Plaintiff may call the inventor, Patrick Nunally, as a witness to testify regarding each of
the disputed terms identified above. ...
Defendants may call Dr. Earl Sacerdoti. Dr. Sacerdoti may testify as to the
understanding of individuals of ordinary skill in the art at the relevant time period for the
Asserted Patents. Specifically, Dr. Sacerdoti may provide testimony regarding background
technology or to demonstrate that Dropcam’s constructions of the proposed claim terms and
phrases are consistent with the meaning of such terms and phrases in the relevant art during the
relevant time period for the Asserted Patents. Such testimony will address both the general
understanding of the relevant terms and phrases in the field of the art as well as the
understanding of such terms and phrases in the context of the specifications and claims of the
Asserted Patents. Dropcam does not plan to bring Dr. Sacerdoti to the claim construction
hearing unless the Court requests his presence in advance. Dropcam further reserves the right to
introduce expert testimony from Dr. Sacerdoti to rebut e.Digital’s claim construction positions,
and any expert testimony introduced by e.Digital.
