UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
`
`CISCO SYSTEMS, INC.,
`Petitioner
`
`U.S. Patent No. 7,013,482
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`_____________________
`
`DECLARATION OF DR. HENRY HOUH,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 5 
`I. 
`Qualifications and Professional Experience .................................................... 6 
`II. 
`III.  Level of Ordinary Skill in the Art ................................................................. 12 
`IV.  Relevant Legal Standards .............................................................................. 13 
`V. 
`Background .................................................................................................... 14 
`VI.  Overview of the ’482 Patent .......................................................................... 16 
`VII.  Claim Construction ........................................................................................ 18 
`VIII.  Identification of how the Claims are Unpatentable ....................................... 19 
`A.  Ground 1: Claims 1-4 are obvious under 35 U.S.C. § 103(a)
`over Carter and Maria. ........................................................................ 19 
`1. 
`Summary of Carter ........................................................ 20 
`2. 
`Summary of Maria ......................................................... 23 
`3. 
`Reasons to Combine Carter and Maria .......................... 25 
`4. 
`Claim 1 ........................................................................... 31 
`5. 
`Claim 2 ........................................................................... 54 
`6. 
`Claim 3 ........................................................................... 55 
`7. 
`Claim 4 ........................................................................... 55 
`Ground 2: Claims 11-16, 31-36, 40-41, 61, 64, and 65 are
`obvious under 35 U.S.C. § 103(a) over Carter, Maria, and
`Salim. ................................................................................................... 56 
`1. 
`Summary of Salim ......................................................... 56 
`2. 
`Reasons to Combine Salim with Carter and Maria ....... 58 
`3. 
`Claim 11 ......................................................................... 63 
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`B. 
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`2
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`Claim 12 ......................................................................... 65 
`4. 
`Claim 13 ......................................................................... 67 
`5. 
`Claim 14 ......................................................................... 68 
`6. 
`Claim 15 ......................................................................... 71 
`7. 
`Claim 16 ......................................................................... 71 
`8. 
`Claim 31 ......................................................................... 72 
`9. 
`Claim 32 ......................................................................... 80 
`10. 
`Claim 33 ......................................................................... 80 
`11. 
`Claim 34 ......................................................................... 83 
`12. 
`Claim 35 ......................................................................... 85 
`13. 
`Claim 36 ......................................................................... 86 
`14. 
`Claim 40 ......................................................................... 87 
`15. 
`Claim 41 ......................................................................... 88 
`16. 
`Claim 61 ......................................................................... 89 
`17. 
`Claim 64 ......................................................................... 90 
`18. 
`Claim 65 ......................................................................... 90 
`19. 
`Ground 3: Claims 37-39 are obvious under 35 U.S.C. § 103(a)
`in view of Carter, Maria, Salim, and Loschke. ................................... 91 
`1. 
`Summary of Loschke ..................................................... 91 
`2. 
`Reasons to Combine Loschke with Carter, Maria, and
`Salim .............................................................................. 93 
`Claim 37 ......................................................................... 95 
`Claim 38 ......................................................................... 97 
`Claim 39 ......................................................................... 99 
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`3. 
`4. 
`5. 
`
`C. 
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`3
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`IX.  Conclusion ................................................................................................... 101 
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`Houh Declaration
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`Inter Partes Review of U.S. 7,013,482
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`I, Henry Houh, do hereby declare as follows:
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`I.
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`INTRODUCTION
`1.
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`I am making this declaration at the request of Cisco Systems, Inc. in
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`the matter of the Inter Partes Review of U.S. Patent No. 7,013,482 (“the ’482
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`Patent”) to Krumel.
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`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the specifics of my testimony.
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`3.
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`I have been asked to provide my opinions regarding whether claims 1-
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`4, 11-16, 31-41, 61, and 64-65 (“the Challenged Claims”) of the ’482 Patent are
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`unpatentable as they would have been obvious to a person having ordinary skill in
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`the art (“POSITA”) at the time of the alleged invention, in light of the prior art. It
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`is my opinion that all of the limitations of the challenged claims would have been
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`obvious to a POSITA.
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`4.
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`a.
`
`b.
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`In the preparation of this declaration, I have studied:
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`the ’482 Patent, Ex. 1001;
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`the prosecution history of the ’482 Patent (“’482 File History”), Ex.
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`1002;
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`
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`c.
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`U.S. Patent No. 5,386,470 to Carter et al. (“Carter”), Ex.1005;
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`5
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`d.
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`e.
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`5.
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`U.S. Patent No. 6,092,110 to Maria et al. (“Maria”), Ex.1006; and
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`U.S. Patent No. 6,628,653 to Salim et al. (“Salim”), Ex.1007.
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`In forming the opinions expressed below, I have considered:
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`the documents listed above;
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`the relevant legal standards, including the standard for obviousness,
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`and any additional authoritative documents as cited in the body of this
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`declaration; and
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`my own knowledge and experience based upon my work in the field
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`of networking as described below, as well as the following materials.
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`6.
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`U.S. Patent No. 6,556,574 to Pearce et al. (“Pearce”), Ex.1008;
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`U.S. Patent No. 6,728,885 to Taylor et al. (“Taylor”), Ex.1009;
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`U.S. Patent No. 6,219,706 to Fan et al. (“Fan”), Ex.1013;
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`U.S. Patent No. 5,956,336 to Loschke et al. (“Loschke”), Ex.1015;
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`Interconnections: Bridges and Routers, Radia Perlman, Ex.1018
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`Building Internet Firewalls, Elizabeth Zwicky, Ex.1019.
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`Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`7. My complete qualifications and professional experience are described
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`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`6
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`following is a brief summary of my relevant qualifications and professional
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`
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`experience.
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`8.
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`I received a Ph.D. in Electrical Engineering and Computer Science
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`from the Massachusetts Institute of Technology (“MIT”) in 1998. Beforehand, I
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`received a Master of Science degree in Electrical Engineering and Computer
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`Science in 1991, a Bachelor of Science degree in Electrical Engineering and
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`Computer Science in 1989, and a Bachelor of Science degree in Physics in 1990,
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`all from MIT.
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`9.
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`I am currently self-employed as an independent technical consultant. I
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`am also president of a company that provides supplemental science, technology,
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`engineering, and mathematics (“STEM”) education to children of all ages.
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`10.
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`I first entered telecommunications in 1987 when I worked as a
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`summer intern at AT&T Bell Laboratories as part of a five-year dual degree
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`program at MIT. I continued to work at AT&T Bell Laboratories as part of this
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`MIT program. While at MIT, I was a teaching assistant (“TA”) in the Electrical
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`Engineering and Computer Science Department’s core Computer Architectures
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`course. I first was a TA as a senior for a role typically reserved for graduate
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`students. I later became head TA. The course covered various topics in computer
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`architectures. As a TA, I helped write homework assignments, lab assignments,
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`and exams. I also taught in the recitation sections.
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`11. Later, as part of my doctoral research at MIT from 1991-1998, I was a
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`research assistant in the Telemedia Network Systems (“TNS”) group at the
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`Laboratory for Computer Science. The TNS group built a high-speed gigabit
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`network and created applications that ran over the network. Example applications
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`included ones for remote video capture, processing, and display of video on
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`computer terminals. In addition to working on the design of core network
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`components, designing and building the high-speed links, and designing and
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`writing the device drivers for the interface cards, I also set up the group’s web
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`server.
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`12.
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`I also helped to build the web pages that initiated the above-
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`mentioned video sessions via a web interface. Vice President Al Gore visited our
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`group in 1996 and received a demonstration of—and remotely drove—a radio-
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`controlled toy car with a wireless video camera mounted on it that was built by our
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`group. This toy car device received commands transmitted over a network from a
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`remote computer, and video data from the toy car was transmitted wirelessly then
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`over a computer network back to the user controller. On occasion, we allowed
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`users visiting our web site to drive the toy car from their remote computer while
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`they watched the video on their computer. The video stream was encoded by TNS-
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`designed hardware, streamed over the TNS-designed network, and displayed using
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`TNS-designed software.
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`8
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`13.
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`I defended and submitted my Ph.D. thesis, titled “Designing Networks
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`for Tomorrow’s Traffic,” in January 1998. As part of my thesis research, I
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`analyzed local area and wide area flows to show a more efficient method for
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`routing packets in a network, based on traffic patterns at the time.
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`14. From 1997 to 1999, I was a Senior Scientist and Engineer at NBX
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`Corporation, a start-up that made business telephone systems for streaming
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`packetized audio over data networks instead of using traditional telephone lines.
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`NBX was later acquired by 3Com Corporation and the phone system is still used
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`today by numerous businesses.
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`15. As part of my work at NBX, I designed the core audio reconstruction
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`algorithms for the telephones, as well as the packet transmission algorithms. I also
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`designed and validated the core packet transport protocol used by the phone
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`system. The protocol was used for all signaling in the phone system, including for
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`the setup of conference calls.
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`16. The NBX system also featured a computer interface for initiating
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`phone calls, which could also initiate conference calls. The NBX system also
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`supported the Telephony Application Programming Interface (“TAPI”) that
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`allowed other computer programs to integrate with our system telephony features.
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`We obtained U.S. Patent No. 6,697,963, entitled “Telecommunication method for
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`ensuring on-time delivery of packets containing time-sensitive data,” as part of this
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`work.
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`17. From 1999-2004, I was employed by Empirix or its predecessor
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`company, Teradyne. Empirix was a leader in test tools for telecommunications
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`protocols and systems, providing functional testing tools as well as load testing
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`tools. From 2000-2001, I conceived and built a test platform for testing Voice-
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`over-IP (VoIP). The first application on this new test platform was a cloud
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`emulator for simulating the effects of transmitting VoIP over a busy network.
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`18.
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`In 2006, as part of my role at BBN Technologies, I helped found
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`PodZinger Inc., now known as RAMP Inc. PodZinger utilized BBN’s speech
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`recognition algorithms to search through the spoken words in audio and video
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`segments. While I was Vice President of Operations and Technology, PodZinger
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`followed its initial prototype with a full streaming audio and video search solution.
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`I also created a social networking web site, which BBN sold to a venture-funded
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`startup company. In the process of creating the web site, I designed and specified
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`the authentication and authorization protocols.
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`19.
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`I have been awarded several United States patents, and I have several
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`patent applications pending including the following examples:
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` U.S. Patent No. 7,975,296, “Automated security threat testing of
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`web pages”;
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`10
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` U.S. Patent No. 7,877,736, “Computer language interpretation and
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`optimization for server testing”;
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` U.S. Patent No. 7,801,910, “Method and apparatus for timed tagging
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`of media content”;
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` U.S. Patent 7,590,542, “Method of Generating Test Scripts Using a
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`Voice-Capable Markup Language”;
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` U.S. Patent No. 6,967,963, “Telecommunication method for
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`ensuring on-time delivery of packets containing time-sensitive
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`data”;
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` U.S. Patent Application Publication No. 20070106685, “Method
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`and apparatus for updating speech recognition databases and
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`reindexing audio and video content using the same”;
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` U.S. Patent Application Publication No. 20070106693, “Methods
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`and apparatus for providing virtual media channels based on media
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`search”;
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` U.S. Patent Application Publication No. 20070106760, “Methods
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`and apparatus for dynamic presentation of advertising, factual, and
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`informational content using enhanced metadata in search-driven
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`media applications”;
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` U.S. Patent Application Publication No. 20070112837, “Method
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`and apparatus for timed tagging of media content”;
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` U.S. Patent Application Publication No. 20070118873, “Methods
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`and apparatus for merging media content”; and
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` U.S. Patent Application Publication No. 20090222442, “User-
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`directed navigation of multimedia search results”.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`20.
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`I understand there are multiple factors relevant to determining the
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`level of ordinary skill in the pertinent art, including (1) the levels of education and
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`experience of persons working in the field at the time of the invention; (2) the
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`sophistication of the technology; (3) the types of problems encountered in the field;
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`and (4) the prior art solutions to those problems.
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`21. A person of ordinary skill in the art (“POSITA”) in the field of the
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`’482 Patent, as of its earliest possible filing date of July 7, 2000, would have been
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`someone knowledgeable and familiar with the networking arts that are pertinent to
`
`the ’482 Patent. A POSITA would have been familiar with the field of network
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`protocols and network security, during the early 2000s. That person would have a
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`master’s degree in electrical engineering, or equivalent training, and approximately
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`two years of experience working in the field of data networking, data networking
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`protocols, and network security. Lack of work experience can be remedied by
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`additional education, and vice versa.
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`22. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the priority
`
`date of the ’482 Patent. Unless otherwise stated, when I provide my understanding
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`and analysis below, it is consistent with the level of a POSITA prior to the priority
`
`date of the ’482 Patent.
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`IV. RELEVANT LEGAL STANDARDS
`23.
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`I am not an attorney. In preparing and expressing my opinions and
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`considering the subject matter of the ’482 Patent, I am relying on certain basic
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`legal principles that counsel have explained to me. These principles are discussed
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`below.
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`24.
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`I understand that prior art to the ’482 Patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
`
`invention recited in the ’482 Patent. For purposes of this Declaration, I am
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`applying July 7, 2000 as the earliest possible priority date of the ’482 Patent.
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`25.
`
`I have been informed that a claimed invention is unpatentable under
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`35 U.S.C. § 103 if the differences between the invention and the prior art are such
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`that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person having ordinary skill in the art to which the subject
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`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
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`the scope and content of the prior art, and the differences between the prior art and
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`the claimed subject matter.
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`26.
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`I have been informed by counsel that the Supreme Court has
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`recognized several rationales for combining references or modifying a reference to
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`show obviousness of claimed subject matter. Some of these rationales include the
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`following: (a) combining prior art elements according to known methods to yield
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`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
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`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
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`in the prior art that would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at the claimed
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`invention.
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`V. BACKGROUND
`27. Data is generally transmitted in packets. Data packets may be in
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`variety of forms including “ATM (Asynchronous transfer Mode) cells, frame relay
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`frames, ethernet frames, T1 data units, and IP packets.” Salim, 6:17-19. A data
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`packet includes a header and a payload. The payload includes the data that is being
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`transmitted, and the header includes information about the packet. This
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`information may include source address, destination address, and other metadata
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`for the packet.
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`28. The header may also include protocol information. Most packet data
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`transmission networks use multiple layers of hierarchical protocols (often referred
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`to as within the OSI model). “Starting with the raw data from a top level
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`application, each protocol adds its own header information to that added previously
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`by preceding (higher) protocols.” Salim, 1:17-20. “In the course of transmission
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`through the network, the packet may pass through and be routed, forwarded
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`switched or processed according to information stored in various parts of the
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`packet header, depending on which level of the various levels of protocols, is being
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`used.” Salim, 1:20-25. Computer networks are often described in terms of the
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`Open Systems Interconnection (OSI) model and the Transmission Control
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`Protocol/Internet Protocol (TCP/IP). See Pearce, 2:13-26, 3:38-50; Perlman, 1,
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`201.
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`29. For security purposes, it was common to filter data packets to prevent
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`unauthorized access to the network or to prevent undesirable content from being
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`accessed. See Fan, 1:8-52; Zwicky, 3-5 For example, it was known to filter data
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`packets to prevent eavesdropping. See Carter, 1:48-51. In a further example, “data
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`packet filters are currently available which filter out data packets from certain
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`Internet sites.” Maria, 1:19-21.
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`30. As will be explained in more detail below, the ’482 Patent describes
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`and claims no more than commonly known packet filtering concepts.
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`VI. OVERVIEW OF THE ’482 PATENT
`31. The ’482 Patent generally relates to “Methods and systems for
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`firewall/data protection that filters data packets in real time and without packet
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`buffering.” Ex.1001, abstract. The ’482 Patent describes passing packets between
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`“two PHY interfaces, one for the Internet or other external network connection,
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`and one (or more) for the internal network.” Ex.1001, 5:56-58. The packets pass
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`through a repeater core 16, which “functions as an Ethernet repeater (as defined by
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`the network protocols of the IEEE standard 802.3) and serves to receive packets
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`from external PHY 14, reshape the electrical signals thereof, and transmit the
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`packets to internal PHY 18, which is coupled to internal network 20.” Ex.1001,
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`5:64-6:2. “While the packet is being received, reshaped, and transmitted between
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`PHYs 14 and 18, however, it is simultaneously being evaluated in parallel with
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`filtering rules to determine if it should be allowed to pass as a valid packet.”
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`Ex.1001, 6:2-5.
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`16
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`32. With application of the filtering rules, “by the time that the entire
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`packet reaches repeater core 16… the packet will either be allowed to pass as a
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`valid packet or will be failed and junked as a suspect (or otherwise invalidated)
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`packet.” Ex.1001, 6:38-41. “Junking is defined as changing bits or truncating data,
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`depending on the type of link, in a manner such that the packet is corrupted or
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`otherwise will be detected by the receiving computers as invalid or unacceptable,
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`etc.” Ex.1001, 5:1-4. Fig. 2 is shown below.
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`Ex.1001, Fig. 2
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`33. As I will explain below, the concept of a repeater that corrupts data in
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`packets that do not meet filtering criteria was well known at the time the ’482
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`Patent was filed.
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`VII. CLAIM CONSTRUCTION
`34.
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`It is my understanding that in order to properly evaluate the ’482
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`Patent, the terms of the claims must first be interpreted. It is my understanding that
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`for the purposes of this inter partes review, the claims are to be construed under
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`the so-called Phillips standard, under which claim terms are given their ordinary
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`and customary meaning as would be understood by one of ordinary skill in the art
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`in light of the specification and prosecution history, unless the inventor has set
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`forth a special meaning for a term. Counsel has explained to me that none of the
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`claim terms are believed to require express construction.
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`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`35.
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`I have been asked to provide my opinion as to whether the Challenged
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`Claims of the ’482 Patent would have been obvious in view of the prior art. The
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`discussion below provides a detailed analysis of how the prior art references
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`identified below teach the limitations of the Challenged Claims of the ’482 Patent.
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`36. As part of my analysis, I have considered the scope and content of the
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`prior art and any differences between the alleged invention and the prior art. I
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`describe in detail below the scope and content of the prior art, as well as any
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`differences between the alleged invention and the prior art, on an element-by-
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`element basis for each Challenged Claims of the ’482 Patent.
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`37. As described in detail below, the alleged invention of the Challenged
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`Claims would have been obvious in view of the teachings of the identified prior art
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`references as well as the knowledge of a POSITA.
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`A. Ground 1: Claims 1-4 are obvious under 35 U.S.C. § 103(a) over
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`Inter Partes Review of U.S. 7,013,482
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`Carter and Maria.
`1.
`Summary of Carter
`38. Like the ’482 Patent, Carter describes a “repeater” that has “means for
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`storing access rules for the items of equipment connected to it.” Carter, abstract.
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`Carter’s repeater “reads a portion of each frame, which may be all or part of the
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`destination address segment and/or of the source address segment and/or of the
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`control segment of each incoming data frame, or it could be a frame or protocol
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`identifier incorporated in opening bytes of the data segment.” Id. Carter’s repeater
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`then filters the frames by comparing “the data that it reads with the stored access
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`rules to determine whether the frame is permitted or not.” Id. If a packet is not
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`permitted based on the access rules, then “the repeater modifies the frame which it
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`is in the course of re-transmitting, for example by overwriting it with meaningless
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`digits.” Id.
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`39. Carter provides, in Fig. 2, a “block diagram of those parts of a
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`multiport repeater that are relevant to the understanding of the present invention.”
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`Carter, 3:67-4:2.
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`filtering circuitry
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`input
`MUX
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`output MUX
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`Carter, Fig. 2 (annotated)
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`40. Carter’s device receives frames “on any one of ports 1 to 4 passing via
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`respective port interface units 5.” Carter, 4:23-25. Incoming data from a frame is
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`passed through an input MUX 6, through selection MUX 7, and placed in a first
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`in/first out memory 8. See Carter, 4:23-30. Simultaneously, the packet is passed
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`through filtering circuitry: “[T]he incoming signal is also passed via a shift register
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`13 which extracts the destination address and the source address in parallel form to
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`latches 14 and 15 which are switched by counters 16 enabled by the start of frame
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`Inter Partes Review of U.S. 7,013,482
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`signal from detector 9.” Carter, 4:40-45.
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`41. The source address and the destination address are then “passed to
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`comparators 17 and compared with the access rules previously stored in a database
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`18.” Carter, 4:45-47. “If the comparators indicate that the frame is not in
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`accordance with the rules contained in the database, then a signal is output via a
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`delay 19 (serving to ensure that the source address will never be corrupted) to the
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`multiplexer 7.” Carter, 4:54-58. This causes the multiplexer 7 “to transmit, for the
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`remainder of the length of the frame, a meaningless sequence of digits (such as all
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`1's, all 0's, a cyclically repeated sequence or a pseudo-random sequence) available
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`to it from a sequence generator 20 instead of the incoming signal.” Carter, 4:58-62.
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`In other words, “Data may be modified, when required, by corrupting it, as by
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`overwriting a series of binary digits selected from all 1's, all 0's, cyclically repeated
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`sequences and pseudo-random sequences.” Carter, 3:17-20.
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`42. Whether data has been modified based on the comparison made by
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`comparators 17, or not, it is transmitted through output multiplexer 11 to all ports:
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`“Provided there are then at least 3 bits of data in the memory 8, the multiplexer 11
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`is switched to begin reading out the data stored in the memory, and in the ordinary
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`way will continue to do so until the complete frame has been received into and
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`then read from the memory 8.” Carter, 4:34-39. Accordingly, Carter shows that it
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`was well known to use a repeater to filter frames as they are being received and
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`transmitted, as well as to corrupt the frames when they do not meet filtering
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`criteria.
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`2.
`Summary of Maria
`43. Like Carter and the ’482 Patent, Maria relates to data packet filtering.
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`See Maria, abstract. Maria describes a “dedicated data packet filtering processor”
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`that looks “at the source IP address of each received data packet to determine if the
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`source IP address matches one of the stored source IP addresses.” Maria, 2:34-36.
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`Maria’s packet filter will then “either discard or forward the data packet depending
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`on the processor configuration.” Maria, 2:37-39. Maria’s packet filter is shown
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`below in Fig. 1.
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`Maria, Fig. 1
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`44. Maria states that the packet filter “may be used in conjunction with a
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`local area network and many end users (such as in a commercial or business
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`environment), or a single end user computer (such as in a home environment).
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`Further, the filtering processor may be connected to the Internet.” Maria 2:41-45.
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`As shown in Fig. 1, the packet filtering processor 14 is placed between an external
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`network (such as the Internet on the other side of router 12) and a local network 16
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`or local computer:
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`The placement of packet filter processor 14 in a network is also variable
`depending on where a network designer would desire to control the in-
`flow or out-flow of packets between networks or network devices. In
`this embodiment of the invention, packet filter processor 14 is
`positioned at the only entry and exit point of either network 10 or 16,
`thereby controlling which packets enter either network. It can be
`appreciated, however, that packet filter processor 14 could be placed on
`an individual network device, such as a personal computer, thereby
`controlling the flow of packets only to the personal computer, or in any
`other strategic point within a network.
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`Maria, 3:18-30.
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`45. Maria also teaches that “[p]acket filter processor 14 has a restrictive
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`mode and a permissive mode.” Maria, 6:20-21. “Restrictive mode refers to a
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`condition where a select number of packets are to be passed, and all others
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`blocked.” Maria, 6:21-23. “In restrictive mode, the packet is passed if the source IP
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`address does match an address from list 33, and is dropped otherwise.” Maria,
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`6:28-30. “If processor 14 has been set to restrictive mode, and there is not a match
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`at step 56, then the packet is dropped at step 64.” Maria, 6:37-39. Accordingly,
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`Maria teaches a default-deny rule where if a packet cannot be determined as valid,
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`it is dropped.
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`3.
`Reasons to Combine Carter and Maria
`46. Carter provides evidence that it was well known to corrupt packets as
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`they passed through a filtering device. Maria provides evidence tha