Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 1 of 11
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`Case No. 3:22-CV-3199-JD
`
`DECLARATION OF VOJIN
`OKLOBDZIJA, PH.D.
`
`Case No. 3:22-CV-3202-JD
`
`Case No. 3:21-CV-9773-JD
`
`VOIP-PAL.COM, INC.,
`Plaintiff,
`
` v.
`GOOGLE LLC,
`
` Defendant.
`
`VOIP-PAL.COM, INC.,
`Plaintiff,
`
` v.
`META PLATFORMS INC., et. al.
`
` Defendants.
`
`TWITTER, INC.,
`Plaintiff,
`
` v.
`VOIP-PAL.COM, INC.,
`
` Defendant.
`
`I, Vojin Oklobdzija, declare as follows:
`
`I.
`
`INTRODUCTION
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`1
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 2 of 11
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`1.
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`I have personal knowledge of the facts contained in this declaration and, if called as a
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`witness, I could and would competently testify to those facts. I am being compensated at my normal
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`consulting rate. My compensation does not depend on and in no way affects the substance of my
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`statements in this Declaration.
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`II. QUALIFICATIONS
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`2.
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`I am an independent consultant with Integration Corp. I reside in Berkely, California,
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`and my place of business is at 855 Marina Bay Pkwy, Suite 130, Richmond, CA 94804. I am over the
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`age of eighteen, and I am a citizen of the United States.
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`3.
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`I have over 50 years of commercial, industrial, and university experience in all aspects
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`of Electrical Engineering such as: Electronics (Analog and Digital), Telecommunication (Radio and
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`Signal Processing), Computer Science (Computer Architecture and Computer Arithmetic), Computer
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`Design (Hardware) and Semiconductor Integrated Circuits.
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`4.
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`I received a Dip.
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`Ing. degree
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`(MSc EE equivalent)
`
`in Electronics and
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`Telecommunications from the University of Belgrade, Yugoslavia in 1971, a Master of Science degree
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`in computer science from the University of California, Los Angeles in 1978, and a Doctor of
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`Philosophy (Ph.D.) degree in computer science from the University of California, Los Angeles in
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`1982.
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`5.
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`Since 1997, I have been the owner and Principal Researcher at Integration Corp., which
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`provides services to the electronics industry including consulting, research, product development,
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`design, and testing. My previous industry experience includes employment at Xerox Corp., IBM T. J.
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`Watson Research Center, Sun Microsystems, AT&T Bell Laboratories, Fujitsu Ltd., Hitachi Ltd.,
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`Sony Corp., Siemens/Infineon Corp., Intel Corp., Samsung Corp., and several startup companies, such
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`as Skyera Inc., Wave Semi Inc., Esperanto Technologies Inc., SambaNova System Inc., and including
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`my own, now defunct, startup company Silicon Analytics Inc.
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`2
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 3 of 11
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`6.
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`In addition to my work at Integration, I have been a Professor of Engineering at
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`University of California, Davis since 1991, and University Professor Emeritus since 2006. I was also
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`a professor at University of California, Berkeley from 1988 to 1990, Sydney University (Australia),
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`Ecole Politechnique Federal du Lausanne (Switzerland), University of Texas, and University of New
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`Mexico.
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`7.
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`From 1991 to 2006, I was a tenured Full Professor at the University of California,
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`Davis. While there, I established a Computer Engineering (“CE”) program in the Electrical
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`Engineering Department, which later became the Electrical and Computer Engineering Department to
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`reflect the addition of Computer Engineering. I taught all the critical courses in the CE curriculum,
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`such as Digital Systems I and Digital Systems II, Computer Architecture, Assembly Language and
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`Computer Organization, and Digital Integrated Circuits, as well as graduate courses, such as Advanced
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`Logic Design, Computer Architecture, High- Performance Computer Architecture and Computer
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`Arithmetic. During my tenure at other universities, I also taught courses in VLSI Design, Low-Power
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`VLSI Circuits Design, and Digital Logic Design, and at UC Berkeley Extension in Silicon Valley. I
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`started the Advanced Computer System Engineering Laboratory (“ACSEL”) at the University of
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`California, Davis in 1992. ACSEL consisted of my graduate students, professors associated with the
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`group, industrial researchers, and past doctoral students. ACSEL has been working on solving
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`important problems associated with computer and electronic/VLSI systems.
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`8.
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`Upon my retirement as a university professor in 2012, I returned to work full-time in
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`the industry. I joined Skyera Inc. (“Skyera”), a startup in San Jose, California, where I had the title of
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`Senior Director, Processor Design. At Skyera, I managed a group of engineers involved in designing a
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`proprietary processor for Skyera. The Skyera processor consisted of many CPUs on the chip with two
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`levels of cache hierarchy and DRAM memory.
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`3
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`

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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 4 of 11
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`9.
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`After Skyera was acquired in 2014 by Hitachi, I commenced working as a consultant
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`for Wave Semi Inc. on multi-CPU chip design. My work was on the CPU and arithmetic elements of
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`the processor, which was later tailored towards machine learning.
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`10.
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`In December of 2015, I switched to Esperanto Technologies Inc. (“Esperanto Tech.”), a
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`startup company working on a “machine-learning” chip. During my work at Esperanto Tech.,
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`I personally worked on CPU and memory design.
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`11.
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`In April of 2018, I joined SambaNova Systems Inc. (“SNS Inc.”), a Palo Alto based
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`startup that is one of the two leading companies in machine learning, having received over one billion
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`dollars in funding. At SNS Inc., I designed specialized CPUs tailored for machine learning.
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`12.
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`As detailed in my curriculum vitae, in addition to my industry, private consulting, and
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`research work, I have published numerous articles in industry journals and proceedings, presented
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`papers at industry technical and professional meetings, and participated in electronics and computer
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`science industry professional meetings, conferences, trade groups, and professional organizations.
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`13.
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`Since 1995, I have been a Fellow of the Institute of Electrical and Electronic Engineers
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`(“IEEE”), a professional organization with over 400,000 members in more than 160 countries. IEEE
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`states: “IEEE Fellow is a distinction reserved for select IEEE members whose extraordinary
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`accomplishments in any of the IEEE fields of interest are deemed fitting of this prestigious grade
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`elevation.” No more than 0.1% of the IEEE voting membership on record may be elevated to Fellow
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`in a year. Since 2014, I have been “Life Fellow of IEEE.” From 2014 to 2016, I served as President
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`of IEEE Circuits and Systems Society (IEEE’s oldest and founding society), Vice President of the
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`IEEE Circuits and Systems from 2012 to 2014, and Chair of Vision Committee of IEEE Circuits
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`and Systems Society prior to 2014. In addition, during this time, I served on the Board of Governors
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`of the IEEE from 2012-2016.
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`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 5 of 11
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`14.
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`I am the named inventor on 20 U.S. patents and four currently pending patents, all of
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`which are directed in general to computers, electronic circuits, and integrated circuits.
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`15. My experience as it specifically relates to networking dates to 1999-2000 and the work
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`on network encryption processors, for two companies Blue Steel Networks Inc. and Digital Archways
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`Inc. Blue Steel Networks Inc. was successfully sold to Broadcom Corp and became part of Broadcom,
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`owned by Avago. The processor was an ad-on network card which handled encrypted network traffic.
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`The second company related to network processors was Digital Archways Inc, which dealt with the
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`same secure network processor. The company failed and went out of business due to the lack of
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`funds.
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`16.
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`I have provided a copy of my complete curriculum vitae as an attachment to this
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`declaration as Exhibit A.
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`III.TASK
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`17.
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`I have been asked to provide testimony regarding the understanding of a person of
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`ordinary skill in the art (“POSITA”) at the time of invention regarding the technology disclosed and
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`claimed in VoIP-Pal’s patents in general, and U.S. Patent Nos. 8,630,234 (“the ’234 patent”) and
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`10,880,721 (“the ’721 patent”) in particular. This declaration is not the first time I have provided
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`testimony for VoIP-Pal. I provided expert reports in VoIP-Pal.com, Inc. v. Amazon.com, Inc., 6:21-cv-
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`00668 (WDTX); VoIP-Pal.com, Inc. v. Verizon Communications, Inc., 6:21-cv-00672 (WDTX); VoIP-
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`Pal.com, Inc. v. T-Mobile USA, Inc., 6:21-cv-00674 (WDTX) relating to the ’234 and ’721 patents. I
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`also have submitted declarations in VoIP-Pal.com, Inc. v. Meta Platform, Inc., 3:22-cv-4279
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`(NDCAL) and VoIP-Pal.com, Inc. v. Google LLC, 3:22-cv-5479 (NDCAL) relating to U.S Patent No.
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`10,218,606. While I am not a lawyer and have no formal legal training, I am a prolific inventor with
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`issued Patents, and have worked at the intersection of patents and computer technology for the past
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`several years. In making the statements in this declaration, I have relied on my education in computer
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`5
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 6 of 11
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`engineering, 50+ years of professional experience, and the ’234 and ’721 patents. In forming my
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`opinions for this Declaration, I have adopted the perspective of a POSITA as of the priority date of
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`these patents, which I am defining as follows: a POSITA would be someone with an undergraduate
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`degree in either Computer Science, Computer Engineering, Electrical Engineering, or a related
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`discipline, and would likely have about 2 years of experience in system-level development, but a
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`greater degree of professional experience could serve to replace some formal education and a higher
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`degree of education could replace some professional experience. Based on my education and
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`experience, I believe I would qualify as a POSITA both now and as of the patents’ priority date.
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`IV.DISCUSSION OF VOIP-PAL PATENTS
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`18.
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`I have been asked to explain the focus of the ’234 and ’721 patent claims. I understand
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`that the claims should be read in the context of other claims and in light of the specification as a whole
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`from the viewpoint of a person of skill in the art (“POSITA”). Below, I will explain why a POSITA
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`would understand that the invention in the claims-at-issue is focused on the concept of using an
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`“access code” to enable a calling party (or “first participant”) to initiate a communication to a called
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`party (or “second participant”) through an optimized point-of-access (or “channel”) to a network, one
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`based on the calling device’s current location and not based on conventional roaming techniques.
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`19.
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`Claim 1 of the ’234 Patent recites a method of “roaming with a mobile telephone.”
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`Here, the word “roaming” is not used in a conventional sense, because the patent specification
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`distinguishes between traditional roaming (’234 Patent at 1:18-19) and “avoid[ing]” “roaming
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`charges” (among others) by using the inventive method (id. at 13:4-9). The mobile phone is simply
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`changing location, and being allowed to make a connection to communications infrastructure by using
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`the inventive method including the specific steps below the preamble. In particular, Claim 1 recites
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`transmitting an “access code request message including said callee identifier and a location identifier
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`separate and distinctive from said callee identifier, said location identifier identifying a location of the
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`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 7 of 11
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`mobile telephone.” Claim 1 also recites “receiving an access code reply message from the access
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`server” in response, which includes “an access code different from said callee identifier and associated
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`with said location identifier and/or associated with a location pre-associated with the mobile
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`telephone.” The access code is used to “initiat[e] a call with the mobile telephone.” In Claim 1, the
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`message to the access server serves to “seek an access code from a pool of access codes,” wherein it
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`“identifies a respective telephone number of Internet Protocol (IP) network address that enables a local
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`call to be made to call the callee.” Thus, the “access code” “enables a local call to be made.” From
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`the context of the claim, as supported by the patent specification as a whole, it is apparent that the call
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`is “local” relative to the location of the calling mobile telephone, in that the access code identifies an
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`element of communication infrastructure that is geographically proximate to the calling device. The
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`claim indicates that access codes can identify a “telephone number or Internet Protocol (IP) network
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`address” to enable the local call. For example, the specification illustrates that a local call may relate
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`to a PSTN channel that is in a nearby PSTN local calling area, i.e., based on the geographical location
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`of the telephone. Id. at 9:18-35. However, Claim 1 also recites that an IP address can be used, and the
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`patent specification goes on to clarify that the concept of local is not limited to the PSTN, but can
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`instead work through channels that “need not be PSTN telephone lines.
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`Id. at 1:35-43. In other
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`words, a POSTIA would understand that Claim 1 enables supplying an access code to the mobile
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`telephone (which is “roaming” in the sense of changing its location), and that the access code will
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`identify an optimal telephone number or IP address that is “local” or geographically proximate. In the
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`case of a telephone number, the number may be connected to a “local” central office or exchange. In
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`the case of an IP address, the initiate IP address is geographically proximate to the calling mobile
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`telephone, albeit the definition of proximity or the granularity of geographical areas may differ for IP-
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`based infrastructure. For example, IP-based infrastructure may have a much larger service area such
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`as all of Western Canada or Eastern Canada, depending on such factors as latency, quality of service,
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`7
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 8 of 11
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`load capacity, and so forth. Id. at 23:26-28, 8:51-61. Claim 1 of the ’234 Patent is performed by a
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`mobile telephone but it assumes that a communication infrastructure exists that will cooperate with the
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`method performed by the phone. The mobile phone, for example, does not do routing. The mobile
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`phone merely initiates a connection to the communication infrastructure, using the claimed method.
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`20.
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`Various dependent claims provide additional details about the location identifier that
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`represents or identifies the location of the mobile telephone. Id., for example, claims 3-5, 10, are all
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`dependent from Claim 1 of the ‘’234 Patent and recite additional possible location-based features to
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`support the method of Claim 1. In addition, Claim 8 recites that an access code that is a “telephone
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`number” may identify a “channel operably configured to cooperate with an IP network to cause a call
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`involving the mobile telephone and the callee to be routed through the IP network.” This is consistent
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`with what was stated above; the mobile phone does not perform routing, but the channel identified by
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`the access code can lead to an IP network that completes the path of the communication. Claim 10
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`recites a routing controller that obtains the access code, that the “access code identifies a
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`communications channel associated with [the] location identifier,” and that the “access code is useable
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`by the mobile telephone to cause the routing controller to establish a call to the callee using the
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`channel.” Claim 10 is consistent with the concept of optimized location-based access to a network.
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`21.
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`Other independent claims (and their respective dependent claims) in the ’234 Patent
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`also focus on the concept of optimized, location-based access to the network for mobile devices, i.e.,
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`by initiating communications via a point of access to the network that is geographically proximate to
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`the device. Some of the claims focus on enabling optimized location-based network access to a
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`mobile phone or device, however, some of the claims relate to other portions of the overall system,
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`such as the access server and/or routing controller which interacts with the mobile phone or device.
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`22.
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`Independent claim 11 recites means and functions for “enabl[ing] a local call to be
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`made” by a “mobile telephone apparatus.” This includes transmitting “a location identifier separate
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`8
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 9 of 11
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`and distinctive from said callee identifier, said location identifier identifying a location of the mobile
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`telephone.” This also involves receiving a message with an “access code… associated with said
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`location identifier and/or associated with a location pre-associated with the mobile telephone.”
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`23.
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`Independent Claim 20 is a mobile telephone apparatus which causes a request to an
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`access server to be transmitted including a “a location identifier separate and distinctive from said
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`callee identifier, said location identifier identifying a location of the mobile telephone.” An access
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`code is returned which is “different from said callee identifier and associated with said location
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`identifier and/or associated with a location pre-associated with the mobile telephone,” and use of this
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`“access code” enables a “local call to be made.”
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`24.
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`Independent Claim 29 is directed to a computer readable medium which has codes to
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`enable mobile telephone roaming and to enable a local call to be made. Similarly, the claim transmits
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`a request with a “a location identifier separate and distinctive from said callee identifier, said location
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`identifier identifying a location of the mobile telephone,” and recites receiving a reply with an “access
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`code” that is “associated with said callee location identifier and/or associated with a location pre-
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`associated with the mobile telephone,” which is used by the mobile phone to initiate a call.
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`25.
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`Independent Claim 30 of the ’234 Patent recites a method for enabling mobile
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`telephone roaming, but it is focused on responding to and cooperating with a mobile telephone’s
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`requests. In other words, this claim facilitates or enables a mobile telephone to perform “roaming” (in
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`a non-conventional sense, as explained above.). Claim 30 does this by “producing an access code
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`identifying a communication channel based on said location identifier and/or based on a location pre-
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`associated with the mobile telephone.” The specification provides examples of “channels,” and this
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`was already discussed above. As explained, and as Claim 30 suggests, communication channels need
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`not be PSTN devices that are accessed through a PSTN telephone number; some channels may be
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`identified by other means, such as by an “Internet Protocol (IP) network address.” Claim 30 recites,
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`9
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 10 of 11
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`“selecting said access code from a pool of access codes, wherein each access code in said pool of
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`access codes identifies a respective telephone number or Internet Protocol (IP) network address.”
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`26.
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`Some of the dependent claims further flesh out optional features that support the
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`geographically-based network access method of independent Claim 30. For example, dependent
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`Claim 33 recites “determining from said location identifier a local calling area associated with the
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`mobile telephone and selecting an access code associated with a calling area matching said local
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`calling area associated with the mobile telephone.” Dependent Claims 35 to 37 indicate different
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`methods of supplying a “location identifier” of the phone, for example, it could be an “IP address of
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`the mobile telephone.” (Claim 35), an “identifier of a wireless voice signal station” (Claim 36), or a
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`“user-configured identifier” (Claim 37) of location, which is used to produce the “access code.”
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`27.
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`A POSITA would appreciate that every remaining independent claim in the ‘’234
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`Patent (independent Claims 46, 62, and 78) are directed to the actions of an apparatus or server that is
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`interacting with a mobile telephone or device that is initiating a communication. In each of these
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`independent claims, the concept of providing or selecting an “access code” based on a “location
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`identifier” that represents the location of the calling device, is present, and this “access code” is what
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`allows the calling mobile phone or device to gain access to the network, which will then carry the
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`communication to the “destination node” (or called party). In so doing, the calling device may bypass
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`other less-optimal, or more expensive, networks such as the networks of wireless carriers.
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`28.
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`In the ’721 Patent, each of the independent Claims 1, 20, 38 and 50 relate to the
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`operation of a mobile device at a particular location (which may change), whereas independent Claims
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`51, 77, 103, 129, and 130, relate to apparatuses or servers that respond to the aforesaid mobile devices,
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`and cooperate with them to provide them with an access code that is based on a “location identifier”
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`representing the location of the mobile device. For example, Claim 1 of the ’721 Patent recites “a
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`location identifier identifying a geographical location of the wireless device,” and also recites a reply
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`10
`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 62-7 Filed 03/20/23 Page 11 of 11
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`message that includes “an access code based on the location identifier.” These features work together
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`to enable access by the “wireless device” to a communication channel or operation through an “IP
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`network communication device” that is suitable for the mobile device. In effect, the access code
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`identifies a geographically appropriate point of access to the network for the wireless device. Each of
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`these claims recite location-based features that, while different from the above-mentioned claims in
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`certain respects, recite an inventive concept in which a mobile device is provided with optimized,
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`location-based access to suitable communications network infrastructure based on a location identifier.
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`29.
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`In view of the patent specification as a whole, and the general knowledge of a POSITA,
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`it is apparent that seeking an access code for enabling a connection by the calling device to
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`geographically proximate communications
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`infrastructure (e.g., a nearby
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`telephone central
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`office/exchange or a geographically proximate IP-based gateway or server) can optimize the
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`communication path, cost and performance: e.g., to provide monetary advantages such as reduced
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`tolls, long distance charges, roaming charges; it allows technical advantages or superior performance
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`such as reduced latency, differentiating features (e.g., videophone services), better load handling and
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`security; and it provides the benefit of keeping subscribers on your own network for billing; it enables
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`the option of sending calls via service providers of your choice that provide superior cost/service. See
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`’234 Patent at 8:33-61, 9:24-43, 9:44-58, 10:1-5, 17:36-42, 23:20-28; 24:32-35, 27:23-59, 28:20-25.
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`I declare under penalty of perjury under the laws of the State of California and United States of
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`America that the foregoing statements are true and correct.
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`Dated this 20th day of March, 2023.
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`Vojin Oklobdzija, Professor Emeritas
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`DECLARATION OF DECLARATION OF VOJIN OKLOBDZIJA
`Case Nos.: 3:22-cv-3199-JD; 3:22-cv-3203-JD; 3:21-cv-9773-JD
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