UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`
`
`
`
`MOBILE TELECOMMUNICATIONS TECHNOLOGIES, LLC
`Patent Owner
`
`____________
`
`
`
`Case IPR2014-01033
`Patent 5,894,506
`
`____________
`
`
`
`PATENT OWNER MOBILE TELECOMMUNICATIONS
`TECHNOLOGIES, LLC’S PRELIMINARY RESPONSE
`
`
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`

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`2.
`3.
`4.
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`5.
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`6.
`7.
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`
`
`TABLE OF CONTENTS
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`Page
`
`
`INTRODUCTION ........................................................................................... 1 
`I.
`BACKGROUND ............................................................................................. 1 
`II.
`III. PROPER CLAIM CONSTRUCTION ............................................................ 2 
`1.
`“a first file,” “a second file … corresponding to the first
`file,” and “a third file … corresponding to the first file” ............ 4 
`“the message code” ..................................................................... 6 
`“relaying the message code” ....................................................... 7 
`“a message terminal” and “a designated other message
`terminal” ...................................................................................... 9 
`“a file of canned messages and message codes … and a
`file of canned multiple response options and response
`codes” ........................................................................................ 11 
`“the response code” ................................................................... 12 
`“transmitting the message code … and the response
`code” and “compiling the assigned message code and the
`response codes” ......................................................................... 13 
`IV. REFERENCES RELIED UPON BY PETITIONER .................................... 15 
`A.
`Cannon ................................................................................................ 15 
`B.
`LaPorta ................................................................................................ 23 
`C. Will ...................................................................................................... 28 
`V. GROUND 1 – CLAIMS 8-9 ARE NOT ANTICIPATED BY
`CANNON. ...................................................................................................... 33 
`A.
`Cannon does not disclose relaying the message code. ........................ 33 
`B.
`Cannon and LaPorta are not prior art. ................................................ 38 
`VI. GROUND 2 – CLAIMS 10, 19, AND 21 ARE NOT OBVIOUS
`OVER CANNON IN VIEW OF LAPORTA. ................................................. 41 
`A.
`Cannon and LaPorta do not disclose relaying message codes or
`separate files for messages and responses. .......................................... 41 
`
`
`
`

`
`ii.
`
`1.
`2.
`
`Claim 10 is not obvious over Cannon in view of LaPorta. ...... 41 
`Claims 19 and 21 are not obvious over Cannon in view
`of LaPorta. ................................................................................ 44 
`i.
`Neither Cannon Nor LaPorta Teaches or Suggests
`Elements 19(a) or 21(a) of Independent Claims 19
`and 21 .............................................................................. 45 
`Neither Cannon Nor LaPorta Teaches or Suggests
`Elements 19(e) or 21(e) of Independent Claims 19
`and 21. ............................................................................. 48 
`B.
`Cannon and LaPorta are not prior art. ................................................ 53 
`VII. GROUND 3 – CLAIMS 11-12 ARE NOT OBVIOUS OVER
`CANNON IN VIEW OF WILL. ..................................................................... 53 
`A.
`Cannon and Will do not disclose relaying a message code. ............... 53 
`B.
`Cannon is not prior art. ....................................................................... 56 
`VIII. GROUND 4 – CLAIMS 13-14 ARE NOT OBVIOUS OVER
`CANNON IN VIEW OF WILL AND LAPORTA. ......................................... 56 
`A.
`Cannon, Will, and LaPorta do not disclose relaying a message
`code. ..................................................................................................... 56 
`B.
`Cannon and LaPorta are not prior art. ................................................ 57 
`IX. CONCLUSION .............................................................................................. 57 
`
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`

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`TABLE OF AUTHORITIES
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`Page
`
`CASES 
`Advanced Display Sys. Inc. v. Kent State Univ., 212 F.3d 1272 (Fed. Cir.
`2000) ................................................................................................................... 33
`Facebook, Inc. v. Evolutionary Intelligence, LLC, IPR2014-00093, Paper 12
`(P.T.A.B. Apr. 28, 2014) ...................................................................................... 3
`In re Royka, 490 F.2d 981 (CCPA 1974) ......................................................... 41, 44
`In re Zletz, 13 USPQ2d 1320 (Fed. Cir. 1989) .......................................................... 3
`Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359 (Fed. Cir. 2008) .............. 33, 35
`Xerox Corp. v. 3Com Corp., 458 F.3d 1310 (Fed. Cir. 2006) ................................. 33
`
`OTHER AUTHORITIES 
`
`35 United States Code § 102 ...................................................................................... 1
`35 United States Code § 103 ...................................................................................... 1
`35 United States Code § 312(c) ................................................................................. 2
`37 Code of Federal Regulations § 42.100(b) ............................................................. 3
`37 Code of Federal Regulations § 42.104(b)(3) ........................................................ 2
`Manual of Patent Examining Procedure § 715.07 ................................................... 38
`
`
`
`
`iii
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`

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`PATENT OWNER EXHIBIT LIST
`2000. April 2014 Deposition of
`in Mobile
` Mr. Gregory Pinter
`Telecommunications Technologies, LLC v. Sprint Nextel Corporation, Civil
`Action No. 2:12-cv-832-JRG-RSP, U.S.D.C. for the Eastern District of
`Texas
`
`2001.
`
`Sheth Memo dated February 17, 1995
`
`2002. Huller Memo dated February 23, 1995
`
`2003.
`
`2004.
`
`1995 Functional Requirements dated March 13, 1995
`
`The WSJ article dated September 19, 1995
`
`2005. USA Today article dated September 19, 1995
`
`iv
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`

`
`
`I.
`
`INTRODUCTION
`
`Patent Owner, Mobile Telecommunications Technologies, LLC, submits this
`
`Preliminary Response to the Petition for Inter Partes Review of claims 8-14, 19,
`
`and 21 of U.S. Patent No. 5,894,506 (“the ‘506 Patent”). 37 C.F.R. § 42.107.
`
`Patent Owner respectfully requests that the Board deny the Petition on every
`
`ground alleged by Petitioner for, at least, the following reasons. First, with regard
`
`to grounds 1-4, Cannon does not teach relaying the message code as recited in
`
`claims 8-14. LaPorta and Will do not cure the defect of Cannon. Second, with
`
`regard to ground 2, Cannon in view of LaPorta does not teach or suggest sending
`
`or compiling a message code together with a response code in an original message
`
`as recited in claims 19 and 21, respectively. Therefore, there is no reasonable
`
`likelihood that Petitioner can prevail with regard to claims 8-14, 19, and 21 of the
`
`‘506 Patent.
`
`II. BACKGROUND
`
`On June 27, 2014, Apple Inc. filed a Petition for Inter Partes Review under
`
`37 C.F.R. § 42.100, requesting inter partes review of claims 8-14, 19, and 21 of
`
`the ‘506 Patent. Petitioner asserts that claims 8-14, 19, and 21 of the ‘506 Patent
`
`are unpatentable over the following references under 35 U.S.C. §§ 102 and 103:
`
`(1) Claims 8 and 9 as anticipated by U.S. Patent No. 5,850,594 (Exhibit
`
`1004, “Cannon”);
`
`1
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`

`
`
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`(2) Claims 10, 19, and 21 as obvious over Cannon in view of U.S. Patent
`
`No. 5,970,122 (Exhibit 1005, “LaPorta”);
`
`(3) Claims 11 and 12 as obvious over Cannon in view of U.S. Patent No.
`
`5,588,009 (Exhibit 1006, “Will”); and
`
`(4) Claims 13 and 14 as obvious over Cannon in view of Will and
`
`LaPorta.
`
`III. PROPER CLAIM CONSTRUCTION
`
`By statute, Petitioner must identify “in writing, and with particularity, each
`
`claim challenged, the grounds on which [each] challenge … is based, and the
`
`evidence that supports the grounds . . . .” 35 U.S.C. § 312(c). This requires a
`
`precise statement on “[h]ow the challenged claim is to be construed.” 37 C.F.R. §
`
`42.104(b)(3). The Petition fails to set forth how the independent claims are to be
`
`construed. Petitioner construes only four terms. Petitioner dismisses its
`
`obligations by saying, “[a]ll remaining terms should be given their plain meaning,”
`
`without articulating any such construction. Paper 6 at 4.
`
`By leaving the entire breadth of the independent claims without an
`
`articulated construction, Petitioner’s asserted grounds for unpatentability are
`
`deficient because the basis of Petitioner’s conclusion that a particular claim
`
`element or limitation is taught in the asserted references is unclear.
`
`
`
`2
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`

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`
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`Petitioner makes clear that it has taken this approach, because it does not
`
`want to be bound by constructions adopted in this proceeding. Petitioner points
`
`out that “[b]ecause the standards of claim interpretation applied in litigation differ
`
`from PTO proceedings, any interpretation of claim terms in this IPR is not binding
`
`upon Apple in any litigation related to the subject patent.” Paper 6 at 3-4 footnote
`
`2 (citing In re Zletz, 13 USPQ2d 1320, 1322 (Fed. Cir. 1989)). Petitioner’s
`
`approach unfairly forces Patent Owner (as well as the Board) to guess at how
`
`Petitioner is construing any given term. Consequently, on its face, the Petition is
`
`deficient and fails to meet the standard for institution of review. If the Board does
`
`not summarily deny the Petition for this reason, Patent Owner respectfully submits
`
`the following proposed constructions for purposes of this proceeding only.
`
`Claim terms in an unexpired patent are given their broadest reasonable
`
`construction in light of the specification. 37 Code of Federal Regulations §
`
`42.100(b) (emphasis added). Claim terms are given their ordinary and customary
`
`meaning, as would be understood by one of ordinary skill in the art in the context
`
`of the entire disclosure. Facebook, Inc. v. Evolutionary Intelligence, LLC,
`
`IPR2014-00093, Paper 12 (P.T.A.B. Apr. 28, 2014) (Decision Denying Institution
`
`of Inter Partes Review), at p. 7 (internal citations omitted).
`
`Petitioner acknowledges this rule in passing, yet does not cite the ‘506
`
`Patent to support any of its four claim constructions. Instead, Petitioner cites to the
`
`
`
`3
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`

`
`
`specification only indirectly by citing the declaration of Dr. Surati for its
`
`constructions
`
`i and
`
`ii and
`
`the claim construction order from Mobile
`
`Telecommunications Technologies, LLC v. Apple Inc., Civil Action No. 2:13-cv-
`
`258-JRG-RSP (E.D. Tex.) (“Markman Order”) for constructions i, ii, iii, and iv.
`
`Markman Orders are irrelevant here because they are based on the litigation
`
`positions of the parties. “Litigation positions taken subsequent to issuance of the
`
`patent are unreliable.” IPR2012-00001 Paper 15 at 7. To the extent Petitioner’s
`
`claim constructions i, ii, iii, and iv are based on a Markman Order, they should be
`
`excluded.
`
`Moreover, the Petition sets forth no alternative claim constructions, with
`
`respect to independent claims 8, 19, and 21. Therefore, Patent Owner’s proposed
`
`constructions stand unchallenged.
`
`1.
`
`“a first file,” “a second file … corresponding to the first
`file,” and “a third file … corresponding to the first file”
`
`Challenged claim 8 recites “a first file” of canned messages and message
`
`codes at the network operation center (“NOC”), a “second file” of canned
`
`messages and message codes at the first terminal “corresponding to the first file,”
`
`and “a third file” of canned messages and message codes at the second terminal
`
`“corresponding to the first file.” Here, “a first file,” “a second file,” and “a third
`
`file” are “separate files on separate devices that each include customized messages
`
`
`
`4
`
`

`
`
`and message codes.” The ’506 Patent specification supports this plain and
`
`ordinary construction in describing that a messaging group or organization
`
`establishes a file of customized canned messages and response options. Ex. 1001
`
`at 5:59-61. In addition, the first and second files are updated according to the
`
`needs of a particular group of subscribers and corresponding canned message files
`
`(the third file) “are also maintained at receiving subscriber terminals, such that the
`
`canned messages may be communicated to the receiving subscribers in message
`
`code form.” Id. at 2:1-6 and 2:28-32.
`
`Thus, “corresponding to the first file” is construed here as “having the same
`
`contents as the first file.” As both the second and third files have the same
`
`contents as the first file, both the second and third files have the same content. The
`
`plain language of claim 8 confirms this. Claim 8 provides that a canned message is
`
`selected from the second file on the first terminal. The message code of the
`
`selected canned message is sent to the NOC that, in turn, relays the message code
`
`to the second terminal. The second terminal retrieves the canned message from the
`
`third file using the relayed message code and displays the canned message. By this
`
`plain language, the second file and the third file have to have the same contents
`
`(canned messages and message codes). Otherwise, the second terminal could not
`
`use the relayed message code to successfully find the same canned message as was
`
`selected on the first terminal. In other words, in order to decode the message code,
`
`
`
`5
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`

`
`
`both the first and the second terminals have to have access to the same canned
`
`messages and message codes.
`
`The ‘506 Patent likewise shows that “corresponding to the first file” means
`
`“having the same contents as the first file.” The ’506 Patent explicitly describes
`
`that “NOC 12 maintains multiple files of canned messages and canned response
`
`options, including files identical to those stored at calling terminal 10 and possibly
`
`also at receiving terminal 14.” Id. at 6:3-6. (Emphasis added.)
`
`In summary, “a first file,” “a second file,” and “a third file” are “separate
`
`files on separate devices that each include the same contents (or same messages
`
`and message codes).”
`
`2.
`
`“the message code”
`
`Challenged claim 8 recites sending, relaying, and using “the message code.”
`
`For this proceeding only, a “message code” is “the code assigned to the selected
`
`canned message that replaces the selected canned message in a transmission.”
`
`Claim 8 recites “selecting an appropriate canned message … for
`
`transmission to the second terminal.” So, it is intended that the selected canned
`
`message be transmitted to the second terminal. The selected canned message is
`
`never sent or transmitted anywhere in the claim. Indeed, the next lines recite
`
`“sending the message code assigned to the selected canned message to the network
`
`operation center” and “relaying the message code … from the network operation
`
`
`
`6
`
`

`
`
`center to the second terminal.” Thus, the plain and ordinary meaning of this
`
`language is that a message code assigned to the selected canned message replaces
`
`the selected canned message in the transmission to the second terminal.
`
`In addition, the ‘506 Patent explains that message codes replace canned
`
`messages: “commonly used phrases can be treated as ‘canned’ messages that can
`
`be replaced by short message codes.” Ex. 1001 at 1:47-48.
`
`3.
`
`“relaying the message code”
`
`Challenged claim 8 recites “relaying the message code … from the network
`
`operation center to the second terminal.” Thus, “relaying the message code”
`
`means “passing on the message code” from the NOC to the second terminal.
`
`The plain and ordinary meaning of “relay” is “the act of passing something
`
`from
`
`one
`
`person
`
`or
`
`device
`
`to
`
`another.”
`
`
`
`http://www.merriam-
`
`webster.com/dictionary/relay. The plain and ordinary meaning of “relaying” is “to
`
`pass along by relays.” Id. Therefore, “relaying the message code” means “passing
`
`on the message code” from the NOC to the second terminal. The specification
`
`supports this construction.
`
`The ‘506 Patent describes that “FIG. 3 is a flow diagram illustrating the
`
`operation of the network operation center (NOC) … when relaying a message from
`
`the calling terminal to the receiving terminal.” Ex. 1001 at 2:63-66 (emphasis
`
`added). FIG. 3 of the ‘506 Patent is reproduced below.
`
`
`
`7
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`

`
`
`
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`
`
`In step 50 of FIG. 3, “[t]he canned message/response option codes … are
`
`received by a NOC receiver….” Id. at 5:46-49. In step 52, the identities of the
`
`calling and receiving terminals are found so that the NOC can determine if “the
`
`designated receiving party is a member of a messaging group or organization that
`
`has established a file of customized canned 60 messages and response options and
`
`thus has access to a terminal in which files of the customized canned
`
`messages/response options and associated codes are stored in memory.” Id. at
`
`5:58-63. In step 56, “[i]f the designated receiving terminal can accept canned
`
`message/response option codes, they are transmitted to the designated receiving
`
`party terminal in the same form as received from the sending party terminal.” Id.
`
`
`
`8
`
`

`
`
`at 6:12-15 (emphasis added). Therefore, FIG. 3 shows that codes from the calling
`
`terminal 10 are “transmitted in the same form” or “passed on” to the receiving
`
`terminal by the NOC, if the receiving terminal is from the same group or
`
`organization as the second terminal.
`
`From constructions 1-3, it is clear that claim 8 recites a method for
`
`communicating a canned message from a calling (first) terminal to a receiving
`
`(second) terminal by passing on a message code from the calling terminal to the
`
`receiving terminal using a NOC. The message code represents the canned message
`
`by both the calling terminal and the receiving terminal, because the calling
`
`terminal and the receiving terminal have separate files (the second file and the third
`
`file) that have the same contents (or same messages and message codes).
`
`4.
`
`“a message terminal” and “a designated other message
`terminal”
`
`Challenged claims 19 and 21 recite “a message terminal” and “a designated
`
`other message terminal.” For this proceeding only, “a message terminal” is “a
`
`calling terminal,” and “a designated other message terminal” is “a receiving
`
`terminal.”
`
`The plain and ordinary meaning of the words of claims 19 and 21 describe
`
`that the message terminal has a “means for selecting one of the canned messages
`
`and at least one of the multiple response options … for communication to a
`
`
`
`9
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`

`
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`designated other message terminal” and “a transmitter for transmitting the message
`
`code … and the response code.” In other words, the message terminal selects and
`
`sends both the canned message and a response option to the designated other
`
`message terminal. Thus, the message terminal is the initiating and calling terminal
`
`and the designated other message terminal is the receiving terminal.
`
`The ‘506 Patent confirms this construction by disclosing that “calling
`
`terminal 10 includes a stored file of canned messages and associated canned
`
`message codes.” Id. at 3:44-46. “The calling party browses through the file to
`
`determine if the text of any of the canned messages is appropriate to convey the
`
`particular message that the calling party wishes to send to the receiving party. If
`
`an appropriate canned message is noted, the calling party selects this canned
`
`message.” Id. at 3:50-55. “[T]he present invention also provides for the addition
`
`of response options to certain canned messages typically posed as questions.” Id.
`
`at 4:33-35. “The selected canned response codes and parameters are then compiled
`
`with the canned message code and any canned message parameters (step 32). The
`
`calling terminal then transmits the compiled canned message and response codes,
`
`together with any parameters to NOC 12 (step 34).” Id. at 4:50-55. “NOC 12
`
`determines whether the designated receiving party terminal can accept the canned
`
`message in code form.” Id. at 6:7-9. “If the designated receiving terminal can
`
`
`
`10
`
`

`
`
`accept canned message/response option codes, they are transmitted to the
`
`designated receiving party terminal.” Id. at 6:12-14.
`
`This construction is important, because it shows that claims 19 and 21 are
`
`directed to the actions of the calling terminal. They are not directed to the actions
`
`of the user or the receiving terminal.
`
`5.
`
`“a file of canned messages and message codes … and a file
`of canned multiple response options and response codes”
`
`Challenged claims 19 and 21 recite a memory storing “a file of canned
`
`messages and message codes” and “a file of canned multiple response options and
`
`response codes.” Here, “a file of canned messages and message codes … and a file
`
`of canned multiple response options and response codes” are “two separate files
`
`with one file containing canned messages and message codes and the other file
`
`containing canned multiple response options and response codes.”
`
`The plain and ordinary meaning of the conjunction “and” in claims 19 and
`
`21 shows that two separate files are being stored and retrieved. The claims recite
`
`“a memory storing a file of canned messages and message codes … and a file of
`
`canned multiple response options and response codes” and a “means for retrieving
`
`the file of canned messages … and the file of canned multiple response options
`
`from the memory.”
`
`
`
`11
`
`

`
`
`
`The ‘506 Patent reinforces this construction in describing that “[i]n
`
`accordance with the present invention, calling terminal 10 includes a stored file of
`
`canned messages and associated canned message codes.” Id. at 3:44-46 (emphasis
`
`added). In another passage, the ‘506 Patent describes “the addition of response
`
`options to certain canned messages typically posed as questions. To this end,
`
`terminal 10 maintains a file of canned response options.” Id. at 4:33-36.
`
`6.
`
`“the response code”
`
`Challenged claims 19 and 21 recite transmitting “the response code” from
`
`the message terminal. For this proceeding only, “the response code” is “the code
`
`assigned to the selected at least one response option that replaces the selected at
`
`least one response option in a transmission.”
`
`Claims 19 and 21 recite the response code or the response codes “assigned to
`
`the selected multiple response options. Therefore, the plain and ordinary meaning
`
`of these words is that “the response code” is referring to the code assigned to the at
`
`least one response option that was selected by the means for selecting.
`
`In addition, the specification of the ‘506 Patent provides that “[t]he 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.
`
`
`
`12
`
`

`
`
`
`7.
`
`“transmitting the message code … and the response code”
`and “compiling the assigned message code and the response
`codes”
`
`Claims 19 and 21 recite “transmitting the message code … and the response
`
`code” and “compiling the assigned message code and the response codes” from the
`
`message terminal, respectively. Here, “transmitting the message code … and the
`
`response code” means “transmitting the message code together with the response
`
`code,” and “compiling the assigned message code and the response codes” means
`
`“compiling the assigned message code together with the response codes.”
`
`The plain and ordinary meaning of the conjunction “and” means that the
`
`message code is transmitted together with the response code, and the message code
`
`is compiled together with the response code by the message terminal.
`
`Further, the specification of the ‘506 Patent describes that “[t]he calling
`
`terminal then transmits the compiled canned message and response codes, together
`
`with any parameters to NOC 12.” Id. at 4:53-54. The ‘506 Patent also describes
`
`that “[t]he selected canned response codes and parameters are then compiled with
`
`the canned message code and any canned message parameters (step 32). The
`
`calling terminal then transmits the compiled canned message and response codes,
`
`together with any parameters to NOC 12 (step 34).” Id. at 4:50-55.
`
`
`
`13
`
`

`
`
`
`From constructions 4-7, challenged claims 19 and 21 mean that a calling
`
`message terminal transmits a message code together with a response code to a
`
`receiving message terminal. The message code and the response code are obtained
`
`from separate files. Since the message code and the response code are transmitted
`
`together, it is clear that claims 19 and 21 are directed to transmitting an original
`
`message from a calling terminal that includes a selectable response option.
`
`Claims 19 and 21 are not directed to the actions of a receiving terminal in
`
`response to an original message. “FIG. 4 [shown below] illustrates the operation
`
`of receiving terminal 14 upon receiving a message transmission.” Id. at 6:25-26.
`
`
`
`14
`
`

`
`
`
`
`
`Step 80 in FIG. 4 shows that a receiving terminal only transmits a response
`
`option in response to an original message from a calling terminal. In other words,
`
`since the receiving terminal does not send the message code and response code
`
`together, claims 19 and 21 cannot be construed as directed to a receiving terminal
`
`that is transmitting in response to an original message from a calling terminal.
`
`IV. REFERENCES RELIED UPON BY PETITIONER
`
`A. Cannon
`
`Cannon is directed to a communication system designed “to keep messages
`
`
`
`15
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`

`
`
`transmitted over the wireless channel as short as possible” in order to “provide
`
`more efficient messaging.” Ex. 1004 at 1:23-25 and 1:35-36. FIG. 1 (shown
`
`below) illustrates the communication system of Cannon:
`
`
`
`The communication system of Cannon includes “one or more portable
`
`messaging units (PMUs) 105” that engage in two-way communication with system
`
`controller 110 “over at least one wireless communication channel.” Id. at 2:8-12.
`
`“The system controller 110 can also be coupled to other types of devices, such as
`
`computers 115, by wireline communication links.” Id. at 2:14-16.
`
`“Because radio frequency communication channels typically have limited
`
`bandwidths,” communication system 100 “employs relatively short aliases to
`
`communicate frequently transmitted information from the PMUs 105 to the system
`
`controller 110. Specifically, frequently used messages can be represented by
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`message aliases, and addresses of recipients to whom messages are frequently
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`[sent] can be represented by recipient aliases.” Id. at 2:16-26. In other words, the
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`communication system provides more efficient messaging across the wireless
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`channel between a PMU and the system controller by sending a message alias
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`rather than the full message.
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`“Databases of the frequently transmitted information and the associated
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`aliases are preferably stored at the PMUs 105 and at the system controller 110 so
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`that each device can recognize an alias and conveniently interpret the more lengthy
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`message or friend address associated therewith.” Id. at 2:18-32. “FIG. 2 [shown
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`below] is an electrical block diagram of a PMU 105.” Id. at 2:39.
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`FIG. 2 shows that the database 230 of a PMU includes a message list.
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`“[T]he lists in the database 230 are maintained in accordance with instructions by
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`the user of the PMU.” Id. at 2:50-52. In other words, the message list of a PMU is
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`maintained by a user. This means that the message list on each PMU is specific to
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`that PMU. Since “each message included in the message list is associated with a
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`message alias,” each message and associated message alias is specific to a PMU.
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`Id. at 3:11-12.
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`“FIG. 12 [shown below] is an electrical block diagram of the system
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`controller 110.” Id. at 7:23-24.
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`FIG. 12 shows that database 530 of system controller 110 includes multiple
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`message lists. “A subscriber database 530 is coupled to the CPU 515 for storing
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`subscriber information, such as addresses of devices that subscribe for service
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`within the system 100 and friend and message lists associated with subscribing
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`PMUs.” Id. at 7:23-24. In other words, the system controller stores the message
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`lists associated with each PMU.
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`This explains how the system controller is able to understand the message
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`aliases sent from different PMUs. Because each PMU has a specific message list
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`that includes messages and associated aliases, the system controller has to have a
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`message list corresponding to each PMU that it communicates with. The following
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`Annotation 1 of FIG. 1 (below) shows how the message lists are stored among
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`different PMUs and the system controller.
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`The annotations to FIG. 1 show that two different PMUs have two different
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`message lists, Message List A and Message List B. A message alias can be sent
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`between the PMUs and the system controller, because the system controller stores
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`all the message lists of the PMUs. The system controller uses the message list of
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`the PMU that sends a message alias to decode the alias and obtain the message.
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`Using this mechanism of decoding aliases using the message list of a particular
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`PMU, the communication system can also send a message from one PMU to
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`another using aliases.
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`FIG. 13 of Cannon is a flowchart depicting the operation of the CPU of the
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`system controller. When the information received by the system controller
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`indicates “that the user of the PMU 105 is sending a message to another device, the
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`CPU 515 determines, at step 582, whether the message information included in the
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`incoming signal is in the form of a message alias.” Id. at 8:20-25. “When a
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`message alias is included in the signal from the PMU 105, the CPU 515 references,
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`at step 584, the subscriber database 530 to determine whether the received message
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`alias is included in the canned message list associated with the PMU 105. When it
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`is, if it is, the message associated with the canned message alias is recovered, at
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`step 586, and the router 540 is activated.” Id. at 8:30-36. In other words, when the
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`system controller receives a message alias from a sending PMU that is meant to
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`convey a message to another PMU, the first action of the system controller is to
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`decode the alias or look up the alias in the message list of the sending PMU and
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`recover the full canned message. This full canned message is then sent to the
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`router algorithm.
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`The router algorithm performs a reverse lookup in the message list of the
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`receiving PMU that is located on the system controller. “FIG. 14 [shown below] is
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`a flowchart depicting an operation of a router included in the system controller.”
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`Id. at 1:65-66.
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`At step 605 in FIG. 14, the router receives “message information comprising
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`a message and recipient information.” Id. at 8:41-42. Note that the router does not
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`receive a message alias. Instead, the router uses the full canned message recovered
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`from the sending PMU’s message list to lookup a message alias in the receiving
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`PMU’s message list. “[A]t step 630, the canned message list for the recipient
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`device is referenced. When, at step 635, the message to be sent to the device
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`comprises a canned message stored in the device’s list, the message alias
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`representative of the message is recovered.” Id. at 8:50-54.
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`The system controller then sends the message alias that the receiving PMU
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`understands to the receiving PMU. “The recipient address, the message code, the
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`message number, and the message alias are then provided, at step 640, to the
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`transceiver 505 for transmission to the recipient device, which can, for instance,
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`comprise another PMU.” Id. at 8:54-58.
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`Annotation 1 of FIG. 1 of Cannon, shown above, also shows how message
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`aliases are used to send a canned message from a s