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Judge Andrews issues claim construction opinion

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Judge Richard G. Andrews recently construed several claims terms across five patents: U.S. Patent Nos. 5,793,853; 5,742,605; 6,108,339; 6,452,931; and 6,870,832. Sprint Communications Company L.P. v. Comcast IP Holdings I, LLC et al., C.A. No. 12-1013-RGA, Mem. Op. (D. Del. Jan. 28, 2014). Judge Andrews construed the terms consistently across the patents at issue, unless otherwise noted. Specifically, Judge Andrews construed the disputed claim terms as follows:

U.S. Patent No. 5,793,853

-“primary network element” means “[t]he first network element to receive the service request.”

-“operator center” means “[a] network element providing telecommunications services.”

-“means for assigning an identification key to the primary and secondary records” is a means-plus-function limitation. The function is “assigning an identification key to the primary and secondary records,” and the structure is “a network element comprising a counter device as disclosed at 5:61-6:9 and equivalents thereof.”

-“means for comparing the identification keys assigned to the records” is a means-plus-function limitation. The function is “comparing the identification keys assigned to primary and secondary records” and the structure is “a merge processor (as disclosed at item 42 in Figures 1 and 2) and equivalents thereof.”

-“means for merging associated records” is a means-plus-function limitation. The function is “merging records that are associated by reference to information included in their identification keys” and the structure is “a merge processor (as disclosed at item 42 in Figures 1 and 2) and equivalents thereof.”

U.S. Patent Nos. 5,742,605, 6,108,339, and 6,452,931

-“[SONET] ring” means “[a] self-healing SO NET architecture connecting ring terminals in a loop in which each ring terminal in the loop is directly connected only to the adjacent ring terminal(s) in each direction around the loop.”

-“span” means “[t]he logical connection between ring terminals.”

-“ring terminal[s]” mean “[a] network element that includes a SO NET add/dropmux (ADM) and is capable of receiving, switching, grooming, and transmitting SO NET traffic on the connected SONET spans.”

-“are stacked within a single fiber route” means “[o]ccupying at least a portion of the same fiber route.”

-“are stacked within a single physical route” means “[o]ccupying at least a portion of the same physical route.”

-“work line” / “protect line” means “[a] line of a ring over which traffic is transported when there is no interruption in the ring.” / “A line of a ring allocated to transport the traffic in the event the work line of the ring becomes unavailable due to an interruption in the ring.”

-Judge Andrews found the following two terms indefinite: (i) “rings [that] individually encompass geographic areas that are large[r] than a LATA” / “rings [that] individually encompass geographic areas that are larger than a metropolitan area” and (ii) “wherein a plurality of the rings individually encompass geographic areas that are operational to connect two non-adjacent LA T As on a single ring” I “wherein a plurality of the rings individually encompass geographic areas that are operational to connect two metropolitan areas on a single ring.”

U.S. Patent No. 6,870,832

-“software agent” means “[a] software interface between a session manager and a telephony card.”

-“communication hub” means “[e]quipment that stores and executes the software agent.”

“session manager” means “[a] platform that controls a communications network.”

-Judge Andrews also found that six disputed terms did not require any construction. See Mem. Op. at 22-25.

Sprint Communications Company L.P. v. Comcast IP Holdings I, LLC et al., C.A. No. 12-1013-RGA (D. Del. Feb….

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