Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 1 of 2892
`Case 1:16-cv—02690-AT Document 121-18 Filed 08/05/16 Page 1 of 2892
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`E-8
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`E-8
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`

`
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`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 2 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`a sensor configured to translate a physical condition
`into an analog version of the application system
`input.
`
`standard interface for the attachment of any number of I/O devices.” ‘650
`patent, 7:24-27.
`
`“The DA 102 can be programmed to periodically (e.g., once a month) read the
`meters by issuing commands to the I/O device. The I/O device 206 can
`continuously read the meters or be powered down to conserve energy. In the
`preferred embodiment, the I/O device is kept in a low power state and activated
`under control of the DA 102. When I/O device is activated, it reads all of the
`meters 502, 504, 506 and transfers the measured data to DA 102.” ‘’650
`patent, 9:37-45.
`
`“Those skilled in the art will recognize that minor changes can be made to the
`foregoing method. For example, a meter reading may be initiated by the first
`APP 112 to request data for a billing period. When the APP 112 requests meter
`data, the DCS 100 sends a command to the DA 102 which in turn commands
`the I/O device to transfer meter data from all of the meters to its primary cache
`202.” ‘650 patent, 10:6-12.
`“The system provides a remotely located data acquisition device which may be
`a sensor or a piece of equipment which performs a specific active function,
`such as irrigation in agricultural environments or control of a manufacturing
`assembly line.” ‘650 patent, 4:25-28.
`
`“A significant advantage of the program storage is that in combination with the
`uniform I/O connector interface, it allows a single interchangeable RF
`transceiver type to be customized to work with a wide variety of devices, such
`as weather or security sensors, agricultural devices, manufacturing equipment,
`etc.” ‘650 patent, 5:37-42.
`
`“User applications may be any activity suitable for a system which requires
`data from a wide area to be transmitted to a central control point. For example,
`in a vineyard operation, each DA 112 could be a sensor device such as a
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 3 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`
`51. The system as defined in claim 49, wherein the
`at least one gateway translates the RF signal and the
`RF control signal into TCP/IP for communication
`over the WAN.
`
`weather station or ground water monitor, a unit of active equipment such as
`fertilizing or irrigation equipment, etc., or a combination of any of these
`devices. Each APP 112 can be used for a specific purpose such as water
`monitoring, fertilizing, etc.” ‘650 patent, 6:2-10.
`
`The above contentions for claim 49 are hereby incorporated by reference.
`
`“In the preferred embodiment, APPs 112 can access any appropriate DA 102.
`The purpose and timing of each access can vary from APP 112 to APP 112.
`However, some of the data used by each APP 112 may be the same. Therefore,
`by caching the data, the DA 102 does not have to regenerate it for each APP
`112. This figure also illustrates that APPs 112 can reside within the processor
`104 or at a remote location which accesses DAs 102 through the DCS. As
`shown, remote APPs 112 are connected to processor 104 by client connectors
`110 (hereinafter CC 110) via RF links 114 or conventional telephone links 116.
`Those skilled in the art will recognize that the CCs 110 can be any suitable
`hardware and software needed to convert received data and commands to a
`form suitable for the software in the processor 104. The techniques required to
`implement a CC 110 are well known in the art.” ‘650 patent, 6:11-26.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`To the extent that Plaintiffs contend that this claim limitation is not disclosed
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 4 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`explicitly or inherently in the ‘650 patent, it would have been obvious to a
`person ordinary skill in the art to combine and/or modify the ‘650 patent with
`the teachings of one or more of the additional references teaching this
`limitation, for example:
`
`Jubin discloses:
`
`“The PRNET can also be accessed from other networks via an Internet
`gateway.” Jubin page 23.
`
`Burchfiel discloses:
`“When some other network is present, it is important to provide connections
`between the terminals and hosts of the PRN and the terminals and hosts of the
`other network. This is being done for the ARPANET in two ways:
`1. For communications with ARPANET hosts which support a protocol
`congruent with the PRN connection protocol (the Cerf-Kahn protocol
`mentioned previously qualifies here), the station functions as an
`extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header format is converted to that of the
`destination network. …
`2. The second approach will be conversion between the host-host
`protocols of the two networks….” Burchfiel page 249.
`
`
`Figure 4, Burchfiel page 249.
`
`Figure 5, Burchfiel page 250.
`
`“Finally, the PRN TELENT process performs the second type of gateway
`function described above: conversion between the PRN connection protocol
`and the ARPANET host-host protocol. Terminals on the PRN appear identical
`to the terminals attached to the PDP-11, and are able to access remote
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 5 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`ARPANET service hosts in the same way.” Burchfiel page 250.
`
`The ‘773 patent discloses:
`
`“Providing Gateway Services to the individual Minion devices means that all
`Minion devices effectively become part of the Internet as shown in FIG. 2.
`Status enquiries and data messages can originate at any Internet workstation in
`the world and can be directed to any Minion device." ‘773 patent, 7:39-43.
`
`‘773 patent, Figure 2.
`
`The ‘817 patent discloses:
`
`“FIG. 3 schematically illustrates a communication protocol in accordance with
`the present invention. This protocol is explained in greater detail below.
`However, it may be briefly summarized as entailing use of the TCP and IP
`protocols for communications among the server 20 (FIG. 1) and the
`node/collector units 18 (only one of which is shown in FIG. 1.” ‘817 patent,
`6:1-8.
`
`The above contentions for claim 49 are hereby incorporated by reference.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`
`52. The system as defined in claim 49, wherein the
`WAN in the Internet.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 6 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`
`To the extent that Plaintiffs contend that this claim limitation is not disclosed
`explicitly or inherently in the ‘650 patent, it would have been obvious to a
`person ordinary skill in the art to combine and/or modify the ‘650 patent with
`the teachings of one or more of the additional references teaching this
`limitation, for example:
`
`Jubin discloses:
`
`“The PRNET can also be accessed from other networks via an Internet
`gateway.” Jubin page 23.
`
`Burchfiel discloses:
`“When some other network is present, it is important to provide connections
`between the terminals and hosts of the PRN and the terminals and hosts of the
`other network. This is being done for the ARPANET in two ways:
`1. For communications with ARPANET hosts which support a protocol
`congruent with the PRN connection protocol (the Cerf-Kahn protocol
`mentioned previously qualifies here), the station functions as an
`extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header format is converted to that of the
`destination network. …
`2. The second approach will be conversion between the host-host
`protocols of the two networks….” Burchfiel page 249.
`
`
`Figure 4, Burchfiel page 249.
`
`Figure 5, Burchfiel page 250.
`
`“Finally, the PRN TELENT process performs the second type of gateway
`function described above: conversion between the PRN connection protocol
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 7 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`and the ARPANET host-host protocol. Terminals on the PRN appear identical
`to the terminals attached to the PDP-11, and are able to access remote
`ARPANET service hosts in the same way.” Burchfiel page 250.
`
`The ‘773 patent discloses:
`
`“Providing Gateway Services to the individual Minion devices means that all
`Minion devices effectively become part of the Internet as shown in FIG. 2.
`Status enquiries and data messages can originate at any Internet workstation in
`the world and can be directed to any Minion device." ‘773 patent, 7:39-43.
`
`‘773 patent, Figure 2.
`
`The ‘817 patent discloses:
`
`“FIG. 3 schematically illustrates a communication protocol in accordance with
`the present invention. This protocol is explained in greater detail below.
`However, it may be briefly summarized as entailing use of the TCP and IP
`protocols for communications among the server 20 (FIG. 1) and the
`node/collector units 18 (only one of which is shown in FIG. 1.” ‘817 patent,
`6:1-8.
`
`
`The above contentions for claim 49 are hereby incorporated by reference.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`
`53. The system as defined in claim 49, wherein the
`WAN is a dedicated Intranet.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 8 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`
`To the extent that Plaintiffs contend that this claim limitation is not disclosed
`explicitly or inherently in the ‘650 patent, it would have been obvious to a
`person ordinary skill in the art to combine and/or modify the ‘650 patent with
`the teachings of one or more of the additional references teaching this
`limitation, for example:
`
`Jubin discloses:
`
`“The PRNET can also be accessed from other networks via an Internet
`gateway.” Jubin page 23.
`
`Burchfiel discloses:
`“When some other network is present, it is important to provide connections
`between the terminals and hosts of the PRN and the terminals and hosts of the
`other network. This is being done for the ARPANET in two ways:
`1. For communications with ARPANET hosts which support a protocol
`congruent with the PRN connection protocol (the Cerf-Kahn protocol
`mentioned previously qualifies here), the station functions as an
`extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header format is converted to that of the
`destination network. …
`2. The second approach will be conversion between the host-host
`protocols of the two networks….” Burchfiel page 249.
`
`
`Figure 4, Burchfiel page 249.
`
`Figure 5, Burchfiel page 250.
`
`“Finally, the PRN TELENT process performs the second type of gateway
`function described above: conversion between the PRN connection protocol
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 9 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`and the ARPANET host-host protocol. Terminals on the PRN appear identical
`to the terminals attached to the PDP-11, and are able to access remote
`ARPANET service hosts in the same way.” Burchfiel page 250.
`
`The ‘773 patent discloses:
`
`“Providing Gateway Services to the individual Minion devices means that all
`Minion devices effectively become part of the Internet as shown in FIG. 2.
`Status enquiries and data messages can originate at any Internet workstation in
`the world and can be directed to any Minion device." ‘773 patent, 7:39-43.
`
`‘773 patent, Figure 2.
`
`The ‘817 patent discloses:
`
`“FIG. 3 schematically illustrates a communication protocol in accordance with
`the present invention. This protocol is explained in greater detail below.
`However, it may be briefly summarized as entailing use of the TCP and IP
`protocols for communications among the server 20 (FIG. 1) and the
`node/collector units 18 (only one of which is shown in FIG. 1.” ‘817 patent,
`6:1-8.
`
`The above contentions for claim 49 are hereby incorporated by reference.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`
`
`54. The system as defined in claim 49, wherein the
`at least one gateway is connected to the WAN by a
`network selected from the group consisting of a
`telecommunications network, private radio-
`frequency network, and a computer network.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 10 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`
`55. A method of collecting information and
`providing data services comprising:
`
`adaptively configuring a data translator at the output
`of a local controller, wherein the data translator
`converts the output data stream into an information
`signal consisting of a transmitter code and an
`information field;
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`“A customizable data acquisition device (DA) and data collection system
`(DCS). The DA is remotely located for attachment to a variety of I/O devices,
`and uses an RF transceiver with a primary cache. A centrally located or mobile
`DCC with a secondary cache communicates with one or more DA’s and stores
`DA data in the secondary cache.” ‘650 patent Abstract
`
`“The foregoing examples concentrated on utility meter data collection as a
`method of illustrating general data acquisition and power conservation
`concerns. However, those skilled in the art will recognize that a variety of
`applications exist for the collection of data, including industrial, manufacturing,
`financial, security and agriculture, to name just a few. Industrial processes may
`require monitoring of materials as they are processed. Manufacturing plants
`can be designed to control activity and parts delivery on an long assembly line.
`Remote devices such as ATMs can be monitored for maintenance and security.
`Security systems are needed for monitoring homes and businesses.
`Agricultural uses include control systems for fertilization and irrigation. As
`can be seen, data acquisition systems an be used for numerous purposes.” ‘650
`patent, 3:1-15.
`“The present invention solves the foregoing problems by providing a data
`acquisition device and a data collection system. The data acquisition device
`includes a primary cache, a detachable RF transceiver, and a user supplied
`sensor device. The data collection system includes a secondary cache. The
`detachable RF transceiver has a programmable controller and an I/O interface
`capable of attaching to a variety of user supplied sensor devices….Each data
`acquisition device is capable of peer to peer communication such that data
`acquisition devices outside of the range of the data collection device can
`communicate with the data collection device through other data acquisition
`devices.” ‘650 patent, 3:27-47.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 11 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`
`“The system provides a remotely located data acquisition device which may be
`a sensor or unit of equipment which performs a specific active function, such as
`irrigation in agricultural environments or control of a manufacturing assembly
`line.” ‘650 patent, 4:25-29.
`
`“FIG. 2 provides a more detailed block diagram of the DA 102. The DA 102
`includes RF Transceiver 210, primary cache 202, program storage 208,
`microprocessor 212, microcontroller 214, and I/O interface connector 204.”
`‘650 patent, 7:1-4.
`
`‘650 patent, Figure 2.
`
`“I/O device 206 can be any suitable user designed unit required for a particular
`function. For example, it can be a weather station, irrigation equipment,
`manufacturing equipment, security system, etc. For ease of illustration, this
`figure illustrates the I/O device 206 as part of the DA 102. However, in practice
`the DA 102 can be attached directly to an I/O device 206 or it can be remotely
`attached via cable.” ‘650 patent, 7:9-13.
`
`“As shown above, in FIG. 3, the DA 102 is also designed to function as a node
`in a mesh of RF-communicating devices, relaying information received from
`I/O devices 206 (which may be sensors or active devices), across the network
`in a daisy-chain form. Since each node is individually addressable, messages
`can be routed from source to destination via any number of nodes, without
`limiting the coverage area.” ‘650 patent, 11:47-54.
`“The present invention solves the foregoing problems by providing a data
`acquisition device and a data collection system. The data acquisition device
`includes a primary cache, a detachable RF transceiver, and a user supplied
`sensor device. The data collection system includes a secondary cache. The
`detachable RF transceiver has a programmable controller and an I/O interface
`
`adaptively configuring at least one transmitter with
`the data translator, wherein the transmitter converts
`the information signal into a low-power RF signal;
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 12 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`capable of attaching to a variety of user supplied sensor devices….Each data
`acquisition device is capable of peer to peer communication such that data
`acquisition devices outside of the range of the data collection device can
`communicate with the data collection device through other data acquisition
`devices.” ‘650 patent, 3:27-47.
`
`“The system provides a remotely located data acquisition device which may be
`a sensor or unit of equipment which performs a specific active function, such as
`irrigation in agricultural environments or control of a manufacturing assembly
`line.” ‘650 patent, 4:25-29.
`
`“FIG. 2 provides a more detailed block diagram of the DA 102. The DA 102
`includes RF Transceiver 210, primary cache 202, program storage 208,
`microprocessor 212, microcontroller 214, and I/O interface connector 204.”
`‘650 patent, 7:1-4.
`
`‘650 patent, Figure 2.
`
`“I/O device 206 can be any suitable user designed unit required for a particular
`function. For example, it can be a weather station, irrigation equipment,
`manufacturing equipment, security system, etc. For ease of illustration, this
`figure illustrates the I/O device 206 as part of the DA 102. However, in practice
`the DA 102 can be attached directly to an I/O device 206 or it can be remotely
`attached via cable.” ‘650 patent, 7:9-13.
`
`“As shown above, in FIG. 3, the DA 102 is also designed to function as a node
`in a mesh of RF-communicating devices, relaying information received from
`I/O devices 206 (which may be sensors or active devices), across the network
`in a daisy-chain form. Since each node is individually addressable, messages
`can be routed from source to destination via any number of nodes, without
`limiting the coverage area.” ‘650 patent, 11:47-54.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 13 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`placing a plurality of relatively low-power radio-
`frequency (RF) transceivers dispersed
`geographically wherein the low power RF signal is
`received and repeated as required to communicate
`the information signal to a gateway, the gateway
`providing access to a WAN;
`
`
`“The present invention solves the foregoing problems by providing a data
`acquisition device and a data collection system. The data acquisition device
`includes a primary cache, a detachable RF transceiver, and a user supplied
`sensor device. The data collection system includes a secondary cache. The
`detachable RF transceiver has a programmable controller and an I/O interface
`capable of attaching to a variety of user supplied sensor devices….Each data
`acquisition device is capable of peer to peer communication such that data
`acquisition devices outside of the range of the data collection device can
`communicate with the data collection device through other data acquisition
`devices.” ‘650 patent, 3:27-47.
`
`“The system provides a remotely located data acquisition device which may be
`a sensor or unit of equipment which performs a specific active function, such as
`irrigation in agricultural environments or control of a manufacturing assembly
`line.” ‘650 patent, 4:25-29.
`
`“FIG. 2 provides a more detailed block diagram of the DA 102. The DA 102
`includes RF Transceiver 210, primary cache 202, program storage 208,
`microprocessor 212, microcontroller 214, and I/O interface connector 204.”
`‘650 patent, 7:1-4.
`
`‘650 patent, Figure 2.
`
`“I/O device 206 can be any suitable user designed unit required for a particular
`function. For example, it can be a weather station, irrigation equipment,
`manufacturing equipment, security system, etc. For ease of illustration, this
`figure illustrates the I/O device 206 as part of the DA 102. However, in practice
`the DA 102 can be attached directly to an I/O device 206 or it can be remotely
`attached via cable.” ‘650 patent, 7:9-13.
`
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 14 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`translating the low-power RF signal within the
`gateway to a WAN compatible data transfer
`protocol;
`
`transferring the translated low-power RF signal via
`the WAN to a computer wherein the computer is
`configured to manipulate and store data provided in
`said signal; and
`
`“As shown above, in FIG. 3, the DA 102 is also designed to function as a node
`in a mesh of RF-communicating devices, relaying information received from
`I/O devices 206 (which may be sensors or active devices), across the network
`in a daisy-chain form. Since each node is individually addressable, messages
`can be routed from source to destination via any number of nodes, without
`limiting the coverage area.” ‘650 patent, 11:47-54.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`“In the preferred embodiment, APPs 112 can access any appropriate DA 102.
`The purpose and timing of each access can vary from APP 112 to APP 112.
`However, some of the data used by each APP 112 may be the same. Therefore,
`by caching the data, the DA 102 does not have to regenerate it for each APP
`112. This figure also illustrates that APPs 112 can reside within the processor
`104 or at a remote location which accesses DAs 102 through the DCS. As
`shown, remote APPs 112 are connected to processor 104 by client connectors
`110 (hereinafter CC 110) via RF links 114 or conventional telephone links 116.
`Those skilled in the art will recognize that the CCs 110 can be any suitable
`hardware and software needed to convert received data and commands to a
`form suitable for the software in the processor 104. The techniques required to
`implement a CC 110 are well known in the art.” ‘650 patent, 6:11-26.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 15 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`granting client access to the computer.
`
`
`56. The method of claim 55 wherein the WAN is
`the Internet.
`
`“Ensuring the appropriate DA 102 communicates with the appropriate APP 112
`is accomplished via any suitable identification protocol for communication
`devices.” ‘650 patent, 6:60-63.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`The above contentions for claim 55 are hereby incorporated by reference.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`“In systems which cover wide geographical or nationwide areas, many data
`collection systems may be linked together in a hierarchical or distributed server
`network, thereby allowing applications located on other computers or networks
`to access the data from a particular data acquisition device. By caching the data
`at the data collection system, substantial improvements in the overall system
`performance can be achieved. When global networks, such as the Internet, are
`used to access data acquisition devices worldwide, the use of the dual cache
`system described above becomes even more advantageous.” ‘650 patent, 5:12-
`22.
`
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 16 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`To the extent that Plaintiffs contend that this claim limitation is not disclosed
`explicitly or inherently in the ‘650 patent, it would have been obvious to a
`person ordinary skill in the art to combine and/or modify the ‘650 patent with
`the teachings of one or more of the additional references teaching this
`limitation, for example:
`
`Jubin discloses:
`
`“The PRNET can also be accessed from other networks via an Internet
`gateway.” Jubin page 23.
`
`Burchfiel discloses:
`“When some other network is present, it is important to provide connections
`between the terminals and hosts of the PRN and the terminals and hosts of the
`other network. This is being done for the ARPANET in two ways:
`1. For communications with ARPANET hosts which support a protocol
`congruent with the PRN connection protocol (the Cerf-Kahn protocol
`mentioned previously qualifies here), the station functions as an
`extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header format is converted to that of the
`destination network. …
`2. The second approach will be conversion between the host-host
`protocols of the two networks….” Burchfiel page 249.
`
`
`Figure 4, Burchfiel page 249.
`
`Figure 5, Burchfiel page 250.
`
`“Finally, the PRN TELENT process performs the second type of gateway
`function described above: conversion between the PRN connection protocol
`and the ARPANET host-host protocol. Terminals on the PRN appear identical
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 17 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`to the terminals attached to the PDP-11, and are able to access remote
`ARPANET service hosts in the same way.” Burchfiel page 250.
`
`The ‘773 patent discloses:
`
`“Providing Gateway Services to the individual Minion devices means that all
`Minion devices effectively become part of the Internet as shown in FIG. 2.
`Status enquiries and data messages can originate at any Internet workstation in
`the world and can be directed to any Minion device." ‘773 patent, 7:39-43.
`
`‘773 patent, Figure 2.
`
`The ‘817 patent discloses:
`
`“FIG. 3 schematically illustrates a communication protocol in accordance with
`the present invention. This protocol is explained in greater detail below.
`However, it may be briefly summarized as entailing use of the TCP and IP
`protocols for communications among the server 20 (FIG. 1) and the
`node/collector units 18 (only one of which is shown in FIG. 1.” ‘817 patent,
`6:1-8.
`
`The above contentions for claim 55 are hereby incorporated by reference.
`
`“Likewise, the APPS 112 may reside on a single DCS 100, or be distributed
`over a hierarchical network of computers.” ‘650 patent, 8:42-44.
`
`“For example, the Internet allows weather data from DAs 102 located
`anywhere to be provided to a single APP 112.” ‘650 patent, 10:54-57.
`
`“In systems which cover wide geographical or nationwide areas, many data
`collection systems may be linked together in a hierarchical or distributed server
`
`
`57. The method of claim 55 wherein the WAN is an
`Intranet.
`
`

`

`
`
`Case 1:16-cv-02690-AT Document 121-18 Filed 08/05/16 Page 18 of 2892
`Exhibit P6 – Invalidity Chart for U.S. Patent No. 6,437,692 based on U.S. Patent No. 5,963,650
`
`network, thereby allowing applications located on other computers or networks
`to access the data from a particular data acquisition device. By caching the data
`at the data collection system, substantial improvements in the overall system
`performance can be achieved. When global networks, such as the Internet, are
`used to access data acquisition devices worldwide, the use of the dual cache
`system described above becomes even more advantageous.” ‘650 patent, 5:12-
`22.
`
`To the extent that Plaintiffs contend that this claim limitation is not disclosed
`explicitly or inherently in the ‘650 patent, it would have been obvious to a
`person ordinary skill in the art to combine and/or modify the ‘650 patent with
`the teachings of one or more of the additional references teaching this
`limitation, for example:
`
`Jubin discloses:
`
`“The PRNET can also be accessed from other networks via an Internet
`gateway.” Jubin page 23.
`
`Burchfiel discloses:
`“When some other network is present, it is important to provide connections
`between the terminals and hosts of the PRN and the terminals and hosts of the
`other network. This is being done for the ARPANET in two ways:
`1. For communications with ARPANET hosts which support a protocol
`congruent with the PRN connection protocol (the Cerf-Kahn protocol
`mentioned previously qualifies here), the station functions as an
`extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header forma