Free Claim Construction Chart - District Court of Delaware - Delaware

Case 1:04-cv-00357-GMS

Document 67-2

Filed 07/18/2005

Page 1 of 14

Joint Claim Construction Chart ­ U.S. Patent 5,528,2221
Claim Text (U.S. Patent 5,528,222) Intermec's Proposed Construction Intrinsic Evidence for Intermec's Proposed Construction Symbol's Proposed Construction Intrinsic Evidence for Symbol's Proposed Construction

1. A thin flexible electronic radio frequency tag circuit comprising; an insulating, flexible substrate; an antenna that is an integral part of the substrate and that has terminals;

The preamble is not a claim limitation. ordinary meaning The phrase "integral part of Col. 4, lns. 6-8 the substrate" includes but is not limited to "etched onto or plated on the substrate." remaining terms ­ ordinary meaning The phrase "adjacent Col. 4, lns. 18-27; proximity" means "close (i.e., Fig. 2. not stacked)", where "stacked" refers to the stacking of electrical planes as opposed to physical stacking. remaining terms ­ ordinary meaning

The preamble is not a claim limitation. ordinary meaning The phrase "integral part of Col. 4, lns. 6-8 the substrate" includes but is not limited to "etched onto or plated on the substrate." remaining terms ­ ordinary meaning "adjacent proximity" means "close with no stacking"

a circuit chip having a modulator circuit, a logic circuit, a memory circuit, and chip connectors and being on the substrate in adjacent proximity to the antenna;

Col. 4, lns. 22-26; Col. 3, lns. 19-20 File History ("FH"): Application filed 9/9/94 at p. 10.

remaining terms ­ ordinary meaning

1

Shaded rows indicate that the parties are in agreement as to the claim construction for that particular claim limitation.

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Intrinsic Evidence Symbol's Proposed for Intermec's Construction Proposed Construction one or more connecting The phrase "connecting lines" Figs. 7A-E; Col. 6, "connecting lines" means lines between the antenna should be given its ordinary lns. 1-38. "electrical conductor terminals and the chip and accustomed meaning to excluding the bonding types connectors, the connecting mean "any substance that of thermal compression, lines being coplanar with the connects two or more single point bonding, C4 antenna and antenna electrical components." bonding, and conductive terminals. adhesive" The term "coplanar" should be Col. 2, lns. 48-50; construed to mean "no vias, Col. 3, lns. 15-18; "coplanar" means "a single crossovers, etc. single plane of Col. 4, lns. 19-21; plane of wiring" wiring." "Coplanar," Fig. 2 therefore, refers to components being in the same electrical plane while not necessarily in the same physical or geometric plane. remaining terms ­ ordinary meaning remaining terms ­ ordinary meaning

Claim Text (U.S. Patent 5,528,222)

Intermec's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction Col. 7, lns. 57-60; Col. 8, lns. 29-38.

FH: Application filed 9/9/94 at p. 10; Col. 4, lns. 20-22; Col. 5, lns. 41-42

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Joint Claim Construction Chart

Case 1:04-cv-00357-GMS

Document 67-2

Filed 07/18/2005

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Joint Claim Construction Chart ­ U.S. Patent 5,912,632
Claim Text (U.S. Patent 5,912,632) Intermec's Proposed Construction Intrinsic Evidence for Intermec's Proposed Construction Symbol's Proposed Construction Intrinsic Evidence for Symbol's Proposed Construction

1. A passive radio frequency (RF) transponder (tag) for receiving an RF signal from a base station, comprising; a tag antenna for receiving the RF signal fron [sic] the base station the RF signal having a carrier frequency; a tag rectification power supply connected to the tag antenna; a tag logic section and a tag memory section the tag logic section and the tag memory section receiving power only from the tag antenna through the tag rectification power supply; a receiver section connected to the tag antenna; and a tag oscillator connected to the receiver section,

The preamble is not a claim limitation

The preamble is not a claim limitation

ordinary meaning, where there is no distinction between "base station" and an RFID reader. ordinary meaning

ordinary meaning, where there is no distinction between "base station" and an RFID reader. ordinary meaning

ordinary meaning

ordinary meaning

ordinary meaning ordinary meaning

ordinary meaning ordinary meaning

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Joint Claim Construction Chart

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

the tag oscillator having a plurality of possible discrete frequencies of oscillation, the tag oscillator having a tag oscillation frequency much less than the carrier frequency,

ordinary meaning

ordinary meaning

The phrase "much less than" means "less than one-fifth as much"

The phrase "much less than" means "less than one-fifth as much" remaining terms ­ ordinary meaning "backscatter" means "the Col. 1, lns. 46-51 rebroadcasting or reflection of incoming RF energy at the carrier frequency." remaining terms ­ ordinary meaning ordinary meaning

remaining terms ­ ordinary meaning the tag oscillator frequency The term "backscatter" means used to determine a tag "the reflection of incoming RF modulation frequency of an energy centered about the RF signal backscattered carrier frequency." from the tag antenna, remaining terms ­ ordinary meaning the tag oscillation frequency This claim limitation should determined by the RF signal be construed to mean that the sent from the base station. "tag oscillation frequency" is "determined by" the modulation frequency of "the RF signal sent from the base station" as opposed to the carrier frequency of "the RF signal sent from the base station."

Col. 1, lns. 12-14; Col. 5, lns. 2-4; Fig. 8; Col. 8, lns. 21-24.

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

13. A method of setting a tag oscillation frequency of a tag oscillator of a passive RF tag comprising; a) receiving an RF signal from a base station, and;

The method is limited to a passive tag.

The method is limited to a passive tag.

ordinary meaning, where there is no distinction between "base station" and an RFID reader. b) adjusting the tag This claim limitation should oscillation frequency in be construed to mean response to the RF signal "adjusting the tag oscillation from the base station, frequency in response to" the modulation frequency of "the RF signal from the base station" as opposed to the carrier frequency of "the RF signal from the base station." wherein the tag oscillation The phrase "much less than" frequency is much less than means "less than one-fifth as a carrier frequency of the much" RF signal, remaining terms ­ ordinary meaning

Col. 1, lns. 12-14; Col. 5, lns. 2-4; Fig. 8; Col. 8, lns. 21-24.

ordinary meaning, where there is no distinction between "base station" and an RFID reader. ordinary meaning

The phrase "much less than" means "less than one-fifth as much" remaining terms ­ ordinary meaning

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

remaining terms ­ ordinary meaning 22. A system for sending and The preamble is not a claim receiving modulated RF limitation. signals, comprising; a base station for sending ordinary meaning, where there modulated RF signals, the is no distinction between "base RF signals having a carrier station" and an RFID reader. frequency; and at least one passive RF tag ordinary meaning for receiving the RF signals, the RF tag comprising a tag antenna for receiving ordinary meaning the RF signal from the base station, a tag receiver section ordinary meaning connected to the tag antenna; and a tag oscillator connected to ordinary meaning the tag receiver section,

and wherein the tag oscillation frequency is used to determine a tag modulation frequency of an RF signal backscattered from the tag.

The term "backscatter" means "the reflection of incoming RF energy centered about the carrier frequency."

"backscatter" means "the rebroadcasting or reflection of incoming RF energy at the carrier frequency." remaining terms ­ ordinary meaning The preamble is not a claim limitation. ordinary meaning, where there is no distinction between "base station" and an RFID reader. ordinary meaning

Intrinsic Evidence for Symbol's Proposed Construction Col. 1, lns. 46-51

ordinary meaning

ordinary meaning

ordinary meaning

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

the tag oscillator having a tag oscillation frequency much less than the carrier frequency,

The phrase "much less than" means "less than one-fifth as much"

The phrase "much less than" means "less than one-fifth as much" remaining terms ­ ordinary meaning "backscatter" means "the Col. 1, lns. 46-51 rebroadcasting or reflection of incoming RF energy at the carrier frequency." remaining terms ­ ordinary meaning ordinary meaning

remaining terms ­ ordinary meaning the tag oscillation frequency The term "backscatter" means used to determine the a "the reflection of incoming RF modulation frequency of an energy centered about the RF signal backscattered carrier frequency." from the tag antenna, remaining terms ­ ordinary meaning the tag oscillator frequency This claim limitation should determined by the RF be construed to mean that the signals sent by the base "tag oscillation frequency" is station. "determined by" the modulation frequency of "the RF signals sent by the base station" as opposed to the carrier frequency of "the RF signals sent by the base station."

Col. 1, lns. 12-14; Col. 5, lns. 2-4; Fig. 8; Col. 8, lns. 21-24.

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Joint Claim Construction Chart

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Filed 07/18/2005

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

28. A passive radio The preamble is not a claim frequency (RF) transponder limitation. (tag) for receiving an RF signal from a base station, comprising; a tag antenna for receiving ordinary meaning the RF signal from the base station, the RF signal having a carrier frequency; a receiver section connected ordinary meaning to the tag antenna; a tag rectification power ordinary meaning supply connected to the tag antenna; a tag logic section and a tag ordinary meaning memory section, the tag logic section and the tag memory section receiving power only from the tag antenna through the tag rectification power supply; and a tag oscillator connected to ordinary meaning the receiver section,

The preamble is not a claim limitation.

ordinary meaning

ordinary meaning ordinary meaning

ordinary meaning

ordinary meaning

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Joint Claim Construction Chart

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Filed 07/18/2005

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Claim Text (U.S. Patent 5,912,632)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

the tag oscillator having a tag oscillation frequency much less than the carrier frequency,

The phrase "much less than" means "less than one-fifth as much"

The phrase "much less than" means "less than one-fifth as much" remaining terms ­ ordinary meaning "backscatter" means "the Col. 1, lns. 46-51 rebroadcasting or reflection of incoming RF energy at the carrier frequency." remaining terms ­ ordinary meaning ordinary meaning

remaining terms ­ ordinary meaning the tag oscillation frequency The term "backscatter" means used to determine a tag "the reflection of incoming RF modulation frequency of an energy centered about the RF signal backscattered carrier frequency." from the tag antenna, remaining terms ­ ordinary meaning the tag oscillation frequency This claim element should be determined by the RF signal construed to mean that the "tag sent from the base station. oscillation frequency" is "determined by" the modulation frequency of "the RF signal sent from the base station" as opposed to the carrier frequency of "the RF signal sent from the base station."

Col. 1, lns. 12-14; Col. 5, lns. 2-4; Fig. 8; Col. 8, lns. 21-24.

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Joint Claim Construction Chart ­ U.S. Patent 5,995,019
Claim Text (U.S. Patent 5,995,019) Intermec's Proposed Construction Intrinsic Evidence for Intermec's Proposed Construction Symbol's Proposed Construction Intrinsic Evidence for Symbol's Proposed Construction

1. A method for communicating between a base station and a set of radio frequency RF transponders (Tags) comprising: defining a plurality of RF tags into different groups according to a physical wave characteristic of the electromagnetic wave energy received from the RF tags, and

The preamble is not a claim limitation.

The preamble is not a claim limitation.

communicating with the tags in each defined group.

The terms of this claim Col. 2, ln. 61- Col. element should be given their 3, ln 27; ordinary and accustomed Col. 6, lns. 60-64. meaning where "physical wave characteristic" includes any physical attribute of the "electromagnetic wave energy received from the RF tags," including but not limited to signal strength, polarization, phase, carrier frequency and/or modulation frequency. ordinary meaning

"defining a plurality of RF tags into different groups according to a physical wave characteristic of the electromagnetic wave energy received from the RF tags excluding grouping where the tags select themselves according to a signal from the base station"

FH: Response to Amendment received March 17, 1999 at p.5; Col. 2, lns. 46-58; Col. 7, lns. 53-61; Col. 12, lns. 3-11.

"communicating with all of the tags in each group as grouped" ordinary meaning

Col. 2, lns. 18-19; Col. 2, lns. 46-58; Col. 7, lns. 48-61; Col. 11, lns. 12-23.

3. The method of claim 1 ordinary meaning wherein at least one defining physical wave characteristic is the wave frequency. Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS Page 10

Joint Claim Construction Chart

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Claim Text (U.S. Patent 5,995,019)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

Symbol's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction

9. An RF tag base station The preamble is not a claim comprising limitation. a computer ordinary meaning a transmitter ordinary meaning a receiver, and ordinary meaning at least one antenna, ordinary meaning wherein the RF tag base ordinary meaning, where there station communicates with a is no distinction between "base plurality of RF tags by: station" and an RFID reader. interrogating the RF tags ordinary meaning with electromagnetic energy, grouping the RF tags The terms of this claim Col. 2, ln. 61- Col. according to a physical element should be given their 3, ln 27. Col. 6, lns. characteristic of their ordinary and accustomed 60-64. responsive electromagnetic meaning where "physical signals, and characteristic" includes any physical attribute of the "responsive electromagnetic signals," including but not limited to signal strength, polarization, phase, carrier frequency and/or modulation frequency.

The preamble is not a claim limitation. ordinary meaning ordinary meaning ordinary meaning ordinary meaning ordinary meaning where there is no distinction between "base station" and an RFID reader. ordinary meaning

"grouping the RF tags according to a physical characteristic of their responsive electromagnetic signals excluding grouping where the tags select themselves according to a signal from the base station"

FH: Response to Amendment received March 17, 1999 at p.5; Col. 2, lns. 46-58; Col. 7, lns. 53-61; Col. 12, lns. 3-11.

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Claim Text (U.S. Patent 5,995,019)

Intermec's Proposed Construction

Intrinsic Evidence for Intermec's Proposed Construction

reading the RF tags in each The terms of this claim group. element should be given their ordinary and accustomed meaning. 11. A base station as in claim ordinary meaning 9 wherein RF tags are grouped according to the wave frequency of their respective return signals. 16. A base station as in claim ordinary meaning 9 wherein RF tags are grouped according to the frequency modulation of their respective return signals. 18. An RF tag unit reading The preamble is not a claim unit comprising: limitation. a computer; ordinary meaning a transmitter; ordinary meaning a receiver; and ordinary meaning at least one antenna; ordinary meaning wherein the RF tag reading "tag reading unit" means "base Col. 3, lns. 55-62. unit communicates with a station" plurality of RF tags by: interrogating the RF tags ordinary meaning with electromagnetic energy; Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS Page 12

Intrinsic Evidence for Symbol's Proposed Construction "reading all of the tags in each Col. 2, lns. 18-19; group as grouped" Col. 2, lns. 46-58; Col. 7, lns. 48-61; Col. 11, lns. 12-23. ordinary meaning

Symbol's Proposed Construction

ordinary meaning

The preamble is not a claim limitation. ordinary meaning ordinary meaning ordinary meaning ordinary meaning "tag reading unit" means "base Col. 3, lns. 55-62. station" ordinary meaning

Joint Claim Construction Chart

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Intrinsic Evidence Symbol's Proposed for Intermec's Construction Proposed Construction grouping the RF tags The terms of this claim Col. 2, ln. 61- Col. "grouping the RF tags according to a physical element should be given their 3, ln 27; according to a physical characteristic of their ordinary and accustomed Col. 6, lns. 60-64. characteristic of their responsive electromagnetic meaning where "physical responsive electromagnetic signals, and characteristic" includes any signals excluding grouping physical attribute of the where the tags select "responsive electromagnetic themselves according to a signals," including but not signal from the tag reading limited to signal strength, unit" polarization, phase, carrier frequency and/or modulation frequency. reading the RF tags in each ordinary meaning "reading all of the tags in each group. group as grouped"

Claim Text (U.S. Patent 5,995,019)

Intermec's Proposed Construction

Intrinsic Evidence for Symbol's Proposed Construction FH: Response to Amendment received March 17, 1999 at p.5; Col. 2, lns. 46-58; Col. 7, lns. 53-61; Col. 12, lns. 3-11.

Col. 2, lns. 18-19; Col. 2, lns. 46-58; Col. 7, lns. 48-61; Col. 11, lns. 12-23.

Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

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Joint Claim Construction Chart ­ U.S. Patent 6,371,375
Claim Text (U.S. Patent 6,371,375) Intermec's Proposed Construction Intrinsic Evidence for Intermec's Proposed Construction Symbol's Proposed Construction Intrinsic Evidence for Symbol's Proposed Construction

1. A system for storing and The preamble is not a claim retrieving data comprising: limitation. a radio frequency tag having a ordinary meaning memory for storing data; a first identifier stored in the ordinary meaning memory of the radio frequency tag; and a machine readable symbol "Associated" means associated with the radio "perceptually linked" frequency tag, at least a portion of the machine readable symbol encoding a second identifier logically associable with the first identifier. "Logically associable" means that a "correspondence can be drawn between the identifiers, including but not limited to corresponding by matching or corresponding by mapping or corresponding by mathematical transformation" remaining terms ­ ordinary meaning Intermec I.P. Corp. v. Symbol Technologies, C.A. No. 04-357-GMS

The preamble is not a claim limitation. ordinary meaning ordinary meaning

Col. 3, ln. 66 ­ Col. "Associated" means 4, ln. 6; "perceptually linked" Col. 5, lns. 13-20; FH: Response to Office Action dated Sep. 1, 2000, at p. 2. FH: Response to Office Action dated September 1, 2000, at p. 2; Col. 5, lns. 28-38. "Logically associable" means that a "correspondence can be drawn between the identifiers, including but not limited to corresponding by matching or corresponding by mapping or corresponding by mathematical transformation" remaining terms ­ ordinary meaning Page 14

Col. 3, ln. 66 ­ Col. 4, ln. 6; Col. 5, lns. 13-20; FH: Response to Office Action dated Sep. 1, 2000, at p. 2. FH: Response to Office Action dated September 1, 2000, at p. 2; Col. 5, lns. 28-38.

Joint Claim Construction Chart