Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
`VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` DEPOSITION OF HENRY H. HOUH, Ph.D.
`
` VOLUME I
`
` TAKEN ON BEHALF OF THE PATENT OWNER
`
` JANUARY 25, 2017
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`1
`
`Voip-Pal Ex. 2043
`IPR2016-01198
`
`Voip-Pal Ex. 2010
`IPR2017-01398
`
`
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
`VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` DEPOSITION OF HENRY H. HOUH, Ph.D.
`
` VOLUME I
`
` TAKEN ON BEHALF OF THE PATENT OWNER
`
` JANUARY 25, 2017
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`1
`
`Voip-Pal Ex. 2043
`IPR2016-01198
`
`Voip-Pal Ex. 2010
`IPR2017-01398
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` I N D E X
` WITNESS: PAGE
` HENRY H. HOUH, Ph.D.
` EXAMINATION BY MR. THOMAS 5
`
` E X H I B I T S
` NO. DESCRIPTION PAGE
` Exhibit 1 Declaration of Henry H. Houh, Ph.D. 6
` Exhibit 2 United States Patent Chu '684 9
` Exhibit 3 United States Patent Chu '366 9
` Exhibit 4 Petition for Patent '005 9
` Exhibit 5 United States Patent 28
` Application Publication for '919
` Exhibit 6 United States Patent '005 52
`
` (Exhibits were scanned and attached to electronic
` copies and are now retained by Mr. Seitz at Erise.)
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`2
`
`1
`2
`3
`4
`
`5 6
`
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
` VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` TELEPHONIC DEPOSITION OF HENRY H. HOUH,
`PH.D., produced, sworn and examined on
`January 25, 2017, at the offices of Erise IP, P.A.,
`6201 College Boulevard, Suite 300, Overland Park,
`Kansas 66211, before Lauren N. Lawrence, RPR, KS CCR,
`and Notary Public within and for the State of
`Missouri, in a certain cause now pending in the United
`States Patent and Trademark Office before the Patent
`Trial and Appeal Board between APPLE INC., Petitioner,
`vs. VOIP-PAL.COM, INC., Patent Owner; on behalf of the
`Patent Owner.
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`3
`
`1
`2
`
`3 4
`
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` A P P E A R A N C E S
`
`APPEARING FOR THE PETITIONER:
` Mr. Adam P. Seitz
` Mr. Paul R. Hart
` ERISE IP, P.A.
` 6201 College Boulevard
` Suite 300
` Overland Park, Kansas 66211
` 913.777.5600
` adam.seitz@eriseip.com
` paul.hart@eriseip.com
`APPEARING TELEPHONICALLY FOR THE PATENT OWNER:
` Mr. Ryan L. Thomas
` Mr. David A. Gileff
` VOIP-PAL.COM
` 2740 E 1700 N
` Layton, Utah 84040
` 435.630.6005
` thomasattorney711@gmail.com
` Mr. Kerry Taylor
` KNOBBE, MARTENS, OLSON & BEAR, LLP
` 2040 Main Street, 14th Floor
` Irvine, California 92614
` 858.707.4000
` kerry.taylor@knobbe.com
`
`Court Reporter:
`Lauren N. Lawrence, RPR, KS CCR
`Missouri Notary Public
`Midwest Litigation Services
`1301 Oak Street, Suite B
`Kansas City, Missouri 64106
`816-221-1160
`1-800-280-3376
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`4
`
`1
`
`23
`
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` IT IS HEREBY STIPULATED AND AGREED by and between
`counsel for the Petitioner and counsel for the
`Patent Owner that this deposition may be taken in
`shorthand by Lauren N. Lawrence, a Registered
`Professional Reporter and Missouri Notary Public, and
`afterwards transcribed into typewriting; and the
`signature of the witness is expressly reserved.
` * * * * *
` (Deposition commenced at 10:20 a.m.)
` HENRY H. HOUH, Ph.D.,
`having been first duly sworn and examined on behalf of
` the Petitioner, testified as follows:
` EXAMINATION
`BY MR. THOMAS:
` Q. Dr. Houh, I'd like to begin discussing the
`qualifications of a person of ordinary skill in the
`art.
` You described in your declaration at
`paragraph 19, page 6 -- and for purposes of this first
`discussion, I will be referring to your declaration
`associated with the '005. There's similarity
`between the -- the declarations. And so for
`simplicity's sake, I will use the '005.
` At paragraph 19 on page 6, you indicate
`that --
`
`5
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MR. HART: Hey, Ryan --
` Q. (By Mr. Thomas) -- the level of ordin- --
` MR. HART: We need to -- we need to mark
`that as an exhibit here. And -- and give it to --
` MR. THOMAS: Okay. That would be --
` MR. HART: -- give it to Dr. Houh.
` MR. THOMAS: Okay.
` MR. HART: So we're going to mark that as
`Exhibit 1, and you can refer to it however you'd
`like for -- for purposes of the record.
` MR. THOMAS: Thank you very much.
` (Houh Exhibit 1 was marked for
`identification.)
` MR. THOMAS: Are we ready to go?
` MR. HART: He is flipping to the page you
`referenced right now.
` A. Did you say paragraph 19?
` Q. (By Mr. Thomas) Yes. Paragraph 19. There
`you indicate the level of ordinary skill in the art as
`an individual with a bachelor's degree in an academic
`area emphasizing electrical engineering and two to
`four years of industry experience.
` Could you indicate, please --
` THE REPORTER: I'm sorry. What was that?
` Q. (By Mr. Thomas) -- an approximation --
`
`6
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` THE REPORTER: Can you repeat that?
` Q. (By Mr. Thomas) -- the num- --
` MR. THOMAS: We're getting feedback here.
`Are we still all right?
` MR. SEITZ: I think the court reporter just
`missed part of your question. After you read a
`portion of 19, it cut out.
` MR. THOMAS: Thank you.
` Q. (By Mr. Thomas) Again, the portion of 19
`is simply the description of a person of ordinary
`skill in the art as having a bachelor's degree and two
`to four years of industry experience.
` I would like Dr. Houh, please, to give me
`an approximation of the number of individuals in the
`United States who might meet that qualification.
` MR. HART: Objection to form.
` Q. (By Mr. Thomas) The -- please.
` A. My opinion is about the level or ordinary
`skill in the art. I don't have an opinion about
`number of people in the U.S. -- the -- what you asked.
` Q. (By Mr. Thomas) Yes. That's what I asked.
` Let's move then to paragraph 37 on page 17.
` A. Okay.
` Q. All right. You -- at the beginning of
`paragraph 37, you indicate that the system of Chu '684
`
`7
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`contains infrastructure needed to support the
`formatting, and that's following the discussion in the
`previous paragraph that describes the formatting
`compatibility of Chu '366.
` Could you give your opinion on how Chu '366
`would be added into Chu '684 to accomplish the
`reformatting to which you've referred?
` A. Okay. I'm going to take a look at this,
`but I don't have the Chu -- either of the Chu
`references in front of me. So I'd like to read
`this -- you know, review this first, but I think I
`would like to get a copy of those as well.
` Q. That would be great. Let's -- would you
`like to hold on that question, or do you want to take
`a moment to -- to review that? I assume that the --
`you have copies of both of the Chus there. Shall we
`mark them as Exhibits 2 and 3?
` A. There's a significant amount of background
`clatter. I was -- I don't know where it's coming
`from. But...
` Q. (By Mr. Thomas) I'm sorry. I was asking
`whether you wanted to take a moment now to refer to
`Chu '684 and Chu '366. And, if so, we want to get
`those on the record. Let's mark them as Exhibits 2
`and 3, please.
`
`8
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MR. HART: Sounds good, Ryan. Let's just
`give the court reporter a few seconds of silence to go
`ahead and mark those. Chu '684 will be Exhibit 2, and
`Chu '366 will be Exhibit 3.
` MR. THOMAS: Thank you.
` (Houh Exhibits 2 and 3 were marked for
`identification.)
` A. Also, may I take a look at the petition as
`well for the '005?
` MR. HART: All right.
` And, Ryan, the petition for the '005 is
`being marked Exhibit 4.
` MR. THOMAS: Thank you.
` (Houh Exhibit 4 was marked for
`identification.)
` A. Okay. Could you repeat the question,
`please?
` Q. (By Mr. Thomas) Yes.
` You indicate that it would be obvious to
`include the reformatting of Chu '366 into Chu '684. I
`would like your opinion on how that would be
`accomplished.
` A. Sure. So the way the combination of the
`Chu '684 and '366 would work, if you take a look at
`the above paragraph, there are -- there's a citation
`
`9
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`to the Chu '684 in column 8:65 through column 9:1, and
`it talks about what the Chu '684 steps are at the --
`at the server 110, and it says, "At step 608, after
`receiving all the dialed digits from the phone 101,
`server 110 consults its dial plan to determine whether
`the call is local to another on-net phone or to a
`phone that is on the PSTN."
` So at -- at that step in the Chu '684, it's
`receiving the dial digits. But the way the
`combination reference would -- would work is that
`the -- the -- the steps described in -- in the
`Chu '366 reference -- and it goes on to say, after
`that, with examples one thou- -- sorry -- Exhibit 1007
`Chu '366, that Figure 6.
` So if you look at Figure 6 of the Chu '366,
`it describes a number of steps starting with the
`"Parse Entered Telephone Number" at the top left
`corner, labeled 156, and it goes through --
` Q. Yes.
` A. -- a series of steps in the flowchart,
`culminating in the lower right-hand corner that says,
`"Place Call." And these series of steps create a full
`E.164 phone number if -- if the right conditions are
`met. And -- and then it says, "Place Call."
` And so the way the combination would work
`
`10
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`was that the dialed digits would be received from the
`output of this '366 step into the input at that step
`of the Chu '684, which I described at the bottom --
`bottom of column 8, where now it's receiving the
`dialed digits, but it's receiving the dialed digits
`passed through the '366 Chu, as described in Figure 6.
` And -- and -- and now the -- and that's how
`the combination would work, and there's the
`infrastructure in the '684 to support that -- to
`support the reformatting. And -- and for the reasons
`I've discussed elsewhere, there are motivations to
`make that combination. But at -- at that step -- at
`that particular point, that's how the -- the system
`would work. And then the further operation of
`Chu '684 system follows from -- from having that
`Chu '366 formatting step -- or reformatting step at
`that point.
` Q. And, Dr. Houh, is your opinion that the
`reformatting step would occur in the server or what --
`what physically would be the location of that
`operation?
` A. Well, I mean, the server, as I've discussed
`elsewhere -- let me find some good references for you.
`Give me one second, please.
` So the -- the system of the Chu '684 does
`
`11
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`include unique identification information with respect
`to the -- the phones themselves. For example, there
`is a -- I'm -- I'm just trying to figure out --
`there's a lot of references to the E.164 numbers,
`but --
` Q. Yes.
` A. -- I know there's a specific citation I
`have in mind. But it contains, you know, E.164 number
`mappings for -- and IP addresses for the phones. If
`you look in the -- this is the petition on page 18 --
`I -- I describe a little bit of this here. And if you
`look at paragraph 45 in my declaration, you'll also
`see some discussion about that. Maybe I can turn
`there right now.
` So the Chu '8- -- '684 patent teaches that
`each -- each user -- phone user is assigned their --
`they use a dial plan. They use their own dial plan.
`They have a unique IP address, and they have a unique
`E.164-compliant telephone number. I think that's at
`the top of page -- I think this is 21 of my -- my
`declaration. This is paragraph 45.
` And so that Chu -- that information -- you
`know, the server needs that information to be able to
`connect calls correctly. So that's part of the
`infrastructure that already uniquely -- has unique
`
`12
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`information about each of the users -- the phones
`connected to the server of the -- of the Chu '684.
` And now the -- the -- the Chu '366
`reference talks about these -- I want to get the right
`wording here -- I think it's "profile." What's the
`right word?
` Q. Caller profile is one of the expressions.
` A. Yes. I just want to make sure I -- I see
`that. "Locating a caller dialing profile." Okay. So
`that's -- oh, where do I see it from the '366? I just
`want to use the right terminology here. A "call
`origin profile." I'm -- I'm taking that from my --
`this is the -- sorry. This is the petition at
`page 18, but then it refers to Chu '366 at column
`2:9-15. Yes. I think the "call origin profile" is
`what the Chu '366 patent used to describe this
`individual -- individualized profile for every user,
`every caller in the Chu '366. And the Chu '684
`already has information about the individual users
`of -- of the -- each phone in the system of the -- of
`the '684 Chu system.
` I'm sorry. Could you repeat the question
`again, please?
` Q. Yes. The question was:
` Where physically does the reformatting
`
`13
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`occur? Is that at the server level or -- or at some
`other level in terms of the path of the data?
` A. Well, certainly, as I described from that
`citation in -- in the Chu '684 at the bottom of
`column 8, the server consults -- it says, "The
`server 110 consults its dial plan to determine whether
`the call is local to another on-net phone or to a
`phone that's on the PSTN."
` And that's after receiving all the dialed
`digits. And since the dialed digits come from this
`algorithmic step as illustrated in Figure 6 of the
`Chu '366 patent, that would be logical to put that --
`that algorithmic -- that -- include that in the
`server 110.
` And that's -- that's one way that that
`could be implemented. Because the server uses that
`number, that's the output of the Chu '366 Figure 6 to
`actually -- as the dialed digits in Chu '684 that it
`would use to consult its dial plan to determine
`whether the call is local to another on-net phone or
`to a phone that is on the PSTN.
` Q. In the proposed combination, would you
`reformat following the steps of Chu '336 [sic] after
`or before step 608 in Chu '684?
` A. I -- I think you said "Chu 336," but I --
`14
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`I -- to my understanding, it's "Chu '366."
` Q. '36- -- yes. I'm sorry if I misspoke.
`It's '366.
` A. So because the -- that step 608, it's --
`it's receiving the dialed digits, and I -- I stated
`that the -- the reformatting step of Figure 6 would
`happen to -- then the output would be those dialed
`digits. This -- this reformatting either happens
`as -- as part of 60- -- 608 or integrated into it,
`but -- or just prior to it.
` Q. Okay. Thank you.
` There is some confusion on my part relative
`to the use of the term "subscriber" in Chu '684.
`The -- at one point you quote, indicating that the --
`there could be many subscribers, each with multiple
`locations, that could be served by the same
`packet-switch network. Each subscriber uses their own
`IP address as well as their own dial plan.
` The question, specifically, is -- "many
`subscribers, each with multiple locations." That
`sounds like the subscribers that are being referenced
`are a collective -- an enterprise, rather than an
`individual. Could you clarify that, please?
` MR. HART: Hey, Ryan, could you -- for my
`benefit and for Dr. Houh's, could you point us to
`
`15
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`where you were quoting, just to see if I need to
`object -- enter an objection or not?
` MR. THOMAS: Okay. Yes. That is page 16,
`paragraph 36 and page 17, paragraph 37.
` MR. HART: And that's from the Exhibit 1,
`the declaration from the '005 patent proceeding?
` MR. THOMAS: Yes, that's correct. And the
`specific language is from paragraph 37. It's about
`the 5th line in that.
` MR. HART: Got it.
` A. Okay. I see that. So I think there is --
`part of the confusion may arise out of the fact that
`the '815 patent also uses the term "subscriber," and
`the '684 patent uses the term "subscriber."
` So -- and they use them in -- I -- I
`suppose, different senses, and -- and that the '815
`patent uses the term "subscriber" as a -- as an
`individual user, and the discussion in '684 does talk
`about subscriber as an enterprise. And I -- I -- I
`think the confusion arises out of that, but I've tried
`to use the terminology of the -- of the '815 patent,
`but it -- it -- it leads to -- it leads to this issue
`you described.
` But the '684 patent does talk about
`enterprises and enterprise IP-PBX. I -- let me see if
`16
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`I can find a good citation for that. Yes. In the
`description of the background art, it does talk about,
`you know -- like, around 42, that -- or sorry.
`Starting at line 33.
` Q. (By Mr. Thomas) Okay.
` A. It -- it generally talks about IP-PBXs, but
`the system is the IP-PBX. I'm -- so -- I'm sorry.
`The question -- what was the specific question? I
`mean, I think I just answered it.
` Q. I -- I think you did. And -- and let me
`ask a hypothetical that might be clarifying. If we
`were to substitute "enterprise" for "subscriber" in
`'684, is it your opinion that that would be consistent
`with your reading of '684?
` MR. HART: Object to form.
` A. I mean, I would have to look through the
`'684 for every -- every mention of subscriber and --
`and see whether it makes sense or not. And, I mean, I
`think, you know, that's -- that's not part of what I
`talked about in this -- in this declaration.
` Q. (By Mr. Thomas) Is it your opinion that
`the term subscriber could include both individuals
`and an enterprise as described in '684?
` A. I mean, I think if -- if there was an
`individual and they had a server 110 and they had an
`
`17
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`IP phone, I suppose, in that case -- it could be the
`case. But, again, I haven't provided an opinion about
`that particular usage, I don't believe, in my
`declaration.
` Q. The reason for the question is, as you
`indicated a moment ago, the individuals provide -- are
`classified by a reference to the E.164 international
`standard dial plan, and what I was trying to clarify
`is:
` Would the E.164 number that is used in that
`reference -- and, again, specifically, that would be
`in paragraph 36, it -- it -- does that refer to an
`assignment to an enterprise of an E.16- -- an E- --
`excuse me -- 164 number, or is that to a user?
` MR. HART: Object to form.
` A. So let -- I'd like to direct you to the
`petition at page 18 -- the '005 petition. It's marked
`Exhibit 4 -- Houh Exhibit 4.
` And there's a discussion from the -- the
`'684 patent and the citation to column 3:56-64. And
`it says in that column that -- let me read that to
`you.
` "In one embodiment the present invention
`provides a virtual private network service where
`subscribers can use their own internal dial plan.
`
`18
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`This does not preclude each IP phone from being
`assigned its own E.164 number, the international
`standard dialing plan, and receiving calls from the
`PSTN directly."
` And -- and so what I'm referring to here is
`that the -- the phones themselves -- each -- each
`individual phone has an E- -- unique E.164
`assignment -- or that the system doesn't preclude it.
`So the embodiment that you can think of that I'm
`talking about is where the phones do all have the
`E.164 numbers.
` And if you look at Figure 1 in the '684 --
`Chu '684 patent, it's got a li- -- you know, IP phone
`101, IP phone 102, IP phone 103. And each of those
`would have a phone number -- an E.164 phone number
`uniquely assigned to it, as well as an -- as an IP
`address that's also unique. And that's what I'm
`discussing in paragraph -- I think it's in 36.
` Is that the right paragraph? Let me see.
` Q. (By Mr. Thomas) It is a paragraph that
`refers to E.164.
` A. Yes, yes. Yeah. I -- so that's towards
`the bottom of paragraph 36 on page 17. So it's --
`it's the phones that have the unique assignments. And
`what that goes to show is the Chu '684 has the
`
`19
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`appropriate infrastructure for uniquely mapping
`information to each individual phone, and so that the
`call origin profiles of the Chu '366 may be easily
`imported also as -- as -- and combined with the '684
`reference to use the -- the caller-specific call
`origin profiles and the information that it contains
`into the combined system of the Chu '684 and the
`Chu '366. And so it's that combined system that I'm
`talking about that renders the asserted claims
`obvious. And -- and so those -- those -- the E.164
`phone number is associated with an individual IP
`phone, not -- not the enterprise -- not -- not the
`entire enterprise. And I think that was what your
`question was.
` Q. Yes. And perhaps if we could follow then
`to paragraph 37 of Exhibit 4 at -- at page 17 --
` A. Exhibit 4 is the petition. Do you mean
`Exhibit 1, which is my declaration?
` Q. Yeah. Your declaration, page 17 and
`paragraph 37.
` Could you clarify how you -- let me quote
`from the last several sentences what -- dial plans --
`let's begin with, "Assigning subscribers specific dial
`plans, rather than dial plans applicable to all PBX
`subscribers to include subscriber-specific information
`20
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`such as geographical location, area code, et cetera."
` Again, I'm -- I'm not clear as I read that
`in the context of how you've described Chu as using
`"subscriber." Is the subscriber-specific dial plan
`referring to a dial plan associated with an enterprise
`or with an individual?
` A. Are you asking about the combination of the
`'366 and -- and '684, if it was --
` Q. Yes.
` A. -- what I'm addressing?
` Q. Yes. That's right. That's the -- you,
`again, indicate that there would be user -- that it
`would be a subscriber-specific dial plan. And what
`I'm trying to clarify is whether the
`subscriber-specific dial plan is a PBX or a -- an
`enterprise associated with at least a portion of PBX,
`or does it speak about an individual user?
` A. Well, now we're talking the combination of
`'366 and '6- -- '684, the patents. And recall that
`the Chu '366 patent has this thing called the or- --
`origin -- "call origin profile." And that is
`individual to each user -- or, in this case, maybe you
`could map that to a phone, but it's -- the idea,
`it's -- it's an individual's uni- -- own call origin
`profile, which may contain its -- that user's
`
`21
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`information such as the geographic location, preferred
`area code for dialing, and things like that.
` And now the combination works by -- because
`Chu '684 already has the infrastructure to support
`mapping of data to individual phones, and that data
`would be the E.164 phone number and the IP address.
`That -- the call origin profile could then become --
`in combination, it would be part of that unique --
`sorry -- not "unique," but user's -- the phone user's
`individualized information, which then -- now has
`information related to when that specific user makes a
`call.
` So, now, if you're going through the steps
`of the -- like, for example, the Figure 6 in '366,
`that is all individualized to a specific user tied to
`the specific user's call origin profile, and that
`helps create the -- the -- the proper output number
`that is then fed into the rest of the system of the
`Chu '684 to actually complete the call. And so one
`can think of that as a user-specific calling profile
`because now it has the -- the call origin profile of
`the Chu '366 in addition to the IP address and E.164
`number of the -- of the phone the user is calling
`from.
` Q. Thank you.
`
`22
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` Could you clarify, given what you've just
`said, the steps -- is -- is there an order process
`here? Does it necessarily follow a specific order as
`we look at the combination of the two Chus?
` A. I mean, can you say -- I mean -- what you
`mean by order with respect to what and what?
` Q. That -- that is simply the sequence at
`which reformatting or the identification of the E.164
`or other attributes. At what point is there some
`reference to a user-specific attribute? And at one --
`at what point then is it reformatted? And then,
`ultimately, at what point is it routed?
` A. I'm going to start with --
` Q. It's in para- -- yes. Please.
` A. Sorry. I -- I just want to refer to one
`thing, and then I'll -- then I'll start -- I'm just
`looking for one thing now.
` So I'm looking at the declaration first,
`which is Exhibit 4, and -- on page 19, and I do cite
`to the Chu '366 patent in this section. Or it does
`cite to the -- this is the -- the petition. It does
`cite to there. And it talks about -- a user is able
`to enter -- enter telephone numbers for calls -- for
`VoIP telephone calls as they would according to the
`traditional telephone numbering plan for landline
`
`23
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`telephone calls. So that step happens at the very
`beginning when the user of the -- of the combined
`'684/'366 system picks up the phone and enters their
`phone numbers, and -- and then it's received by the
`server.
` And -- and if you look at Figure 6, there's
`this thing that says, "Phone number received." And
`then -- and then "Receives origin designation and
`retrieve formatting data for origin." And that is --
`the "origin information" refers to the call origin
`profile that is individual to each user and caller,
`and so -- and then it -- and then it goes to the steps
`starting at 156, to "Parse the entered telephone
`number," and -- and now this is occurring, you know,
`for example, on the server, in the combined system,
`the server 110. And then this step all occurs.
` And so -- and then at Step 190, where it
`says "Place Call" in the lower right-hand corner of
`Figure 6 from Chu '366, the "Place Call," now you've
`got reformatted digits that comes out of the Chu '366,
`Figure 6, set of steps.
` And -- and as I stated in -- in
`paragraph 36 of my declaration, it talks about at --
`at -- this is citing from the Chu '684, column 8:65.
`Starting there.
`
`24
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` "At step 608, after receiving all the
`dialed digits from the phone 101, server 110 consults
`its dial plan to determine whether the call is local
`to another on-net phone or to a phone that is on the
`PSTN."
` And so it's very straightforward that the
`ordering of this is that the steps of Figure 6 is --
`is -- is -- is done when the -- when the digits are
`received at the server 110 or, you know, wherever this
`figure step can be implemented, and can be implemented
`in server 110.
` And then the "Place Call" is now replaced
`or it feeds into the step 608. And so I think the
`ordering of these steps is that a user dials a call,
`the steps -- the -- the digits are received, as in
`Figure 6. And at the end of Figure 6 in Chu '366 at
`step 190, that reformatted number is used to feed into
`step 608 of -- as described in Chu '684. So that's
`the -- that's the ordering and the combined -- the way
`the combined references work.
` Q. Thank you. As you've described that
`process, could you give your opinion relative to what
`problem is resolved -- or what's the improvement that
`occurs with the combination as you've described it?
` A. So I have addressed that in my petition --
`25
`
`ADVANCED DEPOSITIONS
`www.advanceddepositions.com | 855.811.3376
`
`
`
`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
