Universal Connectivity Technologies Inc. v. Dell Technologies Inc. and Dell Inc.

• Court: District Court, W.D. Texas
• Decided: January 26, 2026
• Docket: 1:23-cv-01506
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

UNIVERSAL CONNECTIVITY § TECHNOLOGIES INC., § Plaintiff § § v. § Case No. 1:23-cv-01506-RP § DELL TECHNOLOGIES INC. and § DELL INC., § Defendants

CLAIM CONSTRUCTION ORDER Now before the Court are the Parties’ claim construction briefs: • Defendants’ Opening Claim Construction Brief, filed August 29, 2025 (Dkt. 77); • Plaintiff Universal Connectivity Technologies Inc.’s Responsive Claim Construction Brief, filed September 26, 2025 (Dkt. 79); • Defendants’ Reply Claim Construction Brief, filed October 20, 2025 (Dkt. 81); • Plaintiff Universal Connectivity Technologies Inc.’s Corrected Sur-reply Claim Construction Brief, filed November 20, 2025 (Dkt. 88); and • Plaintiff’s Notices of Supplemental Authority Regarding Claim Construction, filed November 7, 2025 (Dkt. 84) and November 24, 2025 (Dkt. 89). The Court held a Markman hearing on November 24, 2025 at which both parties appeared through counsel and now enters this order on claim construction. I. Background Plaintiff Universal Connectivity Technology (“UCT”) accuses Defendants Dell Technologies Inc. and Dell Inc. (“Dell”) of infringing eight Asserted Patents that generally relate to technologies for connecting and communicating between multiple devices, such as computers, mobile phones, or peripheral devices.1 The parties ask the Court to construe eighteen claim terms across seven of

1 U.S. Patent Nos. 7,154,905 (“’905 Patent”), 7,187,307 (“’307 Patent”), 7,746,798 (“’798 Patent”), 9,232,265 (“’265 Patent”), 8,680,712 (“’712 Patent”), 7,856,520 (“’520 Patent”), 7,921,231 (“’231 Patent”), and 9,852,103 (“’103 Patent”). the Asserted Patents. Thirteen of those terms were recently construed in co-pending litigation in the Eastern District of Texas set for trial February 6, 2026. Universal Connectivity Techs. Inc. v. Lenovo Grp. Ltd., No. 2:23-cv-00449-JRG (“Lenovo”), Dkt. 204 (E.D. Tex. Sept. 16, 2025), Dkt. 79-2 here. The Northern District of California then adopted all eight of those constructions it considered in another co-pending case set for trial September 21, 2026. Universal Connectivity

Techs. Inc. v. HP Inc., No. 5:24-cv-04097-NW (“HP”), Dkt. 197 (N.D. Cal. Nov. 7, 2025), Dkt. 84-1 here. II. Legal Standards A. Claim Construction Generally Claim terms are generally given their plain and ordinary meaning. Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2005) (en banc). The plain and ordinary meaning of a term is the “meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention.” Id.at 1313. The only two exceptions to this general rule are when the patentee acts as their own lexicographer or disavows the full scope of the claim term either in the specification or during prosecution. Thorner v. Sony Comput. Ent. Am. LLC, 669 F.3d 1362, 1365 (Fed. Cir. 2012). The “standards for finding lexicography and disavowal are exacting.” Hill-Rom

Servs., Inc. v. Stryker Corp., 755 F.3d 1367, 1371 (Fed. Cir. 2014). To act as their own lexicographer, the patentee must “clearly set forth a definition of the disputed claim term” and “clearly express an intent to redefine the term.” Thorner, 669 F.3d at 1365 (citations omitted). “Like the specification, the prosecution history provides evidence of how the PTO and the inventor understood the patent.” Phillips, 415 F.3d at 1317. “[D]istinguishing the claimed invention over the prior art, an applicant is indicating what a claim does not cover.” Spectrum Int’l, Inc. v. Sterilite Corp., 164 F.3d 1372, 1379 (Fed. Cir. 1998) (citation omitted). The doctrine of prosecution disclaimer precludes a patentee from recapturing a specific meaning that was previously disclaimed during prosecution. Omega Eng’g, Inc. v. Raytek Corp., 334 F.3d 1314, 1323 (Fed. Cir. 2003). Alleged disavowing actions or statements made during prosecution must be “both clear and unmistakable.” Id. at 1326. Accordingly, when “an applicant’s statements are amenable to multiple reasonable interpretations, they cannot be deemed clear and unmistakable.” 3M Innovative Props. Co. v. Tredegar Corp., 725 F.3d 1315, 1326 (Fed. Cir. 2013).

A construction of “plain and ordinary meaning” may be inadequate when a term has more than one “ordinary” meaning or when reliance on a term’s “ordinary” meaning does not resolve the parties’ dispute. O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1361 (Fed. Cir. 2008). In that case, the Court must describe what the plain and ordinary meaning is. Id. Extrinsic evidence can be useful but is “less significant than the intrinsic record in determining ‘the legally operative meaning of claim language.’” Phillips, 415 F.3d at 1317 (quoting C.R. Bard, Inc. v. U.S. Surgical Corp., 388 F.3d 858, 862 (Fed. Cir. 2004)). Expert testimony may be helpful, but not an expert’s conclusory or unsupported assertions as to the meaning of a term. Id. at 1318. B. Indefiniteness Indefiniteness “is a question of law and in effect part of claim construction.” ePlus, Inc. v.

Lawson Software, Inc., 700 F.3d 509, 517 (Fed. Cir. 2012). Patent claims must point out and distinctly claim the subject matter regarded as the invention. 35 U.S.C. § 112 ¶ 2. When viewed in light of the intrinsic evidence, a claim must “inform those skilled in the art about the scope of the invention with reasonable certainty.” Nautilus Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 910 (2014). If it does not, the claim fails § 112 ¶ 2 and is invalid as indefinite. Id. at 901. Whether a claim is indefinite is determined from the perspective of one of ordinary skill in the art as of the time the application was filed. Id. at 911. Indefiniteness requires clear and convincing evidence. Sonix Tech. Co., Ltd. v. Publ’ns Int’l, Ltd., 844 F.3d 1370, 1377 (Fed. Cir. 2017). C. Means-Plus-Function Under 35 U.S.C. § 112(f), a patentee may express a claim in terms of “means or step[s] for performing a specified function without the recital of structure, material, or acts in support thereof.” Such means-plus-function claims must “be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.” Id.

Section 112(f) allow[s] patentees to express a claim limitation by reciting a function to be performed rather than by reciting structure for performing that function, while placing specific constraints on how such a limitation is to be construed, namely, by restricting the scope of coverage to only the structure, materials, or acts described in the specification as corresponding to the claimed function and equivalents thereof. Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1347 (Fed. Cir. 2015) (en banc). Courts first must determine whether that limitation is a means-plus-function term subject to § 112(f). See id. at 1348; see also Phillips, 415 F.3d at 1311 (“Means-plus-function claiming applies only to purely functional limitations that do not provide the structure that performs the recited function.”). Generally, use of the term “means” creates a presumption that § 112(f) applies, while absence of the term “means” creates the opposite presumption. Williamson, 792 F.3d at 1349. A party may overcome either presumption by showing that the claims do or do not recite a “sufficiently definite structure” to adequately perform the claimed function. Id. In other words, § 112(f) applies only if “the claim term ‘fails to recite[ ] sufficiently definite structure’ or else recites ‘function without reciting sufficient structure for performing that function.’” Id. at 1348 (quoting Watts v. XL Sys., Inc., 232 F.3d 877, 880 (Fed. Cir. 2000)). If means-plus-function applies, the court engages in a two-step inquiry to construe the claim. The court must “identify the claimed function” first, then “determine what structure, if any, disclosed in the specification corresponds to the claimed function.” Id. at 1351. A structure corresponds to the claimed function if “the specification or the prosecution history clearly links or associates that structure to the function recited in the claim.” Noah Sys., Inc. v. Intuit Inc., 675 F.3d 1302, 1311 (Fed. Cir. 2012) (citation omitted). The corresponding structure “must include all structure that actually performs the recited function.” Default Proof Credit Card Sys. v. Home Depot U.S.A., Inc., 412 F.3d 1291, 1298 (Fed. Cir. 2005). Structure can be recited in various ways,

including by using “‘a claim term with a structural definition that is either provided in the specification or generally known in the art,’ or a description of the claim limitation’s operation and ‘how the function is achieved in the context of the invention.’” Dyfan, LLC v. Target Corp., 28 F.4th 1360, 1366 (Fed. Cir. 2022) (quoting Apple Inc. v. Motorola, Inc., 757 F.3d 1286, 1299 (Fed. Cir. 2005)). If the intrinsic evidence fails to disclose adequate corresponding structure, the claim is indefinite. Noah Sys., 674 F.3d at 1311-12. III. Analysis UCT asks the Court to adopt Judge Payne’s constructions of the disputed terms addressed in Lenovo, stating: “While UCT does not necessarily agree with all the constructions in the Lenovo Order, the Court should nonetheless adopt those constructions to promote consistency across

cases.” Dkt. 79 at 6. Dell argues that the Lenovo constructions “are incorrect as a matter of law and the Court should decline to adopt them.” Dkt. 81 at 7. While the court appointed a technical advisor in Lenovo and Judge Wise adopted the construction of each disputed term also construed in HP, the Court is mindful that the District Court for the Eastern District of Texas has not ruled on Lenovo’s objections to Judge Payne’s claim construction order. This Magistrate Judge has independently construed the disputed terms and carefully considered the parties’ arguments for and against the constructions in Lenovo. As did Judge Wise, this Magistrate Judge finds the Lenovo order to be “supported and well-reasoned” and construes most disputed terms consistently with it. Dkt. 84-1 at 15. A. Disputed Terms 1. “Logic to discover / detect” The first six disputed terms are recited in Claims 10 and 16 of the ’231 Patent. The parties do not dispute that they are means-plus-function terms subject to 35 U.S.C. § 112 ¶ 6. The claims are: 10. A transmitting device comprising: a transmitter to transmit signals to a receiving device; a cable interface to couple with the receiving device, the cable interface including: a single-wire, bi-directional control bus, and a power bus powered by the receiving device; logic to detect signals on the cable interface, the logic including: a first logic to detect a voltage value on the power bus, the transmitter to transition from a disconnect state to a pending state when a predetermined voltage is detected on the power bus by the first logic, the disconnect state indicating that the transmitting device is not connected to a receiving device, and a second logic to detect signals on the control bus, the transmitter to drive a first signal value on the control bus periodically upon transitioning to the pending state, the transmitter to transition to a discovered state when the first signal value is detected by the second logic when the transmitter is not driving the signal value on the control bus, the discovered state indicating that the transmitter has been discovered by the receiving device. 16. A receiving device comprising: a receiver to receive signals from a transmitting device; an interface to be coupled with a transmitting device, the interface including a single- wire control bus and a power bus, the receiving device to enable a voltage potential of a predetermined value on the power bus and to drive a signal on the control bus at a first signal value in a disconnect state, the disconnect state indicating that the receiving device is not connected to a transmitting device; and a switchable pull down circuit on the control bus; logic to discover a transmitting device coupled with the receiving device, wherein the logic includes: a first logic to detect a first signal on the control bus, the receiving device to discover a first type of transmitting device and transition to a first state when the first signal is detected, the receiving device to enable the switchable pull down circuit on the control bus and disable hot plug functionality upon discovering the first type of transmitting device, and a second logic to detect a power signal from the receiving device, the receiving device to discover a second type of transmitting device and transition to a second state when the power signal is detected. ’231 Patent at 12:52-13:7, 13:23-14:11, Dkt. 1-21 at 21-22 (emphasis added). Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’231 Patent, claim 10 Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus-function and dependent claims Function: detect signals on the limitation under 35 U.S.C. § 112(6) 11-14 cable interface Function: Detecting signals on the Structure: The corresponding cable interface “logic to detect signals structure is defined by the Corresponding structure: on the cable interface” subparts of the limitation Because the patent fails to disclose adequate corresponding structure, this limitation is indefinite ’231 Patent, claim 10 Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus-function and dependent claims Function: detect a voltage limitation under 35 U.S.C. § 112(6) 11-14 value on the power bus Function: Detecting a voltage Structure: a voltage detector value on the power bus “a first logic to detect with an input connected to the Corresponding structure: a voltage value on the pin of the transmitter that is Because the patent fails to disclose power bus…” connected to the power bus, adequate corresponding structure, and equivalents thereof this limitation is indefinite ’231 Patent, claim 10 Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus-function and dependent claims Function: detect signals on the limitation under 35 U.S.C. § 112(6) 11-14 control bus Function: Detecting signals on the Structure: a voltage detector control bus “a second logic to with an input connected to the Corresponding structure: detect signals on the pin of the transmitter that is Because the patent fails to disclose control bus…” connected to the control bus, adequate corresponding structure, and equivalents thereof this limitation is indefinite ’231 Patent, claim 16 “logic to discover” This term is a means-plus-function and dependent claims Structure: The corresponding limitation under 35 U.S.C. § 112(6) 17, 18 structure is defined by the Function: Discovering a subparts of the limitation transmitting device coupled with “logic to discover a the receiving device transmitting device Corresponding structure: coupled with the Because the patent fails to disclose receiving device” adequate corresponding structure, this limitation is indefinite Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’231 Patent, claim 16 Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus-function and dependent claims Function: Detect a first signal limitation under 35 U.S.C. § 112(6) 17, 18 on the control bus Function: Detecting a first signal Structure: a voltage detector on the control bus “a first logic to detect with an input connected to the Corresponding structure: a first signal on the pin of the receiver that is Because the patent fails to disclose control bus” connected to the control bus, adequate corresponding structure, and equivalents thereof this limitation is indefinite ’231 Patent, claim 16 Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus-function and dependent claims Function: detect a power limitation under 35 U.S.C. § 112(6) 17, 18 signal from the receiving Function: Detecting a power signal [transmitting] device from the transmitting device. “a second logic to Structure: a voltage detector Corresponding structure: detect a power signal with an input connected to the Because the patent fails to disclose from the transmitting pin of the receiver that is adequate corresponding structure, device…” connected to a power signal this limitation is indefinite line, and equivalents thereof

UCT’s proposed construction is the construction adopted in both Lenovo and HP. Dell contends that the limitations are indefinite because the patent fails to disclose adequate corresponding structure. Dell argues that the only question pertinent to construction of these claims is whether the patent discloses a voltage detector, which is not mentioned in the ’231 Patent. UCT responds that (1) Judge Wise rejected the same argument in HP, (2) “voltage detector” is a well- known term, and (3) neither of the two courts to construe these terms resorted to expert or other extrinsic evidence. Lenovo, Dkt. 79-2 at 33; HP, Dkt. 84-1 at 12-14. As for “a first logic to detect a voltage value on the power bus,” Judge Payne reasoned: There is corresponding structure. Clearly, this logic must involve some hardware because it detects a voltage on a bus. And while the transmitter is a separate element of the claims, the specification is clear that the “logic” is part of the transmitter. See ’231 Patent at 3:24-26 (“[A] transmitting device and a receiving device each further include logic to detect power signals that are received.”), 8:55-59 (“[T]he HDMI transmitter chip 812 and HDMI-E receiver chip 832 include logic to detect signals on the control bus.”). Given this disclosure and the figures, a skilled artisan would understand the “logic to detect” to be a voltage detector internal to the transmitter chip and connected to an input pin of the transmitter. The output of the detector, which is internal to the transmitter chip, provides the indication of whether the voltage has been detected. Accordingly, the Court holds the corresponding structure to be “a voltage detector with an input connected to the pin of the transmitter that is connected to the power bus, and equivalents thereof.” Lenovo, Dkt. 79-2 at 33. While Dell of course is correct that “voltage detector” does not appear in the ’231 Patent, the Court agrees that the claims recite a “sufficiently definite structure” to adequately perform the claimed function. As Judge Payne explained, there is not a “total absence of structure” in the specification, distinguishing this case from Default Proof, 412 F.3d at 1302. The Court holds that the corresponding structure is defined by the subparts of the limitation. The Court finds that the patent discloses corresponding structure for all six related “logic” terms and construes each consistently with Judges Payne and Wise. 2. “Logic to convert” As Judge Payne noted in Lenovo, the parties have similar disputes over “logic to . . .” terms from Claims 12 and 19 of the ’520 Patent, reciting transmitting and receiving devices, respectively: 12. A transmitting device comprising: a connection to a single first control bus, the first control bus being a bi-directional, single-line bus, wherein the transmitting device is operable for coupling with a receiving device via the first control bus; logic to convert each of one or more control signals into a data packet, each of the one or more control signals being one of a plurality of different types of control signals for a standard protocol, each data packet including a plurality of bits to be transmitted; a transmitter, the transmitter to transmit the data packets to the receiving device on the first control bus; and logic to arbitrate use of the first control bus, the logic to arbitrate use being operable to: determine whether the control bus is in use by the receiving device, and if the first control bus is not in use by the receiving device, conduct arbitration for control of the first control bus, and wherein the receiving device is a device utilizing the standard protocol and the transmitting device is a mobile device utilizing a modified protocol, the modified protocol being a modification of the standard protocol that is not included in the standard protocol. ’520 Patent at 12:28-51, Dkt. 1-17 at 18 (emphasis added). 19. A receiving device comprising: a connection to a single first control bus, the first control bus being a bi-directional, single-line bus, wherein the receiving device is operable for coupling with a transmitting device via the first control bus; a receiver to receive one or more data packets on the first control bus, each of the one or more data packets representing one of a plurality of different types of control signals; logic to convert each of the one or more data packets into a control signal; and logic to arbitrate use of the first control bus, the logic to arbitrate use being operable to: determine whether the control bus is in use by the transmitting device, and if the first control bus is not in use by the transmitting device, conduct arbitration for control of the first control bus, and wherein the receiving device is a device utilizing the standard protocol and the transmitting device is a mobile device utilizing a modified protocol, the modified protocol being a modification of the standard protocol that is not included in the standard protocol.2 ’520 Patent at 13:6-14:3, Dkt. 1-17 at 19 (emphasis added). Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, Subject to 35 U.S.C. § 112 ¶ 6 This term is means-plus- asserted claim 12 Function: convert each of one or more function limitations under and dependent control signals into a data packet, each of 35 U.S.C. § 112(6) claims 13, 15, 18 the one or more control signals being one Function: Converting each of a plurality of different types of control of one or more control “logic to convert signals for a standard protocol, each data signals into a data packet. each of one or packet including a plurality of bits to be Corresponding structure: more control transmitted Because the patent fails to signals into a Structure: a general-purpose processor, disclose adequate data packet” special-purpose processor, or logic-circuit corresponding structure, this programmed to form control signal bytes limitation is indefinite into data packets that include (1) a header field indicating the type of the packet, and (2) a control field identifying whether the packet is carrying data or a command, and equivalents thereof

2 The parties’ disputes over the standard and modified protocol claims shown in bold are addressed below. Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, Subject to 35 U.S.C. § 112 ¶ 6 This term is means-plus- asserted claim 19 Function: convert each of the one or more function limitations under and dependent data packets into a control signal 35 U.S.C. § 112(6) claim 25 Structure: a general-purpose processor, Function: Converting each special-purpose processor, or logic circuit of the one or more data “logic to convert programmed to (1) identify the packet type packets into a control signal. each of the one from a header of a received packet, and Corresponding structure: or more data (2) identify whether the packet is data or a Because the patent fails to packets into a command from a control field of the disclose adequate control signal” received packet, and equivalents thereof corresponding structure, this limitation is indefinite

Judge Payne reviewed Figures 7 and 8 in the ’520 Patent, along with the explanations in the patent of how commands are transferred between standard HDMI and HDMI-M devices by mapping standard protocols using a translation layer. Based on this analysis, the Court holds the corresponding structure for the “logic to convert” limitation of Claim 12 to be “a general-purpose processor, special-purpose processor, or logic circuit programmed to form control signal bytes into data packets that include (1) a header field indicating the type of the packet, and (2) a control field identifying whether the packet is carrying data or a command, and equivalents thereof.” The reverse is true for Claim 19, for which the Court holds the corresponding structure is “a general-purpose processor, special-purpose processor, or logic circuit programmed to (1) identify the packet type from a header of a received packet, and (2) identify whether the packet is data or a command from a control field of the received packet, and equivalents thereof.” Lenovo, Dkt. 79-2 at 28. Dell argues that this construction merely restates the function associated with the limitation without disclosing an algorithm. Noah, 675 F.3d at 1316-17 (“[P]urely functional language, which simply restates the function associated with the means-plus-function limitation, is insufficient to provide the required corresponding structure.”). UCT replies that Lenovo both identified the relevant structures and included the necessary steps for performing the “logic to convert” functionality in the claims. The Court agrees with the well-supported analysis in Lenovo and adopts those constructions of the “logic to convert” claims for the reasons explained in that order. 3. “Logic to arbitrate” Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, asserted claims 12 and Subject to 35 U.S.C. § 112 These terms are means- dependent claims 13, 15, 18; asserted ¶ 6 plus-function limitations claim 19 and dependent claim 25 Function: to arbitrate use under 35 U.S.C. § 112(6) of the first control bus, the Function (claims 12 and “logic to arbitrate use of the first logic to arbitrate use being 19): arbitrate use of the control bus, the logic to arbitrate use operable to: [i] determine first control bus by being operable to: whether the control bus is determining whether the determine whether the control bus is in use by the receiving control bus is in use by in use by the receiving device, and device [/ transmitting the receiving device if the first control bus is not in use by device], and [ii] if the first [/ transmitting device] the receiving device, conduct control bus is not in use by and, if the first control arbitration for control of the first the receiving device bus is not in use by the control bus” (claim 12) [/ transmitting device], receiving device “logic to arbitrate use of the first conduct arbitration for [/ transmitting device], control bus, the logic to arbitrate use control of the first control conducting arbitration for being operable to: bus control of the first control Structure: a general- bus. determine whether the control bus is purpose processor, special- Corresponding in use by the transmitting device, and purpose processor, or logic structure: Because the if the first control bus is not in use by circuit programmed with patent fails to disclose the transmitting device, conduct instructions to perform adequate corresponding arbitration for control of the first Steps 304-322 of Figure 3, structure, this limitation control bus” (claim 19) and equivalents thereof is indefinite

Dell argues that UCT’s construction, in which hardware is programmed with software that performs an algorithm, is indefinite because the algorithm is indefinite. Dell contends that the step in Box 306 of Fig. 3, which determines the next step based on whether “CBUS [is] idle or unused for ≥ n cycles,” is indefinite because the specification provides no guidance on the value of n. UCT responds that n simply means that the invention can be implemented by choosing any number of cycles. However, once the chosen number of cycles passes, the same exact arbitration steps (i.e., algorithm) are implemented and the scope of the algorithm is not impacted by whether the arbitration process begins after 2 cycles or 4 cycles, for example. Dkt. 79 at 15. The ’520 Patent “plainly explains that ‘n’ refers to a ‘certain number of cycles,’” UCT argues, and “the same algorithm and steps are followed in Figure 3 irrespective of the number that is input as” n. Dkt. 83 at 7, 8.

Transmitter and receiver are connected to bi-directional single-bit control bus 302|

Determination of the status of CBUS 304]

CBUS idle or unused No Bus is in use by other for 21 device 3 cycles? 308 306 Yes Arbitrate bus usage 310

□□ ceoest RX drives bus low for 1" cycle,

Check signal during 2-4 cycles 318

No CBUS high? 320 ' Yes RX takes control of bus ' 322) !

Fig. 3 Dkt. 1-17 at 6. Dell argues that Judge Payne did not consider this issue because Lenovo did not raise it and because the ’520 Patent is no longer in HP, no court has considered it. Although Judge Payne did not consider this issue, the Court finds that Dell has not shown it changes the Lenovo analysis. The Court adopts Judge Payne’s and UCT’s proposed construction.

4. “Preemption component” Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’905 Patent, asserted Plain and ordinary meaning. This term is a means-plus- claim 21 and dependent This claim term does not invoke function limitation under 35 claims 22, 23, 26 §112(6) U.S.C. § 112(6) Alternatively, should §112(6) Function: signaling the “a preemption component apply: transmission component to that signals the Function: “signals the stop transmitting the first transmission component transmission component to stop packet, transmitting a preempt to stop transmitting the transmitting the first packet, indicator indicating that a first packet, transmits a transmits a pre-empt indicator second packet is to be preempt indicator indicating that a second packet is transmitted, transmitting the indicating that a second to be transmitted, transmits the second packet, and signaling packet is to be second packet, and signals the the transmission component transmitted, transmits the transmission component to to continue transmitting the second packet, and signals continue transmitting the first first packet the transmission packet” Corresponding structure: component to continue Corresponding structure: Because the patent fails to transmitting the first “20:3- 25, Fig. 13 and 20:31-37, disclose adequate packet” Fig. 14 and 20:50-67, and corresponding structure, this equivalents thereof” limitation is indefinite

The term “preemption component” appears only in Claim 21 of the ’905 Patent: 21. A communications device for transmitting packets via a communications link, comprising: a transmission component that transmits a first packet; and a preemption component that signals the transmission component to stop transmitting the first packet, transmits a preempt indicator indicating that a second packet is to be transmitted, transmits the second packet, and signals the transmission component to continue trans mitting the first packet; wherein packets include in-band symbols and the indicators include one or more out- of-band symbols. ’905 Patent at 39:18-40:7, Dkt. 1-1 at 82. The parties dispute whether “a preemption component” is a means-plus-function term. The Court agrees with the Lenovo and HP decisions that it is not. First, the Court presumes that § 112(f) does not apply because the claim does not use the word “means.” Williamson, 792 F.3d at 1349. Second, the claim recites acts to perform entirely what the recited function would have been. Cochlear Bone Anchored Sols. AB v. Oticon Med. AB, 958 F.3d 1348, 1360 (Fed. Cir. 2020). The Court construes this term in accordance with its plain and ordinary meaning. 5. “Identification component”

Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’798 Patent, asserted Subject to 35 U.S.C. § 112 ¶ 6 This term is a means-plus- claim 19 and dependent Function: identifies a packet type of function limitation under claims 20-26, 28 a packet of symbols 35 U.S.C. § 112(6) Structure: “a general-purpose Function: Identifying a “an identification processor, special-purpose packet type of a packet of component that identifies processor, or logic circuit symbols a packet type of a packet programmed to determine whether Corresponding of symbols” the packet was removed from a structure: Because the control queue or a data queue, and patent fails to disclose send an indication of whether the adequate corresponding packet was removed from the structure, this limitation is control queue or the data queue to indefinite the transport layer”

Once again, the parties now do not dispute that this is a means-plus-function claim. The “identification component” term appears in claim 19 of the ’798 Patent: 19. A communications device for transmitting packet types of packets, comprising: an identification component that identifies a packet type of a packet of symbols; and a transmission component that transmits a synchronization symbol that corresponds to the identified packet type, the transmitted synchronization symbol providing synchronization information and each packet type having a different synchronization symbol and permitting an external receiving node to properly align with a synchronization primitive to be correctly aligned on a symbol boundary, and that transmits the symbols of the packet. ’798 Patent at 38:22-33, Dkt. 1-10 at 80. Judges Payne and Wise relied on Figure 12 to identify the corresponding structure that “identifies a packet type of a packet of symbols.” C Select Packet ? 1201 1202 Kags N__| retreive packet from Control Queue 1203 ___ 1204 N retrieve packet from |_| empty Data Queue

1205 packet 1206 □ already selected 1207 send selected symbol

Fig. 12 Dkt. 1-10 at 16. Consistent with Lenovo and HP, the Court construes the term “an identification component that identifies a packet type of a packet of symbols” as having the function of “identifies a packet type of a packet of symbols and the structure of “‘a general-purpose processor, special-purpose processor, or logic circuit programmed to determine whether the packet was removed from a control queue or a data queue, and send an indication of whether the packet was removed from the control queue or the data queue to the transport layer.” 6. “Application data and control bits” This term was not construed in Lenovo or HP. It is used throughout the ’307 Patent, beginning with the abstract reciting: A communication system including two endpoints (transceivers or a transmitter and receiver) and a serial link between them. At least one endpoint is configured to generate encoded data in accordance with a line code and to transmit the encoded data over the link. The line code specifies a block code for encoding cells of application data and control bits, and typically also special characters that do not match bit sequences of encoded cells. Dkt. 1-7 at 2.

ose PSP a el IPSCO IXeneZT Patent, all asserted claims No construction The application data and necessary control bits are not encoded as “application data and control bits” special characters UCT contends that no construction is necessary, while Dell argues that this is insufficient, citing O2 Micro, 521 F.3d at 1361. Relying on the specification and prosecution history, Dell proposes a construction specifying that the application data and control bits are not encoded as special characters. The Court agrees that the claims, specification, and prosecution history support Dell’s proposed construction. In particular, in its preliminary response to a petition for inter partes review (“IPR”) filed by HP, Dell, and Lenovo, UCT explained that “special characters” are distinguished from “application data and control bits”: IPR2024-01429 U.S. Patent No. 7,187,307 10s. 20. x AX a journos 2 2 43 J contrat “4 i OTA CONTROL mm CONTROL | CONTROL pu Cl ) RECT \ | ONTROL 5 a 2 42 at omnes 40 FIG. 1 EX1001, Fig. 1; EX2001 at {§19-22. The packetizing circuitry at the transmitter generates sequences of input words indicative of application data and control bits. EX 1001, Figs 1 and 2, 10:20-39, 10:46-49; EX2001 at 922. The encoding circuitry at the transmitter encodes the input words into a sequence of code words according to a block code specified by a line code. EX 1001, Fig. 2, 11:45-47, 11:66-12:2; EX2001 at 422. The line code also specifies certain special characters which are distinguished from the code words. EX1001, 10: 46-51; EX2001 at 422. These special characters are also transmitted over the link, but they are not encoded with the codewords. EX2001 at 422. Dkt. 77-14 at 5.

UCT contends that Dell seeks to import extraneous limitations into the construction, arguing: “While ‘special characters’ may be separate from ‘application and control bits’ in some exemplary embodiments, that does not mean that the ‘application and control bits’ must always be separate and cannot be encoded as ‘special characters.’” Dkt. 83 at 12. UCT also argues that the patent’s independent claims should not be narrowed by importing “special characters” found only in the

dependent claims. But, as Dell argues, “application data and control bits” and “special characters” are separate claim elements “and every claim is consistent with the specification’s teaching that the former are not encoded as the latter.” Dkt. 81 at 19. There is no teaching in the intrinsic record to the contrary, and that is consistent with the plain meaning of the terms in the art. Id. at 18. For these reasons, the Court adopts Dell’s proposed construction. 7. “AV sink / source operation mode” This term was not construed in Lenovo or HP. The ’265 Patent, a “method, apparatus and system for transitioning an audio/video device between a source mode and a sink mode,” recites

AV source and sink operation modes for providing AV information to and receiving AV information from another device, respectively. Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’265 Patent, all asserted Plain and ordinary meaning. A mode in which the AV claims No further construction device receives (but does not necessary provide) power and receives “AV sink operation mode” and (but does not send) data “AV source operation mode”

The Court agrees with UCT that “[b]ecause the claims already delineate the required functionality for the recited ‘AV sink operation mode’ and ‘AV source operation mode,’ the plain and ordinary meaning controls and no construction is necessary.” Dkt. 79 at 25. No clarification is necessary, and the Court construes these terms according to their plain and ordinary meaning. 8. “Mobile device” This term also was not construed in Lenovo or HP.

Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, all “any mobile electronic A cellular telephone, smartphone, PDA asserted claims & device” (personal digital device), MP3 or other format ’231 Patent, music player, digital camera, video recorder, claim 14 digital storage device, and other similar devices (i.e. portable devices smaller than a standard “mobile device” device such as a personal computer or monitor)

The crux of this dispute is whether “mobile device” as used in the ’520 and ’231 Patents, both filed in 2008, includes personal computers and monitors. During the Markman hearing, counsel for Dell stated that this dispute is significant because personal computers and monitors are “the vast majority of accused products.” UCT argues that Dell’s construction would improperly narrow the universe of “mobile devices.” The patents define “mobile device” as follows: “Mobile device” means any mobile electronic device. The term ‘mobile device’ includes, but it not limited to, a cellular telephone, smartphone, PDA (personal digital device), MP3 or other format music player, digital camera, video recorder, digital storage device, and other similar devices.” ’520 Patent at 2:36-40, Dkt. 1-17 at 13; ’231 Patent at 2:50-54, Dkt. 1-21 at 15. They mention personal computers only once, distinguishing them from “portable devices.” ’520 Patent at 2:61- 3:2, Dkt. 1-17 at 13-14; ’231 Patent at 3:3-12, Dkt. 1-21 at 16 (stating that the HDMI-M device may . . . utiliz[e] USB-OTG [], a standard for portable devices that allows dual-mode operation in which a device may be connected to a personal computer or to another portable device”). The ’231 Patent also identify monitors as “standard” rather than mobile devices.’231 Patent at 2:65-3:1, Dkt. 1-21 at 15-16. As modified during the hearing, Dell’s proposed construction is: “Any mobile electronic device including but not limited to a cellular telephone, smartphone, PDA (personal digital device), MP3 or other format music player, digital camera, video recorder, digital storage device, and other similar devices (i.e. portable devices smaller than a standard device such as a personal computer or monitor).” The Court finds that this construction is consistent with the teaching in the patents.

9. “Standard / modified protocol” As shown in the excerpts above, all asserted claims of the ’520 Patent use the terms “standard protocol” and “modified protocol.” UCT proposes the Lenovo constructions, while Dell proposes limiting these claims to protocols in effect at the time of invention, citing PC Connector Sols. LLC v. SmartDisk Corp., 406 F.3d 1359, 1363 (Fed. Cir. 2005). Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, all “a standardized A communication protocol that was standardized asserted claims communication as of the January 4, 2008 filing date of the ’520 protocol” patent. A device utilizing the standard protocol “standard protocol” communicates over multiple control buses ’520 Patent, all “a modification of A communication protocol that is a modification asserted claims the standard of the standard protocol, that was defined as of the protocol that is not January 4, 2008 filing date of the ’520 patent. A “modified protocol” included in the device utilizing the modified protocol standard protocol” communicates over one (and only one) control bus

In Lenovo, Judge Payne rejected the argument Dell makes here, reasoning: The key difference from PC Connector is the temporal frame of reference between the two terms. Here, “standard” is not used by itself, but rather in juxtaposition to “modified,” and the use of the latter in combination with the former emphasizes that what matters in these claims is not the protocol itself, but the difference between the two related versions of the same protocol. In other words, unlike the patent at issue in PC Connector, the specifics of any protocol are unimportant to the claim. Accordingly, the Court holds the use of “standard protocol” and “modified protocol” are not limited to protocols in existence on the filing dates of the patent and construes these terms as “a standardized communication protocol” and “a modification of the standard protocol that is not included in the standard protocol,” respectively. Dkt. 79-2 at 43-44. Similarly, UCT argues that “the claims and specification use the term ‘modified protocol’ as a relative term in comparison to a ‘standard protocol,’ which is not inherently time- limited.” Dkt. 79 at 28. The number of control buses for each protocol, addressed in the second sentence of each of Dell’s proposed constructions, was not raised in Lenovo. Dell argues that UCT defined the number

of control buses as “characteristic” of each protocol in the IPR. Dkt. 77-28 at 3-4. UCT responds that Dell identifies no lexicography or disavowal supporting its limitations. Dkt. 79 at 30. Alone among the terms construed in Lenovo, this Magistrate Judge does not construe the temporal issue consistently with that decision or accept UCT’s argument that “standard” and “modified” have meaning only in relationship to each other. The Federal Circuit has consistently held that a claim’s meaning “must be interpreted as of its effective filing date.” PC Connector, 406 F.3d 1359, 1363; see also Aylus Networks, Inc. v. Apple Inc., 856 F.3d 1353, 1358 (Fed. Cir. 2017) (“The purpose of claim construction is to give claim terms the meaning understood by a person of ordinary skill in the art at the time of invention.”); BillJCo, LLC v. Cisco Sys., Inc., No. 2:21-cv-

00181-JRG, 2022 WL 782740, at *5 (E.D. Tex. Mar. 14, 2022) (collecting cases). But the Court does agree with UCT that its argument in the IPR that the number of control buses is a “characteristic” of each protocol is not a “clear and unmistakable” disclaimer. 3M Innovative Props., 725 F.3d at 1326. While Dell may attempt to prove that the relevant “standard” and “modified” protocols have multiple buses or only one bus, respectively, the ’520 Patent is not limited to those embodiments. Accordingly, the Court construes “standard protocol” as “a communication protocol that was standardized as of the January 4, 2008 filing date of the ’520 patent” and “modified protocol” as “a communication protocol that is a modification of the standard protocol, that was defined as of the January 4, 2008 filing date of the ’520 patent.” 10. “The modified protocol being a modification of . . . ” Disputed Term Plaintiff’s Proposal Defendant’s Proposal ’520 Patent, all asserted claims No construction necessary Indefinite

“the modified protocol being a modification of the standard protocol that is not included in the standard protocol”

This term was not construed in Lenovo or HP, and the parties offer conflicting expert evidence whether it would confuse a POSITA. UCT’s expert, Dr. Vijay Madisetti, opines that the specifications show the phrase is well-understood by a POSITA, describing the HDMI protocol as an exemplary “standard protocol” and USB as an exemplary “modified protocol” over which HDMI communications can occur. Dkt. 79-3 ¶¶ 73-75. Dell responds that “a POSITA would not understand USB to be ‘a modification of’ HDMI, which was developed after and independently from USB.” Dkt. 77 at 35. Dell’s expert, Steve Novak, explains in detail why the disputed phrase “recites two incompatible requirements of the ‘modified protocol.’” Dkt. 77-8 ¶ 311; see also id. at ¶¶ 306-22. The Court agrees with Dell that the term “the modified protocol being a modification of the standard protocol that is not included in the standard protocol” is indefinite “because a POSITA cannot reasonably ascertain what it means for one protocol to be both ‘a modification of’ and ‘not included in’ a second protocol or what qualifies as a sufficient modification.” Dkt. 81 at 23. 11. “First physical channel” Finally, the Court addresses another disputed term not construed in Lenovo or HP. Disputed Term Plaintiff’s Proposal Defendant’s Proposal 11 ’103 Patent, all asserted “a physical path for A Transition-Minimized claims transmitting electrical Differential Signaling signals” (TMDS) channel “first physical channel” The °103 Patent claims recite two physical channels: a “first physical channel” for video data and USB data and a “distinct” “second physical channel” for control data. Dkt. 1-24. The specification describes the “first physical channel” only as a “transition-minimized differential signaling (TMDS) channel.” See, e.g.,°103 Patent at Figs. 1, 5, Dkt. 1-24 at 4, 8: □ 100

Source Device 110 Sink Device 120 Multimedia Link } ' 134 1 Receiver 112 TX-PLL TX-PLL | 126 Control Logic 1 Logic 114 1 | 124 Clock \ i Clock : :

FIG. 1

500 Source Device Sink Device 110 1 120 ! Send from a source device a first unit I Receive by a sink device a first unit of of data(Forward Data) compliant with a t data (Forward Data) compliant with a USB standard over a first physical I USB standard over a first physical channel (TMDS) during a first time toa I channel (TMDS) during a first time sink device \ from a source device 505 □ 510 ! Receive by a source device a second 1 Send from a sink device a second unit unit of data (Backward Data) compliant | of data (Backward Data) compliant with with a USB standard over a first a USB standard over a first physical physical channel (TMDS) during a i channel (TMDS) during a second time second time from a sink device \ to a source device 220 \ ! Send from a source device control data i Receive by a sink device control data over a second physical channel I over a second physical channel (eCBUS) to a sink device ' (eCBUS) from a source device 525 ! 530 !

FIG. 5 Dell contends that there was a prosecution disclaimer by the applicant who “described the invention as a TMDS channel” in an interview with the examiner before allowance, Dkt. 77-31 at 9, and that the examiner allowed the claims based on the TMDS channel requirement, id. at 31, 33

(“The primary reason for allowance of claims 1, 12, 23 and 24 in the instant application is that prior arts do not teach a TMDS channel that’s transmitting video in only one direction and transmitting USB data bidirectionally at a higher bandwidth.”) (emphasis added). UCT argues that the ’103 Patent never limits the first physical channel to only a TMDS channel and that the patent applicant never made a clear and unmistakable disclaimer.

At the Markman hearing, the parties agreed that Aylus provides the proper analysis for this dispute: Prosecution disclaimer “preclud[es] patentees from recapturing through claim interpretation specific meanings disclaimed during prosecution.” Omega, 334 F.3d at 1323. “[F]or prosecution disclaimer to attach, our precedent requires that the alleged disavowing actions or statements made during prosecution be both clear and unmistakable.” Id. at 1325-26. “Thus, when the patentee unequivocally and unambiguously disavows a certain meaning to obtain a patent, the doctrine of prosecution history disclaimer narrows the meaning of the claim consistent with the scope of the claim surrendered.” Biogen Idec, Inc. v. GlaxoSmithKline LLC, 713 F.3d 1090, 1095 (Fed. Cir. 2013). Such disclaimer can occur through amendment or argument. See Standard Oil Co. v. Am. Cyanamid Co., 774 F.2d 448, 452 (Fed. Cir. 1985). In Standard Oil, we explained, in the context of disclaimer, that the prosecution history “includes all express representations made by or on behalf of the applicant to the examiner to induce a patent grant . . . includ[ing] amendments to the claims and arguments made to convince the examiner.” Id. . . . Ultimately, the doctrine of prosecution disclaimer ensures that claims are not “construed one way in order to obtain their allowance and in a different way against accused infringers.” Southwall Techs., Inc. v. Cardinal IG Co., 54 F.3d 1570, 1576 (Fed. Cir. 1995). Aylus, 856 F.3d at 1359-60. The parties agree, as they must, that “it is the applicant, not the examiner, who must give up or disclaim subject matter that would otherwise fall within the scope of the claims.” Sorensen v. Int’l Trade Comm’n, 427 F.3d 1375, 1379 (Fed. Cir. 2005) (citation omitted). And the Court agrees with UCT that the applicant’s silence in response to the examiner’s unilateral reasons for allowance cannot, “without more,” amount to a clear and unmistakable disavowal of claim scope. Salazar v. Procter & Gamble Co., 414 F.3d 1342, 1345 (Fed. Cir. 2005). The question is whether Dell is correct in arguing that the applicant’s own description of the invention as a TDMS channel in an interview summarized by the examiner is sufficient to constitute a disclaimer. Having carefully considered the cases the parties cite, the Court applies Federal Circuit precedent to find that the record shows the examiner and the applicant understood the “first physical channel” to be a TMDS channel. ACCO Brands, Inc. v. Micro Sec. Devices,

Inc., 346 F.3d 1075, 1079 (Fed. Cir. 2003) (“Although there is no obligation to respond to an examiner’s state of Reasons for Allowance, and the statement of an examiner will not necessarily limit a claim, in this case the examiner simply repeated the arguments that the patentee had presented.”) (citation omitted). For these reasons, the Court finds that the applicant made a clear and unmistakable disclaimer and adopts Dell’s construction. B. Conclusion The Court adopts the below constructions as its final constructions.

Disputed Term Court’s Ruling 1A ’231 Patent, claim 10 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 11-14 Function: detect signals on the cable interface Structure: The corresponding structure is defined “logic to detect signals on the by the subparts of the limitation cable interface” 1B ’231 Patent, claim 10 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 11-14 Function: detect a voltage value on the power bus Structure: a voltage detector with an input “a first logic to detect a voltage connected to the pin of the transmitter that is value on the power bus…” connected to the power bus, and equivalents thereof 1C ’231 Patent, claim 10 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 11-14 Function: detect signals on the control bus Structure: a voltage detector with an input “a second logic to detect signals connected to the pin of the transmitter that is on the control bus…” connected to the control bus, and equivalents thereof 1D ’231 Patent, claim 16 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 17, 18 The corresponding structure is defined by the subparts of the limitation “logic to discover a transmitting device coupled with the receiving device” Disputed Term Court’s Ruling 1E ’231 Patent, claim 16 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 17, 18 Function: detect a first signal on the control bus Structure: a voltage detector with an input “a first logic to detect a first connected to the pin of the receiver that is connected signal on the control bus” to the control bus, and equivalents thereof 1F ’231 Patent, claim 16 and Subject to 35 U.S.C. § 112 ¶ 6 dependent claims 17, 18 Function: detect a power signal from the receiving [transmitting] device1 “a second logic to detect a power Structure: a voltage detector with an input signal from the transmitting connected to the pin of the receiver that is connected device…” to a power signal line, and equivalents thereof 2A ’520 Patent, asserted claim 12 Subject to 35 U.S.C. § 112 ¶ 6 and dependent claims 13, 15, 18 Function: convert each of one or more control signals into a data packet, each of the one or more “logic to convert each of one or control signals being one of a plurality of different more control signals into a data types of control signals for a standard protocol, each packet” data packet including a plurality of bits to be transmitted Structure: a general-purpose processor, special- purpose processor, or logic-circuit programmed to form control signal bytes into data packets that include (1) a header field indicating the type of the packet, and (2) a control field identifying whether the packet is carrying data or a command, and equivalents thereof 2B ’520 Patent, asserted claim 19 Subject to 35 U.S.C. § 112 ¶ 6 and dependent claim 25 Function: convert each of the one or more data packets into a control signal “logic to convert each of the one Structure: a general-purpose processor, special- or more data packets into a purpose processor, or logic circuit programmed to control signal” (1) identify the packet type from a header of a received packet, and (2) identify whether the packet is data or a command from a control field of the received packet, and equivalents thereof Disputed Term Court’s Ruling 3 ’520 Patent, asserted claims 12 Subject to 35 U.S.C. § 112 ¶ 6 and dependent claims 13, 15, 18; Function: to arbitrate use of the first control bus, the asserted claim 19 and dependent logic to arbitrate use being operable to: [i] determine claim 25 whether the control bus is in use by the receiving device [/ transmitting device], and [ii] if the first “logic to arbitrate use of the first control bus is not in use by the receiving device control bus, the logic to arbitrate [/ transmitting device], conduct arbitration for use being operable to: control of the first control bus determine whether the control Structure: a general-purpose processor, special- bus is in use by the receiving purpose processor, or logic circuit programmed with device, and instructions to perform Steps 304-322 of Figure 3, and equivalents thereof if the first control bus is not in use by the receiving device, conduct arbitration for control of the first control bus” (claim 12)

“logic to arbitrate use of the first control bus, the logic to arbitrate use being operable to:

determine whether the control bus is in use by the transmitting device, and

if the first control bus is not in use by the transmitting device, conduct arbitration for control of the first control bus” (claim 19) 4 ’905 Patent, asserted claim 21 Plain and ordinary meaning and dependent claims 22, 23, 26

“a preemption component that signals the transmission component to stop transmitting the first packet, transmits a preempt indicator indicating that a second packet is to be transmitted, transmits the second packet, and signals the transmission component to continue transmitting the first packet” Disputed Term Court’s Ruling 5 ’798 Patent, asserted claim 19 Subject to 35 U.S.C. § 112 ¶ 6 and dependent claims 20-26, 28 Function: identifies a packet type of a packet of symbols “an identification component that Structure: a general-purpose processor, special- identifies a packet type of a purpose processor, or logic circuit programmed to packet of symbols” determine whether the packet was removed from a control queue or a data queue, and send an indication of whether the packet was removed from the control queue or the data queue to the transport layer 6 ’307 Patent, all asserted claims The application data and control bits are not encoded as special characters “application data and control bits” 7 ’265 Patent, all asserted claims Plain and ordinary meaning

“AV sink operation mode” and “AV source operation mode” 8 ’520 Patent, all asserted claims & Any mobile electronic device including but not ’231 Patent, claim 14 limited to a cellular telephone, smartphone, PDA (personal digital device), MP3 or other format music “mobile device” player, digital camera, video recorder, digital storage device, and other similar devices (i.e., portable devices smaller than a standard device such as a personal computer or monitor) 9A ’520 Patent, all asserted claims A communication protocol that was standardized as of the January 4, 2008 filing date of the ’520 patent “standard protocol” 9B ’520 Patent, all asserted claims A communication protocol that is a modification of the standard protocol, that was defined as of the “modified protocol” January 4, 2008 filing date of the ’520 patent 10 ’520 Patent, all asserted claims Indefinite

“the modified protocol being a modification of the standard protocol that is not included in the standard protocol” 11 ’103 Patent, all asserted claims A Transition-Minimized Differential Signaling (TMDS) channel “first physical channel” IT IS FURTHER ORDERED that this case be removed from this Magistrate Judge’s docket and returned to the docket of the Honorable Robert Pitman. SIGNED on January 26, 2026.

SUSAN HIGHTOWER UNITED STATES MAGISTRATE JUDGE