Lupercal LLC v. CitiBank, N.A.

Western District of Texas, txwd-6:2019-cv-00201

Exhibit PC22

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EXHIBIT PC22 From: Ray Mort To: Rodkey, Kevin Cc: Berkowitz, Jeffrey Subject: RE: Lupercal v. PlainsCapital Bank: Defendant"s Terms for Construction Date: Wednesday, November 13, 2019 11:11:54 AM EXTERNAL Email: Kevin, For the "pre-processing parameters" term, we are going to propose it means "values directing the pre-processing," which was construed by the Court in the RIM case and was adopted by the parties in the HTC case. For the "pre-process" term, we propose the following construction "modifying the one or more images, as opposed to data merely associated with the one or more images, at the user device prior to transmission to a remote device." Plains Cap's proposed construction had "image files." This construction tracks the claim language and clarifies that the image does not need to be a saved file. Please let us know if Plains Capital agrees with either of these two constructions. Thanks, - Ray Raymond W. Mort, III The Mort Law Firm, pllc 100 Congress Ave · Suite 2000 Austin · Texas · 78701 · (512)-677-6825 · The statements contained herein are not intended to and do not constitute an opinion as to any tax or other matter. They are not intended or written to be used, and may not be relied upon, by you or any other person for the purpose of avoiding penalties that may be imposed under any Federal tax law or otherwise. CONFIDENTIALITY NOTE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.