Case IPR2019-00820
`Patent 7,937,581
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`MPH TECHNOLOGIES OY,
`Patent Owner.
`____________
`
`Case IPR2019-00820
`Patent 7,937,581
`____________
`
`EXHIBIT 2009
`
`DECLARATION OF PROFESSOR GEORGE N. ROUSKAS, PH.D.
`
`MPH Technologies Oy, Exhibit 2009
`Page 2009 - 1
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`
`I.
`
`II.
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`TABLE OF CONTENTS
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`Page
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`INTRODUCTION ........................................................................................ 1
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`QUALIFICATIONS ..................................................................................... 1
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`III. BASES OF OPINIONS ................................................................................ 6
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`IV. APPLICABLE LEGAL STANDARDS ...................................................... 8
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`A. Ordinary Skill in the Art ........................................................................ 8
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`B. Claim Construction.............................................................................. 10
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`C. Obviousness (35 U.S.C. § 103) ........................................................... 10
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`V.
`
`OVERVIEW OF THE ’581 PATENT AND THE STATE OF THE
`ART AT THE TIME OF THE INVENTION ..........................................14
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`A. Technical Background ......................................................................... 15
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`B. The Mobility Problem Addressed by the ’581 Patent ......................... 21
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`C. The ’581 Patent’s Solution to the Mobility Problem .......................... 23
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`VI. CLAIM CONSTRUCTION .......................................................................28
`
`VII. CLAIMS 1 AND 9 ARE PATENTABLE OVER THE
`COMBINATION OF ISHIYAMA AND MURAKAWA (GROUND 1)
` 42
`
`A. Overview of Ishiyama ....................................................................... 42
`
`B. The Petition Fails to Establish that the Prior Art Teaches the
`“Security Gateway” in “At Least One Mobile Terminal and
`Another Terminal and a Security Gateway Therebetween”
`and Other Limitations ...................................................................... 49
`
`1. Multiple Publications from the Relevant Timeframe
`Confirm that a Correspondent Host is Not a Security
`Gateway .................................................................................... 52
`
`i
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`2.
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`3.
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`4.
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`5.
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`Ishiyama’s Correspondent Host is Demonstrably Not a
`Security Gateway Because it is an End System with a
`Single Communication Interface ........................................... 54
`
`Ishiyama’s Description of the IPSec Processing Using the
`Security Databases Proves that the Correspondent Host is
`not a Security Gateway ............................................................. 55
`
`Petitioner’s Theory that the Correspondent Host Must
`be a Security Gateway Because IPSec Tunnel Mode is
`Used is Incorrect...................................................................... 57
`
`Petitioner’s Argument in this Proceeding that the
`Correspondent Host is a Security Gateway is
`Contradicted by the Position Taken in IPR2019-00821 ...... 66
`
`C. The Petition Fails to Establish that the Prior Art Discloses the
`“Other Terminal” in “At Least One Mobile Terminal and
`Another Terminal and a Security Gateway Therebetween”
`and Other Limitations ...................................................................... 69
`
`D. The Petition Fails to Establish that the Prior Art Teaches
`“While at the Second Address, the Mobile Terminal Sending a
`Request Message to the Gateway Address of the Security
`Gateway to Request the Security Gateway to Change the
`Secure Connection to Be Defined Between the Second Address
`and the Gateway Address of the Security Gateway” ..................... 77
`
`E. The Petition Fails to Establish that the Prior Art Teaches the
`“Mobile Terminal Sending a Secure Message . . . From the
`Second Address of the Mobile Terminal to the Other Terminal
`via the Security Gateway” ................................................................ 78
`
`F. Claim 9 Is Not Unpatentable Over the Combination of
`Ishiyama and Murakawa .................................................................. 83
`
`VIII. CLAIM 4 IS PATENTABLE OVER THE COMBINATION OF
`ISHIYAMA AND MURAKAWA (GROUND 1) BECAUSE THE
`PETITION FAILS TO ESTABLISH THAT THE PRIOR ART
`TEACHES THE “REQUEST MESSAGE AND/OR A REPLY
`MESSAGE IS ENCRYPTED AND/OR AUTHENTICATED” ............88
`
`ii
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`IX. CLAIMS 3 AND 5 ARE PATENTABLE OVER THE
`COMBINATION OF ISHIYAMA, MURAKAWA AND AHONEN
`(GROUND 2) ...............................................................................................91
`
`A. Overview of Ahonen .......................................................................... 92
`
`B. The Combination of Ishiyama, Murakawa and Ahonen Fails
`to Teach Sending a “Reply Back to the Mobile Terminal . . .
`From the Security Gateway” (Claim 3) or a “Reply Message
`to the Mobile Terminal at the Second Address to Confirm the
`Address Change” (Claim 5) .............................................................. 95
`
`C. The Prior Art Fails to Render Obvious Claims 6-7 ....................... 98
`
`X.
`
`CLAIM 8 IS PATENTABLE OVER THE COMBINATION OF
`ISHIYAMA, MURAKAWA AND FORSLOW (GROUND 3) ..............99
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`XI. CONCLUSION .........................................................................................100
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`
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`iii
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`I.
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`INTRODUCTION
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`1.
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`My name is George Rouskas. I have been retained as an expert
`
`witness to provide my independent opinion in regards with matters at issue in the
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`inter partes review of U.S. 7,937,581 (“the ’581 Patent”) in the IPR2019-00820
`
`proceeding. I have been retained by MPH Technologies Oy (“MPH”), the Patent
`
`Owner, in the above proceedings. Petitioner in this case is Apple Inc. (“Apple”).
`
`2.
`
`Unless otherwise noted, the statements made herein are based on my
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`personal knowledge, and if called to testify about this declaration, I could and
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`would do so competently and truthfully.
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`3.
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`A detailed record of my professional qualifications including cases in
`
`which I was an expert is being submitted herewith as Exhibit 2004 and is
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`summarized in Section II, infra.
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`4.
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`I am not a legal expert and offer no opinions on the law. However, I
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`have been informed by counsel of the various legal standards that apply, and I have
`
`applied those standards in arriving at my conclusions.
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`II.
`
`QUALIFICATIONS
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`5.
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`I am an Alumni Distinguished Graduate Professor with Tenure in the
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`Department of Computer Science at North Carolina State University (NC State),
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`where I also serve as the Director of Graduate Programs. I am an experienced
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`researcher and educator in the field of computer networking, with expertise in
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`1
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`Internet architectures and protocols, virtualization and cloud computing, mobile
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`devices, network devices, network security and security protocols, in a variety of
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`applications including providing for the protection of information transmitted
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`between devices within and among networks.
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`6.
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`I have thirty years of experience in computer networking since I
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`received my bachelor’s degree in 1989. I have twenty-five years of experience as a
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`professor in the Department of Computer Science of NC State.
`
`7.
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`During this time, I have led, overseen, and contributed to numerous
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`research projects involving technical concepts that are related to the technology at
`
`issue in the IPR2019-00820 proceeding, which relates to the issue of providing
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`mobility to secure connections over networks, such as where a first computer
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`device in secure communication with a second computer device changes its
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`location from a first address to a second address. For example, as part of our NSF-
`
`funded ChoiceNet project, my research group developed a new Internet
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`architecture, a suite of communication protocols, and a proof-of-concept prototype
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`implementation to enable real-time economic transactions in the network layer,
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`including secure payments. For an earlier NSA-funded Jumpstart project, my
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`group developed a novel signaling architecture and protocol for high-speed
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`networks and designed relevant security mechanisms.
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`2
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`8.
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`I have taught courses on computer networks, Internet protocols, data
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`structures and computer performance evaluation. In 1997 I created one of the first
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`graduate level courses on Internet Protocols, which I teach regularly, and in which
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`I cover in detail topics related to network security (including IPSec) and mobile IP.
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`9.
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`I received numerous accolades for my contributions to computer
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`networking and was elected as Fellow of the IEEE in 2012. These include the
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`Outstanding Service Award for the Optical Networking Technical Committee
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`(ONTC) of the IEEE Communication Society (2019); the Joyce Hatch Service
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`Award from the NC State Chapter of the Association for Computing
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`Machinery/Association of Information Technology Professionals (ACM/AITP)
`
`(2018); Distinguished Lecturer in the IEEE (2010-2012); an IBM Faculty Award
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`(2007); the Best Paper Award for the International Workshop on End-to-End
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`Virtualization and Grid Management (EVGM) (2007) (with C. Castillo and K.
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`Harfoush); the Best Paper Award for the International Symposium on
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`Communication Systems, Networks and Digital Signal Processing (CSNDSP)
`
`(2006) (with B. Chen and R. Dutta); the ALCOA Foundation Engineering
`
`Research Achievement Award, NC State College of Engineering (2004); Alumni
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`Outstanding Research Award, NC State (2003); a CAREER Award from the
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`National Science Foundation (1997); and the Graduate Research Award from the
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`Georgia Tech College of Computing (1994).
`
`3
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`10.
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`I received my PhD in Computer Science (Georgia Institute of
`
`Technology, 1994); M.S. in Computer Science (Georgia Institute of Technology,
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`1991); and B.S. in Computer Engineering (National Technical University of
`
`Athens, 1989).
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`11.
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`In 2000-2001, while on Sabbatical from NC State, I worked as
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`Network Architect for Vitesse Semiconductor, where I was responsible for the
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`design of a state-of-the-art 2.5 Gbps network processor.
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`12. My work as an academic began in 1994, when I joined NC State as an
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`Assistant Professor. In 1999, I was promoted to Associate Professor with Tenure at
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`NC State. In 2002, I was promoted to the position of Professor at NC State.
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`13.
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`I have had visiting positions at a number of international universities,
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`including positions as a Distinguished Scientist at King Abdulaziz University
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`(Saudi Arabia, March 2013 to present); Visiting Professor at the Laboratoire
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`d’Informatique University of Paris 6 (France, October 2012); Visiting Professor at
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`the Universidad Tenia Federico Santa Maria (Chile, December 2008); and Visiting
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`Professor at the Laboratoire de Methods’ Informatiques University of DeVry
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`(France, July 2006, December 2002, June 2000).
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`14.
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`I have received funding from numerous agencies, foundations and
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`companies for research on network design and communication. The sources of
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`funding for this research include the National Science Foundation (NSF), the
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`4
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`Defense Advanced Research Projects Agency (DARPA), the National Security
`
`Agency (NSA), Microsoft, IBM and Cisco.
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`15.
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`I have served in a number of leadership roles for the IEEE, including
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`as Chair of the IEEE Communications Society’s Distinguished Lecturer Selection
`
`Committee (2016-2017); Vice Chair of the IEEE Communications Society’s
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`Technical and Educational Activities Council (2016-2017); and Chair of the IEEE
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`Communications Society’s Optical Networking Technical Committee (2016-2017).
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`16.
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`I have served in various editorial positions, including as founding
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`Editor-in-Chief of IEEE Networking Letters (2018-present); founding Editor-in-
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`Chief of Elsevier Optical Switching and Networking Journal (2004-2017);
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`Associate Editor, IEEE/OSA Journal of Communications and Networking (2010-
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`2012); Co-Guest Editor, JCM Journal of Communications, Special Issue on the
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`“Advances in Communications and Networking,” vol. 6, no. 9, December 2011;
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`Associate Editor, IEEE/ACM Transactions on Networking (2000-2004); Associate
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`Editor, Computer Networks (2001-2004); Associate Editor, Optical Networks
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`(2000-2004); and Co-Guest Editor, IEEE Journal on Selected Areas in
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`Communications, Special Issue on “Protocols for Next Generation Optical WDM
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`Networks,” vol. 18, no. 10, October 2000.
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`17.
`
`I have graduated twenty-five Ph.D. students. Two received PhD
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`dissertation awards, one received an NSF Career award, and one became an NSA
`
`5
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`Fellow. Three of my former Ph.D. students became Assistant Professors upon
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`graduation, and the rest joined significant technology companies or research
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`institutes, including RENCI (UNC-Chapel Hill), IBM Research, Google,
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`Facebook, Cisco, Oracle, Ericsson, Riverbed Technologies, Sprint, and Sierra
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`Wireless, among others. I have graduated twelve M.S. students.
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`18. During the course of my career, I had more than 200 scientific
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`articles, three books and ten book chapters published, which have collectively
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`received more than 8500 citations (Google Scholar, as of November 21, 2019).
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`These are summarized in my curriculum vitae.
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`III.
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`BASES OF OPINIONS
`
`19.
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`In the course of conducting my analysis and forming my opinions, I
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`have reviewed at least the materials listed below as well as all of the exhibits
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`submitted by Patent Owner in IPR2019-00820 and IPR2019-00821:
`
`i.
`
`ii.
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`U.S. Patent No. 7,937,581 and its prosecution history;
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`Petition by Apple in IPR2019-00819;
`
`iii.
`
`Petition by Apple in IPR2019-00820;
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`iv.
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`Petition by Apple in IPR2019-00821;
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`v.
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`Declaration of Dr. David Goldschlag in IPR2019-00819;
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`vi. Declaration of Dr. David Goldschlag in IPR2019-00820;
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`vii. Declaration of Dr. David Goldschlag in IPR2019-00821;
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`6
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`viii. Patent Owner’s Preliminary Response in IPR2019-00819;
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`ix.
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`Patent Owner’s Preliminary Response in IPR2019-00820;
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`x.
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`Patent Owner’s Preliminary Response in IPR2019-00821;
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`xi.
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`Institution Decision by the PTAB in IPR2019-00819;
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`xii.
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`Institution Decision by the PTAB in IPR2019-00820;
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`xiii.
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`Institution Decision by the PTAB in IPR2019-00821
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`xiv. U.S. Pat. No. 7,620,810;
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`xv. U.S. Pat. No. 8,037,302;
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`xvi. U.S. Pat. No. 6,904,466 (“Ishiyama”);
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`xvii. U.S. Pat. No. 7,028,337 (“Murakawa”);
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`xviii. U.S. Pat. No. 6,976,177 (“Ahonen”);
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`xix. WIPO Pub. WO 01/54379 A1 (“Ahonen WO”);
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`xx. U.S. Pat. No., 6,954,790 (“Forslow”);
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`xxi. Gupta et al., “Complete Computing,” WWCA '98 Proceedings of the
`Second International Conference on Worldwide Computing and Its
`Applications (March 4-5, 1998) (“Gupta”)
`
`
`xxii. Network Working Group Requests for Comments: 2401(S. Kent, R.
`Atkinson) (Nov. 1998), “Security Architecture for the Internet
`Protocol”) (RFC 2401)
`
`xxiii. Network Working Group Requests for Comments: 2002 (C. Perkins,
`ed.) (Oct. 1996), “IP Mobility Support” (RFC 2002)
`
`
`xxiv. RFC 1122, “Requirements for Internet Hosts -- Communication
`Layers (R. Braden; October 1989)
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`
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`7
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`IV.
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`APPLICABLE LEGAL STANDARDS
`
`A. Ordinary Skill in the Art
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`20. My opinions in this declaration are based on the understandings of a
`
`person of ordinary skill in the art, which I understand is sometimes referred to as
`
`an “ordinary artisan” or by the acronyms “POSITA” (person of ordinary skill in the
`
`art) or “PHOSITA” (person having ordinary skill in the art), as of the time of the
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`invention, which I understand is here assumed to be at least September 27, 2002.
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`This is because the application leading to the ’581 Patent was filed as a
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`continuation application of the parent application, U.S. App. No. 12/560,481,
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`which was filed on September 27, 2002. I also understand that the ’581 Patent
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`application also asserted priority to the filing date (September 28, 2001) of the
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`application filed in Finland, FI 20011910. See Ex. 1001 [’581 Patent] (Cover Page)
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`0001. My analysis and conclusions are same whether the relevant time period is
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`2001 or 2002. I understand that the person of ordinary skill in the art is a
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`hypothetical person who is presumed to have known the relevant art at the time of
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`the invention. By “relevant,” I mean relevant to the challenged claims of the ’581
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`Patent.
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`21.
`
`I understand that, in assessing the level of skill of a person of ordinary
`
`skill in the art, one should consider the type of problems encountered in the art, the
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`prior solutions to those problems found in the prior art references, the rapidity with
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`8
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`which innovations are made, the sophistication of the technology, the level of
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`education of active workers in the field, and my own experience working with
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`those of skill in the art at the time of the invention.
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`22.
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`In this case, Dr. Goldschlag has asserted in his declaration that a
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`person of ordinary skill in the art as of the time of the ʼ581 Patent would have had
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`a Bachelor’s degree in Electrical Engineering, Computer Engineering, Computer
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`Science, or an equivalent field, as well as at least 2-5 years of academic or industry
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`experience in computer network security. Ex. 1002 [Goldschlag dec.] ¶ 20. For the
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`purposes of the subject IPR proceedings, I have been asked to employ this standard
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`of a person of ordinary skill.
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`23.
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`I was at the time of invention, and am, one of more than ordinary skill
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`in the art through my education and research experience. As of the date of the
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`invention, I am very familiar with the types of problems encountered in computer
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`network security, the types of prior art solutions described in prior art references,
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`and the rapidity at which innovations are made. Indeed, I am very familiar with
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`people having this level of skill in the area of computer network security. At the
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`time of the invention, and since that time, I have been teaching undergraduate and
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`graduate level courses in computer network architecture and protocols including
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`various techniques for addressing information security.
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`9
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`B. Claim Construction
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`24.
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`I understand that claims of the patent-at-issue in this IPR are generally
`
`interpreted according to their ordinary and customary meaning taking into
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`consideration the so-called “intrinsic evidence” of the patent consisting of (1) the
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`claim language; (2) the specification; and (3) the prosecution history.
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`25.
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`I understand that claim terms may be explicitly defined in the patent
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`specification or they may be implicitly defined through consistent usage in the
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`specification. I also understand that the scope of claim terms may be limited by
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`statements in the specification or prosecution history where the applicant clearly
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`disavows or disclaims subject matter.
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`26. Petitioner has not offered any specific claim constructions, opting
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`instead to assert that all claim terms should be accorded their ordinary and
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`customary meaning. Pet., 11.
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`27.
`
`I will offer my opinion on the proper claim construction of “security
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`gateway” in the sections that follow.
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`C. Obviousness (35 U.S.C. § 103)
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`28.
`
`I have been informed that a patent may be invalid if the claimed
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`invention would have been obvious at the time the invention was made to a person
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`having ordinary skill in the art. I have been informed that the following factors
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`10
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`must be evaluated to determine whether Petitioner has met its burden of proof that
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`a claimed invention is obvious:
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`1. The scope and content of the prior art relied upon by Petitioner;
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`2. The difference or differences, if any, between each claim of the patent
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`and the prior art;
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`3. The level of ordinary skill in the art at the time the invention of the patent
`
`was made; and
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`4. Any objective indicia of non-obviousness, including, for example:
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`(1) commercial success of an embodiment; (2) a long-felt need;
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`(3) skepticism; (4) failure by others to find the solution provided by the
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`claimed invention; (5) copying by others of the subject matter of the
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`claim invention; (6) unexpected results of the claimed invention;
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`(7) acceptance of others and industry praise; and (8) licensing of the
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`patents.
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`29.
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`I have been informed that a claim is not proved obvious merely by
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`demonstrating that each of the elements was independently known in the prior art.
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`I have been informed that many, if not all, inventions rely on building blocks
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`already known, and claimed inventions almost of necessity will likely be
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`combinations of what is already known.
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`11
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`30.
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`I have been informed that a combination of prior art references must
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`disclose, teach or suggest all of the recited limitations of the claim for the invention
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`to be found obvious.
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`31.
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`I have been informed that it is important in the obviousness inquiry to
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`identify whether a reason existed at the time of the invention that would have
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`motivated a person of ordinary skill in the art in the relevant field to combine or
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`modify the prior art references in the manner proposed by the Petitioner so as to
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`arrive at the claimed invention. Put another way, a finding of obviousness should
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`be supported by an apparent reason to combine or modify the prior art references
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`as proposed by the Petitioner.
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`32.
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`I have been informed that it is important in the obviousness inquiry
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`that it is understood how the combination of references is supposed to work. An
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`explanation of the operation of the combined references is often a prerequisite to
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`showing that a person of ordinary skill in the art would have been motivated to
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`make the proposed combination and would have had a reasonable expectation of
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`success.
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`33.
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`I have been informed that a finding of obviousness “requires the
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`additional showing that a person of ordinary skill at the time of the invention
`
`would have selected and combined those prior art elements in the normal course of
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`research and development to yield the claimed invention.” Unigene Labs., Inc. v.
`
`12
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`Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir. 2011). In addition, I have been
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`informed that a person of ordinary skill in the art should have had a reasonable
`
`expectation of success in combining the references as proposed.
`
`34.
`
` In assessing obviousness, I have been instructed to consider both the
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`ordinary creativity and common sense of the person of ordinary skill in the art. I
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`also understand that it is impermissible for common sense to be applied to fill gaps
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`in the prior art that fails to teach or suggest a limitation of the claim. I also
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`understand that the obviousness inquiry should guard against hindsight bias or
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`hindsight reconstruction where after-the-fact reasoning is applied to combine prior
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`art elements using the claimed invention as a template, without establishing that, as
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`of the date of the invention, there exists a motivation to combine or apparent
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`reason to combine the prior art as proposed.
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`35.
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`In assessing obviousness, I have been instructed that, in order to
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`qualify as proper prior art for an obviousness analysis, a reference must qualify as
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`analogous art. I have been informed that a reference qualifies as analogous art with
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`respect to the claims if it is either: (1) from the same field or endeavor as the
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`patent; or (2) the reference is reasonably pertinent to the particular problem
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`addressed by the invention. I have also been informed that for a reference to be
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`reasonably pertinent, it must logically have commended itself during the ordinary
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`course of development to an inventor’s attention in considering his problem.
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`36.
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`In assessing obviousness, I have also been instructed that, as noted
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`above, secondary considerations can often be probative evidence of non-
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`obviousness and can serve to avoid hindsight bias. I have been instructed that
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`secondary considerations can be sufficient to overcome a prima facie case of
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`obviousness. I have been instructed that Patent Owner can show non-obviousness
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`if: (1) the industry praised their work; (2) their design was copied by others; (3)
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`their design achieved a high level of commercial success; or (4) their invention had
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`unexpected beneficial results, for example.
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`V.
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`OVERVIEW OF THE ’581 PATENT AND THE STATE OF THE ART
`AT THE TIME OF THE INVENTION
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`For clarity to the reader, my citations will adhere to these formats:
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` Petitions and other papers filed by the parties. Example: Pet., at 10,
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`12) refers to the Petition at pages 10 and 12.
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` Patents will be cited by their exhibit number, bates stamped page and
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`specific column and line numbers when feasible. Example: Ex. 1004
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`[Ishiyama] 0011 (1:10-12) refers to the Ishiyama patent at page 0011
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`and Col. 1, lines 10-12. Ex. 1004 (1:10-12) refers to same passage of
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`Ishiyama.
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` Articles and other publications will be cited by their exhibit number,
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`bates stamped page and their original page number when feasible (and
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`line numbers or paragraph numbers, if appropriate). Ex. 2005 [RFC
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`1122] 5.
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`A. Technical Background
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`37. Telecommunications networks can encompass a vast array of
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`components including local area networks (LANs), wide area networks (WANs)
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`and various computing devices all interconnected using intermediary networking
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`devices. Intermediary networking devices such as routers enable different networks
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`to be interconnected to function as an “internetwork,” that is, as an internet. Such
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`interconnected networks can allow geographically dispersed users to communicate.
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`Ex. 1001 [’581 Patent] 0007 (1:30-42).
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`38. Normally, a person who mails a sealed letter does not want and does
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`not expect that the contents of the letter will be read by a third party while the letter
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`is en route to the intended recipient. In a similar manner, those parties who
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`exchange communications between a first host device and a second host device
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`want to protect the confidentiality and integrity of the information they are
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`exchanging.
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`39. The ’581 Patent explains that secure communications of messages
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`across networks is extremely important. The ’581 Patent identifies various types of
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`security that may be sought for the protection of messages:
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`There is a need to protect data and resources from disclosure, to
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`guarantee the authenticity of data, and to protect systems from network
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`based attacks. More in detail, there is a need for confidentiality
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`(protecting the contents of data from being read), integrity (protecting
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`the data from being modified, which is a property that is independent
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`of confidentiality), authentication (obtaining assurance about the actual
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`sender of data), replay protection (guaranteeing that data is fresh, and
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`not a copy of previously sent data), identity protection (keeping the
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`identities of parties exchanging data secret from outsiders), high
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`availability, i.e. denial-of-service protection (ensuring that the system
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`functions even when under attack) and access control. Ex. 1001 [’581
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`Patent] 0007 (1:43-55).
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`40. At the time of the invention, there was a technique for message
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`protection in computer networks that was described in an Internet specification
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`document, “Security Architecture for the Internet Protocol,” that was issued by the
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`Internet Engineering Task Force (IETF) Network Working Group as RFC 2401.
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`See Ex. 1011 [Security Architecture for the Internet Protocol] (November 1998).
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`This document refers to a technology for message protection known as “IPsec.”
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`Id., 3 (“This memo specifies the base architecture for IPsec compliant systems.”)
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`41. RFC 2401 describes the fundamental features and processes of IPSec
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`secure connections:
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`This memo specifies the base architecture for IPsec compliant systems.
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`The goal of the architecture is to provide various security services for
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`traffic at the IP layer . . . The following fundamental components of the
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`IPsec security architecture are discussed in terms of their underlying,
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`required functionality . . .
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`a. Security Protocols -- Authentication Header (AH) and
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`Encapsulating Security Payload (ESP)
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`b. Security Associations -- what they are and how they work,
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`how they are managed, associated processing
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`c. Key Management -- manual and automatic (The Internet Key
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`Exchange (IKE))
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`d. Algorithms for authentication and encryption
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`
`
`
`
`
`
`Id., [Section 1.1: Summary of Contents of Document] 3.
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`42. The ’581 Patent explicitly references RFC 2401. Ex. 1001 [’581
`
`Patent] 0007 (2:12), 0009 (5:54-57). The ’581 Patent provides a detailed
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`explanation of the features of IPSec:
`
`The IP security protocols (IPSec) provides the capability to secure
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`communications between arbitrary hosts, e.g. across a LAN, across
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`private and public wide area networks (WANs) and across the internet
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`IPSec can be used in different ways, such as for building secure virtual
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`private networks, to gain a secure access to a company network, or to
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`secure
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`communication with
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`other
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`organisations,
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`ensuring
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`authentication and confidentiality and providing a key exchange
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`mechanism. Id., 0007 (1:59-66).
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`43. Addressing the need for secure messaging, the ’581 Patent discloses
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`that IPSec secure connections provide “confidentiality[,] integrity, authentication,
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`replay protection, limited traffic flow confidentiality, limited identity protection,
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`and access control based on authenticated identities.” Id., 0007 (1:67-2:3).
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`44. The ’581 Patent describes fundamental concepts of IPSec secure
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`connections. For example, Security Associations (SAs) are data structures that are
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`fundamental to IPSec processing. Id., 0007 (2:23-34). RFC 2401 also discloses
`
`SAs as fundamental to IPSec processing. Ex. 1011 [RFC 2401] 3. I understand the
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`key role of SAs in IPSec from my personal experience with that technology.
`
`45. The ’581 Patent explains that an SA defines a one-way security
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`relationship that protects the message traffic sent from sender to a receiver. If a
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`two-way secure connection between the sender and receiver is desired, then two
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`SA definitions are required. In some cases, multiple SAs, referred to as an “SA
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`bundle,” are used to protect a data packet being sent from one address to another.
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`In the ’581 Patent, the term “IPsec connection” encompasses an IPSec bundle or
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`IPSec bundles (e.g., one for each direction) of SAs that define the security
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`protocols that will be employed for message traffic between two host devices, for
`
`example. Ex