Apple Inc.,
`v.
`Uniloc 2017 LLC
`
`IPR2019-00700 (U.S. Patent No. 8,406,116)
`IPR2019-00701 (U.S. Patent No. 8,018,877)
`
`Patent Owner’s Demonstrative Exhibits
`
`Before SALLY C. MEDLEY, JEFFREY S. SMITH,
`and JOHN F. HORVATH,
`Administrative Patent Judges.
`May 21, 2020
`
`DEMONSTRATIVE – NOT EVIDENCE
`
`
`v.
`Uniloc 2017 LLC
`
`IPR2019-00700 (U.S. Patent No. 8,406,116)
`IPR2019-00701 (U.S. Patent No. 8,018,877)
`
`Patent Owner’s Demonstrative Exhibits
`
`Before SALLY C. MEDLEY, JEFFREY S. SMITH,
`and JOHN F. HORVATH,
`Administrative Patent Judges.
`May 21, 2020
`
`DEMONSTRATIVE – NOT EVIDENCE
`
`
`
`The ’116 patent (IPR2019-00700)
`
`1. A method of initiating a data exchange session among mobile
`devices, the method comprising:
`receiving, at a server, a request from an initiating mobile device to
`allocate a session identifier to use in a data exchange session
`with a participating mobile device, wherein the session identifier
`comprises a network port number of the server;
`transmitting, from the server, the session identifier to the initiating
`mobile device, wherein the initiating mobile device uses a page-
`mode messaging service to assist in communicating the session
`identifier to the participating mobile device and wherein the
`page-mode messaging service utilizes a unique identifier to
`locate the participating mobile device;
`establishing, at the server, connections with the initiating mobile
`device and the participating mobile device based on the session
`identifier; and
`facilitating, at the server, the data exchange session between the
`initiating mobile device and the participating mobile device.
`
`2
`
`
`
`The ’877 patent (IPR2019-00701)
`
`1. A method of initiating a data exchange session among
`mobile devices, the method comprising:
`transmitting a request to a server to allocate a network
`address and port associated with the server to use in a
`data exchange session with a participating mobile
`device;
`receiving the network address and port from the server;
`using a page-mode messaging service to assist in
`communicating the network address and port to the
`participating mobile device, wherein the page-mode
`messaging service utilizes a unique identifier to locate
`the participating mobile device; and
`participating in the data exchange session with the
`participating mobile device through the server, wherein
`the participating mobile device has established a
`connection with the server using the network address
`and port.
`
`3
`
`
`
`Fig. 3 of Challenged ’116 & ’877 Patents
`
`4
`
`
`
`Petitioner Has Failed to Meet its Burden
`IPR2019-00700 and -701 present virtually identical grounds:
`
` In Ground 1, Petitioner at least fails to establish obviousness based on
`its exclusive reliance on Kirmsefor “[receiving, at a server /an input
`port to receive] a request from an initiating mobile device to allocate a
`session identifier to use in a data exchange session with a
`participating mobile device, wherein the session identifier comprises
`a network port number of the server.”
` In Ground 2, Petitioner at least fails to prove Chambers and RSIP
`discloses “[receiving, at a server,/an input port to receive] a request
`from an initiating mobile device to allocate a session identifier to use
`in a data exchange session with a participating mobile device, wherein
`the session identifier comprises a network port number of the server.”
` In Ground 3, Petitioner at least fails to prove it would have been
`obvious to combine Cordenierand TURN in the manner proposed.
`
`5
`
`
`
`Example Deficiencies of Ground 1
`
` Petitioner fails at least to prove that Kirmse’sdisclosure of serving a
`game based on already existing connection detailsrenders obvious
`the distinguishable requirement, “receiving a request to allocate a
`session identifier.”
` Petitioner’s theory is keyed to an incorrect claim construction—
`i.e., “receiving a request to allocate a session identifier” requires,
`instead, providing existing connection details for accessing an
`already active game (i.e., without allocatinganything).
` Petitioner cites nothing in Kirmseto support the speculation
`(advanced for the first time in the Reply) that merely starting a
`game necessarily comprises a server receiving a request to
`allocate a session identifier.
` Petitioner cannot cure these tacitly acknowledged deficiencies
`by its improper attempt to introduce in its Reply entirely new
`claim construction argument and extrinsic evidence it could
`have, but failed to, present in the Petition itself.
`
`6
`
`
`
`Example Deficiencies of Ground 2
`
` Petitioner at least fails to prove that either Chambersor RSIP
`discloses a server receiving the specific allocation request claimed.
` The Petition acknowledges Chambers at least fails to disclose a
`request for a server to allocate a session identifier comprising a
`network port number of the server.
` RSIP does not cure the conceded deficiencies of Chambers.
`Petitioner erroneously alleges the RSIP’s Gateway and Host(s)
`map onto the claimed “server” and “mobile device” (respectively).
`For the “ASSIGN_REQUEST_RSAP-IP” message, however, RSIP
`discloses it is the requesting Host—and not the Gateway—that
`“specifies two addresses and two port parameters,” including
`“local address and port(s)” of the requesting Host and “the remote
`address and port(s) that will be contacted.”
`
`7
`
`
`
`Example Deficiencies of Ground 2
`
` Petitioner at least fails to prove that either Chambersor RSIP
`discloses a server receiving the specific allocation request claimed.
` Petitioner purports to rely on RSIP’s “no remote flow policy.”
`But under this policy, “the RSIP gateway MUST use ‘don’t care’
`values for the remote address and ports parameters. Ex. 1013 p.
`27 (all caps original). Moreover, under this policy, Hosts use
`“addressing parameters” to communicate with each other peer-to-
`peer, “without explicitly notifying the gateway.” Id. at 9.
` Petitioner’s Reply improperly departs from the Petition by citing
`to different portions of RSIP as newly alleged support, thereby at
`least tacitly admitting the original citations in the Petition do not
`sufficiently support Petitioner’s theory.
`
`8
`
`
`
`Example Deficiencies of Ground 3
`
` Petitioner at least fails to prove it would have been obvious to combine
`Cordenierand TURN in the manner proposed.
` The proposed modification of Cordenierwould render it inoperable
`for its explicitly stated purpose: “It is an object of the invention to
`provide an architecture for peer-to-peer communication between a
`first and second terminal using a data network, but without the
`need for a common exchange server in the data network.” (¶ 6).
` TURN is purportedly cited for using an intermediate relay server to
`forward communications between the terminals. This supposed
`teaching would vitiate Cordenier’sexpressly stated purpose.
`Petitioner’s Declarant, even with a belated and improper second
`declaration, does not attempt to address the fact that the proposed
`modification is contrary to Cordenier’sstated purpose.
` Petitioner’s bleated reliance in its Reply on use of a Network Address
`Translator (“NAT”) fails to recognize that TURN distinguishes its
`TURN Server and NAT as distinct devices with distinct purposes.
`Petitioner cannot advance new mappings in its Reply.
`
`9
`
`
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