Saturday, March 04, 2006 5:05:10 PM
From stkhkw: Three other claims chosen for trial, do not use the “access time register” claim language.
You've got to be kidding me, you really think Stone is going to make this argument? With a straight face?
Let's take a look:
Patent '918
24. The method of claim 18 further including storing a delay time code in an access time register, the delay time code being representative of a number of clock cycles to transpire before data is output onto the bus after receipt of a read request and wherein the first amount of data corresponding to the first block size information is output in accordance with the delay time code.
So I store a delay time code in a register which I call access time register. This delay time code must be "representative" (equal according to the Markman) to the number of clock cycles. You acknowledge Rambus cannot prove DOE on that claim. But now for these other claims:
28. a register which stores a value that is representative of an amount of time to transpire after which the memory device outputs the first amount of data
You claim this is different, and not a "register" which stores the access time value LOL? I wanna see that presentation.
40. a register which stores a value that is representative of an amount of time to transpire after which the memory device outputs the first amount of data
Ditto
So I get it, these are not an "access time register" instead they are an (unnamed) register which stores "access time." Kindly explain how an "access time register" is physically different in any way from the other "registers" in the claims above. If this is your position on the best they can do, they might as well mail it in...
The point made by Whyte was not what they called the register, but the thing that was stored in it: in this case a "value" that is representative of "an amount of time" to transpire after which the memory device outputs the first amount of data. You now know that this is not how the Hynix products work;they store a value which is less than this. If Rambus had done this right the first, second or third time,the claim would have read "an amount of time related to..." or "associated with..." instead of "representative of" - everyone knows the latter is the same as "represents" so requires an equal value. Most patent attorneys in the EE arts know the difference, and it would have avoided the argument about whether it had to be the same or something close to it. But, I forgot, Rambus never makes mistakes LOL.
Da Greek
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