INTEL CORPORATION
`v.
`ALACRITECH, INC.
`
`Case Nos.: IPR2018-00234, IPR2018-01307,
`IPR2018-00403
`U.S. Patent No. 8,805,948 B2
`
`Patent Owner’s Demonstratives
`
`Hearing: March 4, 2019
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`-00234 PO Demonstrative, 11
`
`
`v.
`ALACRITECH, INC.
`
`Case Nos.: IPR2018-00234, IPR2018-01307,
`IPR2018-00403
`U.S. Patent No. 8,805,948 B2
`
`Patent Owner’s Demonstratives
`
`Hearing: March 4, 2019
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`-00234 PO Demonstrative, 11
`
`
`
`Overview of the ‘948 Patent
`
`POR at 7
`
`‘948 Patent, Abstract
`
`Ex. 1001 (“‘948 Patent”)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 2
`
`
`
`OSI Model
`
`POR at 1-2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 3
`
`Ex. 2026 at 19-20
`
`
`
`Layer 3: Network Layer
`
`POR at 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 4
`
`Ex. 2026 at 21
`
`
`
`IP Header
`
`POR at 3
`
`Ex. 2042 at 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 5
`
`
`
`Layer 4: Transport Layer
`
`POR at 3-4
`
`Ex. 2026 at 23
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 6
`
`
`
`TCP Header
`
`POR at 5
`
`Ex. 2042 at 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 7
`
`
`
`Message Processing Under TCP/IP
`
`POR at 6
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 8
`
`Ex. 2026 at 25; Ex. 2043 at 4
`
`
`
`Message Processing Under TCP/IP
`
`POR at 6
`
`Ex. 2026 at 25-26
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 9
`
`
`
`Overview of the ‘948 Patent
`
`POR at 7-8
`
`Ex. 1001, ‘948 Patent, 2:39-42
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 10
`
`Ex. 1008, Figure 1.4
`
`
`
`Overview of the ‘948 Patent
`
`POR at 7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 11
`
`Ex. 2026 at 30
`
`
`
`Overview of the ‘948 Patent
`
`POR at 9
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 12
`
`Ex. 2026 at 31
`
`
`
`Overview of the ‘948 Patent
`
`POR at 9-11
`
`Ex. 1001 at 3:57-62
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 13
`
`Ex. 2026 at 33
`
`
`
`Challenged Claims: 1, 3, 6-8, 17, 19, 21, 22
`
`POR at 11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 14
`
`
`
`Challenged Claims: 1, 3, 6-8, 17, 19, 21, 22
`
`POR at 11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 15
`
`
`
`Challenged Claims: 1, 3, 6-8, 17, 19, 21, 22
`
`POR at 11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 16
`
`
`
`Challenged Claims: 1, 3, 6-8, 17, 19, 21, 22
`
`POR at 11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 17
`
`
`
`Overview of the Prior Art
`
`Challenged Claims
`
`103(a) References
`
`1, 3, 6-8, 17, 19, 21-22
`
`Thia + Tanenbaum + Stevens
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 18
`
`
`
`Overview of Thia
`
`POR at 12-13
`
`Ex. 1015 (Thia) at 1
`
`Ex. 1015 (Thia) at .002
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 19
`
`Ex. 1015 (Thia) at .008
`
`
`
`Thia Is Inoperable and Not Enabled
`
`POR at 13
`
`Ex. 2026 at 41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 20
`
`
`
`Thia Is Inoperable and Not Enabled
`
`POR at 13-14
`
`Ex. 2026 at 38
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 21
`
`Ex. 1015 (Thia) at .003
`
`
`
`Thia Is Inoperable and Not Enabled
`
`POR at 16
`
`Ex. 1015 (Thia) at .003
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 22
`
`Ex. 2026 at 41
`
`
`
`Overview of Tanenbaum
`
`POR at 18-19
`
`EX 2026 at 46
`
`Tanenbaum (EX 1006)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 23
`
`
`
`Tanenbaum Teaches Away From Offloading TCP/IP
`Protocol Processing From The Host CPU
`
`POR at 20-21
`
`EX 1006 at 588-89
`
`Tanenbaum (EX 1006)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 24
`
`
`
`Overview of Stevens
`
`POR at 21-22
`
`EX 2026 at 49-50
`
`Stevens (EX 1013)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 25
`
`
`
`Overview of Stevens
`
`POR at 21-22
`
`EX 2026 at 51
`
`Stevens (EX 1013)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 26
`
`
`
`Both Independent Claims Require the Network Interface
`to Check for IP Fragmentation
`
`POR at 24
`
`‘948 Patent, Claim 1
`
`‘948 Patent, Claim 17
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 27
`
`
`
`IP Fragmentation is Checked at the IP Layer
`
`POR at 24-25
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 28
`
`Ex. 2042 at 2
`
`
`
`Petitioners Instead Point to a TCP Layer Check
`
`POR at 25-27
`
`Pet. at 75
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 29
`
`EX 2026 at 53
`
`
`
`TCP Checksums Are Not IP Fragmentation Checks
`
`POR at 25-27
`
`EX 2026 at 56
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 30
`
`
`
`TCP Checksums Are Not on the IP Layer
`
`POR at 29-30
`
`EX 2026 at 58-59
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 31
`
`
`
`No Motivation to Check for IP Fragmentation
`
`POR at 30
`
`. . .
`
`EX 2026 at 59
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 32
`
`
`
`Both Independent Claims Require Not Storing TCP
`Headers Between Payload Data
`
`POR at 39-40
`
`‘948 Patent, Claim 1
`
`‘948 Patent, Claim 17
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 33
`
`
`
`Thia Transfers the Entire PDU, Including the Headers
`
`POR at 40
`
`Ex. 1015 (Thia) at 9
`
`. . .
`
`Ex. 1015 (Thia) at 11
`(annotated at Ex. 2026 at 62)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 34
`
`Ex. 2026 at 62
`
`
`
`Petitioners Fail to Show that Only the Data is Transferred
`
`POR at 40-41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 35
`
`Ex. 2026 at 63
`
`
`
`Tanenbaum Does Not Cure Thia
`
`POR at 40-41
`
`Ex. 2026 at 64
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 36
`
`
`
`All Challenged Claims Require TCP/IP
`
`POR at 42-43
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 37
`
`
`
`No Dispute that Thia Does Not Disclose TCP/IP
`
`POR at 43
`
`Pet. at 56
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Pet. at 73
`-00234 PO Demonstrative, 38
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 44-45
`
` Tanenbaum teaches speeding up the host software
`
` Tanenbaum teaches away from offloading TCP protocol
`processing to, e.g., Thia’s ROPE chip
`
`EX 1006 (Tanenbaum) at 583
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 39
`
`EX 1006
`(Tanenbaum) at
`588-89
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 45-46
`
`EX 1006 (Tanenbaum) at 016
`
`EX 1006 (Tanenbaum) at 060-061
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 40
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 45-46
`
`“[T]he Board’s analysis encourages the fact-finder
`to outright discard evidence relevant both to
`‘teaching away’ and to whether skilled artisans
`would have been motivated to combine
`references. . . . . . But even if a reference is not
`found to teach away, its statements regarding
`preferences are relevant to a finding regarding
`whether a skilled artisan would be motivated
`to combine that reference with another
`reference.”
`
`Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1069 (Fed. Cir. 2018)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 41
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 46-47
`
` Thia is limited to standard OSI protocols
`
`OSI only
`
`EX 1015 (Thia) at 1
`
`* * *
`
`EX 1015 (Thia) at 6
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`-00234 PO Demonstrative, 42
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 46-47
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 43
`
`EX 2026 at 69
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 47
`
`EX 1015 (Thia) at 7
`
`EX 2026 at 69
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 44
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 47-48
`
`EX 1015 (Thia) at 014
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 45
`
`EX 2026 at 70
`
`
`
`No Motivation to Combine Thia and Tanenbaum
`
`POR at 48
`
` Thia was aware of TCP/IP, but never suggested extending its
`system to TCP protocol
`
`EX 1015 (Thia) at 2
`
`EX 1015 (Thia) at 13
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 46
`
`
`
`No Motivation to Combine Thia and Tanenbaum with
`Stevens
`
`POR at 49-50
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 47
`
`EX 2026 at 71
`
`
`
`Secondary Considerations: Long-Felt Need
`
`POR at 50-52
`
`Ex. 2031 at 1 (1993 IBM Research Division ACM SIGCOMM article)
`
`Ex. 2032 at 1 (1995 Univ. of Berkeley paper)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 48
`
`
`
`Secondary Considerations: Long-Felt Need
`
`POR at 50-52
`
`Ex. 2033 at 1 (1990 IEEE article from AT&T Bell Labs)
`
`Ex. 2034 at 1 (2005 USENIX Conference paper from IBM)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 49
`
`
`
`Secondary Considerations: Long-Felt Need
`
`POR at 50-52
`
`Ex. 2026 at 73
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 50
`
`
`
`Secondary Considerations: Industry Praise
`
`POR at 53-54
`
`Ex. 2039 at 4 (2001 HP Labs research paper)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 51
`
`
`
`Secondary Considerations: Industry Praise
`
`POR at 53-54
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 52
`
`Ex. 2040 at 3 (Shoreline Ventures Press Release)
`
`
`
`Secondary Considerations: Industry Praise
`
`POR at 53-54
`
`Ex. 2026 at 75
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 53
`
`
`
`Secondary Considerations: Failure of Others
`
`POR at 54-55
`
`Ex. 2041 at 2 (2003 HP Labs paper presented at HotOS IX conference)
`
`Id. at 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 54
`
`
`
`Secondary Considerations: Failure of Others
`
`POR at 54-55
`
`Ex. 2026 at 76
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 55
`
`
`
`Secondary Considerations: Skepticism
`
`POR at 55-57
`
`Ex. 1006 at 588-589
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 56
`
`
`
`Secondary Considerations: Skepticism
`
`POR at 55-57
`
`Ex. 2300 at 194 (2001 paper by Petitioner’s expert, Dr. Horst)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 57
`
`
`
`Secondary Considerations: Skepticism
`
`POR at 55-57
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 58
`
`Ex. 2300 at 194
`
`
`
`Secondary Considerations: Skepticism
`
`POR at 55-57
`
`Ex. 2026 at 78
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`-00234 PO Demonstrative, 59
`
`
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