UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`CISCO SYSTEMS, INC.,
`
`Petitioner,
`
`- vs. -
`
`ORCKIT IP, LLC,
`
`Patent Owner.
`_________________________
`
`Case IPR2023-00554
`
`U.S. Patent No. 10,652,111
`
`_________________________
`
`DECLARATION OF SAMRAT BHATTACHARJEE, Ph.D.
`IN SUPPORT OF PETITION FOR INTER PARTES
`REVIEW OF U.S. PATENT NO. 10,652,111
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`TABLE OF CONTENTS
`
`I.
`II.
`
`INTRODUCTION AND QUALIFICATIONS ............................................... 1
`UNDERSTANDING OF THE GOVERNING LAW ..................................... 4
`Invalidity by Obviousness ......................................................................... 4
`Interpreting Claims Before the Patent Office ........................................... 8
`Materials Relied on in Forming My Opinions .......................................... 8
`III. BACKGROUND DISCUSSION COMPUTER NETWORKING
`TECHNOLOGY .............................................................................................. 9
`IV. OVERVIEW OF THE ’111 Patent ................................................................14
`Specification of the ’111 Patent ..............................................................14
`The Claims of the ’111 Patent .................................................................18
`The Prosecution History of the ’111 Patent ............................................19
`The Priority Date of the ’111 Patent .......................................................25
`STATE OF THE ART PRIOR TO THE ’111 Patent ...................................25
`The Person of Ordinary Skill in the Art ..................................................25
`Lin ...........................................................................................................26
`Shieh ........................................................................................................30
`Swenson ..................................................................................................35
`VI. CLAIM CONSTRUCTION ..........................................................................40
`VII. GROUNDS OF INVALIDITY .....................................................................44
`Ground 1: Claims 1-9, 12-24 and 27-31 of the ’111 Patent are obvious
`over Lin in view of Swenson. .................................................................44
`
`V.
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`i
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`a. Claim 1 ..............................................................................................44
`b. Claim 2 ..............................................................................................74
`c. Claim 3 ..............................................................................................75
`d. Claim 4 ..............................................................................................78
`e. Claim 5 ..............................................................................................81
`f. Claim 6 ..............................................................................................82
`g. Claim 7 ..............................................................................................84
`h. Claim 8 ..............................................................................................85
`i. Claim 9 ..............................................................................................85
`j. Claim 12 ............................................................................................87
`k. Claim 13 ............................................................................................88
`l. Claim 14 ............................................................................................88
`m. Claim 15 ............................................................................................89
`n. Claim 16 ............................................................................................91
`o. Claim 17 ............................................................................................92
`p. Claim 18 ............................................................................................93
`q. Claim 19 ............................................................................................95
`r. Claim 20 ............................................................................................95
`s. Claim 21 ............................................................................................97
`t. Claim 22 ............................................................................................98
`u. Claim 23 ............................................................................................98
`v. Claim 24 ............................................................................................99
`w. Claim 27 ..........................................................................................100
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`ii
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`x. Claim 28 ..........................................................................................101
`y. Claim 29 ..........................................................................................101
`z. Claim 30 ..........................................................................................102
`aa. Claim 31 ..........................................................................................103
` Ground 2: Claims 1, 5-9, 12-24 and 27-30 of the ’111 Patent are obvious
`over Shieh in view of Swenson. ............................................................104
`a. Claim 1 ............................................................................................104
`b. Claim 5 ............................................................................................127
`c. Claim 6 ............................................................................................128
`d. Claim 7 ............................................................................................129
`e. Claim 8 ............................................................................................130
`f. Claim 9 ............................................................................................131
`g. Claim 12 ..........................................................................................132
`h. Claim 13 ..........................................................................................133
`i. Claim 14 ..........................................................................................134
`j. Claim 15 ..........................................................................................135
`k. Claim 16 ..........................................................................................136
`l. Claim 17 ..........................................................................................138
`m. Claim 18 ..........................................................................................139
`n. Claim 19 ..........................................................................................140
`o. Claim 20 ..........................................................................................141
`p. Claim 21 ..........................................................................................141
`q. Claim 22 ..........................................................................................142
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`iii
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`r. Claim 23 ..........................................................................................143
`s. Claim 24 ..........................................................................................144
`t. Claim 27 ..........................................................................................145
`u. Claim 28 ..........................................................................................145
`v. Claim 29 ..........................................................................................146
`w. Claim 30 ..........................................................................................146
`VIII. OBJECTIVE INDICIA OF NON-OBVIOUSNESS ...................................148
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`iv
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`I, Samrat Bhattacharjee, Ph.D., hereby declare as follows:
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`I have been retained on behalf of Cisco Systems, Inc. (“Cisco”) to
`
`1.
`
`provide my technical review, analysis, insights, and opinions concerning the validity
`
`of the claims of U.S. Patent No. 10,652,111 (EX1001; “the ’111 Patent”) entitled
`
`“Method and System for Deep Packet Inspection in Software Defined Networks.”
`
`The patent is assigned to Orckit IP, LLC (“Orckit”).
`
`2.
`
`I am a tenured professor in the Computer Science Department and the
`
`Institute for Advanced Computer Studies at the University of Maryland. I am also
`
`an Affiliate Professor with the Department of Electrical and Computer Engineering
`
`at the University of Maryland. I have been an appointed faculty member at the
`
`University of Maryland since 1999.
`
`3.
`
`I received a Ph.D. in computer science from the Georgia Institute of
`
`Technology in 1999. Before that I received a B.S. degree in Mathematics and
`
`Computer Science with Highest Distinction (Summa Cum Laude) and was
`
`recognized as the Outstanding Department Major at Georgia College and State
`
`University, Milledgeville, Georgia in 1994.
`
`4.
`
`I have been involved in the research and development of computing
`
`systems for over two decades. I perform research and I teach in the areas of computer
`
`networks, distributed systems, computer security and operating systems, among
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`1
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`others. A major theme of my research has been the development of technology to
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`improve the performance and security of data transfers on the Internet. My research
`
`has examined problems ranging from network and operating system support audio
`
`and video streaming, large scale Internet video distribution, the design of novel
`
`network architectures for better and secure content distribution, efficiency of content
`
`distribution over wireless networks, and so on.
`
`5.
`
`For example, starting in the late 1990s, the focus of my research was
`
`the development of network and operating system technology to design a new
`
`network architecture that allowed for more efficient data transfer. Part of my Ph.D.
`
`research was to develop new and more efficient architectures for video delivery on
`
`the Internet, and I have published papers on this architecture during my graduate
`
`studies. I continued to work on video delivery as a faculty member, and have
`
`published various papers on video streaming, content delivery architectures, and on
`
`resilient large scale content delivery. During 2007, I was a visiting researcher at
`
`AT&T Labs, and one of the projects I focused on was a video content delivery
`
`platform. This work resulted in both publications and a granted US patent
`
`(US8,752,100 B2).
`
`6.
`
`Along with working on research problems related to video distribution,
`
`I routinely taught this material in both graduate and undergraduate courses. A
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`2
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`number of my papers in this domain are with students at the University of Maryland,
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`many of whom started in this area after taking my classes.
`
`7.
`
`I have authored or co-authored over 100 articles in peer-reviewed
`
`journals, conference proceedings, and workshops in the aforementioned areas of
`
`computer science and others. Over the years I have received several fellowships,
`
`prizes, and awards for teaching excellence and technical papers, including an Alfred
`
`P. Sloan Jr. Fellowship in 2004 and the National Science Foundation CAREER
`
`award in 2001. I have also received an award from the SIGCOMM foundation for a
`
`“Test of Time” paper (that is given to an influential paper published ten years ago).
`
`My research work has been supported by multiple grants from the US National
`
`Science Foundation, and the Department of Defense. I have also started a Joint Ph.D.
`
`program with the University of Maryland and the Max Planck Society in Germany,
`
`and co-founded the annual Cornell, Maryland, Max Planck Research School that
`
`provides research exposure to about 80 students from across the world during a week-
`
`long school.
`
`8.
`
`I have served on numerous paper and proposal review panels and
`
`participated on program committees for ACM/IEEE groups, technical journals, and
`
`conferences in Networking, Security and Systems in the aforementioned areas of
`
`computer science. I have created research software for all of my projects, much of
`
`which is available online for others to build on.
`
`3
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`9.
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`I am a named inventor on three U.S. Patents. These patents are
`
`generally related to computer networking and the delivery of services over networks
`
`and video delivery systems.
`
`10.
`
`I have served as an expert witness and technical consultant in litigation
`
`and Inter Partes Review matters concerning videoconferencing, data conferencing
`
`and screen sharing, voice over IP (VoIP) telephony, multimedia networking,
`
`distributed systems, operating systems, computer networks, and datacenter
`
`networking, among others. I have testified in several trials and depositions as an
`
`expert witness.
`
`11.
`
`I attach as Exhibit 1003 my curriculum vitae, which includes a more
`
`detailed list of my qualifications. My curriculum vitae also contains a list of all other
`
`cases in which, during the previous 4 years, I testified as an expert at trial or by
`
`deposition. My work on this case is being billed at a rate of $700 per hour, with
`
`reimbursement for actual expenses. I have no direct financial interest in the dispute
`
`between the Cisco and Orckit, and my compensation is not contingent upon the
`
`outcome of this Inter Partes review.
`
`II. UNDERSTANDING OF THE GOVERNING LAW
`
`Invalidity by Obviousness
`12.
`I understand that obviousness is analyzed from the perspective of a
`
`person of ordinary skill in the art (“POSA”) at the time of the alleged invention. I
`
`4
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`also understand that a POSA is presumed to have been aware of all pertinent prior
`
`art at the time of the alleged invention.
`
`13.
`
`I understand that an obviousness analysis involves comparing a claim
`
`to the prior art to determine whether the claimed invention as a whole would have
`
`been obvious to a POSA in view of the prior art, and in light of the general
`
`knowledge in the art at the time the invention was made. I also understand that the
`
`invention may be deemed obvious when a POSA would have reached the claimed
`
`invention through routine experimentation.
`
`14.
`
`I understand that obviousness can be established by combining or
`
`modifying the disclosures of the prior art to achieve the claimed invention. It is also
`
`my understanding that where there is a reason to modify or combine the prior art to
`
`achieve the claimed invention, there must also be a reasonable expectation of success
`
`in so doing to render the claimed invention obvious. I understand that the reason to
`
`combine prior art references can come from a variety of sources, not just the prior
`
`art itself or the specific problem the patentee was trying to solve. I also understand
`
`that the references themselves need not provide a specific hint or suggestion of the
`
`alteration needed to arrive at the claimed invention; the analysis may include
`
`recourse to logic, judgment, and common sense available to a POSA.
`
`15.
`
`I understand that when there is some recognized reason to solve a
`
`problem, and there are a finite number of identified, predictable solutions, a POSA
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`5
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`has good reason to pursue the known options within his or her technical grasp. If
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`such an approach leads to the anticipated success, it is likely the product not of
`
`innovation but of ordinary skill and common sense. In such a circumstance, when a
`
`patent simply arranges old elements with each performing the same function it had
`
`been known to perform and yields no more than one would expect from such an
`
`arrangement, the combination is obvious.
`
`16.
`
`I understand that when considering the obviousness of an invention,
`
`one should also consider whether there are any objective indicia that support the
`
`non-obviousness of the invention. I further understand that objective indicia of non-
`
`obviousness include failure of others, copying, unexpected results, information that
`
`“teaches away” from the claimed subject matter, perception in the industry,
`
`commercial success, and long-felt but unmet need. I also understand that in order for
`
`objective indicia of non-obviousness to be applicable, the indicia must have some
`
`sort of nexus to the subject matter in the claim that was not known in the art. I
`
`understand that this nexus includes a factual connection between the patentable
`
`subject matter of the claim and the objective indicia alleged. I also understand that
`
`an independently made invention that is made within a comparatively short period
`
`of time is evidence that the claimed invention was the product of ordinary skill.
`
`17.
`
`Finally, I understand that patent examiners at the U.S. Patent and
`
`Trademark Office (“USPTO”) rely upon certain exemplary rationales in reviewing
`
`6
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`patent applications to understand whether the subject matter of the claims is obvious.
`
`I understand that the following is the list of exemplary rationales relied upon by
`
`patent examiners at the USPTO:
`
`(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 similar devices (methods,
`
`or products) in the same way;
`
`(D) Applying a known technique to a known device (method, or
`
`product) ready for improvement to yield predictable results;
`
`(E) “Obvious to try” – Choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success;
`
`(F) Known work in one field of endeavor may prompt variations of
`
`it for use in either the same field or a different one based on
`
`design incentives or other market forces if the variations are
`
`predictable to one of ordinary skill in the art; and
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`(G) Some teaching, suggestion, or motivation in the prior art that
`
`would have led one of ordinary skill to modify the prior art
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`7
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`reference or to combine prior art reference teachings to arrive at
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`the claimed invention.
`
`
`18.
`
`Interpreting Claims Before the Patent Office
`I understand that Inter Partes Review is a proceeding before the United
`
`States Patent & Trademark Office (“USPTO”) for evaluating the validity of issued
`
`patent claims. I understand that, in an Inter Partes Review, a claim term is
`
`interpreted in a manner consistent with the standard used in patent litigation, as set
`
`forth in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). That
`
`standard generally construes the claims according to their “ordinary and customary”
`
`meaning in view of the claim language, specification, and file history, and where
`
`applicable, relevant other evidence.
`
`19.
`
`I understand that a patent’s “specification” includes all the figures,
`
`discussion, and claims within the patent. I understand that the USPTO will look to
`
`the specification and prosecution history to see if there is a definition for a given
`
`claim term, and if not, will apply the ordinary and customary meaning from the
`
`perspective of a POSA at the time in which the alleged invention was made.
`
` Materials Relied on in Forming My Opinions
`20.
`In forming the opinions expressed in this declaration, I have relied on
`
`my own knowledge, experience, and expertise, as well as the knowledge of a POSA
`
`8
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`in the relevant timeframe. In addition, I have reviewed and relied upon all documents
`
`referenced in this declaration and the following list of materials:
`
`• U.S. Patent No. 10,652,111 (“the ’111 Patent”) (EX1001);
`
`• Prosecution History of the ’111 Patent (EX1002);
`
`• U.S. Patent No. 9,264,400 (“Lin”) (EX1005);
`
`• U.S. Patent Application Publication No. 2013/0291088 (“Shieh”)
`(EX1006);
`
`• U.S. Patent Application Publication No. 2013/0322242 (“Swenson)
`(EX1007);
`
`• RFC 2460, Internet Protocol, Version 6 (IPv6) Specification
`(EX1008); and
`
`• Nunes, A., et al., A Survey of Software-Defined Networking: Past,
`Present, and Future of Programmable Networks (EX1009).
`
`III. BACKGROUND DISCUSSION COMPUTER NETWORKING
`TECHNOLOGY
`To better understand my opinions on the validity of the claims of the
`
`21.
`
`’111 Patent, I provide below some background on computer networking with a
`
`particular focus on software defined networking (“SDN”). All of the concepts
`
`discussed in this section were well known and used prior to the April 22, 2014
`
`priority date for the ’111 Patent.
`
`A. Software Defined Networks (“SDN”)
`
`22.
`
`“Computer networks are typically built from a large number of network
`
`devices such as routers, switches and numerous types of middleboxes (i.e., devices
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`9
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`that manipulate traffic for purposes other than packet forwarding, such as a firewall)
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`with many complex protocols implemented on them.” EX1009 at 1. “Network
`
`operators are responsible for configuring policies to respond to a wide range of
`
`network events and applications.” EX1009 at 1. As computer networks have
`
`evolved, “programmable networks” have been developed to help keep up with the
`
`pace of that evolution. EX1009 at 1.
`
`23. One programmable networking concept that became popular before the
`
`priority date for the ’111 Patent was filed is SDN. EX1005, Col. 1:11-12 (“Software
`
`defined networking (SDN) is an emerging architecture for computer networking.”);
`
`see EX1009 at 1. SDN is a “networking paradigm in which the forwarding hardware
`
`[in a network] is decoupled from control decisions.” EX1009 at 1. “In SDN, the
`
`network intelligence is logically centralized in software-based controllers (the
`
`control plane), and network devices become simple packet forwarding devices (the
`
`data plane) that can be programmed via an open interface (e.g., ForCES, OpenFlow,
`
`etc.).” EX1009 at 1; see EX1005, Col. 1:12-14 (“Unlike traditional computer
`
`network architectures, SDN separates the control plane from the data plane.”).
`
`24. SDN “was developed to facilitate innovation and enable simple
`
`programmatic control of the network data-path.” EX1009 at 3. As shown in the
`
`figure below, “the separation of the forwarding hardware from the control logic
`
`allows easier deployment of new protocols and applications, straightforward
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`network visualization and management, and consolidation of various middleboxes
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`into software control.” EX1009 at 3; see EX1005, Col. 1:14-17 (stating that the
`
`separation of the control plane from the data plane “provides many advantages,
`
`including relatively fast experimentation and optimization of switching and routing
`
`policies.”). “Instead of enforcing policies and running protocols on a convolution of
`
`scattered devices, the network is reduced to ‘simple’ forwarding hardware and the
`
`decision-making network controllers.” EX1009 at 3.
`
`Figure 1 of EX1009
`
`25.
`
`“The underlying network infrastructure may involve a number of
`
`different physical network equipment, or forwarding devices such as routers,
`
`switches, virtual switches, wireless access points, to name a few.” EX1009 at 5. “In
`
`a [SDN], such devices are often represented as basic forwarding hardware accessible
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`via an open interface at an abstraction layer, as the control logic and algorithms are
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`off-loaded to a controller.” EX1009 at 5. “Such forwarding devices are commonly
`
`referred to, in SDN terminology, simply as ‘switches, as illustrated in [the figure
`
`reproduced below].’” EX1009 at 5.
`
`Figure 3 of EX1009
`
`26.
`
`“Traditionally, the basic unit of networking has been the packet.”
`
`EX1009 at 7. “Each packet contains address information necessary for a network
`
`switch to make routing decisions.” EX1009 at 7. “However, most applications send
`
`data as a flow of many individual packets.” EX1009 at 7. “A network that wishes to
`
`provide [Quality of Service] or service guarantees to certain applications may benefit
`
`from individual flow-based control.” EX1009 at 7.
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`12
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`27. However, “[i]n a [SDN] network where network elements are
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`controlled remotely, overhead is caused by traffic between the data-plane and the
`
`control-plane.” EX1009 at 7. “As such, using packet level granularity would incur
`
`additional delay as the controller would have to make a decision for each arriving
`
`packet.” EX1009 at 7-8. “When controlling individual flows, the decision made for
`
`the first packet of the flow can be applied to all subsequent packets of that flow.”
`
`EX1009 at 8. “The overhead may be further reduced by grouping flows together,
`
`such as all traffic between two hosts, and performing control decisions on the
`
`aggregated flows.” EX1009 at 8.
`
`28. Among the functionalities that can be implemented when using SDN
`
`are “network security services, such as firewall or deep packet inspection (DPI).”
`
`EX1005, Col. 3:11-12; see EX1006, ¶[0021].
`
`B. The OpenFlow™ Protocol
`
`29. As discussed above, the OpenFlow™ protocol can be used to
`
`implement SDN. EX1009 at 1; see EX1005, Col. 1:18-32. “The OpenFlow™
`
`protocol is an open protocol for remotely controlling forwarding tables of network
`
`switches that are enabled for SDN.” EX1005, Col. 1:18-20. “Generally speaking, the
`
`OpenFlow protocol allows direct access to and manipulation of the forwarding plane
`
`of network devices, such as switches and routers.” EX1005, Col. 1:20-22. “A control
`
`plane of an OpenFlow™ protocol-compliant computer network (also referred to as
`
`13
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`an ‘OpenFlow™ controller’) may communicate with OpenFlow™ switches (i.e.,
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`network switches that are compliant with the OpenFlow™ protocol) to set flow
`
`policies that specify how the switches should manipulate packets of network traffic.”
`
`EX1005, Col. 1:22-28. “Example packet manipulation actions include forwarding a
`
`packet to a specific port, modifying one or more fields of the packet, asking the
`
`controller for action to perform on the packet, or dropping the packet.” EX1005, Col.
`
`1:28-32.
`
`IV. OVERVIEW OF THE ’111 PATENT
`Specification of the ’111 Patent
`The methods and systems described in the ’111 Patent relate to “deep
`
`30.
`
`packet inspection (DPI) in a software defined network (SDN).” EX1001, Abstract;
`
`see EX1001, Col. 1:14-16. The method disclosed in the ’111 Patent “is performed
`
`by a central controller of the SDN.” EX1001, Col. 2:27-30. The method comprises
`
`“configuring a plurality of network nodes operable in the SDN with at least one
`
`probe instruction.” EX1001, Col. 2:3-32. The method further comprises “receiving
`
`from a network node a first packet of a flow, wherein the first packet matches the at
`
`least one probe instruction” and “wherein the first packet includes a first sequence
`
`number.” EX1001, Col. 2:32-35. The method also comprises “receiving from a
`
`network node a second packet of the flow, wherein the second packet matches the at
`
`least one probe instruction” and “the second packet includes a second sequence
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`number. EX1001, Col. 2:35-38. “[T]he second packet is a response of the first
`
`packet.” EX1001, Col. 2:38-39. The method further includes “computing a mask
`
`value respective of at least the first and second sequence numbers, wherein the mask
`
`value indicates which bytes to be mirrored from subsequent packets belonging to the
`
`same flow.” EX1001, Col. 2:39-44. The method also includes “generating at least
`
`one mirror instruction based on at least the mask value.” EX1001, Col. 2:45-46. The
`
`method further includes “configuring the plurality of network nodes with at least one
`
`mirror instruction.” EX1001, Col. 2:46-47. Finally, “the mirrored bytes are
`
`inspected.” EX1001, Col. 2:44.
`
`31.
`
`“[T]he central controller 111 [shown below in Figure 1 of the ’111
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`Patent] is configured to perform deep packet inspection on designated packets from
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`designated flows or TCP sessions.” EX1001, Col. 4:5-7. “To this end, the central
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`controller 111 is further configured to instruct each of the network nodes 112 which
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`of the packets and/or sessions should be directed to the controller 111 for packet
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`inspections.” EX1001, Col. 4:8-11. “The determination [of whether a packet requires
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`inspection] is performed based on a set of instructions provided by the
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`controller 111.” EX1001, Col. 4:14-15. “A packet that requires inspection is either
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`redirected to the controller 111 or mirrored and a copy thereof is sent to the
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`controller 111.” EX1001, Col. 4:15-18. “It should be noted that traffic flows that are
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`15
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`inspected are not affected by the operation of the network node 112.” EX1001, Col.
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`4:18-19.
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`Figure 1 of the ’111 Patent
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`
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`32. F[igure] 6 [of the ’111 Patent, shown below] shows an exemplary and
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`non-limiting
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`flowchart 600 illustrating
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`the
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`operation
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`of
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`the
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`central
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`controller 111 according to one embodiment.” EX1001, Col. 9:40-42. “At S[tep]
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`610, all network nodes 112 are configured with a set of probe instructions utilized
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`to instruct each node 112 to redirect a TCP packet having at least a flag value as
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`designated in each probe instruction.” EX1001, Col. 9:42-45. “At S[tep] 620, a first
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`TCP packet with at least one TCP FLAG SYN value equal to 1 is received.” EX1001,
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`16
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`Col. 9:47-48. “This packet may have a sequence number M and may be sent from a
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`client device 130.” EX1001, Col. 9:48-50. “At S630, a second TCP packet with at
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`least one TCP FLAG ACK value equal to 1 is received.” EX1001, Col. 9:50-51.
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`“This packet may have a sequence number N and may be sent from a destination
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`server 140 in response to the first TCP packet.” EX1001, Col. 9:51-53. “In an
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`embodiment, the flow table is updated with the respective flow ID and the state of
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`the first and second packets.” EX1001, Col. 9:53-55.
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`17
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`Figure 6 of the ’111 Patent
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`33.
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`“At S[tep] 640, using at least the sequence numbers of the first and
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`second packets a mask value is computed.” EX1001, Col. 9:56-57. “The mask value
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`is utilized to determine which bytes from the flow respective of the sequence
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`numbers N and M should be mirrored by the nodes.” EX1001, Col. 9:40-42. “At
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`S[tep] 650, a set of mirroring instructions are generated using the mirror value and
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`sent to the network nodes.” EX1001, Col. 9:62-63. “Each such instruction defines
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`the packets (designed at least by a specific source/destination IP addresses, and TCP
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`sequences), the number of bytes, and the bytes that should be mirrored.” EX1001,
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`Col. 9:63-67. At S[tep] 660, the received mirror bytes are inspected using a DPI
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`engine in the controller 111.” EX1001, Cols. 9:67-10:1. “In addition, the flow table
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`is updated with the number of the received mirror bytes.” EX1001, Col. 10:1-3.
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`The Claims of the ’111 Patent
`The ’111 Patent includes 54 claims. EX1001, Cols. 10:52-14:60.
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`34.
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`Claims 1 and 32 are independent claims. EX1001, Cols. 10:52-11:4, 13:8-23.
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`Representative Claim 1 recites:
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`A method for use with a packet network including a network node for
`transporting packets between first and second entities under control of
`a controller that is external to the network node, the method