Mr Jameson ,Now, this is in, this is in the briefing and it's
obviously part of the intrinsic record. But to really get an
understanding of what's going on with these inventions, I would
just say to the Court, I call your attention to figures 1 and
2, where they are described, obviously they're described in
detail in the specification, but specifically at columns 5 and
6 there's a very good description of figures 1 and 2. And,
Your Honor, when you take a look at figures 1 and 2, what you
will see, particularly with respect to figure 2, you will see
a box that is called program ROM. Random programmable
read-only memory. And that's obviously memory.
You will also see in figure 1, you'll see a reference
to memory circuitry that is discussed in the specification as
columns 5 and 6. And you will also see in, going back to
figure 2, you will see some references to what's called a
CODEC. It is a term of art. In fact, it's interesting, it's
got multiple definitions. It's a compressor, decompressor,
coder, decoder. And you have a reference to a DSP, digital
sensor processor. And you've got a reference to a
microprocessor 21.
And I point all of that out to you because for those
devices to process information, they have to work with memory.
And when you read columns 5 and 6, you will see the
specification talking about taking an analog signal and
changing it into a digital signal and as you take an analog
signal, in order to turn it into a piece of digital data, if
you will, a one or a zero, you obviously have to do some very
mathematical algorithms to it. And in order to do that, a
computer or a DSP or a CODEC, it's got to have memory. It's
got to be there in order for it to work.
And I call that to your attention because when you
read the briefs, it is crystal clear what the defendants want
to do in this case. They want to read any type of memory in
connection with processing a signal right out of this patent.
And I think that that's inconsistent with the figures, it's
inconsistent with the specification, it's inconsistent with the
prosecution history, it's inconsistent with the Flashback
device that is an embodiment of the invention that is discussed
in the prosecution history.
And that is, that's really what this case is about, in
a nutshell.
I was going to go through claim 1 with you, but
you've -- in light of the fact that you have read all the
briefs, I'm going to skip over that.
I was going to go through the claim terms that we were
going to discuss today, and I don't think I need to do that at
this point in time.
You have already focused on the core issue in this
case, which is this flash memory issue, and I've got that in
red because that is the core issue in this case. So I'm not
going to spend time talking about that now.
I am going to take Your Honor's admonition very
seriously that you don't want us to rehash the briefs, and I am
not going to do that.
