Petitioner
`Petitioner
`Cisco Systems, Inc.
`Cisco Systems, Inc.
`
`IPR2015-01754
`IPR2015-01754
`U.S. Patent No. 6,158,011
`U.S. Patent No. 6,158,011
`
`Theodore Foster
`David McCombs
`Haynes and Boone, LLP
`November 15, 2016
`
`1
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`CSCO-1065
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`
`Petitioner
`Cisco Systems, Inc.
`Cisco Systems, Inc.
`
`IPR2015-01754
`IPR2015-01754
`U.S. Patent No. 6,158,011
`U.S. Patent No. 6,158,011
`
`Theodore Foster
`David McCombs
`Haynes and Boone, LLP
`November 15, 2016
`
`1
`
`CSCO-1065
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`
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`SummarySummary
`
`Combining Alden and Takahashi is obvious:
`1
`– Reduces pre-configuration burdens
`– Avoids changing the communication stack
`– Improves flexibility
`
`Takahashi’s Winsock interception technique was
`2
`admittedly well-known and used in 1997.
`
`The prior art combination describes a Winsock
`3
`“shim”.
`
`2
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`CSCO-1065
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`Claim 1Claim 1
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`Ex. 1001, ’011 Patent, claim 1
`(Discussed inter alia in Petition,
`paper no. 2 at 19-47)
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`3
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`CSCO-1065
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`Alden & Takahashi CombinationAlden & Takahashi Combination
`
`Alden
`
`Takahashi
`
`Ex. 1006, Fig. 21
`(Discussed in Paper 2 at 20-21, 24-26, 28-29, 36, 45;
`Paper 50 at 11, 26)
`
`Ex. 1007, p.2 Fig. 2
`(Discussed in Paper 2 at 13, 35, 40)
`
`Combination
`
`Ex. 1004, p.71
`(Discussed in Paper 2 at 38)
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`4
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`Takahashi Improves Alden’s Pre-Configuration ProcessTakahashi Improves Alden’s Pre-Configuration Process
`
`Alden
`
`Alden, Ex. 1006, Fig. 23 & 4:60-62
`(Discussed in Paper 28 at 57, Paper 50 at 7)
`
`5
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`Takahashi Improves Alden’s Pre-Configuration ProcessTakahashi Improves Alden’s Pre-Configuration Process
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`Deposition of Dr. Hamilton
`
`Ex. 1034, 123:5-9
`(Discussed in Paper 50 at 7)
`
`6
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`Takahashi Improves Alden’s Pre-Configuration ProcessTakahashi Improves Alden’s Pre-Configuration Process
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`Takahashi
`
`Ex. 1007, p. 3 & Fig. 3
`(discussed in Paper 2 at 15)
`
`7
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`Takahashi Improves Alden’s Handling of the Takahashi Improves Alden’s Handling of the
`
`Communication StackCommunication Stack
`Alden
`
`Ex. 1006, Fig. 21 & 18:27-35
`(discussed in Paper 50 at 10-11)
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`8
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`Alden Changes the TCP/IP StackAlden Changes the TCP/IP Stack
`
`Alden
`
`“TCP/IP Illustrated,
`Volume 1:
`The Protocols”
`(Annotated)
`
`Ex. 1006, 19:60-65 (discussed
`in Paper 50 at 9-10)
`
`Ex. 1037, Fig. 9.1 at 112
`(discussed in Paper 50 at 10)
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`Takahashi Avoids Changing Communication SoftwareTakahashi Avoids Changing Communication Software
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`Takahashi
`
`Ex. 1007, pp. 1 & 3 (discussed in Paper 2 at 15 & Paper 50 at 12)
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`10
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`Takahashi Improves Alden’s Flexibility Because Alden is Takahashi Improves Alden’s Flexibility Because Alden is
`
`Limited to Pre-Registered DestinationsLimited to Pre-Registered Destinations
`
`Alden
`
`* * *
`
`Ex. 1006, 18:14-15 & 18:24-30 (discussed in Paper 2 at 14)
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`11
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`Takahashi Provides Flexibility to Connect Takahashi Provides Flexibility to Connect
`
`to Any Secure Destinationto Any Secure Destination
`
`Takahashi
`
`Ex. 1007, p. 3 & Fig. 3
`(discussed in Paper 2 at 15 & Paper 50 at 12-13)
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`12
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`Combination Retains Benefits of Combination Retains Benefits of
`
`Alden’s Applications Level SecurityAlden’s Applications Level Security
`Deposition of Dr. Hamilton
`
`* * *
`
`* * *
`
`Ex. 1034, 97:2-98:7
`(discussed in Paper 50 at 14)
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`13
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`Takahashi’s Low Overhead Technique Takahashi’s Low Overhead Technique
`
`Supports the Combination with AldenSupports the Combination with Alden
`
`Takahashi
`
`Ex. 1007, 6 (discussed in Paper 50 at 24)
`
`Ex. 1007, 6-7 (discussed in Paper 50 at 24)
`
`14
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`Obviousness Is Evaluated At the Time of InventionObviousness Is Evaluated At the Time of Invention
`
`“A critical step in analyzing the patentability
`of claims pursuant to section 103(a) is
`casting the mind back to the time of invention,
`to consider the thinking of
`one of ordinary skill in the art,
`
`guided only by the prior art references
`and the then-accepted wisdom
`in the field.”
`
`In Re Kotzab, 217 F.3d 1365, 1369 (Fed. Cir. 2000)
`(discussed in Paper 50 at 5)
`
`15
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`Ex. 2015 Is Not From the Prior Art TimeframeEx. 2015 Is Not From the Prior Art Timeframe
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`Ex. 2015, p.2 (discussed in Paper 50 at 3.)
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`16
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`Ex. 2015 Addresses a Changed Windows LandscapeEx. 2015 Addresses a Changed Windows Landscape
`
`Ex. 1048, p. 2 (discussed in Paper 50, p. 3)
`
`Ex. 1049, p. 2 (discussed in Paper 50, p. 3)
`
`Ex. 1051, p. 2 (discussed in Paper 50, p. 3)
`
`Ex. 1050, p. 2 (discussed in Paper 50, p. 3)
`
`Ex. 1052, p. 2 (discussed in Paper 50, p. 3)
`
`* * *
`
`Ex. 1053, p. 2 (discussed in Paper 50, p. 3)
`
`17
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`Ex. 2015 Shows Decisions Driven by Practical Business Ex. 2015 Shows Decisions Driven by Practical Business
`
`Needs in a Changed MarketplaceNeeds in a Changed Marketplace
`
`Cisco Document
`
`Ex. 2015, p. 9 (discussed in Paper 50, Petitioner’s Reply, pp. 3 & 19)
`
`2016 Testimony of Vincent Parla
`
`Ex. 2016, at 353:4-7 (discussed in Paper 50, pp. 4 & 19)
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`18
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`Ex. 2015 Confirms Obviousness of Ex. 2015 Confirms Obviousness of
`
`Using Winsock InterceptorsUsing Winsock Interceptors
`
`
`Ex. 2015 Confirms Obviousness ofEx. 2015 Confirms Obviousness of
`Cisco Document
`
`Using Winsock InterceptorsUsing Winsock Interceptors
`
`
`
`2 Cisco Document2 Cisco Document
`
`Ex. 2015, p. 9 (discussed in Paper 50, p. 18)
`
`
`
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`
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`Ex. 2015, p. 9 (discussed in Paper 50, p. 18)Ex. 2015, p. 9 (discussed in Paper 50, p. 18)
`
`19
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`CSCO-1065
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`
`
`SummarySummary
`
`Combining Alden and Takahashi is obvious:
`1
`– Reduces pre-configuration burdens
`– Avoids changing the communication stack
`– Improves flexibility
`
`Takahashi’s Winsock interception technique was
`2
`admittedly well-known and used in 1997.
`
`The prior art combination describes a Winsock
`3
`“shim”.
`
`20
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`CSCO-1065
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`’011 Patent Admits that Winsock Shims Were Well-Known’011 Patent Admits that Winsock Shims Were Well-Known
`
`’011 Patent
`
`Ex. 1001, 7:1-8
`(discussed in Paper 50, p. 15)
`
`Ex. 1001, 10:16-21
`(discussed in Paper 50, p. 15)
`
`21
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`Admissions About POSITA’s Knowledge are BindingAdmissions About POSITA’s Knowledge are Binding
`
`“Here, the Board properly held that
`
`the application's specification
`
`made numerous admissions
`as to what one skilled in the art
`at the time of the invention would have known.”
`
`In Re Morsa, 803 F.3d 1374, 1377 (Fed. Cir. 2015)
`(discussed in Paper 50 at 15-16)
`
`22
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`Winsock Shims Were Well-Known in 1997Winsock Shims Were Well-Known in 1997
`
`U.S. Patent No. 6,085,224
`(filed March 11, 1997)
`
`Ex. 1040, 7:59-67 (discussed in Paper 50, p. 16)
`
`23
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`CSCO-1065
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`Winsock Shims Were Well-Known in 1997Winsock Shims Were Well-Known in 1997
`
`Stardust Website
`
`Ex. 1038, 6 & 7 (discussed in Paper 50, pp. 16-17)
`
`24
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`CSCO-1065
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`Winsock Shims Were Well-Known in 1997Winsock Shims Were Well-Known in 1997
`
`NEC Website
`
`Ex. 1038, 9 & 12 (discussed in Paper 50, p. 17)
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`25
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`CSCO-1065
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`Interception Techniques Were Documented in 1997Interception Techniques Were Documented in 1997
`
`“Windows 95 System Programming Secrets”
`
`Ex. 1041, p. 746 (discussed in Paper 50, p. 17)
`
`26
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`CSCO-1065
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`
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`SummarySummary
`
`Combining Alden and Takahashi is obvious:
`1
`– Reduces pre-configuration burdens
`– Avoids changing the communication stack
`– Improves flexibility
`
`Takahashi’s Winsock interception technique was
`2
`admittedly well-known and used in 1997.
`
`The prior art combination describes a Winsock
`3
`“shim”.
`
`27
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`CSCO-1065
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`Prior Art Teaches a “shim arranged to intercept … Prior Art Teaches a “shim arranged to intercept …
`
`in order to cause … to generate said session key”in order to cause … to generate said session key”
`
`Takahashi
`
`Takahashi
`
`Ex. 1007, p. 3 (discussed in Paper 50, p. 26 & Paper 2, p. 43-44)
`
`Ex. 1007, Fig. 3, detail (discussed in Paper 50, p. 26 & Paper 2, p. 43-44)
`
`28
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`Prior Art Teaches a “shim arranged to intercept … Prior Art Teaches a “shim arranged to intercept …
`
`in order to cause … to generate said session key”in order to cause … to generate said session key”
`
`Schneier, “Applied Cryptography”
`
`Ex. 1009, p. 43 (discussed in Paper 50, p. 26 & Paper 2, p. 43-44)
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`29
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`CSCO-1065
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`Takahashi Teaches a Winsock “Shim”Takahashi Teaches a Winsock “Shim”
`
`Takahashi
`
`Ex. 1007, p. 2 (discussed in Paper 50, p. 76 & Paper 2, p. 41)
`
`’011 Patent
`
`*
`
`*
`
`*
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`Ex. 1001, 7:1-8 (discussed in Paper 50, p. 15)
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`30
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`CSCO-1065
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`Winsock API is Between Two LayersWinsock API is Between Two Layers
`
`Decision on Institution, Paper 9 at 15.
`
`Quinn (Annotated)
`
`Paper 50 at 28 (annotating Ex. 1047, p. 25, Fig. 2-10)
`
`31
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`CSCO-1065
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`Takahashi’s Winsock Interception Takahashi’s Winsock Interception
`
`Uses Same Function Calls as Existing LayersUses Same Function Calls as Existing Layers
`
`Decision on Institution, Paper 9 at 15.
`
`Additional Takahashi Paper
`
`Ex. 1039 at 4 (discussed in Paper 50, p. 27-28)
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`32
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`CSCO-1065
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`
`
`Petitioner
`Petitioner
`Cisco Systems, Inc.
`Cisco Systems, Inc.
`
`IPR2015-01754
`IPR2015-01754
`U.S. Patent No. 6,158,011
`U.S. Patent No. 6,158,011
`
`Theodore Foster
`David McCombs
`Haynes and Boone, LLP
`November 15, 2016
`
`33
`
`CSCO-1065
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