Samsung’s opening claim construction was filed on April 14th.
In that Samsung argues that Neonode tries to alter the scope of its claimed invention.

879 Claim 1:
1. A non-transitory computer readable medium storing a computer program with computer program code, which, when read by a mobile handheld computer unit, allows the computer to present a user interface for the mobile handheld computer unit, the user interface comprising:

a touch sensitive area in which a representation of a function is provided, wherein the representation consists of only one option for activating the function and wherein the function is activated by a multi-step operation comprising (i) an object touching the touch sensitive area at a location where the representation is provided and then (ii) the object gliding along the touch sensitive area away from the touched location, wherein the representation of the function is not relocated or duplicated during the gliding.

Samsung is using three different arguments that Neonode is trying to “fix” its asserted claims to avoid invalidating prior-art;
1) only portion of preamble is limiting
2) plain meaning should be used, NOT needlessly complex construction. However, Samsung later themselves instead goes into (unnecessary) complex claim constructions, instead of using its plain meaning (which Neonode wants). Somewhat double standard by Samsung here.
3) inconsistent statements made by Neonode to PTO during prosecution.

Disputed claim terms:
preamble [= first section in claim that ends with …comprising:]
Samsung wants this to be limited to “user interface“
Neonode wants the whole preamble being limiting.

Preambles are normally not treated as limiting text in a patent claim.
However I don’t see what Samsung can win on this one. My guess is that if the broader reading (i.e not including mobile handheld, etc) opens up for Samsung’s planned prior-art attack.

the representation consists of only one option for activating the function
Samsung think this is indefinite… since a person-skilled-in-the-art (POSITA) can read it to mean three conflicting things;
1) single function – single option (to activate)
2) multiple functions – single option
3) single function – multiple options
According to Samsung, 2 and 3 were advocated by Neonode to the PTO. (something I haven’t seen)
Neonode want to use its plain meaning.

I think the court would go for option 1 = Neonode’s position.
One concern here is that the word “option” is not used anywhere in the specification. [something Samsung notes] and that can go both ways. The lack of use in specification can lead to its plain meaning. At the same time, the absence of it gives no good fallback for Neonode if plain meaning is not accepted.

Though I read this as “option” refers to the “representation of function“, NOT how you enable the function. This is supported by Neonode’s statement to PTO (cited by Samsung in this opening brief) to overcome prior-art Hirshberg.

gliding / object gliding along the touch sensitive area
Samsung believe this is indefinite and goes into lengthy argumentations that a drop (function) should be read into it.
Neonode want to use its plain meaning. Not including a drag and drop operation.

I think this is clear: no “drop” limitation in the claim.
Samsung has a weak case (and no support for) wanting to include “drop” in this meaning…

tapping (Claim 3)
No big deal – not much difference between the parties positions.
Also don’t see how this will effect the case. [Claim 1 is still valid and the most important]

shell upon an operating system (claim 15)
same here, no big deal, not much difference.

Summarising; It is clear that Samsung plays the indefinite card, i.e that the patent is unclear and therefore invalid. (likely together with some prior-art arguments to come during trial)

NOTE: This patent did survive the IPR, which is unusual! The jury will be fully aware of this fact.
It speaks in Neonode’s favour.