Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 1 of 15
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`MULTIMEDIA CONTENT
`MANAGEMENT LLC,
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`Plaintiff
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`v.
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`DISH NETWORK L.L.C.,
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`Defendant.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Civil Action No.: 6:18-cv-00207-ADA
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`JURY TRIAL DEMANDED
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`PATENT CASE
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`
`
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`PLAINTIFF’S REPLY CLAIM CONSTRUCTION BRIEF
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`In accordance with the Court’s Initial Scheduling Order, Plaintiff Multimedia Content
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`Management LLC (“Plaintiff” or “MCM”) submits the following brief in reply to Defendant Dish
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`Network L.L.C.’s (“Defendant” or “Dish) responsive claim construction brief, D.I. 52.
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`
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`1
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`DISH, Exh.1028, p.0001
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 2 of 15
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`Contents
`Introduction ............................................................................................................................. 1
`I.
`II. Disputed Terms of the Independent Claims ............................................................................ 1
`A. Disputed Term No. 1 – “to generate controller instructions” .............................................. 1
`B. Disputed Term No. 2 – “a controller node” ......................................................................... 3
`C. Disputed Term No. 3 – “a service provider network” ......................................................... 4
`D. Disputed Term No. 4 – “selectively transmit[ting, by the plurality of gateway units,] the
`content requests to the service provider network in accordance with the controller instructions”
`
`.............................................................................................................................................. 6
`E. Disputed Term No. 5 – “gateway units” .............................................................................. 7
`F. Disputed Term No. 6 – “network elements” ........................................................................ 8
`III. Disputed Terms of the Dependent Claims ........................................................................... 8
`A. Disputed Term No. 7 – “if the gateway unit enters the inactive state” (ʼ468 Patent, Claim
`29) .............................................................................................................................................. 9
`B. Disputed Term No. 8 – “registration information” (ʼ468 Patent, Claim 33) ....................... 9
`C. Disputed Term No. 9 – “uniquely” .................................................................................... 10
`D. Disputed Term No. 10 – “initial operating parameters” (ʼ468 Patent, Claim 33) ............. 10
`IV. Conclusion ......................................................................................................................... 11
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`2
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`DISH, Exh.1028, p.0002
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 3 of 15
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`Exhibit List
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`
`
`Exhibit No.
`2001
`2002
`
`2003
`
`2004
`2005
`
`2006
`
`Description
`Declaration of Mr. Joel R. Williams
`File History of U.S. Patent Application No. 13/369,174
`Decision Denying Institution of Inter Partes Review, IPR2017-01934,
`Paper No. 10
`U.S. Patent No. 8,799,468
`U.S. Patent No. 9,465,925
`Patent Owner’s Preliminary Response in Inter Partes Review, IPR2017-
`01934, Paper No. 9
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`
`
`
`
`
`
`3
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`DISH, Exh.1028, p.0003
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 4 of 15
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`I.
`
`INTRODUCTION
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`Plaintiff Multimedia Content Management LLC (“Plaintiff” or “MCM”) submits the
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`following brief in reply to Dish’s responsive claim constructions brief submitted to the Court on
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`April 5, 2019, D.I. 52. As detailed below, Dish continues to seek constructions that are not
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`supported by, and are inconsistent with, the specifications and file histories of the Patents-in-Suit.
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`In accordance with the Court’s Scheduling Order, D.I. 33 (Jan. 4, 2019), and the parties’
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`Joint Stipulation Regarding Proposed Amended Scheduling Order, D.I. 42 (March 12, 2019), the
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`parties have not scheduled any exchange of extrinsic evidence regarding claim construction. MCM
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`does not believe any extrinsic evidence is necessary for the Court to properly construe the disputed
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`terms, and therefore MCM has not cited to any extrinsic evidence in support of its proposed
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`constructions.
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`II. DISPUTED TERMS OF THE INDEPENDENT CLAIMS
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`A. Disputed Term No. 1 – “to generate controller instructions”
`
`Defendant’s Construction
`“to create[ing] or bring[ing] into being
`computer executable instructions that
`determine whether to transmit or not transmit
`a content request from a user to the service
`provider network”
`
`
`
`Plaintiff’s Construction
`“generate computer processor-executable
`instructions, excluding merely a uniform
`resource locator (URL) or an internet protocol
`(IP) address”
`
`
`Plaintiff’s Amended Construction
`“generate computer processor-executable
`instructions, excluding merely a uniform
`resource locator (URL) or an internet protocol
`(IP) address, excluding operations in which
`the controller instructions are only transmitted
`or are relayed by a device”
`
`
`
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`As a threshold matter, MCM notes that its proposed construction is identical to the
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`construction offered in the file history of the ʼ468 Patent. Specifically, MCM’s proposed
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`construction is identical to the construction MCM offered in Patent Owner’s Preliminary Response,
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`1
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`DISH, Exh.1028, p.0004
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 5 of 15
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`IPR2017-01934, Paper 9, at 4–8 (attached hereto as EX2006) (“POPR”). Dish has not provided
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`any reason why the Court should deviate from the intrinsic evidence of the ʼ468 Patent—which
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`includes the POPR—in construing the terms of the ʼ468 Patent.
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`In an effort to reduce the number of issues, MCM offered to narrow its construction,
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`explicitly excluding operations in which the controller instructions are only transmitted or are
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`relayed by a device. Despite this, Dish continues to argue that “whether instructions must be
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`created and not simply transmitted or relayed” is in dispute. Dish Responsive Brief at 1. MCM
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`disagrees that this is in dispute.
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`Further, in an effort to further reduce the number of issues, MCM is willing to accept the
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`construction: “create or bring into being computer processor-executable instructions, excluding
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`merely a uniform resource locator (URL) or an internet protocol (IP) address.”
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`Despite the fact that MCM’s proposed construction matches the claim construction that is
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`explicitly part of the intrinsic evidence, see POPR, EX2006 at 8, Dish also argues that the intrinsic
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`evidence supports “the understanding that ‘controller instructions’ must decide whether or not to
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`transmit content requests.” Id. While MCM agrees that this is one function controller instructions
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`can support, Dish’s construction unnecessarily limits controller instructions to just that one
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`function. Dish’s argument is premised on combining the “generate controller instructions” and
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`“selectively transmit” limitations into a single limitation. Reply at 3–5. As MCM noted, controller
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`instructions can instruct a gateway unit to do more than just “determine whether to transmit or not
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`transmit a content request,” as Dish’s construction would require. E.g., ʼ468 Patent, 18:61–63,
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`18:64–67 (Claim 4) (“wherein the controller instructions comprise instructions configured to
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`generate a notification to the controller node if a content request designates a network server of
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`the service provider network.”).
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`2
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`DISH, Exh.1028, p.0005
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 6 of 15
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`Dish’s argument that a construction of controller instructions that properly covers multiple
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`features and functions disclosed by the ʼ468 Patent would somehow “read terms out of the claim”
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`is baseless. In Claim 1 of the ʼ468 Patent, the second processor of the gateway unit is “configured
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`to selectively transmit the content requests to the service provider network in accordance with the
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`controller instructions.” ʼ468 Patent, 18:47–54. That is just one claim, however. In other claims
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`(e.g., Claims 3 and 4 of the ʼ468 Patent), the controller instructions perform more than determining
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`whether to transmit or not transmit a content request. E.g., ʼ468 Patent, 18: 64–67 (Claim 4)
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`(“wherein the controller instructions comprise instructions configured to generate a notification to
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`the controller node if a content request designates a network server of the service provider
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`network.”).
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`B. Disputed Term No. 2 – “a controller node”
`
`Plaintiff’s Construction
`“A network-based router or computer located
`within the network and remote from the
`gateway unit and that controls the operation
`of one or more gateway units”
`
`Defendant’s Construction
`“a single network device that controls the
`operation of the gateway units”
`
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`There are two points of dispute between MCM and Dish regarding this term: (1) whether
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`“a controller node” requires a single device, and (2) whether MCM’s construction “imports
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`limitations from the specification.” The first argument is flawed logically and the second argument
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`ignores the specification of the ʼ468 Patent.
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`First, Dish’s Responsive Claim Construction Brief adds nothing to support its flawed
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`arguments that: (1) because a controller node must both generate and transmit controller
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`instructions, the controller node must be a single device, Dish Brief at 7–8, and (2) because a
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`controller node cannot receive controller instructions from “another device,” the controller node
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`must be a single device. Id. at 8–9. As MCM explained in its Responsive Brief, both arguments
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`3
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`DISH, Exh.1028, p.0006
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 7 of 15
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`are flawed and neither necessitates Dish’s conclusion. See MCM Responsive Brief at 7–9 (“Even
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`if a controller node were incapable of receiving controller instructions from ‘another device,’
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`nothing requires a controller node to be ‘a single network device.’”).
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`Next, Dish argues that MCM’s use of “network-based router or computer located within
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`the network and remote from the gateway unit” somehow “introduce ambiguity and conflict with
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`MCM’s own descriptions of the figures and specification.” Dish Responsive Brief at 8–9. First, it
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`is unclear how (as Dish argues) MCM’s proposed construction is “lexicography or disclaimer.” Id.
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`at 8. Dish admits, through reliance on unnecessary extrinsic evidence, that the term “node” may
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`require construction. Thus, Dish’s argument that MCM’s construction of node requires
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`lexicography rings hollow.
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`However, in the interest of reducing the number of issues, if Dish and/or the Court believes
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`“network device” is more clear to a jury than “network-based router or computer,” MCM is willing
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`to adopt the construction: “a network device located within the network and remote from the
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`gateway unit and that controls the operation of one or more gateway units.”
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`C. Disputed Term No. 3 – “a service provider network”
`
`Plaintiff’s Construction
`“a network that is operated or controlled by a
`service provider to provide regulated access
`to content delivery services for subscribers,
`but not including subscriber equipment or a
`subscriber network”
`Plaintiff’s Amended Construction
`“a network that is operated or controlled by a
`service provider to provide regulated access
`to content delivery services for subscribers,
`but not including subscriber equipment or a
`subscriber network or the entire public
`internet”
`
`Defendant’s Construction
`“a network between the controller node and
`the plurality of gateway units that is not the
`public Internet and only includes those
`network elements operated or controlled by
`the service provider”
`
`
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`4
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`DISH, Exh.1028, p.0007
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 8 of 15
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`As a threshold matter, MCM notes that its proposed construction is substantively identical
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`to the construction offered in the file history of the ʼ468 Patent. Specifically, MCM’s proposed
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`construction is substantively identical to the construction MCM offered in the POPR. EX2006 at
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`4. Dish has not provided any reason why the Court should deviate from the intrinsic evidence of
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`the ʼ468 Patent—which includes the POPR—in construing the terms of the ʼ468 Patent.
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`Dish argues that MCM’s construction “backpedals away” from disclaimers made during
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`IPR2017-01934, Unified Patents Inc. v. Multimedia Content Management LLC (“Unified Patents
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`IPR”). Dish Responsive Brief at 10. MCM respectfully notes that MCM’s construction of “service
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`provider network” is substantively identical to the construction MCM adopted in the Unified
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`Patents IPR. 1 EX2006 at 4–8. It is also substantively identical to the construction proposed by
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`MCM’s expert in the IPR.2 EX2001 at ¶ 47. In an effort to reduce the number of issues, MCM
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`proposed to narrow its construction to explicitly exclude the entire public internet. Dish
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`Responsive Brief at 11–12.
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`Dish’s proposed construction misstates MCM’s positions in the Unified Patents IPR and
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`ignores technical operation of networks and the Internet. First, Dish argues that MCM somehow
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`disclaimed any use whatsoever of the public Internet. Id. at 11–12. As noted above, this is
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`inaccurate. MCM narrowed the construction of service provider network to exclude the entire
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`public Internet. Second, Dish argues that its definition, which “only includes those network
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`                                                            
`1 In the Unified Patent IPR, MCM proposed a construction of “a network that is operated or
`controlled by a service provider to provide regulated access to content delivery services for
`subscribers. The service provider network does not include subscriber equipment or a subscriber
`network.” EX2006 at 4.
`2 Mr. Williams proposed that “service provider network” should be construed as: “A network
`that is operated or controlled by a service provider to provide regulated access to content
`delivery services for subscribers. The service provider network does not include subscriber
`equipment or a subscriber’s local area network.” EX2001 at ¶ 47.
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`5
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`DISH, Exh.1028, p.0008
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 9 of 15
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`elements operated or controller by the service provider network,” is supported by the specification
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`of the ʼ468 Patent. Id. at 13–14. Further, while the service provider network may be “operated or
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`controlled by a service provider,” data packets within the service provider network may travel over
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`cables, fiber, switches, routers, or other network elements that do not belong to the service provider.
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`Dish’s construction that limits a service provider network to a network that “only includes those
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`network elements operated or controlled by the service provider” improperly restricts the ʼ468
`
`Patent to unsupported, unrealistic scenarios.
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`D. Disputed Term No. 4 – “selectively transmit[ting, by the plurality of gateway units,]
`the content requests to the service provider network in accordance with the
`controller instructions”
`
`Plaintiff’s Construction
`“a gateway unit, under control of the remotely
`located controller node, executes previously
`received controller instructions to determine
`whether to transmit a content request from a
`user or to take other action (e.g., deny the
`content request, redirect the content request,
`or notify authorities regarding the content
`request)”
`
`Defendant’s Construction
`“transmitting all content requests to take place
`within the service provider network in
`response to the controller instructions’
`decision to transmit the content requests”
`
`Dish characterizes the “key dispute” for this term as “whether the content requests from
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`the gateway units or network elements must travel over the service provider network or not.” Dish
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`Responsive Brief at 14–17. Dish again makes a sweeping position that is a flawed leap from the
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`support it cites. MCM acknowledges that communications between a gateway unit and a controller
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`node may take place within the service provider network. Dish, however, cannot accept that those
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`communications may not take place within the service provider network. As MCM noted in its
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`Responsive Brief, 12–13, restricting “selectively transmitting” to take place wholly within the
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`service provider network would, for example, exclude any configuration in which the subscriber
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`owned a gateway unit outright.
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`6
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`DISH, Exh.1028, p.0009
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 10 of 15
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`Further, while the service provider network may be “operated or controlled by a service
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`provider,” data packets within the service provider network may travel over cables, fiber, switches,
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`routers, or other network elements that do not belong to the service provider.
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`Finally, Dish’s construction introduces unnecessary ambiguity. Controller instructions do
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`not “decide” to transmit content requests. Controller instructions are computer-executable
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`instructions. A computer device with a processor must execute those instructions. Only in this
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`sense does a device “decide” anything.
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`E. Disputed Term No. 5 – “gateway units”
`
`Plaintiff’s Construction
`“a computer device that is located within a
`subscriber premise, remote from the
`controller node, that is under control of the
`controller node, and that is usable by a
`subscriber to perform certain functionality
`only as permitted by the controller node”
`Plaintiff’s Amended Construction
`“a computer device that is located within a
`subscriber premise, remote from the
`controller node, that is under control of the
`controller node, and that is usable by a
`subscriber to perform certain functionality
`only as permitted by the controller node”
`
`Defendant’s Construction
`“computer devices that are remote from the
`controller node and interface with the service
`provider network and a subscriber terminal”
`
`
`
`
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`Dish states that the parties’ “dispute centers on whether or not the ‘gateway units’ must be
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`‘located within a subscriber premise’ as proposed by MCM.” Dish Brief at 19 (emphasis in
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`original). While MCM disagrees that MCM’s proffered construction was made “without any
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`intrinsic support,” id., in an effort to simplify the issues, MCM proposes to remove the phrase
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`7
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`DISH, Exh.1028, p.0010
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 11 of 15
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`“located within a subscriber premise” from MCM’s proffered construction.3 Dish does not dispute
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`any other portion of MCM’s proposed construction.
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`F. Disputed Term No. 6 – “network elements”
`
`Plaintiff’s Construction
`“a computer device that is located within the
`service provider network and remote from the
`controller node, that is under control of the
`controller node, and that is usable by a
`subscriber to perform certain functionality
`only as permitted by the controller node”
`
`Defendant’s Construction
`“computer devices within the service provider
`network”
`
`Dish’s construction of “network elements” is impermissibly broad. For example, Dish
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`proposes that a service provider network is a network that “includes those network elements
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`operated or controlled by the service provider.” Dish Brief at 11. Therefore, under Dish’s
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`construction of “network elements,” any “computer device” that belongs to the service provider
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`would be a “network element.” This would include any of the service provider’s web servers,
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`databases, or employee laptops. This is inconsistent with the ʼ925 Patent.
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`In an effort to reduce the number of issues, MCM is willing to incorporate Dish’s “within
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`the service provider network” limitation into MCM’s proposed construction, as noted above.
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`III. DISPUTED TERMS OF THE DEPENDENT CLAIMS
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`Dish speculates, without any basis, that MCM proposes constructions of the dependent
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`claim terms “hoping that those limitations will save the claims from future validity challenges.”
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`Dish Responsive Brief at 23. Again, MCM denies Dish’s claim of “litigation gamesmanship,”
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`noting MCM simply intends to clarify the language of the dependent claims.
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`                                                            
`3 Due to timing issues, MCM did not have a chance to share this proposed amendment with Dish.
`Should Dish desire additional time to supplement its Responsive Brief, MCM would not oppose
`any reasonable request to do so.
`
`8
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`DISH, Exh.1028, p.0011
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 12 of 15
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`MCM construed the dependent claim terms listed in the JCCS in accordance with the
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`specifications of the ʼ468 and ʼ925 Patents, as detailed in MCM’s Opening Claim Construction
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`Brief. Despite Dish’s allegations, MCM has never offered any “construction that adds language to
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`a claim without intrinsic support.” Id. In light of this, and to reduce the number of terms in dispute,
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`MCM agrees to Dish’s proposal that “subscriber management system” (ʼ925 Dependent Claim 25)
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`and “authenticate subscribers or devices before allowing access into the service provider network”
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`(ʼ925 Dependent Claim 25) should be given their plain and ordinary meaning.
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`
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`A. Disputed Term No. 7 – “if the gateway unit enters the inactive state” (ʼ468 Patent,
`Claim 29)
`
`Plaintiff’s Construction
`“within a reasonable time before or after the
`gateway unit enters the inactive state”
`
`Defendant’s Construction
`Plain and ordinary meaning, no construction
`necessary with construction of overlapping
`terms as proposed above
`
`Dish argues that MCM’s attempt to clarify the if-then nature of Claim 29 is an improper
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`“temporal limitation.” Dish Responsive Brief at 24. MCM disagrees. The plain and ordinary
`
`meaning of “if” suggests a necessary temporal relationship: if X, then later Y. As MCM has
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`repeatedly argued, the ʼ468 Patent specification does not impose such a hard and fast temporal
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`relationship. See ʼ468 Patent 7:48–52; 10:7–30. MCM therefore submits that clarifying the
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`temporal nature of Claim 29 would aid in a jury’s understanding of the term and is consistent with
`
`the specification of the ʼ468 Patent.
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`B. Disputed Term No. 8 – “registration information” (ʼ468 Patent, Claim 33)
`
`Plaintiff’s Construction
`“information that associates a gateway unit
`with a controller node”
`
`Defendant’s Construction
`Plain and ordinary meaning, no construction
`necessary
`
`Dish argues that MCM’s construction “seeks to transform the claimed ‘registration
`
`information’ in to something very different from what the claims and intrinsic record support.”
`
`9
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`DISH, Exh.1028, p.0012
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 13 of 15
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`Dish Responsive Brief at 25. Dish provides no mention of what this “something very different”
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`might be. While MCM agrees that “both ‘registration’ and ‘information’ can be easily understood
`
`by a jury,” id. at 24, MCM believes it would be helpful to a jury to clarify what is being registered,
`
`and with what else. In the context of Claim 33, MCM believes it would be helpful to a jury to
`
`clarify that a gateway unit is being registered with a controller node. If Dish and/or the Court
`
`believe that the language “information that registers a gateway unit with a controller note” is more
`
`appropriate, MCM has no objection.
`
`C. Disputed Term No. 9 – “uniquely”
`
`Plaintiff’s Construction
`“possessing, within a network, a characteristic
`of a device that is not shared by other devices
`within the network””
`
`Defendant’s Construction
`Plain and ordinary meaning, no construction
`necessary
`
`Dish argues that MCM’s cited portion of the ʼ468 Patent specification “does not mention
`
`a ‘network’ at all, much less that the ‘unique identifying information’ must be identifying
`
`information ‘not shared by other devices within the network’ as MCM alleges.” Dish Responsive
`
`Brief at 25. MCM respectfully submits that this is precisely what an “IP address” is—information
`
`that uniquely identifies a device within a network that is not shared by other devices within the
`
`network.
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`D. Disputed Term No. 10 – “initial operating parameters” (ʼ468 Patent, Claim 33)
`
`Plaintiff’s Construction
`“one or more variables associated with an
`operating mode first entered into by a
`gateway unit after registration”
`
`Defendant’s Construction
`Plain and ordinary meaning, no construction
`necessary
`
`Dish argues that “MCM’s construction requires a limitation (‘after registration’) that only
`
`might occur.” Id. at 26 (emphasis removed). MCM respectfully submits that Claim 33 of the ʼ468
`
`Patent requires a limitation, “initial.” MCM’s proposed construction clarifies what is meant by
`
`10
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`DISH, Exh.1028, p.0013
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 14 of 15
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`initial. A reasonable juror might ask, “initial to what?” or “when does ‘initial’ start?” MCM’s
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`construction clarifies that the answer is “initial to whatever a gateway unit does after registration.”
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`Further, MCM believes that “one or more variables associated with an operating mode” is
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`more readily understandable by a jury than “operating parameters.” However, should Dish and/or
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`the Court prefer the claim language “operating parameters,” MCM would not dispute the
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`construction of “operating parameters first used by a gateway unit after registration.”
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`IV. CONCLUSION
`
`Dish continues to support constructions that are not supported by, and are inconsistent with,
`
`the specifications and file histories of the patents-in-suit. In contrast, MCM has provided
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`constructions consistent with the specifications and file histories of the Patents-in-Suit. The Court
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`should therefore adopt MCM’s proposed constructions.
`
`Dated: April 5, 2019
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`Respectfully submitted,
`
`/s/ Jeffrey G. Toler
`Jeffrey G. Toler
`Aakash S. Parekh
`Benjamin R. Johnson (pro hac vice)
`TOLER LAW GROUP, PC
`8500 Bluffstone Cove
`Suite A201
`Austin, TX 78759
`(512) 327-5515
`jtoler@tlgiplaw.com
`aparekh@tlgiplaw.com
`bjohnson@tlgiplaw.com
`
`Attorneys for Plaintiff Multimedia Content
`Management LLC
`
`
`
`11
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`DISH, Exh.1028, p.0014
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`

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`Case 6:18-cv-00207-ADA Document 59 Filed 04/15/19 Page 15 of 15
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`CERTIFICATE OF SERVICE
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`I hereby certify that on April 15, 2019, I electronically filed the foregoing with the Clerk
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`of Court using the CM/ECF system which will send notification of such filing to all counsel of
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`record in the above-reference matter.
`
`
`
`
`
`/s/ Jeffrey G. Toler
`Jeffrey G. Toler
`TOLER LAW GROUP, PC
`8500 Bluffstone Cove
`Suite A201
`Austin, TX 78759
`(512) 327-5515
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`
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`12
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`DISH, Exh.1028, p.0015
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