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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`VIPTELA, INC., )
` Petitioner, )
` )
`VS. )CASE NO. IPR2017-00684
` )
`FATPIPE NETWORKS PRIVATE )
`LIMITED, )
` Patent Owner. )
`
` VIDEOTAPED ORAL DEPOSITION OF
` DR. LEONARD J. FORYS
` SEPTEMBER 19, 2017
` VIDEOTAPED ORAL DEPOSITION OF
`DR. LEONARD J. FORYS, produced as a witness at the
`instance of the PATENT OWNER, and duly sworn, was taken in
`the above-styled and numbered cause on the 19th day of
`September, 2017, from 9:06 a.m. to 10:39 a.m., before
`Kathryn R. Baker, CSR, RPR, in and for the State of Texas,
`reported by machine shorthand, at the offices of McGuireWoods,
`LLP, 2000 McKinney Avenue, Suite 1400, in the City
`of Dallas, State of Texas, pursuant to the Federal Rules
`of Civil Procedure.
`JOB NO: 129996
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`Viptela v. FatPipe
`IPR2017-00684
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VIPTELA, INC., )
` Petitioner, )
` )
`VS. )CASE NO. IPR2017-00684
` )
`FATPIPE NETWORKS PRIVATE )
`LIMITED, )
` Patent Owner. )
`
` VIDEOTAPED ORAL DEPOSITION OF
` DR. LEONARD J. FORYS
` SEPTEMBER 19, 2017
` VIDEOTAPED ORAL DEPOSITION OF
`DR. LEONARD J. FORYS, produced as a witness at the
`instance of the PATENT OWNER, and duly sworn, was taken in
`the above-styled and numbered cause on the 19th day of
`September, 2017, from 9:06 a.m. to 10:39 a.m., before
`Kathryn R. Baker, CSR, RPR, in and for the State of Texas,
`reported by machine shorthand, at the offices of McGuireWoods,
`LLP, 2000 McKinney Avenue, Suite 1400, in the City
`of Dallas, State of Texas, pursuant to the Federal Rules
`of Civil Procedure.
`JOB NO: 129996
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`Page 2
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` A P P E A R A N C E S
`FOR THE PETITIONER:
`Mr. Sameer Gokhale
`OBLON, MCCLELLAND, MAIER & NEUSTADT
`1940 Duke Street
`Alexandria, Virginia 22314
`
`FOR THE PATENT OWNER:
`Mr. Jason Cook
`Mr. Robert Hilton
`MCGUIREWOODS
`2000 McKinney Avenue
`Dallas, Texas 75201
`
`ALSO PRESENT:
`Mr. Johnny Huddleston, Videographer
`Mr. Jack Lin, In-house counsel
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` INDEX
`Appearances. . . . . . . . . 2
`DR. LEONARD J. FORYS
` Examination by Mr. Gokhale . . . 5
` Cross-Examination by Mr. Cook . . . 50
`Signature and Changes. . . . . 52
`Reporter's Certification . . . 54
`
` EXHIBITS
`NO./DESCRIPTION PAGE
`Exhibit 1001.................................... 15
` United States Patent No. 6,775,235 B2
`Exhibit 1005.................................... 5
` Expert Declaration of Dr. Leonard J. Forys
` for Inter Partes Review of U.S. Patent
` No. 6,775,235
`Exhibit 1006.................................... 15
` United States Patent No. 6,628,617 B1
`Exhibit 1011.................................... 26
` Fifth Edition, Data and Computer Communications
` by Williams Stallings
`
` REQUESTED DOCUMENTS/INFORMATION
`
` (NONE)
`
` CERTIFIED QUESTIONS
` (NONE)
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` DR. LEONARD J. FORYS
` P R O C E E D I N G S
` THE VIDEOGRAPHER: This is the start of
`media label Number 1 in the video depo -- recorded
`deposition of Dr. Leonard J. Forys, in the matter of
`Viptela, Inc., vs. FatPipe Networks Private Limited, in
`the United States Patent Trademark Office Before the
`Patent Trial and Appeal Board, Case Number IPR2017-00684,
`U.S. Patent Number 6,775,235.
` This deposition is being held at
`2000 McKinney Avenue, Suite 1400, Dallas, Texas 75201, on
`September the 19th, 2017, at approximately 9:06 a.m.
` My name is Johnny Huddleston; I am the
`legal video specialist from TSG Reporting, Inc.,
`headquartered at 747 Third Avenue, New York, New York.
`The court reporter is Kathryn Baker in association with
`TSG Reporting.
` Will counsel please introduce themselves
`for the record.
` MR. GOKHALE: My name is Sameer Gokhale
`from Oblon, representing FatPipe, the patent owner.
` MR. COOK: This is Jason Cook with
`McGuireWoods for Petitioner Viptela. With me is
`Robert Hilton, also of McGuireWoods, for Petitioner
`Viptela, and in-house counsel, Jack Lin.
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` DR. LEONARD J. FORYS
` THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
` DR. LEONARD J. FORYS,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. GOKHALE:
` Q. Good morning, Dr. Forys.
` A. Good morning.
` Q. Today I'm going to ask you a set of questions.
`If something I ask you is not clear, please ask me to
`repeat the question, or if you need clarification on a
`question, feel free to ask.
` A. Okay.
` Q. If you need to take a break, that is fine as
`well. Just -- and we'll -- we'll go at your own pace.
` A. Thank you.
` Q. Now, I see you don't have any copies in front of
`you.
` Is it okay if I hand you copies to use for
`this deposition?
` A. Yeah, I didn't bring anything with me.
` Q. Okay. Right now, I'm going to hand you a copy
`of what is labeled Exhibit 1005 in this proceeding.
` (Exhibit 1005 marked.)
`
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` MR. COOK: And, Counsel, for ease of the
`record, why don't we just label it according to the
`exhibit number, so we'll just label it Exhibit 1005,
`instead of Forys 1, just for ease of --
` MR. GOKHALE: Yeah, that's fine.
` MR. COOK: Okay.
` MR. GOKHALE: Should I --
` THE REPORTER: Go ahead.
` MR. COOK: I'm sorry; Counsel, do you have
`a copy for me?
` MR. GOKHALE: Oh, I'm sorry.
` MR. COOK: Thanks.
` Q. (BY MR. GOKHALE) Dr. Forys, do you recognize
`this exhibit?
` A. Yes, I do.
` Q. Can you please explain what this exhibit is?
` A. Yeah. The -- it's the expert declaration of
`Dr. Leonard J. Forys for inter partes review of U.S.
`Patent Number 6,775,235.
` Q. Can you please turn to page 224 of this exhibit?
` A. (Witness complies.)
` All right.
` Q. Is that your signature at the bottom of
`page 224?
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` DR. LEONARD J. FORYS
` A. Yes, it is.
` Q. And is it dated January 11th, 2017?
` A. That's correct.
` Q. Okay. And do you understand that this is your
`declaration for a proceeding before the United States
`Patent and Trademark Office?
` A. Yes.
` Q. And do you understand that the purpose of your
`declaration is to support a petition challenging the
`patentability of certain claims of the U.S. patent?
` A. That's my understanding, yes.
` Q. Okay. And is that Patent Number U.S. 6,775,235?
` A. Yes.
` Q. Have you ever testified before a district court
`before?
` A. Before the district court, you said?
` Q. The district court.
` A. Any district court, yes.
` Q. Yes? About how many times?
` A. In the actual court? I guess, three. I've also
`testified in state courts as well, and arbitration
`hearings -- you don't -- you don't want those.
` Q. No, that's okay.
` A. Okay, yeah. Yeah, about a couple -- three
`
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` DR. LEONARD J. FORYS
`times, four times; something like that.
` Q. Were any of them -- were any of those situations
`related to U.S. patents?
` A. Yes.
` Q. Okay. About how many times have you prepared a
`declaration for an inter partes review proceeding before
`the U.S. Patent and Trademark Office?
` A. More than 20.
` Q. About how many times have you been deposed in
`those proceedings?
` Sorry; how many times have you -- have you
`had a deposition --
` A. Oh.
` Q. -- in those proceedings?
` A. Approximately 75, 80 times over a 22-year
`period.
` Q. Could you please turn to paragraph 13 of your
`declaration, please?
` A. (Witness complies.)
` Yes.
` Q. First, I want to ask: Have you been the author
`of any U.S. patents in the Patent Trademark Office?
` A. I'm not sure. We applied for a patent. I don't
`know how far it went, but I had made a patent application.
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` DR. LEONARD J. FORYS
` Q. Okay.
` A. Maybe more than once, maybe a couple of them,
`but they may not have decided to go forward. I
`don't -- don't recall. This is 20 years ago.
` Q. Okay. About 20 years ago?
` A. Yeah.
` Q. Okay. Regarding paragraph 13 in your
`declaration, it -- it -- you can please read -- read it to
`yourself first, if you -- if you'd like.
` A. Yeah. Paragraph 13: I was a leader in
`developing novel traffic engineering methods for Internet
`data networks. This included characterizing Internet
`traffic and developing loading guidelines for network
`components, including routers and switches. During this
`period, Bellcore tested the voiceover packing capabilities
`of several products, including Internet routers.
` Q. Okay, thank you.
` And just to clarify, if I say, Go ahead and
`read it to yourself, you can just read it to yourself; you
`don't have to say it out loud --
` A. Okay.
` Q. -- just to save your energy.
` A. I thought you meant to say -- I'm sorry. Okay.
`I thought you meant read -- read it into the record.
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` Q. I didn't --
` A. I misinterpreted you; sorry.
` Q. No problem, no problem.
` Regarding this paragraph, the development
`of novel traffic engineering methods for Internet data
`networks, do you have any publications related to
`this -- this project?
` A. Yes.
` Q. Okay. Can you identify those publications?
` A. If I had them here. I don't know. I don't
`think I've included them -- yes, I did. Okay.
` (Witness reviews document.)
` It would be reference 10, would be
`reference 9, would be reference 6, would be reference 5,
`would be reference 2; at least those.
` And also here, reference 17, reference 13,
`reference 19. And bits of it appears in other ones, too.
`These -- some of these were just kind of general topics,
`so they would appear elsewhere as well.
` Q. Okay, thank you.
` Can you please turn to paragraph 24 of your
`declaration, please?
` A. (Witness complies.)
` Q. Now, paragraph 24 describes that you researched
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`and developed your own Call Admission Control strategy for
`ATM switches. In addition, you researched alternative
`routing in failure cases for asynchronous transfer mode,
`ATM, and MPLS IP networks.
` Do you have any publications related to
`this effort?
` A. No. This was proprietary stuff that I was
`trying to sell.
` Q. Okay.
` A. So I didn't publish it, no. It would have -- it
`would have defeated the purpose.
` Q. All right, thank you.
` Now, you have a lot of -- a long
`distinguished career, I noticed in your -- in your CV.
` What professions and positions have you
`held that you believe are most related to the topics of
`traffic -- network traffic engineering and, in particular,
`work on ATM-related equipment?
` A. I've been involved in network engineering for
`most of my career. I started doing Bell Labs. I did work
`on satellite routing and rerouting. Based upon dynamic
`conditions, you would either use a terrestrial circuit or
`you'd use a satellite circuit. And I was -- I had worked
`on determining traffic conditions under which we switch
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`between one network and another. And that's related to
`what these patents are talking about in a way.
` And I worked a lot -- extensively at my
`early career on modeling the performance of switches
`particularly. I switched when I went -- slightly when I
`went to Bellcore, where I was responsible for traffic
`engineering of all the packet components used by the
`Bell-operating companies. So this would include not only
`ATM, but included slow-speed data like X25, X75, but then
`also Frame Relay, which is a component here in at least
`some of the patents.
` ATM, Internet devices, I wrote -- I wrote
`standards to define the capabilities of these devices. On
`the other hand, I also tested these devices for
`conformance to the requirements that we -- that we wrote.
`So I had a dual purpose function.
` When I left Bellcore, I continued doing
`that kind of thing. Specifically, as I noted in my
`biography, I actually tested certain ATM switches. Tried
`to develop my own overall control strategy, the CAC
`strategy, that I -- we mentioned just -- just a minute
`ago.
` I did a lot of work for about maybe a two,
`three-year period for a fiber optic switch company called
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`TeraBurst, in which I was charged with developing network
`planning tools for a WDM network, which is an optical
`network, and planning tools for engineering, planning
`tools for -- for capacity augmentation, and relevant to
`this one, tools that would determine recovery times in
`event of failures; how would you rewrite -- what would you
`do. Okay.
` And -- and I developed, in fact, a user
`tool. I wrote the specification for it; I didn't write
`the code. I wrote the specification for how one would
`evaluate how fast the TeraBurst network would respond to
`failures. You cut a link, and what would happen, and how
`fast would it happen.
` I did work for -- as a consultant for some
`large telephone companies in terms of evaluating the
`benefits, pros and cons of various kinds of voiceover
`packet technologies. So this would have included
`voiceover ATM, voiceover MPLS; that kind of thing. And I
`did -- I did studies assessing for -- as a -- as an expert
`advisor.
` And I did similar things for a large
`consulting company, McKinsey, for example, where I -- I
`tried to assess the economic impacts of moving toward a
`voiceover IP network; what would the cost be, what would
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`the benefits be. And I wrote some position papers for
`them on that.
` I'm sure there -- oh, I also spent a lot of
`time probably on three to five systems doing Internet
`connection via satellites. Ufone planes, and you -- you
`know, they have Internet connections. Well, I worked for
`Boeing developing such a system on the early stages. So I
`did a traffic modeling, some of the architecture issues
`involved in that; how would you use a plane, for example,
`to access the Internet.
` I also work with people like DirecTV, how
`would you access a satellite from your home for the
`Internet, and have provided them with models so that they
`could access things on their own.
` I don't know if it's exhaustive, but I
`think it -- it covers the kind of areas that I've been
`involved with.
` Q. Okay. So this is work that you -- that you've
`done since about 1995 --
` A. Yes. I -- I --
` Q. -- for the consulting company?
` A. Yes. All the stuff about the -- again, the
`TeraBurst thing, the -- the consulting for -- for various
`companies, that was done as a private consultant.
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` DR. LEONARD J. FORYS
` Q. Okay. Okay, thank you.
` (Exhibit 1001 marked.)
` Q. (BY MR. GOKHALE) I'm going to hand you a copy
`of Exhibit 1001 to this proceeding.
` Do you recognize this exhibit?
` A. Yes. This appears to be a copy of the -- the
`patent at issue here.
` Q. Okay. And have you read the entire patent at
`issue?
` A. Yes.
` Q. Would you please -- sorry; could you please turn
`to Claim 6 in this patent. I'm going to refer to this as
`the '235 Patent from here on out. And this is on column
`18, starting about line 10. And if you could please read,
`to yourself --
` A. Thank you.
` Q. -- Claims -- Claims 5 and 6.
` A. All right.
` (Witness reviews document.)
` Okay. I've looked at it.
` Q. Okay, thank you.
` A. I've read it.
` Q. Thank you.
` (Exhibit 1006 marked.)
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. LEONARD J. FORYS
` Q. (BY MR. GOKHALE) I'm going to now hand you
`Exhibit 1006 from this proceeding.
` A. Thank you.
` MR. COOK: Thanks.
` Q. (BY MR. GOKHALE) Do you recognize this
`exhibit?
` A. Yes. This is the prior art reference I use by
`Karol; 6,628,617 is the patent number.
` Q. Now, is it your opinion in your declaration that
`we just talked about that Karol, Exhibit 1006, discloses
`every element of Claims 5 and 6 of the '235 Patent?
` A. Let me look at my declaration just to -- just to
`make sure.
` (Witness reviews document.)
` Okay. I begin my analysis on page -- on
`paragraph 205. Let me see what this says here.
` Paragraph 205, I state that: At least
`because Karol discloses the limitations of this claim
`element -- no, that's -- that's a summary of Claim 4; I
`take that back.
` I believe Karol renders obvious
`limitations, but I think I also may have used Stallings as
`well -- let me just -- just check -- because I know I used
`Stallings several places in my report. Yes, I notice in
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 16
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` DR. LEONARD J. FORYS
`column -- in paragraph 30 -- 233, I discussed Stallings
`as -- in addition to Karol, as meeting one of the claims.
` Q. Dr. Forys --
` A. Yes.
` Q. -- are you familiar with the difference between
`anticipation and obviousness in U.S. patent law?
` A. Yes.
` MR. COOK: Objection, form.
` THE WITNESS: Sorry.
` MR. COOK: Give me time to object, please.
` A. Generally.
` Q. (BY MR. GOKHALE) Are you --
` A. I'm not a lawyer.
` Q. Is it your opinion that Karol anticipates every
`element of Claims 5 and 6 of the '235 Patent?
` A. I -- well -- well, in several places, I state
`that Karol, in view of Stallings, anticipates certain
`claim elements. I'm looking at, for example, paragraph
`240 of my declaration. It renders obvious limitations, so
`I apply an obviousness argument, I believe, in
`certain -- at least in certain cases. Some cases, Karol
`does it by himself, but other cases, I -- I use the
`combination. 258, I say the same thing. That's for claim
`element 5C. Let me see for 5B here. For 5B, also the
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 17
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` DR. LEONARD J. FORYS
`same thing, same statement.
` And in some cases like 228, I see Karol
`discloses the limitations of this claim element under the
`broadest reasonable interpretation proposed herein. So
`it's -- it's a mixed bag.
` Q. Thank you.
` A. So I used both standards.
` Q. Okay. So you -- you found -- it's your opinion
`that -- first, it's your opinion that Karol does
`anticipate limitations of Claims 5 and 6 of the '235
`Patent?
` A. It appears so, but then I also say -- in the
`extent to the alternative, I also introduce combinations
`with -- you know, with Stallings.
` Q. Returning to Claim 6 of the '235 Patent.
` MR. COOK: I'm sorry; what --
` MR. GOKHALE: This is column 18 of -- of
`the '235 Patent.
` MR. COOK: Oh.
` Q. (BY MR. GOKHALE) It mentions an element called
`the packet destination address.
` A. Yes.
` Q. Can you state what element in Karol you believe
`corresponds to the packet destination address of Claim 6?
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. LEONARD J. FORYS
` MR. COOK: Objection, form.
` A. Let me just read what I said here.
` (Witness reviews document.)
` What I stated in paragraph 294 as an
`example was that TCP IP headers, which are -- which
`contain destination addresses, converted into ML5 ATM
`headers, which contain some kind of information that's
`equivalent. But there -- if you look at the -- at the
`language that I cited here from Karol, I think it's maybe
`a little clearer what -- what's happening. I'm looking at
`column 7, lines 14 onward. I want to point to a
`particular --
` THE REPORTER: Hold on.
` THE WITNESS: Sorry. Oh, thank you.
` A. I'd like to point out that, by doing this, it
`appears that TCP connections are terminated at the CL-CO
`gateways from each end point of the communication, and a
`connection of the pipes supported by the CO network is set
`up between CL-CO gateways, such as gateways 140 and 150 of
`Figure 1.
` One of -- one of ordinary skill in the art
`would read this to understand that the -- the destination
`address in the CO network is the -- is the gateway,
`terminating gateway, if you want, that exits the -- the CO
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 19
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` DR. LEONARD J. FORYS
`network. That would be the address that I would believe
`that correspond to what you're talking about.
` Q. (BY MR. GOKHALE) Okay. So in that description
`on column 7, starting at line 14 of Karol --
` A. Yes.
` Q. -- the first sentence says: Protocol converter
`450 is typically a software-implemented process in which
`the user payload is extracted from an IP datagram and
`converted to the CO format so that it can be carried
`directly on connections in the CO network.
` A. Uh-huh.
` Q. Are you interpreting the IP datagram described
`in this description in Karol to correspond to the packet
`that's referred to in Claims 5 and 6, in particular, the
`packets that has the packet destination address on it?
` A. Yes.
` Q. So is the packet destination address, is that an
`IP address on that packet?
` A. It comes in as an IP -- into the -- into
`the -- the gateway as an IP packet. The gateway decides
`whether or not it wants to send it -- continue sending an
`IP or send it to the connection-oriented network. If it
`decides to send it to the connection-oriented network, it
`takes the IP address and then determines what is the
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 20
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` DR. LEONARD J. FORYS
`terminating gateway, if you want, that's connected to the
`connection-oriented network so you can exit and get to
`that IP address.
` So it makes a conversion from an IP address
`into a network address, whatever -- Three Relay, ATM,
`whatever you're talking about, okay, but it has to
`identify the exiting gateway, and that's what is happening
`here.
` Q. I'll ask a different question.
` A. Okay.
` Q. The -- in Claim 6, it refers to modifying the
`packet destination address.
` A. Yes.
` Q. What is the destination address in Karol that is
`being modified?
` A. It says you have a -- that you have an IP
`address, which is the terminating point. You convert
`that, since you're only going to go -- the -- the -- the
`connection-oriented network has a terminating gateway that
`is used to connect then to the IP network. So it would be
`the address of the terminating gateway is what the
`conversion would be about.
` Q. So the IP packet that comes into the gateway has
`an IP address?
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 21
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` DR. LEONARD J. FORYS
` A. Yes.
` Q. What is that IP address referring to in Karol?
` A. The destination of -- of the -- of the packet in
`an IP network.
` Q. Is that the final destination?
` A. Yes.
` Q. Okay.
` A. That's correct.
` Q. So the actual destination of that packet that
`comes into the CL-CO gateway is not an address of -- of a
`device before that; is it?
` A. It could be, because he allows you -- one of
`Karol's -- you know, one of Karol's embodiments allows the
`termination to be a gateway, so it could be. Okay.
`But -- but, normally, that would not be the case. But
`Karol allows for that, so it could both of them be the
`same. But it would have two addresses in that case. It
`would have an IP address, and also have its own internal
`address; ATM address, a Frame Relay address, or whatever
`connection-oriented network you're talking about.
` But in a case where the -- the termination
`is not the router itself, then you make a conversion from
`the -- the destination address to the address of the
`terminating gateway. That's the conversion.
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. LEONARD J. FORYS
` Q. So what happens to the original IP address that
`is directed towards the -- the far end user in the
`network?
` A. Yeah. It -- it stays in the TCP header. So
`you're going to send TCP over ATM. And it describes
`it -- there's a -- there's a conversion -- protocol
`conversion called AAL5 in ATM, adaptation layer 5, which
`converts IP packets, like TCP, which have a TCP address in
`it. Encapsulates it, if you want -- it -- it doesn't do
`that. It chops it up into ATM cells or packets.
` So it takes the large TCP packet, chops it
`up into smaller cells, puts them into the cells, and
`transports it. When you get to the terminating gateway,
`you undo the process. So you reconstruct the TCP packet,
`and in it is the destination -- the original destination
`address in it.
` But that's not used to transport across the
`network. What's used to transport across a connection or
`a network are ATM or Frame Relay or MPLS labels. They
`don't use the addresses. They use labels instead to
`transport. It's the -- the switching is done on what they
`call layer 2. But you don't destroy the original address.
`It stays there, and you unravel it at the end to find out
`what your destination is, and then you send it to the
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. LEONARD J. FORYS
`destination. That's why you need the conversion to occur.
` Q. So you're saying the original IP address stays
`there?
` MR. COOK: Objection, form.
` A. The original IP address is maintained in the
`IP -- in the TCP packet.
` Q. (BY MR. GOKHALE) Okay.
` A. But the TCP packet is transported over a
`connection-oriented network using connection-oriented
`protocols, connection-oriented addresses -- a protocol
`conversion had to take place. So that address now is no
`longer the destination address internal to the
`connection-oriented network --
` THE REPORTER: Slower, please.
` THE WITNESS: I'm sorry.
` A. Internal to the connection-oriented network is
`the terminating gateway address. That's what you're
`shooting for. That's the conversion that takes place.
` Q. (BY MR. GOKHALE) Returning to Claim 6 of the
`'235 Patent.
` A. Yep.
` Q. Does it require a protocol conversion to take
`place?
` MR. COOK: Objection, form.
`
`TSG Reporting - Worldwide 877-702-9580
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`FatPipe Exhibit 2004, pg. 24
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` DR. LEONARD J. FORYS
` A. It implies it by modifying the packet
`destination address. So it's implied in there. It's not
`required, but it's implied.
` Q. (BY MR. GOKHALE) So are you interpreting
`protocol conversion to be equivalent to modifying the
`packet destination address?
` MR. COOK: Objection, form.
` A. It's part of the process. It's not identical.
`As I say, you have to -- I went through a long explanation
`how you have to identify the egress gateway, and that
`becomes a new address. And then that's what you use
`internal to the connection-oriented network. You don't
`worry about where the packet is going. All you care about
`is it's going to end up at the egress gateway. So the
`protocol conversion does that for you.
` I mean, Karol has -- has -- is -- is an
`embodiment that does that. The patent could have other
`embodiments that do it as well. So they're not
`necessarily in need of protocol conversion. I don't know.
`I mean, I'll leave that open. Karol does it, though.
` Q. (BY MR. GOKHALE) Okay, thank you.
` MR. GOKHALE: Sorry; this is a big one.
` MR. COOK: Okay. Stallings?
` MR. GOKHALE: Yeah.
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. LEONARD J. FORYS
` MR. COOK: Yeah.
` THE WITNESS: Oh, yeah, Stallings.
` MR. COOK: Yeah. I
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