Uniloc 2017 LLC et al v. Google LLC, No. 2:18-cv-00499 (E.D. Tex. Mar. 20, 2020)

The Court previously entered a Claim Construction Memorandum and Order (“CCMO”) on January 20, 2020. Dkt. No. 152. This CCMO construed the term “short-range wireless technology” to mean “wireless personal area network technology.” Dkt. No. 152 at 45–50. While the CCMO did not expressly exclude Wi-Fi technology from the scope of this claim term, the reasoning within the CCMO indicated that “short-range wireless technology” did not include Wi-Fi technology. Id. at 48–49. For example, the CCMO stated that “[t]he disclosures regarding ‘short-range wireless technology’ between a mobile device and a stationary terminal thus contrast with the disclosure of ‘access to the Internet’ using WiFi.” Id. at 49.

The Court now enters this Supplemental Order to modify the construction for this term. The Court now construes “short-range wireless technology” to mean “wireless personal area network technology (which excludes, for example, Wi-Fi technology).” The Court alters this construction to eliminate any ambiguity as to whether Wi-Fi technology falls within the scope of this claim term.