The defendant argues that "control unit" is a nonce word that fails to recite sufficiently definite structure. The plaintiff responds that a person of ordinary skill would find that "control unit" has sufficient structure when viewed in light of the specification. The '690 patent identifies the local control unit as the Alarm Control Unit ("ACU"). It describes the structure of the ACU in detail at 16:21-33. The court finds that the patent sufficiently defines and provides structure for the ACU.

The defendant's proposal for corresponding structure highlights the problem with applying § 112 ¶ 6 to this term. The corresponding structure for a means-plus-function term must be clearly linked to the function recited in the claim. Williamson, 792 F.3d at 1352. The defendant asserts the function is "receiving signals from a variety of detection devices monitoring events pertaining to security," and the corresponding structure is "ACU 50 which includes an RSC 300 chip 500, a microprocessor 510, non-volatile Flash memory 501, a microphone 502 with a dual monostable 503 to control its operation and an automatic gain control 504, a speaker 520, user interface controls 506, a low power radio transmitter 507, a 868 MHz low power radio receiver, a power supply with battery backup 518, a modem 519, resistors, capacitors, and logic elements." The defendant obtained this corresponding structure from the specification's description of "control unit." But many of the structural elements recited as part of the ACU have nothing to do with the claimed function of "receiving signals." As the defendants note, radio receiver 517, a substructure of the ACU, performs the function of receiving signals.

This disconnect between the defined structure of "control unit," and the structure linked to the "receiving" function cuts against D's argument that this is a means-plus-function term. To resolve this dispute, the court gives this term its plain and ordinary meaning and separately defines "control unit" consistent with the structure defined in the specification.

The structure must be linked to the claimed function, which in this case is "storing routines" that allow the AMS to perform certain activities. The plaintiff claims that the Alert Generation Database ("AGO") is the only structure linked to the storage of automatic evaluation routines. But the only support the plaintiff provides is Figure 2, which shows the AGO providing information to "Alert Recipients" through an "IP" connection. This is clearly related to the "transfer of information to a chosen remote user terminal," but not clearly related to "storing routines." Because the specification does not identify one structure that performs the function of "storing routines," the court must look more generally at the structures required for the AMS to perform its function.

The specification discloses that the Alarm Monitoring System ("AMSys") is "the intelligence embedded within AMS." '690 patent at 7:27-28. After an alert is received, the AMSys consults the ACU Configuration Database, which contains a "[l]ist of actions to be taken when a particular alert is detected." '690 patent at 7:27-28, 8:17-23. "Having determined the appropriate action to take," the AMSys instructs the AGO to send information to specified Alert Recipients. Id. at 7:32-57. The court finds that the structure recited by the specification for this term includes the Alarm Monitoring System, the Alarm Control Unit Configuration Database, and the Alert Generation Database.

The patent specification provides some guidance as to the meaning of "proprietary." The patent notes that in traditional security systems, "the individual components (sensors, security panels, keypads) operate solely within the confines of a single vendor solution. For example, a wireless motion sensor from vendor A cannot be used with a security panel from vendor B. Each vendor has developed sophisticated proprietary wireless technologies . . . with little or no ability for the wireless devices to operate separate from the vendor's homogenous system." '591 patent at 1:57-67. The court finds that this discussion best aligns with the defendant's proposal, "useful only with the security systems of the same vendor." Accordingly, the court adopts the defendant's proposed construction.

The defendant argues that the reverse is true—that associative binding is narrower than both binding and gateway binding. The specification says that gateway binding "can be implemented without associative binding. That may, however, involve the gateway containing code to do the data conversion from the source device's data format to the destination device's data format." '848 patent at 18:40-43. Based on this language, the court agrees that the plaintiff's construction is too broad. If gateway binding can be implemented without associative binding, associative binding cannot encompass all binding described in the patent. In fact, the patent provides the discussion of the gateway "containing code to do the data conversion" as an example of one form of gateway binding that is not associative binding. The patent also describes an example of associative binding: "Bindings are kept in a table that maps source device properties+values to destination properties+values." Therefore, the court adopts the defendant's construction.