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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS INC.,
`Petitioner
`_______________
`IPR2023-00553
`U.S. Patent No. 9,210,254
`_______________
`DECLARATION OF HENRY HOUH, PH.D.,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW
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`
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`Declaration of Henry Houh, Ph.D.
`Inter Partes Review of U.S. 9,210,254
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`TABLE OF CONTENTS
`INTRODUCTION ..........................................................................................4
`I.
`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ......................7
`II.
`III. LEVEL OF ORDINARY SKILL IN THE ART ..........................................12
`IV. RELEVANT LEGAL STANDARDS ..........................................................13
`V.
`BACKGROUND ..........................................................................................14
`A. Associating Contact Numbers and Addresses ....................................14
`B.
`Communication Application Login Procedures .................................17
`VI. OVERVIEW OF THE ’254 PATENT..........................................................18
`VII. CLAIM CONSTRUCTION..........................................................................21
`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....21
`IX. THE COMBINATION OF BODART, BANISTER, AND
`DHARMARAJAN RENDERS OBVIOUS CLAIMS 1, 2, 6-8, AND 12-14
` ......................................................................................................................22
`A.
`Summary of Bodart ............................................................................22
`B.
`Summary of Banister ..........................................................................25
`C.
`Summary of Dharmarajan ..................................................................26
`D.
`Reasons to Combine Bodart with Banister and Dharmarajan ............28
`1.
`Associating a telephone number with an email address ...........29
`2.
`Associating a telephone number with an IM username ............33
`3.
`Logging into an IM service ......................................................36
`Detailed Analysis of Claims ...............................................................40
`1.
`Claim 1 .....................................................................................40
`2.
`Claim 2 .....................................................................................70
`3.
`Claim 6 .....................................................................................73
`4.
`Claim 7 .....................................................................................75
`5.
`Claim 8 .....................................................................................76
`6.
`Claim 12 ...................................................................................77
`
`E.
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`Declaration of Henry Houh, Ph.D.
`Inter Partes Review of U.S. 9,210,254
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`7.
`Claim 13 ...................................................................................77
`Claim 14 ...................................................................................80
`8.
`X. DE CASTRO RENDERS OBVIOUS CLAIMS 1, 2, 6-8, AND 12-14 .......81
`A.
`Summary of de Castro ........................................................................81
`B.
`Detailed Analysis of Claims ...............................................................85
`1.
`Claim 1 .....................................................................................85
`2.
`Claim 2 ...................................................................................113
`3.
`Claim 6 ...................................................................................117
`4.
`Claim 7 ...................................................................................118
`5.
`Claim 8 ...................................................................................120
`6.
`Claim 12 .................................................................................120
`7.
`Claim 13 .................................................................................121
`8.
`Claim 14 .................................................................................123
`XI. CONCLUSION ..........................................................................................123
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`I.
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`Declaration of Henry Houh, Ph.D.
`Inter Partes Review of U.S. 9,210,254
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`
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`I, Henry Houh, Ph.D., do hereby declare as follows:
`INTRODUCTION
`1.
`I am making this declaration at the request of Cisco Systems, Inc. in the
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`matter of the Inter Partes Review of U.S. Patent No. 9,210,254 (“the ’254 patent”)
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`to Hunt et al.
`
`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 proceeding. My compensation is not
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`contingent on the outcome of this matter or the specifics of my testimony.
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`3.
`
`I have been asked to provide my opinions regarding whether the
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`subject matter of claims 1, 2, 6-8, and 12-14 (“the Challenged Claims”) of the ’254
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`patent would have been obvious to a person having ordinary skill in the art
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`(“POSITA”) at the time of the alleged invention, in light of the prior art. It is my
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`opinion that the Challenged Claims would have been obvious to a POSITA.
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`4.
`
`In the preparation of this declaration, I have studied:
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`the ’254 patent, Ex.1001.
`
`the prosecution history of the ’254 patent (“’254 File History”),
`
`a.
`
`b.
`
`Ex. 1002.
`
`c.
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`U.S. Pat. Pub. No. 2007/0043687 to Bodart et al. (“Bodart”),
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`Ex.1005.
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`Declaration of Henry Houh, Ph.D.
`Inter Partes Review of U.S. 9,210,254
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`U.S. Pat. No. 6,621,892 to Banister et al. (“Banister”), Ex.1006.
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`U.S. Pat. No. 7,089,585 to Dharmarajan (“Dharmarajan”),
`
`
`
`
`d.
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`e.
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`Ex.1007.
`
`f.
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`U.S. Pat. Pub. No. 2012/0016932 to de Castro et al. (“de
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`Castro”), Ex.1008.
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`5.
`
`In forming the opinions expressed below, I have considered: the
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`documents listed above; the relevant legal standards, including the standard for
`
`obviousness; and my own knowledge and experience based upon my work in the
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`field of network communications and security as described below, as well as
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`portions of the following additional materials:
`
`a.
`
`Ben Langfeld, Jose de Castro, “XEP-0327: Rayo,” XMPP
`
`Standards Foundation (archived August 18, 2013) (“the Rayo Specification”),
`
`Ex.1009.
`
`b.
`
`c.
`
`U.S. Pat. No. 6,298,128 to Ramey et al. (“Ramey”), Ex.1010.
`
`John Letzing “Facebook Raises Hackles on Email,” Wall Street
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`Journal Online, June 26, 2012 (archived June 30, 2012), (“Letzing”) Ex.1011.
`
`d.
`
`Shelley O’Hara, “Easy Microsoft® Office Outlook® 2003,”
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`(Que Publishing, September 2003) (“O’Hara”), Ex.1012.
`
`e.
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`U.S. Pat. No. 8,130,751 to Berkley et al. (“Berkley”), Ex.1013.
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`Declaration of Henry Houh, Ph.D.
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`f.
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`U.S. Pat. No. 7,929,519 to Goldman et al. (“Goldman”),
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`Ex.1014.
`
`g.
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`U.S. Pat. Pub. No. 2007/0143231 to Pegaz-Paquet et al. (“Pegaz-
`
`Paquet”), Ex.1015.
`
`h.
`
`i.
`
`j.
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`U.S. Pat. No. 1,276,825 to Swope (“Swope”), Ex.1016.
`
`U.S. Pat. No. 2,308,778 to Prince (“Prince”), Ex.1017.
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`U.S. Patent No. 8,090,787 to Polis et al. (“Polis”), Ex.1022.
`
`6.
`
`I have also considered the following documents as demonstrating the
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`prior art status of the non-patent literature documents listed above, including the
`
`Rayo Specification, Letzing, and O’Hara:
`
`a.
`
`Affidavit of Authenticity of “XEP-0327: Rayo,” confirming the
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`prior art status of the Rayo Specification, Ex.1018.
`
`b.
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`Amazon.com listing for “Easy Microsoft® Office Outlook®
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`2003” (archived February 1, 2008) (“Amazon”), confirming the
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`prior art status of O’Hara, Ex.1019.
`
`c.
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`Affidavit of Authenticity of for Letzing and Amazon, confirming
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`the prior art status of Letzing and O’Hara, Ex.1020.
`
`d.
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`Declaration of Jose de Castro under 37 C.F.R. § 1.68, confirming
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`the prior art status of the Rayo Specification, Ex.1021.
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`Declaration of Henry Houh, Ph.D.
`Inter Partes Review of U.S. 9,210,254
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`Unless otherwise noted, all emphasis in any quoted material has been
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`7.
`
`added. Claim terms are italicized.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`8. My complete qualifications and professional experience are described
`
`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
`
`9.
`
`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
`
`received a Master of Science degree in Electrical Engineering and Computer
`
`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,
`
`all from MIT.
`
`10.
`
`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.
`
`11.
`
`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
`
`students. I later became head TA. The course covered various topics in computer
`
`architectures. As a TA, I helped write homework assignments, lab assignments,
`
`and exams. I also taught in the recitation sections.
`
`12. 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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`13.
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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.
`
`14.
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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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`15. 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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`16. 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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`Inter Partes Review of U.S. 9,210,254
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`17. 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
`
`ensuring on-time delivery of packets containing time-sensitive data,” as part of this
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`work.
`
`18. 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.
`
`19.
`
`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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`20.
`
`I have been awarded several United States patents, and I have several
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`patent applications pending including the following examples:
`
`•
`
`U.S. Patent No. 7,975,296, “Automated security threat testing of
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`web pages”;
`
`•
`
`U.S. Patent No. 7,877,736, “Computer language interpretation and
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`optimization for server testing”;
`
`•
`
`U.S. Patent No. 7,801,910, “Method and apparatus for timed
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`tagging of media content”;
`
`•
`
`U.S. Patent 7,590,542, “Method of Generating Test Scripts Using
`
`a Voice-Capable Markup Language”;
`
`•
`
`U.S. Patent No. 6,967,963, “Telecommunication method for
`
`ensuring on-time delivery of packets containing time-sensitive data”;
`
`•
`
`U.S. Patent Application Publication No. 20070106685, “Method
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`and apparatus for updating speech recognition databases and reindexing
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`audio and video content using the same”;
`
`•
`
`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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`•
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`U.S. Patent Application Publication No. 20070106760, “Methods
`
`and apparatus for dynamic presentation of advertising, factual, and
`
`informational content using enhanced metadata in search-driven media
`
`applications”;
`
`•
`
`U.S. Patent Application Publication No. 20070112837, “Method
`
`and apparatus for timed tagging of media content”;
`
`•
`
`U.S. Patent Application Publication No. 20070118873, “Methods
`
`and apparatus for merging media content”; and
`
`•
`
`U.S. Patent Application Publication No. 20090222442, “User-
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`directed navigation of multimedia search results”.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`21.
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
`
`experience of persons working in the field at the time of the invention; (2) the
`
`sophistication of the technology; (3) the types of problems encountered in the field;
`
`and (4) the prior art solutions to those problems.
`
`22. A Person of Ordinary Skill in The Art (“POSITA”) in October 2013
`
`would have had a working knowledge of the telecommunications and networking
`
`art that is pertinent to the ’254 patent. A POSITA would have had a bachelor’s
`
`degree in electrical engineering, computer science, computer engineering, or an
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`equivalent, and two years of relevant experience in telecommunications and
`
`networking. Lack of professional experience can be remedied by additional
`
`education, and vice versa.
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`23. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my own experience
`
`and what a POSITA would have understood or known generally (and specifically
`
`related to the references I consulted herein), reflect the knowledge that existed in
`
`the relevant field as of the priority date of the ’254 patent.
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`IV. RELEVANT LEGAL STANDARDS
`24.
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’254 patent, I am relying on certain basic
`
`legal principles that Cisco’s counsel has explained to me.
`
`25.
`
`I understand that prior art to the ’254 patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the ’254
`
`patent. For purposes of this Declaration, I am applying October 9, 2013, as the
`
`priority date of the ’254 patent.
`
`26.
`
`I have been informed by Cisco’s counsel that a claimed invention is
`
`unpatentable under 35 U.S.C. § 103 if the differences between the claimed
`
`invention and the prior art are such that the subject matter as a whole would have
`
`been obvious at the time the invention was made to a POSITA. I have also been
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`Declaration of Henry Houh, Ph.D.
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`informed by Cisco’s counsel that the obviousness analysis considers factual
`
`inquiries, including the level of ordinary skill in the art, the scope and content of
`
`the prior art, and the differences between the prior art and the claimed subject
`
`matter.
`
`27.
`
`I have been further informed by Cisco’s counsel that there are several
`
`recognized rationales for combining references or modifying a reference to show
`
`obviousness. These rationales include: (a) combining prior art elements according
`
`to known methods to yield predictable results; (b) simple substitution of one
`
`known element for another to obtain predictable results; (c) use of a known
`
`technique to improve a similar device (method, or product) in the same way; (d)
`
`applying a known technique to a known device (method, or product) ready for
`
`improvement to yield predictable results; (e) choosing from a finite number of
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`identified, predictable solutions, with a reasonable expectation of success; and (f)
`
`some teaching, suggestion, or motivation in the prior art that would have led a
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`POSITA to modify the prior art or to combine prior art teachings to arrive at the
`
`claimed invention.
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`V. BACKGROUND
`A. Associating Contact Numbers and Addresses
`28. Storing telephone numbers and other contact addresses, such as email
`
`addresses and instant messaging (IM) usernames, is a well-known concept in
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`telecommunications applications. Communications applications are typically
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`installed on a user’s computer to provide the user access to one or more
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`communications services, such as email or IM. One example of a communications
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`application is an email application which may include an email client for accessing
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`an email server. A user’s email address, credentials, the server and protocol to be
`
`used are configured within the application to customize the access to email for a
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`particular user.
`
`29. Communications applications often provide a database or digital
`
`rolodex of contact information that can be managed and modified by the user. See,
`
`e.g., O’Hara, pp. 112-118 (describing how contact information is stored using
`
`Microsoft Outlook 2003). This allows the user of the application to input and store
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`the usernames, addresses, telephone numbers, website URLs, physical addresses,
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`and any other addressing mechanisms for each individual in their personal or
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`professional network. The addresses are typically stored as a database and in such
`
`a way that each address or contact number is associated with its corresponding
`
`individual. In the database, the user may store their own contact numbers and
`
`addresses as well as those of their associates.
`
`30. Databases that are used to store contact information are commonly
`
`structured as relational databases. A relational database is typically embodied in a
`
`set of tables where each row in each table is associated with a record, such as for
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`an individual, designated by their name or some other unique identifier. A
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`computer language such as Structured Query Language (SQL) may be used for
`
`accessing a relational database. However, the communications software, such as an
`
`email client, provides a more user-friendly visual interface for the user to search or
`
`browse the stored contact information in the database. The columns or entries in a
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`row in a table may include the contact numbers and addresses, including email
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`addresses, IM addresses, or physical addresses associated with a particular user or
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`individual. A contact database would typically indicate a communication
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`application or platform for each type of address in the database. For example, the
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`each entry in an IM account table would indicate IM addresses and the associated
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`IM platform, such as Microsoft Network (MSN) Messenger, since users may have
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`multiple IM accounts on different platforms and different usernames on each. The
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`structure of the relational database facilitates simple associations of its entries to an
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`individual, such as their telephone number and associated email address. See, e.g.,
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`Berkley, 6:55 – 7:3 (describing active user registry (AUR) databases); Goldman,
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`11:8-17; (AUR database stores telephone numbers, fax numbers, mobile telephone
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`numbers, e-mail addresses, etc.); Pegaz-Paquet, [0116] (a reverse address match
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`database for locating an address associated with an originating telephone number).
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`Declaration of Henry Houh, Ph.D.
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`B. Communication Application Login Procedures
`31. Access to communications services such as email or IM typically
`
`involves gaining authenticated or secure access to a remote server over the internet.
`
`Software installed on the user’s computer typically provides a user-friendly
`
`interface to login to the remote server by providing security credentials, such as a
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`username and password. In some cases, such as with email applications, the user
`
`also provides server settings or configurations, such as the server protocol, and the
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`name or address of the server providing the service. See O’Hara, pp. 104-105;
`
`Polis, 5:27-44. For email service, the server protocol may be post office protocol
`
`(POP), such as POP3, internet message access protocol (IMAP), or Microsoft
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`Exchange, for example. See O’Hara, pp. 104-105; Polis, 5:27-44. For IM, the
`
`server protocol may be Extensible Messaging and Presence Protocol (XMPP). The
`
`user’s computer is commonly referred to as the client computer, and the software
`
`that accesses the remote server is called a software client. If the security credentials
`
`are accepted by the remote server, the server may provide an acknowledgement to
`
`the client computer to allow the client computer to access the user’s messages and
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`data stored on the server.
`
`32. The acknowledgement may be provided with a digital token, or by
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`establishing an authenticated session. See, e.g., Dharmarajan, 5:46-54. A security
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`token is an encrypted file that has a secret key. An authenticated session also
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`involves the server providing a file to the client computer. The session file
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`specifies a time period or timing parameters for the authenticated access.
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`33. All of the features and functionality described in this section were
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`well known in the early 2010s, and a POSITA would have been familiar with
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`them.
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`VI. OVERVIEW OF THE ’254 PATENT
`34. The ’254 patent “relates generally to integrating communications
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`services, and in particular to managing services and applications using telephone
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`numbers as common subscriber identifiers.” ’254 patent, 1:15-19. The ’254 patent
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`describes provisioning telecommunications services from service providers with
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`different ecosystems using a unified software platform. ’254 patent, Abstract, 3:55-
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`58, 11:37-42. The ’254 patent explains that a variety of different applications may
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`be added on request:
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`[C]lient 110 may request to add services and applications to the existing
`telephone service provided by provider 120. Any of various service and
`applications may be requested, including video conferencing, text
`messaging, interactive texting, hosted private branch exchange (PBX)
`seats, voice mail systems, and other services and applications.
`’254 patent, 3:53-58.
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`35. The ’254 patent explains that for “large numbers of customers … the
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`telephone number remains the universal identifier (ID) for communicating with the
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`outside world.” ’254 patent, 1:20-26. “However, many services and applications
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`are supplied by third-party providers in different ecosystems. These third-party
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`ecosystems often use different types of IDs and have different rules and policies
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`for managing and activating their services and applications.” ’254 patent, 1:29-33.
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`The ’254 patent offers allegedly “new techniques for integrating advanced services
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`and applications with legacy telephone service.” ’254 patent, 1:34-36.
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`36. To integrate third-party applications with telephone service, the ’254
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`patent proposes “using the telephone number as the common subscriber ID.” ’254
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`patent, 1:40-42. The ’254 patent further explains that “the telephone number may
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`be used as the central, unifying ID to associate services and applications that are
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`utilized by the corresponding user.” ’254 patent, 1:46-48. When a customer adds a
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`service, the customer’s “telephone number may be translated to a second ID that is
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`utilized as a login ID or user name within the ecosystem of the second [service]
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`provider.” ’254 patent, 8:47-49. This allegedly provides “a unified services enabler
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`platform” that “may allow for the association of internet protocol (IP) enabled
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`services with telephone numbers tied to legacy telephone services.” ’254 patent,
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`1:43-46. The customer’s telephone number is “associated with the relevant
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`interworking data which links all of the IDs and third-party applications and
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`services associated with the telephone number.” ’254 patent, 12:53-58.
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`Inter Partes Review of U.S. 9,210,254
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`37. Fig.1 below illustrates the unified services enabler platform 140
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`connected by internet 130 to client users 110, telephone service provider 120, and
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`application service providers 150, 160. ’254 patent, Fig.1, 3:35-37, 4:14-28.
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`38. As explained in more detail below, these concepts were well known as
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`’254 patent, Fig.1.
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`of the priority date of the ’254 patent. In particular, it was well-known in the prior
`
`art to integrate and provision services from different ecosystems for a single user.
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`It was also well-known in the prior art to associate a user’s telephone number with
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`a user ID corresponding to a different service provider to provision a service. See,
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`e.g., Banister, 2:1-5; de Castro, [0139]-[0141].
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`VII. CLAIM CONSTRUCTION
`39.
`It is my understanding that in order to properly evaluate the ’254
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`patent, the terms of the claims must first be interpreted. It is my understanding that
`
`for the purposes of this inter partes review, the claims are to be construed under
`
`the so-called Phillips standard, under which claim terms are given their ordinary
`
`and customary meaning as would have been understood by a POSITA in light of
`
`the specification and prosecution history, unless the inventor has set forth a special
`
`meaning for a term. I have also been informed that claim terms only need to be
`
`construed to the extent necessary to resolve the obviousness inquiry. I have
`
`reviewed the entirety of the ’254 patent, as well as its prosecution history. It is my
`
`understanding that no terms in the Challenged Claims require specific construction.
`
`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`40. The discussion in this Declaration provides a detailed analysis of how
`
`the asserted prior art references teach each limitation of the Challenged Claims.
`
`41. As part of my analysis, I have considered, and discuss in detail, the
`
`scope and content of the prior art and any differences between the alleged invention
`
`and the prior art.
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`Inter Partes Review of U.S. 9,210,254
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`42.
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`It is my opinion that the alleged invention recited in the Challenged
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`Claims would have been obvious in view of the teachings of the asserted prior art
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`and the knowledge of a POSITA.
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`IX. THE COMBINATION OF BODART, BANISTER, AND
`DHARMARAJAN RENDERS OBVIOUS CLAIMS THE
`CHALLENGED CLAIMS
`Summary of Bodart
`A.
`43. Bodart relates to “personal productivity systems” that provide for “the
`
`integration of personal and public information to enable more productive
`
`individuals by automating routine tasks.” Bodart, [0001]. Like the ’254 patent,
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`Bodart’s systems provide users access to internet-based communications services
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`such as voicemail, text messaging, and voice attendants. See ’254 patent, 4:14-15,
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`24-28, 11:37-40; Bodart, Abstract, [0022], [0025], [0026], [0044], [0064], [0072].
`
`Bodart teaches a virtual assistant having “access to a user’s contacts, calendar, and
`
`location,” as well as “information about the weather, traffic, and mass transit....”
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`Bodart, Abstract. Access to this information “augment [the virtual assistant’s]
`
`ability to make decisions on the user’s behalf.” Bodart, [0020]. The virtual
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`assistant includes “one or more user interfaces 140 which allow a user to interact
`
`with virtual assistant” including “cell phone 145” and “conventional telephone
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`146.” Bodart, [0030]. A schematic representation of Bodart’s system is illustrated
`
`in Fig.1, reproduced in annotated form below:
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`Virtual
`assistant 101
`accessible by
`telephones
`145, 146
`
`Bodart, Fig. 1 (annotated)
`
` Bodart explains that “a remote user can call into his or her virtual
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`
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`44.
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`assistant and provide voice commands.” Bodart, [0026]. Further, “[v]irtual
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`assistant 101 may include the ability to receive a