UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`V.
`
`VOIP-PAL.COM, INC",
`
`Patent Owner
`
`Case No. IPR2016—0l 198
`
`U.S. Patent 9,179,005
`
`DECLARATION IN SUPPORT PATENT OWNER
`
`RESPONSE TO INTER PARTES PETITION
`
`Voip-Pal Ex. 2018
`IPR201 6-01 198
`
`Voip-Pal Ex. 2018
`IPR2016-01198
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`V.
`
`VOIP-PAL.COM, INC",
`
`Patent Owner
`
`Case No. IPR2016—0l 198
`
`U.S. Patent 9,179,005
`
`DECLARATION IN SUPPORT PATENT OWNER
`
`RESPONSE TO INTER PARTES PETITION
`
`Voip-Pal Ex. 2018
`IPR201 6-01 198
`
`Voip-Pal Ex. 2018
`IPR2016-01198
`
`
`
`IPR2016—0l 198
`
`Apple Inc. v. Voip-Pal
`
`1, David Terry, declare as follows:
`
`1.
`
`I am currently employed as a Software Engineer at NAV CANADA,
`
`the operator of Canada's civil air navigation system.
`
`I have over 15 years of
`
`experience in software development.
`
`2.
`
`I was employed by Digifonica in Vancouver, Canada from March
`
`2005
`
`through November 2006.
`
`My responsibilities
`
`included software
`
`development, software packaging and release engineering.
`
`3.
`
`The Digifonica system that was in operation by June 2005 was a voice
`
`over IP (“VOIP”) system that allowed voice calls to be placed between two IP
`
`phones and between an IP phone and the public switched telephone network
`
`(“PSTN”). The Digifonica system utilized multiple geographically distributed
`
`“supernodes” which each handled routing and billing functions for a set of IP
`
`phones. By June 2005 Digifonica had deployed two supernodes, one in London,
`
`UK and one in Vancouver, Canada.
`
`4.
`
`The Digifonica system functioning in June 2005 included hardware
`
`and software that established a user—specific profile for each user containing
`
`attributes such as international dialing digits (IDD), national dialing digits (NDD)
`
`and area code. When a call was placed, the caller identifier was used to locate the
`
`profile associated with the caller containing these attributes from a database. The
`
`caller attributes were then matched against the callee identifier (the dialed digits) to
`
`-2-
`
`
`
`lPR20l6—0l 198
`
`Apple Inc. V. Voip-Pal
`
`create a reformatted callee identifier. Based on the reformatted callee identifier
`
`and a lookup of that number in a database of Digifonica subscribers, a call was
`
`classified as a private, or on—net call if the destination was another Digifonica
`
`subscriber, and classified as a public, or off-net call if the destination was the
`
`PSTN. The Digifonica system was capable of classifying a call as an on-net call
`
`after a user had dialed a PSTN number by first matching the dialing string
`
`according to the caller’s profile, and then checking to see if the destination number
`
`was mapped to a Digifonica IP phone. Once a call was classified, appropriate
`
`routing messages were generated so that a call controller could direct the call
`
`according to the classification of the call. All of these features were incorporated
`
`into the Digifonica system that was deployed and fully operational by June 2005.
`
`5.
`
`The RBR platform was a server within a Digifonica supernode that
`
`received call set up information and responded with call routing messages.
`
`I was
`
`responsible for performing various tasks related to the deployment of RBR
`
`software to the production systems.
`
`I sent and received numerous emails related to
`
`the release or ‘roll—out’ of this software. One of the tasks I performed was to
`
`install RBR software on a machine known as a “package server” which was then
`
`used for the deployment of the software. Digifonica had a “staging” system and a
`
`“production” system. Software was typically first deployed to the staging system
`
`and then deployed to the production system.
`
`The staging system was fully
`
`-3-
`
`
`
`IPR20l6-01198
`
`Apple Inc. V. Voip-Pal
`
`functional and operated the same as the production system including the ability to
`
`place and receive phone calls in the same manner.
`
`6.
`
`I received an email from Emil Bjorsell dated: “Tue, May 31, 2005 at
`
`2:38 PM” and another dated “Tue, May 31, 2005 at 2:44 PM” (Ex. 2022)
`
`announcing that Version 341 of the RBR software had been deployed to both the
`
`Vancouver and the London supemodes.
`
`7.
`
`I sent an email dated: “Mon, Jun 6, 2005 at 9:33 AM” (Ex. 2026)
`
`indicating that RBR Version 361 had been installed on the package server and I
`
`received an email later that day from Emil Bjorsell dated: “Mon, Jun 6, 2005 at
`
`11:33 AM” (Ex. 2027) indicating that RBR Version 361 had been deployed to the
`
`Vancouver and London supernodes. Based on these emails and my recollection of
`
`our deployment procedures, I’m certain that Version 361 of the RBR software was
`
`in operation on the production system on June 6, 2005 and successfully performed
`
`the call routing functions described above in paragraph 4 on that date.
`
`8.
`
`I sent an email dated: “Thu, Aug 4, 2005 at 1:58 PM” (Ex. 2031)
`
`indicating that RBR Version 541 had been installed on the package server.
`
`I
`
`received an email from Emil Bjorsell dated: “Thu, Aug 4, 2005 at 3:59 PM” (Ex
`
`2032) indicating that RBR Version 541 had been deployed to the staging system.
`
`9.
`
`I sent an email dated: “Mon, Aug 8, 2005 at 11:48 AM” and another
`
`dated “Mon, Aug 8, 2005 at 12:00 PM” (EX 2034) indicating that RBR Version
`
`-4-
`
`
`
`IPR2016—0l 198
`
`Apple Inc. V. Voip—Pal
`
`554 had been installed on the package server.
`
`I received an email from Emil
`
`Bjorsell dated: “Mon, Aug 8, 2005 at 12:09 PM” (Ex. 2035) indicating that RBR
`
`Version 544 had been deployed to the staging system.
`
`I received an email from
`
`Samantha Edwards dated: “Mon, Aug 8, 2005 at 7:12 PM” (Ex. 2036) indicating
`
`that RBR Version 554 was going to be released on August 9, 2005.
`
`10.
`
`I received an email from Chris Huff dated: “Tue, Aug 23, 2005 at
`
`1:33 PM” (Ex. 2042) indicating that RBR Version 694 was ready to be installed on
`
`the package server.
`
`I received an email from Samantha Edwards dated: “Wed,
`
`Aug 24, 2005 at 4:02 PM” (Ex. 2019) indicating that RBR Version 694 was going
`
`to be released on August 25, 2005.
`
`ll.
`
`Throughout 2005 and 2006, Digifonica continued updating this RBR
`
`system and deploying further updates in addition to those listed above.
`
`12.
`
`I declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct.
`
`Dated:
`
`8g?,0i7
`
`By:
`
`
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