Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 1 of 3501
`Case 1:16-cv—02690-AT Document 121-16 Filed 08/05/16 Page 1 of 3501
`
`E-6
`
`E-6
`
`

`

`
`
`-Cv-02690-AT Document iled 08/0in
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 2 of 3501
`e
`.
`6 Pa e 2
`I EWUBH? usmfisu 050313305
`STD.NEMA'Cta.La-EN6L Lfifib
`
`ANSI 012.18-1996.
`
`<length>
`
`<nak>
`
`<packet>
`<reserved>
`
`=
`
`=
`
`:=
`:=
`
`<word16>
`
`15H
`
`{ Number of bytes of data in packet. }
`
`‘ <stp> <reserved> <ctrl> <seq_nbr> <Iength> <data> <crc>
`<byte>
`{This field reserved i0r manufacturer 0r utility
`use. Value of the byte should be zero (0054) it
`the field is not used. }
`
`<seq_nbr>
`
`::= <byte>
`
`{Number that is decremented by one for each
`new packet sent. The first packet in a multiple
`packet transmission shall have a <seq_nbr>
`equal to the total number of packets minus one.
`A value of zero in this field indicates that this
`packet is the last packet of a multiple packet
`transmission.)
`
`<stp>
`
`EEH
`
`‘
`
`‘
`
`{Start of packet character.}
`
`26
`
`

`

`CmmmtAv-OZEQGHN-‘ENDDCUIHIHN 1-416I75M08/95I43635Page C-f 3501
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 3 of 3501
`
`ANSI C12.18-1996
`
`ANNEX B
`
`(Informative)
`Communication example (layer 7 and layer 2)
`
`Figures 8-1 and 8-2 show an example of a communications session between a handheld and a meter in
`which a table is read. Annex C, figure 0-1 shows the actual packet data transmission of this example.
`
`HANDHELD
`METER
`LAYER 7
`LAYER 2
`CHANNEL D'HECT'ON
`LAYER 2
`LAYER 7
`
`IDENTiFiCATlON
`REQUEST OUT
`
`I—
`
`»
`
`PACKE“
`
`2
`4—-
`
`'
`
`ACK
`
`iDENTIFiCATION
`REQUEST W
`
`.
`
`IDENTIFICATION
`
`3
`
`<—
`._€_..
`
`ACK
`
`1
`
`IDENTIFICATION
`RESPONSE OUT
`
`RESPONSE IN
`
`'
`5
`REQUEST OUT
`
`PACK“ 1
`
`I
`
`6
`4am——
`
`
`
`<——-—.7
`
`ACK
`
`‘
`
`'
`
`PACKET 1
`
`NEGOTIATE
`REQUEST IN
`
`NEGOTIATE
`RESPONSE OUT
`
`Neeome
`
`g
`
`I
`
`RESPONSE IN
`
`
`REQUEST OUT
`
`I!
`
`II
`
`'
`
`Io
`<— ACK
`
`LOGON
`REQUEST IN
`
`'
`
`<44—
`
`'
`
`LOGON
`
`RESPONSE OUT
`
`. 1
`
`RESPONSE IN
`
`Figure B-1—Communication example
`
`RESPONSE IN
`
`SECURITY
`
`REQUEST OUT
`'
`
`3
`...._..._.>
`
`<J._~_I
`
`ACK
`
`SECURnY
`REQUEST IN
`
`15
`<— PACKET 1
`
`SECURITY
`RESPONSE OUT
`
`
`
`
`
`EiI
`
`27
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 4 of 3501
`C§§é> 1N1'i3'16v-61269d95arflaecmmt JI-lfi4?5@ed10fim$§@b ngge [if 3501 ‘
`ANSI 012.18-1996
`
`LAYER 7
`
`HANDHELD
`LAYER 2
`
`«
`CHANNEL DIRECTION
`
`18
`
`‘
`
`ACK
`
`READ
`REQUEST IN
`
`READ
`RESPONSE OUT
`
`19
`
`<— -PACK“ 1
`20
`.
`
`+1——
`
`22*
`
`7
`23
`‘.———u—
`
`‘
`
`PAcKEr
`
`READ
`RESPONSE IN
`
`ACK
`
`4..»
`
`.
`
`LOGOFF
`REQUEST OUT
`
`PACKET 1
`
`' 27
`
`PACKET 1
`
`LOGOFF
`
`LOGOFF
`RESPONSE OUT
`
`RESPONSE IN
`
`LOGOFF '
`RESPONSE IN
`
`ACK
`
`TERMINATE
`REQUEST OUT
`
`PACKS 1
`
`TERMINATE
`
`ACK
`
`:
`
`.
`
`TERMINATE
`REQUEST IN
`
`TERMINATE
`
`RESPONSE OUT
`
`Figure B-2-Communication example continued
`
`28‘
`
`
`
`
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 5 of 3501
`Case flrbfiwrflefiepafle Mammal-fl HIEUWOfl/flfiuflagmfimf-Sm
`
`‘
`
`ANSI 012.13-1996
`
`ANNEX 0
`(Informative)
`Packet transmission example
`
`Figure C-i shows the actual packet data being transmitted in figures B-1 and 8-2 in Annex B. Numbers
`1)—32) refer to the numbers in figures B-1 and 8-2. All values are specified in hexadecimal format. The
`foilowing arbitrary Inferrnation was used.
`
`00
`
`01
`
`00
`
`0040 (64 bytes)
`
`04 (4 packets)
`
`08 (19200 baud)
`
`1111
`
`*0102030405060708090A
`
`0102 03 04 05 os 07 08 09 0A 013 00 on 0E OF1011121314
`
`0000
`
`000010-
`
`0096 (150 bytes)
`
`01 02 030405 060708090AOB 00 GD GE OF1011 12 1314
`15161718191A1B1C1D1E1F202122232425262728
`29 2A 2B 20 2D 2E2F 30 31 32 333435 36 373839404142
`434445 46 47 48 49 4A 4B 4C 4D 4E 4F 50 51 52 53 54 55 56
`57 58 59 5A SB 50 SD 5E 5F 60 61 62 63 64 65 66 67 68 69 6A
`6B 6C (SD 6E 6F 70 71 72 73 74 75 76 77 78 79'7A 7B 7C 7D 7E
`7F 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96
`
`i!
`
`II
`
`H H
`
`H
`
`<Std>
`
`, <ver>
`
`<rev>
`
`<packeLsize>
`
`<nbr_packet>
`
`<baud_rate>
`
`<user_id>
`
`<username>
`
`<password>
`
`<table_id>
`
`<offset>
`
`<count>
`
`<data>
`
`
`
`29
`
`
`
`

`

`Caserlrfi-fipqwfififiwfet LPDEWLeni 46111-1“- F't'fifi; 8395/1331. 151% @9173i1
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 6 of 3501
`
`ANSI C12.18-1996
`
`-—> EE 000000 0001201310
`1)
`2) <— 06 .
`3) (— EE 00 00 00 0005 00 00 01 00 00 C6 BS
`4) -—> 06
`2
`r
`5)
`-—> EE 00 20 00 0005161 0040 04 08 BA 5F
`6) <— 06
`7) (— EE 00 20 00 0005 00 0040 O4 08 7D F5
`8) ~> 06
`9) —-> EE 00 00 00 000D 501111 0102030405060708090A CA 33
`10) <— 06
`11) <— EE 00 00 000001001131
`12) —> 06
`13) —> EE 00 20 00 0015 51 0102030405060708090AOBOCODOEOF1011121314 86 27
`14) <— 06
`15) <— EE 00 20 00 0001 00 80 51
`16) —> 06
`17) —) EE 00 00 00 0008 SF 0000 000010 0096 BO 7F
`18) (— 06
`19) (— ‘EE 00 CO 02 0038 00 0096 0102030405060708090AOBOCODOEOF101 1121314151617
`181 91 A1 B1 C1 D1 E1 F202122232425262728292A2B202D2E2F303132333435 BA 8E
`
`,
`20) —) 06
`21) (— EE 00 A0 01 0038 363738393A3B3C3D3E3F404142434445464748494A4B4C4D4E4F50
`‘
`5152535455565758595A5BSCSDSESF606162636465666768696AGBBCGD F0 47
`
`22) —> 06
`23) (-— EE 00 80 00 002A 6E6F707172737475767778797A7B7C7D7E7F80818283848586
`B788898A88808D8E8F90919293949596 CS BD B1
`
`
`
`'
`24) —> 06
`25) —> EE 00 20 00 0001 52 17 20
`26) <— 06
`27) (— EE 00 20 00 0001 00 80 51
`28) —) 06
`29) —> EE 00 00 00 0001 21 9A 01
`30) e— 06
`31) (—— EE 00 00 00 000100 1131
`32) —> 06
`
`Figure C-1—Packet transmission example
`
`30'
`
`
`
`

`

`“is I. 9%156, Bageiof 3501 ‘
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 7 of 3501
`
`ANSI 012.18-1996
`
`each service may be restricted to one or more states. SpeCific,vserwces.‘also cause transitions between
`states. The transition is implemented upon positive acknoWiedgementfof‘ the service. The recognized
`states include:
`
`
`a) Base State—This is the state at which communication begins. At this point the default data
`transmission'parameters apply.
`"
`‘
`~
`
`b)
`
`iD State—Once the metering device has beenridentifiedtfthis
`
`the state that is entered.
`
`c) Session State—When a successful logon has been/completed, this is the state achieved.
`The relationship between PSEM services and service sequence
`
`Identification service requests are accepted at the base state only; Acceptance of an identification service
`request, <ok> transitions communications to the ID state.’ This sen/ice cannot Originate from the
`metering device.
`'
`3‘
`. ‘
`
`Wait service requests are accepted in the lD and session states.AcceptanCe of these requests do not
`result in any sequence state changes. This service can originatef‘rom either end oi the communication
`channel.
`’
`‘
`7
`7‘
`
`Negotiate service requests are accepted in the lD state only. AcceptanceVOf'these requests do not result
`in any sequence state changes. Negotiated services are not implemented until after acceptance. This
`service cannot originate from the metering device.
`‘
`
`Logon service requests are accepted at the lD state only. Acceptancefcf" a logon service request, <ok>
`transitions communications to the session state. This service cannot originate from the metering
`device.
`.
`
`Security service requests are accepted at the session state only. Acceptance of these requests do not
`result in any sequence state changes. This service cannot originate from the metering device.
`
`Read and write service requests are accepted in the session state only. Acceptance of these requests do
`not result in any sequence state changes. These services can originate from either end of the
`communication channel.
`
`Logoff service requests are accepted at the session state only. Acceptance of a logoff service request,
`<ok> transitions communications to the D state. This service can originate from either end of the
`communication channel.
`
`Terminate service requests are accepted at the ID and session states. Acceptance of a terminate service
`request, <ok> transitions communications to the base state. This service can originate from either end
`of the communication channel.
`
`31
`
`
`
`
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 8 of 3501
`x Case 1:16-cvg%§$<w cQQQWBmEElmeiIfiOfi/towmvPagwesebsm -
`VANSI 012.18-1996
`
`Base state
`
`ID state
`
`lndentification
`
`Negotiate
`
`-l-
`Base state
`
`Session state
`
`Figure D-1-Communication state diagram
`
`
`
`32
`
`.
`
`
`
`E
`
`g
`
`zE
`fi
`
`.
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 9 of 3501
`Case 1:16-cv-02690-AT Document 121-16 Filed 08 I
`16 Page 9 of 3501
`
` NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION
`
`1300 NORTH 17TH STREET, SUITE 900 ~_ROSSL‘1"N. VA 22209
`’
`www.NEMA.0r~g
`
`
`
`TO ORDER ADDITIONAL NEMA STANDARDS VISIT
`WVVW.GLOBAL.IHS.COM OR CALL 1-800-854-7179/1-303-397-7956
`
`
`
`
`
`
`

`

`The ‘516 Patent – Claims
`
`
`Kahn 1978
`
`
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 10 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`The Kahn reference, Kahn, Robert E., “Advances in Packet Radio Technology,” Proceedings of the IEEE, Vol. 66, No. 11 (Nov.
`1978) (Kahn 1978), includes descriptions relating to station and station‐less routing in a packet radio network.
`Invalidity Chart for U.S. Patent No. 6,249,516
`
`1. A server providing a gateway
`“A primary objective of a packet radio network is to support real‐time interactive
`between two networks, where at least
`communications between computer resources (hosts) connected to the network and
`one of the two networks is a wireless
`user terminals (e.g., terminal‐host, host‐host, and terminal‐terminal interactions).”
`network, said server comprising:
`Kahn 1978 at 1469.
`a radio modem capable of
` “Aspects of the network protocols (such as the radio acknowledgment procedures)
`communicating with a first network
`that operates, at least in part, by
`which must be performed by each radio would be distributed among all radio
`wireless communication;
`elements. However, all network control protocols which can have global effect are
`a network interface capable of
`specifically initiated by one or more entities in the network called stations. The
`communicating with a second
`resulting network control thus takes the form of a two level hierarchical system. The
`network; and
`normal mode of operation utilizes a single station or multiple station. However, a
`a digital controller coupled to said
`stationless mode is also possible.” Kahn 1978 at 1477.
`radio modem and to said network
` “Functions provided within the station software installed in 1977 included: network
`interface, said digital controller
`communicating with said first
`routing control; a gateway to other networks; a network measurement facility which
`network via said radio modem and
`collects, stores, and delivers experimental statistics from any network components; a
`communicating with said second
`debugging facility which supports examining and depositing the contents of memory
`network via said network interface,
`in the PR units; an information service which assists in locating and connecting to
`said digital controller passing data
`people currently using the PRNET; and an experiment configuration control module.”
`packets received from said first
`Kahn 1978 at 1488.
`network that are destined for said
` “The PRNET is normally connected to the ARPANET. This connection is accomplished
`second network to said second
`network, and passing data packets
`using a gateway [34] process, co‐located with the network station processor, to
`1
`
`
`

`

`The ‘516 Patent – Claims
`
`
`Kahn 1978
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 11 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`received from said second network
`communicate with an ARPANET IMP [2].” Kahn 1978 at 1494.
`that are destined for said first
` “An individual packet radio unit is a small piece of electronic equipment which
`network to said first network,
`consists of a radio section and a digital section which controls the radio. The radio
`section contains the antenna, RF transmitter/receiver, and all signal processing and
`data detection logic associated with modulation and demodulation. The digital section
`contains a microprocessor controller plus semiconductor memory for packet
`buffering and software. The radio and digital sections are connected by a high speed
`interface (see Fig. 6). For each transmitted packet, the digital unit selects the transmit
`frequency (normally fixed), data rate, power, and time of transmission. In addition, it
`performs the packet processing to route the packet through the network. In a half
`duplex mode of operation, a radio may be transmitting or receiving, but not both
`simultaneously. In the remainder of this paper we assume that each radio operates as
`a half duplex transceiver in the common frequency band.” Kahn 1978 at 1477.
` “The packet radio network structure should be capable of internetting in such a way
`that a user providing a packet address in another net can expect his network to route
`the associated packet to a point of connection with the other net or to an intermediate
`(transit) net for forwarding. Similarly, arriving internet packets should also be routed
`to the local user.” Kahn 1978 at 1470.
` “The station then deduces the overall connectivity of the network (we assume
`topologically rather than topographically) and determines good routes to itself from
`each of the radios
`in its subset. The station then distributes to each radio in its subset the route from
`that radio to the station.” Kahn 1978 at 1477.
` “As network conditions change (terminal movement, repeater failure or recovery,
`2
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 12 of 3501
`
`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`changes in hop reliability, and changes in network congestion) routes will be
`dynamically reassigned by the station to satisfy the minimum‐delay criteria.” Kahn
`1978 at 1480.
`
` “A renewal point is a PR along the route of a packet where the route (as specified in
`its header) may be altered. In point‐to‐point routing, the header contains fields which
`identify the next few designated repeaters along the path to a specified destination.
`Every repeater on a point‐to‐point route can act as a renewal point where these fields
`are rewritten. Two reasons for identifying more than just the next repeater in the
`header are to allow a detour via an alternate repeater in the event of failures along
`the designated path and to allow some repeaters not to serve as renewal points. The
`detour must be such that it eventually rejoins the designated path.
` To function as a renewal point for a point‐to‐point route, a repeater must have a
`renewal table containing the next few designated repeaters for that route. When a
`packet arrives at the next downstream repeater for relaying, its routing fields are
`rewritten in the header according to the current renewal table entries. To conserve
`table space, each repeater maintains, at most, one table entry for each
`source/destination PR pair. In addition, the table must identify the last few upstream
`repeaters on the path so that the source can be notified in the event of communication
`failures at any point of the path.” Kahn 1978 at 1482.
` “A packet may also contain an entire path of route selectors in the text of the packet.
`This case may be distinguished by a special bit in the packet header which indicates
`that the text contains all the route selectors. Such a packet is known as a route setup
`packet and is used to initialize or refresh the renewal table entries in each repeater.
`Upon receipt of a route setup packet, a repeater extracts the renewal table
`information (normally a few entries) from the entire list of selectors in the text and
`3
`
`The ‘516 Patent – Claims
`
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 13 of 3501
`
`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`writes it into the renewal table. The contents of a route setup packet are normally
`inserted by the digital unit of the destination PR. Any packet may be a route setup
`packet, subject only to the maximum packet length constraints of the network. A
`route setup packet may also contain data.” Khan 1978 at 1482.
` “In the event that one or more stations are available in the net and a point‐to‐point
`route fails (e.g., an intermediate repeater fails) the existing traffic on that route can be
`diverted to the station for forwarding to the final destination. The station must
`recompute a good route to the destination before it can forward the packet. Alternate
`routing is performed by the PR, when necessary, using parameters assigned by the
`station. Multiple receivers are allowed to forward a packet around a failed
`temporarily inaccessable repeater.” Kahn 1978 at 1479‐80.
` “As network conditions change (terminal movement, repeater failure or recovery,
`changes in hop reliability, and changes in network congestion) routes will be
`dynamically reassigned by
`the station to satisfy the minimum‐delay criteria.” Kahn 1978 at 1480.
` “The functions of a station are associated with global management of the radio net
`[24] . Generally speaking, each station is aware of all operational radios in the
`network. The stations discover the existence of new radios waiting to enter the net
`and determine when other radios have departed. The station determines the route to
`each of these radios and plays an active role in initializing, organizing, and
`maintaining the operational network. In particular, all routes are assigned by the
`station to minimize PR cost and complexity. PR's are not required to store
`information about every other PR and terminal device in the network.
` One of the requirements for controlling the PRNET is assessing the reliability of radio
`4
`
`The ‘516 Patent – Claims
`
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 14 of 3501
`
`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`links between PR 's and using the information to assign good routes. A primary source
`of link information is the PR neighbor table whose entries are collected by each radio,
`summarized, and regularly sent to the station along with other status information. For
`example, each radio reports which other radios it can hear along with raw or
`processed information for the station to determine the quality of the transmission
`path between these radios. The station then deduces the overall connectivity of the
`network (we assume topologically rather than topographically) and determines good
`routes to itself from each of the radios in its subset. The station then distributes to
`each radio in its subset the route from that radio to the station. This process is known
`as labeling. The neighbor table is maintained by each PR whether or not an
`operational station is present and can be used in a stationless mode if necessary.”
`Kahn 1978 at 1477.
` “Normal store‐and‐forward operation within the network takes place as follows. A
`user generated packet with associated addressing and control information in the
`packet header is
`input to the digital section of his packet radio, which adds some network routing and
`control information and passes the packet to the radio section for transmission to a
`nearby repeater which is identified within the packet. Upon correct receipt of the
`packet, the nearby repeater processes the header to determine if it should relay the
`packet, deliver it to an attached device, or discard it. Several nearby repeaters may
`actually hear the packet, but only one repeater (which we call the next downstream
`repeater) will typically be identified to relay it. The other repeaters, will discard the
`packet. The packet will then be relayed from repeater to repeater through the
`backbone (in a store‐and‐forward fashion using the procedure described above) until
`it arrives at the final repeater which broadcasts it directly to the user's packet radio.
`At each repeater, the packet is stored in memory until a positive acknowledgment is
`received from the next downstream repeater or a time‐out occurs.” Kahn 1978 at
`5
`
`The ‘516 Patent – Claims
`
`
`
`
`

`

`The ‘516 Patent – Claims
`
`
`Kahn 1978
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 15 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`1477.
` “Received packets are buffered in one of the receiver's descramblers prior to bit
`reordering and storage of the packet in processor memory under control of a DMA
`channel. Two receive descrambler/DMA channels are provided to allow reception of
`two successive packets with minimum interpacket arrival time.” Kahn 1978 at 1492.
` Kahn 1978 at 1480 (Fig. 9):
`
`said digital controller maintaining a
`map of data packet transmission
`paths of a plurality of clients of said
`first network, where a transmission
`
`
`
`
`“[E]ach station is aware of all operational radios in the network. The stations discover
`the existence of new radios waiting to enter the net and determine when other radios
`have departed. The station determines the route to each of these radios and plays an
`active role in initializing, organizing, and maintaining the operational network. In
`6
`
`

`

`The ‘516 Patent – Claims
`
`
`Kahn 1978
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 16 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`particular, all routes are assigned by the station to minimize PR cost and complexity.
`path of a client of said first network to
`PR's are not required to store information about every other PR and terminal device
`said server can be through one or
`more of other clients of said first
`in the network.” Kahn 1978 at 1477.
` “The station then deduces the overall connectivity of the network (we assume
`network;
`topologically rather than topographically) and determines good routes to itself from
`each of the radios in its subset.” Kahn 1978 at 1477.
` “The point‐to‐point route (which consists of an ordered set of selectors) is first
`determined by a station which is the only element in the net that knows the current
`overall system connectivity.” Kahn 1978 at 1479.
` “From the summary ROP's, each station knows the identity of its neighboring stations
`and a point‐to‐point route to each radio labeled by itself and a neighbor.” Kahn 1978
`at 1483.
`
`
`“Once the route finding packet arrives at the destination PR, it contains the estimated
`round‐trip delay for a route which works in both directions. The destination PR will
`wait long enough to receive most of these packets (which may have travelled over
`different routes), will select the route with minimum delay, and will store this as the
`best route.” Kahn 1978 at 1484.
`
`“The functions of a station are associated with global management of the radio net
`[24] . Generally speaking, each station is aware of all operational radios in the
`network. The stations discover the existence of new radios waiting to enter the net
`and determine when other radios have departed. The station determines the route to
`each of these radios and plays an active role in initializing, organizing, and
`maintaining the operational network. In particular, all routes are assigned by the
`7
`
`wherein said digital controller
`changes the transmission paths of
`clients to optimize the transmission
`paths including changing the
`transmission path from the client to
`the gateway so that the path to the
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`The ‘516 Patent – Claims
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`Kahn 1978
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 17 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`station to minimize PR cost and complexity. PR's are not required to store
`gateway is chosen from the group
`information about every other PR and terminal device in the network.
`consisting essentially of the path to
`the gateway through the least possible
` One of the requirements for controlling the PRNET is assessing the reliability of radio
`number of additional clients, the path
`links between PR 's and using the information to assign good routes. A primary source
`to the gateway through the most
`of link information is the PR neighbor table whose entries are collected by each radio,
`robust additional clients, the path to
`the gateway through the clients with
`summarized, and regularly sent to the station along with other status information. For
`example, each radio reports which other radios it can hear along with raw or
`the least amount of traffic, and the
`path to the gateway through the
`processed information for the station to determine the quality of the transmission
`path between these radios. The station then deduces the overall connectivity of the
`fastest clients.
`network (we assume topologically rather than topographically) and determines good
`
`routes to itself from each of the radios in its subset. The station then distributes to
`each radio in its subset the route from that radio to the station. This process is known
`as labeling. The neighbor table is maintained by each PR whether or not an
`operational station is present and can be used in a stationless mode if necessary.”
`Kahn 1978 at 1477.
` “In the event that one or more stations are available in the net and a point‐to‐point
`route fails (e.g., an intermediate repeater fails) the existing traffic on that route can be
`diverted to the station for forwarding to the final destination. The station must
`recompute a good route to the destination before it can forward the packet. Alternate
`routing is performed by the PR, when necessary, using parameters assigned by the
`station. Multiple receivers are allowed to forward a packet around a failed
`temporarily inaccessable repeater.” Kahn 1978 at 1479‐80.
` “As network conditions change (terminal movement, repeater failure or recovery,
`changes in hop reliability, and changes in network congestion) routes will be
`dynamically reassigned by the station to satisfy the minimum‐delay criteria.” Kahn
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`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 18 of 3501
`
`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`1978 at 1480.
` “If there was an operational station on the net, the PR's would send summary ROP's
`directly to the station at appropriate times (on a point‐to‐point route) to convey the
`current labeling information and also the neighbor table information. This is done
`both periodically and upon detection by the PR of a possibly significant change in
`some link.” Kahn 1978 at 1481.
` “3) System Monitoring: Once initialized, each packet radio in the network periodically
`announces its existence by transmitting to the station summary ROP's which contain
`neighbor tables and other status information. Similarly, terminal devices periodically
`send summary TOP's (terminal‐on packets), which serve much the same function as
`their counterpart summary ROP's.
` Both the station and the network monitor make extensive use of summary ROP's and
`TOP's. The station maintains a connectivity matrix based on the information
`contained in the ROP's for assigning routes. Current network connectivity may be
`displayed at the station upon request, and all state changes for nodes and links may
`be time stamped and logged. When active, the independent network monitoring
`system also listens to ROP's, and maintains a table of the last time that ROP's and
`TOP's were heard, for each packet radio or terminal interface unit ID. Thus, the exact
`time of failure of any network element can be obtained‐even if a component of the
`station fails.” Kahn 1978 at 1494.
`
`
`“Functions provided within the station software installed in 1977 included: network
`routing control; a gateway to other networks; a network measurement facility which
`collects, stores, and delivers experimental statistics from any network components; a
`9
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`The ‘516 Patent – Claims
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`
`
`2. A server as recited in claim 1,
`wherein the second network is a
`TCP/IP protocol network.
`
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`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 19 of 3501
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`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`debugging facility which supports examining and depositing the contents of memory
`in the PR units; an information service which assists in locating and connecting to
`people currently using the PRNET; and an experiment configuration control module.”
`Kahn 1978 at 1488.
` “The PRNET is normally connected to the ARPANET. This connection is accomplished
`using a gateway [34] process, co‐located with the network station processor, to
`communicate with an ARPANET IMP [2].” Kahn 1978 at 1494.
` “[34] V. G. Cerf and P. T. Kirstein, "Issues in packet network interconnection,” this
`issue, pp. 1386‐1408.” Kahn 1978 at 1496.
` “D. lntemetting
` The packet radio network structure should be capable of internetting in such a way
`that a user providing a packet address in another net can expect his network to route
`the associated packet to a point of connection with the other net or to an intermediate
`(transit) net for forwarding. Similarly, arriving internet packets should also be routed
`to the local user.” Kahn 1978 at 1470.
` “H. Reliable Delivery Mechanisms
`The inherent undependability of a mobile radio channel requires an end‐to‐end
`protocol to provide reliable operation. For internal network control traffic (nonuser
`traffic), where perhaps one outstanding unacknowledged packet is sufficient, a highly
`efficient but specially designed protocol suffices. For intranet user traffic, or internet
`operation, a more flexible and higher performance protocol is desirable. We assume
`an end‐to‐end error detection and retransmission technique to be used in the
`network for reliable delivery of individual packets. Each source/destination pair on
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`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 20 of 3501
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`Kahn 1978
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`the network could utilize an end‐to‐end protocol such as described in [38], which also
`supports internetworking. In this case the user's terminal could be equipped with a
`microprocessor‐based device known as a Terminal Interface Unit (TIU) which
`performs the end‐to‐end protocol, and any local support for the terminal (e.g., local
`echoing, formatting). The TIU interfaces directly to the digital unit of a packet radio.
`Within the PRNET, stations and radios need to communicate control packets reliably.
`For example, the regular reports from each radio to the station are used to validate
`the radio's continued availability. Without an effective recovery procedure
`the station could declare a perfectly good radio to be out of order and remove it from
`service if several of its reports were lost consecutively. Similarly, parameter change
`packets from the station to the radio should be delivered reliably since these are used
`to set dynamically important radio parameters, such as the retransmission interval or
`the maximum number of allowed retransmissions. The Station‐PR Protocol (SPP)
`provides the reliable delivery mechanism.”
` “By using internet protocols to access the station's X‐RAY process, even the radios
`can be remotely debugged from the ARPANET.” Kahn 1978 at 1494.
` “[38] V. G. Cerf and R. E. Kahn, "A protocol for packet network intercommunications,"
`IEEE Trans. Commun., vol. COM‐22, pp. 637‐648, May 1974.” Kahn 1978 at 1496.
` Kahn’s stations have a gateway functions to a point‐to‐point network, such as the
`internet, which would inherently involve the TCP/IP protocol, and Kahn cites to the
`Cerf and Kahn IEEE article defining TCP. At a minimum, it would have been obvious to
`use TCP/IP in the point‐to‐point protocol network in order to provide a well‐known
`and reliable protocol.
`
`
`11
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`The ‘516 Patent – Claims
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`
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`

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`The ‘516 Patent – Claims
`
`
`Kahn 1978
`
`Case 1:16-cv-02690-AT Document 121-16 Filed 08/05/16 Page 21 of 3501
`
`Exhibit B1 – Invalidity Chart for Brownrigg Family based on Kahn 1978
`“Functions provided within the station software installed in 1977 included: network
`4. A server as recited in claim 1,
`routing control; a gateway to other networks; a network measurement facility which
`wherein the digital controller
`translates data packets received from
`collects, stores, and delivers experimental statistics from any network components; a
`debugging facility which supports examining and depositing the contents of memory
`the second network and destined for
`in the PR units; an information service which assists in locating and connecting to
`the first network into a format used
`people currently using the PRNET; and an experiment configurat