U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`The Accused Products perform a method of interfacing private and public data communications networks,
`through a filter node in communication with both networks.
`
`For example, to the extent the preamble is limiting, each of the Accused Products provides hotspot
`functionality which enables other devices to connect to the internet. The Accused Products act as a filter node
`which enables communication between the first and the second network, as shown by testing citation 11.1(1),
`where a set of packets from one or more devices in the first data communication network is sent to an external
`server through the Accused Product. The Accused Product(s) interfaces the first network with the internet
`using an IP address addressable through the internet, as also shown by citation 11.1(2).
`
`Public document citation 11.1(3) shows that a portable Wi-Fi Hotspot feature is present on all Accused
`Products. Exemplary screenshot citation 11.1(4) shows the hotspot feature provided on the Accused Products
`Nexus 5 and Nexus 7.
`
`
`
`No.
`11.1
`
`Claims
`A method of
`interfacing
`private and
`public data
`communicat
`ions
`networks,
`a
`through
`filter node
`in
`communicat
`ion
`with
`both
`networks,
`comprising
`the steps of:
`
`
`1 The Accused Products include Google’s Nexus 5 and Nexus 7, and any other product uncovered during discovery capable of interfacing first and second data
`communication networks.
`
`
`
`Google Ex. 1027, pg. 1
`
`
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`The Accused Products perform a method of interfacing private and public data communications networks,
`through a filter node in communication with both networks.
`
`For example, to the extent the preamble is limiting, each of the Accused Products provides hotspot
`functionality which enables other devices to connect to the internet. The Accused Products act as a filter node
`which enables communication between the first and the second network, as shown by testing citation 11.1(1),
`where a set of packets from one or more devices in the first data communication network is sent to an external
`server through the Accused Product. The Accused Product(s) interfaces the first network with the internet
`using an IP address addressable through the internet, as also shown by citation 11.1(2).
`
`Public document citation 11.1(3) shows that a portable Wi-Fi Hotspot feature is present on all Accused
`Products. Exemplary screenshot citation 11.1(4) shows the hotspot feature provided on the Accused Products
`Nexus 5 and Nexus 7.
`
`
`
`No.
`11.1
`
`Claims
`A method of
`interfacing
`private and
`public data
`communicat
`ions
`networks,
`a
`through
`filter node
`in
`communicat
`ion
`with
`both
`networks,
`comprising
`the steps of:
`
`
`1 The Accused Products include Google’s Nexus 5 and Nexus 7, and any other product uncovered during discovery capable of interfacing first and second data
`communication networks.
`
`
`
`Google Ex. 1027, pg. 1
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`Exemplary Product Testing Citation 11.1(1)2:
`
`
`
`
`First
`Network
`
`
`Exemplary Product Testing Citation 11.1(2):
`
`
`
`
`2 Rockstar tested the hotspot functionality of various Accused Products, including the Google Nexus 5 and Nexus 7 LTE devices, acting as the hotspot and
`exchange data with an Ekiga server through the internet. Rockstar used Wireshark to capture data packets transferred between laptops and mobile devices
`connected to the Accused Product(s) acting as the hotspot and Shark for Root software to capture data packets transferred between the Accused Product(s) acting
`as the hotspot and the external network.
`
`
`
`Google Ex. 1027, pg. 2
`
`
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`Second
`Network
`
`
`Exemplary Public Document Citation 11.1(3):
`
`
`Source: http://developer.android.com/about/versions/android-2.2-highlights.html
`
`Exemplary Screenshots Citation 11.1(4):
`
`
`
`
`Google Ex. 1027, pg. 3
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 4
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products receive from the private network, a data packet having a destination address
`corresponding to a node in the public network and a source address corresponding to a node in the private
`network.
`
`For example,
`The Accused Products receive packets from the first network comprising the source address of the first
`network and the destination address of the second network. For example, testing citation 11.2(1) shows an
`exemplary Wireshark capture when one or more source devices (e,g., IP address: 192.168.43.102 and IP
`address: 192.168.43.234) communicate with a destination address. Similarly, testing citation 11.2(2) shows a
`node in the second network (e.g., IP address: 86.64.162.35).
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`
`
`Exemplary Product Testing Citation 11.2(1):
`
`
`No.
`
`Claims
`
`11.2
`
`receiving at
`the
`filter
`node,
`from
`the private
`network, a
`data packet
`having
`a
`destination
`address
`correspondi
`ng to a node
`in the public
`network and
`a
`source
`address
`correspondi
`ng to a node
`in
`the
`private
`network;
`
`Google Ex. 1027, pg. 5
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Source IP
`addresses
`
`Destination IP
`addresses
`
`
`
`
`
`Exemplary Product Testing Citation 11.2(2):
`
`
`
`
`Google Ex. 1027, pg. 6
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Exemplary Open Source Citation 11.2(3):
`
`
`
`Google Ex. 1027, pg. 7
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`Source: http://source.android.com/devices/tech/security/
`
`
`
`
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`maintaining, The Accused Products maintain the source address taken from the data packet.
`
`11.3
`
`
`
`Google Ex. 1027, pg. 8
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`For example,
`The Accused Product(s) hotspot functionalty maintains the source address taken from the data packet.
`Citation 11.3(1) shows an exemplary Wireshark capture when a source device (e.g., IP address:
`192.168.43.102) communicates with a destination node when a source node communicates with nodes in an
`external network through the hotspot. Citation 11.3(2) shows an exemplary packet capture when the Hotspot
`device communicates with the destination and the packets received from the source device with IP address:
`192.168.43.102. Citation 11.3(3) shows shows an exemplary packet capture of packets received by The
`Accused Product(s) from the destintation node corresponding to the packets which have to be forwarded to
`the device with IP address (e.g., 192.168.43.102). Citation 11.3(4) shows an exemplary Wireshark capture of
`packets received by the device (Destination IP addresses – 192.168.43.102) in the first network from the
`destination node. Since the Accused Products transmit the response packets from the destination node back to
`the source device (by substituting destination address in the response packets), the hotspot device maintains
`the source address taken from the request data packet.
`
`
`
`Exemplary Product Testing Citation 11.3(1)
`
`No.
`
`Claims
`by the filter
`node,
`the
`source
`address
`taken
`from
`the
`data
`packet;
`
`Google Ex. 1027, pg. 9
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Exemplary Product Testing Citation 11.3(2)
`
`
`
`
`
`
`Google Ex. 1027, pg. 10
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Exemplary Product Testing Citation 11.3(3)
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 11
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Exemplary Product testing Citation 11.3(4)
`
`
`
`
`
`
`Google Ex. 1027, pg. 12
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`
`
`
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`
`
`
`Google Ex. 1027, pg. 13
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products replace, in the data packet, the source address with an address of the filter node,
`wherein the source address includes a port number of the node in the private network and the address of the
`filter node includes a port number of the filter node.
`
`For example:
`The Accused Product(s) hotspot functionality replaces the source address (including the port number) with the
`hotspot address of a packet. As shown by exemplary test citations 11.4(1) and 11.4(2), the source IP address
`192.168.43.102 and the source port 54321 are replaced with the hotspot’s IP address 30.104.45.215 and port
`1024.
`
`
`
`No.
`
`Claims
`
`replacing, in
`the
`data
`packet,
`the
`source
`address with
`an
`address
`of the filter
`node,
`wherein the
`source
`address
`a
`includes
`port number
`of the node
`in
`the
`private
`network and
`the address
`of the filter
`node
`a
`includes
`port number
`of the filter
`node;
`
`11.4
`
`
`
`Google Ex. 1027, pg. 14
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`Exemplary Product Testing Citation 11.4(1)
`
`
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 15
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`Exemplary Product Testing Citation 11.4(2)
`
`
`
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 16
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products route the data packet having the replaced source address, according to the destination
`address, to the corresponding public node network.
`
`For example:
`The Accused Product(s) hotspot functionality transmits the received packet from the first network to the
`second network. Exemplary citations 11.5(1) and 11.5(2) show a data packet transmitted to a node in the
`second network. The source address, including the IP address and the Port address have been replaced in the
`data packet sent to the node in the second network.
`
`Exemplary Product Testing Citation 11.5(1)
`
`
`No.
`
`Claims
`
`routing from
`the
`filter
`node, in the
`public
`network, the
`data packet
`having
`the
`replaced
`source
`address,
`according to
`the
`destination
`address,
`to
`the
`correspondi
`ng
`public
`node
`network;
`
`11.5
`
`
`
`Google Ex. 1027, pg. 17
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`
`Exemplary Product Testing Citation 11.5(2)
`
`
`
`
`
`Google Ex. 1027, pg. 18
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`
`
`
`
`
`Google Ex. 1027, pg. 19
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products wait for a return packet from the public network, responsive to the data packet having
`the replaced source information.
`
`For example:
`The Accused Product(s) hotspot functionality waits for packets from the second network in response to the
`data packets having the replaced source information. As shown in exemplary citation 11.6(1), the hotspot
`receives a data packet from a server in response to a request packet with the replaced source address (e.g., the
`replaced source address can be seen as the destination IP address 30.104.45.214 and the destination Port
`number, 1024).
`
`
`
`No.
`
`Claims
`
`11.6
`
`for
`waiting
`a
`return
`packet from
`the
`public
`network,
`responsive
`to the data
`packet
`having
`replaced
`source
`information;
`
`the
`
`
`
`Google Ex. 1027, pg. 20
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`Exemplary Product Testing Citation 11.6(1)
`
`
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 21
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`11.7
`
`replacing, in
`the
`return
`packet,
`the
`destination
`address with
`the
`maintained
`source
`address; and
`
`ACCUSED PRODUCTS1
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`The Accused Products replace the destination address with the maintained source address in the return packet.
`
`For example:
`The Accused Product(s) replaces the destination address of the returned packet with the maintained source
`address. Citation 11.7(1) shows an exemplary Wireshark capture in the second network, where a return packet
`is received from a node in the second network (source IP address: 86.64.162.35 and source port 5060) having
`the replaced address (destination IP address: 30.104.45.214 and destination port: 1024). Citation 11.7(2)
`shows an exemplary Wireshark capture in the first network. The destination address has been replaced with
`the maintained source address (IP address: 192.168.43.102, Port address: 54321) for the packets received by
`the devices in the first network. Thus, the hotspot replaced the destination addresses (IP address:
`30.104.45.214, Port address: 1024) with the maintained source addresses (IP address: 192.168.43.102, Port
`address: 54321).
`
`
`
`
`
`Google Ex. 1027, pg. 22
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`Exemplary Product Testing Citation 11.7(1)
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 23
`
`
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`Exemplary Product Testing Citation 11.7(2)
`
`
`
`
`
`
`
`Google Ex. 1027, pg. 24
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`11.8
`
`routing from
`the
`filter
`node, in the
`private
`network, the
`return
`packet
`having
`replaced
`destination
`address
`to
`the
`correspondi
`ng
`private
`network
`node.
`
`the
`
`ACCUSED PRODUCTS1
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`The Accused Products route the the return packet having the replaced destination address to the corresponding
`private network node.
`
`For example:
`The Accused Product(s) hotspot functionality transmits the incoming packet having the replaced destination
`address from the second network to the first network. Exemplary citation 11.8(1) shows a data packet in the
`second network which is addressed to the replaced source address (the replaced source address can be seen as
`the destination IP address: 30.104.45.214 and the destination Port number: 1024). Citation 11.8(2) shows an
`exemplary Wireshark capture in the first network. The destination address has been replaced with the
`maintained source address (IP address: 192.168.43.102, Port: 54321) for the packets received by the devices
`in the first network. The Accused Products replace the destination addresses (IP address: 30.104.45.214, Port
`address: 1024) with the maintained source addresses (IP address: 192.168.43.102, Port address: 54321). Thus,
`the packet is transmitted to the corresponding first network node.
`
`Exemplary Product Testing Citation 11.8(1)
`
`
`Google Ex. 1027, pg. 25
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`Exemplary Product Testing Citation 11.8(2)
`
`
`
`
`
`Google Ex. 1027, pg. 26
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`No.
`
`Claims
`
`ACCUSED PRODUCTS1
`
`
`
`
`
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`
`
`
`Google Ex. 1027, pg. 27
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`The Accused Products perform the method claimed in claim 12, wherein the data packets include packets in
`accordance with an internet control message protocol (ICMP).
`
`For example:
`The Accused Products provide hotspot functionality wherein each Accused Product is capable of transmitting,
`processing and receiving data packets in accordance with the Internet Control Message Protocol (ICMP). As
`shown by citation 13(1), at least some of the data packets received/transmitted by the Accused Products can
`be an ICMP message.
`
`Exemplary Product Testing Citation 13(1)
`
`
`
`
`
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products perform a method of operating a filter node for interfacing first and second data
`communications networks.
`
`See, for example and without limitation, chart section 11.1
`
`
`No.
`13.
`
`Claims
`A method as
`claimed
`in
`claim
`12,
`wherein the
`data packets
`include
`in
`packets
`accordance
`with
`an
`internet
`control
`message
`protocol
`(ICMP).
`
`A method of
`operating a
`filter node
`for
`interfacing
`
`14.1
`
`
`
`Google Ex. 1027, pg. 28
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`
`The Accused Products receive from the first network, an outgoing data packet having a destination address
`corresponding to a node in the second network and a source address corresponding to a node in the first
`network.
`
`See, for example and without limitation, chart section 11.2
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`Claims
`and
`first
`second data
`communicat
`ions
`networks,
`comprising
`the steps of:
`receiving
`from
`the
`first
`network, an
`outgoing
`data packet
`having
`destination
`information,
`which
`includes
`destination
`address and
`a destination
`port,
`correspondi
`ng to a node
`in
`the
`second
`network and
`having
`source
`information,
`
`a
`
`No.
`
`14.2
`
`
`
`Google Ex. 1027, pg. 29
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`a
`
`Claims
`which
`includes
`source
`address and
`a
`source
`port,
`correspondi
`ng to a node
`in the first
`network;
`maintaining
`the
`source
`information
`taken
`from
`the outgoing
`data packet
`in
`correlation
`with
`unique
`value
`representing
`a port of the
`filter node;
`replacing in
`the outgoing
`data packet
`the
`source
`address with
`an
`address
`
`a
`
`ACCUSED PRODUCTS1
`
`The Accused Products maintain the source address taken from the outgoing data packet in correlation with a
`unique value representing a port of the Accused Products.
`
`See, for example and without limitation, chart section 11.3
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products replace, in the outgoing data packet, the source address with an address of the filter
`node, wherein the source address includes a port number of the node in the private network and the address of
`the filter node includes a port number of the filter node.
`
`See, for example and without limitation, chart section 11.4
`
`
`No.
`
`14.3
`
`14.4
`
`
`
`Google Ex. 1027, pg. 30
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products send an outgoing data packet having the replaced source address to the second
`network.
`
`See, for example and without limitation, chart section 11.5
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products perform the method claimed in claim 14 wherein the method further comprises the
`steps claimed in claims 15.2-15.5.
`
`Claims
`of the filter
`node
`and
`the
`source
`port
`with
`the
`filter
`node
`port
`value; and
`sending
`to
`the
`second
`network the
`outgoing
`data packet
`having
`the
`replaced
`source
`information,
`whereby the
`packet
`is
`routed
`according to
`its
`destination
`information
`to
`the
`correspondi
`ng
`second
`network
`node.
`A method as
`claimed
`in
`
`No.
`
`14.5
`
`15.1
`
`
`
`Google Ex. 1027, pg. 31
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products receive an incoming packet from the second network, responsive to the data packet
`having the replaced source information.
`
`See, for example and without limitation, chart section 11.6
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products correlate the destination port of the destination information in the incoming data packet
`to particular source information being maintained.
`
`See, for example and without limitation, chart sections 11.3, 11.4 comprising product testing citations
`11.3(1)-11.3(4).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`14,
`
`Claims
`claim
`further
`comprising
`the steps of:
`receiving
`from
`the
`second
`network, an
`incoming
`data packet
`having
`the
`address
`of
`the
`filter
`node as the
`destination
`address;
`correlating
`the
`destination
`port of the
`destination
`information
`in
`the
`incoming
`data packet
`to particular
`source
`information
`being
`maintained;
`
`No.
`
`15.2
`
`15.3
`
`
`
`Google Ex. 1027, pg. 32
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`The Accused Products replace the destination address with the maintained source address in the incoming
`packet.
`
`See, for example and without limitation, chart section 11.7
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products send the incoming packet having the replaced destination address to the first network.
`
`See, for example and without limitation, chart section 11.8
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`
`Claims
`replacing, in
`the
`incoming
`data packet,
`the
`destination
`information
`with
`the
`particular
`source
`information;
`sending
`to
`the
`first
`network the
`incoming
`data packet
`having
`the
`replaced
`destination
`information,
`whereby
`that packet
`is
`routed
`according to
`its
`destination
`information
`to
`the
`correspondi
`ng
`first
`
`No.
`15.4
`
`15.5
`
`
`
`Google Ex. 1027, pg. 33
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`if
`
`the
`
`Claims
`network
`node.
`A method as
`claimed
`in
`claim
`15,
`comprising
`ignoring the
`incoming
`data packet
`received
`from
`second
`network,
`the
`destination
`port of the
`destination
`information
`in that data
`packet can
`not
`be
`correlated to
`the
`maintained
`source
`information.
`A method as
`claimed
`in
`claim
`16,
`wherein
`
`ACCUSED PRODUCTS1
`
`Upon information and belief, the Accused Google products perform the method as claimed in claim 15,
`comprising ignoring the incoming data packet received from the second network, if the destination port of the
`destination information in that data packet can not be correlated to the maintained source information.
`Rockstar will supplement these contentions once Google produces the source code for the Accused Products.
`
`The Accused Products perform the method of claim 16, wherein the Accused Products maintain the source
`information from the outgoing data packet as an entry in a lookup table and use the filter node port value
`correlating to the source information as an index into the lookup table.
`
`
`No.
`
`16.
`
`17.
`
`
`
`Google Ex. 1027, pg. 34
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`See, for example and without limitation, chart sections 11.3, 11.4 comprising product testing citations
`11.3(1)-11.3(4).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products perform the method claimed in claim 17, wherein the incoming and outgoing data
`packets include packets in accordance with a transmission control protocol (TCP) over an internet protocol
`(IP).
`
`
`
`the
`
`Claims
`maintaining
`the
`source
`information
`includes
`storing
`source
`information
`from
`the
`outgoing
`data packet
`as an entry
`in a lookup
`table,
`and
`the
`filter
`node
`port
`value
`correlating
`to
`the
`source
`information
`constitutes
`an
`index
`into
`the
`table
`for
`that entry.
`A method as
`claimed
`in
`claim
`17,
`wherein the
`incoming
`
`No.
`
`18.
`
`
`
`Google Ex. 1027, pg. 35
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`For example, as shown in exemplary product testing citation 18(1), at least some of the outgoing and
`incoming data packets can be in accordance with a Transmission Control Protocol (TCP) over internet
`protocol (IP).
`
`Exemplary Product Testing Citation 18(1):
`
`
`The Accused Products operate in accordance with the architecture shown in open source citation 11.2(3).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`The Accused Products perform a method of operating a filter node for interfacing first and second data
`communications networks.
`
`No.
`
`Claims
`and
`outgoing
`data packets
`include
`in
`packets
`accordance
`with
`a
`transmission
`control
`protocol
`(TCP) over
`an
`internet
`protocol
`(IP).
`
`19.1
`
`A method of
`operating a
`
`
`
`Google Ex. 1027, pg. 36
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`See, for example and without limitation, chart section 11.1
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products receive from the first network, an outgoing data packet having a destination address
`corresponding to a node in the second network and a source address corresponding to a node in the first
`network.
`
`See, for example and without limitation, chart section 11.2
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`Claims
`filter node
`for
`interfacing
`first
`and
`second data
`communicat
`ions
`networks
`comprising
`the steps of:
`receiving
`from
`the
`first
`network, an
`outgoing
`data packet
`having
`destination
`information,
`which
`includes
`destination
`address and
`a destination
`port,
`correspondi
`ng to a node
`in
`the
`second
`network and
`
`a
`
`No.
`
`19.2
`
`
`
`Google Ex. 1027, pg. 37
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`a
`
`Claims
`having
`source
`information,
`which
`includes
`source
`address and
`a
`source
`port,
`correspondi
`ng to a node
`in the first
`network;
`maintaining
`the
`source
`information
`taken
`from
`the outgoing
`data packet
`in
`correlation
`with
`unique
`value
`representing
`a port of the
`filter node;
`replacing in
`the outgoing
`data packet
`
`a
`
`ACCUSED PRODUCTS1
`
`The Accused Products maintain the source address taken from the data packet.
`
`See, for example and without limitation, chart section 11.3
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products replace, in the outgoing data packet, the source address with an address of the filter
`node, wherein the source address includes a port number of the node in the private network and the address of
`the filter node includes a port number of the filter node.
`
`No.
`
`19.3
`
`19.4
`
`
`
`Google Ex. 1027, pg. 38
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`See, for example and without limitation, chart section 11.4
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`No.
`
`Claims
`the
`source
`address with
`an
`address
`of the filter
`node
`and
`the
`source
`port
`with
`the
`filter
`node
`port
`value;
`
`Google Ex. 1027, pg. 39
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`The Accused Products send an outgoing data packet having the replaced source address to the second
`network.
`
`See, for example and without limitation, chart section 11.5
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`No.
`19.5
`
`Claims
`to
`sending
`the
`second
`network the
`outgoing
`data packet
`having
`the
`replaced
`source
`information,
`whereby
`that packet
`is
`routed
`according to
`its
`destination
`information
`to
`the
`correspondi
`ng
`second
`network
`node,
`
`19.6
`
`receiving
`from
`the
`
`The Accused Products receive an incoming data packet having the address of the filter node as the destination
`address.
`
`
`
`Google Ex. 1027, pg. 40
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`
`See, for example and without limitation, chart section 11.6
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products correlate the destination port of the destination information in the incoming data packet
`to particular source information being maintained.
`
`See, for example and without limitation, chart sections 11.3, 11.4 comprising product testing citations
`11.3(1)-11.3(4).
`
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products replace the destination address with the maintained source address in the incoming
`packet.
`
`See, for example and without limitation, chart section 11.7
`
`
`Claims
`second
`network, an
`incoming
`data packet
`having
`the
`address
`of
`the
`filter
`node as the
`destination
`address;
`correlating
`the
`destination
`port of the
`destination
`information
`in
`the
`incoming
`data packet
`to particular
`source
`information
`being
`maintained;
`replacing, in
`the
`incoming
`data packet,
`the
`
`No.
`
`19.7
`
`19.8
`
`
`
`Google Ex. 1027, pg. 41
`
`
`
`U.S. Patent No. 6,128,298
`McKool Smith, PC
`
`ACCUSED PRODUCTS1
`Rockstar reserves the right to add additional information and infringement theories once discovery begins in
`this case, particularly once the defendant produces its source code and technical documents.
`
`
`The Accused Products send the incoming packet having the replaced destination address to the first network.
`
`See, for example and without limitation, char
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