`Patent 8,457,113
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`Paper No. 43
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC,
`
`
`
`
`
`Petitioner
`
`v.
`
`FOCAL IP, LLC,
`
`
`
`Patent Owner
`
`________________
`
`
`Case IPR2016-01261
`Patent Number: 8,457,113
`________________
`
`
`
`
`PATENT OWNER FOCAL IP, LLC’S REPLY IN SUPPORT
`OF PATENT OWNER’S CONTINGENT MOTION TO AMEND
`CLAIM 1 OF U.S. PATENT NO. 8,457,113
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`Case IPR2016-01261
`Patent 8,457,113
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`TABLE OF CONTENTS
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`Paper No. 43
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`I.
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`II.
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`INTRODUCTION ........................................................................................... 1
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`THE SUBSTITUTE CLAIM IS PATENTABLE OVER ARCHER .............. 1
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`III. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LEWIS .................. 6
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`IV. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LAPIER ................ 9
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`V.
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`THE SUBSTITUTE CLAIM IS PATENTABLE AND NOT OBVIOUS ... 11
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`UPDATED LIST OF EXHIBITS
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`2001
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`2002
`2003
`2004
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`2005
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`2006
`2007
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`7,764,777
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`of U.S. Patent No.
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`Declaration of Regis J. “Bud” Bates filed with Preliminary
`Response
`Ray Horak, Communications Systems & Networks, (2nd ed. 2000)
`Ray Horak, Webster’s New World Telecom Dictionary (2008)
`Ray Horak, Telecommunications and Data Communications
`(2007)
`Prosecution History
`(“’777ProsHist”)
`Harry Newton, Newton’s Telecom Dictionary, (23rd ed. 2007)
`Declaration of John P. Murphy in Support of Unopposed Motion
`for Pro Hac Vice Admission
`Declaration of Hanna F. Madbak in Support of Unopposed Motion
`for Pro Hac Vice Admission
`Corrected Declaration of Hanna F. Madbak in Support of
`Unopposed Motion for Pro Hac Vice Admission
`U.S. Patent No. 6,574,328
`Opening Claim Construction Expert Declaration of Dr. Eric
`Burger filed by certain Defendants in the underlying district court
`litigation Case No. 3:15-cv-00742-TJC-MCR, Dkt No. 89-2, filed
`08/12/16.
`Deposition Transcript of Dr. La Porta, Feb. 24, 2017, for
`IPR2016-01259, -01261, -01262, and 01263
`Deposition Transcript of Dr. La Porta, Feb. 23, 2017, for
`IPR2016-01259, -01261, -01262, and 01263 (“La Porta Dep.”)
`Deposition Transcript of Mr. Willis, Mar. 1, 2017, for IPR2016-
`01254 and -01257. (“Willis Dep.”)
`Declaration of Regis J. “Bud” Bates in Support of Response
`Petition filed in IPR2016-01261 (“-01261 Pet.”)
`Petition filed in IPR2016-01254 (“-01254 Pet.”)
`Petition filed in IPR2016-01260 (“-01260 Pet.”)
`Declaration of Dr. La Porta in support of the Petition, Ex. 1002 of
`IPR2016-01262 (“La Porta Dec. of IPR2016-01262”)
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`Declaration of Mr. Willis in support of the Petition, Ex. 1002 of
`IPR2016-01254 (“Willis Dec. of IPR2016-01254”)
`Declaration of Dr. Lavian in support of the Petition, Ex. 1002 of
`IPR2016-01258 (“Lavian Dec. of IPR2016-01258”)
`Deposition Transcript of Dr. Lavian, March 29, 2017, for
`IPR2016-01256, -01258, and -01260 (“Lavian Dep.”)
`Declaration of Dr. Lavian in support of the Petition, Ex. 1002 of
`IPR2016-01256 (“Lavian Dec. of IPR2016-01256”)
`Declaration of Regis J. “Bud” Bates in Support of Motion to
`Amend
`Listing of Section 112 Written Description Support for the
`Proposed Substitute Claims
`Application No. 11/948,965, filed on November 20, 2007
`(annotated with line numbers)
`Application No. 10/426,279, filed on April 30, 2003 (annotated
`with line numbers)
`Application No. 09/565,565, filed on May 4, 2000 (annotated with
`line numbers)
`U.S. Pat. No. 4,646,296 (filed on July 9, 1984)
`U.S. Patent No. 6,381,323 to Schwab, et al. (“Schwab”)
`U.S. Patent No. 6,463,145 to O’Neal et al. (“O’Neal”)
`U.S. Patent No. 6,683,870 to Archer (“Archer”)
`U.S. Patent No. 5,958,016 to Chang et al. (“Chang”)
`U.S. Patent No. 6,353,660 to Burger et al. (“Burger”)
`U.S. Patent No. 6,798,767 to Alexander et al. (“Alexander”)
`PCT Application No. WO 99/14924
`to Shtivelman
`(“Shtivelman”)
`U.S. Patent No. 5,809,128 to McMullin (“McMullin”)
`U.S. Patent No. 6,445,694 to Swartz (“Swartz”)
`An Overview of Signaling System No. 7, Abdi R. Modarressi, and
`Ronald A. Skoog, April, 1992
`U.S. Patent No. 4,646,296 to Bartholet et al. (“Bartholet”)
`$200 Billion Broadband Scandal, Bruce Kushnick, 2006
`U.S. Patent No. 6,744,759 to Sidhu et al. (“Sidhu”)
`U.S. Patent No. 6,041,325 to Shah et al. (“Shah”)
`U.S. Patent No. 5,802,160 to Kugell et al. (“Kugell”)
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`Karen Kaplan, Can I Put You on Hold? Profits are Calling, Los
`Angeles Times, February 3, 1997
`Redline Comparison of the Proposed Substitute Claims and the
`Original Claims and Clean Versions of the Proposed Substitute
`Claims
`“Cheat Sheet” listing the various IPRs by docket number, along
`with the identity of the petitioner, claims at issue, and art at issue
`Declaration of Thomas La Porta in Support of Petition for Inter
`Partes Review of U.S. Patent No. 8,457,113, June 23, 2016,
`submitted in support of IPR2016-01261
`Declaration of Dr. Tal Lavian in Support of Petition for Inter
`Partes Review of U.S. Patent No. 7,764,777, June 23, 2016,
`submitted in support of IPR2016-01258
`Application No. 12/821,119, filed on June 22, 2010
`Declaration of Regis J. “Bud” Bates in Support of Reply in
`Support of Motion to Amend (“ReplyDec”)
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`I.
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`INTRODUCTION
`Substitute Claim 183 is patentable over each of the references identified in
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`Petitioner’s response. ReplyDec, ⁋ 32. Notably, Petitioner failed to map numerous
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`limitations of the Substitute Claim to each of the references, but rather focused on
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`certain features without any context as to how it would read on the claimed invention
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`as a whole. As explained below, each of the references fails to teach, suggest, or
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`disclose several limitations of the Substitute Claim. Id. Indeed, Petitioner failed to
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`provide any reasons supporting an obviousness argument. PO believes Petitioner
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`bears the burden of proving that the Substitute Claim is not patentable.
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`II. THE SUBSTITUTE CLAIM IS PATENTABLE OVER ARCHER
`Archer fails to teach, suggest, or disclose numerous limitations of the
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`Substitute Claim. ReplyDec, ⁋ 33. For example, Archer fails to disclose that
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`“communications between the tandem access controller and the particular PSTN
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`tandem switch occur without passing through any edge switches,” as recited in the
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`Substitute Claim. Archer does not use the term “tandem,” “class 4,” or any other
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`term that refers to the claimed PSTN tandem switch. Mot. at 16. Rather, Archer
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`teaches that data to and from the purported TAC and the PSTN tandem switch must
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`first pass through an edge switch of the PSTN. Mot. at 16-19; ReplyDec, ⁋ 33.
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`Petitioner’s position that converter 126 receives digital signals in a PCM
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`format directly from a PSTN tandem switch is wrong. As an initial matter,
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`Petitioner’s use of the phrase “gateway 126” throughout its response and expert
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`declaration is misleading. Archer consistently uses the terminology “converter 126”
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`(at least 7 times). Archer never uses the terminology “gateway 126.” Although
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`Archer states that “converter 126 can also be referred to as a gateway, a digitizer or
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`an encoder,” there can be no legitimate dispute that “converter 126” is an edge device
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`that receives analog voice signals from an edge switch of the PSTN where the
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`converter then converts the analog signals to a digital format. ReplyDec, ¶ 34.
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`In Fig. 2, telephone 114 is connected to circuit switched network 118, which
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`may be the PSTN. Archer at 4:66-5:9. Archer explicitly notes that, while the core
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`of the PSTN is digital, the lines connecting homes and business to COs are still
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`predominantly analog. Id. at 5:25-32. These analog lines are what connect Archer’s
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`circuit switched network 118 to converter 126. Id. at Fig. 2; ReplyDec, ⁋ 35.
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`Figure 3 and its related disclosure remove any doubt that converter 126
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`receives analog voice signals and converts them to a digital format. As shown in
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`Fig. 3, converter 126 receives signals from PSTN 118. Id. at Fig. 3, 5:47-58.
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`Converter 126 is comprised of modem bank 70, control circuitry 72, and router 74.
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`Archer’s inclusion of modem bank 70 in the converter is particularly telling. Archer
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`describes that modem 70 “translates the signals into digital signals which can be
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`handled by router 74.” Id. This means that Archer’s modem receives analog signals
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`via the PSTN and translates them to digital signals. ReplyDec, ⁋ 36.
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`Petitioner contends that converter 126 “communicates on the PSTN using SS7
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`signaling and digital voice protocol used by PSTN tandem switches.” Resp. at 7.
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`Petitioner further contends that converter 126 “passes information (e.g., voice and
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`signaling) through it, and sends and receives such information in digital formats
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`(e.g., PCM voice and IP voice packets).” Resp. at 7. This position does not square
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`with the actual teachings of Archer. ReplyDec, ⁋ 37.
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`First, PCM stands for pulse coded modulation and simply assigns a digital
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`value to the amplitude of an analog signal at regular intervals, and is used in
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`everything from .wav files to DVDs to HDMI to VoIP signaling – it is hardly unique
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`to telephony products. ReplyDec, ⁋ 38. Because PCM is a digital representation of
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`an analog signal, there would be no reason for converter 126 to include modem bank
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`70 if it received information from the PSTN in a digital format. Indeed, the whole
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`point of a modem (modulator / demodulator) is to convert an analog signal (e.g.,
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`from a telephone line) to a digital format or vice versa. Id. A person of ordinary
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`skill (POSA) would know that modem bank 70 that is external to the PSTN would
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`be coupled to an edge switch, not to a PSTN tandem switch. Id.
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`Second, Archer does not use the word “tandem” anywhere it its disclosure.
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`Nor does Archer use the term “SS7 signaling” in its disclosure. Petitioner’s attempts
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`to convince the Board that Archer’s modem receives digital voice directly from a
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`PSTN tandem switch along with SS7 signaling is simply made up. ReplyDec, ⁋ 39.
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`Third, the only commercially available product Archer describes as
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`performing the functionality of converter 126 is the Netspeak Webphone Gateway
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`Exchange. Archer at 5:63-67. A POSA would know that the Netspeak product
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`connects to the PSTN through an edge switch and is designed to receive analog
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`signals from a PSTN edge switch, not a tandem switch. ReplyDec, ⁋ 40. Finally,
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`the terms used to describe to converter 126 – “converter,” “gateway,” and “digitizer”
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`– make clear that converter 126 is responsible for converting voice signals received
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`in a first format (analog) to a second format (digital), or vice versa. Id.; Archer at
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`5:33-36. It makes no sense to interpret Archer’s converter 126 as receiving digital
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`signals and simply passing them along in digital format over the IP network. Id. In
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`such a scenario, a modem would not be used. Id.
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`Petitioner’s Response mischaracterizes the testimony of Patent Owner’s
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`expert, Mr. Bates. Petitioner asserts that “Mr. Bates testified that the digital format
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`used by Archer’s gateway 126 to communicate voice information with PSTN 118
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`(136)— [is] PCM….” Resp. at 8. This assertion is false. ReplyDec, ⁋ 41. Mr.
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`Bates never testified that converter 126 communicated voice signals with PSTN 118
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`in a PCM format. Id. The citations in support of this statement contain no such
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`testimony. Id. Nor did “Mr. Bates acknowledge[] that Archer’s gateway 126 would
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`typically be connected to a PSTN tandem switch, not an edge switch, in PSTN 118
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`(136).” Resp. at 8; ReplyDec, ⁋ 41. Again, the testimony pointed to by Petitioner
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`contains no such statement, acknowledgement, or suggestion by Mr. Bates. To the
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`contrary, Mr. Bates acknowledged that PCM is a digital format that could be used
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`by a PSTN tandem switch. ReplyDec, ⁋ 41. Archer only discusses PCM as being
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`used by the IP network 130. Id. Indeed, as previously discussed, Archer expressly
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`contemplates that the PSTN voice signals are sent to converter 126 connection is an
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`analog format, thus requiring the use of a modem in order to convert the analog
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`signal into a digital format (i.e., PCM) that can be used by IP network 130. Id. These
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`analog signals could only come from an edge switch, which typically convey data in
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`an analog format to external devices. Id. Archer does not disclose the limitation
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`“wherein communications between the tandem access controller and the particular
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`PSTN tandem switch occur without passing through any edge switches.” Id.
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`Further, Archer fails to disclose a TAC that processes the calls in a manner
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`required by the Substitute Claim of receiving a first call without answering it until a
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`second call is answered, then completing “the call.” Mot. at 3-4, 25; ReplyDec, ⁋
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`42. The Substitute Claim is directed to “a call” for enabling voice communication
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`across two networks (a packet network and a second network) where the TAC
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`receives a “first call request … associated with a first call” and “process[es] a second
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`call request associated with a second call” across the packet network to complete
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`“the call.” Thus, the Substitute Claim requires that the first call not be answered by
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`the TAC until the second call is answered in order for “the call” to be completed.
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`ReplyDec,⁋ 42. Archer, however, teaches that a first call request is answered (e.g.,
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`to collect information from the caller used to make the second call), prior to
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`processing a second call request across the packet network. Mot. at 18, 25; Archer
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`at 8:54-56; ReplyDec, ⁋ 42.
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`III. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LEWIS
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`Petitioner’s characterization of Lewis is contrary to the reference’s actual
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`disclosure. As set forth below, Lewis does not teach, suggest, or disclose (1) a
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`tandem access controller, (2) the call processing steps, including processing a second
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`call request associated with a second call, and (3) establishing voice communication
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`for voice calls in the manner required by the Substitute Claim. ReplyDec, ⁋ 43.
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`On the first point, the descriptive language of the term “tandem access
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`controller” indicates that it is a controller associated with a tandem switch, not an
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`edge switch. Mot. at 3. Petitioner points to open architecture switch 502 as
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`satisfying the claimed tandem access controller. Resp. at 13-18. However, open
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`architecture switch 502 is associated with an edge switch 506, not a tandem switch.
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`Lewis at Fig. 5, 20:30-58, 27:3-18; ReplyDec, ⁋ 44. As the name implies, an open
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`architecture switch is simply a switch that determines whether a particular call is a
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`voice call or a data call, where voice calls are terminated at the edge switch 506 and
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`data calls (non-voice calls) are terminated at a modem 514, which routes the data to
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`an ISP or private data network. Id. There is no disclosure that open architecture
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`switch 502 has any capabilities to apply call features. Nor is there any disclosure
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`that open architecture switch is coupled to a “web enabled processing system
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`including one or more web servers” that would allow a subscriber to set call control
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`features. Id. Petitioner did not even attempt to show that Lewis discloses a “web
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`enabled processing system including one or more web servers coupled to a tandem
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`access controller.” Id.
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`On the second point, Lewis does not teach, suggest, or disclose a TAC that
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`processes the calls in a manner required by the Substitute Claim of receiving a first
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`call without answering it until a second call is answered, then completing “the call.”
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`Mot. at 3-4, 25; ReplyDec, ⁋ 45. Lewis discloses handling a data call from telephone
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`102 to ISP 112. Lewis at 20:44-58, 25:35-44, 27:22-25, 30:48-50, Figs. 4, 5.
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`“Specifically, an outbound data call will be sent to modem NAS bay 514, then to
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`routers (not shown), and then to ISP 112.” Lewis at 20:50-53. Petitioner
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`acknowledges that a data call is answered at modem NAS bay 514. Resp. at 16-17;
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`Lewis at 30:36-43. For at least these reasons, Lewis fails to meet this requirement
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`of the Subsitute Claim. ReplyDec, ⁋ 45.
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`Further, the data call embodiment in Lewis is devoid of any a “second call
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`request associated with a second call.” ReplyDec, ⁋ 46. Rather, after a first call
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`request is answered at modem NAS bay 514, modem NAS bay 514 simply routes
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`the received data to the particular ISP. Lewis at 20:50-53, 30:15-19, ReplyDec, ⁋
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`46. No second call request associated with a second call ever emanates from modem
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`NAS bay 514. ReplyDec, ⁋ 46. Rather, a POSA would understand that all modem
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`NAS bay 514 can do is route the received data to the ISP to which they are attached.
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`Id. Voice calls are handled by an edge switch in the conventional manner, which
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`does not support a first call/second call type of concept. Id.; Lewis at 30:51-60.
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`On the third point, Lewis does not disclose a “method for enabling voice
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`communication of a call … across both the packet network and the second network,”
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`“first call request for the purpose of initiating voice communication to the
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`subscriber,” and “establishing the voice communication … by the tandem access
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`controller.” The entire invention of Lewis is directed to separating data calls from
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`voice calls, and Petitioner relies exclusively on the data call embodiment (i.e., non-
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`voice calls). ReplyDec, ⁋ 47. The data call embodiment relied upon exclusively by
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`Petitioner actually teaches away from the ability to provide voice communications
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`because Lewis teaches that voice calls are diverted to the voice switch 506, which is
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`an edge switch, not a tandem access controller. See, e.g., Lewis at 20:30-58, 27:3-
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`18, Fig. 5, Fig. 10A (step 1008 “distinguish between data calls and voice calls”), Fig.
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`10C (step 1030 and 1042 where if the initial determination is whether the call is a
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`data call or a voice call); ReplyDec, ⁋ 47. Other than a generic definition of VoIP
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`provided by Lewis at 2:50-55, the only other disclosure of VoIP in Lewis is at 26:9-
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`13, which corresponds to Fig. 9A. This disclosure is clear that Lewis is simply
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`teaching that there are many ways to originate the initial call, such as the “calling
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`party 914” being able to initiate a call using VoIP. After a VoIP call request is
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`received, the invention in Lewis still operates in the same manner—where voice
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`calls are diverted to voice switch 506 (edge switch) without ever being received by
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`the modem NAS bay 514. ReplyDec, ⁋ 47. Additionally, a VoIP call from one VoIP
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`caller to another VoIP caller would never even traverse through a PSTN tandem
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`switch. Id. Petitioner mischaracterizes the teachings of Lewis in a futile attempt to
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`change the invention disclosed in Lewis. See, for example, block quote at page 17
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`of the Response where Petitioner intentionally omits the disclosure that “the
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`technique distinguishes between data calls and voice calls” where the method
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`transmits voice calls to voice switch 506. Lewis is devoid of any teaching that voice
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`can ever be converted to a VoIP call by the modem NAS bay 514. Rather, Lewis is
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`clear that voice calls are never received at modem NAS bay 514. ReplyDec, ⁋ 48.
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`IV. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LAPIER
`As set forth below, LaPier does not teach, suggest, or disclose a tandem access
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`controller or the call processing steps, including processing a second call request
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`associated with a second call, as required by the Substitute Claim. ReplyDec, ⁋ 49.
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`On the first point, the descriptive language of the term “tandem access
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`controller” indicates that it is a controller associated with a tandem switch. Mot. at
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`3. The purported TAC in LaPier has no association with a tandem switch, but, rather,
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`its function is to simply act as a protocol converter between protocols of any type of
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`PSTN switch, including edge switches, and Internet protocols. LaPier at 4:56-67,
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`Figs. 1B, 1C; ReplyDec, ⁋ 50. Further, there is no disclosure that LaPier’s purported
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`TAC has any capabilities to apply call features associated with a subscriber. Nor is
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`there any disclosure that the purported TAC is coupled to a “web enabled processing
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`system including one or more web servers” that would allow a subscriber to set call
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`control features. ReplyDec, ⁋ 50. Petitioner did not even attempt to satisfy these
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`limitations of the Substitute Claim. Resp. at 18-23.
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`On the second point, LaPier does not teach, suggest, or disclose processing
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`the first and second calls by the TAC in a manner required by the Substitute Claim.
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`Petitioner argues that a PSTN call is terminated at SAS 112 of LaPier’s purported
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`TAC. Resp. at 21-22. LaPier does not teach a PSTN call is ever terminated or
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`answered at SAS 112. ReplyDec, ⁋ 51. Should the Board find that LaPier discloses
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`that the PSTN call is terminated at the purported TAC, then LaPier fails to disclose
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`a TAC that processes the calls in a manner required by the Substitute Claim of
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`receiving a first call without answering it until a second call is answered, then
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`completing “the call.” Mot. at 3-4, 25; ReplyDec, ⁋ 51.
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`Further, LaPier does not disclose a “second call request associated with a
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`second call.” ReplyDec, ⁋ 52. LaPier simply teaches that a single call request is
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`generated via the PSTN network, which then is converted from PSTN format (IAM
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`Initial Address Message 704) to an IP format (Setup call message 706), and then the
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`call request is answered at a terminating device that is conversant in the IP format.
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`LaPier at Fig. 7A, 38:13-21; ReplyDec, ⁋ 52. Only after the call has been answered
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`at the terminating IP device (i.e., the first time the call is answered), a single call
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`answer message is generated from the IP terminating device, where LaPier’s
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`purported TAC converts the answer message from IP format (Connect message 712)
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`to PSTN format (ANM Answer message 714), and then the answer message is
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`received by a PSTN device conversant in the PSTN format. LaPier at Fig. 7A,
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`38:26-40; ReplyDec, ⁋ 52. For there to be a second call, a separate set of call
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`requests, acknowledge messages, and answer messages would need to be generated.
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`Id.
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`Petitioner alleges that NAS 118a places a second call in a VoIP format, but
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`this is simply not taught by LaPier or in any of the citations provided by Petitioner.
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`See Resp. at 22 (citing to LaPier at Figs 1B, 7A, 8:61-67, 38:26-27, 35:54-62).
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`Rather, LaPier teaches that NAS includes a router, which a POSA would understand
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`is simply routing data associated with one call, not terminating a first call and
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`originating a second call. See, e.g., LaPier at 8:61-67; ReplyDec,⁋ 53. For at least
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`the aforementioned reasons, LaPier fails to teach the call processing features recited
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`in the Substitute Claim. ReplyDec, ⁋ 53.
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`V. THE SUBSTITUTE CLAIM IS PATENTABLE AND NOT OBVIOUS
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` There is simply no evidence in the record that anyone, prior to the date of the
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`invention, with all of the necessary tools in hand – PBXs, tandem switches,
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`gateways, modem banks, IN equipment – had any reason to add call features and
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`process calls in the manner recited in the Substitute Claim, or ever conceived of such
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`a solution. ReplyDec, ¶ 54. Petitioner has not provided any reasons as to how or
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`why any reference could be modified or combined to read on each of the limitations
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`recited in the Substitute Claim. Further, Petitioner did not even attempt to address
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`the majority of the claim limitations. Petitioner did not even attempt to show how
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`any prior art reference could possibly render the Substitute Claim obvious. Indeed,
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`to utilize these references in the manner required by the Substitute Claim would
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`require extensive and unreasonable modifications to the existing PSTN architecture,
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`such that a POSA would have no reason to modify the references in the manner
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`required by the Substitute Claim. Id. To modify or combine any of the art to read
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`on the Substitute Claim would require impermissible hindsight by using the claimed
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`invention as a blueprint. Id. Thus, the invention recited in the Substitute Claim is
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`patentable. Id.; see also ReplyDec, ⁋ 55.
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`Dated: July 31, 2017
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`Respectfully Submitted,
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`/s/ Brent N. Bumgardner
`Brent N. Bumgardner
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 31st day of July, 2017, a copy of Patent Owner
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`FOCAL IP, LLC’s Reply in Support of Patent Owner’s Contingent Motion to
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`Amend has been served in its entirety via email on the following:
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`Wayne Stacy
`BAKER BOTTS L.L.P.
`2001 Ross Avenue
`Dallas, TX 75201
`Phone: (214) 953-6678
`Facsimile: (214) 661-4678
`wayne.stacy@bakerbotts.com
`
`Sarah J. Guske
`BAKER BOTTS L.L.P.
`101 California Street, #3070
`San Francisco, CA 94111
`Phone: (415) 291-6205
`Facsimile: (415) 291-6305
`sarah.guske@bakerbotts.com
`
`May Eaton
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7520
`Facsimile: (650) 739-7620
`may.eaton@bakerbotts.com
`
`Patrick McPherson
`Duane Morris LLP
`505 9th St. NW, Ste 1000
`Washington DC 20004
`Tel: 202-776-5214
`Fax: 202-776-7801
`PDMcPherson@duanemorris.com
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`Christopher Tyson
`Duane Morris LLP
`505 9th St. NW, Ste 1000
`Washington DC 20004
`Tel: 202-776-7851
`Fax: 202-776-7801
`CJTyson@duanemorris.com
`
`Kyle Lynn Elliott
`Spencer Fane LLP
`1000 Walnut, Suite 1400
`Kansas City, MO 64106
`Tel: 816-292-8150
`Fax: 816-474-3216
`sfbbaction@spencerfane.com
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`Dated: July 31, 2017
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`Paper No. 43
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`Respectfully Submitted,
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`/s/ Brent N. Bumgardner
`Brent N. Bumgardner
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`Registration No. 48,476
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3490
`Email: brent@nelbum.com
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