Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`AT&T Services, Inc.
`Petitioner
`v.
`
`Digifonica (International) Limited
`Patent Owner
`
`Patent No. 9,179,005
`_______________
`
`Inter Partes Review No. (To Be Assigned)
`____________________________________________________________
`
`
`
`DECLARATION OF JAMES BRESS IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 et seq.
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`1
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`AT&T, Exh. 1003, p. 1
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`Table of Contents
`I.
`Introduction ......................................................................................................................... 7
`II.
`Summary of Opinions ......................................................................................................... 8
`III.
`Background and Qualifications ........................................................................................... 9
`IV. Materials Considered ........................................................................................................ 20
`V.
`Understanding of the Law ................................................................................................. 21
`A.
`Legal Standard for Prior Art ....................................................................................... 21
`B.
`Legal Standard for Obviousness ................................................................................. 23
`C.
`Legal Standard for Claim Construction ...................................................................... 27
`Level of Skill of One of Ordinary Skill in the Art ............................................................ 28
`VI.
`VII. Brief Overview of the ʼ005 Patent .................................................................................... 30
`A. Admitted Prior Art in the Background ........................................................................ 30
`B.
`The Purported Invention of the ʼ005 Patent ................................................................ 31
`C.
`The Challenged Claims ............................................................................................... 41
`VIII. State of the Art .................................................................................................................. 45
`IX.
`Analysis of the Prior Art ................................................................................................. 125
`A. Nadeau ...................................................................................................................... 126
`B.
`Fisher......................................................................................................................... 134
`C.
`Kelly .......................................................................................................................... 137
`D. Vu .............................................................................................................................. 139
`Summary of the Grounds for Unpatentability of the Challenged Claims ....................... 140
`Fisher-Vu Renders obvious Claims 74–79, 83–84, 88–89, 92, 94–96, and 98–99 ...... 141
`A.
`Claim 74 .................................................................................................................... 142
`1. Preamble: “A method of routing communications in a packet switched network in
`which a first participant identifier is associated with a first participant and a
`second participant identifier is associated with a second participant in a
`communication” .................................................................................................. 142
`2. Limitation 74a: “after the first participant has accessed the packet switched
`network to initiate the communication, using the first participant identifier to
`locate a first participant profile comprising a plurality of attributes associated with
`the first participant” ............................................................................................ 151
`3. Limitation 74b: “when at least one of the first participant attributes and at least a
`portion of the second participant identifier meet a first network classification
`criterion, producing a first network routing message for receipt by a controller, the
`first network routing message identifying an address in a first portion of the
`packet switched network, the address being associated with the second
`participant, the first portion being controlled by an entity” ................................ 156
`
`X.
`XI.
`
`
`
`2
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`J.
`
`K.
`
`L.
`
`4. Limitation 74c: “when at least one of the first participant attributes and at least a
`portion of the second participant identifier meet a second network classification
`criterion, producing a second network routing message for receipt by the
`controller, the second network routing message identifying an address in a second
`portion of the packet switched network, the second portion not controlled by the
`entity” .................................................................................................................. 165
`Claim 75: “The method of claim 74, wherein the packet switched network comprises
`the Internet” .............................................................................................................. 169
`Claim 76: “The method of claim 74, wherein the first participant identifier comprises
`a first participant telephone number or username” ................................................... 170
`Claim 77: “The method of claim 74, wherein the second participant identifier
`comprises a second participant telephone number or username” ............................. 170
`Claim 78: “The method of claim 74, wherein the communication comprises a voice-
`over-IP communication” ........................................................................................... 170
`Claim 79: “The method of claim 74, wherein the packet switched network is accessed
`via an Internet service provider” ............................................................................... 171
`Claim 83: “The method of claim 74, wherein the first network classification criterion
`is satisfied when an address associated with the first participant and the address
`associated with the second participant are both in the first portion of the packet
`switched network” .................................................................................................... 172
`Claim 84: “The method of claim 74, wherein the address in the first portion is
`accessible through the first participant's Internet service provider” ......................... 173
`Claim 88: “The method of claim 74, wherein the entity is an entity supplying
`communication services for the first portion” .......................................................... 174
`Claim 89: “The method of claim 74, wherein the second network classification
`criterion is satisfied when access to the second participant requires routing through a
`portion of the packet switched network operated by a communication service
`supplier” .................................................................................................................... 175
`Claim 92: “The method of claim 74, wherein the address in the second portion of the
`packet switched network comprises an address accessed by a communication service
`supplier” .................................................................................................................... 176
`Claim 94 .................................................................................................................... 177
`1. Preamble: “A system for routing communications in a packet switched network in
`which a first participant in a communication has an associated first participant
`identifier and a second participant in the communication has an associated second
`participant identifier” .......................................................................................... 177
`2. Limitation 94a: “a controller” ............................................................................. 178
`3. Limitation 94b: “a processor operably configured to access a memory” ........... 178
`4. Limitation 94c: “after the first participant has accessed the packet switched
`network to initiate the communication locate a first participant profile in the
`
`
`
`3
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`AT&T, Exh. 1003, p. 3
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`memory using the first participant identifier, the first participant profile
`comprising a plurality of attributes associated with the first participant” .......... 179
`5. Limitation 94d: “produce a first network routing message when at least one of the
`first participant attributes and at least a portion of the second participant identifier
`meet a first network classification criterion, the first network routing message
`identifying an address in a first portion of the packet switched network, the
`address being associated with the second participant, the first portion being
`controlled by an entity” ....................................................................................... 180
`6. Limitation 94e: “produce a second network routing message when at least one of
`the first participant attributes and at least a portion of the second participant
`identifier meet a second network classification criterion, the second network
`routing message identifying an address in a second portion of the packet switched
`network, the second portion not controlled by the entity” .................................. 180
`M. Claim 95 .................................................................................................................... 181
`N.
`Claim 96 .................................................................................................................... 181
`O.
`Claim 98 .................................................................................................................... 181
`P.
`Claim 99 .................................................................................................................... 181
`XII. Nadeau-Kelly Renders obvious Claims 74–79, 83–84, 88–89, 92, 94–96, and 98–99 182
`It was obvious to modify the service logic controller (“SLC”) of Nadeau to perform
`A.
`the gateway selection process taught in Kelly ........................................................... 182
`Claim 74 .................................................................................................................... 186
`1. Preamble: “A method of routing communications in a packet switched network in
`which a first participant identifier is associated with a first participant and a
`second participant identifier is associated with a second participant in a
`communication” .................................................................................................. 186
`2. Limitation 74a: “after the first participant has accessed the packet switched
`network to initiate the communication, using the first participant identifier to
`locate a first participant profile comprising a plurality of attributes associated with
`the first participant” ............................................................................................ 189
`3. Limitation 74b: “when at least one of the first participant attributes and at least a
`portion of the second participant identifier meet a first network classification
`criterion, producing a first network routing message for receipt by a controller, the
`first network routing message identifying an address in a first portion of the
`packet switched network, the address being associated with the second
`participant, the first portion being controlled by an entity” ................................ 192
`4. Limitation 74c: “when at least one of the first participant attributes and at least a
`portion of the second participant identifier meet a second network classification
`criterion, producing a second network routing message for receipt by the
`controller, the second network routing message identifying an address in a second
`portion of the packet switched network, the second portion not controlled by the
`entity” .................................................................................................................. 201
`
`B.
`
`
`
`4
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`AT&T, Exh. 1003, p. 4
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`

`

`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`J.
`
`K.
`
`L.
`
`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`C.
`
`Claim 75: “The method of claim 74, wherein the packet switched network comprises
`the Internet” .............................................................................................................. 208
`Claim 76: “The method of claim 74, wherein the first participant identifier comprises
`a first participant telephone number or username” ................................................... 208
`Claim 77: “The method of claim 74, wherein the second participant identifier
`comprises a second participant telephone number or username” ............................. 208
`Claim 78: “The method of claim 74, wherein the communication comprises a voice-
`over-IP communication” ........................................................................................... 209
`Claim 79: “The method of claim 74, wherein the packet switched network is accessed
`via an Internet service provider” ............................................................................... 210
`Claim 83: “The method of claim 74, wherein the first network classification criterion
`is satisfied when an address associated with the first participant and the address
`associated with the second participant are both in the first portion of the packet
`switched network” .................................................................................................... 210
`Claim 84: “The method of claim 74, wherein the address in the first portion is
`accessible through the first participant's Internet service provider” ......................... 212
`Claim 88: “The method of claim 74, wherein the entity is an entity supplying
`communication services for the first portion” .......................................................... 213
`Claim 89: “The method of claim 74, wherein the second network classification
`criterion is satisfied when access to the second participant requires routing through a
`portion of the packet switched network operated by a communication service
`supplier” .................................................................................................................... 214
`Claim 92: “The method of claim 74, wherein the address in the second portion of the
`packet switched network comprises an address accessed by a communication service
`supplier” .................................................................................................................... 215
`M. Claim 94 .................................................................................................................... 215
`1. Preamble: “A system for routing communications in a packet switched network in
`which a first participant in a communication has an associated first participant
`identifier and a second participant in the communication has an associated second
`participant identifier” .......................................................................................... 216
`2. Limitation 94a: “a controller” ............................................................................. 217
`3. Limitation 94b: “a processor operably configured to access a memory” ........... 217
`4. Limitation 94c: “after the first participant has accessed the packet switched
`network to initiate the communication locate a first participant profile in the
`memory using the first participant identifier, the first participant profile
`comprising a plurality of attributes associated with the first participant” .......... 218
`5. Limitation 94d: “produce a first network routing message when at least one of the
`first participant attributes and at least a portion of the second participant identifier
`meet a first network classification criterion, the first network routing message
`identifying an address in a first portion of the packet switched network, the
`
`
`
`5
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`AT&T, Exh. 1003, p. 5
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`address being associated with the second participant, the first portion being
`controlled by an entity” ....................................................................................... 219
`6. Limitation 94e: “produce a second network routing message when at least one of
`the first participant attributes and at least a portion of the second participant
`identifier meet a second network classification criterion, the second network
`routing message identifying an address in a second portion of the packet switched
`network, the second portion not controlled by the entity” .................................. 219
`Claim 95 .................................................................................................................... 220
`N.
`Claim 96 .................................................................................................................... 220
`O.
`Claim 98 .................................................................................................................... 220
`P.
`Claim 99 .................................................................................................................... 220
`Q.
`XIII. Conclusion ...................................................................................................................... 221
`
`6
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`AT&T, Exh. 1003, p. 6
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`I, James Bress, declares as follows:
`
`I.
`
`INTRODUCTION
`1.
`
`I have been retained as a technical expert on behalf of petitioner
`
`AT&T Services, Inc. in connection with the above-captioned inter partes review
`
`(“IPR”) of U.S. Patent No. 9,179,005 (“the ’005 Patent”). I understand that the
`
`’005 Patent is currently assigned to Digifonica (International) Limited.
`
`2.
`
`I am familiar with the technology at issue in the period prior to
`
`November 2, 2006, which is the filing date of the provisional application to which
`
`the ’005 Patent claims priority. I have not performed an analysis to determine
`
`whether any of the claims of the ’005 Patent should be entitled to this earlier
`
`priority date. However, none of the opinions stated herein would change if any
`
`claim were entitled to this earlier priority date.
`
`3.
`
`I have been asked to provide my technical opinion on concepts
`
`discussed in the ’005 Patent and the reference documents, as well as my technical
`
`opinion on how these concepts relate to several ’005 Patent claim limitations in the
`
`context of the specification.
`
`4.
`
`I have been asked to consider how a person of ordinary skill in the art
`
`would understand the claims of the ’005 Patent and the applied reference
`
`
`
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`combinations. In reaching the opinions stated herein, I have considered the ’005
`
`Patent and the references discussed herein in the context of my own education,
`
`training, research, knowledge, and personal and professional experience.
`
`5.
`
`I am being compensated at my standard hourly rate of $350.00 per
`
`hour. My compensation is not dependent on the outcome of this IPR and in no
`
`way affects the substance of my statements in this declaration.
`
`6.
`
`I make this declaration based upon my own personal knowledge and,
`
`if called upon to testify, would testify competently to the matters contained herein.
`
`I may rely on handbooks, textbooks, technical literature, my own personal
`
`experience in the field, and other relevant materials and/or information to
`
`demonstrate the state of the art in the relevant period and the evolution of relevant
`
`technologies.
`
`II.
`
`SUMMARY OF OPINIONS
`7.
`
`After studying the ’005 Patent, its file history, and the prior art, and
`
`considering the subject matter of the claims of the ’005 Patent in light of the state
`
`of
`
`technical advancement
`
`in
`
`the area of
`
`IP
`
`telephony networks and
`
`telecommunications networks prior to the filing of the ’005 Patent, I reached the
`
`conclusions discussed herein.
`
`
`
`8
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`8.
`
`In light of these general conclusions, and as explained in more detail
`
`throughout this Declaration, it is therefore my opinion that Claims 1, 24–26, 49–
`
`50, 73–79, 83–84, 88–89, 92, 94–96, and 98–99 (the “Challenged Claims”) of the
`
`ʼ005 Patent are invalid as being obvious in the relevant time frame (prior to
`
`November 2006) in light of the knowledge of a person of ordinary skill in the art at
`
`that time and the teachings, suggestions, and motivations present in the prior art.
`
`III. BACKGROUND AND QUALIFICATIONS
`9. My qualifications are stated more fully in my curriculum vitae. See
`
`EX1004. As reflected in my curriculum vitae, and as explained in more detail
`
`below, I have experience with the technology described in the ’005 Patent,
`
`including
`
`telecommunications network architectures, protocols, addressing,
`
`standards, Public Switched Telephone Networks (PSTN), Voice-over-IP (VoIP)
`
`telephony and networks, mobile networks, interworking between PSTN, VoIP, and
`
`mobile networks, the Session Initiation Protocol (SIP), the H.323 Protocol, the
`
`Transmission Control Protocol (TCP), the Internet Protocol (IP), call processing
`
`for both PSTN, VoIP, and mobile networks, network interfacing, network
`
`interconnection, gateways, call controllers, soft switches, etc. Here I provide a
`
`brief summary of my qualifications.
`
`
`
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`

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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`
`10.
`
`I received a Bachelor of Science degree in electrical engineering from
`
`the University of North Carolina at Charlotte in 1985, and a Master of Science
`
`degree in electrical engineering from the California Institute of Technology in
`
`1987. From 1982 to 1984, while still attending the University of North Carolina, I
`
`My duties there included technical writing for field‐located energy management
`field‐located equipment and host systems.
`
`was an engineering technician at Process Systems, Inc., located in Charlotte, NC.
`
`equipment which was remotely accessible via modems and telephone lines, host
`
`system software and user manuals, as well as developing test equipment for the
`
`11.
`
`In addition to my educational background, I have over 30 years of
`
`experience in the telecommunications industry. In 1985, after graduating from the
`
`University of North Carolina, I was employed by Bell Communications Research,
`
`Inc. (also known as Bellcore), located in Piscataway, NJ. I was an engineer and
`
`Member of the Technical Staff (MTS) at Bellcore with responsibility for numerous
`
`telecommunications systems operations and development projects. For these
`
`systems-related projects, I was responsible for development, integration, and
`
`testing including computers, network hardware, network interconnections, network
`
`signaling, network protocols, network equipment provisioning and configurations,
`
`database technologies, applications and software development, user interfaces,
`
`
`
`10
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`AT&T, Exh. 1003, p. 10
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`client-server operations, test systems development, and telephony features
`
`development and prototyping.
`
`12.
`
`In 1995, I founded AST Technology Labs, Inc., located in Melbourne,
`
`Florida, where I am the President and Chief Technical Officer. AST’s business is
`
`focused on telecommunications equipment and networks. My responsibilities at
`
`AST include the development of detailed system specifications, architectures,
`
`hardware, and software for custom telecommunications and telephony test systems
`
`including analog, digital, VoIP, and wireless. My responsibilities also include
`
`researching and analyzing the products that are tested at AST to enable system
`
`configurations, preparation for testing, troubleshooting hardware and software, and
`
`providing consulting to AST’s customers.
`
`13.
`
`I have served on numerous standards setting committees of the
`
`Telecommunications Industry Association (“TIA”) and have been a prime
`
`contributor, editor, and working group chairman for the development of many
`
`published ANSI
`
`(American National
`
`Standards
`
`Institute)
`
`/ TIA
`
`telecommunications standards. I served continuously from 2000 to 2015 as
`
`chairman or vice chairman of the TIA TR41.3 engineering subcommittee for
`
`Performance and Accessibility for Communications Products. Starting in 2015 and
`
`to the present, I am the chairman of the parent engineering committee, TR41. I
`
`
`
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`also authored numerous system requirement publications and recommendations for
`
`Bellcore. Additionally, I am a named inventor on four issued US patents.
`
`14. My first assignment during my employment at Bellcore was in the
`
`software operations area. This area was focused on operations system software
`
`including PREMIS (PREMise Information System), SOAC (Service Order
`
`Analysis & Control), and LFACS (Loop Facility Assignment and Control System).
`
`These software systems integrated hardware (network access and switching
`
`equipment and computers) and software (database, reporting, network control,
`
`monitoring, management, and user interface) used for the operations systems used
`
`by Bellcore’s owners (the Regional Bell Operating Companies (RBOCs) or “Baby
`
`Bells”) in support of the Public Switched Telephone Network (PSTN). My
`
`experiences during this assignment included software installation and testing,
`
`network management, network equipment provisioning, database configuration
`
`and schema development, network connectivity troubleshooting, and software
`
`documentation.
`
`15. My next assignment at Bellcore was on a development team for the
`
`“Information Gateway” project. My responsibilities included data network design,
`
`network connectivity implementation, network equipment configurations and
`
`provisioning, and troubleshooting for the networked connectivity of computer
`
`
`
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`systems located in multiple states across the USA. Networking for this project
`
`included PSTN and data network facilities and services and interworking between
`
`the PSTN and data networks. The computer systems provided access to servers,
`
`databases and terminal interface software from distributed network connected
`
`workstations. In addition to networking, I was also responsible for database
`
`system design and distributed network access to compressed image files located on
`
`a network connected server. One of my many projects included analysis,
`
`configurations, and troubleshooting of X.25 data network termination circuits, and
`
`the related termination equipment, to enable numerous system demonstrations that
`
`were set up in multiple locations across the USA.
`
`16. My work in Bellcore’s “New Services Development” area included
`
`designing and prototyping new services that were focused on the use of the
`
`Advanced Intelligent Network (AIN) system features and components. These
`
`projects required an understanding of telecommunications systems network
`
`architectures, signaling, protocols, standards, and features operations. One of my
`
`projects in this area included interfacing to AIN components including Service
`
`Control Points (SCP) and Signaling Transfer Points (STP) to implement a
`
`telephone network control feature. I am the first named inventor on a patent for
`
`
`
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`one of the systems developed which was integrated with the AIN (U.S. Patent No.
`
`5,570,420, “Customer premise equipment network integrator”).
`
`17. Another assignment I had at Bellcore involving network signaling and
`
`features was for the development of the Analog Display Services Interface (ADSI)
`
`and the Caller ID on Call Waiting (CIDCW) feature that is now well known to
`
`telephone users. My responsibilities included analyzing PSTN switching systems
`
`architectures and capabilities, and feature related network triggers and service
`
`logic. I was also responsible for developing prototype systems, including hardware
`
`and software, for network signaling and features evaluation. Additionally, I was
`
`responsible for developing Bellcore’s Customer Premises Equipment (CPE) test
`
`lab (including hardware, software, lab operations, and reporting) to support the
`
`development of new telephony devices used with the ADSI and CIDCW features.
`
`18.
`
`I started designing network signal detection systems as a
`
`troubleshooting assignment for the Bell Companies. At this time in the late 1980s,
`
`most prison systems used primarily coin telephones, which were owned and
`
`operated by the Bell Companies, to provide telephony services to inmates. Inmates
`
`had discovered that they could defraud the telephone system by playing certain
`
`music into the telephone transmitter (microphone), which would cause the Bell
`
`Company Central Office (CO) accounting and billing systems to errantly record
`
`
`
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`sometimes hundreds of dollars of credit due to falsely detecting coin-drop-
`
`confirmation tones. After this problem was solved, the knowledge I gained was
`
`used to develop Bellcore’s prototype CPE Alerting Signal (CAS) detector that was
`
`a key component of what became the widely popular Caller ID on Call Waiting
`
`(CIDCW) telephony feature. This work led to the issuing of U.S. Patent No.
`
`5,519,774 “Method and system for detecting at a selected station an alerting signal
`
`in the presence of speech” for which I am a named inventor.
`
`19.
`
`I am the first named inventor on U.S. Patent No. 7,076,031 “System
`
`and Method for Telephone Signal Collection and Analysis.” The impetus for this
`
`patent was the development of the TSA-6000® telephone signal recording and
`
`analysis system. This project culminated into the manufacture and sale of TSA-
`
`6000® systems starting in 2002. I was the chief architect for the design of this
`
`system and I continue to serve as the technical lead for this project and product.
`
`The TSA-6000® system was designed using the concept of functional units that
`
`can be combined in any physical implementation including the functions of 1)
`
`signal data capture and recording; 2) analysis of the captured signaling data to
`
`identify pre-defined telephone signals and events occurring in the recorded signals,
`
`as well as identifying the states, or modes of the telephone line; and 3) a user-
`
`friendly graphical interface for viewing signals and analysis data, and also for
`
`
`
`15
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`Declaration of James Bress in Support of Petition for Inter Partes Review
`of U.S. Patent No. 9,179,005
`
`system configurations such as changing the parameters used during the analysis
`
`operations. The software of the TSA-6000® was developed using C language and
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`runs on a Windows®-based computer. The software has been revised over the
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`years for multiple reasons including to add new pre-defined si