No legal distinction between "submit" and "file" in that context. None. Which "prior" claim construction briefs are you referring to?
I remember that the case was getting ready to move to a Markman Hearing in early 2008 when we got stayed because of the USPTO review. I think that claim construction briefs were never submitted because of the stay. Then the original judge died in late 2008. So here we are now 18 months later trying to pick up where we left off.