Judge Richard G. Andrews recently considered plaintiff’s Motion for Partial Clarification and Reconsideration of the Court’s Memorandum Opinion on Claim Construction. M2M Solutions LLC v. Sierra Wireless Am., Inc., et al., C.A. Nos. 12-30-RGA to 12-34-RGA (D. Del. Jan. 24, 2014). Judge Andrews largely denied the motion but did agree to make one modification to the Court’s earlier construction of the term of”wireless communications circuit for communicating through an antenna.” The Court previously construed the term to mean “a complete wireless circuit that transmits and receives data and includes an antenna.” (Nov. 12 opinion at 15). Judge Andrews reconsidered that construction:
The claim language itself requires the circuit to communicate “through an antenna.” The plain meaning of “through an antenna” is “through an antenna,” and this should not be read out of the claim. The construction is revised to read: “a complete wireless circuit that transmits and receives data through an antenna.”
Id. at 5.