`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CIVIL ACTION N0. 2:15-CV-00898-RWS
`(LEAD CASE)
`
`§
`
`§ §
`
`§
`§
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`§ §
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`§
`§
`3
`
`AUTOMATION MIDDLEWARE
`SOLUTIONS, INC.,
`
`Plaintiff,
`
`v.
`
`INVENSYS SYSTEMS, INC.,
`SCHNEIDER ELECTRIC USA, INC.,
`Defendants.
`
`PRELIMINARY CLAIM CONSTRUCTIONSI
`
`CLAIM TERM
`
`PRELIMINARY CONSTRUCTION
`
`Application Program
`
`a software program designed to handle specific tasks
`
`Driver Functions
`
`hardware independent functions that are separate and distinct
`from the component
`fimctions and that directly control
`sofiware drivers
`
`Soflware Driver/Driver
`
`one or more controller dependent software modules that
`generates hardware s
`cific control-codes to implement the
`core
`river unctions on the associated hardware device or
`
`group of related hardware devices
`
`Motion Control
`
`Plain and ordinary meaning.
`
`‘Motion Control
`Operation/Motion Operation
`
`hardware independent operations (such as GET POSITION,
`MOVE RELATIVE, or CONTOUR MOVE)
`that
`are
`performed by a motion control device
`
`Developing/Defining
`
`Plain and ordinary meaning. No “person” or “user” is required.
`
`Desired/A Desired Manner/ A
`Desired Motion Sequence
`
`Plain and ordinary meaning. No “person” or “user” is required.
`
`' These preliminary constructions are only meant to indicate where the Judge stands afier considering the claim
`construction briefing. He may change his position based on the parties’ arguments.
`
`Page 1 of 2
`
`AMS
`
`Exhibit 2016
`
`RA V AMS
`
`IPR20 17-00049
`
`
`
`Primitive Operations
`
`motion control operations that cannot be simulated using a
`combination of other motion control operations
`
`Non-Primitive Operations
`
`motion control operations that can be simulated using a
`combination of other motion control operations
`
`Associates withl Associates
`
`Plain and ordinary meaning.
`
`Worl<station/[Runs/Operates/
`Operating] on [] Workstation
`
`Plain and ordinary meaning.
`
`Motion Control
`Component/Motion
`Component
`
`an intermediate software layer containing code that is separate
`and distinct from the application program and the software
`driver
`
`Control Command Generating
`Module
`
`Plain and ordinary meaning.
`
`software code in the motion control component that associates
`at least some of the component functions with at least some of
`the driver functions
`
`code associated with a hardware device or group of related
`hardware devices, which helps generate commands necessary
`to perform motion control operations associated with at least
`some driver functions
`
`Plain and ordinary meaning.
`
`Component Code
`
`Driver Code
`
`A Controller Capable of
`Generating Electrical Signals
`Based on at Least One Control
`Command of the Controller
`
`Language Associated with the
`Motion Control Device
`
`Page 2 of 2
`
`Page 2 of 2
`
`AMS
`
`Exhibit 2016
`
`RA v AMS
`
`IPR20 l 7-00049
`
`
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