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Proxense LLC v. Apple, Inc., 6:24-cv-00143-ADA
`
`Proxense’s Proposed Constructions
`
`Patent Claims
`
`Apple’s Proposed Terms, Phrases or Clauses
`
`Proxense’s Proposed Construction
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`No construction needed; plain and ordinary meaning
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`A signal or notification enabling or announcing access
`
`No construction needed; plain and ordinary meaning
`beyond any terms that the Court previously construed
`in Proxense v. Samsung.
`
`’730 claims 1, 8
`
`’954 patent, claim
`1
`
`’730 claims 1, 8
`
`’954 claim 1
`
`’905 claim 1
`
`’730 claim 8
`
`“persistently storing biometric data of the user and a
`plurality of codes and other data values comprising a
`device ID code uniquely identifying the integrated
`device and a secret decryption value … to a storage
`element”
`/
`“stores biometric data of a user and a plurality of codes
`and other data values comprising a device ID code
`uniquely identifying the integrated device and a secret
`decryption value … to the memory”
`“access message”
`
`“a verification unit, in communication with the memory,
`receives scan data from a biometric scan for comparison
`against the biometric data, and if the scan data matches
`the biometric data, wirelessly sends one or more codes
`from the plurality of codes and the other data values for
`authentication by an agent that is a third- party trusted
`authority possessing a list of device ID codes uniquely
`identifying legitimate integrated devices”
`
`1
`
`Patent Owner Exhibit 2012, Page 1 of 3
`
`

`

`’730 claims 1, 8
`
`’954 claim 1
`
`’905 claim 1
`
`’989 claim 1
`
`’730 claims 1, 8
`
`’954 claim 1
`
`’042 patent claims
`1, 6
`
`’188 patent claims
`1, 3, 4, 7
`’042 patent claim
`1
`’188 patent claim
`1
`’042 patent claims
`1, 6
`
`’188 patent claim
`1
`
`“device ID code”
`/
`“ID code”
`/
`“identification (ID) code”
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`A unique code identifying a device
`
`“tamper proof format”
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`“hybrid device”
`
`“A hybrid device comprising”
`
`No construction needed; plain and ordinary meaning
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`A device comprising an integrated personal digital key
`(PDK) and an integrated receiver-decoder circuit.
`Plain and ordinary meaning. No construction necessary
`beyond adopting the Court’s prior construction of
`“hybrid device” in Proxense v. Samsung.
`
`“personal digital key (PDK)”
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`An operably connected collection of elements
`including an antenna and a transceiver for
`communicating with a RDC and a controller and
`memory for storing information particular to a user
`
`2
`
`Patent Owner Exhibit 2012, Page 2 of 3
`
`

`

`’042 patent claims
`1, 6
`
`’188 patent claims
`1, 3
`
`“receiver-decoder circuit (RDC)”
`
`Adopt the Court’s prior construction in Proxense v.
`Samsung:
`
`A component or collection of components, capable of
`wirelessly receiving data in an encrypted format and
`decoding the encrypted data for processing
`
`3
`
`Patent Owner Exhibit 2012, Page 3 of 3
`
`

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