IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of:
`U.S. Patent No.:
`Issue Date:
`Appl. Serial No.:
`Filing Date:
`Title:
`
`
`Gregory J. Pinter
`Attorney Docket No.: 39521-0003IP1
`5,894,506
`
`April 13, 1999
`
`08/708,696
`
`
`September 5, 1996
`METHOD AND APPARATUS FOR GENERATING AND COMMUNICATING
`MESSAGES BETWEEN SUBSCRIBERS TO AN ELECTRONIC MESSAGING
`NETWORK
`
`
`DECLARATION OF DR. RAJEEV SURATI
`
`My name is Dr. Rajeev Surati of Cambridge, Massachusetts. I understand that I am submitting a
`declaration offering technical opinions in connection with the above-referenced Inter Partes review
`proceeding pending in the United States Patent and Trademark Office for U.S. Patent No.
`5,894,506 (“the ‘506 Patent”), and prior art references relating to its subject matter. My current
`curriculum vita is attached and some highlights follow.
`
`I have over twenty (20) years of experience in electrical engineering and computer science and in
`network messaging. I attended the Massachusetts Institute of Technology (MIT) from 1988 to
`1999, during which, I earned a Bachelor of Science (1992) , Master of Science (1995) and a Doctor
`of Philosophy (1999) in electrical engineering and computer science.
`
`While at MIT, starting in 1988, I extensively worked with a two-way network messaging system
`known as the Zephyr messaging system, which was part of MIT’s project Athena, MIT’s LAN based
`distributed computing infrastructure.
`
`I am the inventor of US Patent 5,943,478, which is titled, ”System for Popup Messaging over the
`Internet,” and describes a two-way messaging system like AOL Instant Messenger and MIT's
`Zephyr service built at Internet scale.
`
`In 1996, I founded a company, Flash Communications, which was focused on technology related to
`US Patent 5,943,478 and associated technology that I had developed related to pop-up two-way
`messaging over the Internet. Flash Communications was sold to Microsoft Corporation in 1998,
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`APPLE 1003
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`and Flash Communications’ messaging technology was incorporated into Microsoft’s Messenger
`service and Microsoft Exchange 2000 Instant Messaging Server.
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`While working at Microsoft between 1999 and 2000, I implemented an XML-based protocol that
`formed a basis for the Extensible Messaging and Presence Protocol (XMPP), which is now an
`IETF standard for the Exchange Instant Messaging Server. I participated internally with the
`program management team on helping specify this protocol for the IETF standardization process.
`
`During my work at Microsoft, I co-invented the technology described in US Patent 6,415,318, titled
`“Inter-enterprise Messaging System Using Bridgehead Servers,” which describes a particular type
`of instant two-way messaging system now being used in the Microsoft Exchange product, and US
`Patent 6,260,148, titled “Methods and Systems for Message Forwarding and Property Notifications
`Using Electronic Subscriptions,” which describes a particular scheme for implementing two-way
`network based instant messaging.
`
`Between 2000 and 2004, I worked as a consultant and investor at Nexaweb Corporation, where I
`helped implement several two-way messaging features over HTTP.
`
`I founded Scalable Display Technologies in 2004, and I have been the President and Chairman of
`the company since the founding. The products and services of the company are based on
`technologies developed for my Ph.D. thesis and related patents.
`
`Over the course of my career, I have authored and co-authored some ten (10) publications and
`invited talks on various aspects of electrical engineering and computer science, including my
`Bachelor of Science thesis entitled “A Parallelizing Compiler based on Partial Evaluation,” which
`was awarded the Best Undergraduate Thesis in Computer Science in 1992 at MIT.
`
`For my contributions as an inventor and entrepreneur, I have received several awards, including
`the Global Indus Technovator Award 2009 and Laureate of 2009 Computer World Honors
`Program.
`
`I am on the advisory boards of several technology companies, including UnifySquare, which is a
`unified communications/realtime collaboration consultancy; Paneve, which develops general
`purpose ASIC coupled with compiler technology; Nexaweb, which develops realtime web
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`application frameworks using HTTPS; Antix Labs, which develops compiler technology for
`universal gaming platform; Permabit, which develops content addressable storage; and Evoque,
`which is an ecommerce enabling platform publisher.
`
`I have no financial interest in either party or in the outcome of this proceeding. I am being
`compensated for my work as an expert on an hourly basis. My compensation is not dependent
`on the outcome of these proceedings or the content of my opinions.
`
`I have reviewed the content of U.S. Patent No. 5,894,506 (the “‘506 Patent”). Additionally, I have
`reviewed the following documents, each cited by/in this declaration, including: U.S. Patent No.
`5,850,594 to Cannon et al. (“Cannon”); U.S. Patent No. 5,970,122 to LaPorta et al. (“LaPorta”);
`U.S. Patent No. 5,588,009 to Craig A. Will (“Will”); and U.S. Patent No. 5,784,001 to Deluca et al.
`(“Deluca”). I have also reviewed certain sections of the prosecution history of the ‘506 Patent; the
`claim construction order from Mobile Telecommunications Technologies, LLC v. Apple Inc., Docket
`No. 2:13-cv-258 (E.D. Tex.) (“MTel Litigation”); and Plaintiff’s Opening Brief on Issues of Claim
`Construction from the MTel Litigation (“Patent Owner’s Opening Brief”).
`
`Counsel has informed me that I should consider these materials through the lens of one of ordinary
`skill in the art related to the ‘506 Patent at the time of the invention, and I have done so during my
`review of these materials. I believe one of ordinary skill as of September 5, 1996 (the priority
`date of the ‘506 Patent) would have a Bachelor’s degree in computer science or computer
`engineering, as well as practical experience in computer networking and in some aspect of
`two-way messaging with respect to computer networks. I base this on my own personal
`experience, including my knowledge of colleagues and others at the time. With this in mind, for
`purposes of this analysis, references that I make to the views of a person of ordinary skill are
`intended to relate the views of that person as of September 5, 1996 or earlier, whether stated with
`respect to the present or past tense.
`
`I have been informed that claim terminology must be given the broadest reasonable interpretation
`during an IPR proceeding. I have been informed that this means the claims should be interpreted
`as broadly as their terms reasonably allow, but that such interpretation should not be inconsistent
`with the patent's specification and with usage of the terms by one of ordinary skill in the art.
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`Counsel has also informed me that this may yield interpretations that are broader than the
`interpretation applied during a District Court proceeding, such as the pending MTel litigation.
`
`17.
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`My findings, as explained below, are based on my study, experience, and background in the fields
`discussed above, informed by my education in electrical engineering and computer science, and
`my experience in the design and analysis of messaging systems.
`
`18.
`
`This declaration is organized as follows:
`I.
`Brief Overview of the ‘506 Patent (page 4)
`II.
`Discussion of Cannon (page 11)
`III.
`Discussion of Will and Combination with Cannon (page 17)
`IV.
`Discussion of LaPorta and Combinations with Cannon and Will (page 26)
`V.
`Discussion of Deluca and Combinations with LaPorta (page 37)
`VI.
`Conclusion (page 43)
`
`I. BRIEF OVERVIEW OF THE ‘506 PATENT
`
`The '506 Patent is directed to a "method and apparatus for generating and communicating
`messages between subscribers to an electronic messaging network." APL-1001, Title. The
`'506 Patent includes 21 claims, of which claims 1, 8, 15, 19 and 21 are independent.
`
`As a preferred implementation of an electronic messaging network, the ‘506 Patent describes a
`calling party terminal 10 that is connected, via communications link 16, to a network operation
`center (NOC) 12. In turn, the NOC is connected, via communications link 18, to a receiving party
`terminal. Id. at 3:24-35; see also Fig. 1 (reproduced below).
`
`FIG. 1
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`The calling terminal stores a file of canned messages and associated canned message codes.
`When a calling party at terminal 10 wishes to send a message to a receiving party at terminal 14,
`the calling terminal 10 retrieves the file of canned messages from the terminal storage and displays
`the file to the calling party. The calling party selects one of the canned messages from the
`displayed file of canned messages using a suitable pointing means, such as a mouse or a cursor.
`Based on the calling party’s selection, the terminal 10 retrieves from the file the canned message
`code associated with the selected canned message. Id. at 3:44-58.
`
`The '506 Patent describes that in some implementations, the calling party may add response
`options to the selected canned messages. In such implementations, the calling terminal 10
`maintains a file of canned response options and associated response codes. When a calling
`party at terminal 10 wishes to add response options to a selected canned message, the calling
`terminal 10 retrieves the file of canned response options from the terminal storage and displays the
`file to the calling party. The calling party selects one of the canned response options from the
`displayed file of canned response options using a suitable pointing means, such as a mouse or a
`cursor. Based on the calling party’s selection, the terminal 10 retrieves the canned response
`code associated with the selected canned response option. Id. at 4:33-48.
`
`In some implementations, the calling party may add a parameter, e.g., time, date, or phone
`number, to the selected canned message, using an appropriate entry device, e.g. a keypad. Id. at
`5:59-63. The parameter may be added as an alternative, or in addition, to the response options.
`Id. at 4:48-56.
`
`The calling terminal 10 compiles the retrieved message code associated with the selected canned
`message with an appropriate indicator code, calling and receiving terminal addresses. Id. at 3:66.
`If a response option is selected, the associated response code is compiled with the canned
`message code. Additionally or alternatively, if a parameter is selected, the parameter is compiled
`with the canned message code (along with possibly the canned response code). Id. at 3:59-66,
`4:48-53. The calling party then transmits the compiled canned message code, together with the
`compiled canned response code or added parameters, or both, if any, with calling and receiving
`terminal addresses to NOC 12 over communications link 16. Id. at 3:66-4:32, 4:53-5:44.
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`26.
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`Upon receiving the compiled canned message code (along with the response code and/or added
`parameters, if any) with calling and receiving terminal addresses from the calling terminal 10, the
`NOC 12 determines whether the receiving terminal 14 can accept the canned message/response
`options in code form, or whether these must be transmitted in full text to the receiving terminal 14.
`If the receiving terminal 14 can accept the canned message/response option code(s), they are
`transmitted to the receiving terminal 14 in code form. Id. at 5:45-6:15.
`
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`If the designated receiving party terminal is not equipped to process canned message/response
`option codes, NOC 12 uses the canned message/response option codes received from the calling
`terminal 10 to retrieve from the appropriate file(s) the text of the associated canned message and
`multiple response options, if any. The text of the canned message and response options, together
`with parameters, is then transmitted in standard message code format by NOC 12 to the receiving
`terminal 14. Id. at 6:15-24. See also Fig. 3 (reproduced and annotated herein).
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`27.
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`The '506 Patent describes that the NOC 12 stores in memory a file of canned messages and
`associated canned message codes or a file of canned response options and associated response
`codes, or both, that correspond to the file of canned response options and associated response
`codes stored at the calling terminal 10. Id. at 1:54-59, 2:23-27. In some implementations, the
`receiving terminal 14 also stores corresponding files of canned messages and message codes,
`and canned multiple response options and response codes. Id. at 2:28-35, 6:35-38.
`
`
`
`Describing the operation of the receiving terminal 14, the '506 Patent discloses that upon receiving
`the canned message/response option transmission from NOC 12, the receiving terminal 14
`determines whether the canned message/response option reception is in message text or code. If
`in text, the canned message, along with any response options and/or parameters, are displayed to
`the receiving party. However, if the reception is in canned message/response option codes, the
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`receiving terminal 14 retrieves the associated canned messages along with the canned response
`options and/or parameters, if any, from the files stored at the receiving terminal 14. The retrieved
`canned message is displayed, along with the response options and/or parameters, if any, in text
`form for viewing by the receiving party terminal. Id. at 6:25-41. See also Fig. 4 (reproduced and
`annotated herein).
`
`If any response options are displayed to the receiving party, the receiving party may select an
`appropriate response option, which is then transmitted by the receiving terminal 14 back to NOC
`12. Id. at 6:42-45. When the NOC 12 receives the selected response option transmitted by the
`receiving party terminal 14, it determines whether the received response option is in ASCII text
`code format or in canned response option code. If in text code, the NOC relays the selected
`response option to the calling party terminal 10. However, if the selected response option is in
`canned response option code, the NOC 12 determines whether to transmit the selected response
`option to the calling party terminal in canned response code or in ASCII text code. If the former, the
`canned response code is transmitted to the calling party terminal 10 as received from the receiving
`terminal. If in ASCII text code, NOC 12 accesses its stored canned multiple response option file
`and, using the received response option code, retrieves the selected canned response option text,
`which the NOC then transmits in ASCII text code to the calling party terminal 10. Id. at 6:57-7:12.
`
`Upon receiving the selected response option relayed by NOC 12, the calling terminal 10
`determines whether the response option is in text code format or canned response code. If in text
`code, the calling terminal 10 decodes the response option and displays to the calling party. If the
`selected response option is in code form, the calling terminal 10 accesses the stored response
`options file and, using the received response option code, retrieves the associated response option
`text, which is then displayed to the calling party. Id. at 7:13-22.
`
`In describing a canned message and message code, the '506 Patent discloses that “many paging
`messages consists of a relatively small number of common phrases, such as ‘I am on the way
`home’, ‘I am working late’, ‘Can we meet for lunch’, etc. This being the case, such commonly used
`phrases can be treated as ‘canned’ messages that can be replaced by short message codes as
`simple as, for example, one or several ASCII characters.” Id. at 1:43-49 (emphasis added). The
`'506 Patent also states that “[t]he calling party browses through the file to determine if the text of
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`any of the canned messages is appropriate to convey the particular message that the calling party
`wishes to send to the receiving party,” id. at 1:38-49 (emphasis added); “NOC . . . determines . . .
`whether the canned message must be transmitted in full text to the receiving party terminal,” id. at
`6:7-12 (emphasis added); “determining whether the second terminal can receive the canned
`message in a text form or message code form; and communicating the selected canned message
`to the second terminal in either message code form or text code form in response to the
`determination,” id. at 8:60-65 (emphasis added).
`
`With reference to a canned response, the '506 Patent discloses that “multiple response options
`may also be canned responses maintained in files at the network operation center and the
`subscriber terminals and, like the canned messages, have assigned response codes that are
`handled in the same manner as the message codes.” Id. at 2:23-27.
`
`Based on the above teachings of the '506 Patent and in view of my education and experience, it is
`my understanding that, to a person of ordinary skill in the art at the time of filing the '506 Patent, a
`broadest reasonable interpretation of a “canned message” and “canned multiple response options”
`would be broad enough to cover a “predefined sequence of characters” and “predefined responses
`to a canned message,” respectively. In addition, a broadest reasonable interpretation of a
`“message code” or “response code” would be broad enough to cover any relatively short code,
`e.g., one or several ASCII characters, id. at 1:48-49, with the understanding that a “message code”
`corresponds to a “canned message” and a response code corresponds to a “canned response.”
`
`In describing the NOC and the calling terminal, the ‘506 Patent illustrates a preferred structure of
`the calling terminal in Fig. 7 (reproduced below). With reference to Fig. 7, the '506 Patent
`describes the calling terminal as including, among other components, a central processing unit
`CPU 110, a read-only memory ROM 112 that stores an application program for controlling terminal
`operation and a random access memory RAM 114 that stores the canned message/response
`options/parameter files and associated codes. Id. at 7:46-50.
`
`The '506 Patent states that the calling terminal also includes a message compiler 116 that is used
`for “assembling the message/response options/parameter codes, indicator and separator codes,
`and address codes into a message under the control of the application program and CPU 110." Id.
`at 7:50-54. In addition, the calling terminal 10 includes a terminal keypad 126 that is used to
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`37.
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`38.
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`retrieve canned message/response options/parameter files from RAM 114, to scroll through the
`displayed files, and to select the canned message/response options/parameter(s) appropriate for
`sending to the receiving party, among other uses. Id. at 7:60-66.
`
`
`
`Based on the above teaching of the '506 Patent and in view of my education and experience, it is
`my understanding that, to a person of ordinary skill in the art at the time of filing the '506 Patent, a
`broadest reasonable interpretation of a "calling terminal" or a receiving terminal” would be broad
`enough to cover a messaging device, including, for example, a two-way paging receiver (“pager”).
`See also id. at 1:22-35 and 3:32-38.
`
`Based on the above teaching of the '506 Patent and in view of my education and experience, it is
`my understanding that, to a person of ordinary skill in the art at the time of filing the '506 Patent, a
`broadest reasonable interpretation of a “message compiler” would be broad enough to cover a
`processor that executes a software program for processing messages and associated message
`codes, or a software program executed by a processor for processing messages and associated
`message codes. See, e.g., ¶34.
`
`In addition, based on the above teaching of the '506 Patent and in view of my education and
`experience, it is my understanding that, under a broadest reasonable interpretation, a person of
`ordinary skill in the art at the time of filing the '506 Patent would use the calling terminal, or
`components of the calling terminal (e.g., CPU 110, ROM 112, RAM 114, or any suitable
`combination of these) for retrieving from memory the file of canned messages, the file of multiple
`response options, the file of added parameters, or any suitable combination of these, along with
`the associated message codes, response codes, parameter codes, or any suitable combination of
`these. See, e.g., ¶¶21-22, 34.
`
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`39.
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`40.
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`Furthermore, based on the above teaching of the '506 Patent and in view of my education and
`experience, it is my understanding that, under a broadest reasonable interpretation, a person of
`ordinary skill in the art at the time of filing the '506 Patent would use the calling terminal, or
`components of the calling terminal (e.g., terminal keypad 126, a mouse, a cursor, or any suitable
`combination of these), for selecting a canned message, a response option, a parameter, or any
`suitable combination of these, for sending to the receiving party. See, e.g., ¶¶22, 34.
`
`The ‘506 Patent also illustrates a preferred structure of the NOC in Fig. 8 (reproduced below).
`With reference to Fig. 8, the '506 Patent describes the NOC as including a “CPU 131 [that is]
`connected by a system bus 132 to an input/output (I/O) device 134, to which a transmitter 136 and
`a receiver 138 are connected.” APL-1001, 8:8-10. The NOC also includes memory, such as
`ROM 139 for storing application programs, and RAM 140 for storing canned messages, response
`options, and parameters files, among others. Id. at 8:10-24. In addition, the NOC includes a
`message compiler for message formatting and for adding appropriate codes. Id. at 8:25-28.
`
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`41.
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`Based on the above teaching of the '506 Patent and in view of my education and experience, it is
`my understanding that, to a person of ordinary skill in the art at the time of filing the '506 Patent, a
`broadest reasonable interpretation of a “network operation center ” would be broad enough to
`cover a network device. See, e.g., id. at 3:25-40, ¶¶19-20, 39 and Fig. 1.
`
`II. DISCUSSION OF CANNON
`
`In general, Cannon describes a method and apparatus for efficiently transmitting addresses and
`messages from portable messaging units (PMUs) over a wireless communication channel.
`APL-1004, title. The communications system disclosed by Cannon provides two-way messaging
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`in which a subscriber of the communications system, e.g., a user of a portable messaging unit is
`able to transmit messages to a user of another portable unit or a fixed device. It may be desirable
`to keep such messages short because the messages are generally delivered and/or received over
`a wireless communication channel, which usually has a limited bandwidth that permits only a
`limited amount of information to be transmitted over the channel within a specified time interval.
`However, subscribers to the communication system often wish to send and receive relatively long
`messages. APL-1004, 1:14-27.
`
`43.
`
`The communications system 100 described by Cannon and illustrated in Fig. 1 (reproduced below)
`includes a system controller 110 and multiple PMUs 105. Id. at 1:41-43. The communications
`system 100 communicates messages between an originator PMU 105 and a destination PMU 105
`through the system controller 110 for providing two-way communication. Id. at 2:8-13.
`
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`44.
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`Cannon discloses that the PMUs use relatively short codes, which are referred to as “aliases,” to
`communicate frequently transmitted information, where the frequently used messages are
`represented by message aliases. Id. at 2:19-24. Each message alias can be associated with a
`more lengthy message. Id. at 2:31-32.
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`45.
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`46.
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`Annotation 1
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`Cannon discloses that databases of frequently transmitted messages and the associated message
`aliases are stored at the system controller 110 and the PMUs 105 “so that each device can
`recognize an alias and conveniently interpret the more lengthy message or friend address
`associated therewith.” Id. at 2:28-32. See also 2:46-51, which describes that a PMU 105 includes a
`database 210, as shown in Annotation 1 of Fig. 2 (reproduced above), for storing the “frequent
`message (canned message) list,” i.e., the files of canned messages and the associated message
`codes, which are referred to in Cannon as “message aliases.” Cannon discloses that both a
`message originator PMU 105 and a destination PMU 105 store such files or lists of canned
`messages and the associated message aliases. Id. at 5:1-6.
`
`With reference to the system controller 110, Cannon discloses that the system controller includes,
`as illustrated in Annotation 1 of Fig. 12 (reproduced below), a subscriber database 530 for storing
`lists of canned messages and associated message aliases corresponding to each subscriber of the
`communications system 100. The controller 110 also includes a controller memory 525 that stores
`information used in programming the controller and various codes, such as programming code,
`forward code, message code and “AF, AM, DF, and DM codes.” Id. at 7:35-45.
`
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`47.
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`48.
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`Annotation 1
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`One of ordinary skill in the art would have understood that the “message aliases” described in
`Cannon correspond to the message codes described in the ‘506 Patent, whereas the “message
`codes” described in Cannon are used to indicate a function to be performed to send or receive
`messages. Id. at. 3:60-61 and 4:63-64. One of ordinary skill in the art would have understood
`that the database 210 in a PMU 105 or the database 530 in a system controller 110 includes
`memory that stores the lists of canned messages and the associated message aliases.
`
`According to Cannon, the system controller 110 can update the databases of the frequently
`transmitted messages and the associated message aliases that are stored both at the system
`controller 110 and the PMUs 105 when necessary so that the information stored in a PMU
`database is equivalent to that stored in the controller database. Id. at 2:34-38. Cannon discloses
`that a “data entry device 510 can be used to update the subscriber database 530.” Id. at 7:39-40.
`Cannon further discloses that system controller includes “a reconciler for determining that the
`message alias is not included in the list associated with the portable messaging unit.” Id. at
`11:8-10. One of ordinary skill in the art would have understood that the files or lists of canned
`messages and message aliases that are maintained at the sender and receiver PMUs and at the
`system controller in one implementation can be identical to each other, and that the system
`controller can perform actions to maintain these lists consistent across all the devices.
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`49.
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`50.
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`Annotation 2
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`
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`Describing a PMU 105 in general, Cannon provides an electrical block diagram of a PMU 105 in
`Fig. 2,and discloses that the PMU 105 includes a processor 210 “for controlling the operations of
`the PMU 105,” a display 225 that presents information to a user of the PMU “in response to
`activation by the processor 210” and a transceiver 205 “for sending and receiving information over
`a radio frequency communication channel.” Id. at 2:39-46. See also Annotation 2 of Fig. 2
`(reproduced herein). The PMU 105 further includes message memory 225 that is coupled to the
`processor 210 for “storing received messages and message numbers associated with the received
`messages” and, as described above, the database 230.
`
`One of ordinary skill in the art would have understood that either or both of the sender and receiver
`PMU 105 described in Cannon can be a portable two-way messaging device, such as a two-way
`pager. One of ordinary skill in the art would have also understood that the processor 210 can
`coordinate with one or more of the message memory 225, the database 230 and the device
`memory 235 to retrieve canned messages and associated message aliases from the frequent
`message list stored in the memory of the PMU 105, and display the retrieved canned messages to
`the user of the PMU 105 using the display 210.
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`51.
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`52.
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`53.
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`54.
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`55.
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`One of ordinary skill in the art would further understand that the system controller 110 disclosed in
`Cannon can be a network device that is connected to both the originator and destination PMUs via
`network connections, where the system controller receives canned messages and message codes
`from an originator messaging device, and forwards the canned messages and message codes to a
`destination messaging device.
`
`Cannon discloses that a PMU 105 includes a sender 240 module that prepares information for
`transmission from the PMU 105 when the PMU is sending messages and associated information.
`The sender 240 may include firmware “stored in the device memory 235 and executed by the
`processor 210,” or the sender 240 may be implemented “using hardware capable of performing
`equivalent operations.” Id. at 4:1-8. See also Annotation 2 of Fig. 2.
`
`Describing the operation of sending a message from the originator PMU 105, Cannon discloses
`that a user-initiated signal may be received from the controls 215 (see Annotation 2 of Fig. 2)
`indicating that a message is to be transmitted to another device. Upon receiving the signal, the
`sender 240 in the originator PMU 105 references the database 230 to determine whether the
`entered message is a canned message. Then the sender 240 provides the message information or
`message alias associated with the selected canned message to the transceiver 205 (see
`Annotation 2 of Fig. 2), along with the message code, the friend alias or recipient address, for
`transmission from the PMU 105 to the system controller 110. Id. at 5:10-12, 5:29 and 5:56-66.
`
`As an example of a frequent transmitted message sent from the originator PMU 105 to the system
`controller 110 for forwarding to the destination PMU 105, Cannon describes that the PMU 105
`transmits a frequently transmitted message by sending the message alias, along with the message
`code, the friend alias, in a transmission to the system controller 110, as illustrated by Fig. 10
`(reproduced below).
`
`Based on the above teaching of the '506 Patent and in view of my education and experience, a
`person of ordinary skill in the art at the time of filing the '506 Patent would have understood that,
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`56.
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`when the sender 240 is implemented as program code, e.g., firmware, the processor 210 in the
`originator PMU 105 may execute sender 240 code to compile the message alias associated with
`the selected canned message along with the message code, the friend alias or recipient address,
`and/or other associated message information, into a signal for transmission to the system controller
`110. A person of ordinary skill in the art would have also understood that, when the sender 240 is
`implemented as using hardware, the sender 240 hardware may execute instructions to compile the
`message alias associated with the selected canned message along with the message code, the
`friend alias or recipient address, and/or other associated message information, into a signal for
`transmission to the system controller 110.
`
`Describing the operation of the system controller 110, Cannon discloses that the system controller
`includes a router 540 (see Annotation 1 of Fig. 12) that is activated upon receiving a signal from
`the originator PMU 105 that includes a message alias. Id. at 8:20-38. The router relays the
`message alias corresponding to the signal received from the originator PMU 105 to the destination
`PMU 105. Id. at 8:39-58.
`
`Describing the operation of receiving a canned message by a PMU 105, Cannon discloses that,
`upon receiving a message that is routed by the system controller 110, a destination PMU 105
`activates a receiver 245 (see Annotation 2 of Fig. 2), which may be firmware executed by the
`processor 210, or may be implemented in hardware capable of performing equivalent operations.
`Id. at 4:4-12, 4:62-67. Specifically, the receiver 245 compares the received message information
`with aliases in the message list stored in the PMU 105’s memory. When the received message
`alias matches to an alias stored in the message list, the receiver 245 retrieves the corresponding
`canned message from the message list. Then the destination PMU 105 can display the ret