least one substream ...for containing data units only from the main stream” If, however, the court determines that 35 U.S.C. § 112, ¶ 6 applies to the “means for generating,” then: The recited function is generating at least one substream. The corresponding structure is computer hardware and executable code implementing substreams, and equivalents thereof. limitation subject to § 112(6). The recited function is generating at least one substream … each substream for containing data units only from the main stream. The corresponding structure is computer hardware and software that runs a search of a stream using a boolean attribute-and keyword expression or a ‘chronological expression’ and generates another stream having the results of the search, using a data structure that can be examined and to the extent possible manipulated by many processes simultaneously, and that supports the block-at-the-end operation (and structural equivalents). means for receiving data units from other computer systems; 10-5 “means for receiving data units from other computer systems” '227-1 The parties agree that this is a means-plus-function limitation subject to § 112(6). The parties agree that the recited function is receiving data units from other computer systems. The corresponding structure is computer hardware and The parties agree that this is a means-plus-function limitation subject to § 112(6). The parties agree that the recited function is receiving data units from other computer systems. The corresponding structure is computer hardware and Case 6:08-cv-00088-LED Document 175 Filed 01/26/10 Page 4 of 54- 5 - Claim Language U.S. Patent No. 6,006,227 Term # Term Mirror Worlds, LLC’s Proposed Claim Construction Apple Inc.’s Proposed Claim Construction Court’s Construction executable code that
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