`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`
`CISCO SYSTEMS, INC.,
`
`Petitioner,
`
`-vs-
`
`ORCKIT CORPORATION,
`
`Patent Owner
`____________________________
`
`Case No. IPR2023-00554
`U.S. Patent No. 10,652,111
`
`PETITIONER'S DEMONSTRATIVES
`PTAB ORAL ARGUMENT
`July 9, 2024
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`
`
`The ’111 Patent Relates to Deep
`Packet Inspection (DPI) in Software
`Defined Networks (SDN)
`
`EX1001, Col. 1:14-17
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`2
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`
`
`Figure 1 of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`3
`
`EX1001, Figure 1
`
`
`
`Figure 2 of the ’111 Patent
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`EX1001, Figure 2
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`4
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`
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`Figure 3 of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, Figure 3
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`5
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`
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`Figure 4 of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, Figure 4
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`6
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`
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`Figure 6 of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, Figure 6
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`7
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`
`
`Deep Packet Inspection (DPI)
`Was Known
`
`EX1001, Col. 1:20-25
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`8
`
`
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`Software Defined Networking
`(SDN) Was Known
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`EX1001, Col. 1:30-33
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`9
`
`
`
`Background on SDN and
`Open Flow Protocol
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`10
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`EX1001, Col. 1:39-67
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`
`
`Embodiments of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, Col. 2:27-47
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`11
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`
`
`The Central Controller Performs
`Deep Packet Inspection
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`12
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`EX1001, Col. 4:5-19
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`
`
`The Operation of the
`Probe Flow Module
`
`EX1001, Col. 5:50-59
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`13
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`
`
`Claim 1 of the ’111 Patent
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, Cols. 10:51-11:4
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`14
`
`
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`Lin Discloses SDN
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`EX1005, Col. 1:8-9
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`15
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`
`
`Lin Discloses The Flow of Packets
`Through The SDN Switch
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`16
`
`EX1004, ¶76
`
`
`
`Lin Discloses The Flow of Packets
`Through The SDN Switch
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`17
`
`EX1004, ¶76
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`
`
`The Packets Travel From The Sender
`Through The SDN Switch To The Next Hop
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1004, ¶102
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`18
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`
`
`Lin Discloses The Claimed Network Node
`And First And Second Entities
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1004, ¶77
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`19
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`
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`Lin Discloses The Claimed Controller
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`20
`
`EX1004, ¶78
`
`
`
`Lin Teaches That SDN “Separates The
`Control Plane From The Data Plane”
`
`EX1005, Col. 1:10-17
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`21
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`
`
`Lin Discloses The Use Of The
`OpenFlow Protocol
`
`EX1005, Col. 1:18-22
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`22
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`
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`Lin’s Controller And Switch Can
`Utilize The OpenFlow Protocol
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`23
`
`EX1004, ¶186
`
`
`
`Lin’s Controller Determines Flow
`Policies That Contain “A Condition And
`Corresponding Action To Be Performed”
`
`EX1005, Col. 1:39-43
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`24
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`
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`Lin Utilizes An SDN Controller To
`Insert Flow Rules In A Flow Table Of
`The SDN Switch
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1005, Col. 1:57-2:4
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`25
`
`
`
`Lin Discloses The Use Of DPI
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`EX1005, Col. 3:11-14
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`26
`
`
`
`Lin Discloses Packets Sent
`To A Security Service
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`27
`
`EX1005, Col. 3:25-33
`
`
`
`Lin’s Controller And Switch Can Use
`The OpenFlow Protocol
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`28
`
`EX1005, Col. 3:44-52
`
`
`
`Lin’s SDN Controller Controls
`Network Behavior
`
`EX1005, Col. 4:8-10
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`29
`
`
`
`Lin’s Flow Policies Are Enforced
`Through Flow Rules
`
`EX1005, Col. 4:21-27
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`30
`
`
`
`Lin’s Flow Rules Are
`Located In Flow Tables
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`31
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`EX1005, Col. 4:53-65
`
`
`
`The Structure Of Lin’s Flow Tables
`
`EX1005, Col. 5:8-10
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`32
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`
`
`Lin Utilizes The IP Source And
`Destination Addresses
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`33
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`EX1005, Col. 5:15-25
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`
`
`Lin Forms An SDN Pipe Between
`The Sender Component And The
`Security Service
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1005, Col. 5:26-36
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`34
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`
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`Lin’s Security Service Inspects Packets
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`35
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`EX1005, Col. 5:45-55
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`
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`Lin’s Security Service Is
`Connected To The SDN Switch
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`36
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`EX1005, Col. 5:56-67
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`
`
`Lin’s Flow Rules Allow Redirection
`Of Packets To The Security Service
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1005, Col. 6:1-12
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`37
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`
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`Lin’s Security Service May Drop Packets
`Or Perform Other Security Services
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`38
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`EX1005, Col. 6:49-57
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`
`
`Lin May Mirror Packets To
`The Security Service
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`39
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`EX1005, Col. 7:9-19
`
`
`
`Lin Allows Packets To Pass Through The
`SDN Switch If They Do Not Need
`Inspection
`
`EX1005, Col. 7:23-27
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`40
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`
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`Table 2 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`41
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`EX1005, Col. 7:30-37
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`
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`Lin’s Bypass Rules
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`42
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`EX1005, Col. 7:39-50
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`
`
`Lin Chooses Which Packets To
`Redirect To The Security Service
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`43
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`EX1005, Col. 7:51-63
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`
`
`Lin Inspects Certain Packets While
`Allowing Other Packets To Bypass
`Inspection
`
`EX1005, Col. 7:64-67
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`44
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`
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`Table 3 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`45
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`EX1005, Col. 8:1-8
`EX1004, ¶92
`
`
`
`The Operation Of Table 3
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`46
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`EX1005, Col. 8:10-18
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`
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`Lin’s Bypass Flow Rules
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`47
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`EX1005, Col. 9:10-21
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`
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`Figure 2 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`48
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`EX1005, Figure 2
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`
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`Figure 3 of Lin
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`EX1005, Figure 3
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`49
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`
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`Figure 4 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`50
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`EX1005, Figure 4
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`
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`Figure 7 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1005, Figure 7
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`51
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`
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`Figure 8 of Lin
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1005, Figure 8
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`52
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`
`
`Shieh Relates To Network Security
`
`EX1006, ¶[0002]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`53
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`
`
`Shieh Discloses A Client And A Server
`Communicating Through The
`Network Access Device
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`54
`
`EX1004, ¶234
`
`
`
`Shieh Discloses Packets Flowing
`Through A Network Access Device
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`55
`
`EX1004, ¶209
`
`
`
`Shieh’s Network Access Devices Are
`The Claimed Network Nodes
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`56
`
`EX1004, ¶210
`
`
`
`Shieh Discloses The Claimed Controller
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`57
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`EX1004, ¶211, ¶216
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`
`
`Shieh Discloses A Flexible Security System
`That Optimizes The Use Of Resources
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`58
`
`EX1006, ¶[0003]
`
`
`
`Shieh Performs Dynamic Security
`Inspection On Network Packets
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`59
`
`EX1006, ¶[0017]
`
`
`
`Shieh Discloses That A Command From An
`Administrator Can Control How Packets
`Are Forwarded
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`60
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`EX1006, ¶[0017]
`
`
`
`Shieh’s Controller Configures A Network
`Access Device To Set Up Filtering Rules
`
`EX1006, ¶[0018]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`61
`
`
`
`Shieh’s Network Access Device Can Forward
`Certain Packets To A Security Device
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`62
`
`EX1006, ¶[0018]
`
`
`
`Shieh’s System Operates On
`Switches Or Routers
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`63
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`EX1006, ¶[0019]
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`
`
`Shieh Discloses DPI
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`EX1006, ¶[0021]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`64
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`
`
`Shieh Can Utilize A Session Table To Store
`Rules Used To Decide What Packets Are
`Sent To A Security Processing Function
`
`EX1006, ¶[0023]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`65
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`
`
`Shieh Can Utilize A Session Table To Store
`Rules Used To Decide What Packets Are
`Sent To A Security Processing Function
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`66
`
`EX1006, ¶[0023]
`
`
`
`Shieh Discloses A Persistent Connection
`Between Its Controllers And Its Network
`Access Devices
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1006, ¶[0025]
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`67
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`
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`Shieh Can Utilize OpenFlow Technology
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1006, ¶[0026]
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`68
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`
`
`Shieh Discloses That An Administrator
`Configures The Network Access Devices
`Via A Controller
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1006, ¶[0029]
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`69
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`
`
`Shieh Discloses That Security Inspection
`Can Be Bypassed For Certain Packets
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1006, ¶[0035]
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`70
`
`
`
`The Use Of Shieh’s Bypass Flag
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1006, ¶[0037]
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`71
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`
`
`Shieh’s Disclosure Of Load Balancing
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`72
`
`EX1006, ¶[0039]
`
`
`
`Shieh’s Controller Has “Central Control
`And Monitoring Functionality”
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`73
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`EX1006, ¶[0043]
`
`
`
`Shieh – Claim 1
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1006, Claim 1
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`74
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`
`
`Figure 2B of Shieh
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1006, Figure 2B
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`75
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`
`
`Figure 3 of Shieh
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1006, Figure 3
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`76
`
`
`
`Figure 5 of Shieh
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1006, Figure 5
`
`77
`
`
`
`Figure 8 of Shieh
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`78
`
`EX1006, Figure 8
`
`
`
`Swenson Teaches “Real-Time Traffic
`Monitoring” Using A Network Controller
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`79
`
`EX1007, ¶[0023]
`
`
`
`Swenson Discloses A System That
`Maximizes Available Bandwidth
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`80
`
`EX1007, ¶[0018]
`
`
`
`Figure 1 of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`81
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`EX1007, Figure 1
`
`
`
`Figure 3 of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`82
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`EX1007, Figure 3
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`
`
`Figure 4A of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`83
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`EX1007, Figure 4A
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`
`
`Figure 4B of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1007, Figure 4B
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`84
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`
`
`Figure 5 of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`85
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`EX1007, Figure 5
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`
`
`Figure 7 of Swenson
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1007, Figure 7
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`86
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`
`
`Swenson Categorizes Network Traffic,
`Including HTTP Traffic Flows
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1007, ¶[0026]
`
`87
`
`
`
`Swenson’s Controller Is Out-Of-Band And
`Inspects Network Packets For Traffic
`Monitoring And Optimization
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`88
`
`EX1007, ¶[0028]
`
`
`
`Swenson Teaches That Network Packets
`Are Sent To The Controller For
`“Inspection”
`
`EX1007, ¶[0029]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`89
`
`
`
`Swenson Discloses That Its System
`Performs “Security Functions”
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`90
`
`EX1007, ¶[0039]
`
`
`
`Swenson Provides “On-Demand Real-
`Time Network Monitoring”
`
`EX1007, ¶[0056]
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`91
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`
`
`Swenson Performs DPI
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1007, ¶[0059]
`
`92
`
`
`
`Swenson Discloses That Its System
`Performs Inspection Of Network Packets
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`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1007, ¶[0060]
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`93
`
`