Exhibit 2
`
`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 1 of 10 PageID #: 2101
`
`
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 2 of 10 PageID #: 2102
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Invalidity Chart for U.S. Patent No. 7,245,874 Based on Nokia
`
`
`As set forth below, Hughes contends that European Patent Application No. 0,852,448 A1 of Nokia Mobile Phones LTD (“Nokia”)
`anticipates one or more claims of U.S. Patent No. 7,245,874 (“the ‘874 Patent”) or renders ‘874 Patent obvious, either alone or in
`conjunction with other prior art. The ‘874 Patent was filed on August 1, 2001, and makes no claim to an earlier priority date. Nokia
`is, on its face, prior art to the ‘874 Patent at least under 35 U.S.C. § 102(a), (b), and (e) as of its 1998 publication date.
`
`Defendants’ contentions are based upon information available to it at the time of serving these contentions. In the absence of a claim
`construction order from the Court, Defendants have based the invalidity contentions on the broadest reasonable interpretation of the
`claim language itself1 or the meaning ascribed to the claim by Plaintiff in its infringement contentions (which in some instances is
`broader). Defendants’ disclosures do not reflect, and nothing in these disclosures should be construed as reflecting, Defendants’
`endorsement or assertion of any particular claim construction. Defendants reserve the right to propose alternative claim constructions
`and to challenge claim constructions offered by Plaintiff.
`
`In the following claim charts, Defendants have cited representative portions of the identified reference, even where the cited reference
`may contain additional support for a particular claim element. Persons of ordinary skill in the art would have known to read
`references as a whole, and in the context of other publications and literature and the knowledge of one of ordinary skill in the art.
`Defendants may rely on all such information, including uncited portions of the prior art references listed herein and on other
`publications and testimony to provide context and as aids to understanding and interpreting the listed references. Furthermore,
`Defendant may rely on all such information to establish that a person of ordinary skill in the art would have been motivated to modify
`or combine any of the cited references so as to render the claims obvious. Additionally, citations to a particular figure in a prior art
`reference encompass all text relating to the figure, and citations to text encompass all figures relating to that text.
`
`
`
`
`
`
`
`
`
`
`
`1 See, e.g., MPEP § 2111 (8th ed., 8th rev. 2010).
`
`Active 23536145.1
`
`1
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 3 of 10 PageID #: 2103
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`1
`
`‘874 Claim Limitation
`A branch of a cellular telephone network
`based on a first synchronous data
`communication protocol, comprising
`
`1a
`
`interfaces to a satellite link using a
`second, asynchronous, data
`communication protocol,
`
`Invalidity Analysis
`Nokia discloses a branch of a cellular telephone network based on a first
`synchronous data communication protocol. For example,
`
`“The present invention relates to mobile communications.” [Nokia, 1:3-4]
`
`“In one aspect, the present invention is primarily concerned with mobile
`communications in which multiple backbone networks are accessible via one
`or more common protocol radio access networks, and the backbone networks
`operate using technically incompatible communications protocols.” [Nokia,
`1:53-58]
`
`“Referring to Figure 1, a mobile communications system comprises a mobile
`terminal 10 (e.g. a digital cellular telephone or personal digital assistant
`(PDA)); three radio access networks 20a;20b;20c and three backbone
`networks 30a,30b,30c.” [Nokia, 4:12-16]
`
`“However, the present invention is not limited to these protocols but it
`extends also to other currently known protocols such as DAMPS, PDC, DCS
`1800, and modifications thereof, whether these are based on synchronous or
`asynchronous protocols and to completely new protocols which may be
`developed.” [Nokia, 9:24-30]
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Nokia discloses interfaces to a satellite link using a second, asynchronous,
`data communication protocol. For example,
`
`“However, the present invention is not limited to these protocols but it
`
`Active 23536145.1
`
`2
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 4 of 10 PageID #: 2104
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`‘874 Claim Limitation
`
`1b
`
`wherein said interfaces comprise
`converters for converting data of a
`datastream between said first data
`communication protocol and said second
`data communication protocol,
`
`Invalidity Analysis
`extends also to other currently known protocols such as DAMPS, PDC, DCS
`1800, and modifications thereof, whether these are based on synchronous or
`asynchronous protocols and to completely new protocols which may be
`developed.” [Nokia, 9:24-30]
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Nokia discloses said interfaces comprising converters for converting data of a
`datastream between said first data communication protocol and said second
`data communication protocol. For example,
`
`“One way of implementing such systems would be to provide a full set of
`protocol converters within the radio access network (for example, at a point
`corresponding to the BCS of a GSM network) and to allow the mobile
`terminal to communicate using a single stack of high and low level protocols.
`Protocol conversion would then be handled invisibly from the mobile
`terminal, which could be of simple construction. This is the approach which
`has in the past been used, for example, when specifying the interworking
`between DECT (digital European cordless telephony) and GSM systems.”
`[Nokia, 2:1-11]
`
`“The digital signal processor device 13 performs data formatting (for example
`into packets, ATM cells or a TOM bit stream and into a frame structure);”
`[Nokia, 4:30-33]
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`
`Active 23536145.1
`
`3
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 5 of 10 PageID #: 2105
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`‘874 Claim Limitation
`
`1c
`
`1d
`
`1e
`
`2
`
`2a
`
`and wherein said synchronous data
`protocol allows non-data carrying time
`slots,
`
`and said interfaces comprising a non-
`data carrying time slot remover for
`removing said non-data carrying time
`slots during conversion into said
`asynchronous protocol
`
`and a time slot regenerator for
`regenerating non-data carrying time slots
`during reconstruction of said datastream.
`
`The branch of claim 1, being one of
`peripheral branches of a telephone
`network,
`
`the peripheral branches being connected
`to a central high-capacity data trunking
`region and,
`
`Invalidity Analysis
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Nokia discloses the peripheral branches being connected to a central high-
`capacity data trunking region. For example,
`
`“These MSC’s, together with the physical links (e.g. fibre optic cables) which
`interconnect them, make up a backbone network, through which voice calls,
`
`Active 23536145.1
`
`4
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 6 of 10 PageID #: 2106
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`‘874 Claim Limitation
`
`2b
`
`2c
`
`wherein said first synchronous protocol is
`the E1 protocol and wherein said second,
`asynchronous protocol is the TCP/IP
`protocol,
`
`said high-capacity data trunking region
`comprises a satellite interface for a
`satellite connection using a TCP/IP
`protocol,
`
`2d
`
`said satellite interface comprising said
`converter, said converter being an E1-
`
`Invalidity Analysis
`fax calls or data exchanges (hereafter collectively termed “sessions”) are
`routed after leaving the air interface at the BTS.” [Nokia, 1:24-29]
`
`“Referring to Figure 1, a mobile communications system comprises a mobile
`terminal 10 (e.g. a digital cellular telephone or personal digital assistant
`(PDA)); three radio access networks 20a;20b;20c and three backbone
`networks 30a,30b,30c.” [Nokia, 4:12-16]
`
`“The radio access network station 20b shown in Figure 3 is connected to two
`alternative backbone networks; a GSM backbone network 30a and a
`broadband ISDN (B-ISDN) backbone network 30b.” [Nokia, 5:7-10]
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`
`Active 23536145.1
`
`5
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 7 of 10 PageID #: 2107
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`2e
`
`2f
`
`3
`
`4
`
`5
`
`‘874 Claim Limitation
`TCP/IP converter being operable to
`receive E1 signaling containing SS7
`control signaling distributed therein at a
`predetermined data rate,
`said converter using a multiplexer for
`converting between the E1 signal and the
`TCP/IP signal;
`
`wherein said high capacity trunking
`region comprises a terrestrial high
`capacity trunking connection in parallel
`with said satellite connection such that
`said satellite connection is usable to back
`up said terrestrial connection.
`A cellular telephone network according
`to claim 2, wherein said high capacity
`data trunking region comprises a
`terrestrial high capacity trunking
`connection in parallel with said satellite
`connection such that said terrestrial high
`capacity trunking connection is usable to
`back up said satellite connection.
`A cellular telephone network according
`to claim 2, wherein said satellite link is
`via geostationary orbit satellite.
`
`A cellular telephone network according
`to claim 2, wherein said E1-TCP/IP
`
`Invalidity Analysis
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`
`Active 23536145.1
`
`6
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 8 of 10 PageID #: 2108
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`5a
`
`5b
`
`7
`
`8
`
`‘874 Claim Limitation
`converter is operable to receive E1
`signaling containing SS7 control signaling
`distributed therein at a predetermined
`data rate,
`said converter comprising an extractor
`for extracting said SS7 signaling, and
`
`a TCP/IP packet former for arranging
`said extracted signaling into TCP/IP
`packets.
`
`A cellular telephone network according
`to claim 2, wherein at least one of said
`peripheral branches comprises a satellite
`link and an E1-TCP/IP interface.
`
`The branch of claim 1, wherein said first
`synchronous data protocol is the E1
`protocol, the branches comprising
`interfaces to a satellite link,
`
`8a
`
`wherein the second, asynchronous
`protocol is the TCP/IP protocol,
`
`Invalidity Analysis
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`
`Active 23536145.1
`
`7
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 9 of 10 PageID #: 2109
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`Mark
`
`‘874 Claim Limitation
`
`8b
`
`8c
`
`8d
`
`9
`
`11
`
`wherein said converters at said interfaces
`comprise E1-TCP/IP converters for
`converting data between said E1 protocol
`and said TCP/IP protocol,
`
`wherein said interfaces comprising
`encoders for encoding synchronization
`control information of said E1 protocol
`when encoding data of said E1 protocol
`into said TCP/IP protocol, thereby to
`enable reconstruction of a signal in said
`E1 protocol from data in said TCP/IP
`protocol, which reconstructed data
`retains said synchronization,
`each one of said E1-TCP/IP converters
`using a multiplexer for converting
`between the E1 signal and the TCP/IP
`signal.
`
`A branch according to claim 8, wherein
`said interfaces are arranged to provide
`said satellite link as a parallel path to a
`terrestrial data link.
`
`A branch according to claim 8, wherein
`said interfaces comprising decoders
`operable to decode synchronization
`
`Invalidity Analysis
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`
`Active 23536145.1
`
`8
`
`

`

`Case 2:15-cv-00037-RWS Document 87-4 Filed 02/05/16 Page 10 of 10 PageID #: 2110
`
`Exhibit A35 to Hughes Invalidity Contentions
`
`‘874 Claim Limitation
`control information from data arriving
`from said link, to reconstruct a
`synchronized telephony protocol data
`stream.
`A branch according to claim 11, said
`interface further comprising a buffer
`controllable according to said decoded
`synchronization information to recreate
`time delay relationships of said telephony
`protocol data stream.
`
`Invalidity Analysis
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`
`Viewing Nokia as a whole and in view of other prior art, this element would
`have been inherent or obvious to one of ordinary skill in the art. To the extent
`it is found that the element is not expressly disclosed in Nokia, Nokia renders
`it obvious, either alone, in combination with the knowledge of a person of
`ordinary skill in the art, and/or in combination with other prior art references
`identified in the cover pleading or herein.
`
`Mark
`
`12
`
`
`
`
`Active 23536145.1
`
`9
`
`