UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`C-CATION TECHNOLOGIES, LLC,
`
`
`
`
`
` Plaintiff
`
`
`v.
`
`,
`
`
`
`
`
`Case No. 2:14-cv-59
`
`DEMAND FOR JULY TRIAL
`
`
`
`
`TIME WARNER CABLE INC.,
`TIME WARNER CABLE ENTERPRISES
`LLC, TIME WARNER CABLE TEXAS LLC,
`ARRIS GROUP, INC., CISCO
`SYSTEMS, INC., and CASA SYSTEMS,
`INC.
`
`
`
`
`
` Defendants.
`
`COMPLAINT
`
`
`
`
`
`Plaintiff C-Cation Technologies, LLC (“plaintiff”), through its attorneys, for its
`
`complaint against defendants Time Warner Cable Inc., Time Warner Cable Enterprises LLC,
`
`Time Warner Cable Texas LLC, Arris Group, Inc., Cisco Systems, Inc., and Casa Systems, Inc.
`
`(collectively “defendants”), alleges as follows:
`
`THE PARTIES
`
`1.
`
`Plaintiff is a limited liability company organized and existing under the laws of
`
`the State of Texas with a principal place of business at 150 Purchase Street, Suite 9, Rye, New
`
`York.
`
`2.
`
`On information and belief, defendant Time Warner Cable Inc. (“TWC Inc.”) is
`
`a corporation organized and existing under the laws of the State of Delaware with a principal
`
`place of business at 60 Columbus Circle, New York, New York 10023.
`
`
`
`1
`
`

`
`
`
`3.
`
`On information and belief, defendant Time Warner Cable Enterprises LLC
`
`(“TWC Enterprises”) is a subsidiary of TWC Inc. and is a limited liability company organized
`
`and existing under the laws of the State of Delaware with a principal place of business at 60
`
`Columbus Circle, New York, New York 10023.
`
`4.
`
`On information and belief, defendant Time Warner Cable Texas LLC (“TWC
`
`Texas”) is a subsidiary of TWC Enterprises and is a limited liability company organized and
`
`existing under the laws of the State of Delaware with a principal place of business at 60
`
`Columbus Circle, New York, New York 10023.
`
`5.
`
`On information and belief, defendant Arris Group, Inc. (“Arris”) is a corporation
`
`organized and existing under the laws of the State of Delaware with a principal place of business
`
`at 3871 Lakefield Drive, Suwanee, Georgia.
`
`6.
`
`On information and belief, defendant Cisco Systems, Inc. (“Cisco”) is a
`
`corporation organized and existing under the laws of the State of California with a principal
`
`place of business at 170 West Tasman Drive, San Jose, California.
`
`7.
`
`On information and belief, defendant Casa Systems, Inc. (“Casa Systems”) is a
`
`corporation organized and existing under the laws of the State of Massachusetts with a principal
`
`place of business at 100 Old River Road, Suite 100, Andover, MA 01810.
`
`JURISDICTION AND VENUE
`
`8.
`
`This action arises under the patent laws of the United States, Title 35 of the
`
`United States Code.
`
`9.
`
`Subject matter jurisdiction is proper in this Court pursuant to 28 U.S.C. §§ 1331
`
`and 1338(a).
`
`
`
`2
`
`

`
`
`
`10.
`
`This Court has personal jurisdiction over defendants. On information and belief,
`
`defendants either directly or indirectly through one or more of their subsidiaries, affiliates,
`
`partners, or other related parties, have conducted and/or continue to conduct business within the
`
`State of Texas, including the Eastern District of Texas. On information and belief, defendants
`
`have and/or do now, directly or through intermediaries (including distributors, retailers, and
`
`others) ship, distribute, offer for sale, sell, advertise, operate, use and/or direct the operation and
`
`use of their respective cable systems, cable system components, and/or cable services in the
`
`United States, the State of Texas, and the Eastern District of Texas.
`
`11.
`
`On information and belief, venue in this judicial district is proper under 28 U.S.C.
`
`§§ 1391 and 1400(b).
`
`COUNT ONE – INFRINGEMENT OF U.S. PATENT 5,563,883
` BY TWC, INC., TWC ENTERPRISES AND TWC TEXAS
`
`Plaintiff incorporates by reference Paragraphs 1 through 11 in their entirety as if
`
`12.
`
`fully set forth herein.
`
`13.
`
`On October 8, 1996, United States Letters Patent No. 5,563,883 (“the ’883
`
`patent,” attached as Exhibit A), entitled “Dynamic Channel Management and Signalling Method
`
`and Apparatus,” was duly and legally issued. Plaintiff is the owner of all rights, title, and interest
`
`in and to the ’883 patent.
`
`14.
`
`15.
`
`The ’883 patent is valid and enforceable.
`
`On information and belief, TWC Inc., TWC Enterprises, and TWC Texas
`
`(collectively “TWC”) have been and are now infringing the ’883 patent by making, using,
`
`testing, implementing, and/or operating cable systems that fall within and whose use falls within
`
`the scope of at least one claim of the ’883 patent, and/or by offering for sale, selling, advertising
`
`and/or marketing cable services (telephone, internet and/or television services) provided through
`
`
`
`3
`
`

`
`
`
`such cable systems. The accused cable systems include cable system components such as cable
`
`modem termination systems, RF and optical transmission hardware, network monitoring
`
`equipment, and customer premises equipment (e.g., cable modems, embedded multimedia
`
`terminal adapters, and set-top boxes), including but not limited to components that are compliant
`
`with the Data Over Cable System Interface Specification (“DOCSIS”) standard (e.g., versions
`
`1.1, 2.0 and 3.0). In particular, TWC, without authority from plaintiff, provides, operates,
`
`implements, and/or markets cable systems and/or cable services that perform, are capable of
`
`performing, or are provided using channel management functions, including but not limited to
`
`static load balancing, dynamic load balancing, passive load balancing, and/or channel assignment
`
`and reassignment (“accused functions”). TWC’s cable systems that perform or are capable of
`
`performing the accused functions, and/or the use of such cable systems, infringe one or more
`
`claims of the ’883 patent.
`
`16.
`
`On information and belief, the cable system components that perform or are
`
`capable of performing the accused functions in TWC’s accused cable systems are directly or
`
`indirectly purchased from, and/or otherwise supplied by, Arris, Cisco, and/or Casa Systems.
`
`
`
`17.
`
`On information and belief, TWC has had knowledge of the ’883 patent at least as
`
`early as November 1998, through a letter directed to Dick Aurelio, Senior Advisor, that
`
`identified the ’883 patent. On November 16, 1998, TWC’s Chief Technical Officer, James A.
`
`Chiddix, acknowledged receipt of that letter.
`
`18.
`
`On information and belief, TWC is willfully infringing the ’883 patent. TWC has
`
`acted knowingly or with reckless disregard despite an objectively high likelihood that its actions
`
`constitute infringement of plaintiff’s patent rights. TWC knew of or should have known of this
`
`objectively high risk.
`
`
`
`4
`
`

`
`
`
`19.
`
`As a result of TWC’s acts of infringement, plaintiff has suffered and will continue
`
`to suffer damages in an amount to be proven at trial.
`
`COUNT TWO – INFRINGEMENT OF U.S. PATENT 5,563,883 BY ARRIS
`
`20.
`
`Plaintiff incorporates by reference Paragraphs 1 through 19 in their entirety as if
`
`fully set forth herein.
`
`
`
`21.
`
`On information and belief, Arris has been and is now infringing the ’883 patent
`
`by making, using, testing, implementing, selling, and/or offering to sell cable systems and/or
`
`components thereof that fall within and whose use falls within the scope of at least one claim of
`
`the ’883 patent. Any Arris cable systems and/or components that perform or are capable of
`
`performing the accused functions (and/or the use of such cable systems and/or components
`
`thereof), and that are not licensed by plaintiff, infringe one or more claims of the ’883 patent.
`
`22.
`
`On information and belief, Arris has been and is now inducing the infringement of
`
`the ’883 patent by making, offering for sale, selling, advertising and/or marketing to cable
`
`providers such as TWC, who are not licensed by plaintiff, cable system components for use in
`
`cable systems that infringe and whose use infringes at least one claim of the ’883 patent. These
`
`cable system components include, but are not limited to, cable modem termination systems and
`
`customer premises equipment that perform, or are capable of performing, the accused functions.
`
`These components include but are not limited to cable system components that are compliant
`
`with the DOCSIS standard (e.g., versions 1.1, 2.0 and 3.0).
`
`
`
`23.
`
`On information and belief, Arris encourages and instructs its customers, including
`
`cable providers such as TWC, who are not licensed by plaintiff, to infringe with knowledge that
`
`the induced acts constitute patent infringement. Arris has been and is now intentionally
`
`instructing and/or directing cable providers, who are not licensed by plaintiff, to purchase, use
`
`
`
`5
`
`

`
`
`
`and/or implement in their respective cable systems, Arris cable systems and/or cable system
`
`components that perform or are capable of performing the accused functions. Arris possesses
`
`specific intent to encourage infringement by its customers.
`
`24.
`
`On information and belief, Arris has been and is now contributing to the
`
`infringement of the ’883 patent by making, offering for sale and selling to cable providers such
`
`as TWC, who are not licensed by plaintiff, cable system components that perform or are capable
`
`of performing the accused functions, with knowledge that these cable systems components are
`
`especially adapted for use in a system covered by the ’883 patent and/or provided for use in
`
`practicing a method covered by the ’883 patent. On information and belief, there are no
`
`substantial non-infringing uses for the accused functions in Arris’s cable system components,
`
`including but not limited to Arris’s cable modem termination systems.
`
`25.
`
`On information and belief, Arris has had knowledge of the ’883 patent as early as
`
`May of 2003, when Angelo Guglielmo notified Mr. Peter Sheedy, Sr. Product Manager of
`
`Motorola (acquired by Arris in April 2013), about the ’883 patent, and no later than April 17,
`
`2013, when it was served with a subpoena in connection with a lawsuit encaptioned C-Cation
`
`Technologies, LLC. v. Comcast Corporation, et al, case no. 2:11-CV-30 (E.D. Tex), which
`
`concerned allegations of infringement of the ’883 patent.
`
`26. Arris knowingly and with reckless disregard has willfully infringed and continues
`
`willfully to infringe the ’883 patent. Arris has acted despite an objectively high likelihood that
`
`its actions constitute infringement of plaintiff’s patent rights. Arris knew of or should have
`
`known of this objectively high risk.
`
`27.
`
`As a result of Arris’s acts of infringement, plaintiff has suffered and will continue
`
`to suffer damages in an amount to be proved at trial.
`
`
`
`6
`
`

`
`
`
`COUNT THREE – INFRINGEMENT OF U.S. PATENT 5,563,883 BY CISCO
`
`28.
`
`Plaintiff incorporates by reference Paragraphs 1 through 27 in their entirety as if
`
`fully set forth herein.
`
`
`
`29.
`
`On information and belief, Cisco has been and is now infringing the ’883 patent
`
`by making, using, testing, implementing, selling, and/or offering to sell cable systems and/or
`
`components thereof that fall within and whose use falls within the scope of at least one claim of
`
`the ’883 patent. Any Cisco cable systems and/or components that perform or are capable of
`
`performing the accused functions (and/or the use of such cable systems and/or components
`
`thereof), and that are not licensed by plaintiff, infringe one or more claims of the ’883 patent.
`
`
`
`30.
`
`On information and belief, Cisco has been and is now inducing the infringement
`
`of the ’883 patent by making, offering for sale, selling, advertising and/or marketing to cable
`
`providers such as TWC, who are not licensed by plaintiff, cable system components for use in
`
`cable systems that infringe and whose use infringes at least one claim of the ’883 patent. These
`
`cable system components include, but are not limited to, cable modem termination systems and
`
`customer premises equipment that perform, or are capable of performing, the accused functions.
`
`These components include but are not limited to cable system components that are compliant
`
`with the DOCSIS standard (e.g., versions 1.1, 2.0 and 3.0).
`
`
`
`31.
`
`On information and belief, Cisco encourages and instructs its customers,
`
`including cable providers such as TWC, who are not licensed by plaintiff, to infringe with
`
`knowledge that the induced acts constitute patent infringement. Cisco has been and is now
`
`intentionally instructing and/or directing cable providers, who are not licensed by plaintiff, to
`
`purchase, use and/or implement in their respective cable systems, Cisco cable systems and/or
`
`
`
`7
`
`

`
`
`
`cable system components that perform or are capable of performing the accused functions.
`
`Cisco possesses specific intent to encourage infringement by its customers.
`
`32.
`
`On information and belief, Cisco has been and is now contributing to the
`
`infringement of the ’883 patent by making, offering for sale and selling to cable providers such
`
`as TWC, who are not licensed by plaintiff, cable system components that perform or are capable
`
`of performing the accused functions, with knowledge that these cable systems components are
`
`especially adapted for use in a system covered by the ’883 patent and/or provided for use in
`
`practicing a method covered by the ’883 patent. On information and belief, there are no
`
`substantial non-infringing uses for the accused functions in Cisco’s cable system components,
`
`including but not limited to Cisco’s cable modem termination systems.
`
`33.
`
`On information and belief, Cisco has had knowledge of the ’883 patent at least as
`
`early as February 1999, when Alexander Cheng notified William Bailey, Cisco’s Manager of
`
`New Markets and Technology, about the patent, and no later than April 17, 2013, when Cisco
`
`was served with a subpoena in connection with a lawsuit encaptioned C-Cation Technologies,
`
`LLC. v. Comcast Corporation, et al, case no. 2:11-CV-30 (E.D. Tex), which concerned
`
`allegations of infringement of the ’883 patent.
`
`34. Cisco knowingly and with reckless disregard has willfully infringed and continues
`
`to willfully infringe the ’883 patent. Cisco has acted despite an objectively high likelihood that
`
`its actions constitute infringement of plaintiff’s patent rights. Cisco knew of or should have
`
`known of this objectively high risk.
`
`35.
`
`As a result of Cisco’s acts of infringement, plaintiff has suffered and will continue
`
`to suffer damages in an amount to be proved at trial.
`
`
`
`
`
`8
`
`

`
`
`
`COUNT FOUR – INFRINGEMENT OF U.S. PATENT 5,563,883 BY CASA SYSTEMS
`
`36.
`
`Plaintiff incorporates by reference Paragraphs 1 through 35 in their entirety as if
`
`fully set forth herein.
`
`
`
`37.
`
`On information and belief, Casa Systems has been and is now infringing the ’883
`
`patent by making, using, testing, and/or implementing cable systems and/or components thereof
`
`that fall within and whose use falls within the scope of at least one claim of the ’883 patent. Any
`
`Casa Systems cable systems and/or components that perform or are capable of performing the
`
`accused functions (and/or the use of such cable systems and/or components thereof), and that are
`
`not licensed by plaintiff, infringe one or more claims of the ’883 patent.
`
`38.
`
`On information and belief, Casa Systems has been and is now inducing the
`
`infringement of the ’883 patent by making, offering for sale, selling, advertising and/or
`
`marketing to cable providers such as TWC, who are not licensed by plaintiff, cable system
`
`components for use in cable systems that infringe and whose use infringes at least one claim of
`
`the ’883 patent. These cable system components include, but are not limited to, cable modem
`
`termination systems that perform, or are capable of performing, the accused functions. These
`
`components include but are not limited to cable system components that are compliant with the
`
`DOCSIS standard (e.g., versions 1.1, 2.0 and 3.0).
`
`
`
`39.
`
`On information and belief, Casa Systems encourages and instructs its customers,
`
`including cable providers such as TWC, who are not licensed by plaintiff, to infringe with
`
`knowledge that the induced acts constitute patent infringement. Casa Systems has been and is
`
`now intentionally instructing and/or directing cable providers, who are not licensed by plaintiff,
`
`to purchase, use and/or implement in their respective cable systems, Casa Systems cable system
`
`
`
`9
`
`

`
`
`
`components that perform or are capable of performing the accused functions. Casa Systems
`
`possesses specific intent to encourage infringement by its customers.
`
`40.
`
`On information and belief, Casa Systems has been and is now contributing to the
`
`infringement of the ’883 patent by making, offering for sale and selling to cable providers such
`
`as TWC, who are not licensed by plaintiff, cable systems or cable system components that
`
`perform or are capable of performing the accused functions, with knowledge that these cable
`
`systems components are especially adapted for use in a system covered by the ’883 patent and/or
`
`provided for use in practicing a method covered by the ’883 patent. On information and belief,
`
`there are no substantial non-infringing uses for the accused functions in Casa Systems’ cable
`
`system components, including but not limited to Casa Systems’ cable modem termination
`
`systems.
`
`41.
`
`On information and belief, Casa Systems has had knowledge of the ’883 patent at
`
`least as early as the filing of this Complaint.
`
`42.
`
`To the extent Casa Systems did not, or does not, cease its infringing activities as
`
`of the time it learned of the ’883 patent, its infringement is and continues and to be willful and
`
`deliberate. Casa Systems has acted despite an objectively high likelihood that its actions
`
`constitute infringement of plaintiff’s valid patent rights. Casa Systems knew of or should have
`
`known of this objectively high risk.
`
`43.
`
`As a result of Casa Systems’ acts of infringement, plaintiff has suffered and will
`
`continue to suffer damages in an amount to be proved at trial.
`
`
`
`10
`
`
`
`

`
`
`
`PRAYER FOR RELIEF
`
`WHEREFORE, plaintiff prays for the following relief:
`
`A.
`
`A judgment in favor of plaintiff that defendants have infringed, directly and/or
`
`indirectly by way of inducement or contributory infringement, at least one claim of the ’883
`
`patent;
`
`B.
`
`An award to plaintiff of damage pursuant to at least 35 U.S.C. § 284 for
`
`defendants’ past infringement and any continuing or future infringement, including both
`
`compensatory damages and treble damages for defendants’ willful infringement;
`
`C.
`
`A judgment and order requiring defendants to pay the costs of this action
`
`(including all disbursements), as well as attorneys’ fees as provided by 35 U.S.C. § 285;
`
`D.
`
`An award to plaintiff of pre-judgment and post-judgment interest on its damages;
`
`and
`
`E.
`
`Such other further relief in law or equity to which plaintiff may be justly entitled.
`
`
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, plaintiff hereby demands a
`
`trial by jury as to all issues so triable.
`
`
`
`11
`
`

`
`
`
`Dated: February 4, 2014
`
`
`
`
`
`
`
`
`Of Counsel:
`
`
`
`
`
`
`
`Lewis V. Popovski
`
`
`Jeffrey S. Ginsberg
`
`
`Sheila Mortazavi
`KENYON & KENYON LLP
`One Broadway
`
`
`New York, NY 10004-1007
`
`Tel.: (212) 425-7200
`
`Fax: (212) 425-5288
`lpopovski@kenyon.com
`jginsberg@kenyon.com
`smortazavi@kenyon.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`__/s/ Sam Baxter______________________
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`104 East Houston, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`
`
`
`
`
`
`
`
`
` Attorneys for C-Cation Technologies, LLC
`
`
`
`
`
`
`12
`
`

`
`EXHIBIT A
`
`EXHIBIT A
`
`
`
`

`
`United States Patent
`
`[19]
`
`[11] Patent Number:
`
`5,563,883
`
`Cheng
`
`[45] Date of Patent:
`
`Oct. 8, 1996
`
`USOO5563883A
`
`[54] DYNAMIC CHANNEL MANAGEMENT AND
`SIGNALLING NIETHOD AND APPARATUS
`
`[76]
`
`Inventor: Alexander L. Cheng, 11 Sprindale
`Avc., White Plains, N.Y. 10604
`
`[21] Appl. No.: 276,534
`
`[22]
`
`Filed:
`
`Jul. 18, 1994
`
`Int. Cl.5 ....................................................... H04H 1/04
`[51]
`[52] U.S. Cl.
`............................. 370/73; 348/12; 370/857;
`370/85.8; 455/4.2; 455/5.1
`[58] Field of Search ............................. .. 348/6, 9, 12, 13;
`455/3.1, 4.2, 5.1, 6.1, 34.1; 379/71, 73,
`76, 80, 85.3, 85.7, 85.8, 95.1, 95.2
`
`[56]
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`4,573,206
`5,132,680
`5,224,097
`5,331,316
`5,355,375
`5,374,952
`5,434,611
`
`.......................... 455/34.1
`2/1986 Grauel et al.
`.. 370/85.8
`7/1992 Tezuka et al.
`370/85.8
`6/1993 Kaneshima
`370/85.7
`7/1994 Mcstdagh
`10/1994 Christensen ............................ 370/85.8
`12/1994 Flohr ....................................... .. 348/12
`7/1995 Tamura ................................... .. 348/12
`
`
`
`Primary Examiner——Benedict V. Safourek
`
`[57]
`
`ABSTRACT
`
`services on a multiple access communication system, which
`comprises a central controller, a shared transmission media
`and a plurality of remote terminals dispersed throughout the
`network. The central controller comprises switch and con-
`trol apparatus and a pool of transmitters and receivers. The
`communication channels between the central controller and
`remote terminals are arranged for signalling data and trafiic
`bearer channels in the forward and reverse directions. The
`
`number of signalling data channels is adjusted to satisfy the
`trafiic requirements and for redundancy purposes. The for-
`ward and reverse signalling data channels are coupled in
`different mappings to support terminal grouping. Multiple
`access of the remote terminals for the upstream traflic are
`mitigated by separating remote terminals in groups via the
`channel allocation and the terminal assignment process.
`Communication between the central controller and the
`remote terminals follows a multiple access scheme con-
`trolled by the central controller via polling procedure on
`each of the forward signalling data channels independently.
`In case of collision, the central controller engages the remote
`terminals in a selective polling process to resolve the con-
`tention. The overlapping polling method of the controlled
`access scheme increases the utilization of the signalling
`channel and reduces the time required to gain access to the
`shared transmission media. By dynamically adjusting the
`load on signalling data charuiels, the signalling process is
`greatly improved for efficiency and redundancy against
`anomalies with the added benefit of improved flexibility and
`extensibility. The system is especially useful in a two—way
`CATV network.
`
`There is provided a dynamic and adaptable method and
`apparatus to support two-way multi-media communication
`
`20 Claims, 16 Drawing Sheets
`
`controller
`initialization
`
`
`
`lists
`
`required
`
`
`
`terminal
`response
`on RD-x‘
`
` contention
`
`
`selective
`
`poll
`
`resolution
`
`
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 1 of 16
`
`5,563,883
`
`terminals
`remote
`
`H G
`
`.)
`v-—(
`v----(
`
`03
`
`-4
`4-3
`
`fi
`
`O O
`
`v-—l
`
`C6
`3-4
`«I-3
`
`E (
`
`D 0
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 2 of 16
`
`I
`
`5,563,883
`
`RD
`FD
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`
`I ——l
`
`j '‘'''''m
`Figure
`
`3a
`
`R
`
`FD
`n
`
`RD
`0
`
`P
`
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`
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`
`3b
`
`RD
`u
`
`FD
`r
`
`s
`
`t
`Figure
`
`.
`
`3c
`
`controller
`
`initialization
`
`
`
`
`llStS
`
`tx.
`
`polling
`cycle
`
`required
`
`YES
`
`terminal
`response
`on RD—x'
`
`@ YB
`
`YES
`
`N0
`
`contention
`
`
`
`terminal
`request
`
`selective
`PO11
`
`Figure
`
`4
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 3 of 16
`
`5,563,883
`
`
`
`terminal
`
`response
`
`YES
`
`successful '
`
`transmission
`
` Count
`exceeded
`
`
`
`
`
`terminal
`
`failure
`
`
`
`
`processing
`
`
`
`polling
`
`cycle
`
`Figure
`
`5
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 4 of 16 '
`
`5,563,883
`
`terminal
`
`request
`
` registration
`
`message
`
`signalling
`processing
`
`
`
`
`
`newly
`registering
`terminal
`
`authorized
`
`M)
`
`terminal
`
`disable
`
`NO reassign
`
`men‘
`
`Polling
`
`cycle
`
`
`
`available
`
`capacity
`on other
`
`
`
`terminal
`
`assignment
`
`Figure
`
`6
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet5 of 16
`
`_ 5,563,883
`
`
`
`YES
`
`registration
`frame on RD-x
`
`
`
`toggle x
`between 1/2
`
`_ YES
`
`YES
`
`
`
`
`
`
`
`exceeded
`
`toggle x’
`between 1 2
`
`
`
`
`terminal
`.
`chsable
`
`
`
`channel
`.
`ass1gnment
`,
`set x and x
`
`
`
`0P€I‘ati0
`
`Figure 7
`
`retry
`
`count
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 6 of 16
`
`5,563,883
`
` operation
`
`controller
`
`poll or
`command
`
`tx.
`
`required
`
` controller
`
`
`
`response
`
`collision or
`
`error retry
`
` successful
`
`
`
`transmission
`
`terminal
`
`confirmation
`
` Figure 8
`
`

`
`U.S.
`
`Patent
`
`Oct. 8, 1996
`
`Sheet 7 of 16
`
`5,563,883
`
`Signalling data frame in the forward
`direction sent by central controller:
`1
`1
`3
`I
`
`Signalling data frame in the reverse
`direction sent by remote terminals:
`1
`1
`3
`1
`BE!
`
`bytes
`
`pre
`
`amble (PMB)
`sequence to indicate the start of message frame transmission and aid detection of
`collision
`
`Sig
`
`Terminal IDentifier (TID)
`terminal identifier for command
`lower TID of the range for the selective poll
`0 (hexadecimal O0) is an invalid TID used for disabling terminal during the
`registration process (SAT/SRT contains the serial number)
`255 (hex FF) for registration process (SAT/SRT contains the serial number)
`nalling Action Type (SAT)
`serial number of the remote tenninal for channel assignment during registration
`process
`selective poll including higher TID of the range (used also for general/specific poll)
`selective poll with collision alert including higher range (used also for specific poll)
`in-coming call command on the indicated charmel number
`release command
`disable command
`test command
`
`Sig
`
`channel re-assignment command
`nalling Request Type (SRT)
`serial number of the remote terminal for terminal registration process
`on-hook
`off-hook
`switch-hook
`
`ringing
`release
`
`OOOCC0CCIIUI
`
`dial-digits
`incoming call blocking
`incoming call unblocking
`feature code (e.g., conference)
`test report
`alarm message (fault and fraud)
`multiple charmel request (bandwidth-on-demand)
`channelized services (sub-rate & multiple channels)
`Frame Check Sequence (FCS)
`C
`protection, which covers TID and SAT/SRT fields, against transmission error or
`collision
`
`Figure
`
`9
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 8 of 16
`
`5,563,883
`
`1
`
`ranges of remote terminals
`
`r01
`
`11
`
`I
`
`r12
`
`r21
`
`r22
`
`r23
`
`r24
`
`<5§—1—><—’3’2—><fi><fl>45-3—5—><fi> ’37
`:
`:
`0
`O
`
`‘:
`I
`
`'38
`
`N level Of
`halving
`
`0th
`
`lst
`
`2nd
`
`3rd
`:
`I
`
`F i g u r e
`
`1 0
`
`C0
`
`lines
`
`central
`
`remote
`
`controller
`
`terminals
`
`Figure 11
`
`119
`
`120
`
`121
`
`122
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 9 of 16
`
`5,563,883
`
`
`
`
`
`first poll
`
`
`range r11
`
`
`M)
`
`response YES
`
`next poll
`
`range r l 2
`
`
`
` l\D response
`
`processing res-
`ponse from rll
`YES
`
`next poll
`range r21
`
` next poll
`
`range r22
`
`
`
`next poll
`range r31
`
`tx. error
`
`
`
`processin ,4
`
`next poll
`Con ti n wed in
`range r24
`
`
`Con tinued in
`
`
`
`Figure 12b
`
`Figure 12b
`
`
`
`pouing
`cycle
`
`Figure 12a
`
`

`
`U.S. Patent
`
`Oct. 3, 1996
`
`Sheet 10 of 16
`
`5,563,883
`
`from
`Figure 120
`
`Ifrom
`Flgure 12a
`
`
`
`response
`from r31
`
`
`
`next poll
`
` processing res-
`ponse from I23
`range r4 1
`
`
`response
`from I35
`
`
`
`processing res-
`
`next poll
`
`range r49
`
`ponse from r35
`
`
`Figure
`
`12b
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 11 of 16 .
`
`3003,365,5
`
`Tllll32.:
`
`0.5T
`
`H.
`
`9xx
`
`I11
`
`33
`
`02
`
`.$:o.::ou
`.2289
`
`m_m:_E.::
`
`3cEo._
`
`Afr32.:
`
`.$:o.5:oo
`_m.:=ou
`
`m_a:_:E3
`«SE3
`
`Figure
`
`13a
`
`Figure
`
`13b
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 12 of 16
`
`5,563,883
`
`
`
`first poll
`
`range rll
`
`collisio
`
`repeated
`
`tx. error
`
`processing
`
`polling
`
`cycle
`
`
`
`YES
`
`next poll
`
`range I23
`
`
`
`
`
`polling
`Cycle
`
` YES
`
`response
`from I12
`G
`
`'
`_
`continued In
`Figure 14b
`
`processing res-
`ponse from r11
`
`next poll
`range r21
`
`polling
`
`cycle
`
`9
`
`contmued m
`Figure
`
`Figure
`
`14a
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 13 of 16
`
`5,$63,883
`
`from
`
`Figure 14.3
`
`from
`
`Figure 1 4a
`
`
`rocessmg res-
`first poll
`ponse from r12
`range r22
`
`
`
`
`
`
`
`next poll
`
`
`
`range r37
`
`
`
`
`
`
`first poll
`range r24
`
` respons YES
`
`range 135
`
`Figure 14b
`
`

`
`U.S. Patent
`
`Oct. 8, 1996
`
`Sheet 14 of 16‘
`
`5,563,883
`
`thne
`
`‘-1
`G)
`~
`
`T o
`
`:-
`<-*
`=
`O
`Q)
`
`central
`
`.
`
`U)
`u—
`m
`
`E
`E
`3..
`:9
`id
`
`remote
`
`Figure
`
`15
`
`

`
`U.S. Patent
`
`Oct. 3, 1996
`
`Sheet 15 of 16
`
`5,563,883
`
`
`
`168
`
`167
`
`—>
`
`
`
`switching
`
`
`
`matrix
`
`—-|
`
`12
`
`Figure
`
`16
`
`10
`
`

`
`U.S. Patent
`
`Oct. 3, 1996
`
`Sheet 16 of 16
`
`5,563,883
`
`
`
`
`micro-
`
`processor
`
`system bus
`
`Figure
`
`17
`
`

`
`5,563,883
`
`1
`DYNAMIC CHANNEL MANAGEMENT AND
`SIGNALLING METHOD AND APPARATUS
`
`FIELD OF THE INVENTION
`
`The present invention pertains generally to methods and
`apparatus for facilitating the two-way multi-media commu-
`nication based on a shared transmission media such as
`coaxial cable-TV network, and more specifically to methods
`and apparatus for signalling channel management and pro-
`tocol.
`
`10
`
`BACKGROUND OF THE INVENTION
`
`A multiple access communication system comprises a
`central controller, a shared transmission media and a plu-
`rality of remote terminals dispersed geographically. To pro-
`vide the means for multiple access is a classical problem in
`communication systems with a shared common transmission
`media. Some of the well known schemes are frequency
`division multiple access or FDMA, time division multiple
`access or TDMA, and code division multiple access or
`CDMA. These multiple access schemes deal with the tech-
`niques of separating the communication bandwidth into
`traflic-bearing channels. In a FDMA scheme, the commu-
`nication bandwidth is divided into the frequency bands. The
`TDMA scheme separates the communication bandwidth into
`time slots. The traflic is encoded and then decoded using
`different code in a CDMA scheme.
`
`In all these multiple access schemes the contention for
`access is resolved through signalling protocols on a pre-
`determined and fixed signalling channel. There are propos-
`als to dynamically allocate tralfic-bearing channels to meet
`the service requirements in terms of lower blocking prob-
`ability. However, in addition to availability, bandwidth and
`delay of the traflic-bearing channel, the traflic requirements
`should include responsiveness of the signalling process and
`the quality of the transmission means.
`The signalling protocols for multiple access communica-
`tion systems fall in two general categories for resolving the
`possible contention: scheduled access via polling or other
`means, and random access contention. In radiotelephony and
`local-area-network (CSMA/CD) environment, the conten-
`tion is resolved by monitoring the signal during transmis-
`sion, which requires synchronization and/or means to moni-
`tor activities amongst all remote terminals and the central
`controller. In the CATV network, remote terminals have
`dilferent distance from the central controller making syn-
`chronization difficult. It is also not feasible to detect colli-
`sion, i.e., multiple remote terminals transmit at the same
`time, on the CATV network since the remote terminals are
`attached to different branches of the network. The poll and
`response method is often used to schedule the multiple
`access from plurality of remote terminals, but it has the
`disadvantage of ineflicieney due to wasteful interaction with
`remote terminals that are not in need of servicing.
`
`DESCRIPTION OF THE RELATED ART
`
`There are many proposals of means for dynamically
`adjusting the number of traflie-bearing channels according
`to varying traffic demands or the transmission quality in the
`radio telephony environment, eg., U.S. Pat. Nos. 5,134,709,
`5,235,631 and 5,276,908. In addition U.S. Pat. No. 4,868,
`811 discusses the protocol over the common signalling
`charmel for allocation of trafiic-bearing channels. U.S. Pat.
`No. 4,870,408 proposes a process of re-assigning subscriber
`
`20
`
`25
`
`30
`
`35
`
`40
`
`45
`
`50
`
`55
`
`60
`
`65
`
`2
`units to balance the traflic load over the available charmels.
`U.S. Pat. No. 5,010,329 discloses a method for dynamically
`grouping terminals in blocks for which the central unit
`performs block polling on a common data channel. The
`present invention presents a method to dynamically allocate
`both signalling data and traflic-bearing channels and to
`dynamically assign remote terminals to these charmels.
`The polling scheme is commonly used to resolve conten-
`tion in a multiple access system. U.S. Pat. No. 4,385,314
`proposes a system to sequentially poll all terminals. Due to
`the inherent inefiiciency with sequential polling method,
`some proposals with the following variations for perfor-
`mance improvement have been presented. U.S. Pat. No.
`4,754,426 proposes a two-level polling scheme with distrib-
`uted control. U.S. Pat. No. 4,829,297 proposes use of a high
`priority group. U.S. Pat. No. 4,868,816 proposes a binary
`polling scheme