Motorola Mobility LLC (Petitioner) v.
`Intellectual Ventures II LLC (Patent Owner)
`
`Case IPR2014-00504 (U.S. Patent 7,382,771)
`Petitioner’s Demonstrative Exhibits (Exhibit 1015)
`
`Petitioners’ Exhibit 1015-1
`
`
`Intellectual Ventures II LLC (Patent Owner)
`
`Case IPR2014-00504 (U.S. Patent 7,382,771)
`Petitioner’s Demonstrative Exhibits (Exhibit 1015)
`
`Petitioners’ Exhibit 1015-1
`
`
`
`INSTITUTED GROUNDS
`
`• Anticipation by Boehm: Claims 1 and 2
`
`• Obvious over Mitchell and Boehm: Claims 1, 3, 4, 7,
`and 18
`
`• Obvious over Veeck, Boehm, and Mitchell: Claims 1–4
`and 18
`
`Exhibit 1015-2
`
`
`
`CLAIMS UNDER REVIEW
`
`’771 Patent
`Claims Under
`Review
`1
`2
`3
`4
`7
`18
`
`Disclosed
`by Boehm
`
`
`
`
`Disclosed by
`Mitchell and
`Boehm
`?
`
`*
`*
`*
`*
`
`Disclosed by
`Veeck, Boehm,
`and Mitchell
`?
`*
`*
`*
`
`*
`
` - Asserted by Petitioner, not disputed by Patent Owner
`* - Asserted by Petitioner, disputed by Patent Owner solely on
`the basis of their dependence on the independent claim
`? - Asserted by Petitioner, disputed by Patent Owner
`Exhibit 1015-3
`
`
`
`ISSUES
`
`Not Disputed
`• Boehm discloses all features of claim 1
`
`• Additional features recited in claims 2-4, 7, and 18
`are disclosed by the cited combinations
`
`Exhibit 1015-4
`
`
`
`ISSUES
`
`Disputed - Whether
`• Mitchell-Boehm combination teaches all features of
`claim 1
`
`• Veeck-Boehm-Mitchell combination teaches all
`features of claim 1
`
`• Boehm is prior art
`
`Exhibit 1015-5
`
`
`
`OVERVIEW – ’771 PATENT
`
`Claim 1
`
`Exhibit 1015-6
`
`
`
`OVERVIEW – ’771 PATENT
`
`• Patent Owner distinguished the prior art by amending claim 1 to
`recite a stand-alone system that enables Internet access without
`an external service controller server
`
`Ex. 1003, p. 80 (cited in Revised Petition at 8)
`
`Exhibit 1015-7
`
`
`
`OVERVIEW – ’771 PATENT
`
`• Patent Owner distinguished the prior art by amending claim 1 to
`recite a stand-alone system that enables Internet access without
`an external service controller server
`
`Ex. 1003, p. 87 (cited in Revised Petition at 8)
`
`Exhibit 1015-8
`
`
`
`EXPLANATION OF A STAND-ALONE SYSTEM ENABLING INTERNET
`ACCESS WITHOUT AN EXTERNAL SERVICE CONTROLLER SERVER
`
`Comparison Between Kokkinen and ’771 Patent
`
`• Kokkinen: two servers for providing Internet access
`(1) a “service controller server” with a DHCP module and a NAT
`module
`(2) a server onboard a train that receives an address from the
`service controller server
`
`See Ex. 1004, ¶ [0024] (cited in Revised Petition at 8-9)
`
`•
`
`’771 patent: hotspot with DHCP module and NAT module
`See Ex. 1001, 3:63-65 and 4:10-12 (cited in Revised Petition at 9)
`
`Exhibit 1015-9
`
`
`
`OVERVIEW OF CITED ART – BOEHM
`
`Ex. 1005, FIG. 3 (cited in Revised Petition at 14)
`
`Exhibit 1015-10
`
`
`
`BOEHM DISCLOSES A STAND-ALONE SYSTEM ENABLING INTERNET
`ACCESS WITHOUT AN EXTERNAL SERVICE CONTROLLER SERVER
`
`Comparison Between ’771 Patent and Boehm
`
`•
`
`’771 patent: hotspot with DHCP module and NAT module
`See Ex. 1001, 3:63-65 and 4:10-12 (cited in Revised Petition at 8-9)
`
`• Boehm: router that provides DHCP and NAT
`See Ex. 1005 ¶ [0022] (cited in Revised Petition at 16)
`
`Exhibit 1015-11
`
`
`
`OVERVIEW OF CITED ART – MITCHELL
`
`• System and Method for Internet Access on a Mobile
`Platform
`
`See Ex. 1006 (cited in Revised Petition at 17)
`
`• A communication system for use with a mobile platform
`(e.g., automobiles, aircraft, or other vehicles)
`See Ex. 1006, Abstract (cited in Revised Petition at 23-24)
`
`•
`
`In some embodiments, an aircraft receives Internet data
`via a satellite link and an aircraft network server
`distributes the received Internet data to client computers
`in the aircraft via a wireless network
`See Ex. 1006, 20:13-15, 23:51-54, 23:61-66 (cited in Revised Petition at 24-25)
`
`Exhibit 1015-12
`
`
`
`OVERVIEW OF CITED ART – MITCHELL
`
`Ex. 1006, FIG. 12 (cited in Revised Petition at 24)
`
`Exhibit 1015-13
`
`
`
`OVERVIEW OF CITED ART – VEECK
`
`• Wireless communication system for a transportation
`vehicle (e.g., aircraft, bus, cruise ship, train)
`See Ex. 1008 ¶ [0011] (cited in Revised Petition at 48)
`
`•
`
`Includes a data server with an Internet connection that
`wirelessly distributes Internet content to passenger
`devices (e.g., using 802.11 wireless protocol)
`See Ex. 1008 ¶¶ [0012], [0022]-[0025], [0027] (cited in Revised Petition at 54-57)
`
`Exhibit 1015-14
`
`
`
`OVERVIEW OF CITED ART – VEECK
`
`Ex. 1008, FIG. 2 (cited in Revised Petition at 54)
`
`Exhibit 1015-15
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1
`
`Claim 1
`
`Exhibit 1015-16
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1:
`INTERNET ACCESS
`
`Patent Owner’s Allegations
`•
`“Internet access” requires
`bidirectional
`communication
`
`Deficiency of Patent Owner’s Position
`• A device that receives Internet data has
`“Internet access”
`
`• Mitchell’s receiver does
`not provide bi-directional
`communication
`
`• Patent Owner concedes that Mitchell
`discloses a system that receives Internet
`data
`
`Exhibit 1015-17
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: INTERNET ACCESS
`Dr. Roy’s Declaration Testimony Regarding “Internet Access”
`
`Ex. 1012 ¶ 15 (cited in Reply at 11)
`
`Exhibit 1015-18
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: INTERNET ACCESS
`
`• Patent Owner concedes that Mitchell discloses a receiver
`system for receiving Internet service, including broadcast or
`push Internet
`
`. . .
`
`Response at 41-42
`
`Exhibit 1015-19
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1
`
`Claim 1
`
`Exhibit 1015-20
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1:
`ROUTING SYSTEM
`
`Deficiency of Patent Owner’s Position
`• Mitchell’s server is a “routing system”
`under the broadest reasonable
`construction of that term
`
`Patent Owner’s Allegations
`• A routing system must
`control client devices’
`Internet access (e.g., using
`authentication and NAT)
`
`• Mitchell’s network server is
`not a routing system
`because it does not
`perform authentication or
`NAT
`
`Exhibit 1015-21
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: ROUTING SYSTEM
`Dr. Roy’s Declaration Testimony Regarding “Routing System”
`
`. . .
`
`Ex. 1012 ¶ 18 (cited in Reply at 12)
`
`Exhibit 1015-22
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: ROUTING SYSTEM
`
`• Mitchell’s aircraft server is a “routing system” at least because it
`receives Internet data from a satellite link and distributes the
`Internet service to clients via a wireless network
`
`Ex. 1006,
`FIG. 12 (excerpt)
`
`•
`
`Internet data from receiver 364 is provided to aircraft network
`server 271, which distributes Internet service in aircraft 250 via
`wireless network 275 to client personal computer 272
`See Ex. 1006, 20:13-15 and 23:61-66 (cited in Revised Petition at 25)
`
`Exhibit 1015-23
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1
`
`Claim 1
`
`Exhibit 1015-24
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1:
`STAND-ALONE SYSTEM
`
`Patent Owner’s Allegations
`• Mitchell’s use of a back-
`channel for Internet
`communication precludes
`stand-alone operation
`
`Deficiency of Patent Owner’s Position
`• Mitchell’s “back-channel” is the same
`type of intermediary communication
`system contemplated by the ’771 patent
`
`Exhibit 1015-25
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION TEACHES
`ALL FEATURES OF CLAIM 1: STAND-ALONE SYSTEM
`
`• The ’771 patent clearly contemplates using long-range networks
`similar to Mitchell’s “back-channel” even with the “stand-alone”
`system recited in claim 1
`
`Ex. 1001, 2:13-15 (cited in Reply at 13)
`
`Exhibit 1015-26
`
`
`
`WHETHER THE MITCHELL-BOEHM COMBINATION TEACHES
`ALL FEATURES OF CLAIM 1: STAND-ALONE SYSTEM
`Dr. Roy’s Declaration Testimony Regarding “Stand-Alone”
`System and Mitchell’s Back-Channel
`
`Ex. 1012, ¶ 62 (cited in Reply at 13)
`
`Exhibit 1015-27
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1
`
`Claim 1
`
`Exhibit 1015-28
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL
`COMBINATION TEACHES ALL FEATURES OF CLAIM 1:
`ROUTING SYSTEM
`
`Patent Owner’s Allegations
`• Veeck’s data server is not
`a routing system because it
`does not perform
`authentication or NAT
`
`Deficiency of Patent Owner’s Position
`• Veeck’s server is a “routing system”
`under the broadest reasonable
`construction of that term
`
`Exhibit 1015-29
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: ROUTING SYSTEM
`
`• Veeck’s data server is a “routing system” at least because the
`server delivers content to clients on an individual basis
`
`Ex. 1008 ¶ [0027] (cited in Reply at 14)
`
`Exhibit 1015-30
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: ROUTING SYSTEM
`Dr. Roy’s Declaration Testimony Regarding “Routing System”
`and Veeck’s Data Server
`
`Ex. 1012 ¶ 66 (cited in Reply at 14)
`
`Exhibit 1015-31
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL
`COMBINATION TEACHES ALL FEATURES OF CLAIM 1
`
`Claim 1
`
`Exhibit 1015-32
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL
`COMBINATION TEACHES ALL FEATURES OF CLAIM 1:
`STAND-ALONE SYSTEM
`
`Patent Owner’s Allegations
`• Veeck’s data server is not
`a stand-alone system
`because it incorporates
`Galipeau to teach Internet
`access
`
`Deficiency of Patent Owner’s Position
`• The Petition cites Mitchell’s teachings in
`combination with Veeck to teach Internet
`access
`• Veeck does not incorporate Galipeau to
`teach Internet access
`
`Exhibit 1015-33
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: STAND-ALONE SYSTEM
`
`• Veeck’s Internet communication architecture is not limited by
`Galipeau, which is only cited once in the background as an
`example of distributing data within a vehicle, not an example of
`Internet communication
`
`Ex. 1008 ¶ [0003] (cited in Reply at 15)
`
`Exhibit 1015-34
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: STAND-ALONE SYSTEM
`
`• Veeck’s description of Internet communication architecture
`lacks any citation to Galipeau and is not limited by Galipeau’s
`teachings
`
`Ex. 1008 ¶ [0027] (cited in Reply at 15)
`
`Exhibit 1015-35
`
`
`
`WHETHER THE VEECK-BOEHM-MITCHELL COMBINATION
`TEACHES ALL FEATURES OF CLAIM 1: STAND-ALONE SYSTEM
`
`• Mitchell’s teaching of Internet access cited by Petition in Veeck-
`Boehm-Mitchell combination
`
`Ex. 1006, 19:48-55 (cited in Revised Petition at 56)
`
`Exhibit 1015-36
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`KEY DATES
`
`November 4
`Boehm filed
`
`2002
`
`September 24
`Alleged
`conception
`
`October 21
`Alleged
`reduction
`to practice
`
`December 15
`Alleged
`reduction to
`practice
`
`See Response, pp. 14, 25, 28; Ex. 1005
`
`Exhibit 1015-37
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`DILIGENCE
`
`Deficiency of Patent Owner’s Position
`• Gaps in activity in the evidence that
`Patent Owner claims corroborates
`diligence are comparable in length to
`the activity gaps in cases where the
`courts and the Board have found an
`absence of diligence
`
`Patent Owner’s Allegations
`• Conception on
`September 24, 2002
`(pre-Boehm)
`• Actual reduction to
`practice on December
`15, 2002 (post-Boehm)
`• Diligence beginning at
`least just prior to
`Boehm’s November 4,
`2002 filing date
`
`Exhibit 1015-38
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`DILIGENCE
`Even a short period of unexplained inactivity is sufficient to
`defeat a claim of diligence
`Microsoft Corp. v. Surfcast, Inc., 2014 WL 5337868, *11 (P.T. A.B. Oct 14, 2014)
`
`• Microsoft: “an entire week of inactivity” as well as
`“numerous gaps [ranging from 1-5 days in duration]” and
`“seventeen days [that] involved activity of 45 minutes or
`less”
`
`See Microsoft *11-*12
`
`• Lapse of two days
`
`• Lapse of thirteen days
`
`In re Mulder, 716 F.2d 1542, 1542–46 (Fed. Cir. 1983)
`
`Rieser v. Williams, 255 F.2d 419, 424 (CCPA 1958)
`
`Exhibit 1015-39
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`DILIGENCE
`Microsoft: “an entire week of inactivity . . .”
`
`See Ex. 2014 (cited in Response at 27-28)
`
`Exhibit 1015-40
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`DILIGENCE
`Microsoft: “. . . numerous gaps [ranging from 1-5 days in duration]”
`
`See Exs. 2016, 2018, 2028, 2027, 2028 (cited in Response at 38)
`
`Exhibit 1015-41
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`DILIGENCE
`Microsoft: “. . . numerous gaps [ranging from 1-5 days in duration]”
`
`See Exs. 2014, 2020, 2022, 2028, 2032, 2034 (cited in Response at 38-39)
`
`Exhibit 1015-42
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`Patent Owner’s Allegations
`• Exhibits 2012 and 2014
`show that the patentees
`reduced the alleged
`invention to practice in
`October 2002, prior to
`Boehm’s filing date
`
`Deficiency of Patent Owner’s Position
`• Exhibit 2012 lacks any depiction of the
`claimed features
`• Exhibit 2014 lacks any description of
`features alleged to show enablement of
`Internet access without an external
`service controller server
`
`Exhibit 1015-43
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`The Patent Owner must corroborate that all features were
`reduced to practice
`
`• To establish reduction to practice, Patent Owner must
`prove that the patentees constructed every element of the
`claimed invention, and that the constructed system
`worked for its intended purpose
`See Mazzari v. Rogan, 323 F.3d 1000, 1006 (Fed. Cir. 2003)
`
`Exhibit 1015-44
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`• Exhibit 2012 does not corroborate reduction to practice
`because it does not depict all features of the claimed
`mobile hotspot (e.g., enabling Internet access without an
`external service controller server)
`
`Ex. 2012, p. 1 (cited in Response at 25)
`
`Exhibit 1015-45
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`• Exhibit 2012 does not corroborate reduction to practice
`because it does not depict all features of the claimed mobile
`hotspot (e.g., enabling Internet access without an external
`service controller server)
`
`Ex. 2012, p. 2
`(cited in Response at 26)
`
`Patent Owner also concedes that “[t]he 1xRTT [long-range
`wireless Internet access] interface card itself is not visible”
`Response at 26
`
`Exhibit 1015-46
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`• Exhibit 2012 does not corroborate reduction to practice
`because it does not depict all features of the claimed
`mobile hotspot (e.g., enabling Internet access without an
`external service controller server)
`
`Ex. 2012, p. 3
`(cited in Response at 26)
`
`Exhibit 1015-47
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`• Patent Owner alleged that “Ticket #1015” in Exhibit 2014
`corroborates reduction to practice
`
`Response at 25
`
`Exhibit 1015-48
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`•
`
`“Ticket #1015” in Exhibit 2014 does not identify or
`describe any of the claimed features allegedly reduced to
`practice and indicates that the mobile hotspot did not work
`for its intended purpose
`
`Ex. 2014, p. 2 (cited in Response at 25)
`
`Exhibit 1015-49
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`• Patent Owner alleged that “Ticket #1016” in Exhibit 2014
`corroborates reduction to practice
`
`Response at 27
`
`Exhibit 1015-50
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`•
`
`“Ticket #1016” in Exhibit 2014 does not identify or
`describe any of the claimed features allegedly reduced to
`practice
`
`Ex. 2014, p. 2 (cited in Response at 27)
`
`Exhibit 1015-51
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`• Patent Owner alleged that “Ticket #1019” in Exhibit 2014
`corroborates reduction to practice
`
`Response at 27-28
`
`Exhibit 1015-52
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`REDUCTION TO PRACTICE
`
`•
`
`“Ticket #1019” in Exhibit 2014 does not identify or
`describe any of the claimed features allegedly reduced to
`practice
`
`Ex. 2014, p. 2 (cited in Response at 27-28)
`
`Exhibit 1015-53
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`Patent Owner’s Allegations
`• Exhibit 2009 shows that
`hotspot provided DHCP
`functionality for clients
`
`Deficiency of Patent Owner’s Position
`• Exhibit 2009 does not clearly show that
`the hotspot acted as a DHCP server that
`enabled Internet access without an
`external service controller server
`
`• Exhibit 2009 shows that
`the hotspot used the
`network address
`translation functionality in
`Windows 98
`
`• Exhibit 2009 does not show
`contemporaneous appreciation of any
`specific feature (including network
`address translation) that may have been
`provided in Windows 98
`
`Exhibit 1015-54
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`The Patent Owner must corroborate conception of all claimed features
`
`• Patent Owner must provide corroborating evidence showing a
`disclosure in such clear terms as to enable those skilled in the art to
`make the invention
`
`See Coleman v. Dines, 754 F.2d 353, 359 (Fed. Cir. 1985)
`
`•
`
`“Conception requires contemporaneous recognition and
`appreciation of the limitations of the claimed invention . . .”
`Mycogen Plant Science, Inc. v. Monsanto Co., 252 F.3d 1306, 1314 (Fed. Cir. 2001)
`
`• An inventor who failed to appreciate the claimed inventive features
`at the time of alleged conception cannot use his later recognition of
`those features to retroactively cure his inadequate conception
`See Hitzeman v. Rutter, 243 F.3d 1345, 1358–59 (Fed. Cir. 2001)
`
`Exhibit 1015-55
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`Corroboration of enabling Internet access “without the need to
`access an external service controller server”
`
`• Support for a negative limitation requires the patentee to have
`shown a reason to exclude the relevant limitation
`See Santarus, Inc. v. Par Pharmaceutical, Inc., 694 F.3d 1344 (Fed. Cir. 2012)
`
`• A Patent Owner may not claim an earlier priority date for a
`negative limitation if the priority document did not disclose a
`reason for excluding the relevant limitation
`See SAP America, Inc. v. Pi-Net Intern’l, Inc.,
`IPR2014-00414, 2014 WL 4101767, *7 (P.T.A.B. Aug 18, 2014)
`
`Exhibit 1015-56
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`• Patent Owner cites the references to DHCP functionality in
`Exhibit 2009 as corroborating conception of a stand-alone
`system that enables Internet access without an external service
`controller server, as required by claim 1
`
`Response at 17
`
`Exhibit 1015-57
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Patent Owner alleges that the DHCP implemented at the hotspot
`was used to provide IP addresses to user devices
`
`Response at 26
`
`Exhibit 1015-58
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Because Patent Owner cites the hotspot’s DHCP functionality as
`enabling Internet access without an external service controller
`server, the Patent Owner must corroborate that the hotspot
`locally implemented DHCP server functionality
`
`Ex. 1012 ¶ 28 (cited in Reply at 3-4)
`
`Exhibit 1015-59
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Exhibit 2009 describes DHCP client functionality rather than
`DHCP server functionality that would enable Internet access
`without an external service controller server
`
`Ex. 2009 § 2.3.4 (cited in Reply at 3-4)
`
`Exhibit 1015-60
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Dr. Roy explained that Exhibit 2009 fails to describe the DHCP
`functionality in a manner that would corroborate conception of
`enabling Internet access without an external service controller
`server
`
`Ex. 1012 ¶ 31 (cited in Reply at 4)
`
`Exhibit 1015-61
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Patent Owner’s post-Boehm
`evidence describes using an
`external DHCP server
`
`Ex. 2018 at 1
`
`Ex. 2018 at 8 (cited in Reply at 4)
`
`Exhibit 1015-62
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`Dr. Roy’s Declaration Testimony Regarding “External DHCP
`Server” and Enabling Internet Access Without an External Service
`Controller Server
`
`Ex. 1012 ¶ 43 (cited in Reply at 4)
`
`Exhibit 1015-63
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• Patent Owner cites the reference to Windows 98 in Exhibit 2009
`as showing NAT functionality that would corroborate conception
`of enabling Internet access without an external service controller
`server, as required by claim 1
`
`Response at 17
`
`Exhibit 1015-64
`
`
`
`WHETHER BOEHM IS AVAILABLE AS PRIOR ART:
`CONCEPTION
`
`• The single reference to “Windows 98” in Exhibit 2009 does not
`show that the patentees used NAT or any other functionality in
`Windows 98 (even if available) to enable Internet access without
`an external service controller server
`
`Ex. 2009 § 2.4.1.1.1 (cited in Reply at 5-6)
`
`Ex. 1012 ¶¶ 35-36 (cited in Petitioner’s Reply to Patent
`Owner’s Opposition to Motion to Exclude at 4)
`
`Exhibit 1015-65
`
`
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