IPR2016-01082
`Unified Patents v. Voip-Pal
`
`I.
`
`Comparison of Petition at pp. 15-20 with Declaration at ¶¶36-47
`
`Petition at pp. 15-20
`
`Caloyannides Declaration, EX1002 at
`¶¶36-47
`C.A. Ground 1: Turner anticipates
`claims 1, 2, 7, 27, 28, 29, 34, 54, 72, 73,
`74, 92, 93 and 111 under 35 U.S.C. §
`102(b)
`36. Turner discloses a
`
`computerized method and system for
`routing calls between parties at different
`locations. EX1003, Abstract. Calling
`and called parties can be located on
`private networks such as Internet
`Protocol networks connected to a
`gateway, or on public networks such as
`a PSTN. EX1003Id., FIG. 1, EX1002 ¶
`36. [...]
`
`37. A call agent receives a
`called address from an IP gateway
`associated with a caller, after the caller
`dials a number of a callee. EX1003 Id.
`at 9:13-22. The addresses of the caller
`and callee are cross-translated and
`reformatted to be analyzed and
`compared. Id.EX1003 at 9:22-30,
`EX1002 ¶ 37.
`
`38. The call agent then sends a
`query to a directory server for a caller
`profile that is associated with the caller,
`and the directory server retrieves the
`caller’s profile. EX1003 Id. at 22:9-15;,
`FIG. 6, elements 602-606. The caller’s
`profile includes information including,
`for example, an ID or customer address,
`preferences, user profile data. Id. at FIG.
`3, EX1002 ¶ 38. [...]
`
`39. The user profile and linked
`network address object (data structure)
`include information associated with the
`
`
`
`
`
`C. Ground 1: Turner anticipates
`claims 1, 2, 7, 27, 28, 29, 34, 54, 72, 73,
`74, 92, 93 and 111 under 35 U.S.C.
`102(b)
`
`Turner discloses a computerized
`method and system for routing calls
`between parties at different locations.
`EX1003, Abstract. Calling and called
`parties can be
`located on private
`networks such as Internet Protocol
`networks connected to a gateway, or on
`public networks such as a PSTN.
`EX1003, FIG. 1, EX1002 ¶ 36.
` [...]
`
`A call agent receives a called address
`from an IP gateway associated with a
`caller, after the caller dials a number of
`a callee. EX1003 at 9:13-22. The
`addresses of the caller and callee are
`cross-translated and reformatted to be
`analyzed and compared. Id. at 9:22-30,
`EX1002 ¶ 37.
`
`The call agent then sends a query
`to a directory server for a caller profile
`that is associated with the caller, and the
`directory server retrieves the caller's
`profile. EX1003 at 22:9-15; FIG. 6,
`elements 602-606. The caller's profile
`includes information including, for
`example, an ID or customer address,
`preferences, user profile data. Id. at FIG.
`3, EX1002 ¶ 38. [...]
`
`The user profile and linked
`network address object (data structure)
`include information associated with the
`
`-1-
`
`Voip-Pal Ex. 2001
`IPR2016-01082
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`

`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`caller such as a customer address (CA)
`and network address (NA). EX1003 at
`7:29-61. The network address and
`customer address include information
`such as a telephone number or number
`indicative of a location of the caller. Id.
`at 9:13-36, 10:25-53. For example, the
`CA and NA are indicative of a network
`in which the caller is located, a gateway
`associated with the caller, and/or a
`location of the caller. Id. The NA can be
`updated to reflect a current location if
`the caller roams to a new location. Id. at
`22:2-8. Thus, the data stored and
`accessed by the Directory Server for a
`caller includes data associated with the
`caller (caller attributes) such as
`addresses and preferences. EX1002 ¶
`39.
`After retrieving the caller's
`
`profile, the call agent determines
`whether the called party is within the
`same gateway as the caller. EX1003 at
`9:24-36. Turner's example discusses
`translating a called CA number to a NA,
`such as by translating "2002" to "313-
`555-2002." Id. The translated NA is
`then compared to the caller number
`(313-555-2001), and the call agent
`determines that the matching numbers
`("333-555") indicate that the caller and
`callee are within the same gateway. Id.
`
`Another example from Turner
`discusses that a caller may dial a
`number (3001), and that the call agent
`may assign the NA identifying the caller
`as "313-555-2002." EX1003 at 10:25-
`48. The call agent then queries the
`Directory Server, which retrieves a user
`profile for the caller and translates the
`
`caller such as a customer address (CA)
`and network address (NA). EX1003 Id.
`at 7:29-61. The network address and
`customer address include information
`such as a telephone number or number
`indicative of a location of the caller. Id.
`at 9:13-36, 10:25-53. For example, the
`CA and NA are indicative of a network
`in which the caller is located, a gateway
`associated with the caller, and/or a
`location of the caller. Id. The NA can be
`updated to reflect a current location if
`the caller roams to a new location. Id. at
`22:2-8. Thus,This means the data stored
`and accessed by the Directory Server for
`a caller includes data associated with the
`caller (caller attributes) such as
`addresses and preferences. EX1002 ¶
`39.
`40. After retrieving the caller’s
`
`profile, the call agent determines
`whether the called party is within the
`same gateway as the caller. EX1003 at
`9:24-36. Turner’s example discusses
`translating a called CA number to a NA,
`such as by translating “2002” to “313-
`555-2002.” Id. The translated NA is
`then compared to the caller number
`(313-555-2001), and the call agent
`determines that the matching numbers
`(“333-555”) indicate that the caller and
`callee are within the same gateway. Id.
`
`41. Another example from Turner
`discusses that a caller may dial a
`number (3001), and that the call agent
`may assign the NA identifying the caller
`as “313-555-2002.” EX1003 at 10:25-
`48. The call agent then queries the
`Directory Server, which retrieves a user
`profile for the caller and translates the
`
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`

`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`dialed number (3001) to a NA for the
`callee—in this example it is “709-555.”
`Id. Based on the NA, the call agent
`recognizes the network locations of the
`caller and callee and recognizes that the
`called party is within the private
`network but is located on a different
`gateway. Id. Thus, theThe call agent,
`therefore, determines matches between
`the numbers in the callee and caller
`information, as well as locations of the
`numbers based on stored information
`associated with the caller and callee
`numbers (e.g., attributes). EX1002 ¶ 41.
`
`42. Based on the analysis of the
`NA and/or CA of the caller and the
`callee, as well as stored information
`associated with the NA and CA, the call
`agent of Turner determines whether the
`callee is within the same gateway as the
`caller and can be processed internally,
`such as a private network call. EX1002
`¶ 42. The call agent also determines
`whether the call is directed toward a
`callee on another gateway, such as a
`public network call. EX1003 at 9:30-36,
`FIG. 4A (portion reproduced to the
`right). ThereforeThus, the call agent of
`Turner classifies the call as a private
`network call or a public network call.
`EX1002 ¶ 42.
`
`43. In addition to the analysis of
`the CA and NA, the Directory Server
`analyzes the called address to identify
`codes or digits that are associated with
`the caller as being numbers for “private
`trunk network access” or “escape to the
`PSTN.” EX1003 at 12:44-67. If the
`Directory Server recognizes such a
`code/digit, it returns the caller and callee
`
`dialed number (3001) to a NA for the
`callee—in this example it is "709-555."
`Id. Based on the NA, the call agent
`recognizes the network locations of the
`caller and callee and recognizes that the
`called party is within the private
`network but is located on a different
`gateway. Id. Thus, the call agent
`determines matches between the
`numbers in the callee and caller
`information, as well as locations of the
`numbers based on stored information
`associated with the caller and callee
`numbers (e.g., attributes). EX1002 ¶ 41.
`
`Based on the analysis of the NA
`and/or CA of the caller and the callee, as
`well as stored information associated
`with the NA and CA, the call agent of
`Turner determines whether the callee is
`within the same gateway as the caller
`and can be processed internally, such as
`a private network call. EX1002 ¶ 42.
`The call agent also determines whether
`the call is directed toward a callee on
`another gateway, such as a public
`network call. EX1003 at 9:30-36, FIG.
`4A (portion reproduced to the right).
`Therefore, the call agent classifies the
`call as a private network call or a public
`network call. EX1002 ¶ 42.
`
`In addition to the analysis of the
`CA and NA, the Directory Server
`analyzes the called address to identify
`codes or digits that are associated with
`the caller as being numbers for “private
`trunk network access” or “escape to the
`PSTN.” EX1003 at 12:44-67. If the
`Directory Server recognizes such a
`code/digit, it returns the caller and callee
`
`
`
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`

`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`numbers to the call agent, and the call
`agent recognizes the code/digit. Id.
`Then, the call agent sends a request to
`the appropriate gateway to route the
`call. Id, EX1002 ¶ 43.
`
`Once the call is classified as a
`public network call (e.g., internal
`gateway or IP network call) or a public
`network (e.g., PSTN) call, the call agent
`composes and sends gateway
`instructions to route the private network
`or public network call. EX1003 at 9:57-
`63, 10:12-22, 12:44-67, FIGS. 4B, 4C
`(reproduced below). [...]
`
`If the call can be processed
`internally and thus is classified as a
`private network call, the call agent sends
`setup instructions to the gateway, id. at
`FIG. 4B step 186, by composing a local
`IP address where the callee is located.
`Id. at 10:12-22. The call agent then
`sends the setup instructions to the
`gateway to route the call to the callee in
`the internal network. Id.
`
`If the call is classified as a public
`network call, such as a call that will be
`routed through the PSTN or to a PSTN
`destination, then the call agent sends
`instructions to the trunk gateway to set
`up the call using the PSTN. EX1003 at
`9:57-63, 12:44-67, FIG. 4C step 193.
`
`[...]
`
`
`
`
`
`numbers to the call agent, and the call
`agent recognizes the code/digit. Id.
`Then, the call agent sends a request to
`the appropriate gateway to route the
`call. Id, EX1002 ¶ 43.
`
`44. Once the call is classified as a
`public network call (e.g., internal
`gateway or IP network call) or a public
`network (e.g., PSTNPTSN) call, the call
`agent composes and sends gateway
`instructions to route the private network
`or public network call. EX1003 at 9:57-
`63, 10:12-22, 12:44-67, FIGS. 4B, 4C
`(reproduced below). [...]
`45. If the call can be processed
`
`internally and thus is classified as a
`private network call, the call agent sends
`setup instructions to the gateway, id. at
`FIG. 4B step 186, by composing a local
`IP address where the callee is located.
`Id. at 10:12-22. The call agent then
`sends the setup instructions to the
`gateway to route the call to the callee in
`the internal network. Id.
`
`46. If the call is classified as a
`public network call, such as a call that
`will be routed through the PSTN or to a
`PSTN destination, then the call agent
`sends instructions to the trunk gateway
`to set up the call using the PSTN.
`EX1003 at 9:57-63, 12:44-67, FIG. 4C
`step 193.
`
`[...]
`
`-4-
`
`

`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`
`
`Petition at pp. 34-40
`
`II. Comparison of Petition at pp. 34-40 with Declaration at ¶¶48-59
`
`Caloyannides Declaration, EX1002 at
`¶¶48-59
`D.B. Ground 2: Kaczmarczyk in
`view of Turner renders claims 1, 2, 7,
`27, 28, 29, 34, 54, 72, 73, 74, 92, 93
`and 111 obvious under 35 U.S.C. §
`103(a)
`48. Kaczmarczyk discloses a call
`
`routing and signaling system that routes
`calls across different types of networks,
`such as calls from an IP network to a
`PSTN (public) network, or calls from a
`PSTN network to an IP network.
`EX1004, Abstract, 6:52-7:10, EX1002 ¶
`48. The system receives information for
`a call request (such as a number dialed)
`and translates the received information
`into a usable format. EX1004 Id. at
`6:62-7:10, 8:25-48. A call control
`engine then accesses tables stored in
`external databases and associated with
`the caller, such as a calling address
`attribute table, and route plan table. Id.
`at 7:47-59, FIG. 2B (reproduced below).
`
`[...]
` 49. Using the accessed tables, the
`call control engine determines a call
`type and an appropriate route for the
`call. The call control engine locates the
`calling address in a calling address
`attribute table, and then "screens" the
`called address by comparing and
`analyzing the called address number to
`components from the calling address
`attribute table. Id. at 9:15-67, FIG. 4B
`(reproduced below), EX1002 ¶ 49.
`[...]
` 50. To screen the called address
`
`D. Ground 2: Kaczmarczyk in view
`of Turner renders claims 1, 2, 7, 27,
`28, 29, 34, 54, 72, 73, 74, 92, 93 and
`111 obvious under 35 U.S.C. § 103(a)
`
`
`
`Kaczmarczyk discloses a call
`routing and signaling system that routes
`calls across different types of networks,
`such as calls from an IP network to a
`PSTN (public) network, or calls from a
`PSTN network to an IP network.
`EX1004, Abstract, 6:52-7:10, EX1002 ¶
`48. The system receives information for
`a call request (such as a number dialed)
`and translates the received information
`into a usable format. EX1004 at 6:62-
`7:10, 8:25-48. A call control engine then
`accesses tables stored in external
`databases and associated with the caller,
`such as a calling address attribute table,
`and route plan table. Id. at 7:47-59, FIG.
`2B (reproduced below).
`
`[...]
`
`Using the accessed tables, the call
`control engine determines a call type
`and an appropriate route for the call.
`The call control engine locates the
`calling address in a calling address
`attribute table, and then "screens" the
`called address by comparing and
`analyzing the called address number to
`components from the calling address
`attribute table. Id. at 9:15-67, FIG. 4B
`(reproduced below), EX1002 ¶ 49.
`[...]
`To screen the called address
`
`
`
`-5-
`
`

`
`number, the call control engine
`determines a call type based on
`comparing the called address to a
`"called digits analysis table," and
`attributes in the attributes tables.
`EX1004 at 9:41-53, FIG. 4B (right), 5A
`(portion reproduced below), EX1002 ¶
`50.
`[...]
`
` 51. Based on the determined call
`type and analysis of attributes, the call
`control engine determines services
`available to the caller, and selects an
`appropriate route, such as routing a call
`from an IP network caller to a PSTN
`callee. EX1004 at 7:28-41, 9:53-67.
`Based on the selected route, the call
`routing and signaling system generates
`and sends instructions for routing the
`call through a media gateway to the
`PSTN. Id. at 6:62-7:10, 7:22-27, 8:42-
`48, 10:58-66, FIG. 4A (below), EX1002
`¶ 51. [...]
`
`52. Kaczmarczyk discloses
`routing calls across different networks
`such as from an IP network to a PSTN,
`or from a PSTN to an IP network.
`ThereforeIn other words, Kaczmarczyk
`discloses routing calls from a private
`network to a public network, and vice
`versa. EX1002 ¶ 52. As
`Kaczmarczyk'sBecause Kaczmarczyk’s
`disclosure focuses on techniques for
`signaling between IP networks and the
`PSTN, it is silent regarding routing calls
`in a private network, such as calls
`between individuals within an IP
`network. Id.
`
`53. Turner, as discussed above, is
`a reference in an analogous art of trans-
`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`number, the call control engine
`determines a call type based on
`comparing the called address to a
`"called digits analysis table," and
`attributes in the attributes tables.
`EX1004 at 9:41-53, FIG. 4B (right), 5A
`(portion reproduced below), EX1002 ¶
`50.
`[...]
`
`Based on the determined call type
`
`and analysis of attributes, the call
`control engine determines services
`available to the caller, and selects an
`appropriate route, such as routing a call
`from an IP network caller to a PSTN
`callee. EX1004 at 7:28-41, 9:53-67.
`Based on the selected route, the call
`routing and signaling system generates
`and sends instructions for routing the
`call through a media gateway to the
`PSTN. Id. at 6:62-7:10, 7:22-27, 8:42-
`48, 10:58-66, FIG. 4A (below), EX1002
`¶ 51. [...]
`
`Kaczmarczyk discloses routing
`calls across different networks such as
`from an IP network to a PSTN, or from
`a PSTN to an IP network. Therefore,
`Kaczmarczyk discloses routing calls
`from a private network to a public
`network, and vice versa. EX1002 ¶ 52.
`As Kaczmarczyk's disclosure focuses on
`techniques for signaling between IP
`networks and the PSTN, it is silent
`regarding routing calls in a private
`network, such as calls between
`individuals within an IP network. Id.
`
`
`
`Turner, a reference in an
`analogous art of trans-network call
`
`-6-
`
`

`
`network call routing, . Turner cures the
`deficiencies of Kaczmarczyk, because
`Turner discloses the additional
`techniques of determining that a call is
`directed to a party within the same (i.e.
`private) network, and routing the call to
`the private network recipient. EX1002 ¶
`53.
`54. In particular, Turner discloses
`
`a call agent that receives a called
`address from an IP gateway associated
`with a caller, after the caller dials a
`number of a callee. Id. at 9:13-22.
`Similar to Kaczmarczyk, Turner
`discloses reformatting/translating the
`addresses of the caller, and then
`accessing a profile having information
`about the caller. Id. at 9:22-30, 22:9-15,
`FIG. 6, elements 602-606, FIG. 3,
`EX1002 ¶ 54.
`
`55. After retrieving the caller's
`profile, the call agent of Turner
`determines whether the called party is
`within the same gateway as the caller.
`EX1003 at 9:24-36. That is, based on
`the analysis of the NA and/or CA of the
`caller and the callee, as well as stored
`information associated with the NA and
`CAIn other words, the call agent of
`Turner determines whether the callee is
`within the same gateway as the caller
`and can be processed internally, such as
`a private network call based on the
`analysis of the NA and/or CA of the
`caller and the callee, as well as stored
`information associated with the NA and
`CA. The call agent also determines
`whether the call is directed toward a
`callee on another gateway, such as a
`public network call. EX1003 at 9:30-36,
`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`routing, cures the deficiencies of
`Kaczmarczyk, because Turner discloses
`the additional techniques of determining
`that a call is directed to a party within
`the same (i.e. private) network, and
`routing the call to the private network
`recipient. EX1002 ¶ 53.
`
`
`
`
`
`In particular, Turner discloses a
`call agent that receives a called address
`from an IP gateway associated with a
`caller, after the caller dials a number of
`a callee. Id. at 9:13-22. Similar to
`Kaczmarczyk, Turner discloses
`reformatting/translating the addresses of
`the caller, and then accessing a profile
`having information about the caller. Id.
`at 9:22-30, 22:9-15, FIG. 6, elements
`602-606, FIG. 3, EX1002 ¶ 54.
`
`After retrieving the caller's
`profile, the call agent of Turner
`determines whether the called party is
`within the same gateway as the caller.
`EX1003 at 9:24-36. That is, based on
`the analysis of the NA and/or CA of the
`caller and the callee, as well as stored
`information associated with the NA and
`CA, the call agent of Turner determines
`whether the callee is within the same
`gateway as the caller and can be
`processed internally, such as a private
`network call. The call agent also
`determines whether the call is directed
`toward a callee on another gateway,
`such as a public network call. EX1003
`at 9:30-36, FIG. 4A (portion reproduced
`to the right). Therefore, the call agent
`classifies the call as a private network
`call or a public network call. EX1002 ¶
`
`-7-
`
`

`
`FIG. 4A (portion reproduced to the
`right). Therefore, theThe call agent of
`Turner, therefore, classifies the call as a
`private network call or a public network
`call. EX1002 ¶ 55.
`
`56. If the call can be processed
`internally and thus is classified as a
`private network call in the Turner
`system, the call agent sends setup
`instructions to the gateway, EX1004id.
`at FIG. 4B step 186, by composing a
`local IP address where the callee is
`located. Id. at 10:12-22. The call agent
`then sends the setup instructions to the
`gateway to route the call to the callee in
`the internal network. Id, EX1002 ¶ 56.
`
`It57. In my opinion, it would be
`have been obvious to POSA to combine
`Kaczmarczyk's trans-network call
`routing and signaling system with
`Turner's techniques for routing calls
`within a private network. EX1002 ¶ 57.
`Both Turner and Kaczmarczyk disclose
`call routing and signaling systems for
`both private and public communication
`networks, as demonstrated in the
`similarities between Figure 1 of Turner:
`[...]
`
`58. and FIG. 1 of Kaczmarczyk:
`[...]
`
`Furthermore, a59. A POSA, in
`
`my opinion, incorporating the features
`of Turner into the systems and methods
`of Kaczmarczyk would have expected
`the results to improve call management
`services in calls within a private
`network and calls that traverse between
`IP and public network. See EX1003 at
`1:17-2:22, EX1002 ¶¶ 59, 60.
`[...]
`
`IPR2016-01082
`Unified Patents v. Voip-Pal
`
`55.
`
`
`
`If the call can be processed
`internally and thus is classified as a
`private network call in the Turner
`system, the call agent sends setup
`instructions to the gateway, EX1004 at
`FIG. 4B step 186, by composing a local
`IP address where the callee is located.
`Id. at 10:12-22. The call agent then
`sends the setup instructions to the
`gateway to route the call to the callee in
`the internal network. Id, EX1002 ¶ 56.
`
`It would be have been obvious to
`POSA to combine Kaczmarczyk's trans-
`network call routing and signaling
`system with Turner's techniques for
`routing calls within a private network.
`EX1002 ¶ 57. Both Turner and
`Kaczmarczyk disclose call routing and
`signaling systems for both private and
`public communication networks, as
`demonstrated in the similarities between
`Figure 1 of Turner: [...]
`
`
`
`and FIG. 1 of Kaczmarczyk:
`[...]
`
`Furthermore, a POSA
`
`incorporating the features of Turner into
`the systems and methods of
`Kaczmarczyk would have expected the
`results to improve call management
`services in calls within a private network
`and calls that traverse between IP and
`public network. See EX1003 at 1:17-
`2:22, EX1002 ¶¶ 59, 60.
`[...]
`
`
`
`-8-