Case 6:24-cv-00298-DC Document 1 Filed 05/30/24 Page 1 of 54
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`VOIP-PAL.COM, INC.
`Plaintiff,
`
`v.
`T-MOBILE USA, INC.;
`Defendant.
`
`CIVIL ACTION NO. : 6:24-cv-298
`
` JURY TRIAL DEMANDED
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff VoIP-Pal.com, Inc. (“VoIP-Pal”), for its Complaint against Defendant T-Mobile
`
`USA, Inc. (“T-Mobile”) alleges as follows:
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`THE PARTIES
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`1.
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`Plaintiff VoIP-Pal is a Nevada corporation with its principal place of business
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`located at 7215 Bosque Boulevard, Waco, Texas 76710. VoIP-Pal is registered to do business in
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`the State of Texas.
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`2.
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`On information and belief, T-Mobile USA, Inc. is a Delaware corporation with its
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`principal place of business at 12920 Southeast 38th Street, Bellevue, Washington 98006. T-
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`Mobile USA, Inc. has regular and established places of business throughout this District, including
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`at least at 100 N. New Road Suite 110, Waco, Texas 76710 and at 2448 West Loop 340, Waco
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`Texas 76711. T-Mobile USA, Inc. may be served through its registered agent Corporation Service
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`Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701. On information and belief, T-Mobile
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`USA, Inc. is registered to do business in the State of Texas and has been since at least November
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`22, 1999.
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`3.
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`On information and belief, on April 29, 2018, T-Mobile and Sprint Corporation
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`announced their intention to merge. On information and belief, the merger closed on April 1,
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`2020. On information and belief, T-Mobile has assumed Sprint Corporation’s responsibility for
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`patent infringement for the Sprint Accused Instrumentalities identified in this Complaint.
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`4.
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`On information and belief, T-Mobile regularly conducts and transacts business in
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`the State of Texas, throughout the United States, and within this District, and as set forth below,
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`has committed and continues to commit, tortious acts of infringement within and outside the State
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`of Texas and within this District.
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`JURISDICTION AND VENUE
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`5.
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`This action is a civil action for patent infringement arising under the patent laws of
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`the United States, Title 35, United States Code (“U.S.C.”) § 1 et seq., including 35 U.S.C. §§ 271
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`and 281-285. This Court has exclusive subject matter jurisdiction over this case for patent
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`infringement under 28 U.S.C. §§ 1331 and 1338.
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`6.
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`This Court has personal jurisdiction over T-Mobile by virtue of its systematic and
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`continuous contacts with this jurisdiction, as alleged herein, as well as because the injury to VoIP-
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`Pal occurred in the State of Texas and the claim for relief possessed by VoIP-Pal against T-Mobile
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`for that injury arose in the State of Texas. On information and belief, T-Mobile has purposely
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`availed itself of the privileges of conducting business within the State of Texas, such business
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`including but not limited to: (i) at least a portion of the infringements alleged in this Complaint;
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`(ii) purposefully and voluntarily placing one or more infringing products or services into the stream
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`of commerce with the expectation that they will be purchased and used by consumers in this forum;
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`or (iii) regularly transacting or soliciting business, engaging in other persistent courses of conduct,
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`or deriving or attempting to derive substantial revenue and financial benefits from goods and
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`services provided to individuals residing in the State of Texas and in this District. Thus, T-Mobile
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`is subject to this Court’s specific and general personal jurisdiction under due process and the Texas
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`Long Arm Statute.
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`7.
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`Personal jurisdiction also exists specifically over T-Mobile because T-Mobile,
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`directly or through subsidiaries or intermediaries (including customers, distributors, retailers, and
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`others), subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, sells, imports,
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`advertises, or markets in the State of Texas and in this District, one or more products or services
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`that infringe the Patents-in-Suit, as described particularly below. T-Mobile has purposefully and
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`voluntarily placed one or more of its infringing products or services, as described below, into the
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`stream of commerce with the awareness and/or intent that these products or services will be
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`purchased or used by consumers in this District. T-Mobile has knowingly and purposefully
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`shipped or made available infringing products and services into and within this District through
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`an established distribution channel. These infringing products or services have been and continue
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`to be purchased or used by consumers in this District.
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`8.
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`VoIP-Pal’s claim for relief for patent infringement arises directly from the activities
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`of T-Mobile in this District.
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`9.
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`On information and belief, T-Mobile, directly and/or through its customers has
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`transacted business in this District and has committed acts of patent infringement in this District.
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`By virtue of its offices, facilities, and/or stores in this District, T-Mobile has a regular and
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`established place of business in this District. Thus, venue is proper in this District under 28 U.S.C.
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`§§ 1391 and 1400(b).
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`10.
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`T-Mobile also has submitted to jurisdiction in this District by asserting
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`counterclaims against VoIP-Pal in Civil Action No. 6:21-cv-674-ADA, which is pending in this
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`District.
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`BACKGROUND OF THE TECHNOLOGY
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`11. United States Patent No. 8,542,815 (“the ’815 patent”) entitled “Producing Routing
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`Messages for Voice Over IP Communications” was duly and legally issued by the United States
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`Patent and Trademark Office on September 24, 2013, after full and fair examination. A copy of
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`the ’815 patent is attached to this Complaint as Exhibit 1.
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`12. United States Patent No. 9,179,005 (“the ’005 patent”) entitled “Producing Routing
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`Messages for Voice Over IP Communications” was duly and legally issued by the United States
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`Patent and Trademark Office on November 3, 2015, after full and fair examination. A copy of the
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`’005 patent is attached to this Complaint as Exhibit 2.
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`13. United States Patent No. 10,218,606 (“the ’606 patent”) entitled “Producing
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`Routing Messages for Voice Over IP Communications” was duly and legally issued by the United
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`States Patent and Trademark Office on February 26, 2019, after full and fair examination. A copy
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`of the ’606 patent is attached to this Complaint as Exhibit 3.
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`14.
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`The ’815, ’005, and ’606 patents are referred to in this Complaint as the “Patents-
`
`in-Suit”.
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`15. VoIP-Pal is the sole owner and assignee of the entire right title and interest in the
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`Patents-in-Suit and has the right to sue and recover damages for any current or past infringement
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`of the Patents-in-Suit.
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`16.
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`The inventions of the Patents-in-Suit originated from breakthrough work and
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`development in the field of internet protocol communications.
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`17. VoIP-Pal has provided significant improvements to communications technology by
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`the invention of novel methods, processes and apparatuses that facilitate communications across
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`and between internet protocol based communication systems and networks, such as internally
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`controlled systems and external networks (e.g., across private networks and between private
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`networks and public networks), including the classification and routing of such communications.
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`Some of these improvements are represented in the asserted claims as explained further herein.
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`18.
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`The earliest telephone systems to receive public use within the United States
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`involved a telephone directly connected to a human operator. A portion of the phone rested on a
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`mechanical hook such that the operator was signaled when the portion was lifted from the hook.
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`A caller would then say the name of the person they wished to call to the operator. If the callee
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`was connected to the same telephone switchboard, the operator would physically pull out a cable
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`associated with the caller’s phone and plug the cable into a socket associated with the callee’s
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`telephone. If the callee was associated with a different switchboard, and thus out of reach of the
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`operator, the operator could connect the caller to an appropriate switchboard with a different
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`human operator. While this arrangement provided basic telephone service, it proved error-prone
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`(operators would sometimes connect the wrong party) and limited the number of telephone
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`connections because of the physical limits of switchboards and cable to be pulled. This basic
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`system corresponds to the introduction of a Plain Old Telephone Service (“POTS”) analog
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`connection to the operator. In these configurations, there was a dedicated, point-to-point electrical
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`connection established between the caller and the callee during a call.
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`19. Rotary dialing eventually was introduced, beginning at around the turn of the 20th
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`century, where a rotary disk was marked with numbers from zero to nine. A caller would spin the
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`wheel and a mechanical device in the telephone would cause a sequence of electrical pulses to be
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`sent to the network corresponding to the digit dialed, for example, four pulses would be sent for
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`the number four. Rather than speaking to a human operator, an electric device would count the
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`pulses and begin to route a call once an appropriate and valid sequence of digits was dialed by the
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`caller. This advancement improved the reliability of call routing and reduced the time required to
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`initiate a call. But, even so, there was a dedicated, point-to-point analog electrical connection
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`between the caller and the callee. As multiple companies entered the market of telephone service
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`and the number of customers increased, an issue emerged where a caller would be a customer of
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`one telephone company and the callee would be a customer of another. The solution to this
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`problem was to introduce trunk lines connecting one company to another.
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`20.
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`Eventually, as the number of companies continued to increase and telephone
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`services spread over much larger geographic areas, the notion of a Public Switched Telephone
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`Network (“PSTN”) emerged. The term derives from the notion, at least in part, that the dedicated
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`wires used to connect the caller and callee were “circuit-switched” to connect the two parties
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`during a call. The PSTN developed gradually into the middle of the 20th century, still built around
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`the notion of rotary dialing and POTS connections to the individual telephones. These calls
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`involved analog communications over a circuit-switched network of electrical connections which
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`assigned dedicated resources, such as switch settings and specific wires, to establish a link from
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`the caller to the callee. While a circuit-switched network call is ongoing, these dedicated resources
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`cannot be used for any other communications.
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`21.
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`The next important advancement for consumer telephone service, introduced
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`broadly during the second half of the 20th century, was the introduction of push-button telephones.
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`The rotary dial of telephones was replaced by a matrix of buttons, each labeled with a digit from
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`zero through nine along with the additions of ‘*’ and ‘#’. The underlying signaling technology
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`was called dual-tone multiple-frequency (“DTMF”) and involves two different audible tones being
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`sent simultaneously by the telephone into the telephone network. A receiver within the network
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`decoded these tones, for example, to form a sequence of digits indicating a callee’s number.
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`22. Around this same time a scheme for international telephone addressing was
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`introduced, with a numeric protocol for identifying one country from another and providing
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`country-specific routing within the destination country. The E.164 standard now documents how
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`a caller anywhere in the world can identify a telephone number at any other location. While many
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`advances, such as DTMF dialing and automated international routing, may have been originally
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`introduced via ad hoc methods, eventually they required multiple parties (companies and
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`governments) to agree on protocols to enable widespread reliable use and inter-operability among
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`different telephone communications networks. Even with all these advances, the systems still
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`relied on circuit-switched technology that dedicated resources between the caller and the callee
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`for the duration of a call. The move to take human operators out of the loop, with the introduction
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`of rotary dialing, combined with the fast increase in demand for telephone services throughout the
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`20th century, resulted in the development of automated telephone switches. These devices
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`comprised a set of input ports, each dedicated to and associated with a specific caller, and output
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`ports, each capable of being associated with a callee. A small local telephone system may have
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`had a single switch while a larger service would use a large number of switches that were
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`connected to each other. A switch from a local service provider would be connected to a trunk line
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`which then connected to an input switch of another service provider. These switches originally
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`supported analog voice calls initiated via rotary dialing and dedicated input and output ports as
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`well as physical wires for each circuit-switched call.
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`23.
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`Eventually, analog voice services were replaced within the network with digital
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`voice. Digital voice is communicated using a sequence of chunks (or packets) of data. This
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`advancement allowed physical resources to be shared among multiple calls over short bursts of
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`time. For example, a physical wire can move a packet for one call at a specific instance in time
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`and then move a packet for a totally different call subsequently, only to later return to transfer a
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`new packet for the original call. This advance is called packet-switched communications and
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`provided an important increase in network reliability and efficiency while driving down the cost.
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`However, in most situations throughout the 20th century (and often still today), the connection to
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`the end user’s physical telephone is analog. While network switches operate via digital circuitry,
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`and often comprise programmable processors executing software, they tend to be dedicated
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`special-purpose devices. The conversion between analog signals and digital encoding is typically
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`done at the point where the PSTN network switch connects to the POTS handset, for example, at
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`a device called a Class-5 telephone switch, which connects the customer POTS handset to the
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`PSTN network at a service provider’s central office.
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`24.
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`The Internet became important to consumers, via broad deployment, during the late
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`1980’s and early 1990’s. Eventually, available bandwidth and reliability increased to the point
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`where pioneers began to experiment with techniques to carry voice communications over the
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`Internet. These early efforts began to focus on techniques called Voice Over Internet Protocol
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`(VoIP) and session initiation protocol (SIP). VoIP provided a consistent set of protocols and
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`mechanisms for moving digital voice packets between two callers using digital networks such as
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`the Internet rather than existing PSTN networks. SIP provided a mechanism for establishing and
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`terminating communication sessions, such as calls between users of a VoIP service. For example,
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`a callee could register with a VoIP service so that an identifier (such as their name, email address
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`or a nickname) could be associated with the computer to which they were logged in. Eventually
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`VoIP services began to provide interoperability with the existing PSTN services. For example, the
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`company Skype allowed a user to call a PSTN number using a feature marketed as “Skype out”.
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`However, the user was required to explicitly classify the call as a PSTN call by specifying a real
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`physical telephone number. In this case, the VoIP system includes a gateway to bridge from the
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`VoIP network to the PSTN network in order to route to the physical telephone. Calls that used a
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`proprietary non-PSTN user identifier such as an email or nickname remained within the VoIP
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`network and were not routed to the PSTN network and did not connect to a POTS telephone.
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`25.
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`The advent of VoIP technology allowed customers to physically move their
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`telephones from one location to another, even from one continent to another, with no fundamental
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`change in its operation from the point of view of a caller once a connection to the Internet was
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`established. However, the integration of network gateways to route between different types of
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`networks using VoIP, for example from a VoIP caller in Europe to a PSTN callee in the United
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`States, introduced a number of new complications. The VoIP service needed to be able to
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`distinguish between callees that were within the VoIP network and those that were outside of it
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`and thus required different methods for identifying callees and routing to them depending on
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`whether the callees were within or outside the VoIP network. One way to identify callees on the
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`VoIP network was to use a predefined proprietary user identifier such as an email or nickname.
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`The VoIP service provider also needed to interpret dialed PSTN numbers in order to correctly
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`route calls to a PSTN callee. A VoIP caller had to use different types of callee identifier depending
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`on whether or not the destination (callee) they were calling was within the VoIP network or not.
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`The caller’s choice of the type of callee identifier thus specified the network of the destination to
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`be called. However, the Patents-in-Suit disclose and claim a distinct manner of call routing.
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`26. Digifonica, a wholly owned subsidiary of patent owner VoIP-Pal, starting in 2004,
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`eventually came to employ over a dozen top professionals (e.g., software developers, system
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`administrators, QA/test analysts) including three Ph.D.’s with engineering backgrounds, to
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`develop innovative software solutions for communications. Digifonica spent over $15,000,000
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`researching, developing, and testing a communication solution capable of seamlessly integrating
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`a private voice-over-IP (“VoIP”) communication network with an external network (e.g., the
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`“public switched telephone network” or “PSTN”), by bridging the disparate protocols, destination
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`identifiers and addressing schemes used in the two networks. By the mid-2000’s, Digifonica had
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`successfully tested intra- and inter-network communications (i.e., communications within the
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`private, multi-node Digifonica system and between the Digifonica system and the PSTN) by
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`implementing high-capacity communication nodes across three geographic regions, including
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`actual working communication nodes in Vancouver (Canada) and London (UK). Digifonica’s
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`R&D efforts led to a number of patent grants, including the Patents-in-Suit.
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`27.
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`Prior to the ’815 patent, private branch exchange (PBX) systems typically enabled
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`users to call destinations internal to the PBX by dialing a short extension (i.e., “private number”)
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`and destinations external to the PBX on the public switched telephone network (PSTN) by dialing
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`a “public number.” Such PBX systems relied on a user-specified classification of the dialed
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`number to interpret the number and route the call. For example, it was a well-known practice to
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`require that a user placing a call to the public network dial a predefined prefix, such as “9”, to
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`indicate that subsequent digits were to be interpreted as a public PSTN number. If no prefix was
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`dialed, the dialed digits were to be interpreted as a private PBX extension. The number alone, as
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`dialed, dictated how the call was routed. Thus, the user made an affirmative decision when placing
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`a call as to whether the call would be routed over a public or private network. Some PBX systems
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`had Direct Inward Dialing (DID) features to allow incoming calls from the PSTN to be routed
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`directly to a specific extension or phone within the organization’s Private Branch Exchange (PBX)
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`system. Typically, an organization that operated its own PBX would buy a block of PSTN
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`numbers from a PSTN service provider (e.g., AT&T) such that if any of those numbers were
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`dialed, they were forwarded by AT&T to the PBX, which in turn, would distribute the call to the
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`appropriate extension based on the PBX configuration. This enabled the direct inward dialing of
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`calls from the PSTN to PBX users, with the PBX administrator assigning specific PSTN phone
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`numbers to particular local (PBX) extensions, whereas other PBX extensions did not necessarily
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`have dedicated PSTN numbers. Conventionally, however, outgoing calls from PBX users to
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`PSTN numbers were signaled by the PBX users dialing a certain prefix (e.g., “9”), thus PBX users
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`specified routing over the PSTN by dialing this prefix.
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`28. Digifonica’s system employed an approach that was fundamentally different from
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`traditional PBX’s: it did not rely on a caller-specified classification (e.g., a prefix) to distinguish
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`private network calls from PSTN calls. Rather, Digifonica provided flexible, user-specific dialing
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`features and could decouple the type of number being called from the manner in which the call
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`would be handled. For example, even if a subscriber dialed a public PSTN number, Digifonica’s
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`system could determine that the call should be routed to an internal destination on its private
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`network, thus allowing the advantages of private network calling even if callers were unaware that
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`the call recipient (“callee”) was a Digifonica system subscriber. If, on the other hand, the PSTN
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`number represented a destination on an external network (e.g., the public network), the Digifonica
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`system facilitated the routing of the call to the destination through a gateway. Incoming calls from
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`the PSTN were also automatically routed to private network subscribers assigned a PSTN number.
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`29. VoIP-Pal’s/Digifonica’s
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`technology
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`and patents
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`represent
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`fundamental
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`advancements to Internet Protocol (“IP”) based communication, including improved functioning,
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`classification, routing and reliability of Voice-over-IP (VoIP) and IP-based transmission of audio,
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`video, photographs, messages and mixed media, as well as improved interoperability of IP-based
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`private communication networks with external networks, such as the public switched telephone
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`network (PSTN), interconnected with a private communication network via one or more gateways.
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`The technology also provided novel methods of routing calls within the private network itself.
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`30.
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`The Patents-in-Suit provide, inter alia, improvements in routing controllers,
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`processes, networks and systems. Several illustrative examples of such improvements are briefly
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`described below, though the patented invention is not limited to these improvements or examples.
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`31.
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`The public switched telephone network (PSTN) connected callers through nodes
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`such as central offices or exchanges. Because these nodes were limited to providing services only
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`to subscribers in a “local calling service area,” they required callers to place calls in a specific
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`manner, e.g., by requiring the use of certain dialing patterns and conventions associated with that
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`local area. See, e.g., the ’815 patent at 1:29-39. For example, it was known to a person of skill in
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`the art (POSITA) in the field of the invention that PSTN nodes conventionally required PSTN
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`callers to dial in a manner compatible with a local numbering plan (e.g., in the U.S., a plan
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`consistent with the “North American Numbering Plan” or “National Numbering Plan,” in use by
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`AT&T as early as about the 1940’s and further developed in later years) as well as to dial in a
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`manner compatible with
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`international standards such as
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`those of
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`the International
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`Telecommunications Union (ITU) Telecommunications Standardization Sector (ITU-T). See ’815
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`patent at 18:23-31. For example, it is known in the field of telephony that early numbering plans
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`assigned an “area code” of 312 for calling Illinois, which remains in use even today as an area
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`code for Chicago. To take another example, the ITU designates “44” as a “country code” for
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`calling the United Kingdom. Id. at Fig. 12 (“County Code” attribute for London user is “44”).
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`32.
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`Large organizations were able to avoid PSTN dialing constraints for internal calls
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`by using private branch exchanges (PBXs) and private numbering plans for their internal private
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`telephone networks. However, these PBXs also needed to provide caller access to the PSTN. See
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`’815 patent at 1:22-28. As Andy Valdar has explained in his textbook, “Businesses which have
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`more than a few telephones use a private branch exchange system, known as a PBX, to provide
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`call connections between each telephone (which become ‘extensions’) and links into the PSTN...
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`The PBX is really a small version of the PSTN exchanges, typically ranging in sizes from 10 up
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`to 5,000 extensions. A private numbering scheme is required to enable extension to extension
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`dialing, also special codes (e.g. ‘dial 9’) are required to enable calls to be made to the PSTN. [...]
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`In the case where a company extends over two or more sites (e.g. office or factory buildings) the
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`PBXs on each site can be linked by private circuits, thus enabling calling between all the
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`extensions. This is known as a ‘private corporate network’ (or just ‘private network’). In this case
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`the private numbering scheme extends across all the PBXs and usually each PBX is linked to the
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`PSTN.” (See Valdar, Andy, Understanding Telecommunications Networks, The Institution of
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`Engineering and Technology, London, UK, 2006, p. 38 (emphasis added)).
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`33.
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`It was well-understood, routine and conventional for PBXs to require users to dial
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`a special code (e.g., a prefix digit of “9”) if they wanted to place a call on the PSTN, as noted by
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`Valdar and numerous other sources. For example, one telecom dictionary distinguishes between
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`dialing an “internal PBX station number” and an “external number,” wherein in the latter case,
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`“the user must dial an access code in order to gain access to an external trunk connected to the
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`public switched telephone network (PSTN)... The conventional access code is nine (9) in the
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`United States and Canada, and zero (0) in most other countries”. (See Ray Horak, Webster’s New
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`World Telecom Dictionary, Wiley Publishing, Inc., Indianapolis, Indiana, 2008, p.133 [emphasis
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`added]). To take another example, U.S. Patent No. 3,725,596 to Maxon et al. (“Maxon”), filed in
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`1971, discloses an discloses an early private branch exchange (PBX) having equipment for
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`automatically generating and transmitting calling station and trunk number information to a
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`central office on outgoing calls. Maxon indicates that “a calling party at station ST10... dials a
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`prefix digit, such as the conventional prefix digit 9, to initiate an outgoing call to the central office.
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`The digit 9 is... detected by the dial 9 detector 152. Upon the detection of this digit, the register
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`control circuit 153 advises common control that the digit 9 has been dialed for a central office
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`call.” [emphasis added]. Maxon at 9:66-10:6; see also Fig. 1B (152), 8:58-68, 9:21, 9:38-40, 13:3-
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`6, 14:6-7 and at 14:59. Webster’s New World Telecom dictionary and Maxon both confirm that
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`it was considered “conventional” to use a prefix digit such as “9” to place a PSTN call from a
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`PBX. The Patents-in-Suit eschewed such well-understood, routine and conventional approaches
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`to integrating private and public networks.
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`34. A POSITA, upon review of the Patents-in-Suit, would have understood that the
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`claimed inventions are inherently computer-based and do not merely implement or automate long-
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`standing human processes such as the operation of historical switchboard operators. The POSITA
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`would further appreciate that the asserted claims of the Patents-in-Suit are necessarily rooted in
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`computer technology for the operation of communication networks, and provide technical
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`improvements to overcome certain technical limitations of prior art routing controllers, processes,
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`systems and networks. Below are examples of improvements and inventive concepts disclosed
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`and/or claimed by the Patents-in-Suit are discussed. A POSITA would appreciate that not every
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`asserted claim necessarily embodies every improvement or inventive aspect discussed. Also,
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`Case 6:24-cv-00298-DC Document 1 Filed 05/30/24 Page 15 of 54
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`these examples are not exhaustive and do not necessarily capture every feature or benefit disclosed
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`or claimed. See also Exhibit 4 (Declaration of Dr. Danijela Cabric) (“Cabric Declaration”),
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`incorporated by reference.
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`35.
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`Prior art communication systems required users to place a call by using a specific
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`callee identifier format or by following certain dialing conventions with no opportunity for
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`defining a user-specific manner of placing calls. For example, as discussed above, PSTN nodes
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`were typically limited to supporting only the dialing conventions of their local calling service area,
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`processed calls locally (see ’815 patent at 1:29-39), and did not support user-specific calling. The
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`technology disclosed in the Patents-in-Suit overcomes such technical limitations and supports
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`user-specific calling, e.g., calling styles from any continent or country based on the application of
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`user-specific attributes and network classification criteria to callee identifiers to route a call. It is
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`unnecessary for the user to do anything special to “trigger” such user-specific call processing. See,
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`e.g., ’815 patent at 18:5-67 (disclosing storing a user-specific profile in association with each
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`subscriber/user capable of supporting numerous global styles of dialing), and Figs. 8A-8D
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`(disclosing steps for processing a routing request based in part on a user-specific profile). By
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`evaluating a called party identifier based on profile settings or “attributes” associated with the
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`calling party, the technology provides an individually customizable manner of initiating a
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`communication to a destination party. To be clear, it is not merely a calling party’s identifier (i.e.,
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`“caller ID” or “caller identifier”) that is used to evaluate the called party’s identifier (e.g., “callee
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`identifier”); rather, a caller-specific profile, identifying caller-specific parameters/attributes, is
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`used to evaluate the called party’s identifier, to determine the routing destination and to identify
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`the appropriate network infrastructure for effecting the communication. A POSITA would
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`recognize, in light of the patent specification, that this approach is capable of fulfilling various
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`Case 6:24-cv-00298-DC Document 1 Filed 05/30/24 Page 16 of 54
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`individual service preferences among users for initiating communications (e.g., any desired PSTN
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`dialing style, unconventional dialing styles, and even use of special callee identifiers such as
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`usernames). See id. at 18:55-67; 19:50-20:8; 21:17-22:33. To give just one illustrative example,
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`the profiles of two different users may specify different ways of dialing an international call (e.g.,
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`an “IDD” attribute in two different user’s profiles may differ: see id., “IDD” attributes in the user
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`profiles shown in Figs. 11 and 12 are set to “011” and “00”, respectively; compare blocks 257-
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`259 in Fig. 8B). Moreover, system-stored settings associated with each user (e.g., profile
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`attributes) could be set differently than in the above example or further re