`Patent 7,620,810
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`MPH TECHNOLOGIES OY,
`Patent Owner.
`____________
`
`Case IPR2019-00819
`Patent 7,620,810
`____________
`
`EXHIBIT 2003
`
`DECLARATION OF PROFESSOR GEORGE N. ROUSKAS, PH.D.
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`MPH Technologies Oy, Exhibit 2003
`Page 2003 - 1
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`Apple EX1021
`Apple v. MPH
`IPR2019-00821
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`
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`TABLE OF CONTENTS
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`Page
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`I.
`
`II.
`
`III.
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`IV.
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`INTRODUCTION ........................................................................................ 1
`
`QUALIFICATIONS ..................................................................................... 1
`
`BASES OF OPINIONS ................................................................................ 6
`
`APPLICABLE LEGAL STANDARDS ...................................................... 8
`
`A. Ordinary Skill in the Art ........................................................................ 8
`
`B.
`
`Claim Construction.............................................................................. 10
`
`C. Obviousness (35 U.S.C. § 103) ........................................................... 10
`
`V.
`
`OVERVIEW OF THE ’810 PATENT AND THE STATE OF THE
`ART ..............................................................................................................14
`
`A.
`
`B.
`
`C.
`
`Technical Background ......................................................................... 15
`
`The Mobility Problem Addressed by the ’810 Patent ......................... 21
`
`The ’810 Patent’s Solution to the Mobility Problem .......................... 23
`
`VI.
`
`CLAIM CONSTRUCTION .......................................................................28
`
`VII. CLAIM 1 IS 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
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`1. Multiple Publications from the Relevant Timeframe
`Confirm that a Correspondent Host is Not a Security
`Gateway .................................................................................... 52
`
`2.
`
`3.
`
`4.
`
`5.
`
`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 ................................. 65
`
`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 ........................................................................................... 68
`
`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 Address of the Security Gateway to Change the
`Secure Connection to Be Defined Between the Second Address
`and the Address of the Security Gateway ........................................... 76
`
`E.
`
`F.
`
`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” ......................................................................... 77
`
`The Petition Fails to Establish that the Prior Art Teaches the
`“Request Message and/or a Reply Message Being Encrypted
`and/or Authenticated by Using the Same SA Already Established” .. 81
`
`VIII. CLAIM 7 IS PATENTABLE OVER THE COMBINATION OF
`ISHIYAMA AND MURAKAWA (GROUND 1) ....................................84
`
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`IX. CLAIMS 2-3 ARE PATENTABLE OVER THE COMBINATION OF
`ISHIYAMA, MURAKAWA AND AHONEN (GROUND 2) .................88
`
`A. Overview of Ahonen ........................................................................... 89
`
`B. The Combination of Ishiyama, Murakawa and Ahonen Fails to
`Teach Sending a “Reply Back to the Mobile Terminal . . . From
`the Security Gateway” (Claim 2) or a “Reply Message to the
`Mobile Terminal at the Second Address to Confirm the Address
`Change” (Claim 3)............................................................................... 92
`
`X.
`
`CLAIM 6 IS PATENTABLE OVER THE COMBINATION OF
`ISHIYAMA, MURAKAWA AND FORSLOW (GROUND 3) ..............94
`
`XI. CONCLUSION ...........................................................................................96
`
`iii
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`I.
`
`INTRODUCTION
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`1. My name is George Rouskas. I have been retained as an expert
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`witness to provide my independent opinion in regards with matters at issue in the
`
`inter partes review of U.S. 7,620,810 (“the ’810 Patent”) in the IPR2019-00819
`
`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
`
`personal knowledge, and if called to testify about this declaration, I could and
`
`would do so competently and truthfully.
`
`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.
`
`4.
`
`I am not a legal expert and offer no opinions on the law. However, I
`
`have been informed by counsel of the various legal standards that apply, and I have
`
`applied those standards in arriving at my conclusions.
`
`II.
`
`QUALIFICATIONS
`
`5.
`
`I am an Alumni Distinguished Graduate Professor with Tenure in the
`
`Department of Computer Science at North Carolina State University (NC State),
`
`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
`
`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
`
`applications including providing for the protection of information transmitted
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`between devices within and among networks.
`
`6.
`
`I have thirty years of experience in computer networking since I
`
`received my bachelor’s degree in 1989. I have twenty-five years of experience as a
`
`professor in the Department of Computer Science of NC State.
`
`7.
`
`During this time, I have led, overseen, and contributed to numerous
`
`research projects involving technical concepts that are related to the technology at
`
`issue in the IPR2019-00819 proceeding, which relates to the issue of providing
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`mobility to secure connections over networks, such as where a first computer
`
`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
`
`architecture, a suite of communication protocols, and a proof-of-concept prototype
`
`implementation to enable real-time economic transactions in the network layer,
`
`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
`
`networks and designed relevant security mechanisms.
`
`2
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`8.
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`I have taught courses on computer networks, Internet protocols, data
`
`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
`
`I cover in detail topics related to network security (including IPSec) and mobile IP.
`
`9.
`
`I received numerous accolades for my contributions to computer
`
`networking and was elected as Fellow of the IEEE in 2012. These include the
`
`Outstanding Service Award for the Optical Networking Technical Committee
`
`(ONTC) of the IEEE Communication Society (2019); the Joyce Hatch Service
`
`Award from the NC State Chapter of the Association for Computing
`
`Machinery/Association of Information Technology Professionals (ACM/AITP)
`
`(2018); Distinguished Lecturer in the IEEE (2010-2012); an IBM Faculty Award
`
`(2007); the Best Paper Award for the International Workshop on End-to-End
`
`Virtualization and Grid Management (EVGM) (2007) (with C. Castillo and K.
`
`Harfoush); the Best Paper Award for the International Symposium on
`
`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
`
`Outstanding Research Award, NC State (2003); a CAREER Award from the
`
`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.
`
`I received my PhD in Computer Science (Georgia Institute of
`
`Technology, 1994); M.S. in Computer Science (Georgia Institute of Technology,
`
`1991); and B.S. in Computer Engineering (National Technical University of
`
`Athens, 1989).
`
`11.
`
`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.
`
`12. My work as an academic began in 1994, when I joined NC State as an
`
`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.
`
`13.
`
`I have had visiting positions at a number of international universities,
`
`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
`
`d’Informatique University of Paris 6 (France, October 2012); Visiting Professor at
`
`the Universidad Tecnica Federico Santa Maria (Chile, December 2008); and
`
`Visiting Professor at the Laboratoire de Méthodes Informatiques University of
`Evry (France, July 2006, December 2002, June 2000).
`
`14.
`
`I have received funding from numerous agencies, foundations and
`
`companies for research on network design and communication. The sources of
`
`funding for this research include the National Science Foundation (NSF), the
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`
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`Defense Advanced Research Projects Agency (DARPA), the National Security
`
`Agency (NSA), Microsoft, IBM and Cisco.
`
`15.
`
`I have served in a number of leadership roles for the IEEE, including
`
`as Chair of the IEEE Communications Society’s Distinguished Lecturer Selection
`
`Committee (2016-2017); Vice Chair of the IEEE Communications Society’s
`
`Technical and Educational Activities Council (2016-2017); and Chair of the IEEE
`
`Communications Society’s Optical Networking Technical Committee (2016-2017).
`
`16.
`
`I have served in various editorial positions, including as founding
`
`Editor-in-Chief of IEEE Networking Letters (2018-present); founding Editor-in-
`
`Chief of Elsevier Optical Switching and Networking Journal (2004-2017);
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`Associate Editor, IEEE/OSA Journal of Communications and Networking (2010-
`
`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
`
`Editor, Computer Networks (2001-2004); Associate Editor, Optical Networks
`
`(2000-2004); and Co-Guest Editor, IEEE Journal on Selected Areas in
`
`Communications, Special Issue on “Protocols for Next Generation Optical WDM
`
`Networks,” vol. 18, no. 10, October 2000.
`
`17.
`
`I have graduated twenty-five Ph.D. students. Two received PhD
`
`dissertation awards, one received an NSF Career award, and one became an NSA
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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.
`
`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).
`
`These are summarized in my curriculum vitae.
`
`III.
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`BASES OF OPINIONS
`
`19.
`
`In the course of conducting my analysis and forming my opinions, I
`
`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.
`
`U.S. Patent No. 7,620,810 and its prosecution history;
`
`Petition by Apple in IPR2019-00819;
`
`iii.
`
`Petition by Apple in IPR2019-00820;
`
`iv.
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`Petition by Apple in IPR2019-00821;
`
`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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`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;
`
`xi.
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`Institution Decision by the PTAB in IPR2019-00819;
`
`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. 7,937,581;
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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”);
`
`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)
`
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`xxiv. RFC 1122, “Requirements for Internet Hosts -- Communication
`Layers (R. Braden; October 1989)
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`
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`IV.
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`APPLICABLE LEGAL STANDARDS
`
`A. Ordinary Skill in the Art
`
`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 the filing date (September 27,
`
`2002) of the Patent Cooperation Treaty (PCT), PCT/FI02/00770, from which the
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`original patent application of the ’810 Patent asserted priority. I also understand
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`that the original patent application of the ’810 Patent asserts priority to the filing
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`date (September 28, 2001) of the application filed in Finland, FI 20011910. My
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`analysis and conclusions are same whether the relevant time period is 2001 or
`
`2002. I understand that the person of ordinary skill in the art is a hypothetical
`
`person who is presumed to have known the relevant art at the time of the invention.
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`By “relevant,” I mean relevant to the challenged claims of the ’810 Patent.
`
`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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`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.
`
`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 ʼ810 Patent would have had
`
`a Bachelor’s degree in Electrical Engineering, Computer Engineering, Computer
`
`Science, or an equivalent field, as well as at least 2-5 years of academic or industry
`
`experience in computer network security. Ex. 1002 ¶ 20. For the purposes of the
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`subject IPR proceedings, I have been asked to employ this standard of a person of
`
`ordinary skill.
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`23.
`
`I was at the time of invention, and am, one of more than ordinary skill
`
`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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`B. Claim Construction
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`24.
`
`I understand that claims of the patent-at-issue in this IPR are generally
`
`interpreted according to their ordinary and customary meaning taking into
`
`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.
`
`I understand that claim terms may be explicitly defined in the patent
`
`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., 12.
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`27.
`
`I will offer my opinion on the proper claim construction of “security
`
`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
`
`invention would have been obvious at the time the invention was made to a person
`
`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
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`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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`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.
`
`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
`
`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
`
`as proposed by the Petitioner.
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`32.
`
`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.
`
`33.
`
`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.
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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 prior art that fails to teach or suggest a limitation of the claim. I also understand
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`that the obviousness inquiry should guard against hindsight bias or hindsight
`
`reconstruction where after-the-fact reasoning is applied to combine prior art
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`elements using the claimed invention as a template, without establishing that, as of
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`the date of the invention, there exists a motivation to combine or apparent reason to
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`combine the prior art as proposed.
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`35.
`
`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
`
`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 ’810 PATENT AND THE STATE OF THE ART
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`For clarity to the reader, my citations will generally adhere to these formats:
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` Petitions and other papers filed by the parties. Example: Pet., 10, 12
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`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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`and bates stamped page and their original page number when feasible.
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`Example: Ex. 2005 [RFC 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 [’810 Patent] 0008 (1:25-40).
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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 ’810 Patent explains that secure communications of messages
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`across networks is extremely important. The ’810 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 [’810
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`Patent] 0008 (1:41-53).
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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 ’810 Patent explicitly references RFC 2401. Ex. 1001 [’810
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`Patent] 0008 (2:10), 0010 (5:59-62). The ’810 Patent provides a detailed
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`explanation of the features of IPSec:
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`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., 0008, (1:57-64).
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`43. Addressing the need for secure messaging, the ’810 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., 0008 (1:64-2:1).
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`44. The ’810 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., 0008 (2:21-32). RFC 2401 also discloses
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`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.
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`45. The ’810 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 ’810 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
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`example. Ex. 1001 [’810 Patent] 0008 (2:21-40).
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`46. The ’810 Patent discloses that an SA is uniquely defined by three
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`parameters: (1) the Security Parameters Index