Rex Computing, Inc. v. Cerebras Systems Inc., 1:21-cv-00525

This is a patent infringement suit between Rex Computing Systems, Inc. (Plaintiff) and Cerebras Systems Inc. (Defendant) regarding U.S. Patent No. 10,355,975.
The case is before the District of Delaware and concerns claim construction, specifically of the terms “optimization module” and “when the function executes optimally.”
The court previously construed both disputed terms and the parties filed a joint letter raising further disputes over those constructions.
Oral argument was held, and this memorandum order clarifies and resolves the parties’ disputes.
The resolution of these issues is pertinent to the infringement and validity analysis for the asserted patent claims.
The Court applies standard claim construction principles, giving primary weight to intrinsic evidence (claims, specification, prosecution history) and less to extrinsic evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether “optimization module”	Steps in either Figure 7A or 7B individually suffice as structure.	All steps from both Figures 7A and 7B must be included as structure.	Either 7A or 7B alone suffices; both are not required.
Scope of “when the function executes optimally”	"Optimal" is best among the considered configurations.	Must determine the absolute best among all possible configurations.	"Optimal" means the best of the configurations considered.

Teva Pharms. USA, Inc. v. Sandoz, Inc., 574 U.S. 318 (standard for resolving factual disputes in claim construction)
Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc) (how claim terms are generally interpreted and the primacy of the specification)
Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (specification is the best guide to the meaning of a disputed term)
Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir. 1995) (en banc), aff’d, 517 U.S. 370 (1996) (role of prosecution history and claim construction)
Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir. 2014) (specification and intent to limit claim scope)
Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir. 2004) (when claims should not be read restrictively)
Pitney Bowes, Inc. v. Hewlett-Packard Co., 182 F.3d 1298 (Fed. Cir. 1999) (reliance on extrinsic evidence improper where intrinsic record is clear)