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` UNITED STATES DISTRICT COURT
`
` CENTRAL DISTRICT OF CALIFORNIA
`
` SOUTHERN DIVISION
`
`- - -
`
` THE HONORABLE JAMES V. SELNA, JUDGE PRESIDING
`
` vs.
`
` SPEX TECHNOLOGIES, INC., )
` Plaintiff, )
` )
` ) SACV-16-01790-JVS
` )
` KINGSTON TECHNOLOGY
` ) WITH RELATED MATTERS:
` CORPORATION, et al.,
` Defendant. )
` ----------------------------) SACV-16-01799-JVS
` SACV-16-01800-JVS
` SACV-16-01805-JVS
` SACV-16-07349-JVS
`
` REPORTER'S TRANSCRIPT OF PROCEEDINGS
`
` Santa Ana, California
`
` September 18, 2017
`
` SHARON A. SEFFENS, RPR
` United States Courthouse
` 411 West 4th Street, Suite 1-1053
` Santa Ana, CA 92701
`(714) 543-0870
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 1 of 82
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` 1
`
` UNITED STATES DISTRICT COURT
`
` CENTRAL DISTRICT OF CALIFORNIA
`
` SOUTHERN DIVISION
`
`- - -
`
` THE HONORABLE JAMES V. SELNA, JUDGE PRESIDING
`
` vs.
`
` SPEX TECHNOLOGIES, INC., )
` Plaintiff, )
` )
` ) SACV-16-01790-JVS
` )
` KINGSTON TECHNOLOGY
` ) WITH RELATED MATTERS:
` CORPORATION, et al.,
` Defendant. )
` ----------------------------) SACV-16-01799-JVS
` SACV-16-01800-JVS
` SACV-16-01805-JVS
` SACV-16-07349-JVS
`
` REPORTER'S TRANSCRIPT OF PROCEEDINGS
`
` Santa Ana, California
`
` September 18, 2017
`
` SHARON A. SEFFENS, RPR
` United States Courthouse
` 411 West 4th Street, Suite 1-1053
` Santa Ana, CA 92701
`(714) 543-0870
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 1 of 82
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`APPEARANCES OF COUNSEL:
`
`For the Plaintiff:
`
`BENJAMIN T. WANG
`MARC A. FENSTER
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`(310) 826-7474
`
`For Defendants WESTERN DIGITAL CORPORATION; WESTERN
` DIGITAL TECHNOLOGIES, INC.; HGST, INC.:
`
`FRANKLIN P. COTE
`WILLIAM C. ROOKLIDGE
`RUSTIN KENT MANGUM
`GIBSON, DUNN & CRUTCHER, LLP
`3161 Michelson Drive, Suite 800
`Irvine, CA 92612-4408
`(949) 451-3800
`
`For Defendants TOSHIBA AMERICA ELECTRONICS COMPONENTS, INC.,
` et al.:
`
`DOUGLAS F. STEWART
`JARED DYLAN SCHUETTENHELM
`BRACEWELL, LLP
`701 Fifth Avenue, Suite 6200
`Seattle, WA 98104
`(206) 204-6200
`
`For Defendant APRICORN:
`
`CHRISTOPHER D. BRIGHT
`MCDERMOTT WILL & EMERY, LLP
`4 Park Plaza, Suite 1700
`Irvine, CA 92614-2559
`(949) 851-0633
`
`For Defendants KINGSTON TECHNOLOGY CORPORATION, et al.:
`
`DAVID M. HOFFMAN
`DAVID S. MORRIS
`FISH & RICHARDSON, P.C.
`111 Congress Avenue, Suite 810
`Austin, TX 78701
`(512) 472-5070
`
`
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 2 of 82
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` 3
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`VICTORIA D. HOA
`LAW OFFICE OF VICTORIA HAO
`5480 Wisconsin Avenue, Suite 222
`Chevy Chase, MD 20815
`(888) 240-5840
`
`For Defendant IMATION CORPORATION:
`
`STEPHEN J. AKERLEY
`MINTZ LEVIN COHN FERRIS GLOVSKY & POPEO, P.C.
`44 Montgomery Street, 36th Floor
`San Francisco, CA 94104
`(415) 432-6001
`
`For Defendant DATALOCKER, INC., et al.:
`
`DOUGLAS WAYNE ROBINSON
`SHOOK HARDY & BACON, LLP
`Jamboree Center
`5 Park Plaza, Suite 1600
`Irvine, CA 92614-2546
`(949) 475-1500
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`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 3 of 82
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`SANTA ANA, CALIFORNIA; MONDAY, SEPTEMBER 18, 2017; 3:03 P.M.
`
`THE CLERK: Item No. 16, SACV-16-01790-JVS, SPEX
`
`Technologies, Inc., versus Kingston Technology Corporation,
`
`et al.; with related matters SACV-16-01799-JVS;
`
`SACV-16-01800-JVS; SACV-01805-JVS; and SACV-16-07349-JVS.
`
`Counsel, please state your appearance for the
`
`record.
`
`MR. FENSTER: Good afternoon, Your Honor. Marc
`
`Fenster for the plaintiff SPEX.
`
`MR. WANG: Good afternoon, Your Honor. Ben Wang
`
`for plaintiff SPEX.
`
`MR. COTE: Good afternoon, Your Honor. Frank Cote
`
`for defendants Western Digital Corporation, Western Digital
`
`Technologies, and HGST.
`
`MR. STEWART: Good afternoon, Your Honor. Doug
`
`Stewart on behalf of the Toshiba entities; and my associate,
`
`Jared Schuettenhelm, is here as well.
`
`MR. BRIGHT: Good afternoon, Your Honor. Chris
`
`Bright on behalf of defendant Apricorn.
`
`MR. ROOKLIDGE: Good afternoon, Your Honor. Bill
`
`Rooklidge for the Western Digital defendants.
`
`MR. HOFFMAN: Good afternoon, Your Honor. David
`
`Hoffman for Kingston with my colleague David Morris.
`
`MR. ROBINSON: Good afternoon, Your Honor.
`
`Douglas Robinson for defendant DataLocker.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
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`MR. AKERLEY: Good afternoon, Your Honor. Stephen
`
`Akerley for the Imation defendant.
`
`MR. MANGUM: Good afternoon, Your Honor. Rustin
`
`Mangum for the Western Digital defendants.
`
`MS. HOA: Good afternoon, Your Honor. Victoria
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`Hoa on behalf of the Kingston defendants.
`
`THE COURT: Good afternoon.
`
`Okay, what are we going to talk about this
`
`afternoon?
`
`MR. FENSTER: Your Honor, we have seen your
`
`tentative. Thank you very much for your tentative. We
`
`would propose to just go through in the order of the
`
`tentative. We will be submitting on many of those, but I
`
`thought we would address them one by one in that order.
`
`THE COURT: That's fine.
`
`I guess the first term is "defined interaction."
`
`MR. FENSTER: The first term is "defined
`
`interaction." The plaintiff submits on the Court's
`
`tentative, so I will let the defendants address that one.
`
`THE COURT: Okay.
`
`MR. BRIGHT: Your Honor, may I approach? We have
`
`copies of our slides.
`
`THE COURT: Sure.
`
`MR. BRIGHT: I'm Chris Bright on behalf of
`
`defendant Apricorn.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 5 of 82
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`Your Honor, I will be brief on this term. I just
`
`want to highlight a few issues on the "defined interaction"
`
`term, which we have also termed Nos. 1 and 1A in the Joint
`
`Claim Construction Statement.
`
`Let's go to Slide 3 if we could.
`
`Your Honor, obviously this is an excerpt from your
`
`tentative order on claim construction. Of course we see in
`
`the first part of your tentative construction that there is
`
`an acknowledgment that this is an interaction with the host
`
`computing device. The second part of that is it can provide
`
`a variety of functionalities.
`
`We of course agree that SPEX's proposal which was
`
`trying to read out the requirement of an interaction was
`
`improper. That's how we briefed it. Your Honor's
`
`construction recognizes that.
`
`What we would like to point out is the issue we
`
`are having with the tentative is that we don't see an
`
`expression -- we don't know to express it, and this is how
`
`we briefed the issue -- of what is a defined interaction as
`
`distinct from an interaction? Of course as we briefed the
`
`term, the term "defined" must have meaning. So we just want
`
`to be clear for the record that as we said before we think
`
`the term remains indefinite, particularly because the term
`
`modifies "interaction" with the word "defined."
`
`If we could go to Slide 5, please.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 6 of 82
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`What we have done here is we just summarized even
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`in view of the Court's tentative what we think the problems
`
`are with this term. There is no ordinary meaning in the
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`art. There is actually apparently no dispute between the
`
`experts on that issue in terms of whether this actual
`
`phrase, "defined interaction," was something that was used
`
`in those words, and the record reflects that.
`
`So what we raise here on this slide is whether the
`
`Court's tentative is actually a construction that we get
`
`from the Court's view that it's lexicography or not. Our
`
`position is as we briefed it that there is no lexicography
`
`in the asserted patents for this term, so there is no way to
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`arrive at a construction from the perspective of
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`lexicography either.
`
`We have listed here that -- and summarized that we
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`don't think there is any description of any objective
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`boundary in the asserted patents. We don't get something
`
`like a description of the prior art and how it's
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`distinguished in any way on the basis of a defined
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`interaction. We don't get any description, for example, of
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`what might be inputs or outputs necessarily here of a
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`defined interaction. We don't have something like a box in
`
`one of the figures that labels a defined interaction, and we
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`know what the inputs are and we know what the outputs are.
`
`We don't have any of that. We don't have any guidance.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 7 of 82
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`Finally, as we summarize on this slide, we don't
`
`have any description in the asserted patents of any
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`distinctions between a defined interaction and other
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`interactions because of course not all interactions are
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`defined.
`
`That's the summary of our argument on that issue
`
`of course recognizing that you have reached your tentative.
`
`I do want to raise a few other issues. If we
`
`could go to the next slide, please.
`
`Here what I want to bring to the Court's attention
`
`is of course the Court recognizes that it has construed the
`
`term "defined interaction." This term is found in recited
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`functionality for means-plus-function claim terms, for a
`
`target means and for a target module. That's in the
`
`asserted patents. So what has not been presented really to
`
`Your Honor is what is the effect of Your Honor's
`
`construction for the term "defined interaction" in this
`
`functionality on whether there is corresponding structure
`
`for those terms? Now, that's because neither party briefed
`
`the construction that Your Honor reached.
`
`With that in view, we think there is a very real
`
`issue that there is no corresponding structure for these
`
`means-plus-function terms. We think that needs to be
`
`briefed. Those terms have to be construed. They are
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`means-plus-function terms, and we just don't think the
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
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`corresponding structure is there. I just want to leave it
`
`at that for the moment, particularly because you don't have
`
`briefing in front of you, but we would like to and will be
`
`seeking leave to file briefing on that issue.
`
`THE COURT: Okay.
`
`MR. BRIGHT: Then if we could go to Slide 23,
`
`please.
`
`THE COURT: We are just going to go term by term.
`
`MR. BRIGHT: Yes. I have one more issue quickly
`
`on "defined interaction." What I have done here is I have
`
`shown on Slide 23 a portion of SPEX's tutorial for the
`
`Court. They of course taut that there have been three IPR
`
`petitions that have been rejected. Two of those petitions
`
`were rejected on August 17. So this is after the briefing
`
`on claim construction before Your Honor.
`
`We think it's important for the Court's
`
`consideration how the PTAB reached those decisions, how
`
`those petitions were rejected. I just mention here -- just
`
`briefly in that final point on the slide, you will see in
`
`further briefing that SPEX distinguished a transfer of data
`
`from a defined interaction. The PTAB bought that argument
`
`and rejected the petitions. So we think this is also
`
`pertinent to the briefing we would like to submit to Your
`
`Honor.
`
`Thank you, Your Honor.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 9 of 82
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`THE COURT: Thank you.
`
`Mr. Fenster.
`
`MR. FENSTER: Your Honor, very briefly, with
`
`respect to "defined interaction," one, we think the Court
`
`got the analysis just right. What the experts agreed was
`
`that it's not a term of art, and it's not a specific term of
`
`art used in the technology. Defined interaction are common
`
`ordinary words used in their common ordinary way consistent
`
`with the Court's tentative. That's what Dr. Gomez testified
`
`as well.
`
`Defined interaction is just -- as described in the
`
`specification, it can be any of a variety of defined
`
`interactions. We do not object to having what we put in our
`
`proposed construction, which is that it be a predefined
`
`interaction or a specified interaction. That's what makes
`
`it a defined interaction versus a non.
`
`The only other issue that I wanted to address -- I
`
`apologize. I meant to do this at the outset. I did just
`
`want to clarify that the Court's proposed construction,
`
`which is, "an interaction with a host computing device that
`
`can provide a variety of functionalities" -- I do not
`
`understand that language, but I want to clarify that that
`
`language does not require a variety, meaning a plurality, of
`
`functionalities. The defined interaction can be a singular
`
`interaction. So what I would propose is maybe to insert
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 10 of 82
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` 11
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`"one or more of a variety of functionalities." That would
`
`be our only proposed modification of that.
`
`THE COURT: Okay. What about consideration of the
`
`PTAB decision?
`
`MR. FENSTER: This is the first I have heard of
`
`it. I have reviewed those decisions. I do not see those as
`
`inconsistent with any of the positions taken here or the
`
`Court's construction. My general recollection of those IPRs
`
`-- there have been several IPR decisions that denied it, but
`
`they were primarily denied on the definition of a
`
`means-plus-function language and the failure to identify
`
`corresponding structures in the prior art. I am happy to
`
`take a look at it, but I don't really have much to add on
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`that at this point.
`
`THE COURT: Okay.
`
`Mr. Bright.
`
`MR. BRIGHT: Very quickly, Your Honor, just on
`
`this issue of a variety of functionalities in Your Honor's
`
`construction, of course our position remains as defendants
`
`have termed "defined interaction" is indefinite. But
`
`looking at the Court's reasoning, it seems to be using a
`
`particular part of the specification, for example, the '802
`
`Patent Abstract, to arrive at that part of its construction.
`
`So we would take issue with departing from the
`
`specificity there because, again, the term has no ordinary
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 11 of 82
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` 12
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`meaning in the art. Given that, with no anchor to any
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`ordinary meaning in the art, if Your Honor is going to use
`
`the specification, we would counsel using it very closely.
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`THE COURT: If you want to submit a supplement
`
`based on the recent PTAB ruling, can you do that within
`
`seven days?
`
`MR. BRIGHT: Yes.
`
`THE COURT: Seven days to reply?
`
`MR. FENSTER: That's fine.
`
`THE COURT: Okay. I'm not going to go any further
`
`with this particular construction to other constructions.
`
`The plate is full. I mean, construing any one of these
`
`things could lead to a lot of places, but for today's
`
`purposes, I'm sticking to what we are construing.
`
`MR. FENSTER: The plaintiff is fine with the
`
`Court's tentative construction of peripheral device and
`
`similarly for modular device. The Court construed modular
`
`device consistent with peripheral device. As long as it's
`
`the same construction -- I will just note that the chart on
`
`page 12 in the Court's tentative -- the construction of
`
`"modular device" did not include the "including" phrase.
`
`THE COURT: Well, it should.
`
`MR. FENSTER: It should. It is included in a
`
`different chart later.
`
`THE COURT: Yes.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 12 of 82
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`MR. FENSTER: Other than that, the plaintiff is
`
`fine with the Court's tentative on "peripheral" and "modular
`
`device."
`
`MR. STEWART: Doug Stewart on behalf of the
`
`defendants on this term.
`
`Your Honor, I apologize. It appears that the
`
`slides that we have prepared after your tentative ruling
`
`didn't make it into the handout that you have in front of
`
`you. We have them on the screen, and I hope that we can use
`
`those.
`
`Your Honor, with regard to the tentative ruling,
`
`we certainly agree that the first portion of the
`
`construction is correct. There is no question about that.
`
`It comes straight from the specification. But we are a
`
`little bit concerned about the inclusion of the last clause
`
`simply because we don't believe it's necessary, and it could
`
`inject some ambiguity.
`
`THE COURT: Why does it inject ambiguity?
`
`MR. STEWART: I believe it's possible that the
`
`briefing by the parties may have confused the issue and not
`
`been very clear for the Court.
`
`Basically the issue here relates to the definition
`
`in the specification, which is laid out here on the screen.
`
`That's the first part of your construction, Your Honor. We
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`certainly agree with the requirement that that be the
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 13 of 82
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`construction. But it seems that in the context of the
`
`Court's analysis, which again I believe was the result of
`
`the briefing by the parties -- it seems that the Court
`
`believed that there was a dispute about physical separation
`
`between the peripheral and the host computing device.
`
`Certainly the word "outside" implies some sort of spacial
`
`relationship, but, in fact, that's not what the patent is
`
`about, and that's certainly not the position that the
`
`defendants have taken in any of the briefing, so that wasn't
`
`an issue that we raised.
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`Could we go to the next slide, please.
`
`I think what happened was we had a little bit of a
`
`mixup on the briefing in the sense that we filed our opening
`
`brief. About two hours later the plaintiff filed their
`
`brief, which contained a new claim construction that we
`
`hadn't seen before for this term, so our claim construction
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`opening briefing was not responsive to what was in the
`
`brief. It was responsive to what was in the joint claim
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`chart. In the reply, we were certainly able to address some
`
`of those issues.
`
`In essence, the issue that relates to the outside
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`of the host computing device is something that's kind of at
`
`the core of this patent. It relates to not a physical
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`location, not a spacial location, but a functional
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`relationship. That's what the patent is directed to.
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 14 of 82
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`That's what the inventor was attempting to secure with the
`
`Patent Office. That's actually why the patentee used their
`
`ability to be their own lexicographer in this patent.
`
`The defendants don't dispute that there was an
`
`ordinary meaning for "peripheral." It's in the dictionary.
`
`The expert testified about it. I suspect Your Honor from
`
`past experience knew of it.
`
`THE COURT: Even lay persons know what a
`
`peripheral is today.
`
`MR. STEWART: But in this case, the patentee went
`
`out of their way to specifically define "peripheral" in the
`
`specification, which they wouldn't have to do if everybody
`
`understood the term. The reason is -- the basis, the
`
`objective, of this invention was to specifically change the
`
`functional relationship between the claimed peripheral and
`
`the host computing device.
`
`Your Honor, this is a slide that was taken from
`
`SPEX's technical tutorial where they are describing Fig. 1
`
`of the patent, which is also laid out in the specification.
`
`This represents the prior art where the security operations
`
`were occurring in the host computing device. According to
`
`this description and to the prior art, at this point in
`
`time, in the late mid '90s, this was considered to be a
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`deficient process. It was considered to be inherently
`
`insecure. So this represented the prior art technology that
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 15 of 82
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`the inventor was looking to overcome to improve upon, and
`
`that is where we get to the invention as laid out in Fig. 6
`
`where the claimed peripheral was taken outside of the host
`
`computing device.
`
`So in this figure, the host computing device is
`
`described in the specification as containing three
`
`components. It has got a user display and a keyboard.
`
`Those two components are referred to as the user interface.
`
`then inside that dotted line there is a Box 604, and that's
`
`a housing that contains four components comprising the host
`
`computing device. Separately from that, you have the
`
`claimed peripheral. The claimed peripheral is also
`
`comprised of four components, including its own memory.
`
`It's a self-contained peripheral unit.
`
`This was keep in mind at a time when memory was
`
`expensive, so systems were designed to share resources
`
`typically. But in this case to overcome that problem in the
`
`prior art about the host computing device being inherently
`
`insecure, the claimed peripheral that's set forth in these
`
`patents was separately provided its own resources. It was
`
`taken outside of the host computing device.
`
`That's really the key to the patent here. It's
`
`not physical proximity. It's the fact that the claimed
`
`peripheral, which is defined as being outside of the host
`
`device, is a separate component of the system. In fact, the
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 16 of 82
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`specification at column 6, lines 46 to 48, explain that Fig.
`
`6 is designed to illustrate with clarity this aspect of the
`
`invention.
`
`Then when you go to Fig. 5, Fig. 5 is discussed at
`
`column 6. If you look at lines 52 to 54, this is where the
`
`patent explains what a user has to do in order to use this
`
`peripheral, the claimed peripheral, not any peripheral. The
`
`first step is to connect the claimed peripheral to the host
`
`computing device via the Input/Output interface, the I/O
`
`interface. Each of the two components has an I/O interface,
`
`and when those components are connected, then the system is
`
`in place. There are three examples given on how they could
`
`connect. One is a PCMCIA card. That is a card that goes
`
`into the host computing device. There is a cord, and then
`
`there is a wireless connection. Those are just three
`
`examples.
`
`But in each of those situations even though they
`
`are connected, they are functionally separate. It's
`
`possible -- in fact, I think looking at the figure, Your
`
`Honor, a PCMCIA card which is inserted into a slot in the
`
`body of a laptop, for example, would be within the housing.
`
`That's not really the issue that's at the core of why the
`
`patentee acted as his own lexicographer. The issue was the
`
`functional relationship, that despite the connection the
`
`claimed peripheral has to be outside of the host computing
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 17 of 82
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`device.
`
`So one of the reasons I think this may have gotten
`
`confused is that in the reply brief there was some
`
`discussion by the plaintiff about a dispute between the
`
`parties about whether or not an internal hard drive would
`
`fall within the scope of the peripheral device. The
`
`plaintiff's experts also referred to some sort of position
`
`that the defendants were presumed to have taken about
`
`physical location. In fact, that's not our position. Our
`
`position is about functional relationship.
`
`So if you look at the host computing device as its
`
`described in the patent, it includes things such as the --
`
`the memory or the drive in the host computing system
`
`includes things like the operating system. It includes the
`
`drivers for peripherals. In fact, the internal hard drive
`
`of a host computing device is a peripheral because it's
`
`attached to the motherboard somehow, but it's not the
`
`claimed peripheral.
`
`Really what the issue comes down to is whether or
`
`not the claimed peripheral can also be in the host computing
`
`device. By in, I mean part of the host computing device
`
`when the patent is clearly directed to segregating those two
`
`parts of the system. That's what is set forth in the
`
`description of the figure.
`
`THE COURT: Well, is a better way to capture this
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 18 of 82
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`then "a device that operates functionally separate from the
`
`host computing device"?
`
`MR. STEWART: Your Honor, I think that would work
`
`for us, except for the fact that the specification
`
`explicitly has this construction. I think my goal here was
`
`more just to explain that the parties' understanding of
`
`outside might be slightly different than is laid out in the
`
`Court's analysis. But certainly to the extent that there
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`was going to be a change to the construction to reference a
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`functional relationship -- if there is a way to do that
`
`without giving rise to a lot of other issues -- we might
`
`need to confer before -- you know, there might be some other
`
`language perhaps that might be better.
`
`THE COURT: Well, it would certainly capture the
`
`patentee's solution for the problem, namely, separating the
`
`function of this peripheral from the internal function of
`
`the host computing device.
`
`MR. STEWART: Correct. I think that would be fine
`
`with us. I think our concern was that the construction
`
`seemed to be leaning towards a discussion about spacial
`
`relationships and physical proximity, and that's not
`
`something that we necessarily are concerned about. This is
`
`really about whether or not one hard drive in one laptop can
`
`act both a host computing device and a peripheral. We think
`
`it can because it has to be outside of the host computing
`
`SHARON A. SEFFENS, U.S. DISTRICT COURT REPORTER
`
`WESTERN DIGITAL CORPORATION, EXHIBIT 1017
`Page 19 of 82
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`device.
`
`THE COURT: Or at least function separately.
`
`MR. STEWART: Well, Your Honor, there is nothing
`
`in the patent I think that would allow for one drive to
`
`accomplish both tasks. The patent very clearly says that
`
`the peripheral, which is a hardware device -- it's an
`
`apparatus -- is outside of the host computing device.
`
`THE COURT: Well, it functions physically and
`
`operationally separate.
`
`MR. STEWART: By physically separate, you mean a
`
`separate component?
`
`THE COURT: Right. I mean, you are positing a
`
`drive that services both the host device and accesses a
`
`separate component for the security aspects of the patent.
`
`I agree with you that that drive can't do both. Otherwise,
`
`you lose the security that the patentees strove for by
`
`separating those tasks.
`
`MR. STEWART: Yes. Certainly the technology has
`
`changed, and at the time this was filed, that was the
`
`solution, to separate things out. Now technology is
`
`different. This is really the issue that goes to the core
`
`of the infringement case for at least some of us. So it is
`
`important for us that the Court at least understand that
`
`outside in the context of the patent as it is used in the
`
`specification is not so much a spacial out
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