`EXHIBIT 1019
`
`
`EXHIBIT 1019
`
`
`
`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
` VIPTELA, INC.
` Petitioner,
` v.
` FATPIPE NETWORKS INDIA LIMITED,
` Patent Owner.
` ____________
` Case IPR2017-00684
` Patent 6,775,235
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 1
`
`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
` VIPTELA, INC.
` Petitioner,
` v.
` FATPIPE NETWORKS INDIA LIMITED,
` Patent Owner.
` ____________
` Case IPR2017-00684
` Patent 6,775,235
`
` VIDEOTAPED DEPOSITION OF
` JOEL ROBERT WILLIAMS
` Alexandria, Virginia
` Tuesday, December 19, 2017
`
`Pages: 1 - 84
`Job No. 123729
`Reported by: Cindy L. Sebo, RMR, CRR, RPR, CSR,
`CCR, CLR, RSA, LiveDeposition Authorized Reporter
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 2
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
` December 19, 2017
` 9:07 a.m.
`
`3
`
` Videotaped Deposition of JOEL
`ROBERT WILLIAMS, held at:
`
` Oblon, McClelland, Maier & Neustadt, L.L.P.
` 1940 Duke Street
` Alexandria, Virginia 22314
`
` Pursuant to notice, before Cindy
`L. Sebo, Registered Merit Reporter, Certified
`RealTime Reporter, Registered Professional
`Reporter, Certified Shorthand Reporter, Certified
`Court Reporter, Certified LiveNote Reporter,
`Realtime Systems Administrator, LiveDeposition
`Authorized Reporter and a Notary Public in and for
`the Commonwealth of Virginia.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 3
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
` A P P E A R A N C E S:
`
`4
`
` On behalf of the Petitioner:
` ROBERT C. HILTON, ESQUIRE
` MCGUIREWOODS LLP
` 2000 McKinney Avenue
` Suite 1400
` Dallas, Texas 75201
` 214.932.6406
` rhilton@mcguirewoods.com
` -and-
` GEORGE B. DAVIS, ESQUIRE
` Gateway Plaza
` 800 East Cary Street
` Richmond, Virginia 23219-3916
` 804.775.1129
` gdavis@mcguirewoods.com
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 4
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`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`A P P E A R A N C E S (Continued):
`
`5
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` On behalf of the Patent Owner:
` ROBERT C. MATTSON, ESQUIRE
` SAMEER GOKHALE, ESQUIRE
` OBLON, MCCLELLAND, MAIER & NEUSTADT, L.L.P.
` 1940 Duke Street
` Alexandria, Virginia 22314
` 703.412.6466
` rmattson@oblon.com
` sgokhale@oblon.com
`
` ALSO PRESENT: NAT PHAM, Videographer
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 5
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
` C O N T E N T S
`EXAMINATION OF JOEL ROBERT WILLIAMS PAGE
` By Mr. Hilton 8
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`6
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` E X H I B I T S
` (None Marked)
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`7
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` ---------------
` P R O C E E D I N G S
` ---------------
`
` Alexandria, Virginia
` Tuesday, December 19, 2017; 9:07 a.m.
`
` THE VIDEOGRAPHER: Good morning.
` We are now on the record.
` Here begins the video deposition of
` Joel Williams, taken in the matter of
` Viptela, Inc. v. FatPipe Networks
` India Limited.
` Today's date is December 19th, 2017.
` The time is 9:07.
` This deposition is being held at
` 1940 Duke Street, Alexandria, Virginia.
` Our court reporter is Cindy Sebo, on
` behalf of CSI. My name is Nat Pham, also on
` behalf of CSI.
` Will counsel please identify themselves
` and state whom you represent?
` MR. HILTON: Yes. For Petitioner,
` Robert Hilton at McGuireWoods, and you
` also have George Davis at McGuireWoods.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 7
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`8
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` MR. MATTSON: For Patent Owner,
` FatPipe, Robert Mattson of the Oblon
` firm, and with me is my partner,
` Sameer Gokhale.
` THE VIDEOGRAPHER: Will the court
` reporter please swear in the witness?
` - - -
` JOEL ROBERT WILLIAMS,
` after having been first duly sworn, was
` examined and testified as follows:
` - - -
` - - -
` EXAMINATION BY COUNSEL FOR PETITIONER
` - - -
` BY MR. HILTON:
` Q. All right. Good morning, Mr. Williams.
` A. Good morning.
` Q. Would you please state your full name
` for the record?
` A. Joel Robert Williams.
` Q. Okay. And can you please state your
` address for the record?
` A. It's 1240 McKendrie Street, San José,
` California.
` Q. Okay. Is there anything today that
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`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 8
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`
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`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`9
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` would prevent you from testifying truthfully
` and -- and accurately?
` A. No.
` Q. Okay. You understand that you're going
` to be asked to testify today regarding
` IPR 2017-00684?
` A. I don't know the number off the top of
` my head, but I assume it's the Viptela IPR.
` Q. That's -- that's correct.
` I am going to distribute exhibits, so
` I'm going to put four exhibits in front of you.
` Okay. So one of these exhibits is
` labeled Exhibit 1001, which is U.S. Patent
` Number 6,775,235.
` Is that correct?
` A. That's correct. That's what it's
` labeled.
` Q. The next exhibit is Exhibit 1006, which
` is the Karol reference, also known as U.S. Patent
` Number 6,628,617; is that correct?
` A. That's what it's labeled.
` Q. Finally, we have -- actually, the third
` exhibit is Exhibit 1011, and these are excerpts
` from the Stalling [sic] reference that's cited to
` in IPR 2017-00684.
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`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 9
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`
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`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`10
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` Do you -- do you recognize that?
` A. I recognize it. I believe it's from
` the Stalling [sic].
` Q. Okay. Specifically, what we have there
` is we have all of Chapter 16 -- the excerpt, at
` least, is all of Chapter 16 and parts of
` Chapter 19.
` Do you see that?
` A. Well, without going through it, I'll
` take your word for it.
` Q. The final exhibit that I've handed to
` you is Exhibit 2006.
` Is that -- is that the declaration that
` you provided in the IPR?
` A. It appears to be.
` Q. Does this declaration -- does it
` reflect your complete opinion -- opinion on the
` issues associated with the IPR?
` A. It does.
` Q. Do you have any additional opinions
` outside of what you declared in -- in the
` declaration as to the claims of the '235 patent or
` Karol or Stallings?
` A. Not at this time.
` Q. Okay. Did you bring any notes or other
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 10
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`
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`11
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` materials to the deposition with you today?
` A. No. I did bring a -- basically a blank
` pad, which you're welcome to keep.
` Q. Okay. So I wanted to talk a little bit
` today about your -- about your background.
` Do you -- do you have experience with
` frame relay networks?
` A. I have some experience with frame
` relay.
` Q. Okay. When -- when did you obtain that
` experience?
` A. So some of it would be with -- in
` connection with my work at Cisco --
` Q. Okay.
` A. -- just back in the '90s when the -- I
` believe it was the Catalyst product, and with --
` if -- Network Equipment Technologies --
` Q. Okay.
` A. -- there's probably some other ones if
` I -- let's see.
` I don't recall off the top of my head.
` Q. About how much time do you think -- how
` many -- over -- over the course of how many years
` or over what time period did you -- do you believe
` you worked with frame relay networks?
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`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`12
` A. I -- I'd say it was maybe two years --
` Q. Okay.
` A. -- it was -- it was not -- it's not my
` major focus, but I certainly came in contact with
` it and --
` Q. Um-hum.
` A. -- actually, let me add another one.
` Hewlett-Packard as well --
` Q. Okay --
` A. -- in their --
` Q. -- and when were you at --
` A. -- frame relay interface.
` Q. -- when were you at Hewlett-Packard?
` A. That was also in the '90s.
` Q. Okay. And what -- and characterize
` generally what your involvement was with frame
` relay networks.
` A. It would be configuring it on -- on the
` equipment and software that would involve
` configuring routers and -- and products that had
` frame relay interfaces.
` Q. Okay. And when -- when was your most
` recent experience with frame relays?
` A. It would be back in the '90s. I don't
` recall exactly.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 12
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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` Q. Have you ever personally -- in -- in --
` in the experiment -- in experience that you had,
` have you ever personally configured a router for a
` frame relay?
` A. I believe that I have.
` Q. Where -- where would you --
` A. I --
` Q. -- have done that?
` A. -- think it was at Cisco, certainly, at
` NET.
` Q. But you're not -- you're not certain of
` the -- of the circumstances surrounding that or --
` A. It would be setting up in a lab for
` testing.
` Q. Okay. Did -- do you have any
` experience with ATM networks?
` A. I have a lot of experience with ATM
` networks.
` Q. Okay. When -- when was this
` experience?
` A. It would be with -- again, it was --
` Network Equipment Technologies was a company that
` was making ATM, and I was involved heavily in the
` design of an ATM switch. I was involved in the --
` heavily in the design of an ATM switch for Cisco.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 13
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`14
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` It was called the LightStream 1010 -- was the
` model. And I was involved at Ipsilon; it was a
` start-up company that did fast path switching and
` that used ATM.
` There's some other ones in here.
` AD- -- some of my work on ADSL, DSL that uses ATM
` as well, involved with -- heavily involved in
` configuring and working with ATM at that level.
` Did I -- I mentioned NET. Let's see.
` There's other ones. I also have a patent related
` to ATM switching.
` Q. Okay. What's the title of that patent?
` Do you have it or . . .
` A. It's in my -- it's Patent
` Number 5,914,956. It's a cache for improving the
` connection capacity of a communications switch --
` Q. Okay.
` A. -- and if you look at that patent, it's
` all about ATM or centralized -- center -- centers
` on ATM technology.
` Q. Was your involvement with ATM networks
` also done during the '90s?
` A. Yes.
` Q. Okay. Any experience outside the '90s?
` A. Yeah. The -- as I mentioned, the DSL
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 14
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`15
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` work would have been up through -- I'm not sure
` when, but I think the early 2000s -- or middle
` 2000s, I guess, till 2005, around there --
` Q. So most --
` A. -- which is probably --
` Q. -- most recently --
` A. -- the last time would be -- most
` recently, about 2005 --
` Q. Understand.
` A. -- somewhere around there.
` Q. Okay. Do you -- do you -- have you
` ever personally configured a router for an ATM
` network?
` A. Many times, yes.
` Q. At each one of the companies you -- you
` mentioned or --
` A. Yes.
` Q. Okay. Do you -- do you have any
` experience with X.25 networks?
` A. I do.
` Q. Okay. Tell me about that experience.
` When -- when was that?
` A. The major one would be at
` Hewlett-Packard. I worked on the X.25 interface
` for Linux -- or I'm sorry -- for UNIX systems for
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`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`16
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` Hewlett-Packard.
` So a company called Ditech, that was in
` the early 2000s, I believe -- I think it was early
` 2000s -- had X.25 capability for -- used for
` network management, of all things --
` Q. Okay.
` A. -- I -- I probably have some other ones
` if I go through my résumé.
` Q. Okay. So --
` A. I had --
` Q. -- the years or the -- the time period
` of -- of that -- of that experience was '90s and
` 2000s --
` A. Yes.
` Q. -- correct?
` A. Yes, that's correct. Possibly '8 --
` late '80s as well, but probably early '90s.
` Q. And -- and -- and what was the most
` recent involvement on -- on the X.25 network?
` A. That would have been at Ditech, which I
` don't have the date available. I believe it was
` early 2000s.
` Q. Okay. Have you ever personally
` configured a router for an X.25 network?
` A. I have.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 16
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`17
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` Q. Okay. Where was that?
` A. Hewlett-Packard -- well -- did I do a
` router?
` Well, X.25 equipment at Ditech, I'm not
` sure I would characterize it as a router; it was
` transmission equipment.
` Q. Okay.
` Okay. Is X.25 a connection-oriented
` protocol?
` A. Yes.
` Q. And how -- how is a connection set up
` in X.25?
` A. Well, there's a protocol that -- it's
` going back a ways, but a protocol to set up a
` connection to -- there's -- very much like you
` would set up a telephone call. You sent up -- you
` send out a request for a connection. There's a
` negotiation for the parameters, and then the
` connection is set up.
` Q. Okay. What is the method of addressing
` a packet in X.25?
` A. A method of addressing a packet --
` Q. Or not -- is -- is -- is the X.121
` address format used in X.25?
` A. I'd have to go back and look, but I
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`JOEL ROBERT WILLIAMS
`December 19, 2017
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`18
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` believe that's -- there is a spec for it --
` Q. Do you --
` A. -- again, I haven't worked with that
` for quite a while, so I don't remember the
` details. There's certainly -- there's --
` Q. It's been since the '90s on -- on -- or
` 2000s, I guess, on X.25?
` Do you -- do you recall what the --
` what the address format is for X.121?
` A. I do not.
` Q. Okay. Do you recall if the X.121
` address format is the same as the address format
` for an IP address?
` A. I believe that it is not, to the best
` of my recollection.
` Q. What -- what do you -- what do you
` recall are the differences there?
` A. I don't recall. I just remember that
` they didn't -- weren't the same.
` Q. In your involvement with X.25, have you
` ever seen Internet protocol addressing -- IP
` addressing used in setting up a path in X.25?
` A. Not that I recall.
` Actually, let me be clear about that.
` There are gateway products -- and Hewlett-Packard,
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 18
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`19
` in fact, did this -- where you would associate an
` IP address with an X.25 connection, but the
` addressing was different. I mean, you terminated
` the -- the IP, and you did -- and you went over
` the X.25, or you -- or what HP -- most -- most
` people did was they tunnel it so the IP address
` would be carried through an X.25 tunnel or --
` Q. And why is that?
` A. Why?
` Q. Why is that?
` A. X.25 is just used as a way to extend
` the IP networking without -- without transparently
` extending it, because, I mean, for business
` reasons, people have X.25 they want to use.
` Q. But it -- the -- but it would not work
` to use the IP address over the X.25 network?
` A. That's not what I said.
` You can carry an -- an IP address over
` an X.25 network, but that IP address does not
` participate at the X.25 level. It's just carried
` as data by X.25.
` Q. So the data can be -- or -- the data
` regarding the IP address can be carried over the
` X.25 network, but it is not actively used in -- in
` addressing on the X.25 network?
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`20
` A. To the best of my recollection, that's
` correct.
` Q. If a device is on both an X.25 network
` and an IP network, would it have two addresses,
` one that's a X.121 address and one that's a -- an
` IP address?
` A. Could you be more specific? I'm not
` sure I understand the question.
` Q. If a -- if a -- if a device is
` connected to -- or available through either --
` either of those two networks -- IP network, X.25
` network -- would it have two addresses to access
` that device through the separate -- through the --
` through the respective networks?
` MR. MATTSON: Objection:
` foundation.
` THE WITNESS: Is -- does -- does
` this device have two interfaces, one for
` X.25 and one for IP? Is that what you're
` trying to say?
` BY MR. HILTON:
` Q. Yes.
` A. Yeah, in that case -- yeah, it would
` have an X.25 address, which I believe you said was
` X.21, off the top of my head -- I'll -- I don't
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`21
`
` remember -- and it would have an IP address.
` Q. All right. Can both of these addresses
` be destination addresses for that device?
` A. Possibly.
` Q. Under what circumstances would they not
` be destination addresses?
` A. Well, you didn't define what the device
` is. If it's a router and the packets are just
` passing through it, it wouldn't be a destination.
` If it's a -- if it's a termination point of that
` connection, then it would be.
` Q. So a router that is not the end device
` does not have a destination address?
` A. Well, no. I didn't say that, either.
` It depends -- I mean, your -- routers do many
` things. And if it's a gateway device that's --
` that's going between X.25 and IP, it's more just
` a -- a basic router. It has a gateway capability.
` And in that case, it -- it -- it may --
` again, it may terminate the IP connection and --
` and send the data over a X.25 connection, or it
` may do, as I explained before, an encapsulation,
` where it just takes the IP address and puts -- IP
` packet, including the IP address, and sends it
` over X.25.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
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`
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`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`22
` Q. How does the packet get to, if it is a
` gateway, that gateway?
` A. I don't understand the question.
` Q. Does -- does the gateway -- if we're --
` if we're talking about a gateway, does the gateway
` have an address that allows a -- a -- an
` originating destination to send the data to the
` gateway?
` A. It -- well, as a gateway product -- as
` a gate -- as -- as a networking product, it will
` have a destination address that's used for things
` like maintenance of -- of the gateway. If it's --
` if it's used -- and -- and in its role as sending
` the data across, it may respond to many addresses
` that it's pro -- programmed to do and terminate
` them. So it may have more than one address.
` Q. Okay. More than one destination
` address?
` A. Well, let me be clear. It's not the
` destination; it's -- it's -- it's basically -- I'm
` not sure if I'd use the correct word, but
` spoofing, or faking out and making pretend it's
` the end of -- so that it can then carry the data
` forward through X.25, through the gateway.
` It -- it, in itself, is not the end --
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 22
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`23
`
` end destination. It's -- it's making pretend or
` proxying -- there's a number of different words
` you could use for that.
` Q. Can I get you to turn to your
` declaration, Paragraph 83 in the declaration, and
` read that?
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Okay. I've read the
` paragraph.
` BY MR. HILTON:
` Q. Okay. So in -- in 83, it states,
` Conventional routing is generally -- in general,
` includes two types of addresses that work: (i), a
` final destination address; and, (ii), an
` intermediate (next-hop) destination address.
` Is that correct?
` A. That's what I wrote here.
` Q. Is the destination -- or is the address
` associated with the gateway that we were just
` discussing -- would -- would you consider that to
` be an intermediate address or a --
` A. Okay -- excuse me.
` So let me -- I think you're confusing
` things here a little bit.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 23
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`24
`
` So this talks about conventional
` routing. What we were just talking about is -- is
` a gateway functionality, which is not conventional
` routing; it's beyond that.
` So this is addressing conventional
` routing. So -- and there would be -- so given
` that, could you rephrase the question?
` Q. I believe that you stated that the
` gateway can have multiple addresses associated
` with it?
` A. In the role of a gateway functional --
` in the role of being a gateway that's converting
` from, like, X -- IP to X.25 was the example that
` you gave. It could --
` Q. Right.
` A. -- have -- it could respond to multiple
` addresses.
` I did not say it had multiple
` addresses.
` Q. Recognizing, though, that the gateway
` is not the final device that the data or packet is
` being routed to, is the -- the gateway still has
` an address that allows that data to get to the
` gateway?
` A. Maybe.
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 24
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`25
`
` Again, are we talking about a gateway
` function or conventional routing, as I have
` written here?
` Q. I -- I'm -- I'm just talking about
` getting the data to the gateway on its way to a --
` ultimately, a device that's beyond the gateway.
` A. So it may not -- so when you say it
` "has an address," what do you mean by it "has an
` address"?
` Q. How does it get there?
` A. Okay.
` So when one router wants to send a
` packet to another router, it -- it picks up the
` address of -- of -- of that other router -- the
` new router, and it sends it to it. When it get --
` when that new router gets that packet, it looks at
` it and sees what it should do with that and sends
` it along its next stop --
` Q. So you used --
` A. -- so I'm not sure --
` Q. -- you used the word "address" there.
` You said one router --
` A. So -- yeah --
` Q. -- links to the address of the other --
` the other router --
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 25
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`26
`
` A. No, I did not say that.
` One router looks up in its routing
` table -- the destination address -- it takes the
` destination address, looks in its routing table to
` find where to send the next packet to. The next
` packet may be a -- I'm sorry -- the next router
` may be a -- either it could be identified as an IP
` address, it could be identified as a port on that
` outgoing router, and it doesn't know or care. It
` just -- it just -- the -- the destination address
` is just used in that first router to identify
` where to send the packet to next. Okay?
` The route -- the -- the -- when that
` packet is received at the router, it wasn't
` necessarily addressed specifically to that router.
` It's addressed to a desk -- final destination.
` And that next router will do the same thing; it
` will look in its routing table to figure out where
` the next place to send it to is.
` Q. I believe you did use the word
` "address" with respect to the router.
` MR. HILTON: Can we get the court
` reporter to please read back the -- the
` answer?
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 26
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`27
`
` - - -
` (Whereupon, the court reporter read
` back the pertinent part of the
` record.)
` - - -
` THE WITNESS: Okay. So let me
` clarify that --
` BY MR. HILTON:
` Q. Okay.
` A. -- how routing works and how routing
` tables work.
` If you look in a routing table -- and
` I'm using the example of Linux as one that's --
` I'm most familiar with or I'm most recently
` familiar with, but they all work in -- mostly --
` most of them work in a similar way.
` In the routing table, you have a --
` the -- the range of addresses that you're -- that
` pertain to a pack -- to a set of packets -- to a
` set of sources -- places -- I'm sorry -- a set of
` destinations, and then -- and then there's
` place -- and then there's another thing -- it's
` usually called a "next hop" -- of where to send it
` to.
` Now, that next hop could be an IP
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 27
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`28
`
` address, or it could be a -- a -- a port on that
` outgoing router, or it could be a number of
` things. If it's a gateway product, it might be
` sending it to the gateway component within the
` router. I mean, it's a lot of things it could be.
` If it is an IP address in that route --
` anyway -- it then does another translation or some
` kind of lookup to figure out, okay, for that
` address, what port do I send it on? And I should
` have been more clear about that. So it's using
` that as a port to say it goes through that -- to
` that router.
` Now, that -- that IP address that it's
` using is -- you can consider it an intermediate
` value. Typically, it is the IP address of the
` router, and, often, it's the one that's used for
` mat -- managing the router. It has its own --
` just -- just as an easy way to identify it,
` because that -- people in this business think in
` terms of IP addresses for things.
` But, essentially, it's a figure of
` merit. It's just a value you can use to get -- to
` figure out which port to send it out on.
` Q. But it is an IP address associated with
` the next router?
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`IPR2017-00684
`Viptela, Inc. - v. Fatpipe - Exhibit 1019
`Page 28
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`
`
`JOEL ROBERT WILLIAMS
`December 19, 2017
`
`29
`
` A. It is an IP address associated with
` the -- yeah, it typically is, yeah. It's with,
` again, the management port of the router. Yes.
` Q. So -- so it is -- it is an address --
` A. It is an address associated --
` Q. -- and it's associated --
` A. -- with the router -- with the router,
` yes.
` Q. -- and it's associated with the next
` device to which the packet is being passed?
` A. Yes.
` Q. Okay. Thank you.
` A. I -- I would hesitate -- I would
` want to -- for completeness, I want to add it is
` not being sent to that address as a destination;
` it's just being forwarded to that router -- to
` that address as -- as the next place to be
` processed or forwar
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