throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Attorney Docket No. 062891.3964
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`IPR No. Unassigned
`
`
`
`In Re:
`
`U.S. Patent 6,069,895
`
`Inventor:
`
`Siamack Ayandeh
`
`Filed:
`
`Issued:
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`August 29, 1997
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`May 30, 2000
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`:
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`:
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`:
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`:
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`Assignee: Bockstar Technologies LLC
`Title:
`Distributed Route Server
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`Submitted Electronically via the Patent Review Processing System
`
`DECLARATION OF DR. PAUL C. CLARK
`UNDER 37 C.F.R. § 1.132
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`CISCO Exhibit 1009
`Cisco v. Bockstar
`Trial IPR2014 - 1
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`Table of Contents
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`Introduction ...................................................................................................... 1
`I.
`Background and Qualifications ....................................................................... 2
`II.
`III. Legal Understanding ........................................................................................ 5
`IV. Level of Ordinary Skill in the Art ................................................................... 7
`V.
`The ’895 Patent ................................................................................................ 9
`A. Overview of the ’895 Patent ......................................................................... 9
`B. Claim Construction ..................................................................................... 11
`VI. The Prior Art .................................................................................................. 19
`A.
`Prior Art Considered ................................................................................... 19
`B. The Background of Routing Architectures ................................................. 19
`C. Newman and Bion ....................................................................................... 21
`D.
`Souza ........................................................................................................... 42
`E.
`Jain .............................................................................................................. 45
`F. Wicki ............................................................................................................ 48
`G. Katsube ........................................................................................................ 52
`H.
`Internet Archive Downloads ....................................................................... 58
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`CISCO Exhibit 1009
`Cisco v. Bockstar
`Trial IPR2014 - 2
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`Declaration of Dr. Paul C. Clark
`
`
`I, Dr. Paul C. Clark, declare as follows:
`
`I.
`
`Introduction
`1.
`
`I have been retained as a technical expert on behalf of Cisco Systems,
`
`Inc. in connection with the above-captioned petition (“Petition”) for Inter Partes
`
`Review (“IPR”) of U.S. Patent No. 6,069,895 (“the ’895 Patent”). I understand
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`that the ’895 Patent is currently assigned to Bockstar Technologies LLC.
`
`2.
`
`I am familiar with the technology at issue as of August 29, 1997,
`
`which is the filing date of the application from which the ’895 Patent granted.
`
`3.
`
`I have been asked to provide my technical opinion on concepts
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`discussed in the ’895 Patent and the prior art references, as well as my technical
`
`opinion on how these concepts relate to several ’895 Patent claim limitations in the
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`context of the specification.
`
`4.
`
`I have been asked to consider how a person of ordinary skill in the art
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`would understand the claims of the ’895 Patent and the prior art references
`
`identified in the Petition. In reaching the opinions stated herein, I have considered
`
`the ’895 Patent, the Petition, and the references listed in Section V in the context of
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`my own education, training, research, knowledge, and personal and professional
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`experience.
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`Cisco v. Bockstar
`Trial IPR2014 - 3
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`5.
`
`I am being compensated at my standard hourly rate of $590 per hour.
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`My compensation is not dependent on the outcome of this IPR and in no way
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`affects the substance of my statements in this declaration.
`
`II. Background and Qualifications
`6. My qualifications are stated more fully in my curriculum vitae.
`
`CSCO-1010. Here I provide a brief summary of my qualifications:
`
`7.
`
`In 1986, I received a Bachelor of Science degree in Mathematics from
`
`the University of California, Irvine. In 1988, I received a Master of Science degree
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`in Electrical Engineering and Computer Science from the University of Southern
`
`California. In 1994, I received a Doctor of Science degree in Computer Science
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`from George Washington University.
`
`8.
`
`From 1985 to 1989, I worked as a Systems Engineer at Ultrasystems
`
`Defense and Space. At Ultrasystems, I designed and implemented large-scale
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`simulation and network-based systems for the United States Department of
`
`Defense (“DoD”). A custom high-speed database server I designed and
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`implemented was used for real-time intelligence collection by the National
`
`Security Agency (“NSA”).
`
`9.
`
`From 1989 to September 1990, I worked as a Technical Lead at GTE
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`Government Systems. While at GTE, I designed and implemented network load
`
`generators for an OS/2 LAN Manager to measure network performance load
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`metrics for the Central Intelligence Agency (“CIA”). I also developed X Windows
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`interfaces for a large-scale multiuser event driven network database system.
`
`10. From 1990 to 1995, I worked as a Senior Security Engineer at Trusted
`
`Information Systems. While at Trusted Information Systems, I implemented
`
`Privacy Enhanced Mail (“PEM”) as defined in RFC 1113, 1114 and 1115 and was
`
`involved in the design and implementation of the MIME Object Security Services
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`front end to PEM as specified in the PEM-MIME Internet Draft and subsequent
`
`RFC 1848. In connection with this work I attended and closely followed security
`
`industry conferences, working groups and publications. I also designed and
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`implemented high assurance security systems, including trusted operating systems
`
`and applications for NSA and the Defense Advanced Research Projects Agency
`
`(“DARPA”) and a secure email forwarder for the first whitehouse.gov email
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`server. Based upon the TIS PEM implementation, the White House mail forwarder
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`inspected email to ensure it was digitally signed and from an authorized sender. If
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`the message was properly validated, the signed version was archived on the server
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`and the un-enhanced email forwarded to the intended recipient. My work at
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`Trusted
`
`Information Systems
`
`involved cryptography, multilevel systems,
`
`smartcards, and other cutting edge network and security technologies.
`
`11. From 1995 to 1999, I worked as Chief Scientist at DynCorp Network
`
`Solutions, where I served as senior internal consultant for a variety of projects. For
`
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`Cisco v. Bockstar
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`example, I was architect and Technical Director of the IRS Secure Submission and
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`Retrieval System that allowed the digitally signed and encrypted submission of tax
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`data over the Internet. I also created a suite of security products for providing
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`secure wide area access to database and application servers that was marketed and
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`sold to the DoD and other parts of the federal government.
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`12. Since 1999, I have been President and Chief Technology Officer of
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`Paul C. Clark LLC/SecureMethods, Inc. SecureMethods specializes in the design,
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`implementation, and deployment of advanced secure network applications for
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`commercial and government clients, including the United States Department of
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`Defense. SecureMethods provides a comprehensive scalable, COTS-based secure
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`architecture, implemented through the use of the SM Gateway. The SM Gateway
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`is a next-generation security appliance developed by SecureMethods that is
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`available on UNIX-based platforms using commercial, government, and Type I
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`cryptography, implemented in both hardware and software. In my capacity as
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`President and Chief Technology Officer of SecureMethods, I have technical and
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`operational oversight of all projects and corporate technical operations. I also
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`provide guidance to senior technical personnel relating to design, implementation,
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`and troubleshooting for a wide range of systems both internal and external. My
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`work
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`includes network systems and security, cryptographic applications,
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`certification, key management, authentication, and integrity strategies for network
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`applications. My firm specializes in complex software and hardware systems for
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`commercial and DoD clients.
`
`13.
`
`I have also been a member of the Federal Advisory Committee for
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`Key Management
`
`Infrastructure
`
`(“KMI”), serving as Chairman of
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`the
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`Interoperability Working Group for Cryptographic Key Recovery. I have also
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`served as an adjunct professor in the Computer Science Department at George
`
`Washington University, where I have taught doctoral-level cryptography and
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`computer security courses. I have also appeared before a Congressional committee
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`to provide testimony on the “Advanced Technology for Border Control.”
`
`14.
`
`I have co-authored a number of publications in the computer
`
`networking and security areas, and I am a named inventor on two patents, U.S.
`
`Patent Nos. 5,448,045 and 5,892,902.
`
`III. Legal Understanding
`15. My opinions are informed by my understanding of the relevant law. I
`
`understand that the patentability analysis is conducted on a claim-by-claim basis.
`
`16.
`
`I understand that in proceedings before the USPTO, the claims of an
`
`unexpired patent are to be given their broadest reasonable interpretation in view of
`
`the specification from the perspective of one of ordinary skill in the art. I have
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`been informed that the ’895 Patent has not expired.
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`17.
`
`I understand that the prior art may render a patent claim “obvious.” I
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`understand that two or more pieces of prior art that each disclose fewer than all
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`elements of a patent claim may nevertheless be combined to render a patent claim
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`obvious if the combination of the prior art collectively discloses all elements of the
`
`claim and one of ordinary skill in the art at the time would have been motivated to
`
`combine the prior art. I understand that this motivation to combine need not be
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`explicit in any of the prior art, but may be inferred from the knowledge of one of
`
`ordinary skill in the art at the time the patent was filed. I also understand that one
`
`of ordinary skill in the art is not an automaton, but is a person having ordinary
`
`creativity. I further understand that one or more pieces of prior art that disclose
`
`fewer than all of the elements of a patent claim may render a patent claim obvious
`
`if including the missing element would have been obvious to one of skill in the art
`
`(e.g., the missing element represents only an insubstantial difference over the prior
`
`art or a reconfiguration of a known system).
`
`18.
`
`I understand that a patent claim is obvious if the differences between
`
`the subject matter claimed and the prior art are such that the subject matter as a
`
`whole would have been obvious at the time of the invention. I understand that the
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`obviousness analysis must focus on the knowledge available to one of skill in the
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`art at the time of the invention in order to avoid impermissible hindsight. I further
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`understand that the obviousness inquiry assumes that the person having ordinary
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`skill in the art would have knowledge of all relevant references available at the
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`time of the invention.
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`19.
`
`I also understand that the USPTO has identified exemplary rationales
`
`that may support a conclusion of obviousness, and I have considered those
`
`rationales in my analysis. The rationales include:
`
`(A) combining prior art elements according to known methods to
`yield predictable results;
`
`(B) simple substitution of one known element for another to obtain
`predictable results;
`
`(C) use of known techniques to improve similar devices (methods
`or products) in the same way;
`
`(D) applying a known technique to a known device (method or
`product) ready for improvement to yield predictable results;
`
`(E) “obvious to try” – choosing from a finite number of identified,
`predictable solutions, with a reasonable expectation of success;
`
` known work in one field of endeavor may prompt variations of
`(F)
`it for use in either the same field or a different one based on design
`incentives or other market forces if the variations are predictable to
`one of ordinary skill in the art; and
`
`(G) some teaching, suggestion, or motivation in the prior art that
`would have led one of ordinary skill to modify the prior art reference
`or to combine prior art reference teachings to arrive at the claimed
`invention.
`
`IV. Level of Ordinary Skill in the Art
`20.
`I have approached my analysis of the ’895 Patent from the perspective
`
`of a hypothetical person of ordinary skill in the art at the time of the filing of the
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`Cisco v. Bockstar
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`’895 Patent.
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`21. The ’895 Patent relates to the design of a network router. In order to
`
`determine who a hypothetical person of ordinary skill would be for purposes of this
`
`declaration, I have considered what was reasonably known in the field as of
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`August 29, 1997 (the filing date of the ’895 Patent), the education levels of active
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`workers in the field, the problems encountered in working in the field, the nature of
`
`the prior art relating to the field, and the complexity and speed of the development
`
`of the technology.
`
`22.
`
`I am familiar with the knowledge and capabilities one of ordinary skill
`
`in the computer networking arts in the period prior to August 1997. For example,
`
`my work as the Chief Scientist for DynCorp Network Solutions often involved
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`network architecture, capacity planning, configuration and deployment. These
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`projects included the interconnection of multiple IRS service centers on the
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`Treasury Communication System (TCS) wan and the Internet. I also had technical
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`oversight and involvement in a variety of other network projects including DoD
`
`and USPS. My work during that period allowed me to become personally familiar
`
`with the level of skill of individuals and the general state of the art. Unless
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`otherwise stated, my testimony below refers to the knowledge of one of ordinary
`
`skill in the computer networking arts in the period around August 1997, the period
`
`that includes the filing date of the ’895 Patent.
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`Cisco v. Bockstar
`Trial IPR2014 - 10
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`23. Based on these factors, it is my opinion that a hypothetical person of
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`ordinary skill in the art of the ’895 Patent would be (1) an engineer with at least a
`
`degree in electrical engineering, computer science, computer engineering, or a
`
`related discipline and several years of professional or research experience in
`
`computer networking; or (2) an engineer with at least five years of professional or
`
`research experience in computer networking.
`
`V. The ’895 Patent
`A. Overview of the ’895 Patent
`24.
`I have reviewed the ’895 Patent by Ayandeh, which is titled
`
`“Distributed Route Server.” CSCO-1001. I understand that the ’895 Patent was
`
`filed on August 29, 1997, and issued on May 30, 2000. See id. I also understand
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`that the ’895 Patent does not claim priority to any other patent application. See id.
`
`25.
`
`I understand the ’895 Patent relates to a design for a network route
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`server (e.g., a router) where routing functions are distributed in multiple packet
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`processing elements of the server. See id. at Abstract. The ’895 Patent discloses
`
`that the design includes a “route server element” that creates a routing table using a
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`topology database. Id. at 11:13-17. Instead of the route server element routing the
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`packets, the ’895 Patent discloses a scalable array of “packet processing elements”
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`(also referred to as “intelligent line-cards” in the patent) that individually receive
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`copies of the routing table and route the packets. Id. at 11:24-28. The packet
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`processing elements are able to route the packets autonomously using the copies of
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`the routing table without needing to consult the route server element. Id. Packets
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`are communicated between the packet processing elements using a “switch fabric”
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`according to the ’895 Patent. Id. at 1:28-33.
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`26. According to the ’895 Patent, this design is scalable in that the speed
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`and/or capacity to process packets can be increased by increasing the number of
`
`the intelligent line-cards since they are processing the packets and not the route
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`server element. Id. at 10:50-55. But this capacity is scalable only up to the
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`capacity of the switch fabric because the switch fabric is responsible for
`
`communicating packets between the intelligent line-cards in the design. See id. at
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`10:50-55 and 2:46-48.
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`27.
`
` The ’895 Patent specification contemplates embodiments in which
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`the packet processing elements also handle both connectionless and connection-
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`oriented traffic. Id. at 11:45-63. Connection-oriented services route traffic
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`between endpoints through fixed paths and intermediate hops or nodes simply need
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`to send the traffic along the fixed paths. Connectionless routing allows for
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`different paths between the endpoints at the cost of additional processing required
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`to make routing decisions at each intermediate hop or node. The ’895 Patent
`
`teaches that, in order to handle both of these types of traffic, the packet processing
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`elements have both a routing table and VCI (virtual circuit identifier) table. Id. at
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`3:8-30. The routing table is used to route connectionless traffic and the VCI table
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`is used to route connection-oriented traffic. Id.
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`28. The ’895 Patent also describes how often these tables are updated.
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`The routing tables can be updated periodically or when there is a change in the
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`network topology or traffic patterns. Id. With respect to the VCI tables, though,
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`the ’895 Patent teaches that the VCI tables are updated as connections get setup or
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`taken down. Id. at 3:31-32. This is because, in a connection-oriented system, the
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`path through multiple hops must be established in order for the data to be routed
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`through the network; thus, delays in having routers configured with the appropriate
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`VCI information translates into delays in getting the packet routed through the
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`network.
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`B. Claim Construction
`(i)
`“Scalable Switching Architecture” / “Scalable Array of Packet
`Processing Elements”
`
`29.
`
`It is my opinion that the broadest reasonable interpretation of
`
`“scalable switching architecture” in the context of the ’895 Patent’s specification is
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`“a switching architecture whose capacity can be increased without modifying the
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`architecture” and a broadest reasonable interpretation of the term “scalable array of
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`packet processing elements” is “an array of packet processing elements whose
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`capacity can be increased without modifying the architecture.”
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`30. The ’895 Patent specification states that “[i]t should also be
`
`appreciated by those skilled in the art that the aggregate performance of a server
`
`constructed with the intelligent line-cards 48 in accordance with the invention
`
`scales by increasing the number of intelligent line-cards 48 up to a point where the
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`switch fabric capacity is realized.” Id. at 10:50-55. In addition, the applicant of
`
`the ’895 Patent stated: “The disclosure explicitly explains that the capacity of the
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`switch is scalable because the packet processing elements have an aggregate
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`capacity that is scalable to a capacity of the switch fabric.” CSCO-1002 at 73-74.
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`Hence, the intrinsic evidence teaches that the architecture is “scalable” because the
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`number of packet processing elements can be scaled; that is, in order to process
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`more packets, packet processing elements would be added to the architecture and
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`connected to the switch fabric in the same way as the other packet processing
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`elements. The limit to how much this can scale is the capacity of the switch fabric.
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`This is because the switch fabric interconnects packet processing elements; thus, if
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`packets would be sent to the switch fabric by the set of packet processing elements
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`at a rate that is higher than the capacity of the switch fabric, there would be delays
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`in the switching of the packets that corresponds to the capacity of the switch fabric.
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`31.
`
` Given that the intrinsic evidence both teaches how to scale the
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`architecture of the ’895 Patent and the limits of how far up it can scale in terms of
`
`components of the architecture itself and without modification of the architecture,
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`one of ordinary skill in the art at the time the ’895 Patent was filed would have
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`understood that “scalable” architectures are ones in which capacity can be
`
`increased without needing to change the architecture. This is in accord with the
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`intrinsic evidence of the ’895 Patent as it teaches increasing the capacity by adding
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`line cards to the system. Therefore, one of ordinary skill in the art would
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`understand that for a switching architecture or an array of packet processing
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`elements to be “scalable” its capacity must be capable of being increased without
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`significant change to the underlying architecture. That is why it is my opinion that
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`the broadest reasonable interpretation of “scalable switching architecture” in the
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`context of the ’895 Patent’s specification is “a switching architecture whose
`
`capacity can be increased without modifying the architecture” and a broadest
`
`reasonable interpretation of the term “scalable array of packet processing
`
`elements” is “an array of packet processing elements whose capacity can be
`
`increased without modifying the architecture.”
`
`(ii)
`
`“Processor Means” (of the “Route Server Element”)
`
`32.
`
`Independent Claims 1, 9, and 16 recite a “processor means” of the
`
`“route server element” for either “creating a routing table for the route server using
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`a topology database and a routing algorithm” (Claim 1) or “executing a topology
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`discovery protocol and maintaining a topology database of the network, and for
`
`creating a routing table for the route server using the topology database and a
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`routing algorithm” (Claims 9 and 16). I understand that these limitations are
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`presumed to be means-plus-function limitations governed by 35 U.S.C. § 112, ¶ 6
`
`and that the construction of these terms depends on the corresponding structure
`
`identified in the specification of the ’895 Patent. I also understand that, because
`
`these are software means-plus-function limitations, the corresponding structure
`
`must also include an algorithm to perform the recited function. It is my opinion
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`that the broadest reasonable interpretation of the corresponding structure to these
`
`limitations disclosed in the ’895 Patent’s specification is a central controller
`
`performing the recited function using the Shortest Path First routing algorithm. I
`
`have not formed an opinion of whether the ’895 Patent has disclosed sufficient
`
`structure to comply with 35 U.S.C. § 112, ¶ 6.
`
`33. The ’895 Patent specification states: “The intelligent line-cards 48 in
`
`accordance with the invention accommodate complete copies of the routing tables
`
`computed by the central controller 46. These complete copies of the routing tables
`
`are downloaded periodically by the central controller 46 to the intelligent line-
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`cards 48 in accordance with criteria which will be explained below in some detail.”
`
`CSCO-1001 at 7:63-8:2. It also states that “[t]he size of the routing tables created
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`by the central controller 46 and downloaded to the intelligent line-cards 48 can be
`
`on the order of 100 kbytes, or more.” Id. at 9:17-19. One of ordinary skill in the
`
`art at the time the ’895 Patent was filed would understand that the structure
`
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`identified by the specification that “creat[es] a routing table for the route server
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`using a topology database and a routing algorithm” (Claim 1) or “execut[es] a
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`topology discovery protocol and maintain[s] a topology database of the network,
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`and for creating a routing table for the route server using the topology database and
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`a routing algorithm” (Claims 9 and 16) is a “central controller.” The ’895 Patent
`
`does not appear to provide any details of how a “central controller” is
`
`implemented. Regarding the algorithm for performing the recited function, the
`
`’895 Patent discusses in several places the creation of the routing table. However,
`
`in many of those instances, it simply states that the routing table is created using a
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`topology database and a routing algorithm. CSCO-1001 at Abstract, 1:32-36, and
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`2:31-32. But this is already in the recited function of the means-plus-function
`
`limitations. The only algorithm discussed in the ’895 Patent’s specification for
`
`performing the recited function (i.e., creating a routing table using the topology
`
`database and a routing algorithm”) is the well-known Shortest Path First algorithm.
`
`CSCO-1001 at 4:37-41, 5:15-18, and 5:60-65. Thus, I believe the broadest
`
`reasonable interpretation of the corresponding structure to these limitations
`
`disclosed in the ’895 Patent’s specification is a central controller performing the
`
`recited function using the Shortest Path First routing algorithm or equivalents
`
`thereof.
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`(iii)
`
`“Memory Means” (of the “Packet Processing Element”)
`
`34.
`
`Independent Claims 1, 9, and 16 recite a “memory means” of the
`
`“packet processing element” for “storing a copy of the routing table.” I understand
`
`that these limitations are presumed to be means-plus-function limitations governed
`
`by 35 U.S.C. § 112, ¶ 6 and that the construction of these terms depends on the
`
`corresponding structure identified in the specification of the ’895 Patent. It is my
`
`opinion that the broadest reasonable interpretation of the corresponding structure to
`
`these limitations disclosed in the ’895 Patent’s specification is a memory or
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`equivalents thereof for performing the recited function. I have not formed an
`
`opinion of whether the ’895 Patent has disclosed a sufficient structure to comply
`
`with 35 U.S.C. § 112, ¶ 6.
`
`35. The ’895 Patent specification states: “The intelligent line-cards 48 are
`
`preferably integrated input/output (I-O) controllers having input ports 50 and
`
`output ports 52 . . . . The intelligent line-cards 48 also are equipped with
`
`processors and memory to permit them to execute programs relating to
`
`sophisticated routing functions.” CSCO-1001 at 7:4-6, 21-24. It also states: “The
`
`intelligent line-cards 48 in accordance with the invention accommodate complete
`
`copies of the routing tables computed by the central controller 46. These complete
`
`copies of the routing tables are downloaded periodically by the central controller
`
`46 to the intelligent line-cards 48 in accordance with criteria which will be
`
`
`
`16
`
`
`CISCO Exhibit 1009
`Cisco v. Bockstar
`Trial IPR2014 - 18
`
`

`
`explained below in some detail.” Id. at 7:63-8:2. Further, the specification states:
`
`“The size of the routing tables created by the central controller 46 and downloaded
`
`to the intelligent line-cards 48 can be on the order of 100 kbytes, or more.” Id. at
`
`9:16-18. The ’895 Patent does not appear to provide any further details of what is
`
`used to store a routing table other than “a memory.” Thus, I believe the broadest
`
`reasonable interpretation of the corresponding structure to these limitations
`
`disclosed in the ’895 Patent’s specification is a “memory” or equivalents thereof
`
`for performing the recited function.
`
`(iv)
`
`“Processor Means” (of the “Packet Processing Element”)
`
`36.
`
`Independent Claims 1, 9, and 16 recite a “processor means” of the
`
`“packet processing element” for “using the copy of the routing table to route
`
`packets received by the packet processing element” (Claims 1 and 9) or “for using
`
`the copy of the routing table to route packets received by the processing element”
`
`(Claim 16). I understand that these limitations are presumed to be means-plus-
`
`function limitations governed by 35 U.S.C. § 112, ¶ 6 and that the construction of
`
`these terms depends on the corresponding structure identified in the specification
`
`of the ’895 Patent. I also understand that, because these are software means-plus-
`
`function limitations, the corresponding structure must also include an algorithm to
`
`perform the recited function. It is my opinion that the broadest reasonable
`
`interpretation of the corresponding structure to these limitations disclosed in the
`
`
`
`17
`
`
`CISCO Exhibit 1009
`Cisco v. Bockstar
`Trial IPR2014 - 19
`
`

`
`’895 Patent’s specification is a processor for performing the recited function by
`
`finding destination port information of the device routing a packet in a routing
`
`table and forwarding the packet using the destination port information or
`
`equivalents thereof.; I have not formed an opinion of whether the ’895 Patent has
`
`disclosed sufficient structure to comply with 35 U.S.C. § 112, ¶ 6.
`
`37. The ’895 Patent specification states: “The intelligent line-cards 48 are
`
`preferably integrated input/output (I-O) controllers having input ports 50 and
`
`output ports 52 . . . . The intelligent line-cards 48 also are equipped with
`
`processors and memory to permit them to execute programs relating to
`
`sophisticated routing functions.” CSCO-1001 at 7:4-6, 21-24. The ’895 Patent
`
`does not appear to provide any further details of what is used to route packets using
`
`the routing table other than “processors.” Regarding the algorithm for performing
`
`the recited function of using the routing table to route the packets, the ’895 Patent
`
`discloses: “The forwarding function is then invoked which finds the destination
`
`port-id based on the information in the routing table.” CSCO-1001 at 7:37-40.
`
`Thus, I believe the broadest reasonable interpretation of the corresponding
`
`structure to these limitations disclosed in the ’895 Patent’s specification is a
`
`processor for performing the recited function by finding destination port
`
`information of the device routing a packet in a routing table and forwarding the
`
`packet using the destination port information or equivalents thereof.
`
`
`
`18
`
`
`CISCO Exhibit 1009
`Cisco v. Bockstar
`Trial IPR2014 - 20
`
`

`
`VI. The Prior Art
`A. Prior Art Considered
`38.
`I have reviewed and considered the following documents:
`
`CSCO-1003
`
`“IP Switching and Gigabit Routers” by P. Newman, et al.
`(“Newman”)
`
`CSCO-1004 U.S. Patent No. 6,097,718 by Joel P. Bion (“Bion”)
`
`CSCO-1005
`
`“GIGAswitch System: A High-performance Packet-switching
`Platform” by Robert J. Souza, et al. (“Souza”)
`
`CSCO-1006 U.S. Patent No. 5,377,327 by Rajendra K. Jain, et al. (“Jain”)
`
`CSCO-1007 U.S. Patent No. 5,740,346 by Thomas M. Wicki, et al.
`(“Wicki”)
`
`CSCO-1008
`
`“Router Architecture Extensions for ATM: Overview” by
`Yasuhiro Katsube, et al. (“Katsube”)
`
`CSCO-1013 Moy, J., Networking Working Group RFC 1583, March 1994
`(“RFC 1583)
`
`CSCO-1014 Baker, Fred, Network Working Group RFC 1812, June 1995
`(“RFC 1812”)
`
`CSCO-1015
`
`Institute, University of Southern
`Information Sciences
`California, RFC 791, “Internet Protocol,” September 1981
`(“RFC 791”)
`
`
`B. The Background of Routing Architectures
`39. The ’895 Patent generally relates to an architecture for a route server
`
`(e.g., a router). According to the ’895 Patent, several well known routing protocols
`
`(including the Open Shortest Path First (OSPF) protocol) identify a route server
`
`
`
`19
`
`
`CISCO Exhibit 1009
`Cisco v. B

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