UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
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`
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`SECURUS TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`GLOBAL TEL*LINK CORPORATION
`Patent Owner
`_________________________
`
`
`DECLARATION OF IVAN ZATKOVICH
`REGARDING U.S. PATENT NO. 7,256,816
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`1
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`SECURUS EXHIBIT 1002
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`Page 1 of 119
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`I.
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`Qualifications ................................................................................................... 3
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`II. Materials Considered ....................................................................................... 6
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`III. Legal Standards ............................................................................................... 6
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`IV. Level of Skill ................................................................................................... 8
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`V.
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`Summary of Opinions ...................................................................................... 9
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`VI. The ’816 Patent ..............................................................................................10
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`VII. Meaning of Claim Terms ...............................................................................13
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`A.
`
`B.
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`“multiplexing means ...” ......................................................................13
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`“transmitting means ...” .......................................................................17
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`VIII. The Prior Art ..................................................................................................18
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`A.
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`Bulriss ..................................................................................................18
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`B. Hesse....................................................................................................25
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`C.
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`Rae .......................................................................................................28
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`IX. Rationale to Combine Bulriss and Hesse ......................................................30
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`X.
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`Rationale to Combine Rae with Bulriss and Hesse .......................................39
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`XI. Bulriss and Hesse Collectively Disclose Every Feature of Claims 1-
`21, 25-50, 54, and 55 .....................................................................................41
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`A.
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`Independent Claims 1 and 30 ..............................................................41
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`B. Dependent Claims 1-21, 25-29, 31-50, 54, and 55 .............................56
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`XII. Bulriss, Hesse, and Rae Collectively Disclose Every Feature of
`Dependent Claims 22-24 and 51-53 ..............................................................75
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`XIII. Claim Chart Applying Bulriss, Hesse, and Rae to Claims 1-55 ...................79
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`XIV. Conclusion ...................................................................................................119
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`
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`2
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`I, Ivan Zatkovich, have been retained by Securus Technologies, Inc. as an
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`expert to provide my opinions regarding U.S. Pat. No. 7,256,816 (“the ’816
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`patent”). My qualifications are established by my curriculum vitae, which I
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`understand is exhibit 1003. I am being compensated for my time in this matter, but
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`my opinions are based on my own views of the patented technology and the prior
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`art. My compensation is not, in any way, dependent on the outcome of this
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`proceeding or the substance of my opinion.
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`I.
`
`QUALIFICATIONS
`[001] I received a Bachelor’s degree in Computer Science, with a minor in
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`Electrical Engineering Digital Circuit Design, from the University of Pittsburgh in
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`1980. I completed a Master’s thesis in Computer Networks. Byte Magazine
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`published a portion of the results from my Master’s thesis. My curriculum vitae
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`(Ex. 1003) includes information regarding my professional career.
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`[002] I have over thirty years of experience in telecommunications,
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`Internet, and communication networks. For at least 12 years, my work focused on
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`technology related to communications such as: Computer Telephony Integration
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`(CTI), call routing, speech recognition, telecom systems integration, telecom
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`billing systems, telephone carrier networks including traditional public switched
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`telephone networks (PSTN), wireless, and Voice-over-Internet Protocol (VoIP)
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`methodologies. I also have experience with multiparty videoconferencing,
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`conferencing and message protocols, including H.323 and SIP, and network
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`security services, including firewall and virtual private networks (VPNs).
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`[003] Currently, I am the Principal Consultant of eComp Consultants, a
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`position I have held for over 15 years. eComp Consultants provides professional
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`intellectual property consulting in the fields of telecommunications, web
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`publishing, eCommerce, computer related telephony, and network
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`communications. Such consulting services include working with clients on
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`specific information technology projects, process improvement, project
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`management and other technology issues, as well as providing professional expert
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`witness services.
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`[004] I have consulted for companies such as Verizon, Deustche Telekom,
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`PTT Netherlands, Bell Canada, and Qwest Communications. For these companies
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`I provided consultation on Telecommunications, Internet, and eCommerce
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`technology, including CTI with specific project consulting for Contact Center
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`management, video conferencing, and integration of PBX, IVR, ACD, VoIP, and
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`Unified Messaging technology. I have also implemented contact centers for 3rd
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`party Call Assistant and Call Relay configuration.
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`[005] From 1980 to 1987, I was employed as a Software Engineer for
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`Digital Equipment Corporation, a leading vendor of computer systems, including
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`computers, software and peripherals, where I developed telephone management
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`systems for an early CTI and computer command system.
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`[006] From 1987 to 1996, I was employed as a Project Manager of
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`Telecom Software at GTE Data Services, an eight billion dollar
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`telecommunications company, which was the predecessor to Verizon. During my
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`employment at GTE Data Services, I developed Telephone Switch Management
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`and Service Provisioning software, and implemented: teleconference systems for
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`hands free operation, multiple microphones and audio sources, and combining and
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`filtering audio feedback; routing & switching services within a network; and early
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`VoIP gateway prototypes for Integrated Services Digital Network (“ISDN”) to
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`Internet telephone services.
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`[007] From 1999 to 2002, I was employed as an eBusiness Engagement
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`Manager at Tanning Technology and IMRGlobal, an international systems
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`integrator specializing in network infrastructure and channel integration for
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`financial markets and the insurance industry. During my employment at Tanning
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`Technology, I developed Integrated VoIP contact centers to cross-utilize call center
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`agents for simultaneous telephone, Interactive Voice Response (“IVR”), chat
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`room, and eMail support.
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`[008] By virtue of the above experience, I have gained a detailed
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`understanding of the technology that is at issue in this petition. In addition, my
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`experience with telecom systems integration and telephone carrier networks,
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`including traditional PSTNs, wireless, and VoIP methodologies, are relevant to the
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`subject matter of the ’816 patent.
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`[009] I am being compensated for my time at my customary rate. I am
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`being paid for my time, regardless of the facts I know or discover and regardless of
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`the conclusions or opinions that I reach and express. I have no financial interest in
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`the outcome of this proceeding.
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`[010] Except as otherwise stated, I have personal knowledge of the facts
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`stated in this Declaration, and I have formed the opinions expressed in this
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`Declaration based on my expertise, experience, and information that I have
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`reviewed.
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`II. MATERIALS CONSIDERED
`[011] In forming my opinions, I have considered the materials cited in this
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`declaration.
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`III. LEGAL STANDARDS
`[012] In preparing this declaration, I have been educated generally on
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`relevant patent law issues, including the standards for claim construction and
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`obviousness.
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`[013] I understand that, in proceedings like this one before the United
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`States Patent & Trademark Office, a claim in an unexpired patent shall be given its
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`broadest reasonable construction in light of the specification of the patent in which
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`it appears. I also understand that district courts may apply a different claim
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`construction standard, and that claims there should be given their ordinary meaning
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`to a person having ordinary skill in the art at the relevant timeframe in light of the
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`claim language, patent specification, and prosecution history.
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`[014] I understand that a patent claim can be invalid if it is anticipated in
`
`view of the prior art. I understand that anticipation of a claim requires that every
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`element of a claim be disclosed expressly or inherently in a single prior art
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`reference, arranged as in the claim.
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`[015] I understand that a patent claim can be invalid for obviousness only
`
`if the invention described in the claim would have been obvious to a person of
`
`ordinary skill in the art at the time the invention was made, taking into account (1)
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`the scope and content of the prior art, (2) the differences between the prior art and
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`the claimed invention, (3) the level of ordinary skill in the art, and (4) any
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`secondary considerations of non-obviousness, including commercial success of
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`products or processes using the invention, long felt need for the invention, failure
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`of others to make the invention, industry acceptance of the invention, and copying
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`of the invention by others.
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`[016] I understand that multiple references can be combined with one
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`another, or with the knowledge of a person of ordinary skill in the art, to make a
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`claim obvious. I also understand that there must be a reason that would have
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`prompted a person of ordinary skill in the art to combine the features of the prior
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`art in the way the claimed invention does.
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`[017] I also understand that obviousness of a patent cannot be established
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`through hindsight, and I understand that elements from different prior art
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`references cannot be selected to create the claimed invention using the invention
`
`itself as a roadmap.
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`IV. LEVEL OF SKILL
`[018] I am informed that several factors are to be considered in
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`determining who would be a person of ordinary skill in the art. These factors
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`include: (1) the types of problems encountered in the art; (2) the prior art solutions
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`to those problems; (3) the rapidity with which innovations are made; (4) the
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`sophistication of the technology; and (5) the educational level of active workers in
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`the field.
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`[019] Based on these factors, a person of ordinary skill at the time of the
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`alleged invention of the ’816 patent would have held a bachelor’s or master’s
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`degree in computer or electrical engineering, computer science, or a related field,
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`and at least three years of experience working with computerized communication
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`systems.
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`V.
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`SUMMARY OF OPINIONS
`[020] I have been asked to consider the ’816 patent and certain prior art
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`references and to offer my opinions on the effect of that art on the claims of the
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`’816 patent. While I understand that the claims set forth the full scope of the
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`alleged invention, in general the ’816 patent claims a prison inmate-visitor video
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`conferencing system that includes a data center, establishes a video conference at a
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`scheduled time, and splits and copies audio and visual (A/V) signals.
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`[021] Prison inmate-visitor video conferencing systems were well-known
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`in the art at the time of the ’816 patent’s filing. Some of these known systems
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`included a data center, established a video conference at a scheduled time, and split
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`and copied A/V signals.
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`[022] One of ordinary skill in the art at the relevant time would have found
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`it obvious, at the time of the alleged invention, to have modified existing prison
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`inmate-visitor video conferencing systems that split and copy A/V signals with
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`other prison inmate-video conferencing systems that established video conferences
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`at a scheduled time to arrive at the system and method claimed by the ’816 patent.
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`[023] As I explain in more detail below, the prior art teaches each and
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`every feature of the ’816 patent’s claims, and the prior art provides a motivation to
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`combine those features in the manner claimed with a reasonable expectation of
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`success.
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`[024] A person of ordinary skill in the art would have understood that
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`claims 1-55 of the ’816 patent would have been obvious in view of U.S. Patent No.
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`7,061,521, which I refer to as “Bulriss” (Ex. 1005), U.S. Patent No. 7,046,779,
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`which I refer to as “Hesse” (Ex. 1006) and U.S. Patent No. 7,899,167, which I
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`refer to as “Rae” (Ex. 1007).
`
`VI. THE ’816 PATENT
`[025] The ’816 patent describes a system for conducting video visits (or
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`conferences) between two participants, such as prison inmates and visitors. (Ex.
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`1001 at 5:15-21.) The ’816 patent’s system includes two endpoints, one for the
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`visitor and one for the inmate. At each endpoint, the visitor or the inmate uses a
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`terminal to participate in the video conference. The two endpoints are shown in
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`Figure 1 of the ’816 patent.
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`[026] As shown in Figure 1, a data center is between the two endpoints and
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`provides the connection between them. (Ex. 1001 at 4:19-22.) The data center
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`initiates audio/video connections between the visitor and the inmate, and houses
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`the equipment used for scheduling. (Ex. 1001 at 4:19-22, 6:12-14). The ’816
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`patent’s system also includes a station and a terminal for an “overseer” to monitor
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`the video visits between inmates and visitors. (Ex. 1001 at 8:58-63.)
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`[027] Figure 1 also shows what the ’816 patent refers to as a “multiplexing
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`means 140” (a and b). The ’816 patent describes that the multiplexing means
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`receives communications data via a unicast connection and copies it. (Ex. 1001 at
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`7:44-50). As a result, the multiplexing means generates two identical data streams
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`during a video visit, with one data stream going to the inmate’s terminal and the
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`other going to the overseer terminal 145. (Ex. 1001 at 7:50-56). The ’816 patent
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`describes that the multiplexing means can be “a physical device, similar in function
`
`to a router, but is configured to copy or split the signal rather than redirect it.” (Ex.
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`1001 at 9:27-30.)
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`[028] The use of a multiplexing means is critical to the alleged invention of
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`the ’816 patent. It addresses latency, which is what the ’816 patent describes as
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`“the most important reason why traditional video conferencing would not be
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`workable for prison visitation and other similar situations.” (Ex. 1001 at 2:25-28.)
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`According to the ’816 patent, the disclosed system’s use of a multiplexing means
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`“greatly reduce[s], and in most cases eliminate[s], [the] difference in latency in
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`transmissions/streams used in conventional video conferencing” (Ex. 1001 at 7:16-
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`21). This, according to the ’816 patent, sets its technology apart from “traditional
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`video conferencing systems” that used a Multi-point Control Unit (MCU). Since an
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`MCU requires distinct data connections between each of the participants of the
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`video visit (inmate, visitor and overseer) and the MCU, “an inherent latency exists
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`between these multiple connections that poses a significant security risk for the
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`prison. Because of latency in the data path during data transmission,
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`communication is not instantaneous; the delay is a function of all intermediate
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`equipment and media along the data path.” (Ex. 1001 at 2:25-38.)
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`[029] Second, the function performed by the multiplexing means, splitting
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`and copying communication data, was critical for the applicant during prosecution.
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`The Examiner did not allow the challenged claims until the applicant amended
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`claim 12 (issued as claim 1) to recite “splitting along the first or second data
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`connection,” and claim 41 (issued as claim 30) to recite a “multiplexing means
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`along the first or second data connection ... configured to split ... original
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`communications data.” (Ex. 1004 at 91-95, 12/8/2006 Claim Amendment,
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`underlining shows added claim language; Ex. 1004 at 65, Notice of Allowance
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`Mailed 4/18/2007.) The applicant contended that the amended claims distinguished
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`over the prior art because the amended claims “split[] the audio and video data
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`along the data connections, rather than within the data center,” which applicant
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`alleged was advantageous because “no discernible delay is imparted on to the
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`copied signals.” (Ex. 1004 at 101, 12/8/2006 Comments, p. 13.)
`
`[030] The filing date of the ’816 patent is October 25, 2004, and at that
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`time video conferencing between inmates and visitors was well known. The ’816
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`patent acknowledges this. (Ex. 1001 at 2:10-11.) Bulriss, which is prior art to the
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`’816 patent, also acknowledges that the general concept of a courtroom/jail video
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`conference systems was not new when Bulriss was filed. (Ex. 1005 at 3:1-5:25.)
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`VII. MEANING OF CLAIM TERMS
`[031] I understand that use of the word “means” in a claim term triggers a
`
`rebuttable presumption that it is written in a means-plus-function format, and that
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`this presumption can be rebutted when the claim term recites structure sufficient to
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`perform the claimed function in its entirety. I also understand that means-plus-
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`function claim terms are limited to the corresponding structure, material, or acts
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`described in the specification, and their equivalents, that perform the claimed
`
`function.
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`“multiplexing means ...”
`A.
`[032] Claims 2, 4, 5, 7, 8, 30, 33, 34, 36, 37, and 54 recite a “multiplexing
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`means.” These claims depend directly or indirectly from claims 2 and 30.
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`According to the plain language of claims 2 and 30, the claimed function of the
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`“multiplexing means” is “splitting either the original communications data
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`transmitted from one of the first or second participants to the data center, or the
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`original communications data transmitted to the one of the first or second
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`participants from the data center, to create a copy of the video and audio
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`communications data from the original video and audio communications data.”
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`[033] Claim 2 recites that the multiplexing means “split[s] the original
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`communications data” as part of the “splitting” step of claim 1. (Ex. 1001 at 16:48-
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`50.) The “splitting” of “original communications data” in claim 1 includes
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`“splitting along the first or second data connection ... the communications data
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`transmitted from one of the first and second participants to the data center ... to
`
`create a copy of the video and audio communications data from the original video
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`and audio communications data.” (Ex. 1001 at 16:35-42.) Claim 30 similarly
`
`recites “multiplexing means along the first or second data connection configured to
`
`split either the original communications data transmitted from one of the first or
`
`second participants to the data center, or the original communications data
`
`transmitted to the one of the first or second participants from the data center, to
`
`create a copy of the video and audio communications data from the original video
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`and audio communications data.” (Ex. 1001 at 16:48-50.).
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`[034] One of ordinary skill in the art is not sufficiently informed as to the
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`structure for performing the function of the “multiplexing means” based on the
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`plain language of those claims. Thus, claims 2 and 30 do not recite sufficient
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`structure for performing the recited function of the “multiplexing means.” As a
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`result, I am informed that the “multiplexing means” claim term is a means-plus-
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`function claim term, and that “multiplexing means” should be construed by one of
`
`ordinary skill in the art to include the structures performing the claimed function of
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`the “multiplexing means” and their equivalents.
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`[035] Turning to the specification for the corresponding structure, the ’816
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`patent describes that the
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`“multiplexing means 250 is a physical device, similar in
`function to a router, but is configured to copy or split the
`signal rather than redirect it. In other embodiments,
`however, the multiplexing means 250 may be entirely
`software-based, such as a software daemon. In such
`embodiments, multiplexing means 250 could be a piece
`of code that runs on a networking server, or a cluster of
`servers. For example,
`the code embodying
`the
`multiplexing means 250 may be running on servers that
`are located in the local LAN.” (Ex. 1001 at 9:27-36.)
`[036] In the above passage, the specification states that the multiplexing
`
`means may be implemented in software. It states that the software can be a daemon
`
`or a piece of code that runs on a networking server, or a cluster of servers. But, the
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`specification does not describe details of the software implementation for the
`
`multiplexing means. For example, the specification does not describe in prose or in
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`any figure an algorithm for splitting original communications data to create a copy
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`of the video and audio communications data. The specification does not describe
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`any process steps or operation flow for splitting original communications data to
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`create a copy of the video and audio communications data. At most, the
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`specification describes a black box that performs the splitting and copying
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`functions of the multiplexing means, and the location of that black box. The
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`specification does not describe the implementation details of that black box.
`
`[037] The specification does, however, does mention a hardware
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`embodiment. The ’816 patent describes that the multiplexing means can be a
`
`“physical device, similar in function to a router, but is configured to copy or split
`
`the signal rather than redirect it.” (Ex. 1001 at 9:27-30). Accordingly, the structure
`
`corresponding to the function of the “multiplexing means” is a “physical device
`
`configured to copy or split a signal rather than redirect it,” and its equivalents.
`
`[038] Putting the function and structure together, it is my opinion that the
`
`appropriate construction for the “multiplexing means” clause is “a physical device
`
`configured to copy or split a signal rather than redirect it, and the physical device’s
`
`equivalents, that splits either the original communications data transmitted from
`
`one of the first or second participants to the data center, or the original
`
`communications data transmitted to the one of the first or second participants from
`
`the data center, to create a copy of the video and audio communications data from
`
`the original video and audio communications data.”
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` “transmitting means ...”
`B.
`[039] Claim 30 recites a “transmitting means” having the function
`
`“transmit[ing] all of the original communications data to and from the first and
`
`second participants across the computer network and via the data center.” (Ex.
`
`1001 at 18:23-25.)
`
`[040] I reviewed the ’816 patent and I was unable to identify any structure
`
`corresponding to the claimed function of the “transmitting means.” The ’816 patent
`
`describes that communications data is sent via computer network 205, (Ex. 1001 at
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`8:22-57, Fig. 2.), and that “computer network 205 may be a packet-based network,
`
`such as the Internet, capable of transmitting communications signals used in
`
`conducting the video visits via data packets.” (Ex. 1001 at 8:22-29.) The
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`specification further describes that “high-speed connections are provided using
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`conventionally available high-speed data connections, such as a T1 connection,”
`
`(Ex. 1001 at 7:13-16), and “[a]ny type of connection may be employed ... to
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`accommodate the number of video visits or number of participants in any one
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`video visit ... includ[ing] T1, T3, T4, DSL, SHDSL, DS3, OC3, a satellite link, and
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`other types of wired or wireless high-speed data communications links.” (Ex. 1001
`
`at 8:41-46.)
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`[041] While the specification does not describe the structure of hardware
`
`that transmits the original communications data across the computer network 205,
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`one of ordinary skill in the art would understand that some equipment must
`
`perform this operation to carry out the claimed function of the “transmitting
`
`means.” Thus, although the equipment itself is undefined in the specification, one
`
`of ordinary skill in the art would understand that the structure corresponding to the
`
`“transmitting means” is “equipment capable of transmitting data via a packet-
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`based, wired or wireless network, such as the Internet,” and its equivalents.
`
`[042] Therefore, taking the function and structure together, it is my opinion
`
`that the appropriate construction of the entire “transmitting means” clause is
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`“equipment capable of transmitting data via a packet-based, wired or wireless
`
`network, such as the Internet, and its equivalent equipment, configured to transmit
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`all of the original communications data to and from the first and second
`
`participants across the computer network and via the data center.”
`
`VIII. THE PRIOR ART
`A. Bulriss
`[043] Bulriss discloses “a video conferencing system connecting a
`
`courtroom with a jail.” (Ex. 1005 at 1:9-10.) Fig. 1A of Bulriss shows the basic
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`configuration of the system.
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`
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`[044] As shown in Figure 1A above, the Bulriss system is installed
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`between a courthouse and a jail. This configuration allows point-to-point
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`communication between one or more individuals located within a courtroom 16 in
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`the courthouse 12 and an inmate physically located in the jail 14. (Ex. 1005 at
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`9:37-44.)
`
`[045] The Bulriss system includes a switching device 22 that “basically
`
`operates as a public exchange device (otherwise referred to as a ‘PBX’ device).
`
`The A/V signals from the A/V IO device 20 in each of the courtrooms 16 are
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`collected, processed, and routed by the switching device 22 to various recipients,
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`including the inmate conference room 18 at the jail 14.” (Ex. 1005 at 10:1-10.) The
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`switching device 22 “is responsible for establishing a point-to-point
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`communications link between a selected courtroom 16 and a selected inmate
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`conference room 18 or jail 14, as appropriate.” (Ex. 1005 at 10:1-10.)
`
`[046] Figure 2A provides a more detailed illustration of the system. Below,
`
`I have annotated Figure 2A to highlight the components of the system I will refer
`
`to most in my analysis:
`
`
`
`[047] On the courthouse side, the inmate’s attorney uses “courtroom
`
`attorney-client sidebar station 48,” which “generates an A/V signal that is
`
`processed by the system 10 and sent to the jail A/V IO device 28.” (Ex. 1005 at
`
`13:18-22.) The A/V signal includes both audio and video. For example, Bulriss
`
`describes that “the attorney station 48 within the courtroom 16 includes a handset
`
`20
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`118, 168 that connects to the courtroom control interface device 42. When the
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`attorney-client sidebar feature is active, the attorney may pick up the handset 118,
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`168 and speak to the inmate via the handset 118, 168. A video image of the
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`defense attorney is captured separately by a camera (and microphone) system
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`integrated with the attorney station 48.” (Ex. 1005 at 18:9-17.)
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`[048] As shown in the annotated Figure 2A above, the courthouse side of
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`the system also includes “control interface device 42.” The control interface device
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`42 is connected to the “judge’s control panel 44 through a two-way
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`communications link 46 ... [and is also connected to] courtroom attorney-client
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`sidebar station 48 via a two-way communications link 50.” (Ex. 1005 at 11:66-
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`12:6.) The control interface device 42 “which may comprise a multiplexer,” splits
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`signals going to and from the switching device 22 for the judge control panel 44
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`and the courtroom attorney-client sidebar station 48. (Ex. 1005 at 11:66-12:6,
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`12:64-13:14.)
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`[049] Also on the courtroom side is the judge control panel 44. A judge
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`uses judge control panel 44 to control the system, including selecting “the
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`preferred display format for the display devices 96. In one example, the judge may
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`select a format where the prosecuting attorney, the defense, attorney, the inmate,
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`and the judge are simultaneously depicted on the display devices 96. In this
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`manner, not only can the conduct of each of the parties be displayed to the jury, but
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`the conduct of each of the parties may be recorded by the recording device 58.”
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`(Ex. 1005 at 17:5-12.) The judge, along with other members of the courtroom, can
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`monitor the video conference using the display devices 96. (Ex. 1005 at 16:54-
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`17:12.)
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`[050] As shown in Figure 2A, A/V signals to and from the courtroom pass
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`through control interface device 42 and switching device 22 before coming from,
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`and going to, the jail side. For example, “[f]rom the courtroom attorney-client
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`sidebar station 48, the A/V signals travel through the control interface device 42,
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`through the switching device 22, through the courthouse interface device 24, and
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`through the jail interface device 26. From the jail interface device 26, the A/V
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`signals travel through the jail control interface device 60 and are retrieved and
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`played on the inmate attorney-client sidebar station 62.” (Ex. 1005 at 13:5-12.)
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`[051] On the jail side, the inmate uses inmate attorney-client sidebar
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`station 62. “[W]hatever image or images are projected on the display devices 96
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`within the courtroom 16, the same image or images may be transmitted to the
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`inmate and may be displayed to the inmate via the inmate’s station 62.
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`Accordingly, the inmate may be aware of all of the activity in the courtroom 16.”
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`(Ex. 1005 at 17:20-25.) The inmate attorney-client sidebar station 62 also includes
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`a camera, a microphone, and a handset that can be used to communicate privately
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`with the defense attorney. (Ex. 1005 at 18:18-27.)
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`[052] In the primary embodiment of Bulriss, the switching device 22 is
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`located within the courthouse. But, in some alternative embodiments, “the
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`switching device 22 may be used to collect, process, and route signals from
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`multiple courthouses 12 connected thereto. In such a configuration, the switching
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`device 22 may connect several courthouses 12 together in instances where a single
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`switching device 22 for a single courthouse 12 is not economically justified.” (Ex.
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`1005 at 10:11-16.) In a multiple courthouse configuration, one of ordinary skill in
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`the art would understand that at least one of the multiple courthouses would not
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`have an on-premises switching device as it would rely on a single switching device
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`located at another courthouse or a location separate from the courthouses that the
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`switching device serves.
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`[053] The Summary of Invention section of Bulriss describes a “signal
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`processor.” Bulriss describes that the “signal processor [is] disposed in the
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`communications link between the first and second locations. The signal processor
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`routes the signals between the input-output devices at the first and second
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`locations.” (Ex. 1005 at 6:32-35). Bulriss also describes that “[t]he first control
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`interface device is communicatively coupled between the first input-output device
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`and the signal processor. The signal processor is communicatively coupled
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`between the control interface device and the second input-output device.” (Ex.
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`1005 at 7:3-5.). Bulriss also describes that “another aspect of the invention
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`provides for the signal processor being a switching device.” (Ex. 1005 at 7:66-67.)
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`Based on this disclosure, one of ordinary skill in the art would understand that the
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`“signal processor” in the Summary of the Invention section is analogous to
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`“switching device 22” in the Description of Preferred Embodiments of the
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`Invention section.
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`[054] Since Bulriss describes the switching device as a “signal processor”
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`and also describes that the switching device performs operations similar to a PBX
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`device (Ex. 1005 at 10:1-10), processes A/V signals (Ex. 1005 at 12:51-52), and is
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`connected to the Internet (Ex. 1005 at 11:35), one of ordina