PATENT OWNER’S PRESENTATION
`The ‘8923 Patent
`BRIGHTHOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.
`v.
`FOCAL IP, LLC
`
`ORAL HEARING
`September 19, 2017
`
`U.S. Patent Nos. 7,764,777, 8,155,298, and 8,457,113
`IPR2016-01259, -01261, -01262, and -01263
`
`1
`
`
`The ‘8923 Patent
`BRIGHTHOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.
`v.
`FOCAL IP, LLC
`
`ORAL HEARING
`September 19, 2017
`
`U.S. Patent Nos. 7,764,777, 8,155,298, and 8,457,113
`IPR2016-01259, -01261, -01262, and -01263
`
`1
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`CLAIM CONSTRUCTION OF
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`CLAIM CONSTRUCTION OF
`UNAMENDED CLAIMS
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`UNAMENDED CLAIMS
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`2
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 24 (-1258, -1262)
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`3
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 24 (-1258, -1262)
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`4
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 25 (-1258, -1262)
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`5
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 25 (-1258, -1262)
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`6
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’113 Pat.) at 22 (-1260, -1261)
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`7
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’298 Pat.) at 21 (-1256, -1259)
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`8
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’298 Pat.) at 13 (-1256, -1259)
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`9
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 17 (-1258, -1262)
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`10
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 17 (-1258, -1262)
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`11
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 17 (-1258, -1262)
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`12
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 18 (-1258, -1262)
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`13
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 18 (-1258, -1262)
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`14
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 18 (-1258, -1262)
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`15
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`Claim Construction
`The ‘8923 Patent
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`Ex. 1001 (’777 Pat.) at 19 (-1258, -1262)
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`16
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`Claim Construction
`The ‘8923 Patent
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`…
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`Ex. 2005 (’777 Pros. Hist.) at 151-152; Paper 30 pp. 23, 30 (-1258, -1262)
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`17
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`Claim Construction
`The ‘8923 Patent
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`Ex. 2005 (’777 Pros. Hist.) at 81-82 (-1258, -1262)
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`18
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`Claim Construction
`The ‘8923 Patent
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`Ex. 2005 (’777 Pros. Hist.) at 82 (-1258, -1262)
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`19
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`Claim Construction
`The ‘8923 Patent
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`Ex. 2005 (’777 Pros. Hist.) at 63 (-1258, -1262)
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`20
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`
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`THE CHALLENGED CLAIMS ARE
`
`THE CHALLENGED CLAIMS ARE
`PATENTABLE OVER THE INSTITUED
`GROUNDS
`
`PATENTABLE OVER THE INSTITUED
`
`GROUNDS
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`21
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`
`
`U.S. Patent No. 6,683,870 to Archer
`US. Patent No. 6,683,870 to Archer
`(IPR2016-01262, Exhibit 1003)
`(IPR2016-01262, Exhibit 1003)
`
`22
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`
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`Archer Figure 2
`Claim 24
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`Archer Figure 2
`
`(IPR2016-01262, Exhibit 1003)
`(I PR201 6-01 262, Exhibit 1003)
`
`FIG. 2
`
`23
`23
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`
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`Archer 5:23—31
`Archer 5:23-31
`Claim 24
`
`The public switched telephone network (PSTN) is the
`preferred circuit-switched communication network 118. In
`this context, the PSTN refers to the worldwide voice tele-
`phone system. Once only an analog system, the heart of most
`telephone networks today is digital. In the United States,
`most of the remaining analog lines are the ones from homes
`and offices to the telephone company’s central office. It is
`not difficult to imagine that some day these lines will also be
`digital.
`
`(IPR2016-01262, Exhibit 1003)
`(I PR201 6-01 262, Exhibit 1003)
`
`24
`24
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`
`
`Archer 5:32—46
`Archer 5:32-46
`Claim 24
`
`The circuit-switched communication network 118 is
`
`coupled to converter 126 which serves to convert the tele-
`phone signals into digitized packets. Converter 126 can also
`be referred to as a gateway, a digitizer or an encoder. For
`voice communicationsz the conversion function would
`include sampling the voice signals and generating digitized
`representations. This digital sample data can then be com-
`bined with packet headers and footers in a manner consistent
`with the protocol used on packet-switched network 130.
`While Internet Protocol (IP) is preferred, the precise proto-
`col used is not critical to the claimed invention. In general,
`converter 126 may convert signals from a first network (e.g.,
`circuit-switched network 118 into a di ital
`rotocol which
`
`can be routed through packet—switched network 130.
`
`(IPR2016-01262, Exhibit 1003)
`(I PR201 6-01 262, Exhibit 1003)
`
`25
`25
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`
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`Archer’s Converter 126
`Claim 24
`
`(IPR2016-01262, Exhibit 1003)
`
`26
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`
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`Archer 5:47—58
`Archer 5:47-58
`Claim 24
`
`FIG. 3 illustrates a simplified block diagram of a con-
`verter 126. The converter receives telephone signals from
`circuit-switched network 118. These signals are provided to
`a modem 70 and control circuitry 72. The modem translates
`the signals into digital signals which can be handled by
`router 74. The control circuitry 72 utilizes the signaling
`information to generate the packet addressing information
`for router 74. In the preferred embodiment, control circuitry
`72 comprises a processor based system such as a computer
`or specialized hardware. The control circuitry 72 can be
`embedded within router 74. The router then provides pack-
`etized information to the packet-switched network 130.
`
`(IPR2016-01262, Exhibit 1003)
`(I PR201 6-01 262, Exhibit 1003)
`
`27
`27
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`
`
`IPR 2016-01262, Petition, p. 21
`Claim 24
`
`(IPR2016-01262, Paper 1, p. 21)
`
`28
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`
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`IPR 2016-01262, Petition, pp. 19-20
`Claim 24
`
`(IPR2016-01262, Paper 1, pp. 19-20)
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`29
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`
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`IPR 2016-01262, Petition, pp. 24-25
`Claim 24
`
`(IPR2016-01262, Paper 1, pp. 24-24)
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`30
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`
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`IPR 2016-01262, Petition, p. 21
`Claim 24
`
`(IPR2016-01262, Paper 1, p. 21)
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`31
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`IPR 2016-01262, Petition, p. 26
`The ‘8923 Patent
`
`(IPR2016-01262, Paper 1, p. 26)
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`32
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`
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`IPR 2016-01262, Institution Decision, p. 16
`Claim 24
`
`(IPR2016-01262, Paper 19, p. 16)
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`33
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`IPR 2016-01262, Petitioners’ Reply, p. 7
`Claim 24
`
`(IPR2016-01262, Paper 34, p. 7)
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`34
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`IPR 2016-01262, Petitioners’ Reply, p. 5
`The ‘8923 Patent
`
`(IPR2016-01262, Paper 34, p. 5)
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`35
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`Archer’s Converter 126
`Claim 24
`
`(IPR2016-01262, Exhibit 1003, 5:59-67)
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`36
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`
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`Bates Declaration, Para. 76
`Claim 24
`
`(IPR2016-01262, Exhibit 2022)
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`37
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`
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`PO’s Response / Bates Declaration
`Claim 24
`
`(IPR2016-01262, Paper 34, p. 41; see also Exhibit 2022, para. 68)
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`38
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`
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`IPR2016-01262, Petitioners’ Reply, p. 9
`Claim 24
`
`(IPR2016-01262, Paper 34, p. 9)
`
`777 Reply, P. 9
`39
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`
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`IPR2016-01262, Petitioners’ Reply, p. 10
`Claim 24
`
`(IPR2016-01262, Paper 34, p. 10)
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`777 Reply, P. 9
`40
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`
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`IPR2016-01262 (‘777 Patent, Claim 18)
`Claim 24
`
`•
`
`•
`
`“a controlling device in communication with the
`switching facility”
`
`“switching facilities for routing calls to edge
`switches, or other switching facilities local or in
`other geographic areas…”
`
`(IPR2016-01262, Exhibit 1001)
`
`41
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`
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`IPR2016-01261 (‘113 Patent, Claim 1)
`Claim 24
`
`•
`
`•
`
`“a call processing system”
`
`“switching facilities for routing calls to other edge
`switches or other switching facilities local or in other
`geographic areas…”
`
`IPR2016-01261 (‘113 Patent, Claim 94)
`
`•
`
`“the call processing system coupled to at least one
`tandem switch of the circuit-switched network”
`
`(IPR2016-01261, Exhibit 1001)
`
`42
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`
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`IPR2016-01263 (‘298 Patent, Claim 1)
`Claim 24
`
`•
`
`•
`
`“the web-enabled processing system coupled to at
`least one of the switching facilities of the network”
`
`“switching facilities for routing calls to other edge
`switches or other switching facilities local or in other
`geographic areas”
`
`(IPR2016-01263, Exhibit 1001)
`
`43
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`
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`IPR2016-01259 (‘298 Patent, Claim 20)
`Claim 24
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`•
`
`•
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`“a controller…”
`
`“switching facilities for routing calls to other edge
`switches or other switching facilities local or in other
`geographic areas…”
`
`(IPR2016-01259, Exhibit 1101)
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`44
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`IPR 2016-01263, Petition, p. 26
`The ‘8923 Patent
`
`(IPR2016-01263, Paper 5, p. 59)
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`45
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`Archer Figure 4
`Archer Figure 4
`Claim 24
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`Establish mmmunication
`
`68
`
`(IPR2016-01262, Exhibit 1003)
`(I PR201 6-01 262, Exhibit 1003)
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`46
`46
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`‘113 Patent, Claims 18 and19
`Claim 24
`
`(IPR2016-01261, Exhibit 1001)
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`47
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`U.S. Patent No. 5,958,016 to Chang
`US. Patent No. 5,958,016 to Chang
`(IPR2016-01263, Exhibit 1004)
`(IPR2016-01263, Exhibit 1004)
`
`48
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`
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`|PR2016—01263, Petition, p. 21
`IPR2016-01263, Petition, p. 21
`Claim 24
`
`C.
`
`Independent Claim 1 is Obvious Under Ground 1
`
`Petitioners” ground 1 renders every limitation of claim 1 obvious. Petitioner
`
`believes Archer teaches or renders obvious every limitation of claim 1, but adds
`
`Chang for additional disclosure of the web server and web-enabled processor
`
`connected to a switching facility in the preamble.
`
`(IPR2016-01263, Paper 5, p. 21)
`(IPR2016-01263, Paper5, p. 21)
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`49
`49
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`Chang Figure 1
`Claim 24
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`(IPR2016-01263, Paper 26, p. 13)
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`50
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`IPR2016-01263 (‘298 Patent, Claim 1)
`Claim 24
`
`•
`
`“the web-enabled processing system is configured
`to perform the following operations to execute the
`control criteria: … fifth, route the communication in
`accordance with the control criteria, and sixth,
`complete a communications link…”
`
`(IPR2016-01263, Exhibit 1001)
`
`51
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`
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`Chang 11:30-35
`Chang 11:30—35
`Claim 24
`
`The secure access platform interfaces to a public packet
`switched data network, such as the Internet 27. To the
`network 27, the platform 25 appears as a Web server, and as
`discussed more below, the platform receives HTTP requests
`and provides HTML web pages in response.
`
`(IPR2016-01263, Exhibit 1004)
`(IPR2016-01263, Exhibit 1004)
`
`52
`52
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`
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`CONTINGENT MOTION TO AMEND
`
`CONTINGENT MOTION TO AMEND
`CLAIM 46 OF U.S. PATENT NO.
`7,764,777 TO PROPOSED
`7,764,777 TO PROPOSED
`SUBSTITUTE CLAIM 49
`
`CLAIM 46 OF US PATENT NO.
`
`SUBSTITUTE CLAIM 49
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`53
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`Substitute Claim 49 Of ‘777 Patent
`The ‘8923 Patent
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`54
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`Substitute Claim 49 Of ‘777 Patent
`The ‘8923 Patent
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`55
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`CONTINGENT MOTION TO AMEND
`
`CONTINGENT MOTION TO AMEND
`CLAIM 1 OF U.S. PATENT NO.
`8,457,113 TO PROPOSED
`8,457,113 TO PROPOSED
`SUBSTITUTE CLAIM 183
`
`CLAIM 1 OF US PATENT NO.
`
`SUBSTITUTE CLAIM 183
`
`56
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`Substitute Claim 183 Of ‘113 Patent
`The ‘8923 Patent
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`57
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`Substitute Claim 183 Of ‘113 Patent
`The ‘8923 Patent
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`58
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`CLAIM CONSTRUCTION OF
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`CLAIM CONSTRUCTION OF
`AMENDED CLAIMS
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`AMENDED CLAIMS
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`59
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`Construction of Tandem Access Controller
`Claim 24
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`Tandem Access Controller:
`
`“a controller associated with a
`tandem switch, not an edge switch.”
`
`Mot. to Amend, Paper 31 of -01262 at 3
`
`60
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`
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`Construction of PSTN Tandem Switch
`Claim 24
`
`PSTN Tandem Switch:
`
`“a switch in the PSTN that
`interconnects other PSTN tandem
`switches and edge switches.”
`
`Mot. to Amend, Paper 31 of -01262 at 4
`
`61
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`
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`Construction of Request to Establish a Call
`Claim 24
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`Request to Establish a Call:
`
`“signaling indicating a request to set
`up a connection that provides for a
`two way voice communication”
`
`Mot. to Amend, Paper 31 of -01262 at 7
`
`62
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`
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`PRIOR ART IN IPR PETITIONS
`
`PRIOR ART IN IPR PETITIONS
`
`63
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`
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`MATERIAL PRIOR ART IN IPR PETITIONS
`The ‘8923 Patent
`Substitute Claim is Patentable Over the IPR Art
`External to PSTN:
`• Alexander
`• Archer
`• Burger
`• McMullin
`• O’Neal
`• Schwab
`• Shtivelman
`• Swartz
`
`Internal to PSTN:
`• Chang
`
`Mot. to Amend, Paper 31 of -01262 at 15
`
`64
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`
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`Chang
`Chang
`
`65
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`
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`IN Art - Chang
`Claim 24
`
`IN Art fails to disclose:
`
`• a TAC that receives call requests, initiates
`calls, answers a call, and other functions
`of the TAC recited in the Substitute
`Claims
`
`Chang’s Purported TAC
`• Secure Access Platform that operates as
`a normal web server
`• SCP that merely serves as a database to
`receive database queries and send
`responses to those queries
`
`Mot. to Amend, Paper 31 of -01262 at 18-21
`
`66
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`
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`IN Art - Chang
`Claim 24
`
`•
`
`•
`
`•
`
`IN Art is a Closed System
`• Not capable of processing a call sent
`over a different network than the
`PSTN
`
`IN Art’s SCP does not receive a call
`request to establish voice communication
`
`IN Art Requires Modification to Switches
`to Communicate with the SCP
`Mot. to Amend, Paper 31 of -01262 at 20
`
`67
`
`
`
`No Reason to Modify EXT Art with IN Art
`Claim 24
`
`• EXT Art’s architectural design and
`implementation is a completely different
`solution than the closed IN architecture
`
`• Unclear how or why a POSA would
`modify Archer with Chang with a
`predictable result
`
`• To modify or combine any of the art to
`read on the Substitute Claims requires
`impermissible hindsight to use the
`claimed invention as a blueprint
`
`Mot. to Amend, Paper 31 of -01262 at 21, 25
`
`68
`
`
`
`Proposed Substitute Claim 49 is
`Patentable Over Archer
`
`69
`
`
`
`Subst. Claim 49 is Patentable Over Archer
`Claim 24
`
`Archer fails to disclose:
`
`“communications, including the first request
`to establish the incoming call, between the
`tandem access controller and the particular
`PSTN tandem switch, occur without passing
`through any of the edge switches”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 1-6
`
`70
`
`
`
`Subst. Claim 49 is Patentable Over Archer
`Claim 24
`
`• Archer does not use the term “tandem” or
`any other term that refers to the claimed
`PSTN tandem switch
`
`• Archer teaches that data to and from the
`purported TAC must first pass through an
`edge switch of the PSTN
`• Modem converts analog to digital
`• Netspeak product designed to receive
`analog signals from an edge switch
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 1-6
`
`71
`
`
`
`Subst. Claim 49 is Patentable Over Archer
`Claim 24
`
`Archer fails to disclose:
`
`•
`
`•
`
`“control criteria is previously entered via a
`web-based interface” and;
`
`“blocking the incoming call received at the
`tandem access controller in accordance
`with the control criteria.”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 6
`
`72
`
`
`
`Proposed Substitute Claim 183 is
`Patentable Over Archer
`
`73
`
`
`
`Subst. Claim 183 is Patentable Over Archer
`Claim 24
`
`Archer fails to disclose:
`
`“communications between the tandem
`access controller and the particular PSTN
`tandem switch occur without passing through
`any edge switches”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 1-6
`
`74
`
`
`
`Subst. Claim 183 is Patentable Over Archer
`Claim 24
`
`• Archer does not use the term “tandem” or
`any other term that refers to the claimed
`PSTN tandem switch
`
`• Archer teaches that data to and from the
`purported TAC must first pass through an
`edge switch of the PSTN
`• Modem converts analog to digital
`• Netspeak product designed to receive
`analog signals from an edge switch
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 1-6
`
`75
`
`
`
`Subst. Claim 183 is Patentable Over Archer
`Claim 24
`
`Substitute Claim 183 is directed to:
`
`•
`
`“a call” for enabling voice communication
`across two networks
`
`• TAC receives a “first call request …
`associated with a first call”
`
`• TAC “process[es] a second call request
`associated with a second call across the
`packet network to complete the call”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 5-6
`
`76
`
`
`
`Subst. Claim 183 is Patentable Over Archer
`Claim 24
`
`• Archer fails to disclose receiving a first
`call without answering it until a second
`call is answered, then completing “the
`call”
`
`• Archer discloses that a first call request is
`answered prior to processing a second
`call request across the packet network
`
`•
`
`e.g., to collect information from the caller
`that is used to make the second call
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 5-6
`
`77
`
`
`
`Proposed Substitute Claim 49 is
`Patentable Over Lewis
`
`78
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`Lewis fails to disclose:
`
`•
`
`•
`
`•
`
`“tandem access controller”;
`
`“the control criteria is previously entered
`via a web-based interface”; and
`
`“blocking the incoming call received at the
`tandem access controller in accordance
`with the control criteria”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 6-8
`
`79
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`Lewis, 30:51-60
`
`80
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`• Lewis fails to disclose a TAC that receives
`“a first request to establish the incoming
`call”
`
`• PO construed this term to be “signaling
`indicating a request to set up a
`connection that provides for a two way
`voice communication”
`
`• Petitioner relies exclusively on the
`embodiment directed to data calls (i.e.,
`non-voice calls)
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 8-9
`
`81
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 8-9
`Lewis,. 27:3-18
`
`82
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 8-9
`Lewis, Fig. 10A
`
`83
`
`
`
`Subst. Claim 49 is Patentable Over Lewis
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 8-9
`Lewis, Fig. 5
`
`84
`
`
`
`Proposed Substitute Claim 183 is
`Patentable Over Lewis
`
`85
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`Lewis fails to disclose:
`
`•
`
`“tandem access controller”; and
`
`• open architecture switch coupled to a
`“web enabled processing system
`including one or more web servers” that
`would allow a subscriber to set call
`control features.
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 6-7
`
`86
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 8
`Lewis, 30:51-60
`
`87
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`• Lewis fails to disclose:
`• a “method for enabling voice communication of a call”;
`•
`“first call request for the purpose of initiating voice
`communication to the subscriber”; or
`“establishing the voice communication … by the
`tandem access controller”
`
`•
`
`• Petitioner relies exclusively on the embodiment directed to
`data calls (i.e., non-voice calls)
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 8-9
`
`88
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`• Lewis fails to disclose a TAC that processes calls of
`receiving a first call without answering it until a second call
`is answered, then completing “the call”
`
`• Petitioner acknowledges that a data call is answered at
`modem NAS bay 514
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 7
`
`89
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`• Lewis is devoid of any “second call request associated with
`a second call”
`
`• Lewis only discloses routing received data to an ISP:
`
`Lewis, 20: 50-53
`
`Lewis, 30: 15-19
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 7-8
`
`90
`
`
`
`Subst. Claim 183 is Patentable Over Lewis
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 7-8
`Lewis, Fig. 5
`
`91
`
`
`
`Proposed Substitute Claim 49 is
`Patentable Over LaPier
`
`92
`
`
`
`Subst. Claim 49 is Patentable Over LaPier
`Claim 24
`
`LaPier fails to disclose:
`
`•
`
`•
`
`“tandem access controller” and;
`
`“the control criteria is previously entered
`via a web-based interface”
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01262 at 9-10
`
`93
`
`
`
`Proposed Substitute Claim 183 is
`Patentable Over LaPier
`
`94
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`LaPier fails to disclose:
`
`•
`
`“tandem access controller”; and
`
`• open architecture switch coupled to a
`“web enabled processing system
`including one or more web servers” that
`would allow a subscriber to set call
`control features.
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 9-10
`
`95
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`• LaPier is devoid of any “second call request associated with
`a second call”
`
`• LaPier teaches:
`• A single call request is generated via the PSTN, which then is
`converted from PSTN format (IAM 704) to an IP format (Setup
`call message 706), then the call request is answered at a
`terminating device conversant in the IP format.
`
`• Only after the call has been answered, a single call answer
`message is converted from IP format (Connect message 712)
`to PSTN format (ANM 714), and then the answer message is
`received by PSTN device conversant in the PSTN format.
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 10-11
`
`96
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 11
`LaPier, Fig. 7A
`
`97
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 10-11
`LaPier, 38:13-24
`
`98
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 10-11
`LaPier, 38:25-39
`
`99
`
`
`
`Subst. Claim 183 is Patentable Over LaPier
`Claim 24
`
`• LaPier fails to disclose a TAC that processes calls of
`receiving a first call without answering it until a second call
`is answered, then completing “the call”
`
`• Petitioner argues that a data call is answered at SAS 112 of
`LaPier’s purported TAC
`
`Reply to Opp. to Mot. to Amend, Paper 43 of -01261 at 10
`
`100
`
`
`
`Questions
`
`Questions
`
`101
`
`
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