EXHIBIT C-1
`Defendant’s Preliminary Invalidity Contentions
`Orckit Corporation v. Cisco Systems, Inc., 2:22-cv-00276-JRG-RSP
`____________________________________________________________________________________________________________
`
`Chart for U.S. Patent 7,545,740 (“the ’740 Patent”)
`U.S. Patent Publication No. 2006/0221974 to Hilla et al. (“Hilla”)
`
`As shown in the chart below, all Asserted Claims of the ’740 Patent are invalid under (1) 35 U.S.C. § 102 (a), (e), and (g) because Hilla
`meets each element of those claims, and/or (2) 35 U.S.C. § 103 because Hilla renders those claims obvious either alone, or in combination
`with the knowledge of a person having ordinary skill in the art, and in further combination with the references specifically identified
`below and in the following claim chart and/or one or more references identified in Defendant’s Preliminary Invalidity Contentions. The
`following quotations and diagrams come from Hilla titled “Method And Apparatus For Dynamic Load Balancing Over A Network Link
`Bundle”, which was filed on April 2, 2005, and published on October 5, 2006.
`
`Motivations to combine the disclosures in Hilla with disclosures in other publications known in the art, as explained in this chart,
`include at least the similarity in subject matter between the references to the extent they concern methods of data communication
`systems, and specifically to methods and systems for link aggregation in a data communication network. Insofar as the references cite
`other patents or publications, or suggest additional changes, one of ordinary skill in the art would look beyond a single reference to
`other references in the field.
`
`These invalidity contentions are based on Defendant’s present understanding of the asserted claims, and Orckit’s apparent construction
`of the claims in its November 3, 2022 Disclosure of Asserted Claims and Infringement Contentions Pursuant to P.R. 3-1, and Orckit’s
`January 19, 2023 First Amended Disclosure of Asserted Claims and Infringement Contentions Pursuant to P.R. 3-1 (Orckit’s
`“Infringement Disclosures”), which is deficient at least insofar as it fails to cite any documents or identify accused structures, acts, or
`materials in the Accused Products with particularity. Defendant does not agree with Orckit’s application of the claims, or that the claims
`satisfy the requirements of 35 U.S.C. § 112. Defendant’s contentions herein are not, and should in no way be seen as, admissions or
`adoptions as to any particular claim scope or construction, or as any admission that any particular element is met by any accused product
`in any particular way. Defendant objects to any attempt to imply claim construction from this chart. Defendant’s prior art invalidity
`contentions are made in a variety of alternatives and do not represent Defendant’s agreement or view as to the meaning, definiteness,
`written description support for, or enablement of any claim contained therein.
`
`1
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 1 of 1736
`
`

`

`The following contentions are subject to revision and amendment pursuant to Federal Rule of Civil Procedure 26(e), the Local Rules,
`and the Orders of record in this matter subject to further investigation and discovery regarding the prior art and the Court’s construction
`of the claims at issue.
`
`
`ʼ740 Patent Claim 1
`No.
`1[preamble] A method for
`communication,
`comprising:
`
`Hilla
`Hilla discloses a method for communication.
`
`For example, Hilla discloses communication techniques for distributing data packets between
`nodes over a network link bundle.
`
`Hilla at Abstract (“Techniques for distributing data packets over a network link bundle include
`storing an output data packet in a data flow queue based on a flow identification associated
`with the output data packet. The flow identification indicates a set of one or more data packets,
`including the output data packet, which are to be sent in the same sequence as received. State
`data is also received. The state data indicates a physical status of a first port of multiple active
`egress ports that are connected to a corresponding bundle of communication links with one
`particular network device. A particular data flow queue is determined based at least in part on
`the state data. A next data packet is directed from the particular data flow queue to a second
`port of the active egress ports. These techniques allow a more efficient use of a network link
`bundle.”)
`
`Hilla at [0006] (“Communications between nodes are typically effected by exchanging discrete
`packets of data. Each packet typically comprises 1] header information associated with a
`particular protocol, and 2] payload information that follows the header information and
`contains information to be processed, often independently of that particular protocol. In some
`protocols, the packet includes 3] trailer information following the payload and indicating the
`end of the payload information. The header includes information such as the source of the
`packet, its destination, the length of the payload, and other properties used by the protocol.
`Often, the data in the payload for the particular protocol includes a header and payload for a
`different protocol associated with a different, higher layer of the OSI Reference Model. The
`higher layer protocol is said to be encapsulated in the lower layer protocol. The headers
`included in a packet traversing multiple heterogeneous networks, such as the Internet,
`typi-cally include a physical (layer 1) header, a data-link (layer 2) header, an internetwork
`
`2
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 2 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`(layer 3) header and a transport (layer 4) header, as defined by the Open Systems
`Intercon-nection (OSI) Reference Model.”)
`
`Hilla at [0033] (“A method and apparatus are described for dynamic balancing of data packet
`traffic loads over a link bundle in a network. In the following description, for the purposes of
`explanation, numerous specific details are set forth in order to provide a thorough
`understanding of the present inven-tion. It will be apparent, however, to one skilled in the art
`that the present invention may be practiced without these specific details. In other instances,
`well-known structures and devices are shown in block diagram form in order to avoid
`unnecessarily obscuring the present invention.”)
`
`Hilla at [0034] (“The invention is described in the following sections in the context of an
`Ethernet 802.3ad link bundle between two routers in the core or backbone of an enterprise
`network, but the invention is not limited to this context. In other embodiments, the link bundle
`is at a network edge, for example connecting an end node performing as a host for a high-
`throughput network server process of a client-server application. In other embodiments,
`different communication links are bundled between two network nodes, such as Packet over
`SONET (POS), and High-level Data Link Control (HDLC) links, among others.”)
`
`Hilla at [0036] (“FIG. 1 illustrates a link bundle 130 that includes five communication links
`between intermediate network node 110c and network node 110b. Network node 110b may be
`an intermediate network node or an end node that is connected both to intermediate network
`node 11 Oc and subnetwork 102a. For purposes of illustration, intermediate network node 110c
`is connected by a bundle 130 of five communication links to network node 110b and thereby
`to subnetwork 102a and end node 11 Oa. Similarly, intermediate network node 110c is
`connected by three unbundled com-munication links to network nodes 110d, ll0e, 110/,
`respec-tively, and thence to sub-network 102b and end node 110g. In other embodiments an
`intermediate network node 11 Oc may be connected to more or fewer network nodes with
`more or fewer links in each of one or more link bundles as part of a network with the same or
`more end nodes.”)
`
`
`3
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 3 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
` Hilla at [0065] (“FIG. 4A is a flow diagram that illustrates a method 400 for dynamically
`balancing data packet traffic load on a link bundle, according to an embodiment. Although
`steps are shown in FIG. 4A and subsequent flow diagrams 4B and 5 in a particular order for
`purposes of illustration, in other embodiments one or more steps are performed in a different
`order or overlapping in time or are omitted, or changed in some combination of ways. For
`example, in a preferred embodiment shown in FIG. 4B, step 490 to advance age counters is
`performed in a separate aging process 244 on DLB block 240, and thus overlaps in time any
`of the other steps depicted in FIG. 4A.”)
`
`Hilla at Figure 1
`
`4
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 4 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`
`
`
`5
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 5 of 1736
`
`

`

`No.
`1[a]
`
`ʼ740 Patent Claim 1
`coupling a network
`node to one or more
`interface modules
`using a first group of
`first physical links
`arranged in parallel,
`
`Hilla
`Hilla discloses coupling a network node to one or more interface modules using a first group
`of first physical links arranged in parallel.
`
`For example, Hilla discloses connecting network nodes to line cards using communication
`links such as ports arranged in parallel.
`
`Hilla at [0004] (“Networks of general purpose computer systems connected by external
`communication links are well known and widely used in commerce. The networks often
`include one or more network devices that facilitate the passage of information between the
`computer systems. A network node is a network device or computer system connected by the
`communication links.”)
`
`Hilla at [0005] (“Information is exchanged between network nodes according to one or more
`of many well known, new or still developing protocols. In this context, a protocol consists of
`a set of rules defining how the nodes interact with each other based on information sent over
`the communication links. The protocols are effective at different layers of operation within
`each node, from generating and receiving physical signals of various types, to selecting a link
`for transferring those signals, to the format of information indicated by those signals, to
`identifying which software application executing on a computer system sends or receives the
`information. The conceptually different layers of protocols for exchanging information over a
`network are described in the Open Systems Interconnection (OSI) Reference Model. The OSI
`Reference Model is generally described in more detail in Section 1.1 of the reference book
`entitled Interconnections Second Edition, by Radia Perlman, published September 1999,
`which is hereby incorporated by reference as though fully set forth herein.”)
`
`Hilla at [0008] (“Routers and switches are network devices that determine which
`communication link or links to employ to support the progress of packets through the network.
`For example, Ethernet switches forward packets according to the Ethernet protocol. Some
`current routers implement sophis-ticated algorithms that provide high performance forwarding
`of packets based on combining layer 2 and layer 3 header information, or some other
`combination. For example, instead of making forwarding decisions separately on each packet
`in a stream of related packets ( called a "packet flow" or simply a "flow"), such as a stream
`
`6
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 6 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`directed from the same source node to the same destination node, these routers identify the
`packet flow from a unique signature derived from the layer 2 or layer 3 header information
`and forward each member of the flow according to the same decision made for the first packet
`in the flow.”)
`
`Hilla at [0012] (“A load-balancing process is used on the sending network node of the pair
`connected by a bundle of commu-nication links for the purpose of determining which
`com-munication link to use for sending one or more data packets to the receiving network node
`of the pair. Current balancing algorithms use a fixed mapping to associate data packets with a
`specific port in a set of ports connected to the communication links in the bundle. Typically,
`information in a header portion of a data packet is used to derive a value that is associated with
`one port of the set. The algorithm is designed to generate a value in a range of values that are
`associated with the full set of ports. Thus data packets directed to the receiving node are
`distributed over all com-munication links in the bundle by the load balancing pro-cess. Many
`load-balancing processes are designed so that all data packets in the same data flow are sent
`through the same port.”)
`
`Hilla at [0035] (“FIG. 1 is a block diagram that illustrates a network with a link bundle,
`according to an embodiment. A computer network is a geographically distributed collection of
`inter-connected sub-networks (e.g, sub-networks 102a, 102b, collectively referenced
`hereinafter as sub-networks 102) for transporting data between network nodes (e.g., network
`nodes 110a, 110b, 110c, 110d, ll0e, 110/, 110g, collectively referenced hereinafter as network
`nodes 110). A local area network (LAN) is an example of such a sub-network 102. The
`network's topology is defined by an arrangement of end nodes that communicate with one
`another, typically through one or more intermediate network nodes such as a router or switch,
`which facilitates routing data between end nodes. As used herein, an end node is a node that is
`configured to originate or terminate communications over the network. In contrast, an
`intermediate network node facilitates the pas-sage of data between end nodes. In FIG. 1, the
`network nodes 110 include both end nodes (e.g., nodes 110a, 110g) and intermediate nodes
`(e.g., network node 110c). Each sub-network 102 includes zero or more intermediate net-work
`nodes.”)
`
`
`7
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 7 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`Hilla at [0036] (“FIG. 1 illustrates a link bundle 130 that includes five communication links
`between intermediate network node 110c and network node 110b. Network node 110b may be
`an intermediate network node or an end node that is connected both to intermediate network
`node 11 Oc and subnetwork 102a. For purposes of illustration, intermediate network node 110c
`is connected by a bundle 130 of five communication links to network node 110b and thereby
`to subnetwork 102a and end node 11 Oa. Similarly, intermediate network node 110c is
`connected by three unbundled com-munication links to network nodes 110d, ll0e, 110/,
`respec-tively, and thence to sub-network 102b and end node 110g. In other embodiments an
`intermediate network node 11 Oc may be connected to more or fewer network nodes with
`more or fewer links in each of one or more link bundles as part of a network with the same or
`more end nodes.”)
`
`Hilla at [0038] (“FIG. 2 is a block diagram that illustrates a link-bundle switching system 200
`in a router, which can be used as intermediate network node 11 Oc, according to an
`embodi-ment. The switching system 200 includes a switching system component 202
`connected to communication links, includ-ing link bundle 130. The switching system
`component 202 includes multiple ingress line cards, including cards 210a, 210b, 210c, for
`receiving inbound data packets, switching fabric component 220, and multiple egress line
`cards for sending outbound data packets, including egress line card 230 for link bundle 130.”)
`
`Hilla at [0039] (“An ingress line card (e.g., 210a) receives a data packet, inspects the
`appropriate header fields to make a forwarding decision, and forwards the packet toward the
`egress line card via the switching fabric component 220. The switch fabric component 220
`forwards the packet to the appropriate egress line card 230. Multiple ingress line cards can
`forward traffic toward a single egress line card 230. In this example, the link bundle 130 is
`capable of transmitting more packets simultaneously because of the increased band-width
`achieved by bundling. Some ingress line cards ( e.g., 210c) are connected to a link bundle with
`multiple commu-nication links. All communication links in the link bundle are considered a
`single ingress logical link. In the illustrated embodiment, the five communication links
`connected to ingress line card 210c are connected to network node 110b. The ingress line card
`210c handles incoming traffic on the link bundle 130, while the egress line card 230 handles
`the outbound traffic on the link bundle 130.”)
`
`8
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 8 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`
`
`Hilla at [0040] (“The ingress line cards 210 determine an outbound physical or logical link to
`use to forward the data packet, for example using data in a routing table stored on the router,
`and sends information to the egress line card associated with the outbound physical or logical
`link. All communication links in the link bundle 130 are considered a single logical link.
`Information about data packets to be output on the link bundle 130 is sent to the egress line
`card 230.”)
`
`Hilla at [0041] (“The egress line card 230 includes a switching application specific integrated
`circuit (ASIC) 232, a traffic manager block 234, a bank 236 of physical ports, at least some of
`which are connected to the communication links in the link bundle. In the illustrated
`embodiment, a dynamic load balancing (DLB) block 240 is included in the traffic manager
`234. In some embodiments, the switching ASIC 232, traffic manager 234 and ports bank 236
`are standard components of conventional egress cards for link bundles, and the DLB block 240
`is external to the traffic manager 234.”)
`
`Hilla at [0054] (“In some embodiments, the flow control status table 344 is in the same memory
`block as the port buffers 340. In some embodiments, the flow control status table 344 is in a
`different memory block. For example, in some embodi-ments, the port buffers 340 are in a
`main memory for the router and the flow control status table 344 is on egress line card 230,
`such as on ports bank 236 or in DLB block 240. In an illustrated embodiment, the port buffers
`340 are in the ports bank memory on the egress line card 230. The contents of the flow control
`status bits are generated by the ports bank memory fill levels and fed directly to a register or
`small memory for the flow control status records 342 in the DLB 240.”)
`
`Hilla at Figure 2 (annotations added)
`
`9
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 9 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`
`
`
`10
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 10 of 1736
`
`

`

`No.
` 1[b]
`
`ʼ740 Patent Claim 1
`at least one of said first
`physical links being a
`bi-directional link
`operative to
`communicate in both
`an upstream direction
`and a downstream
`direction
`
`Hilla
`Hilla discloses at least one of said first physical links being a bi-directional link operative to
`communicate in both an upstream direction and a downstream direction.
`
`For example, Hilla discloses sending inbound and outbound packets over communications link
`such as ports to communicate in both an upstream direction and a downstream direction.
`
`Hilla at [0035] (“FIG. 1 is a block diagram that illustrates a network with a link bundle,
`according to an embodiment. A computer network is a geographically distributed collection of
`inter-connected sub-networks (e.g, sub-networks 102a, 102b, collectively referenced
`hereinafter as sub-networks 102) for transporting data between network nodes (e.g., network
`nodes 110a, 110b, 110c, 110d, ll0e, 110/, 110g, collectively referenced hereinafter as network
`nodes 110). A local area network (LAN) is an example of such a sub-network 102. The
`network's topology is defined by an arrangement of end nodes that communicate with one
`another, typically through one or more intermediate network nodes such as a router or switch,
`which facilitates routing data between end nodes. As used herein, an end node is a node that is
`configured to originate or terminate communications over the network. In contrast, an
`intermediate network node facilitates the pas-sage of data between end nodes. In FIG. 1, the
`network nodes 110 include both end nodes (e.g., nodes 110a, 110g) and intermediate nodes
`(e.g., network node 110c). Each sub-network 102 includes zero or more intermediate net-work
`nodes.”)
`
`Hilla at [0036] (“FIG. 1 illustrates a link bundle 130 that includes five communication links
`between intermediate network node 110c and network node 110b. Network node 110b may be
`an intermediate network node or an end node that is connected both to intermediate network
`node 11 Oc and subnetwork 102a. For purposes of illustration, intermediate network node 110c
`is connected by a bundle 130 of five communication links to network node 110b and thereby
`to subnetwork 102a and end node 11 Oa. Similarly, intermediate network node 110c is
`connected by three unbundled com-munication links to network nodes 110d, ll0e, 110/,
`respec-tively, and thence to sub-network 102b and end node 110g. In other embodiments an
`intermediate network node 11 Oc may be connected to more or fewer network nodes with
`more or fewer links in each of one or more link bundles as part of a network with the same or
`more end nodes.”)
`
`11
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 11 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`
`
`Hilla at [0038] (“FIG. 2 is a block diagram that illustrates a link-bundle switching system 200
`in a router, which can be used as intermediate network node 11 Oc, according to an
`embodi-ment. The switching system 200 includes a switching system component 202
`connected to communication links, includ-ing link bundle 130. The switching system
`component 202 includes multiple ingress line cards, including cards 210a, 210b, 210c, for
`receiving inbound data packets, switching fabric component 220, and multiple egress line
`cards for sending outbound data packets, including egress line card 230 for link bundle 130.”)
`
`Hilla at [0039] (“An ingress line card (e.g., 210a) receives a data packet, inspects the
`appropriate header fields to make a forwarding decision, and forwards the packet toward the
`egress line card via the switching fabric component 220. The switch fabric component 220
`forwards the packet to the appropriate egress line card 230. Multiple ingress line cards can
`forward traffic toward a single egress line card 230. In this example, the link bundle 130 is
`capable of transmitting more packets simultaneously because of the increased band-width
`achieved by bundling. Some ingress line cards ( e.g., 210c) are connected to a link bundle with
`multiple commu-nication links. All communication links in the link bundle are considered a
`single ingress logical link. In the illustrated embodiment, the five communication links
`connected to ingress line card 210c are connected to network node 110b. The ingress line card
`210c handles incoming traffic on the link bundle 130, while the egress line card 230 handles
`the outbound traffic on the link bundle 130.”)
`
`Hilla at [0040] (“The ingress line cards 210 determine an outbound physical or logical link to
`use to forward the data packet, for example using data in a routing table stored on the router,
`and sends information to the egress line card associated with the outbound physical or logical
`link. All communication links in the link bundle 130 are considered a single logical link.
`Information about data packets to be output on the link bundle 130 is sent to the egress line
`card 230.”)
`
`Hilla at [0044] (“The ports bank 236 is a bank of ports which includes multiple ports that are
`treated by a router as a single logical port for purposes of communicating through link bundle
`130 as a single logical link. Each communication link in the link bundle 130 is connected to a
`
`12
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 12 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`1[c]
`
`coupling each of the
`one or more interface
`modules to a
`communication
`network using a second
`group of second
`physical links arranged
`in parallel,
`
`Hilla
`different port of the ports bank 236. In the illustrated embodiment, ports bank 236 includes
`eight ports 238a, 238b, 238c, 238d, 238e, 238/, 238g, 238h ( collectively referenced hereinafter
`as ports 238). For purposes of illustration, it is assumed that these eight ports are identified by
`a three bit code that represents the eight values from O through 7 to correspond to ports 238a
`through 238h, respectively. Each three bit code is called a port number (port #), herein. Only
`five of the ports ( e.g., 238b, 238c, 238d, 238e, 238/, identified by code values 1 through 5,
`respectively) are connected to communication links of the link bundle 130 in the illustrated
`embodiment. These are called active ports. The remaining three ports (e.g., 238a, 238g, 238h,
`identified by code values 0, 6, 7, respectively) are inactive ports. In some embodiments, a port
`becomes inactive by virtue of a communication link that is attached to the port going down.
`When a port goes down, it is no longer eligible to send traffic and the link is removed from the
`route table. In an example embodiment, the hard-ware described in more detail below would
`detect the link's inability to forward traffic and dynamically shift traffic over to an active link.
`Such a hardware shift can occur much faster than waiting for a routing table update.”)
`
`
`Hilla discloses coupling each of the one or more interface modules to a communication
`network using a second group of second physical links arranged in parallel.
`
`For example, Hilla discloses connecting the line cards to a network via a switching system
`including a switch fabric and bus using parallel connections. A person of ordinary skill would
`understand that the switching system is connected to ingress and egress line cards through
`parallel connections that comprise the second ground of second physical links. Thus, at least
`under the apparent claim scope alleged by Orckit’s Infringement Disclosures, this limitation is
`met. To the extent that the Hilla is found to not meet this limitation, coupling each of the one
`or more interface modules to a communication network using a second group of second
`physical links arranged in parallel would have been obvious to a person having ordinary skill
`in the art, as explained below.
`
`Hilla at [0038] (“FIG. 2 is a block diagram that illustrates a link-bundle switching system 200
`in a router, which can be used as intermediate network node 11 Oc, according to an
`embodi-ment. The switching system 200 includes a switching system component 202
`
`13
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 13 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`connected to communication links, includ-ing link bundle 130. The switching system
`component 202 includes multiple ingress line cards, including cards 210a, 210b, 210c, for
`receiving inbound data packets, switching fabric component 220, and multiple egress line
`cards for sending outbound data packets, including egress line card 230 for link bundle 130.”)
`
`Hilla at [0039] (“An ingress line card (e.g., 210a) receives a data packet, inspects the
`appropriate header fields to make a forwarding decision, and forwards the packet toward the
`egress line card via the switching fabric component 220. The switch fabric component 220
`forwards the packet to the appropriate egress line card 230. Multiple ingress line cards can
`forward traffic toward a single egress line card 230. In this example, the link bundle 130 is
`capable of transmitting more packets simultaneously because of the increased band-width
`achieved by bundling. Some ingress line cards ( e.g., 210c) are connected to a link bundle with
`multiple commu-nication links. All communication links in the link bundle are considered a
`single ingress logical link. In the illustrated embodiment, the five communication links
`connected to ingress line card 210c are connected to network node 110b. The ingress line card
`210c handles incoming traffic on the link bundle 130, while the egress line card 230 handles
`the outbound traffic on the link bundle 130.”)
`
`Hilla at [0042] (“The switching ASIC performs various standard functions well known in the
`art, such as retrieving data packet contents from router memory based on information received
`from the switching fabric 220 and appending a revised header to the beginning of the packet.”)
`
`Hilla at [0067] (“In step 412 a current flow ID is determined for the current data packet. Any
`method known in the art at the time the method 400 is implemented may be used. In some
`embodiments, step 412 includes determining and combining the bit values in one or more
`fields in the header portions of one or more protocols. In some embodiments, step 412 involves
`receiving the current flow ID from another com-ponent, e.g., from switching fabric block 220,
`or switching ASIC 232 or traffic manager block 234. In some embodi-ments, the flow ID is
`the same as the particular queue 332 where the data packet is stored by the traffic manager
`234. In some embodiments in which packet sequence within a data flow is not important and
`commit depth is not used to select ports, step 412 is omitted.)
`
`
`14
`
`Orckit Exhibit 2017
`Cisco Systems v. Orckit Corp.
`IPR2023-00554, Page 14 of 1736
`
`

`

`No.
`
`ʼ740 Patent Claim 1
`
`Hilla
`Hilla at [0121] (“Computer system 600 includes a communication mechanism such as a bus
`610 for passing information between other internal and external components of the computer
`system 600. Information is represented as physical signals of a measurable phenomenon,
`typically electric voltages, but including, in other embodiments, such phe-nomena as magnetic,
`electromagnetic, pressure, chemical, molecular atomic and quantum interactions. For example,
`north and south magnetic fields, or a zero and non zero electric voltage, represent two states
`(0, 1) of a binary digit (bit). A sequence of binary digits constitutes digital data that is used to
`represent a number or code for a character. A bus 610 includes many parallel conductors of
`information so that information is transferred quickly among devices coupled to the bus 610.
`One or more processors 602 for processing information are coupled with the bus 610. A
`processor 602 performs a set of operations on information. The set of operations include
`bringing information in from the bus 610 and placing information on the bus 610. The set of
`opera-tions also typically include comparing two or more units of information, shifting
`positions of units of information, and combining two or more units of information, such as by
`addition or multiplication. A sequence of operations to be executed by the processor 602
`constitute computer instruc-tions.”)
`
`Hilla at [0122] (“Computer system 600 also includes a memory 604 coupled to bus 610. The
`memory 604, such as a random access memory (RAM) or other dynamic storage device, stores
`information including computer instructions. Dynamic memory allows information stored
`therein to be changed by the computer system 600. RAM allows a unit of information stored
`at a location called a memory address to be stored and retrieved independently of information
`at neighboring addresses. The memory 604 is also used by the processor 602 to store temporary
`values during execution of computer instructions. The computer system 600 also includes a
`read only memory (ROM) 606 or other static storage device coupled to the bus 610 for storing
`static information, including instructions, that is not changed by the computer system 600.
`Also coupled to bus 610 is a non-volatile (persistent) storage device 608, such as a mag-netic
`disk or optical disk, for storing information, including instructions, that persists even when the
`computer system 600 is turned off or otherwise loses power.”)
`
`Hilla at [0126] (“Computer system 600 also includes one or more instances of a
`communications interface 670