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
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`Voip-Pal Ex. 2043
`IPR2016-01201
`
`Voip-Pal Ex. 2010
`IPR2017-01399
`
`
`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
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`Voip-Pal Ex. 2043
`IPR2016-01201
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`Voip-Pal Ex. 2010
`IPR2017-01399
`
`
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`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.)
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`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.
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`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
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` 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 --
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` 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 --
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` 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
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`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.
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` 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
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`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
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`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
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`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
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`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
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`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 --
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`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
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`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
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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.
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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
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`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
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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.
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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` 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
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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`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.
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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` "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 --
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`Henry Houh, Ph.D., 1/25/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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