IPR2016-01201
`Apple v. Voip-Pal
`
`I.
`
`Comparison of Petition at pp. 18-20 (Ground 1)
`With the Petition at pp. 39-41 (Ground 2)
`
`Petition at pp. 39-41
`(Chu ‘684 + Chen argument)
`There
`is
`significant overlap
`
`between Chu ’684 and Chu ’366Chen.
`Both
`references
`teach
`telecommunications systems in which
`VoIP subscribers can place calls to a
`customer on the public PSTN. Compare
`Ex. 10061003, Chu ’684 at 8:65-9:1
`(“At step 608, after receiving all the
`dialed digits from the phone 101, server
`110 consults its dial plan to determine
`whether the call is local, to another on-
`net phone, or to a phone that is on the
`PSTN.”) with Ex. 1007, Chu ’366 at
`14:30-33 (“[T]here is shown1004, Chen
`at Fig. 5 (Illustrating a system for
`communications between a computing
`202
`environment
`including
`the
`application program according to the
`present systemVoIP customer “SIP
`Phone,” external number Translator,
`“PSTN Gateway, and a PSTN telephone
`216.”Switch).
`Both references also teach a process in
`which dialed digits and caller attributes
`are used to determine where the call
`routed. Compare Ex.
`should be
`10061003, Chu ’684 at 8:65-9:1 (“At
`step 608, after receiving all the dialed
`digits from the phone 101, server 110
`consults
`its dial plan
`to determine
`whether the call is local, to another on-
`net phone, or to a phone that is on the
`PSTN.”) with Ex. 1007, Chu ’3661004,
`Chen at Fig. 6. Finally, both references
`expressly
`reference E.164
`as
`an
`
`
`
`Petition at pp. 18-20
`(Chu ‘684 + Chu ‘366 argument)
`There
`is
`significant overlap
`
`between Chu ’684 and Chu ’366. Both
`references
`teach
`telecommunications
`systems in which VoIP subscribers can
`place calls to a customer on the public
`PSTN. Compare Ex. 1006, Chu ’684 at
`8:65-9:1 (“At step 608, after receiving
`all the dialed digits from the phone 101,
`server 110 consults its dial plan to
`determine whether the call is local, to
`another on-net phone, or to a phone that
`is on the PSTN.”) with Ex. 1007, Chu
`’366 at 14:30-33 (“[T]here is shown a
`system for communications between a
`computing environment 202 including
`the application program according to the
`present system and a PSTN telephone
`216.”).
`
`
`
`Both references also teach a process in
`which dialed digits and caller attributes
`are used to determine where the call
`should be routed. Compare Ex. 1006,
`Chu ’684 at 8:65-9:1 (“At step 608,
`after receiving all the dialed digits from
`the phone 101, server 110 consults its
`dial plan to determine whether the call is
`local, to another on-net phone, or to a
`phone that is on the PSTN.”) with Ex.
`1007, Chu ’366 at Fig. 6. Finally, both
`references expressly reference E.164 as
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`IPR2016-01201
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`

`
`plan.
`dial
`standard
`international
`Compare Ex. 10061003, Chu ’684 at
`3:59-61 (“[E]ach IP phone [may be]
`assigned its own E.164 number (the
`international standard dial plan) and
`receiving
`calls
`from
`the PSTN
`1007, Chu
`directly.”) with Ex.
`’3661004, Chen at 1:18-20¶ 006
`(“E.164 [ ] provides a uniform means
`for identifying any telephone number in
`the world to any telephony user in the
`world.”). is an ITU-T (International
`Telecommunication
`Union
`Telecommunication
`Standardization
`Sector) recommendation that defines the
`international public telecommunication
`numbering plan.”).
`
`
`
`It would have been obvious to
`one of skill in the art to modify the
`system described by Chu ’684 with the
`specific
`dialed
`digit
`reformatting
`teachings of Chu ’366Chen. Given that
`the system of Chu ’684 already contains
`all the infrastructure needed to support
`such reformatting, the modification to
`Chu ’684 would be straightforward, not
`requiring undue experimentation, and
`would produce predictable results. Upon
`reading the disclosure of Chu ’684, a
`person of ordinary skill in the art would
`have recognized that allowing users to
`place calls as if they were dialing from a
`standard PSTN phone would be
`desirable, creating a system capable of
`supporting a more intuitive and user-
`friendly interface. See Ex. 10091006,
`Houh Decl. at ¶¶ 35-39.40-44.
`
`IPR2016-01201
`Apple v. Voip-Pal
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`international standard dial plan.
`an
`Compare Ex. 1006, Chu ’684 at 3:59-61
`(“[E]ach IP phone [may be] assigned its
`own E.164 number (the international
`standard dial plan) and receiving calls
`from the PSTN directly.”) with Ex.
`1007, Chu ’366 at 1:18-20 (“E.164 [ ]
`provides
`a
`uniform means
`for
`identifying any telephone number in the
`world to any telephony user in the
`world.”).
`
`
`
`It would have been obvious to
`one of skill in the art to modify the
`system described by Chu ’684 with the
`specific
`dialed
`digit
`reformatting
`teachings of Chu ’366. Given that the
`system of Chu ’684 already contains all
`the infrastructure needed to support such
`reformatting, the modification to Chu
`’684 would be straightforward, not
`requiring undue experimentation, and
`would produce predictable results. Upon
`reading the disclosure of Chu ’684, a
`person of ordinary skill in the art would
`have recognized that allowing users to
`place calls as if they were dialing from a
`standard PSTN phone would be
`desirable, creating a system capable of
`supporting a more intuitive and user-
`friendly interface. See Ex. 1009, Houh
`Decl. at ¶¶ 35-39.
`
`
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`IPR2016-01201
`Apple v. Voip-Pal
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`
`
`One of ordinary skill would thus
`appreciated
`that
`these
`have
`improvements to Chu ’684 could be
`achieved by merely programming the
`system of Chu ’684 to analyze the
`dialed digits and reformat as necessary
`using caller attributes such as national
`and area code. Such modifications are
`simply a combination of the system of
`’684 with elements of Chu
`Chu
`that would have yielded
`’366Chen
`predictable results without requiring
`undue experimentation. IdSee id. at ¶
`3843. Thus, it would have been natural
`and an application of nothing more than
`ordinary skill and common sense to
`combine Chu ’684 with the number
`reformatting of Chu ’366Chen. Id.
`Therefore, claims 1, 7, 27-28, 34, 54,
`72-74, 92-93, and 111 of the ’815 Patent
`are unpatentable under §103(a) as
`obvious over Chu ’684 in view of Chu
`’366Chen, as shown in the charts below.
`
`
`
`
`One of ordinary skill would thus
`appreciated
`that
`these
`have
`improvements to Chu ’684 could be
`achieved by merely programming the
`system of Chu ’684 to analyze the
`dialed digits and reformat as necessary
`using caller attributes such as national
`and area code. Such modifications are
`simply a combination of the system of
`Chu ’684 with elements of Chu ’366
`that would have yielded predictable
`results without
`requiring
`undue
`experimentation. Id. at ¶ 38. Thus, it
`would have been natural and an
`application of nothing more
`than
`ordinary skill and common sense to
`combine Chu ’684 with the number
`Id.
`reformatting
`of Chu
`’366.
`Therefore, claims 1, 7, 27-28, 34, 54,
`72-74, 92-93, and 111 of the ’815 Patent
`are unpatentable under §103(a) as
`obvious over Chu ’684 in view of Chu
`’366, as shown in the charts below.
`
`
`
`
`
`
`
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`IPR2016-01201
`Apple v. Voip-Pal
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`II. Comparison of Petition at pp. 20-36 (Ground 1)
`With the Petition at pp. 41-58 (Ground 2)
`
`
`Right-hand column compares:
`
`the claim chart for Chu ‘684 + Chu ‘366 (Ground 1) with
`the claim chart for Chu ‘684 + Chen (Ground 2).
`Red strikethrough represents text in Ground 1, but not in Ground 2.
`Blue underline represents text in Ground 2, but not in Ground 1.
`[underlining in original omitted]
`
`
`
`US Patent 8,542,815
`
`1. A process for operating a
`call routing controller to
`facilitate communication
`between callers and callees
`in a system comprising a
`plurality of nodes with
`which callers and callees
`are associated, the process
`comprising:
`
`Obvious over Chu ’684 (Ex. 1003) in view of Chu
`’366Chen (Ex. 1004)1005)
`
`Chu ’684 teaches a process for operating a soft-
`switch (“call routing controller”)
`to
`facilitate
`telephone calls (“communication”) between callers
`and callees, each of which is associated with one of a
`plurality of network nodes.
`
`Chu ’684 describes “a novel method for establishing
`and managing voice call traffic in an VoIP IP virtual
`private network. The method comprises, in one
`embodiment, determining the relative location of a
`terminating point with respect to an originating point
`of a new communication containing the voice data,
`determining one or more IP addresses to egress the
`communication from the originating point to the
`terminating point.” Ex. 1003, Chu ’684 at 2:34-44.
`
`“An apparatus for IP-based VPN communications
`includes at least one soft-switch and at least one
`packet switch having an interface to said at least one
`soft-switch. The packet switch has a VPN processing
`module for selectively establishing a VPN based on a
`selection of originating and terminating IP addresses
`of voice calls passed to the at least one soft-switch
`and at least one packet switch. . . . The apparatus
`may further include a PSTN gateway connected to a
`gateway soft-switch and said at least one soft-switch
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`(a) in response to initiation
`of a call by a calling
`subscriber, receiving a
`caller identifier and a callee
`identifier;
`
`(b) locating a caller dialing
`profile comprising a
`username associated with
`the caller and a plurality of
`calling attributes associated
`with the caller;
`
`for processing “off-net” calls.” Id. at 2:51- 64; see
`also id. at 1:9-13.
`
`Chu ’684 teaches servers and soft-switches that
`receive subscriber identification (e.g., IP address
`and ID of IP phone connection to server) and dialed
`digits of the called party (“caller identifier and
`callee identifier”) when a caller initiates a call.
`
`“The soft-switch is the intelligence of the system. It
`contains all the information regarding the
`subscribers' VPNs. For example, it keeps track of the
`VPN that a location belongs to, the dial plans of the
`subscribers, the VPN identifier for an VPN (or a
`particular interface) and the like.” Id. at 4:59-63.
`
`“At step 608, after receiving all the dialed digits from
`the phone 101, server 110 consults its dial plan to
`determine whether the call is local, to another on-net
`phone, or to a phone that is on the PSTN. . . . The
`server 110 then sends an SIP “invite” message to
`soft-switch 220 at the central office 205. . . . The out-
`going call request message from server 110 to soft-
`switch 220 includes the following information . . . :
`(1) the called number; (2) whether the number plan is
`the private numbering plan or the public E.164
`number plan; (3) the ID of the connection to used [ ];
`(4) the IP address of IP phone 101 and UDP port
`number for the backward and forward channels; and
`(5) other parameters required for enhanced services
`and features.” Id. at 8:65-9:26 (emphasis added).
`Chu ’684 teaches locating a subscriber’s dial plan
`that includes a unique subscriber identifier (e.g.,
`E.164 telephone number) (“username”) and calling
`attributes of the subscriber.
`
`“The soft-switch is the intelligence of the system. It
`contains all the information regarding the
`subscribers' VPNs. For example, it keeps track of the
`VPN that a location belongs to, the dial plans of the
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`IPR2016-01201
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`(c) determining a match
`when at least one of said
`calling attributes matches at
`
`subscribers, the VPN identifier for an VPN (or a
`particular interface) and the like.” Id. at 4:59-63.
`
`“[U]pon receipt of the SIP “invite” message from the
`server 110, the soft-switch 220 consults the dial plan
`for this subscriber. The dial plan to use can be
`determined from the ID of the server 110.” Id. at
`9:30-33.
`
`“Many subscribers, each with multiple locations, can
`be served by the same packet-switch/soft-switch
`network. Each subscriber can use their the [sic] own
`IP address plan as well as their own dial plan. To
`each subscriber, it appears that all their locations are
`connected by a private network, although the same
`network is used to serve multiple subscribers.” Id. at
`12:60-66; see also id. at 3:56-64 (noting each IP
`phone can be assigned its own E.164 number and IP
`address); Ex. 1006, Houh Declaration at ¶ 45 (noting
`that because multiple subscribers can be associated
`with a single server, a subscriber’s dial plan, in
`addition to an ID of the server, must necessarily
`include unique subscriber-specific information such
`as an E.164 telephone number, globally unique
`database key, or the like).
`
`Additionally, Chu ’366Chen teaches establishing a
`caller dial plan that users may set up “call origin
`profiles” that include calling includes attributes of
`the calling party such as geographic location,
`country code, and area code.
`
`Ex. 1004, Chu ’366Chen at 2:9-15¶ 0033 (describing
`call origin location profiles).dial plan); see also id. at
`Fig. 6 (illustrating the caller’s country code and area
`code appended to dialed digits to create an E.164
`compliant number).
`As illustrated in Fig. 8B of the ’815 Patent, an initial
`“match” between the dialed digits (“callee
`identifier”) and calling attributes determines
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`least a portion of said callee
`identifier; (d) classifying
`the call as a public network
`call when said match meets
`public network
`classification criteria and
`classifying the call as a
`private network call when
`said match meets private
`network classification
`criteria;
`
`whether the dialed digits must be reformatted in
`order to identify the intended callee. Once
`reformatted (e.g., NDD removed and caller country
`code prepended), the reformatted callee identifier is
`used to determine whether the callee is a subscriber
`on the private network or is a customer on the public
`network, i.e., whether “public network classification
`criteria” or “private network classification criteria”
`are met. The combination of Chu ’684 and Chu
`’366Chen performs this precise process.
`
`Chu ’366Chen teaches reformatting dialed digits to
`generate an E.164 compliant callee identifier when
`dialed digits “match” caller attributes, e.g., when the
`dialed digits equal the national dialing length of the
`caller’s origin designationan NDD prefix in the
`caller’s dial plan.
`
`“The intelligent VoIP formatting system includes a
`presentation and user interface layer, an E.164
`formatting engine, a location routine, and a database
`of telephone number data which are used to
`deconstruct input telephone numbers and reconstruct
`them as E.164 compliant telephone numbers.” Id. at
`Abstract.
`
`“According to the present system, a user is able to
`enter telephone numbers for VoIP telephone calls as
`they would according to a traditional telephone
`numbering plan for land-line telephone calls. . . . The
`E.164 formatting engine receives the entered phone
`number and retrieves the call origin location.” Id. at
`1:67-2:20 (emphasis added); see also id. at 2:46-53.
`
`“In step 172, if the number of digits entered in a
`telephone number equals the national length of
`telephone numbers in the country of the call origin
`location (e.g., ten digits in the United States), the
`engine 102 interprets this as a call somewhere within
`the country of the designated call origin location.
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`IPR2016-01201
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`(e) when the call is
`classified as a private
`network call, producing a
`private network routing
`message for receipt by a
`call controller, said private
`
`Accordingly, in step 174, the engine 102
`concatenates the E.164 prefix, the country code for
`the country of the designated call origin location and
`the entered telephone number to form a fully
`formatted E.164 telephone number.” Id. at 2:14-22
`(emphasis added).“In the present invention, each
`translation function has a corresponding dial plan,
`and each dial plan has the following components
`needed by either the translation-1 or the translation-
`2: (1) IDD prefix, (2) NDD prefix, (3) Country code,
`and (4) Area code.” Id. at ¶ 0033; see also id. at ¶¶
`0035-0040.
`
`Compare Id.id. at Fig. 6 (illustrating numerous
`number match and reformatting scenarios based on
`matching, including, e.g., Cells 606-607 where E.164
`compliant number created by removing NDD prefix
`and prepending caller’s country code when dialed
`digits to caller attributesequal NDD prefix) with Ex.
`1001, ‘815 Patent at Fig. 8B (same at Cells 380-
`388).
`
`Once the callee identifier is reformatted, Chu ’684
`determines whether the callee is a private packet
`network subscriber or a public PSTN customer (i.e.,
`whether the call “meets public network classification
`criteria” or “private network classification
`criteria”).
`
`“At step 608, after receiving all the dialed digits from
`the phone 101, server 110 consults its dial plan to
`determine whether the call is local, to another on-net
`phone, or to a phone that is on the PSTN.” Ex. 1003,
`Chu ’684 at 8:65-9:1.
`Chu ’684 teaches generating a private network
`routing message identifying an IP address of the
`egress packet switch (“address, on the private
`network, associated with the callee”) when the call is
`classified as private.
`
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`IPR2016-01201
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`network routing message
`identifying an address, on
`the private network,
`associated with the callee;
`
`(f) when the call is
`classified as a public
`network call, producing a
`public network routing
`message for receipt by the
`call controller, said public
`network routing message
`identifying a gateway to the
`public network.
`
`“At step 610, upon receipt of the SIP “invite”
`message from the server 110, the soft-switch 220
`consults the dial plan for this subscriber. The dial
`plan to use can be determined from the ID of the
`server 110. In this example, the call is to another on-
`net phone in another location. From the database
`associated with the dial plan, soft-switch 220
`determines the following: (1) the IP address of the
`egress packet switch; (2) the connection to use as the
`next hop for the bearer traffic; and (3) the IP address
`of the soft-switch of the next hop packet switch.
`Once the soft-switch 220 has determined this
`information, it sends H.248 commands to packet
`switch 210.” Id. at 9:30-49 (emphasis added); see
`also id. at Figs. 6-11, 14a, 4:52-56 (describing a first
`soft-switch sending routing message to a second soft-
`switch, which controls the egress packet switch).
`Chu ’684 teaches generating a public network
`routing message identifying a gateway to the public
`PSTN when the call is classified as terminating to a
`public PSTN customer.
`
`“For connectivity to the PSTN, gateways 1302 are
`deployed in the network 200. For an outgoing call
`from an originating point phone (IP phone 101 in
`FIG. 13), the operation is very similar to that of an
`intra-net call. From the dialed digits (of a destination
`phone that is being called, PSTN phone 1301),
`ingress soft switch 220, determines that this call is
`for the PSTN. From the same dialed digits, the soft-
`switch also determines the egress PSTN gateway
`1302 and its controlling soft-switch 1304. The
`ingress soft-switch 220 will proceed the call
`signaling and control as described previously. The
`gateway 1302 acts as an “egress packet switch”
`having modifications.” Id. at 13:12-34 (emphasis
`added); see also id. at 4:52-56 (describing a first soft-
`switch sending routing message to a second soft-
`switch, which controls the egress PSTN gateway),
`Fig. 13.
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`7. The process of claim 1
`further comprising
`formatting said callee
`identifier into a pre-defined
`digit format to produce a
`re-formatted callee
`identifier.
`
`27. A non-transitory
`computer readable medium
`encoded with codes for
`directing a processor to
`execute a method of
`operating a call routing
`controller to facilitate
`communication between
`callers and callees in a
`system comprising a
`plurality of nodes with
`which callers and callees
`are associated, the method
`comprising:
`(a) in response to initiation
`of a call by a calling
`subscriber, receiving a
`caller identifier and a callee
`identifier;
`(b) locating a caller dialing
`profile comprising a
`username associated with
`the caller and a plurality of
`calling attributes associated
`with the caller;
`(c) determining a match
`when at least one of said
`
`Chu ’366Chen teaches reformatting dialed digits
`(“callee identifier”) to generate an E.164 compliant
`calleecalled party identifier.
`
`See Chu ’366Chen disclosures set forth at claim
`element 1(c-d).
`
`Compare Ex. 1004, Chu ’3661005, Chen at Fig., 6
`(illustrating numerous number reformatting scenarios
`based on matching the caller’s country code and area
`code appended to dialed digits to caller
`attributescreate an E.164 compliant number) with Ex.
`1001, ‘815 Patent at Fig. 8B (same).
`See disclosure set forth at claim element 1
`(preamble).
`
`See disclosure set forth at claim element 1(a).
`
`See disclosure set forth at claim element 1(b).
`
`See disclosure set forth at claim element 1(c-d).
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`calling attributes matches at
`least a portion of said callee
`identifier;
`(d) classifying the call as a
`public network call when
`said match meets public
`network classification
`criteria and classifying the
`call as a private network
`call when said match meets
`private network
`classification criteria;
`(e) when the call is
`classified as a private
`network call, producing a
`private network routing
`message for receipt by a
`call controller, said private
`network routing message
`identifying an address, on
`the private network,
`associated with the callee;
`and
`(f) when the call is
`classified as a public
`network call, producing a
`public network routing
`message for receipt by a
`call controller, said public
`network routing message
`identifying a gateway to the
`public network.
`28. A call routing apparatus
`for facilitating
`communications between
`callers and callees in a
`system comprising a
`plurality of nodes with
`which callers and callees
`are associated, the
`
`See disclosure set forth at claim element 1(c-d).
`
`See disclosure set forth at claim element 1(e).
`
`See disclosure set forth at claim element 1(f).
`
`See disclosure set forth at claim element 1
`(preamble).
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`apparatus comprising:
`(a) receiving means for
`receiving a caller identifier
`and a callee identifier, in
`response to initiation of a
`call by a calling subscriber;
`
`(b) means for locating a
`caller dialing profile
`comprising a username
`associated with the caller
`and a plurality of calling
`attributes associated with
`the caller;
`
`(c) means for determining a
`match when at least one of
`said calling attributes
`matches at least a portion
`of said callee identifier; (d)
`means for classifying the
`call as a public network call
`
`As described in Section III.C.2(a), the corresponding
`structure for “receiving means” is I/O (input/output)
`port 208. Chu ’684 teaches servers and soft-switches,
`all of which necessarily include I/O ports, that
`receive subscriber identification (e.g., IP address
`and ID of IP phone connection to server) and dialed
`digits of the called party (“caller identifier and
`callee identifier”) when a caller initiates a call.
`
`See disclosure set forth at claim element 1(a). See
`also, Ex. 1006, Houh Declaration at ¶ 47
`(concluding that the servers and soft-switches
`disclosed by Chu ’684 necessarily include I/O ports
`that are equivalent to the disclosed I/O Port 208).
`As described in Section III.C.2(b), the corresponding
`structure for “means for locating” is a processor
`circuit programmed to implement the algorithm
`disclosed in cell 254 of Fig. 8A. Chu ’684 teaches a
`subscriber’s and Chen teach caller dial plan and
`Chu ’366 teaches “call origin profiles,”plans, both
`of which are necessarily located by a processor
`circuit programmed with algorithms equivalent to
`cell 254.
`
`See disclosure set forth at claim element 1(b). See
`also, Ex. 1006, Houh Declaration at ¶ 48
`(concluding that the caller dialing profiles taught by
`Chu ’684 and Chu ’366Chen are necessarily located
`by processors programmed with algorithms
`equivalent to the disclosed RC processor circuit 200
`programmed to implement the algorithm disclosed in
`cell 254 of Fig. 8A).
`As described in Section III.C.2(c), the corresponding
`structure for these limitations“means for
`determining” is a processor for implementing one or
`more branch of the algorithm in Fig. 8B. The
`combination of Chu ’684 and Chu ’366Chen
`determines when a portion of the dialed digits (callee
`identifier) matches calling attributes (e.g., dialing
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`
`when said match meets
`public network
`classification criteria; (e)
`means for classifying the
`call as a private network
`call when said match meets
`private network
`classification criteria;
`
`(f) means for producing a
`private network routing
`message for receipt by a
`call controller, when the
`call is classified as a private
`network call, said private
`network routing message
`identifying an address, on
`the private network,
`associated with the callee;
`and
`
`(g) means for producing a
`public network routing
`message for receipt by a
`call controller, when the
`call is classified as a public
`network call, said public
`network routing message
`identifying a gateway to the
`public network.
`
`length, area code, etc.) in order to reformat the
`callee identifier as necessary and to then determine if
`the callee is on the public or private network, which
`is equivalent to the algorithm in Fig. 8B.
`
`See disclosure set forth at claim element 1(c-d). See
`also, Ex. 1006, Houh Declaration at ¶ 49
`(concluding that the combination of Chu ’684 and
`Chu ’366Chen implements an algorithm equivalent
`to the processor-implemented algorithm of Fig. 8B).
`As described in Section III.C.2(d), the corresponding
`structure for “means for producing” is a processor
`circuit programmed to implement the algorithm
`illustrated in cell 350 of FIG. 8A and cell 644 of Fig.
`8C. Chu ’684 teaches generating a private network
`routing message identifying an address on the
`private packet network that is necessarily located by
`a processor circuit.
`
`See disclosure set forth at claim element 1(e). See
`also, Ex. 1006, Houh Declaration at ¶ 50
`(concluding that the routing message generation
`taught by Chu ’684 is necessarily performed by a
`processor equivalent to the disclosed processor 202
`of RC processor circuit 200, programmed to
`implement the algorithms illustrated in cell 350 of
`FIG. 8A and cell 644 of Fig. 8C).
`As described in Section III.C.2(d), the corresponding
`structure for “means for producing” is a processor
`circuit programmed to implement the claimed
`function. Chu ’684 teaches generating a public
`network routing message identifying a gateway to the
`public PSTN that is necessarily located by a
`processor circuit.
`
`See disclosure set forth at claim element 1(f). See
`also, Ex. 1006, Houh Declaration at ¶ 50
`(concluding that the routing message generation
`taught by Chu ’684 is necessarily performed by a
`processor equivalent to the disclosed processor 202
`
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`
`

`
`IPR2016-01201
`Apple v. Voip-Pal
`
`34. The apparatus of claim
`28 further comprising
`formatting means for
`formatting said callee
`identifier into a pre-defined
`digit format to produce a
`re-formatted callee
`identifier.
`
`54. A process for operating
`a call routing controller to
`establish a call between a
`caller and a callee in a
`communication system, the
`process comprising:
`(a) in response to initiation
`of a call by a calling
`subscriber, locating a caller
`dialing profile comprising a
`plurality of calling
`attributes associated with
`the caller; and
`(b) when at least one of
`said calling attributes and
`at least a portion of a
`
`callee identifier associated
`with the callee match and
`when the match meets a
`private network
`
`of RC processor circuit 200, programmed to
`implement the claimed function).
`As described in Section III.C.2(f), the corresponding
`structure for “formatting means” is a processor for
`implementing one or more branch of the algorithm in
`Fig. 8B. Chu ’366Chen teaches reformatting dialed
`digits to generate an E.164 compliant called party
`identifier by comparing the dialed digits to specific
`attributes of the calling party, e.g., a dial plan
`including at least a national code and area code of
`the call origin locationcaller, which is equivalent to
`the algorithm in Fig. 8B.
`
`See disclosure set forth at claim 7.
`
`See also, Ex. 1006, Houh Declaration at ¶ 49
`(concluding that the combination of Chu ’684 and
`Chu ’366Chen implements an algorithm for
`formatting the callee identifier that is equivalent to
`the processor-implemented algorithm of Fig. 8B).
`See disclosure set forth at claim element 1
`(preamble).
`
`See disclosure set forth at claim elements 1(a-b).
`
`See disclosure set forth at claim elements 1(c-e).
`
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`
`

`
`IPR2016-01201
`Apple v. Voip-Pal
`
`classification criterion,
`producing a private
`network routing message
`for receipt by a call
`controller, said private
`network routing message
`identifying an address, on a
`private network, the
`address being associated
`with the callee; and
`(c) when at least one of
`said calling attributes and
`said at least said portion of
`said callee identifier
`associated with the callee
`match and when the match
`meets a public network
`classification criterion,
`producing a public network
`routing message for receipt
`by a call controller, said
`public network routing
`message identifying a
`gateway to a public
`network.
`72. The process of claim 54
`further comprising causing
`the private network routing
`message or the public
`network routing message to
`be communicated to a call
`controller to effect routing
`of the call.
`
`See disclosure set forth at claim elements 1(c-d & f).
`
`Chu ’684 teaches a soft-switch that sends routing
`messages to a second soft-switch (“call controller”)
`which controls the egress packet switch for a private
`VoIP call and to the PSTN gateway for call
`terminating to the public PSTN.
`
`“The soft-switch 220, based on requests from the
`server 110 or peer soft-switches (explained in greater
`detail below), sends the appropriate commands to
`packet switch 210 to set up the appropriate cross-
`connects.” Ex. 1003, Chu ’684 at 4:52-56; see also
`id. at 9:30-49 (describing private routing message for
`calls to “on-net phone in another location”); id. at”),
`Figs. 6-11, 14a, 13:12-34 (describing public routing
`message for calls to PSTN), Fig. 13.
`
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`
`

`
`IPR2016-01201
`Apple v. Voip-Pal
`
`73. A non-transitory
`computer readable medium
`encoded with codes for
`directing a processor to
`execute the method of
`claim 54.
`
`74. A call routing controller
`apparatus for establishing a
`call between a caller and a
`callee in a communication
`system, the apparatus
`comprising:
`(a) a processor operably
`configured to: access a
`database of caller dialing
`profiles wherein each
`dialing profile associates a
`plurality of calling
`attributes with a respective
`subscriber, to locate a
`dialing profile associated
`with the caller, in response
`to initiation of a call by a
`calling subscriber; and
`(b) produce a private
`network routing message
`for receipt by a call
`controller, said private
`network routing message
`identifying an address, on a
`private network, through
`which the call is to be
`routed, when at least one of
`said calling attributes and
`at least a portion of a callee
`identifier associated with
`the callee match and when
`the match meets a private
`network classification
`
`One of skill in the art would understand that the soft-
`switch and packet switch functionalities described in
`Chu ’684 are necessarily implemented in software,
`which necessarily involves codes for directing a
`processor to implement the method steps
`describeddescribes in the excerpts above. Ex. 1006,
`Houh Declaration at ¶ 53.
`See disclosure set forth at claim element 1
`(preamble).
`
`See disclosure set forth at claim elements 1(a-b).
`
`See disclosure set forth at claim elements 1(c-e).
`
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`
`

`
`IPR2016-01201
`Apple v. Voip-Pal
`
`criterion, the address being
`associated with the callee;
`and
`(c) produce a public
`network routing message
`for receipt by a call
`controller, said public
`network routing message
`identifying a gateway to a
`public network, when at
`least one of said calling
`attributes and said at least
`said