EXHIBIT 2041
`
`LISTING OF SECTION 112 WRITTEN DESCRIPTION SUPPORT FOR
`THE PROPOSED SUBSTITUTE CLAIM 184 (ORIGINAL CLAIM 143)
`
`As stated on the first page of the ’113 Patent, it issued from Application No.
`
`12/821,119, filed on June 22, 2010 (herein referred to as the ’119 App.) (Ex. 2066).
`
`The ’119 App. was a continuation of application 11/948,965, filed on November 30,
`
`2007 (herein referred to as the ’965 App.) (Ex. 2042). The ’965 App was a divisional
`
`of Application No. 10/426,279, filed on April 30, 2003 (Ex. 2043), and, as such, has
`
`an identical disclosure (excluding, the Abstract and Claims) (herein referred to as
`
`the ’279 App.). The ’279 App., was a continuation-in-part of Application No.
`
`09/565,565, filed on May 4, 2000 (Ex. 2044) (herein referred to as the ’565 App.).
`
`The ’113 Patent claims priority to the ’565 App.
`
`As between the ’119 App. and ’565 App., the major difference is the later filed
`
`’119 App. contains two additional figures (Figs. 9-10) as well as additional
`
`disclosure associated with those figures. This added disclosure is found in col. 7, ln.
`
`55 – col. 12, ln. 20 of the ’113 Patent. The remaining portions of the two documents
`
`are much more similar than they are different. As for Figures 1-8 in the two
`
`documents, they contain the same disclosure, but are somewhat visually distinct.
`
`Line numbers have been added to the ’119, ’965, ’279, and ’565 Apps. The
`
`charts below show where support is found for the Proposed Substitute Claims in the
`
`’119, ’965, ’279, and ’565 Apps.
`
`1
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 1
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`LISTING OF SECTION 112 WRITTEN DESCRIPTION SUPPORT FOR
`THE PROPOSED SUBSTITUTE CLAIM 184 (ORIGINAL CLAIM 143)
`
`As stated on the first page of the ’113 Patent, it issued from Application No.
`
`12/821,119, filed on June 22, 2010 (herein referred to as the ’119 App.) (Ex. 2066).
`
`The ’119 App. was a continuation of application 11/948,965, filed on November 30,
`
`2007 (herein referred to as the ’965 App.) (Ex. 2042). The ’965 App was a divisional
`
`of Application No. 10/426,279, filed on April 30, 2003 (Ex. 2043), and, as such, has
`
`an identical disclosure (excluding, the Abstract and Claims) (herein referred to as
`
`the ’279 App.). The ’279 App., was a continuation-in-part of Application No.
`
`09/565,565, filed on May 4, 2000 (Ex. 2044) (herein referred to as the ’565 App.).
`
`The ’113 Patent claims priority to the ’565 App.
`
`As between the ’119 App. and ’565 App., the major difference is the later filed
`
`’119 App. contains two additional figures (Figs. 9-10) as well as additional
`
`disclosure associated with those figures. This added disclosure is found in col. 7, ln.
`
`55 – col. 12, ln. 20 of the ’113 Patent. The remaining portions of the two documents
`
`are much more similar than they are different. As for Figures 1-8 in the two
`
`documents, they contain the same disclosure, but are somewhat visually distinct.
`
`Line numbers have been added to the ’119, ’965, ’279, and ’565 Apps. The
`
`charts below show where support is found for the Proposed Substitute Claims in the
`
`’119, ’965, ’279, and ’565 Apps.
`
`1
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 1
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`SUPPORT FOR PROPOSED SUBSITUTE CLAIM 184 IN THE ’119 APP
`
`Figs. 1 and 5
`
`’119 App, 11:6-8 and 11:21-22
`
`
`“[0042] FIG. 5 is a flowchart of actions taken by the
`TAC 10 in response to an inbound call (using the
`subscriber's public phone number) to the subscriber.”
`
`“[0043] Incoming call data is received by the TAC 10
`from the tandem switch 16.”
`
`Fig. 2
`
`’119 App, 9:17-29
`
`
`“Rather, it redirects calls to subscribers. The
`TAC 10 provides intelligent interconnection between a
`calling party and a subscriber.
`[0036] The reader should keep in mind that although
`only one tandem switch 16 is shown in FIG. 1, the
`invention will apply equally well to a network of
`tandem switches, as shown in FIG. 2. FIG. 2 also
`illustrates how the subscriber can make calls using
`voice over IP via a conventional digital telephone 21.
`[0037] FIG. l illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`
`A method of providing an intelligent
`interconnection at a tandem access controller
`between a first communication network and a
`second communication network, comprising:
`
`
`
`
`
`
`
`
`
`2
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 2
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`receiving at the tandem access controller a first
`request to establish a first incoming call and call
`data which is associated with the first request to
`establish the first incoming call via a first
`communication network,
`
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser.”
`
`Fig. 5, Box 2
`
`’119 App, 8:28 – 9:2 and 13:14-22
`
`
`“[0034] The PSTN tandem switch 16 directs a first call
`(from the calling party 20 to the subscriber's phone 14
`using the subscriber's public phone number) to the
`TAC 10, which in turn places a second call, subject to
`3rd-party control information, to the subscriber's
`"private" phone number without yet terminating the
`first call.”
`
`“[0051] Certain advantages that can be obtained using
`the invention include the following:
`Web-Based Telecom Navigator
`Manage Incoming Call Control
` • Conditional Call Blocking/Forwarding/Alerting
` • Time-of-Day, Day-of-Week, Follow-Me, Caller
` Recognition/Password
`• Caller ID, etc.”
`
`
`Figs. 2 and 5, Boxes 2 and 3
`
`’119 App, 8:7 – 9:13
`
`
`
`
`3
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 3
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`“[0032] FIG. l shows a tandem access controller
`(TAC) 10 that allows an authorized subscriber 12 to
`establish 3rd-party control criteria for calls to the
`subscriber's telephone 14 (having a "public" phone
`number that callers dial). In one embodiment, the
`TAC 10 is a programmed processor. The TAC 10 may
`use any combination of hardware, firmware, or
`software and, in one embodiment, is a conventional
`computer programmed to carry out the functions
`described herein.
`[0033] The TAC 10 is connected to or inside the
`conventional PSTN tandem switch 16 such that calls
`may flow through the TAC 10 in the same manner as
`the existing PSTN tandem switch, except that
`additional 3rd-party features are applied to the call. As
`is well known, PSTN tandem switches are exchanges
`that direct telephone calls (or other traffic) to central
`offices 17, 18 or to other tandem switches. Details of
`the operation of the existing phone network may be
`found in the publication entitled "New Net SS7
`Tutorial," by ADC Telecommunications, copyright
`1999, incorporated herein by reference. Additional
`details may be found in the numerous books describing
`the PSTN.
`[0034] The PSTN tandem switch 16 directs a first call
`(from the calling party 20 to the subscriber's phone 14
`using the subscriber's public phone number) to the
`TAC 10, which in turn places a second call, subject to
`3rd-party control information, to the subscriber's
`4
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 4
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`"private" phone number without yet terminating the
`first call. The TAC 10 is connected within the
`subscriber's local service area so calls from TAC 10 to
`the subscriber do not incur a toll. When the subscriber
`12 terminates (or answers) the second call, the TAC 10
`terminates the first call and connects it to the second
`call, thereby connecting the calling party 20 to the
`subscriber 12. Hence, the calling party essentially
`calls the TAC 10, using the subscriber's public phone
`number, and the TAC 10, after processing the call
`using the selected features, calls the subscriber, as
`appropriate, using the subscriber's private phone
`number and connects the two calls. The process is
`transparent to the parties.”
`
`’119 App, 10:10 (“Receives SS7 data indicating an
`incoming call”)
`
`
`’119 App, 2:8-14
`
`
`“[0005] The Public Switched Telephone Network
`(PSTN) consists of a plurality of edge switches
`connected to telephones on one side and to a network
`of tandem switches on the other. The tandem switch
`network allows connectivity between all of the edge
`switches, and a signaling system is used by the PSTN
`to allow calling and to transmit both calling and called
`party identity.”
`
`wherein the first communication network is a
`PSTN communication network comprising a
`plurality of edge switches connected to
`telephones on one side and PSTN tandem
`switches on the other side, wherein the PSTN
`tandem switches includes the particular PSTN
`tandem switch,
`
`
`
`
`5
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 5
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`wherein the PSTN tandem switches are not the
`edge switches,
`
`
`
`wherein the PSTN tandem switches are not
`directly connected to any of the telephones,
`
`wherein the tandem access controller is not any
`of the edge switches,
`
`
`
`
`
`Figs. 1, 2, 7, and 8
`
`Figs. 1, 2, 7, and 8
`
`’119 App, 2:8-14 and 8:20-22
`
`
`“[0005] The Public Switched Telephone Network
`(PSTN) consists of a plurality of edge switches
`connected to telephones on one side and to a network
`of tandem switches on the other. The tandem switch
`network allows connectivity between all of the edge
`switches, and a signaling system is used by the PSTN
`to allow calling and to transmit both calling and called
`party identity.”
`
`“As is well known, PSTN tandem switches are
`exchanges that direct telephone calls (or other traffic)
`to central offices 17, 18 or to other tandem switches.”
`
`
`Figs. 1, 2, 7, and 8
`
`Figs. 1, 2, 7, and 8
`
`’119 App, 8:16-27
`
`
`6
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 6
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`“[0033] The TAC 10 is connected to or inside the
`conventional PSTN tandem switch 16 such that calls
`may flow through the TAC 10 in the same manner as
`the existing PSTN tandem switch, except that
`additional 3rd-party features are applied to the call. As
`is well known, PSTN tandem switches are exchanges
`that direct telephone calls (or other traffic) to central
`offices 17, 18 or to other tandem switches. Details of
`the operation of the existing phone network may be
`found in the publication entitled "New Net SS7
`Tutorial," by ADC Telecommunications, copyright
`1999, incorporated herein by reference. Additional
`details may be found in the numerous books describing
`the PSTN.”
`
`Figs. 1, 2, 5 (Box 2), 7, and 8
`
`’119 App, 2:15 – 3:3
`
`
`“[0006] Until now, optional features were provided by
`the local service telephone company (telco) through
`the edge switch at the central office (CO). It was not
`possible to provide optional features through any other
`means. Control of these features was done through the
`first party (calling party) or the second party (called
`party), or worse yet, manually by calling the business
`office.
`[0007] In the past, numerous devices have been built
`
`wherein communications, including the first
`request to establish the first incoming call,
`between the tandem access controller and the
`particular PSTN tandem switch occur without
`passing through any of the edge switches;
`
`
`
`
`7
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 7
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`accessing control criteria by the tandem access
`controller based upon the call data;
`
`
`that allow the connection of two lines together at an
`edge switch. These devices can be used to add
`features to a telephone network by receiving a call on
`one line and then dialing out on another line. The
`problem with these devices is that, because they are
`connected through an edge switch, transmission losses
`and impairments occur, degrading the overall
`connection. In addition, signaling limitations prevent
`full control, by the subscriber or the system, over the
`call.
`[0008] A preferred embodiment of the inventive
`system described herein connects at the tandem,
`thereby eliminating these problems.”
`
`Fig. 5, Boxes 4, 7 and 10
`
`’119 App, 10:16-22, 9:26 – 10:4, 11:17-19
`
`
`“[0039] FIG. l uses a public internet portal connected
`via a data link to the TAC 10 or other interface system.
`As a registered subscriber, a user logs onto the portal
`(FIG. 3) and is granted access, allowing the user to
`make additions or changes to features such as speed
`calling, call forwarding, selection of such descriptors
`as time of day, busy status, caller ID status, etc.”
`
`“[0037] FIG. l illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`
`
`
`8
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 8
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser. By "authorized"
`we mean a subscriber who is registered and has
`logged-in with appropriate security and password
`controls. The subscriber 12 interacts with the web 22
`via the Internet to quickly and easily specify the
`enhanced 3rd-party call control features. Web 22 then
`relays this information, in appropriate form, to the
`TAC 10.”
`
`“Places outgoing calls in response to incoming calls
`according to information downloaded on the data
`link.”
`
`’119 App, 2:22-31 and 4:12-18
`
`
`“[0007] In the past, numerous devices have been built
`that allow the connection of two lines together at an
`edge switch. These devices can be used to add
`features to a telephone network by receiving a call on
`one line and then dialing out on another line. The
`problem with these devices is that, because they are
`connected through an edge switch, transmission losses
`and impairments occur, degrading the overall
`connection. In addition, signaling limitations prevent
`full control, by the subscriber or the system, over the
`call.”
`
`“[0013] In addition to these toll services, there are
`9
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 9
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`edge devices that perform some of the same services.
`Edge devices such as phones and PBXs that include
`voice mail, inter-active voice response, call
`forwarding, speed calling, etc., have been used to
`provide additional call control. These devices allow
`the phone user direct control over incoming and
`outgoing calls.”
`
`Fig. 5, Box 11
`
`’119 App, 8:28 – 9:2 and 11:17-19
`
`
`“[0034] The PSTN tandem switch 16 directs a first call
`(from the calling party 20 to the subscriber's phone 14
`using the subscriber's public phone number) to the
`TAC 10, which in turn places a second call, subject to
`3rd-party control information, to the subscriber's
`"private" phone number without yet terminating the
`first call.”
`
`“Places outgoing calls in response to incoming calls
`according to information downloaded on the data
`link.”
`
`
`Fig. 2, Fig. 4
`
`’119 App, 9:17-29, 10:15, 10:31-11:5
`
`
`“Rather, it redirects calls to subscribers. The
`10
`
`initiating a second call request to establish a
`second call via the second communication
`network by the tandem access controller, without
`yet answering the first incoming call, using the
`call data and the control criteria, wherein the
`second communication networks is a voice over
`IP (VOIP) network;
`
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 10
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`TAC 10 provides intelligent interconnection between a
`calling party and a subscriber.
`[0036] The reader should keep in mind that although
`only one tandem switch 16 is shown in FIG. 1, the
`invention will apply equally well to a network of
`tandem switches, as shown in FIG. 2. FIG. 2 also
`illustrates how the subscriber can make calls using
`voice over IP via a conventional digital telephone 21.
`[0037] FIG. l illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser.”
`
`“[0038] The invention may also include ivr/vm/voverip.”
`
`“[0041] FIG. 4 is a flowchart of actions that may be
`taken by the TAC 10 in response to the subscriber (or
`other service) controlling the TAC, using the web or
`other packet-based system, to change the subscriber's
`telephone provisioning or perform another function,
`such as make a VoIP call.”
`
`Fig. 5
`
`’119 App, 8:28 – 9:13
`
`
`“[0034] The PSTN tandem switch 16 directs a first call
`
`answering the first incoming call at the tandem
`access controller when the second call is
`answered; and
`
`enabling communication between the first call
`and the second call by the tandem access
`
`
`
`11
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 11
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`(from the calling party 20 to the subscriber's phone 14
`using the subscriber's public phone number) to the
`TAC 10, which in turn places a second call, subject to
`3rd-party control information, to the subscriber's
`"private" phone number without yet terminating the
`first call. The TAC 10 is connected within the
`subscriber's local service area so calls from TAC 10 to
`the subscriber do not incur a toll. When the subscriber
`12 terminates (or answers) the second call, the TAC 10
`terminates the first call and connects it to the second
`call, thereby connecting the calling party 20 to the
`subscriber 12. Hence, the calling party essentially
`calls the TAC 10, using the subscriber's public phone
`number, and the TAC 10, after processing the call
`using the selected features, calls the subscriber, as
`appropriate, using the subscriber's private phone
`number and connects the two calls. The process is
`transparent to the parties.”
`
`
`
`
`
`
`controller when the second call is answered by
`connecting the first call to the second call.
`
`
`
`
`12
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 12
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`A method of providing an intelligent
`interconnection at a tandem access controller
`between a first communication network and a
`second communication network, comprising:
`
`SUPPORT FOR PROPOSED SUBSITUTE CLAIM 184 IN THE ’965 APP
`
`Figs. 1 and 5
`
`’965 App, 9:3-4 and 9:13
`“Fig. 5 is a flowchart of actions taken by the TAC 10
`in response to an inbound call (using the subscriber's
`public phone number) to the subscriber.”
`
`“Incoming call data is received by the TAC 10 from
`the tandem switch 16.”
`
`Fig. 2
`
`’965 App, 7:29 – 8:7
`
`
`“Rather, it redirects calls to subscribers. The TAC 10
`provides intelligent interconnection between a calling
`party and a subscriber.
`The reader should keep in mind that although only one
`tandem switch 16 is shown in Fig. 1, the invention will
`apply equally well to a network of tandem switches, as
`shown in Fig. 2. Fig. 2 also illustrates how the
`subscriber can make calls using voice over IP via a
`conventional digital telephone 21.
`Fig. 1 illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser.”
`13
`
`
`
`
`
`
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 13
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`receiving at the tandem access controller a first
`request to establish a first incoming call and call
`data which is associated with the first request to
`establish the first incoming call via a first
`communication network,
`
`
`Fig. 5, Box 2
`
`’965 App, 7:16-19 and 10:25 – 11:2
`
`
`“The PSTN tandem switch 16 directs a first call (from
`the calling party 20 to the subscriber's phone 14 using
`the subscriber's public phone number) to the TAC 10,
`which in turn places a second call, subject to 3rd-party
`control information, to the subscriber's "private" phone
`number without yet terminating the first call.”
`
`“Certain advantages that can be obtained using the
`invention include the following:
`Web-Based Telecom Navigator
`Manage Incoming Call Control
` • Conditional Call Blocking/Forwarding/Alerting
` • Time-of-Day, Day-of-Week, Follow-Me, Caller
` Recognition/Password, Caller ID, etc.”
`
`Figs. 2 and 5, Boxes 2 and 3
`
`’965 App, 7:2-26
`
`
`“Fig. 1 shows a tandem access controller (TAC) 10
`that allows an authorized subscriber 12 to establish
`3rd-party control criteria for calls to the subscriber's
`telephone 14 (having a "public" phone number that
`
`
`
`14
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 14
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`callers dial). In one embodiment, the TAC 10 is a
`programmed processor. The TAC 10 may use any
`combination of hardware, firmware, or software and,
`in one embodiment, is a conventional computer
`programmed to carry out the functions described
`herein.
`The TAC 10 is connected to or inside the conventional
`PSTN tandem switch 16 such that calls may flow
`through the TAC 10 in the same manner as the existing
`PSTN tandem switch, except that additional 3rd-party
`features are applied to the call. As is well known,
`PSTN tandem switches are exchanges that direct
`telephone calls (or other traffic) to central offices 17,
`18 or to other tandem switches. Details of the
`operation of the existing phone network may be found
`in the publication entitled "New Net SS7 Tutorial," by
`ADC Telecommunications, copyright 1999,
`incorporated herein by reference. Additional details
`may be found in the numerous books describing the
`PSTN.
`The PSTN tandem switch 16 directs a first call (from
`the calling party 20 to the subscriber's phone 14 using
`the subscriber's public phone number) to the TAC 10,
`which in turn places a second call, subject to 3rd-party
`control information, to the subscriber's "private" phone
`number without yet terminating the first call. The
`TAC 10 is connected within the subscriber's local
`service area so calls from TAC 10 to the subscriber do
`not incur a toll. When the subscriber 12 terminates (or
`15
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 15
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`answers) the second call, the TAC 10 terminates the
`first call and connects it to the second call, thereby
`connecting the calling party 20 to the subscriber 12.
`Hence, the calling party essentially calls the TAC 10,
`using the subscriber's public phone number, and the
`TAC 10, after processing the call using the selected
`features, calls the subscriber, as appropriate, using the
`subscriber's private phone number and connects the
`two calls. The process is transparent to the parties.”
`
`’965 App, 9:6 (“Receives SS7 data indicating an
`incoming call”)
`
`
`
`’965 App, 2:1-5
`
`
`“The Public Switched Telephone Network (PSTN)
`consists of a plurality of edge switches connected to
`telephones on one side and to a network of tandem
`switches on the other. The tandem switch network
`allows connectivity between all of the edge switches,
`and a signaling system is used by the PSTN to allow
`calling and to transmit both calling and called party
`identity.”
`
`
`Figs. 1, 2, 7, and 8
`
`Figs. 1, 2, 7, and 8
`
`wherein the first communication network is a
`PSTN communication network comprising a
`plurality of edge switches connected to
`telephones on one side and PSTN tandem
`switches on the other side, wherein the PSTN
`tandem switches includes the particular PSTN
`tandem switch,
`
`
`wherein the PSTN tandem switches are not the
`
`
`
`16
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 16
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`edge switches,
`
`
`
`wherein the PSTN tandem switches are not
`directly connected to any of the telephones,
`
`wherein the tandem access controller is not any
`of the edge switches,
`
`
`
`’965 App, 2:1-5 and 7:10-12
`
`
`“The Public Switched Telephone Network (PSTN)
`consists of a plurality of edge switches connected to
`telephones on one side and to a network of tandem
`switches on the other. The tandem switch network
`allows connectivity between all of the edge switches,
`and a signaling system is used by the PSTN to allow
`calling and to transmit both calling and called party
`identity.”
`
`“As is well known, PSTN tandem switches are
`exchanges that direct telephone calls (or other traffic)
`to central offices 17, 18 or to other tandem switches.”
`
`Figs. 1, 2, 7, and 8
`
`Figs. 1, 2, 7, and 8
`
`’965 App, 7:8-15
`
`
`“The TAC 10 is connected to or inside the
`conventional PSTN tandem switch 16 such that calls
`may flow through the TAC 10 in the same manner as
`the existing PSTN tandem switch, except that
`additional 3rd-party features are applied to the call. As
`
`
`
`17
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 17
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`wherein communications, including the first
`request to establish the first incoming call,
`between the tandem access controller and the
`particular PSTN tandem switch occur without
`passing through any of the edge switches;
`
`
`is well known, PSTN tandem switches are exchanges
`that direct telephone calls (or other traffic) to central
`offices 17, 18 or to other tandem switches. Details of
`the operation of the existing phone network may be
`found in the publication entitled "New Net SS7
`Tutorial," by ADC Telecommunications, copyright
`1999, incorporated herein by reference. Additional
`details may be found in the numerous books describing
`the PSTN.”
`
`Figs. 1, 2, 5 (Box 2), 7, and 8
`
`’965 App, 2:6-18
`
`
`“Until now, optional features were provided by the
`local service telephone company (telco) through the
`edge switch at the central office (CO). It was not
`possible to provide optional features through any other
`means. Control of these features was done through the
`first party (calling party) or the second party (called
`party), or worse yet, manually by calling the business
`office.
`In the past, numerous devices have been built that
`allow the connection of two lines together at an edge
`switch. These devices can be used to add features to a
`telephone network by receiving a call on one line and
`then dialing out on another line. The problem with
`these devices is that, because they are connected
`
`
`
`18
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 18
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`accessing control criteria by the tandem access
`controller based upon the call data;
`
`
`through an edge switch, transmission losses and
`impairments occur, degrading the overall connection.
`In addition, signaling limitations prevent full control,
`by the subscriber or the system, over the call.
`A preferred embodiment of the inventive system
`described herein connects at the tandem, thereby
`eliminating these problems.”
`
`Fig. 5, Boxes 4, 7 and 10
`
`’965 App, 8:19-22, 8:5-10, 9:11-12
`
`
`“Fig. 1 uses a public internet portal connected via a
`data link to the TAC 10 or other interface system. As
`a registered subscriber, a user logs onto the portal (Fig.
`3) and is granted access, allowing the user to make
`additions or changes to features such as speed calling,
`call forwarding, selection of such descriptors as time
`of day, busy status, caller ID status, etc.”
`
`“Fig. 1 illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser. By "authorized"
`we mean a subscriber who is registered and has
`logged- in with appropriate security and password
`controls. The subscriber 12 interacts with the web 22
`via the Internet to quickly and easily specify the
`
`
`
`19
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 19
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`enhanced 3rd-party call control features. Web 22 then
`relays this information, in appropriate form, to the
`TAC 10.”
`
`“Places outgoing calls in response to incoming calls
`according to information downloaded on the data
`link.”
`
`’965 App, 2:11-16 and 3:14-17
`
`
`“In the past, numerous devices have been built that
`allow the connection of two lines together at an edge
`switch. These devices can be used to add features to a
`telephone network by receiving a call on one line and
`then dialing out on another line. The problem with
`these devices is that, because they are connected
`through an edge switch, transmission losses and
`impairments occur, degrading the overall connection.
`In addition, signaling limitations prevent full control,
`by the subscriber or the system, over the call.”
`
`“In addition to these toll services, there are edge
`devices that perform some of the same services. Edge
`devices such as phones and PBXs that include voice
`mail, inter-active voice response, call forwarding,
`speed calling, etc., have been used to provide
`additional call control. These devices allow the phone
`user direct control over incoming and outgoing calls.”
`
`
`20
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 20
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`initiating a second call request to establish a
`second call via the second communication
`network by the tandem access controller, without
`yet answering the first incoming call, using the
`call data and the control criteria, wherein the
`second communication networks is a voice over
`IP (VOIP) network;
`
`
`
`
`Fig. 5, Box 11
`
`’965 App, 7:16-19 and 9:11-12
`
`
`“The PSTN tandem switch 16 directs a first call (from
`the calling party 20 to the subscriber's phone 14 using
`the subscriber's public phone number) to the TAC 10,
`which in turn places a second call, subject to 3rd-party
`control information, to the subscriber's "private" phone
`number without yet terminating the first call.”
`
`“Places outgoing calls in response to incoming calls
`according to information downloaded on the data
`link.”
`
`
`Fig. 2, Fig. 4
`
`’965 App, 7:29 – 8:7, 8:18, 8:29 – 9:2
`
`
`“Rather, it redirects calls to subscribers. The TAC 10
`provides intelligent interconnection between a calling
`party and a subscriber.
`The reader should keep in mind that although only one
`tandem switch 16 is shown in Fig. 1, the invention will
`apply equally well to a network of tandem switches, as
`shown in Fig. 2. Fig. 2 also illustrates how the
`subscriber can make calls using voice over IP via a
`conventional digital telephone 21.
`Fig. 1 illustrates the preferred method for an
`21
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 21
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`authorized subscriber to modify the 3rd-party control
`criteria by means of the world wide web 22 (and web
`server 23) using an internet browser.”
`
`“The invention may also include ivr/vm/voverip.”
`
`“Fig. 4 is a flowchart of actions that may be taken by
`the TAC 10 in response to the subscriber (or other
`service) controlling the TAC, using the web or other
`packet-based system, to change the subscriber's
`telephone provisioning or perform another function,
`such as make a VoIP call.”
`
`Fig. 5
`
`’965 App, 7:16-26
`
`
`“The PSTN tandem switch 16 directs a first call (from
`the calling party 20 to the subscriber's phone 14 using
`the subscriber's public phone number) to the TAC 10,
`which in turn places a second call, subject to 3rd-party
`control information, to the subscriber's "private" phone
`number without yet terminating the first call. The
`TAC 10 is connected within the subscriber’s local
`service area so calls from TAC 10 to the subscriber do
`not incur a toll. When the subscriber 12 terminates (or
`answers) the second call, the TAC 10 terminates the
`first call and connects it to the second call, thereby
`
`answering the first incoming call at the tandem
`access controller when the second call is
`answered; and
`
`enabling communication between the first call
`and the second call by the tandem access
`controller when the second call is answered by
`connecting the first call to the second call.
`
`
`
`
`22
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 22
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`connecting the calling party 20 to the subscriber 12.
`Hence, the calling party essentially calls the TAC 10,
`using the subscriber's public phone number, and the
`TAC 10, after processing the call using the selected
`features, calls the subscriber, as appropriate, using the
`subscriber's private phone number and connects the
`two calls. The process is transparent to the parties.”
`
`
`
`
`
`
`23
`
`
`
`
`
`CISCO SYSTEMS, INC. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2041 - 23
`Section 112 Written Description Support
`IPR2016-01257
`
`
`
`A method of providing an intelligent
`interconnection at a tandem access controller
`between a first communication network and a
`second communication network, comprising:
`
`SUPPORT FOR PROPOSED SUBSITUTE CLAIM 184 IN THE ’279 APP
`
`Figs. 1 and 5
`
`’279 App, 8:1-2 and 8:11
`“Fig. 5 is a flowchart of actions taken by the TAC 10
`in response to an inbound call (using the subscriber's
`public phone number) to the subscriber.”
`
`“Incoming call data is received by the TAC 10 from
`the tandem switch 16.”
`
`Fig. 2
`
`’279 App, 6:29 – 7:5
`
`
`“Rather, it redirects calls to subscribers. The TAC 10
`provides intelligent interconnection between a calling
`party and a subscriber.
`The reader should keep in mind that although only one
`tandem switch 16 is shown in Fig. 1, the invention will
`apply equally well to a network of tandem switches, as
`shown in Fig. 2. Fig. 2 also illustrates how the
`subscriber can make calls using voice over IP via a
`conventional digital telephone 21.
`Fig. 1 illustrates the preferred method for an
`authorized subscriber to modify the 3rd-party control
`criteria by means of the world wide web 22 (and web
`server 23) us
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