UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`VOIP-PAL.COM INC.,
`Patent Owner.
`______________
`
`Cases IPR2016-01198 and IPR2016-01201
`Patents 9,179,005 B2 and 8,542,815, B2
`______________
`
`Record of Oral Hearing
`Held: July 20, 2017
`
`
`
`Before JOSIAH C. COCKS, JENNIFER MEYER CHAGNON, and JOHN
`A. HUDALLA, Administrative Patent Judges.
`
`
`
`
`
`
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`VOIP-PAL.COM INC.,
`Patent Owner.
`______________
`
`Cases IPR2016-01198 and IPR2016-01201
`Patents 9,179,005 B2 and 8,542,815, B2
`______________
`
`Record of Oral Hearing
`Held: July 20, 2017
`
`
`
`Before JOSIAH C. COCKS, JENNIFER MEYER CHAGNON, and JOHN
`A. HUDALLA, Administrative Patent Judges.
`
`
`
`
`
`
`
`
`
`Case IPR2016-01198 (Patent 9,179,005 B2)
`Case IPR2016-01201 Patent 8,542,815, B2)
`
`APPEARANCES
`
`ON BEHALF OF THE PETITIONER, APPLE INC.:
` ADAM SEITZ, ESQUIRE
` ERISE IP, P.A.
` 6201 College Boulevard
` Suite 300
` Overland Park, Kansas 66211
` 913.777.5600
`
`ON BEHALF OF THE PETITIONER, APPLE INC.:
` PAUL HART, ESQUIRE
` ERISE IP, P.A.
` 5600 Greenwood Plaza Boulevard
` Suite 200
` Greenwood Village, Colorado 80111
`
`ON BEHALF OF THE PATENT OWNER, VOIP-PAL.COM INC.:
` STEPHEN W. MELVIN, PH.D., ESQUIRE
` ZYTEK COMMUNICATIONS CORPORATION
` 1275 West 6th Avenue
` Suite 300
` Vancouver, British Columbia V6H 1A6
` 604.628.9589
`
`ON BEHALF OF THE PATENT OWNER, VOIP-PAL.COM, INC.:
` KERRY S. TAYLOR, PH.D., ESQUIRE
` KNOBBE MARTENS
` 12790 El Camino Real
` San Diego, California 92130
` 858.707.4000
`
`
`The above-entitled matter came on for hearing on Thursday, July 20,
`
`2017, at the U.S. Patent and Trademark Office, 600 Dulany Street,
`Alexandria, Virginia in courtroom A, at 10:02 a.m.
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`Case IPR2016-01201 Patent 8,542,815, B2)
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`P R O C E E D I N G S
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` JUDGE COCKS: Good morning. Welcome to the board.
`We're here today for a consolidated oral argument in two
`cases -- in connection with two cases, IPR2016-01198 and
`IPR2016-01201 involving patents 9,179,005 and 8,542,815.
` Let's begin with introductions of counsel.
` Would counsel for the Petitioner please state your
`appearance.
` MR. SEITZ: Good morning, Your Honors. I'm Adam
`Seitz with Erise IP for Petitioner, Apple. With me is Paul
`Hart.
` JUDGE COCKS: All right. Thank you, Mr. Seitz.
` And would counsel for Patent Owner please state
`their appearance.
` MR. MELVIN: Steven Melvin with Patent Owner,
`VoIP-PAL. And with me is Kerry Taylor.
` JUDGE COCKS: All right. Thank you, Mr. Melvin.
` Now will be set forth in the trial hearing order.
`Each side has 60 minutes of argument time. Petitioner bears
`the burden of showing unpatentability and will proceed first.
`They may reserve rebuttal time. The Patent Owner will then
`argue their opposition and may also reserve rebuttal time.
`Petitioner will then use any time they reserve to respond to
`all aspects of the Patent Owner's case. And then the Patent
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`Owner will use their reserve time to respond to the
`Petitioner's case when it comes to the motion to exclude and
`to antedating certain references involved in this proceeding.
` With that being said, Mr. Seitz, you may begin.
` MR. SEITZ: Thank you, Your Honor. I have paper
`copies of the presentation submitted.
` JUDGE COCKS: Yes, you may approach.
` MR. SEITZ: Thank you.
` Your Honors, I would like to reserve 10 minutes,
`please.
` JUDGE COCKS: Okay. Thank you.
` You may proceed.
` MR. SEITZ: Thank you.
` My may it please the Court. Your Honors, we
`already mentioned we're here on two different petitions today
`relating to two different patents, the '005 and the '815.
`The issues in these patents are nearly identical.
` The challenged grounds are identical between the
`two relating to Chu in combination with Chu, and Chu in
`combination with Chen. Our base reference is Chu '684. The
`other reference, to avoid confusion, is Chu '366.
` Let's talk about the challenged patents and get an
`understanding for what the basic functionality is here.
`Looking at DX3, there's three fundamental aspects I'm going
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`to be focusing on today. Specifically in the challenged
`patents, this is from the abstract, they talk about a caller
`identifier, and a callee identifier, and then a receipt. They
`talk about a call classification criteria that's associated
`with the caller identifier that's used to classify the call
`as a public call or a private call. And then a routing
`message identifying an address that sends that call along.
` Moving to DX4 let's talk about how this works in
`practice. So the main concepts of the challenged patents.
`You have a VoIP phone system, a voice over Internet protocol
`phone system, that allows a user, a caller, to make a phone
`call to one of two different locations. Another user on the
`private network, an IP-to-IP call, or a phone call from the
`IP network to what is called the PSTN, public switched
`telephone network, that's your standard landline.
` The system of the challenged patents will then look
`at the caller information and look at the attributes of the
`dialed phone number, and it's going to compare the number
`that you've dialed to see what format you've put it in. For
`example, have you used a short form seven-digit phone number
`such as 555-1234. It's going to compare that to a caller
`profile, the caller information, to look at the attributes to
`make certain assumptions about the phone number you're trying
`to reach. It's then going to reformat that number based on
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`the assumptions that it's making.
` Why would it need to do this reformat? It
`fundamentally has to do with the difference between IP phones
`and the standard PSTN phones. The traditional phones that
`we're used to hanging in your kitchen -- used to be hanging
`in your kitchen were hard-wired through an actual line to a
`local office in your neighborhood. What that meant is that
`they had a physical location. And because they had a
`physical location, when you made a phone call on a standard
`phone, assumptions could be made.
` If you dialed a seven-digit number, the phone
`system could assume that you were making a local call in your
`area, and it would apply your area code, and it would apply
`the 1 that we're comfortable dialing with, the national
`dialing code.
` That assumption does not exist with IP phones. IP
`phones can be taken and plugged in anywhere into any network
`in any country, any location in the United States. So those
`dialing conventions don't apply anymore.
` So the idea here with the challenged patents was
`because you're dealing with an IP phone that does not allow
`someone to dial in the format that they're used to, in fact,
`an IP phone would require you to dial with what's called an
`E.164 number. I'm going to use that a lot today. An E.164
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`number is just a standard phone number -- a standard format
`for a phone number that's used worldwide to be able to say
`this is the one phone number that identifies this one person.
`So VoIP phones require you to use an E.164 number.
` So the system of the challenged patents would take
`the number that was dialed, it would reformat it by comparing
`the number that was dialed to the information that's in the
`caller profile. And then based on that reformatted number,
`it would look in its database to see is that a user of our IP
`network; if so, it's a private call. If it's not a user of
`our IP network, then it would be sent to the public, the
`PSTN, for a phone call there.
` Prosecution shown on DX5. The main focus -- the
`only focus in prosecution was on this question of the
`reformatting. The comparison of the dialed phone number, in
`the example I gave you, the seven-digit number, to the caller
`profile. And then using that comparison to reformat the
`phone numbers. You see here in the '815 prosecution, it
`stated, "Alexander simply looks up the callee number and
`fails to disclose or suggest any criteria that are used in
`conjunction with the comparison involving calling
`attributes." That comparison, again, is the looking at the
`dialed number to what is in the user profile, the caller's
`profile, to make assumptions about how to reformat that phone
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`number. Based on this distinction, the reformatting of the
`patents were granted.
` Now, let's take a look at DX6. This is probably
`our best example of how this reformatting works in the
`patent. Shown in DX6 is Figure 8B and it includes the claim
`language from the '005 patent Claim 1. Now, the '005 and the
`'815 have very similar claim language for this reformatting.
`I'm going to show you how this works and we'll be talking
`about the reformatting in the context of these limitations as
`we proceed.
` So the '005 says, "When at least one of said
`calling attributes and at least a portion of a callee
`identifier associated with the callee meet private network
`classification criteria." So let's break this down. We have
`calling attributes from the caller, that's the person making
`the call. Those are contained in a caller profile and it
`includes information about me, what my national dialing digit
`would be, my international dialing digit, an area code that
`you would want to apply, that's in the user -- the caller
`profile. The system then looks at the dialed number and
`compares it to those calling attributes, that's the left side
`of Figure 8B that we see on DX6 here.
` As you walk down the left side, you see a
`comparison looking for a match. We start with the callee
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`identifier, it begins with a caller IDD, international
`dialing digit, and it proceeds to look for a match. I've
`highlighted box 396 here in the instance of where a match is
`made. The callee identifier length matches the caller local
`dialing length.
` So in this instance, we're using the seven-digit
`555-1234 seven-digit short form. It compares that to the
`caller profile. It realizes that the seven matches the
`seven-digit shortened number in the caller profile and it
`makes a match. In this instance, it's going to set the call
`as local. It's going to proceed to box 400, at which point,
`it's going to reformat the phone number into a standard
`format, an E.164 for example.
` It's going to reformat the phone number based on
`the assumptions that it's made from the caller's profile, at
`which point, this proceeds to box 269 in the upper right
`corner. There it's going to take that reformatted phone
`number, which is now something that can identify a single
`person, and it's going to look in its database to see is that
`single person one of you our subscribers; if so, it proceeds
`to the green box B for a private IP system call. If not, it
`proceeds to green box C for a public system call.
` DX7 shows claim language from the '815 patent Claim
`1 "determining a match when at least one of said calling
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`attributes matches at least a portion of said callee
`identifier." This is the same functionality that I just
`described shown in Figure 8B. So those are the two
`limitations relating to the formatting aspect.
` Now I want to talk about our base --
` JUDGE COCKS: Counsel, may I ask you.
` MR. SEITZ: Yes, sir.
` JUDGE COCKS: Go back one slide.
` Is there any difference in this limitation from the
`prior limitation of the patent? What's the difference
`between those two limitations?
` MR. SEITZ: In operation, there's no difference.
`And no party has claimed that there is any difference here.
` JUDGE COCKS: Go ahead. Thank you.
` MR. SEITZ: So let's take a look at our base
`reference. Our base reference is Chu '684, it is a
`VoIP-based phone system dated September 2003. Chu '684 IP
`phone system and what we see here are Figures 2 and Figures 8
`put together from Chu on DX8. In Chu '684, it allows the
`user to make two different kinds of phone calls, an IP-to-IP
`phone call, which is what it calls an on-net call. It also
`allows the user to make an on-net -- I'm sorry, not an
`on-net, an IP-to-PSTN phone call, what they call an off-net
`call. So on-net is IP to IP. Off-net is IP to PSTN.
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` Looking still at DX8 in Figure 2 on the left side,
`we have an IP phone in the yellow triangle. That IP phone
`can make a phone call to another IP phone shown on the far
`right side of this figure here, 601. It can do that by
`dialing an E.164 number. Chu '684 specifically states that
`each IP phone includes or is assigned its own E.164, the long
`standard phone number. When that phone call is made, it
`sends that to server 110, which is in the upper left corner.
`Server 110 is going to look at the dialed number. It's going
`to determine if that's a user that's on its network for an
`on-net call or whether it's a user that's off-net for a
`public call.
` In this example here on DX8, we have an on-net
`call. In that instance, the soft switch 220 is going to
`create a private network routing message that's going to
`identify on the right side in Figure 8 of the right side of
`DX8, an egress packet switch which is connected to the
`destination customer premises, at which point, that phone
`call will be completed for an on-net phone call.
` DX9 gives us an example of an on-net to an off-net,
`or an IP to a PSTN, an off-net phone call, and there it
`operates just the same. A phone number will be dialed, the
`server will determine whether that is an on-net call or an
`off-net call, it will then identify a PSTN gateway, and send
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`the call off to the public phone on the PSTN network.
` Now, Chu '684 only looked at the dialed digits. It
`processes those dialed digits to look and see where to assign
`the call. What it did not have was the ability to look at a
`caller profile and examine and compare. And so I want to
`talk briefly about our secondary references.
` Now, Chu '684 was a VoIP phone system. So we know,
`based on the disclosure in Chu '684 that you used an E.164
`phone number. That is a long, cumbersome phone number to put
`in, very much not like we're used to dialing a normal phone
`that would have been hanging in our kitchen on a standard
`PSTN network. There's two references, Chu '366 and Chen that
`we've used for the two combinations in this case, both
`disclose VoIP phone systems that allow a phone number to be
`reformatted so that you can dial in a way that you're used to
`dialing so that a VoIP phone system won't be a complete
`change to a user. They can pick that up and they can
`continue to dial just like they've always dialed from their
`standard PSTN phone.
` Chu '366 and Chen both have user specific profiles,
`that is what we talked about before, information about the
`caller that is specific to that caller, their location, their
`national dialing digit, their area code, information that is
`user specific. That's part one of how we're using these
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`references. That is not in dispute that these two are user
`specific profiles. Dr. Mangione-Smith, VoIP-Pal's expert,
`has agreed that both Chu '366 and Chen teach user specific
`dialing profiles. So the first part of these references is
`the user profile contains information about the dialer.
` DX12 gets us into the second part of these
`references. This brings us around to bringing a user back, a
`dialer, a caller back to a familiar dialing format. And here
`in DX12, we're looking at Chen. Chen allows a user to dial a
`phone in a manner similar to how they would have dialed a
`standard PSTN phone. And it follows a number reformatting
`process nearly identical in its Figure 6 to Figure 8B of the
`challenged patents.
` Looking at Figure 6 on the right side of DX12 from
`Chen, we see a flowchart that walks through the matching and
`reformatting process. This starts with a dial plan. And the
`dial plan is disclosed at paragraph 33 in Chen. And the dial
`plan includes an IDD, an NDD, country code and area code,
`information specific to that caller. Using that dial plan,
`which they call prefix-A in this figure, it receives the
`dialing number at 601 and then it proceeds to walk through
`each of these boxes in the flowchart to create a match.
` Here I've highlighted box 606 for our example.
`It's looking at the dial number, comparing that to the user
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`profile and comparing. And when we reach box 606, we see
`that here our national dialing digits match of the called
`number and the the caller profile. When that matches, it
`moves to box 607, which reformats the phone number to a
`standard E.164 format. The very same comparison and
`reformatting is shown on the left side of DX12 in Figure 8B.
`Box 380, a caller identifier, that's your dialed number,
`begins with the caller national dialing digits, the
`comparison to the NDD from the dial number to the NDD in the
`user profile. When those match, we see box 388 reformats the
`phone number.
` Moving to DX13, Chu '366 includes another almost
`identical figure here. Here in Chu '366, they have caller
`profiles, user profiles. In Chu '366, they're called call
`origin location profiles. Those are disclosed in column 2,
`line 9 to 13. The call origin location profile is a
`mouthful, but it's a user profile, a caller profile. That
`contains information such as geographic information on where
`you are, your area code and your country code. That is also
`run through a comparison to the dialed number.
` So starting with 156 and Figure 6 of Chu, we see
`that it's going to parse the number that you've dialed at
`which point it's going to begin comparing the number you
`dialed to the information in the caller profile. Box 172,
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`when you match a length from the dial number to a length
`that's in the caller profile, it proceeds to box 174, it
`reformats the phone number and puts it into E.164 format.
`Again, identical to Figure 8B, as shown on the left side,
`it's going to match the caller identifier length, the dialed
`number length to the length that's in the caller profile,
`it's then going to proceed to reformat the phone number.
` Our specific combinations here rest on taking Chu
`'684, which teaches a VoIP phone system that can send calls
`to either an IP phone, an on-net call, or a PSTN phone, an
`off-net call. And it processes and looks at phone numbers to
`make that determination. Then using the secondary references
`to teach that you would look at a user profile and to teach
`the reformatting, the steps we just walked through, to
`perform that functionality. Once the number is reformatted
`based on the match that we just discussed, Chu '684 uses that
`phone number, that reformatted phone number, to do a
`comparison into its database to look and see whether that's a
`subscriber, that would be a on-net call, or if it's not a
`subscriber, which would be an off-net to the PSTN call.
`Those are our specific combinations here.
` Now, there's two main arguments that VoIP-Pal has
`made in this case at a very high level. Their primary
`argument is their swear-behind effort and I'm going to come
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`back to that. I'm going to start with their other arguments
`on the substance of our combinations and the substance of our
`references. There they've identified three specific what
`they believe to be weaknesses; specific dialing conventions,
`enterprise versus user specific profiles, and then a
`challenge to the motivation to combine.
` Let's talk about special dialing conventions.
`Special dialing conventions, according to Patent Owner, are a
`requirement in Chu '684. We see here from their response,
`Patent Owner's response, their claim about how Chu '684 must
`work. Patent Owner's claiming in such a system, system of
`Chu '684, a user must do one of two things: One, dial a
`private number to place a call to another private IP phone,
`or, two, dial a PSTN access code such as 9 to reach an
`outside line.
` Patent Owner's contention here is that because you
`would either dial -- you must dial a private number to go to
`another IP phone such as an extension or a 9 to reach an
`outside line, you would never combine it with another
`reference that would reformat to then perform that comparison
`process. You'll notice there's no citation after this
`contention of what Chu '684 requires. There's no citation
`because Chu '684 does not actually teach these specific
`dialing conventions.
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`Case IPR2016-01198 (Patent 9,179,005 B2)
`Case IPR2016-01201 Patent 8,542,815, B2)
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` Moving to DX17. Dr. Mangione-Smith, Patent Owner's
`expert, admitted and could point to no teaching in Chu '684
`that suggested the prefix digits were required. When asked,
`"Can you point me to any specific teaching in Chu '684 that
`says a prefix digit," a 9 for example, "must be dialed to reach
`a destination callee on the PSTN?" he answered, "Off the top
`of my head, no." When asked if he relied on such a teaching,
`his answer was, "I don't recall if I relied upon it." He did
`not rely upon it because it doesn't exist.
` As we pressed him further, Dr. Mangione,
`admitted -- Dr. Mangione-Smith admitted -- and this is at
`page 147, lines 3 to 4 of his deposition -- that his guess --
`quote, "My guess is we dial 9 or 8 to get an outside line
`here," talking about how Chu '684 would operate. So he's
`making a guess as to how Chu '684 operates. He then
`continues on as we see the citation on DX18 on the top right
`side where he says, "I think that" -- that's difficult to
`read up there. What he says is that "I think that that's
`inherent in a PBX system unless told otherwise." So
`Dr. Mangione-Smith admitted that he's guessing there's an
`inherent limitation as to the prefix or privately dialing
`requirements.
` Two big problems with that. One,
`Dr. Mangione-Smith is not a telephony expert. He lists no
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`Case IPR2016-01201 Patent 8,542,815, B2)
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`telephony experience in his CV. He doesn't list any
`telephony experience or requirement for his definition of one
`of skill in the art. And he admitted he has never worked on
`any PBX system. He simply doesn't have the qualifications as
`a telephony expert to say what would have been inherent or
`make a guess about what would have been inherent in one of
`these systems.
` Even if you assume he is a great telephony expert,
`he is going against the expressed teaching of Chu '684, which
`is a much bigger problem. On DX19, we see that Chu '684 does
`not require a prefix digit, a 9, to dial out to the PSTN.
`There --
` JUDGE COCKS: Counsel, I have one quick question.
` MR. SEITZ: Yes, sir.
` JUDGE COCKS: Just to be clear. So do you agree
`that the claims of the '005 and '815 patent exclude the use
`of a prefix digit?
` MR. SEITZ: Do I agree that they exclude the use?
` JUDGE COCKS: Yes.
` MR. SEITZ: I don't believe they would require the
`use of that, no.
` JUDGE COCKS: So they do not require, but they do
`not exclude the use of a digit?
` MR. SEITZ: No, they would exclude because it's
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`Case IPR2016-01198 (Patent 9,179,005 B2)
`Case IPR2016-01201 Patent 8,542,815, B2)
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`comparing the dialed digits of the phone number to parse what
`we see in Figure 8, which does not involve a prefix digit.
` JUDGE COCKS: Go ahead. Okay. Thank you.
` MR. SEITZ: Chu '684 tells us very clearly from the
`dialed digits of a destination phone that is being called,
`PSTN phone, ingress soft-switch determines that this call is
`for the PSTN. So Chu '684 has an express disclosure that
`it's looking at the dialed digits of the PSTN phone to make
`the determination as to whether it is a public call for the
`PSTN. Again, contrary to what Dr. Mangione-Smith is saying.
` DX20 we see the same thing for the private dialing
`convention, dialing an extension, for example, on the IP
`network. Chu '684 teaches us -- and I touched on this
`briefly -- that each IP phone is assigned an E.164 phone
`number, that's the citation on the top right side of DX20.
`Chu '684 also teaches each here in the example on the bottom
`right from column 8:65 to 9:17, in the example of an on-net
`phone call to another on-net phone call at another location.
`Looking at the very bottom-sided portion, the outgoing call
`request message from server 110 to soft-switch 220 includes
`whether the number plan is private numbering plan or the
`public E.164 number plan.
` So the expressed disclosure of Chu '684 tells us
`that in an IP-to-IP phone call, an on-net situation, it will
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`look at whether the user has dialed an E.164 number of the
`other IP phone. So there's a clear disclosure in Chu '684,
`important for the public E.164 number here, the Patent Owner
`is excluding from this. So there's no requirement in
`Chu '684 that you dial a 9, no expressed requirement, and
`there is no expressed requirement that you only dial another
`IP phone through a private numbering scheme.
` Let's look at the next argument they've made, which
`is the enterprise versus user specific dialing profile.
`Here, Patent Owner has argued that we are misinterpreting the
`term "subscriber" in Chu '684 and denoting it as an
`individual caller or user when the disclosure of Chu '684
`refers to an enterprise as opposed to an individual caller.
`This seems to be based on a misunderstanding or a fundamental
`misinterpretation of how we have put forth our combinations
`in this case.
` Our combinations in this case clearly identify the
`user specific dialing profile from the secondary references
`being used instead of the enterprise dial plan or enterprise
`profile from Chu '684. If you look at our petitions in the
`'005, for example, limitation 1A, page 18 and page 42, we
`cite Chu '684, but we also include a citation to the user
`specific dialing plans from the secondary references. The
`user specific dial plans include the information about an
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`Case IPR2016-01201 Patent 8,542,815, B2)
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`individual user, not an enterprise user. And as we've
`already discussed, there's no debate, no dispute that our
`secondary references teach user specific dialing plans.
` We've also set forth, it's our contention our
`expert has described that this would be an easy combination.
`Chu '684 already has the necessary infrastructure to do a
`lookup of an individual user's information. We know
`Chu '684, from its expressed disclosure, includes a lookup to
`see what the E.164 number is for each individual IP phone.
`So the ability to look at an individual caller, an individual
`user, and match that IP phone and its IP decrease to an E.164
`number is already in Chu '684. It would be an easy
`combination because the infrastructure is already there to
`add the user specific caller profile with the more specific
`geographic information to Chu '684.
` Finally, that takes us to the motivation to combine
`arguments. Patent Owner has argued that we failed to provide
`any particularized reasoning for the motivation to combine.
`Let's start with the secondary references themselves. They
`provide some of the best explanation for a motivation to
`combine here. Recall Chu '684 is a VoIP phone system. It
`discusses assigning E.164 phone numbers to each of its IP
`phones. An E.164 number is a rather long number starting
`with a plus sign and then including your full international,
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`Case IPR2016-01198 (Patent 9,179,005 B2)
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`national dialing format. It's a long and cumbersome format.
` Chu here looking at DX25, Chu '366, discusses this
`problem and why it would be beneficial to have a system that
`allowed normal dialing. Chu -- looking at Chu '366 here,
`they talk about how when making telephones calls via a
`traditional PSTN, a subscriber can enter abbreviated numbers,
`the seven digit that we talked about, for local and national
`telephone calls.
` By contrast, there is no such concept of local,
`long distance or national calls when making a phone call via
`a Internet telephony. Chu '36 [sic] goes on to say, "Even
`when making a local phone call, within . . . the United States [in a
`VoIP system], instead of simply entering the seven digit
`telephone phone number, the VoIP subscriber must enter plus,
`[and] then the country code, [and] then the area code, [and] then
`the telephone number. This is time-consuming and bothersome,
`especially when subscribers are used to the concept of
`abbreviated telephone numbers for local and national calls
`with traditional PSTN systems." That cumbersome dialing is
`what was present in Chu '684.
` Chen includes a similar disclosure on DX26. There,
`Chen describes "A primary object of the present invention is
`to provide a communication method . . . so that a user in any
`region or country may place phone calls in a familiar manner."
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`Case IPR2016-01198 (Patent 9,179,005 B2)
`Case IPR2016-01201 Patent 8,542,815, B2)
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`Dr. Houh also provided additional explanation for the
`motivations to combine in his declarations. They c
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