Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________
`
` CISCO SYSTEMS, INC.,
` Petitioner,
` v.
` FATPIPE NETWORKS PRIVATE LIMITED,
` Patent Owner
` _________
` Case IPR2017-01845
` U.S. Patent No. 6,775,235
` Case IPR2017-01846
` U.S. Patent No. 7,406,048
`
`________________________________________________________
`
` ORAL AND VIDEOTAPED DEPOSITION OF
` DR. NARASIMHA REDDY
` APRIL 17, 2018
`________________________________________________________
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 1
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Case IPR2017-01845
`
`April 17, 2018
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________
`
` CISCO SYSTEMS, INC.,
` Petitioner,
` v.
` FATPIPE NETWORKS PRIVATE LIMITED,
` Patent Owner
` _________
` Case IPR2017-01845
` U.S. Patent No. 6,775,235
` Case IPR2017-01846
` U.S. Patent No. 7,406,048
`
`________________________________________________________
`
` ORAL AND VIDEOTAPED DEPOSITION OF
` DR. NARASIMHA REDDY
` APRIL 17, 2018
`________________________________________________________
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 1
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`2
`
` On the 17th day of April, 2018, the Oral and
`Videotaped Deposition of DR. NARASIMHA REDDY was taken
`pursuant to Notice by the Patent Owner, FatPipe Networks
`Private Limited, before Judith G. Werlinger, Texas CSR
`#731, FAPR RMR CRR CMRS, in reference to the
`above-entitled and -numbered cause between the hours of
`9:10 a.m. and 12:55 p.m., at the offices of Hub
`Collaborative, 404 Jane Street, Suite 100, College
`Station, Texas 77840.
` Said Deposition was reported by stenographic means
`and transcribed with computer-assisted translation.
`
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 2
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`3
`
` APPEARANCES
`ATTORNEYS FOR THE PETITIONER,
`CISCO SYSTEMS, INC.:
`
` HAYNES AND BOONE, LLP
` By: Mr. John Russell Emerson
` 2323 Victory Avenue, Suite 700
` Dallas, Texas 75219
` (214) 651-5328
` Fax (214) 200-0884
` russ.emerson@haynesboone.com
`and
` By: Mr. Raghav Bajaj
` 600 Congress Avenue, Suite 1300
` Austin, Texas 78701
` (512) 867-8520
` Fax (512) 867-9603
` raghav.bajaj@haynesboone.com
`
`ATTORNEYS FOR THE PATENT OWNER,
`FATPIPE NETWORKS PRIVATE LIMITED:
` OBLON, McCLELLAND, MAIER & NEUSTADT, LLP
` By: Mr. Sameer Glokhale
` 1940 Duke Street
` Alexandria, Virginia 22314
` (703) 413-3000
` Fax (703) 413-2220
` sgokhale@oblon.com
`
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 3
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`4
`
` INDEX
`ORAL VIDEOTAPED DEPOSITION OF:
`DR. NARASIMHA REDDY
`
`APRIL 17, 2018
`EXAMINATION BY MR. GOKHALE
` Direct............................ 5
`Deposition Concluded................... 74
`Certificate of Reporter................ 75
`
`
` EXHIBITS
`
`Exhibit 1001 Patent No. 6,775,235 B2 6
`Exhibit 1006 Patent No. 6,243,754 B1 11
`Exhibit 1008 Article "Inside Cisco IOS 40
` Software Architecture"
` (Bollapragada Reference)
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 4
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`5
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` DR. NARASIMHA REDDY
`being first duly sworn, testified on his oath as
`follows:
` DIRECT EXAMINATION
`BY MR. GOKHALE:
` Q. Good morning, Dr. Reddy. My name is Sameer
`Gokhale.
` I am here to take your deposition.
` THE REPORTER: Would you speak up,
`please.
` MR. GOKHALE: Yes.
` Q. (By Mr. Gokhale) Hello. Can you hear my now?
` A. Yes.
` Q. I am here taking the deposition regarding
`patent matters, specifically two petitions for Inter
`Partes Review.
` I am going to show you a few documents
`now and ask you to verify what these documents are.
` (Pause).
` Q. (By Mr. Gokhale) I am going to hand you a
`pair of documents right now, and there is another copy
`in the room. If you could please look over those
`documents, and if you could please identify what each
`document is.
` A. The first document says Declaration of
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 5
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`6
`Narasimha Reddy, In Support of Petition for Inter Partes
`Review of U.S. Patent No. 6,775,235.
` And the second one says Petition U. S.
`Patent No. 6,775,235.
` Q. Okay. In the Declaration, sorry.
` A. This is -- did you give me both of these, both
`for 6,775,235?
` Q. Yes. Is one a Petition and one a Declaration?
` A. That's the Petition.
` Q. Yes.
` And in the Declaration documents that
`you've just described, is that your Declaration that you
`have authorized?
` A. It seems to be.
` Q. Could you please turn to Page 103?
` A. Yes.
` Q. Is that your signature?
` A. Yes.
` Q. And is your Declaration in support of the
`Petition that I also gave you?
` A. Yes, appears to be.
` Q. Okay. You understand that's the Petition for
`Intra Partes Review of U.S. Patent No. 6,775,235, filed
`by Cisco Systems?
` A. It appears to be.
`
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 6
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`7
`
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` Q. Thank you.
` I hand you what is another pair of
`documents. Can you identify the two documents that I
`just handed you?
` A. The first one is a Petition for Inter Partes
`Review of U.S. Patent No. 7,406,048, and the second
`document is Declaration of Narasimha Reddy, Support of
`Petition for Inter Partes Review for U.S. Patent No.
`7,406,048.
` Q. Would you please turn to Page 66 in the
`Declaration document.
` A. Which one?
` Q. In the Declaration document for the '048
`Patent.
` A. Again, the page number?
` Q. 66.
` A. Yes.
` Q. Would you please verify that your signature is
`on that page?
` A. Yes.
` Q. And is it your understanding that the
`Declaration document that you just verified is for a
`Petition for Inter Partes Review of U.S. Patent
`7,406,048, filed by Cisco Systems?
` A. Yes.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 7
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`8
`
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` Q. Thank you.
` Now, I am here today to ask you -- I
`have some questions relating to your opinion that
`appeared in the two Declaration documents that I just
`handed to you.
` To make things easier, if you want to
`refer to your Declaration for the '235 Patent, that's
`what I will mainly be talking about for right now. So
`if you want to put aside the '048 documents, I will try
`to make that a little bit easier on you.
` Would you please explain your background
`in networking technology?
` A. Okay. I've been working in networking since
`about '95, actually even before.
` I've been working in networking since at
`least '95. I have been teaching courses here in
`networking, multimedia networks, and network security.
` Q. By "here," you mean the University of Texas
`A&M?
` A. Texas A&M University.
` Q. All right.
` And are you familiar with programming of
`Cisco routers, or routers in general?
` A. Yes.
` Q. Okay. And do you have certifications related
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 8
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
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`to programming Cisco routers or detector routers?
` A. No. No.
` Q. Are you familiar with how to configure a
`virtual private network on a router?
` A. Yes.
` Q. Are you familiar with configuring a frame or
`relay network on a frame relay network?
` A. No, not...
` Q. In your professional experience, have you ever
`been involved in the configuration of a frame relay
`network?
` A. No, not the actual operations.
` Q. In your professional experience or your
`academic experience, have you ever designed your own web
`page?
` A. Yes, I have.
` Q. So are you familiar with the HTTP protocol?
` A. Yes, I am.
` Q. Is this the first time you have given an
`expert Declaration or testimony related to a patent
`matter?
` A. No.
` Q. About how many times previously have you --
`have you provided expert witness or declaration support
`for a patent matter?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 9
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`10
` A. I can't recall the exact numbers. Probably be
`seven to ten times.
` Q. Are you familiar with the difference between
`anticipation and obviousness?
` A. As far as I can tell, yes, I do understand the
`difference.
` Q. Can you please turn in the Declaration
`document related to the '235 Patent -- and I'll use '235
`as short-term for U.S. Patent 6,775,235 from now on.
` If you would turn to Page 27 of that
`document, please.
` Does this page refer to the Preamble of
`Claim 5 of the '235 Patent?
` A. Pardon me?
` Q. Sorry. Does this -- does this page include an
`analysis of the first sentence or the first paragraph,
`sometimes called the Preamble, of Claim 5 of the '235
`Patent?
` A. Yes, if you don't mind, can I have access to
`the patent?
` Q. Oh, sorry.
` (Document handed to witness.)
` Q. (By Mr. Gokhale) Sir, is this page referring
`to the first sentence of Claim 5 of the '235 Patent?
` A. Yes.
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`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 10
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`11
` Q. There is a term that appears in this sentence,
`in bold face, after the 5.0 header, it says "Disparate
`Parallel Networks."
` I'm going to hand you another document
`now.
` I just handed you a copy of the U.S.
`Patent No. 6,243,754 to Guerin, Et Al. Do you recognize
`this document?
` A. Yes, I do.
` Q. Now, is it your opinion that Guerin does or
`does not teach a network having disparate parallel
`networks?
` A. I don't understand the question.
` Q. So the Claim presentation 5.0 mentions the
`term "Disparate Parallel Networks."
` In your Declaration, did you provide an
`opinion on the term "Disparate Parallel Networks"?
` A. I don't think I have.
` Q. From what you recall of the Guerin reference,
`does the Guerin reference teach the network having
`disparate parallel networks?
` A. Guerin talks about multiple networks providing
`alternate paths and it also talks about employing
`networks of different characteristics.
` So, based on my understanding of what
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 11
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`12
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`disparate parallel networks means, I think it does.
` Q. Would you please turn to Page 24 of the
`Declaration, please.
` On Page 24 there is a description of a
`ground of rejection that includes, it's called Ground 1
`at the top of Page 24. It covers Claims 5 through 6, 8,
`10, 14, and 22, and it indicates these claims are
`obvious under 35 U.S.C. Section 103 over Guerin and the
`Admitted Prior Art.
` Is it your opinion that Claim 5 is
`rendered obvious by combination of Guerin and the
`Admitted Prior Art?
` A. Yes.
` Q. Okay. Have you considered whether Claim 5 is
`anticipated by Guerin?
` A. Can you repeat the question?
` Q. Have you considered whether Claim 5 of the
`'235 Patent is anticipated by the Guerin reference? Do
`you believe that Guerin teaches all of the features of
`Claim 5?
` A. I will have to take some time to look through.
` MR. EMERSON: I object to the form.
` A. Guerin teaches most of the art -- similar art,
`and I relied on the Admitted Prior Art.
` Q. (By Mr. Gokhale) So -- so is it fair to say
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 12
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`13
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`that your opinion only includes an analysis of
`obviousness of Claim 5 with respect to the Guerin
`reference --
` A. Yes --
` Q. -- not -- not to the picture?
` A. That's what I rely on for, for obviousness.
` Q. Can you turn to -- can you please turn to Page
`28 and 29 of the Declaration?
` Starting on Paragraph 67, it discusses
`the Admitted Prior Art, which refers to disclosures that
`appear in the '235 Patent itself; is that correct?
` A. That's correct.
` Q. What feature of Claim 5 are you relying on the
`Admitted Prior Art to disclose?
` A. Can you repeat that question?
` Q. Which specific elements of Claim 5 of the '235
`Patent are you relying on the Admitted Prior Art to
`disclose or to render obvious in combination with
`Guerin?
` A. Okay. That's a really long question. Can you
`repeat that question?
` Q. How are you relying on the Admitted Prior Art
`in your analysis of Claim 5?
` A. Again, it states clearly here on 67, for
`example, and 68.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 13
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`14
` Q. Okay, sir. The specific elements that you're
`saying the Admitted Prior Art explicitly features is
`disparate parallel networks; is that correct?
` A. Yes, that's what -- that's what it says.
` Q. My question is: Did you feel there was
`something missing from Guerin's disclosure regarding
`disparate parallel networks that caused you to seek the
`teaching of the Admitted Prior Art for that particular
`feature?
` A. I'm not sure what you're asking.
` Q. I previously asked you if you believed that
`Guerin teaches disparate parallel networks, and you said
`you believe it does.
` A. Uh-huh.
` Q. In the opinion in your Declaration in
`Paragraph 67, you're looking to the Admitted Prior Art
`to teach that specific feature.
` Was there something in Guerin that you
`believe was deficient that caused you to rely on the
`secondary reference?
` A. This is to further bolster the argument that a
`combination of this clearly teaches the preferred
`patent.
` Q. But you do not have any analysis in your
`Declaration that relies solely on Guerin to teach the
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 14
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
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`features of Claim 5?
` A. I think here my Declaration states I relied on
`Guerin and Admitted Prior Art together, for Claim 5.
` Q. Could you please turn to Page 33 of the
`Declaration, please.
` On Page 33, it refers to an Element 5.1
`from Claim 5 of the '235 Patent, and it recites
`obtaining at least two known location address ranges
`which have associated networks.
` There is a description in Paragraph 78
`from Guerin related to this feature. And if you would
`read this to yourself. But would you please review the
`analysis in that paragraph, please.
` A. (Witness reading).
` Yes.
` Q. Thank you.
` And this description refers to a pass --
`to the passages in Guerin, and this is referenced as
`Column 4 at Lines 35 to 46.
` It specifically describes assigning block
`of addresses for two -- what appears to be two separate
`networks. One starts with prefix 5, the other one
`starts with prefix 6.
` Could you explain what Guerin is doing in
`this particular description?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 15
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
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` A. Okay.
` MR. EMERSON: Object to form.
` A. Okay. You had a specific question?
` Q. (By Mr. Gokhale) So in Guerin, is it correct
`that it's describing two separate IP-based networks
`being used in parallel?
` A. This is discussing two networks that are using
`IP addresses.
` Q. Okay. Is there IP routing being performed on
`these two networks?
` A. That's -- that's what the description seems to
`show.
` Q. Is that your interpretation of that
`description?
` A. That's correct.
` Q. Why does Guerin assign two separate blocks of
`addresses in this description, depending on which --
`which service providers he used?
` MR. EMERSON: Object to the form.
` A. Can you repeat that question again?
` Q. (By Mr. Gokhale) Guerin describes assigning
`one block of addresses, that starts with prefix 5, as
`one of the service providers that he used, and using a
`different block of addresses with prefix six, is a
`different service provider he used.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 16
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`17
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` Can you explain why Guerin is doing
`that?
` MR. EMERSON: Object to the form.
` A. So some of this may be -- depends on how -- on
`where you're getting the addresses from. If you are
`getting addresses from the network provider, the network
`provider can supply a block of addresses.
` So if you go to network one, you get one
`set of block of addresses; if you go to network two, you
`get a second set of block of addresses.
` Q. (By Mr. Gokhale) What is the need to assign a
`new address, that difference -- what is the need to get
`a new source address and destination address in the
`networks as opposed to the original source address, the
`destination address that may have been at the end
`terminals?
` A. I think some of that is described here in the
`patent somewhere, in the background.
` For example, Column 1, 55 to 63.
` Q. Can you repeat the line numbers in Column 1,
`please?
` A. Okay.
` Q. On mine, 51 of Column 1 in the Guerin
`reference, it says that, "If the destination address
`belongs to the address space of ISP-B, then it is quite
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 17
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`18
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`likely that the packet will cross over from provider
`ISP-A to ISP-B prematurely, thereby rendering the delay
`guarantee of ISP-A null and void."
` Could you at least describe what Guerin
`means by something will "cross over"?
` A. Okay. The routing in a pathway network can
`take various forms and various metrics. Each provider
`can have its own way of routing packets.
` So generally, the tendency for a network
`provider is to do something called "hot-potato routing."
`And the intent is to get the packets across the network
`as soon as possible to the other providers.
` So, in this example, what Guerin is
`talking about is if you have a packet that belongs to
`ISP-B, that packet may be sent from ISP-A to ISP-B at
`some point in time; it may not be all of the destination
`packet headed to ISP-A.
` This is what this is talking about here.
` Q. Thank you, sir.
` So the packet may intend to go over one
`network, but because of the routing, they cross over to
`the other network by accident, is that correct, or by
`design?
` MR. EMERSON: Object to form.
` A. Can you repeat the question?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 18
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`19
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` Q. (By Mr. Gokhale) So it says it may
`prematurely cross over between these two service
`providers.
` Why -- why would it cross over?
` A. I just explained why that might happen.
` Q. Okay. I'm -- I'll -- I'll skip to the next
`question then.
` By changing the addresses to the blocks
`of addresses that it describes in a previous passage,
`how does that fix that problem?
` A. Okay. If the --
` MR. EMERSON: Object to the question.
` A. If the network address belongs to the
`provider, the provider tends to carry the packet within
`its network. The routing is determined by that network.
`So...
` Q. (By Mr. Gokhale) Would you please turn back
`to Pages 28 and 29 in the Declaration, please.
` On Paragraph 67 through 69, you describe
`a frame relay network from the Admitted Prior Art from
`the '235 Patent. Is frame relay -- how is a frame relay
`network different than an IP-based routing network?
` A. I don't understand that question. We can run
`IP addresses on top of frame relay networks.
` Q. I'm sorry, could you repeat your answer?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 19
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`20
` A. You can use IP addresses on top of frame relay
`networks.
` Q. Is it -- so you're saying, does frame relay
`rely on the IP addresses to transport packets through a
`frame relay network?
` A. It could.
` Q. How so?
` A. It could use different addresses. It could
`use IP addresses.
` Q. So your opinion is that a frame relay network
`will use IP addresses to transport data over a frame
`relay network at the time of the final issue of the '235
`Patent?
` MR. EMERSON: Object to the form.
` A. All -- all I said was we could use IP
`addresses on top of frame relay networks.
` Q. (By Mr. Gokhale) Does frame relay encapsulate
`the IP address?
` MR. EMERSON: Object to the form.
` A. Frame relay works where IP addresses could
`layer on top of frame relay.
` Q. (By Mr. Gokhale) So when you're using a frame
`relay network, what is the unit of data that is received
`at the network element in a frame relay network?
` And to clarify my question, you refer to
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 20
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`21
`packets usually in IP-based networks. What is the data
`unit that's used in the frame relay network?
` A. Well, it is normally called a frame or a
`protocol data unit.
` Q. What -- with respect to the -- the OSI
`reference model, what layers do you say these frames are
`defined in?
` A. I would say that would be layer two.
` Q. Layer two.
` When a frame is received at a frame relay
`switch, does the frame relay switch need to inspect the
`IP address that may be layered on top of layer two?
` A. Need not; depends on how the switch is
`configured.
` Q. Now, in your combination of Guerin and the
`Admitted Prior Art -- and I am going to refer to
`Paragraph 74 of your Declaration on Page 32, Paragraph
`74 refers, "To the extent any modification would have
`been needed to the teachings of Guerin in order to
`accommodate the teachings of the Admitted Prior Art..."
` The later sentence says, "For example, to
`the extent any software or hardware modification to
`Guerin's system were necessary, parentheses, for
`example, use of a frame relay network interface instead
`of another type of network interface), such a
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 21
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`22
`modification would have been well within the level of a
`POSITA" -- a person of ordinary skill in the art -- "at
`the time of the '235 Patent."
` What choice of software or hardware
`modification would be necessary to Guerin to put that
`frame relay network into Guerin?
` A. So clearly it says specifically here, just
`talking about the frame network interfaces, so you would
`need a specific hardware to talk to the frame relay. It
`would need to talk to another network in the interface.
`And it's well within the skill for people to know how to
`develop hardware for talking to specific network
`interfaces.
` Q. Are you aware of the specific modifications
`that would be necessary in this paragraph?
` MR. EMERSON: Object to form.
` A. So you would use the different network
`interfaces to talk to the different networks.
` Q. (By Mr. Gokhale) Now, when you make that
`modification, what happens to the use of IP addresses in
`the Guerin network for the frame relay network that is
`now replacing one of the server provider networks?
` A. I'm not sure I understand the question.
` Q. Let me -- let me...
` Would you please turn to Page 74 of the
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 22
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`23
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`Declaration.
` There is a figure, an annotated figure of
`Figure 1 of Guerin shown on Page 74. And it shows that
`one of the networks in Guerin, No. 107, is a frame relay
`network; is that correct?
` A. Yes.
` Q. Okay. So is it your suggested combination of
`Guerin and the Admitted Prior Art that a frame relay
`network will replace one of the service provider
`networks originally taught by Guerin?
` A. I think that some of Guerin's teachings of
`networks, that could be.
` Q. The specific suggested modification is that
`fix?
` A. The figure is showing that one of the provider
`networks could be, depending on frame relay one, could
`be using VPNs.
` Q. At least one of them is a frame relay,
`providing a frame relay network?
` A. That's correct.
` Q. Okay. Now, we previously talked about Guerin
`having a block of addresses, IP addresses for each of
`these two original service provider networks.
` What happens to that block of addresses
`if you change one of them to a frame relay network?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 23
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`24
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` A. There's no need to make any changes. It is
`depending on how the code is configured.
` Q. So previously we discussed that these
`addresses, these blocks of IP addresses, one of them
`265, the other one 266, are specifically assigned to the
`site, depending on which service provider is being used;
`is that correct?
` A. I think we talked about having both sets of
`addresses, that's correct.
` Q. Would you need to make that change when you
`use the frame relay network instead of the service pro
`-- the IP-based routing network that Guerin originally
`provided?
` A. I'm not sure I understand the question.
` Q. So there was previously a problem we discussed
`describing Guerin, the problem of crossover between
`these two networks that could occur?
` A. Uh-huh.
` Q. And so one of the -- one of the features of
`Guerin is assigning specific blocks of addresses that
`are separate between the two service provider networks.
` Have you considered if that will still be
`necessary if you change one of those to a frame relay
`network instead of the original IP routing-based network
`that Guerin originally taught?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 24
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`25
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` MR. EMERSON: Object to form.
` A. I'm not sure I understand the question, but
`could you repeat or -- I got lost in the long question
`there.
` Q. (By Mr. Gokhale) I will take my time.
` So in Column 4 of Guerin, starting at
`Line 35 -- I should say, really, from Line 6 all the way
`to Line 64, this is -- this is -- I will read part of
`the portion that was referenced in the Declaration that
`describes the process in which there are two separate
`blocks of addresses.
` One has prefix 5, the other one has
`prefix 6. And these are not the original IP addresses
`used by Site A, Site B. These are the ones that are
`assigned by the service provider networks.
` Now, they have this problem of crossover,
`and they talk between the prior art and Guerin, where
`the packet may prematurely cross over to one of the
`networks. And I think you explained that.
` Does the address in Guerin described in
`this column force IP routing through a particular
`network?
` A. No. No, it's not necessary.
` Q. Okay.
` From the description -- I will go to one
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`FatPipe Exhibit 2021, pg. 25
`Cisco v. FatPipe
`IPR2017-01845
`
`
`
`Reddy, Dr. Narasimha
`
`Case IPR2017-01845
`
`April 17, 2018
`
`26
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`of the figures.
` Look at Figure 3 of Guerin.
` On the second provider network 307, it's
`using IP addresses in the -- what appears to be the
`6.0.0.X range; is that correct?
` A. That's correct.
`
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