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`Case 1:16-cv-00453-RGA Document 509-1 Filed 03/15/18 Page 2 of 77 PageID #: 43551
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`1
`
`IN THE UNITED STATES DISTRICT COURT
`IN AND FOR THE DISTRICT OF DELAWARE
`- - -
`
`CIVIL ACTION
`
`NO. 16-0453-RGA
`CIVIL ACTION
`
`NO. 16-0454-RGA
`
`:::::::::::::::::::
`
`ACCELERATION BAY, LLC,
`Plaintiff,
`
`vs.
`ACTIVISION BLIZZARD,
`Defendant.
`---------------------------
`ACCELERATION BAY, LLC,
`Plaintiff,
`
`vs.
`ELECTRONIC ARTS INC.,
`Defendant.
`
`- -
`-
`Wilmington, Delaware
`Monday, December 18, 2017
`9:03 o'clock, a.m.
`-
`- -
`BEFORE: HONORABLE RICHARD G. ANDREWS, U.S.D.C.J.
`-
`- -
`
`Valerie J. Gunning
`Official Court Reporter
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`construction, that we can make sure that the claim is
`interpreted in some way that we understand, and if there's
`going to be a reconstruction of the term processor to
`include something -- to basically broaden it out so it
`doesn't require hardware, we would like the opportunity to
`brief that, and at the same time we would like the
`opportunity to brief the consequence of that.
`THE COURT: All right. Anything else?
`MR. TOMASULO: No, Your Honor. Thank you for
`
`your time.
`
`THE COURT: All right. Mr. Frankel, I did have
`one question, which I must ask you, which is not really a
`claim construction. Is it true that all your infringement
`claims are direct infringement claims?
`MR. FRANKEL: Yes.
`THE COURT: Okay. Thank you.
`MR. FRANKEL: Should I briefly address counsel's
`
`points?
`
`THE COURT: It's up to you.
`MR. FRANKEL: Just to be clear, we're not
`disputing that a processor is not hardware, but the term
`processor doesn't appear in any of these claims. At the
`time we briefed the means-plus-function elements, defendants
`had taken the position that the component was software, so
`that wasn't a dispute that the parties were considering.
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`ordering algorithm. The term appears in two separate
`limitations. And so it's a computer system for locating a
`call-in port of a portal computer.
`The call-in port is basically, in the context of
`software, a port is a logical construct which you could sort
`of look at it as the building is your IP address, your
`office is the port, and so there are 65,000 ports or, so, in
`other words, for me to get a letter to you or a phone call
`to you, I would need to know the address of the building,
`and then I would also need to know your suite address or
`something like that. So that's kind of what a port is. And
`so the port plus the IP address constitutes the complete
`address of an application. In other words, so if I'm trying
`to contact an application that's running the plaintiff's
`software, I need to know what the computer's address is.
`That's the address of the portable computer. And I need to
`know which of the 65,000 ports that that computer has
`allocated for the specific process that I'm trying to
`contact. So that's what a port is.
`THE COURT: Okay.
`MR. TOMASULO: Is that clear enough or clear
`enough for now?
`THE COURT: It's clear enough for now.
`MR. TOMASULO: Okay. So what this is talking
`about is in the context of the patent as a whole, this is a
`
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`Now that they've raised, they've changed their construction
`for component, that's why this issue is coming to the
`forefront.
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`1
`peer-to-peer network where all of the -- the network is sort
`2
`of self-contained. So if I'm the seeking computer, I need
`3
`to try to find a portal computer. That's a specially
`4
`designated member of the broadcast channel that is ready to
`And everything that the Court cited in its order
`5
`receive me and help me join the network. So I know the
`construing the means-plus-function claims, all of the
`6
`identity of these portal computers, but I don't know what
`citations to the specification are directed to algorithms.
`7
`port they have been deciding to operate on. And so the
`None of them are talking about a particular processor.
`8
`purpose of this is for me as a seeking computer to try to
`THE COURT: All right. Thank you.
`9
`guess which port the portable computer has opened up for the
`MR. TOMASULO: We have one more term. So the
`10
`application, so I can make contact with that particular
`last term, Your Honor, is port ordering algorithm.
`11
`portal computer.
`THE COURT: Right.
`12
`And so what they talk about here is, the
`MR. TOMASULO: I can start off by sort of
`13
`component has to have the means for identifying the portal
`helping frame the dispute.
`14
`computer. In other words, I have to be able to find the
`THE COURT: Actually, before you do that, one
`15
`portable computer in the first place. And the portable
`more random question that I have is: How many asserted
`16
`computer has a dynamically selected call-in port for
`claims are there right now?
`17
`communicating with other computers. In other words, when
`MR. TOMASULO: Sixteen, or something like that.
`18
`the portal computer has dynamically selected a specific port
`THE COURT: Okay.
`19
`that it is going to be operating on, and so that -- so I
`MR. TOMASULO: Six patents.
`20
`need to know, I have a means to identify the portal
`THE COURT: All right.
`21
`computer, but I'm also going to need to figure out what port
`MR. TOMASULO: So here is part of the
`22
`that portable computer is operating on. Otherwise, I will
`construction. The issue is, can the claimed algorithym
`23
`not be able to make contact.
`include random ordering of the ports?
`24
`So it says the means for identifying the call-in
`THE COURT: Right.
`25
`MR. TOMASULO: Again, here's the claim. Port
`port of the identified portal computer by trying to
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`| “Appl,No.09/628,042
`
`
`sExpressMailLabelEV335522411US
`
`
`InesDocketNo.030048008
`
`We
`PATENT
`6 Ry
`bg
`INTHEUNITEDSTATES PATENTANDTRADEMARKOFFICE
`Pr 8 |)
`
`eee:
`INRYAPPLICATiONOF FREOB. HOLTeran
`EXAMINER: BRADLEYE. EpeuMaANn
`aCOrCATIONNO.:
`-09/689,042
`| ArrUner:
`2153
`Fru:
`JULY 31, 2000
`| Cone. No:
`4750
`
`pose
`wie jem,
`
`on
`
`\
`
`For: DISTRIBUTED GAME ENVIRONMENT
`
` «RECEIVED
`Amendorent Under37 CFR. §1.111
`SEP 15 2003
`Technology Center 2100
`
`Obaa
`
`Alexandria, VA22313-1450
`
`Sir:
`
`In response to the Office Action dated May 21, 2003, please amend the above-identified
`
`application asfollows:
`
`Amendments to the Claims are reflected in the listing of the Claims. which begins on
`
`page 2 ofthis paper.
`
`Amendments to the Drawings begm on page 6 of this paper and includeattached
`
`drawingsheets.
`
`Remarks/Arguments begin on pave 7 ofthis paper
`
`Oo1oaed RSAYGRL: GuGG000R OGLAIOG?
`
`GTR.
`
`6
`
`{OG004BORDA 2005-05-23 RESPONSEDOG)
`
`4
`
`“see
`
`Page 02330
`
`ATV1I0013079
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`
`
`Case 1:16-cv-00453-RGA Document 509-1 Filed 03/15/18 Page 12 of 77 PageID #: 43561
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`PUARBI, Ne, 09/629,042
`
`
`
`Amendments to the Claims
`
`
`
`irney Docket No, 030048000US
`
`This listing of claims will replace all prior versions, and listings, of claims in the
`
`maintains
`i_Bpplication:
`Iaanenenneerens)
`
`networkism-regular,wheremistheexactnumberofneighbor participantsofeach
`
`t.
`
`(Currently amended) A computer network for providing a gameenvironment for a
`
`plurality of participants, each participant having connections
`
`fo at
`
`least
`
`three neighbor
`
`participants, wherein an originating participant sends data to the other participants by sendingthe
`
`data through each of ifs connections to its neighbor participants and wherein each participant
`
`sends data that it receives from a neighbor participant to its other neighbor participants,farther
`
`whereinthe
`
`<
`
`(Original) The computer network of claim | wherein each participant is connected
`
`to-4 other participants.
`
`3,
`
`(Original) The computer network ofclaim | wherein each participant is connected
`
`to an even number ofother participants.
`
`wool
`
`4.
`Fee
`
`(Cancelled)
`
`H ‘ {Onginal) The computer network ofclaim ] wherein the network is m-connected,
`
`where m is the number ofneighbor participants of each participant.
`
`[03004CONBIOA 2003.05.21 RESPONBE.DOR!
`
`Z
`AY
`
`“ye
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`Page02331
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`ATV1I0013080
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`Case 1:16-cv-00453-RGA Document 509-1 Filed 03/15/18 Page 13 of 77 PagelD #: 43562
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`\
`
`“ Appl. No. 09/628,042
`
`
`
`
`
`Scdrney Docket No. o3d04a009UIS
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`& (Original) The computer network of claim 1 wherein the network is m-regular and
`
`m-connected, where m is the number ofneighbor participants ofeach participant.
`
`Pp
`(Original) The computernetwork ofclaim | wherein all the participants are peers,
`L (Original)Thecomputer network ofclaim | wherein theconnectionsarepeer-to-
`ifrrm
`
`2°—(Original) The computer network ofclaim 1 wherein the connections ate TCP/AP
`
`JS (Original) The computer network ofclaim | wherein each participant is a process
`
`executing on a computer.
`
`,A
`
`t—Original) The computer network of claim 1 wherein a compater hosts more than
`
`one participant.
`
`{
`JX—(Original) The computer network of claim 1 wherein each participant sends to each
`
`ofits neighbors only one copy ofthe data.
`
`he
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`(Original) The computer network of claim 1] wherein the interconnections of
`
`participants form a broadcast channel for a gameofinterest.
`
`$02004BOOGIDA 2002-05-21 RESPONSEDOC}
`
`-3b>
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`fs
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`Page023320
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`ATV10013081
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`Case 1:16-cv-00453-RGA Document 509-1 Filed 03/15/18 Page 14 of 77 PageID #: 43563
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`“Appl, No. 08/629,042 ©)
`
`
`smey Docket Ne. o30048009US
`
`7J—(
`
`Currently Amended)Adistributed game systemcomprising:
`
`a plurality of broadcast channels, each broadcast channel for playing a game,each
`
`ofthebroadcastchannelsforprovidinggameinformation related to sai
`
`
`
`means for connecting to the identified broadcast channel L-
`
`means for identifying abroadcast channel for a game ofinterest; and
`
`sultinginanon-completegraph,
`
`Je (Gripinal)Thedistributedgamesystemofclaim Iimeansforidentifyinga
`
`>
`
`game ofinterest includes accessing a web server that maps games to corresponding broadcast
`
`channel
`
`io[?,
`es
`
`=
`(Original) The distributed game system ofclaim 14 wherein a broadcast channel is
`
`formed by player computers that are each intercanmected fo at least three orher computers.
`
` _ t=
`
`[03004BOOS/DA2008-05-21 RESPONSENOG}
`
`éj[ 4
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`ates
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`Page 02333
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`(D3004,8N09/OA 2003-05-21 RESPONSE.DOG]
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`4S
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`| ‘Appi. No. 08/629,042 ©
`
`
`C2iney Docket No. 0300480038US
`
`The attached sheets of drawings include changes to Figures 6 and 7. These sheets, which
`
`include Figures 6 and 7, replace the onginal sheets including Figures 6 and 7, respectively.
`
`Attachment: Replacement Sheets
`
`(03004,B0C9OA 2003-05-21 RESPONSEDOC}
`
`6
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`Page 02335
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`ATVI0013084
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`‘Appl. No, 09/629,042
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`
`
`
`ey Docket No. 030048009US
`
`
`
`Reconsideration and withdrawalofthe rejections set forth in the OfficeAction dated May
`
`21, 2003 are respectfullyrequested. In that Office Action, the Examiner objectedto the drawings
`
`as failing to include certain reference signs mentioned im the description. Twa replacement sheets
`
`for Figures @ and 7 are submitted herewith with the appropriate reference signs included. The
`
`Examiner is requested to approve these replacement sheets for entry into this application.
`
`Turning to the rejection of the claims based upon the prior art, the Examiner rejects
`
`Claims. 14-16 under 35 U.S.C. § 102(b) being anticipated by Micrusoft's Interset Gaming Zone:
`
`as well as being in public use more than one year prior to the filing date of this application as
`
`evidenced by the Internet Gaming Zone (1GZ) article. The Examiner aiso rejects Claims 1-13 as
`
`being obvious over the Alager et al. paper.
`
`
`
`|
`
`The IGZ article is a press release detailing the Internet Gaming Zone by Microsoft. As
`detailed inthe press release, the [GZ article describes a system that allows fer multi-playergaming
`
`via the Internet. There is however no indication as to how such a network system is implemented,
`
`‘The Alagar reference relates to a reliable mobile wireless network. The term “mobile
`
`wireless network" as used in Alagar means that the network does not contain any static support
`
`stations. The example given in the Alagar reference is of a military theater where each of the
`
`nodes (troops, tanks, etc:
`
`.
`
`. ) are mobile and can communicaie with each other using wireless
`
`transmissions. Because of the mobile nature of the network, there are frequent changes in link
`
`connectivity between various nodes. The mobile wireless network, because it does not contain
`
`any static support stations, is dissimilar to the Internet or even cellular telephony.
`
`JOSOO4SONG/OA2003.08.21RESPONSECOC!
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`7
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`h
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`Appl. No. 099629,042
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`
`
`
`
`dmey Docket No. o30048006US
`
`Because ofthe mobile nature ofthe network nodes, the Alagar reference teaches thal two
`
`mobile nodes are “neighbors” if they can hear each other. Each host detects its neighbors by
`
`periodically broadcasting a probe message. A host
`
`that hears a probe message sends an
`
`acknowledgement to the probing host. Every host maintains a list of neighbors and periodically
`
`updates the list based on acknowledgements received. When two hosts become neighbors, a
`
`wirelesslink is established between them, and they execute a handshake procedure. As part of the
`
`handshakeprocedure, they update their list of neighbors.
`
`Because of the mobile nature of the nodes, # is not uncontmion that the link may be
`
`disconnected between two nodes. Because of this, messaves are transmilted from node to node
`
`using a flooding methodology that involves transmitting the message to every node im the
`
`network. Thus, to broadcast a message, a mobile node transmits the measage to all of its
`
`neighbors. On receiving a broadcast message, an intermediate mobile host retransmits the
`
`message to all ofits neighbors. The Alagar reference also provides a methodology for limitingthe
`
`amount of yetransmission of messages.
`
`‘This is accomplished by means of an acknowledgement
`
`protocol,
`
`
`
`The Examiner rejects Claims14-16 under 35 US.C. §102 as boing anticipated by the 1GZ
`“article. The Examiner argues that the 1GZ article discloses a plurality of broadoast channels and
`
`means for broadcasting a broadcast channel for topics ofinterest.
`
`Next, the Examiner rejects Claims 1-13 under 35 U.S.C. § 103 as beingobvious over the
`
`Alagar etal. reference. The Examiner argues that Alagar discloses a plurality of nodes thatform a
`
`network and that the data is sent ic theother participants by a flooding techmque.
`
`Applicants respectfilly request reconsideration.
`
`[23004SONN/OA2003.05-2} RESPONSE.DOR}
`
`8
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`NK
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`.
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`Appl. No, 09/629,042
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`
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`
`
`a
`fecarney Docket No, 090048008US
`
`Applicants
`
`Applicants have significantly amended independent Claims 1 and 14.
`
`In addition, new
`
`made to Claim 14 to includeall of the limitations of Claim 1, the arguments will be primarily directed towards theAlagar refereniuewhich was used to reject Claims 1-13.
`
`independent Claims 17 and 19 have been added which applicants believe should be allowable over
`
`the cited prior art in view of the remarks set forth below.
`
`In view of the substantial amendments
`
`Firat, one iniportant aspect of the Alagar reference is that the flooding protocol disclosed
`
`in Alagar dictates that when a node receives a message, that node will rebroadeadt that message to
`
`ali of ite neighbors. See Alager at page 239, column 1, lines 13-15. Specifically, the Alagar
`
`reference at page 239, column 2, lines7-23 dictates that whenevera host (1.¢., node) receives a
`
`message, that message is broadcast to all ofits neighbors.
`
`Tn contrast, the present claimed invention of Claim 1 dictates and requires that each
`
`participant only rebroadcasts received messages to its neighbors other than the neighbor from
`
`which the node received the message.
`
`‘The Alugarreference requires a larger number of messages
`
`to be broadcast. Por example, if mis the number ofnodes and N is the number of neighbors for
`
`each node, then the total number of messages ism x N.
`
`In contrast, by limiting the rebroadcast to “other neighbors,” this reduces the number of
`
`messages to be broadcast ta (m-1)N + 1. For large networks, the saved bandwidth can be
`
`significant. For this sole reason alone, Claim | has a requirement of “other neighbors" which is
`
`wot fairly shown in the Alagar reference. Therefore, Claim | and all dependent claims therefrom
`
`are in condition for adawance.
`
`Secondly, the Alegar reference teaches the indigeriminant linking with neighbors regardless
`
`For example, Alagar
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`of the number of total neighbors that are capable of heing connected.
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`103004SQUSIDA 2003.05.01 RESPONSE.DOC]
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`_ Appl. No, 09/629,042
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`network. Thus, Figure | ofthe Alagar reference shows a complete eraph. Eachof the nodes has
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`teaches that the definition of a “neighbor”is any two mobile hosts that can “hear eachother. See
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`Alagar at page 238, columm1, fines 5-6.
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`In other words, there is no "regularity" to the network
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`formed by Alagar because each of the nodes can link to as few as one neighbor or a potentially
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`extremely large number ofneighbors. The only limitation is that the node will link and classify as
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`a neighbor any other node that is within hearing distance. This is precisely the opposite of the
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`amended claimed invention Claim 1 as amended requires that cach participant in the network
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`connects to andforms a neighbor bondto exactly an m number of neighbors
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`Independent clainis
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`i4 and 17contain similar limitations.
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`Figure 1 of the Alagar reference is deceiving in that it coincidentally shows « 4-regular
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`network. However, thatis aot the typical situation as is clear from a caretul review of the Alagar
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`reference. Calum 1 of page 236 of the Alagar reference clearly indicates that there is in fut
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`nonrepularity in a computer network formed because the number of neighbors is not set at a
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`predetermined number, but rather based upon the particular encountered terrain of the mobile
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`nodes.
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`Claim 1 as amended requires that the computer network be m regular at substantially alt
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`times where there are not new nodes entering or leaving the network. Furthermore, Claim 17
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`requires thet the networkis “in a stable 4-regular state.” For this reason, the claims are allowable
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`over thecited prior art.
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`Third, and yet another independent reason for allowing the claims, as amended, over the
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`Alagar patent, is that the claims as amended now require that the computer network so formed is
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`not 4 “complete graph." A complete graph is a network thatis characterized by N=m+ 1. A
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`"complete graph" in graph theory is that each node has @ connection to every other node in the
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`(03004.SO0G/5A 2003-05-21 RESPONSE.DOC}
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` "Appl. No, 09/628,042
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`a connectionto every other nade in the network. Obviously, for a five-nade network, this will
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`network. Claim 19 is specifically directedto this aspect of theinverition.
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`require four communications connections for each node.
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`Cisims | and 17 have been amended to recite that there are at least two more nodes than
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`there are maxima number of neighbors. For example, Claun 17 requires that for a 4-regular
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`network, there are at least six participants, Claim 1 requires that the parameter N is at least two
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`greater than the parameter m. Alagar does notshow this limitation whatzocver.
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`In fact, the only
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`m-reguiar network shown in Alager is a complete graph.
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`It is the combination of having a
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`computer network that is m regular and that is not a complete graph that is patentable over the
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`Alapar reference. This combination has been shown to produce an efficient and stable computer
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`In view of the foregoing,
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`the claims pending in the application comply with the
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`reqiirements of35 U.S.C. § 112 and patentably define over the prior art. ANotice of Allowance
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`is, therefore, respectfully requested.
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`If the Examiner has any questions or believes a telephone
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`conference would expedite prosecution ofthisapplication, the Examiner is encouraged to call the
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`undersigned af (206) 359-6488.
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`Yeofes_ote aicsci
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`pac OE ee
`.
`Chun M. Ng
`=>
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`Registration No, 36,878
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`Respectfully submitted,
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`Perkins Coie LLP
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`Correspondence Address:
`Customer No. 25096
`Perkins Cole LLP
`P.O, Bax 1247
`Seattle, Washington 98111-1247
`(206) 349-8000
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`$03004BO08/OA 2009-05-21 RESPONSEDOC]
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`a
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`EXHIBIT F-13
`EXHIBIT F-13
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`OS,65; 64
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`ry
`Express Mail No, EV336677851US
`a»
`IN THE UNITED STATES PATENT AND TRADEMARKOFFICE
`
`
`
`RE APPLICATION OF: FRED B.HOLT ET AL.
`
`APPLICATION NO.:
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`09/629,576
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`FILED:
`
`JULY 31, 2000
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`2155
`‘_Dsitorney DocketNo. 03004ER01US
`yi
`eT Fr
`patent oewad
`a“
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`tr?
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`EXAMINER: YOUNG N. Won
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`ARTUNIT:
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`2155
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`ConF. No:
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`5408
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`For: BROADCASTING NETWORK
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`Amendment Under 37G.F.R.§ 1.111 RECEIVED
`Commissioner for Patents
`4
`MAY 0 7 2004
`P.O. Box 1450
`Alexandria, VA 22313-1450
`Technology Center 2100
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`Sir;
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`The present communication responds to the Office Action dated February 4,
`2004 in the above-identified application. Please amend the application as follows:
`
`Amendments to the Specification begin on page 2.
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`Amendments to the Claims are reflected In the listing of claims- beginning on
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`page 6.
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`Remarks begin on page 13.
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`.
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`2
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`“fe
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`Jus
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`Page 00248
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`(‘)
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`c iis Docket No. Gl00sa007US
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`Amendments to the Specification:
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`in accordance with 37 CFR 1.72(b), an abstractof the disclosure has been
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`In accordance with 37 CFR 1.73, a brief surnmary of the invention
`included on page 3.
`has been included on page 4.
`[In addition, the status of the related caseslisted an page
`4 of the specification has been undated and can be found on page 5.
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`Page 00249
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`{
`f
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`gf
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`; agdesgoo1us
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`{3
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`ABSTRACT
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`A technique for broadcasting data across a network is provided. An originating
`participant sends data to another participant, which in turn sends the date that it
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`receives from a neighbor participant to its other neighbor participants. Communication
`in the broadcast network is controlled by a contact module that locates the neighbor
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`participants to which the seeking participant can be connected and by a join module that
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`establishes the connection between the neighbor participants and the seeking
`participant. Data is nurnbered sequentially so that data that is received out of order can
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`\"
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`be queued and rearranged.
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`$$$tf
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`Page 00250
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`ATV10009322
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` SUNMARY OF THE INVENTION
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`Embadiments of the invention deal with a non-routing table based method for
`broadcasting messages in a network. More specifically, a network in which each
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`participant has at least three neighbor participants broadcasts data through each of its
`connections fo neighbor participants, which in turn send the data that it receives to its
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`other neighbor participants. The data is numbered sequentially so that data that is
`received out of order can be queued and rearranged.
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`Communication within the broadcast channel is controlled by a contact module
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`and by a join module. The cantact module locates a portal computer and requests the
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`located portal computer to provide an indication of neighbor participants to which the
`participant can be connected. The join module receives the indication of the neighbor
`participants and establishes a connection between the seeking participant and each of
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`the indicated neighbor participants.
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`Each participant in the network is connected to neighbor participants, and the
`paricipants and connections between them form an m-requiar graph, where m is
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`in addition, when a participant receives data from a neighbor
`greater than 2.
`participant,it sends the data to &s other neighbor participants.
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`eeenancies |
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`Page 00251
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`ATV1I0009323
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`Case 1:16-cv-00453-RGA Document 509-1 Filed 03/15/18 Page 27 of 77 PageID #: 43576
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`
`
`CHANNEL,” filed on July 31, 2000 ¢@ tomey-Decket-No-03004
`Application No.00/629,577, “LEAVING A BROADCAST CHANNEL,” filed oni St,
`2000Sata (, Dasket-No--036048008-US}, U.S. Patent Application No._09/629,575,
`antiled "BROABCASTING ON A BROADCAST CHANNEL,” filed on July 31, 2000
`oo
`
`(AttorneyBocks
`U.S. Patent Application No.nae Sentitled
`
`Patent Application No,_09/629,043,
`entitled
`‘ mr
`AUCTION SYSTEM,” filedon July31,oysterrrsy Ducks
`Wor gsesssosr vs LS
`
`“NOTUSOU4SDOTUS), U.S. Patent
`SERVICE,” fled on July 31, 2000.
`Application No._09/629,024, eittitied “DISTRIBUTED cSON} ERENCING SYSTEN,* filed
`
`on July 34, 2000
`(Attorney Desket-No--030048008-99 and U.S. Patent Application
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`No,09/628,042,
`entifled
`“DISTRIBUTED GAME
`ENVIRONMENT,”
`filed
`on
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`
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`y OOF800SUS),Atorney—t Pees
`July 31, 2000
`pey—Decket-No--08
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`incorporatedherein by referende
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`
`,
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`the disclosures of which are
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`a
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`5
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`Page 00252
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`+*
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`pee
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`{ ?
`9
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`- Amendments to the Claims:
`
`leet
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`Si
`ey
`Docket No.
`re
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`OOS
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`Following is a complete listing of the claims pending in the application, as
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`“ol
`
`
`
`
`
`amended:
`
`
`4.
`(Currently Arnended)
`A non-routing table based computer network
`having a plurality of participants, each participant having connections to at least three
`neighbor participants, wherein an originating participant sends data to the other
`participants by sending the data through each of its connections to its neighbor
`participants, and wherein each participant sends data that it receives from a neighbor
`
`participant fo its other neighbor participants, and wherein data is numbered sequentially
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`80that data received out of order can be queued and rearranged.
`
`
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`The computer network of claim 1 wherein each parlicipantis
`(Original)
`2.
`connected to 4 otherparticipants.
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`3
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`(Original)
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`The carnputer network of claim 1 wherein each participant is
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`connected to an even number of other participants.
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`The acl network of claim 1 wherein the nebwork is m-
`{Original}
`4.
`regular, where m is the number of neighbor participants of each participant.
`
`
`(Original)
`5.
`The
`connected, where m is the numb
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`6.
`
`(Original)
`
` T
`
`
`
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`reguiar and m-connected, where m is the number of neighbor participants of each
`
`
`4
`AO (Original}
`are peers.
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`The computer network of claim 1 wherein all the participants
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`Page 00253
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`ATV1I0009325
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`FZ
`faa
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`* AttomayDocketNe, Ga6048001US
`‘2
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`ae
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`(Original)
`
`The cornputer network of claim 1 wherein the connections
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`are peerto-peer connections.
`ve
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`are TCPHP connections.
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`AS—{Original) ~The computer network of claim 1 wherein the connections
`
`The computer network of claim 1 wherein each participant is
`se (Srginal)
`a process executing on a computer.
`
`% 3
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`4=(Original)=The computer network of claim 1 wherein a computer hosts
`more than one participant.
`
`4
`
`4
`x
`
`4ێ.
`
`(Original)
`
`The computer network of claim 1 wherein each participant
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`sends to each of its neighbors only one copy of the data.
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`
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`14,=(Original) vRG component of claim 13 wherein each participant is a
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`computer process.
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`
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`
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`45. (Original)/The component of claim 13 wherein the indicated
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`
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`participants are computér processes executing on different computer systems.
`poe
`/
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`eet
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`He
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`Page 00254
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`{
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`G
`Hetil
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`=" AltomayDocketNo. G40048001U5
`Y
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`16.
`
`(Original)
`
`The componenf of claim 13 including:
`
`a broadcast module that receives data from a neighbor participant of the
`
`participant and transmits the regeived data to the other neighbor participants.
`
`
`
`17.
`
`(Original)
`
`The component of claim 13 including:
`
`
`
`
`{ module that receives a request to connect to another
`
`Ara neighbor participant, and con