IPR2016-01321 Petition
`Patent 6,442,261
`
`Filed on behalf of: Unified Patents Inc.
`By:
`Jeff Toler
`
`Toler Law Group, PC
`
`8500 Bluffstone Cv. Suite A201
`
`Austin, TX 78759
`Telephone: (512) 327-5515
`E–mail:
`jtoler@tlgiplaw.com
`
`Jonathan Stroud
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC, 20009-5728
`Telephone: 650-999-0455
`E-mail:
`jonathan@unifiedpatents.com
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`VOXATHON LLC
`Patent Owner
`____________
`
`IPR2016-01321
`
`U.S. Patent 6,442,261
`Call Recovery Method and Apparatus for an Attendant Telephone Set
`
`
`
`
`
`PETITION FOR INTER PARTES REVIEW OF
`ALL CLAIMS 1–6 OF U.S. PATENT 6,442,261
`
`i
`
`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`
`
`
`II. 
`
`TABLE OF CONTENTS
`
`I.  MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(B) ........................ - 1 - 
`A. 
`REAL PARTY IN INTEREST ........................................................ - 1 - 
`B. 
`RELATED MATTERS .................................................................... - 1 - 
`C. 
`PAYMENT OF FEES ...................................................................... - 2 - 
`D.  DESIGNATION OF COUNSEL ..................................................... - 3 - 
`E. 
`SERVICE INFORMATION ............................................................ - 3 - 
`F. 
`POWER OF ATTORNEY ............................................................... - 3 - 
`REQUIREMENTS FOR INTER PARTES REVIEW ................................. - 3 - 
`A.  GROUND FOR STANDING ........................................................... - 3 - 
`B. 
`OVERVIEW OF CHALLENGE AND RELIEF REQUESTED ..... - 4 - 
`1. 
`Prior Art References............................................................... - 4 - 
`2. 
`Grounds for Challenge ........................................................... - 4 - 
`III.  OVERVIEW OF THE ’261 PATENT ....................................................... - 5 - 
`A. 
`SUMMARY OF THE ALLEGED INVENTION ............................ - 5 - 
`B. 
`LEVEL OF ORDINARY SKILL IN THE ART ............................. - 7 - 
`C. 
`PROSECUTION HISTORY ............................................................ - 7 - 
`D. 
`CLAIM CONSTRUCTION ............................................................. - 8 - 
`IV.  SPECIFIC GROUNDS FOR REVIEW ..................................................... - 8 - 
`A.  Ground 1: Coyne anticipates claims 1 and 4 .................................... - 9 - 
`1. 
`Overview of Coyne ................................................................ - 9 - 
`
`ii
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`

`
`B. 
`
`IPR2016-01321 Petition
`Patent 6,442,261
`2. 
`Claim Chart for Ground 1 .................................................... - 12 - 
`3. 
`Claim 1 is anticipated by Coyne .......................................... - 12 - 
`4. 
`Claim 4 is anticipated by Coyne .......................................... - 23 - 
`Ground 2: Coyne in view of Rust renders claims 2–3 and 5–6
`obvious ........................................................................................... - 30 - 
`1. 
`Overview of Rust ................................................................. - 30 - 
`2. 
`A person having ordinary skill in the art would have
`combined Coyne with Rust. ................................................. - 31 - 
`3. 
`Claim Chart for Ground 2 .................................................... - 32 - 
`4. 
`Claim 2 is obvious over Coyne in view of Rust ................... - 32 - 
`5. 
`Claim 3 is obvious over Coyne in view of Rust ................... - 35 - 
`6. 
`Claim 5 is obvious over Coyne in view of Rust ................... - 36 - 
`7. 
`Claim 6 is obvious over Coyne in view of Rust ................... - 38 - 
`Ground 3: Claims 1 and 4 are obvious over Burke in view of
`Baxter ............................................................................................. - 39 - 
`1. 
`Overview of Burke ............................................................... - 39 - 
`2. 
`Overview of Baxter .............................................................. - 39 - 
`3. 
`A Person having ordinary skill in the art would have
`combined Burke with Baxter. .............................................. - 40 - 
`4. 
`Claim Chart for Ground 3 .................................................... - 41 - 
`5. 
`Claim 1 is obvious over Burke in view of Baxter ................ - 41 - 
`6. 
`Claim 4 is obvious over Burke in view of Baxter ................ - 47 - 
`D.  Ground 4: Burke in view of Baxter and Rust renders claims 2–3
`and 5–6 obvious .............................................................................. - 53 - 
`1. 
`A person having ordinary skill in the art would have
`combined Burke and Baxter with Rust. ............................... - 53 - 
`
`C. 
`
`iii
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`

`
`2. 
`3. 
`
`IPR2016-01321 Petition
`Patent 6,442,261
`Claim Chart for Ground 4 .................................................... - 54 - 
`Claim 2 is Obvious over Burke in view of Baxter and
`Rust ....................................................................................... - 54 - 
`Claim 3 is Obvious over Burke in view of Baxter and
`Rust ....................................................................................... - 57 - 
`Claim 5 is Obvious over Burke in view of Baxter and
`Rust ....................................................................................... - 58 - 
`Claim 6 is Obvious over Burke in view of Baxter and
`Rust ....................................................................................... - 60 - 
`CONCLUSION ......................................................................................... - 61 - 
`
`
`5. 
`
`6. 
`
`4. 
`
`V. 
`
`iv
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`

`
`
`
`Exhibit No. Description
`1001
`U.S. Patent 6,442,261 (filed on Jan. 28, 1999)
`1002
`U.S. Patent 4,631,364 (“Coyne”) (filed on Feb. 23, 1984; issued
`on Dec. 23, 1986)
`U.S. Patent 5,136,637 (“Rust”) (filed on Jan. 22, 1990; issued on
`Aug. 4, 1992)
`U.S. Patent 6,597,785 (“Burke”) (filed on Oct. 15, 1998; issued
`on Jul. 22, 2003)
`U.S. Patent 4,741,026 (“Baxter”) (filed on May 29, 1986, issued
`on Apr. 26, 1988)
`Petitioner’s Voluntary Interrogatory Responses
`Declaration of Joel R. Williams (“Williams Decl.” or “Williams”)
`Curriculum Vitae of Joel R. Williams
`
`1006
`1007
`1008
`
`1003
`
`1004
`
`1005
`
`IPR2016-01321 Petition
`Patent 6,442,261
`
`EXHIBIT LIST
`
`
`v
`
`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`
`I. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(B)
`
`A. REAL PARTY IN INTEREST
`
`Pursuant to 37 C.F.R. § 42.8(b)(1), Unified Patents Inc. (“Unified” or
`
`“Petitioner”) is the real party-in-interest and further certifies that no other party
`
`exercised control or could exercise control over Unified’s participation in this
`
`proceeding, the filing of this petition, or the conduct of any ensuing trial. In this
`
`regard, Unified has submitted voluntary discovery. See EX1006 (Petitioner’s
`
`Voluntary Interrogatory Responses).
`
`B. RELATED MATTERS
`
`U.S. Patent 6,442,261 (“the ’261 Patent” (EX1001)) is assigned to Voxathon
`
`LLC (“Voxathon” or “Patent Owner”). On Apr. 29, 2015, Voxathon filed lawsuits
`
`asserting the ’261 Patent in the following cases in the Eastern District of Texas:
`
`Voxathon v. Alpine Electronics of America, Inc., No. 2-15-cv-00562
`
`Voxathon v. American Honda Motor Co., Inc., No. 2-15-cv-00563
`
`Voxathon v. FCA US LLC, No. 2-15-cv-00564
`
`Voxathon v. Ford Motor Co., No. 2-15-cv-00565
`
`Voxathon v. General Motors Co., No. 2-15-cv-00566
`
`Voxathon v. Hyundai Motor America, No. 2-15-cv-00567
`
`Voxathon v. Jaguar Land Rover North America, LLC, No. 2-15-cv-00568
`
`Voxathon v. Nissan North America Inc., No. 2-15-cv-00569
`
` - 1 -
`
`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`Voxathon v. Pioneer Electronics (USA) Inc., No. 2-15-cv-00570
`
`Voxathon v. Subaru of America, Inc., No. 2-15-cv-00571
`
`Voxathon v. Toyota Motor Sales, USA, Inc., No. 2-15-cv-00572
`
`Voxathon v. Volkswagen Group of America, Inc., No. 2-15-cv-00573.
`
`The suits against Alpine Electronics, American Honda, Ford, General
`
`Motors, Jaguar Land Rover, Pioneer, and Volkswagen were dismissed prior to Jan.
`
`21, 2016. On Jan. 21, 2016, Judge Rodney Gilstrap issued a Memorandum Opinion
`
`and Order granting Hyundai’s, Toyota’s, and Subaru’s Motions to Dismiss, finding
`
`that the claims of the ’261 Patent were not patent-eligible subject matter under 35
`
`U.S.C. § 101, and terminating the suits against the remaining defendants (FCA,
`
`Hyundai, Nissan, Subaru, and Toyota) pending appeal. Voxathon appealed the
`
`Memorandum Opinion and Order to the Federal Circuit on February 22, 2016, and
`
`the appeal (Voxathon v. FCA US LLC, case no. CAFC-16-1614) is pending.
`
`C. PAYMENT OF FEES
`
`This Petition for inter partes review of Claims 1–6 of the ’261 Patent is
`
`accompanied by a payment of $23,000 in accordance with 37 C.F.R. § 42.15.
`
`Thus, this Petition meets the fee requirements under 35 U.S.C. § 312(a)(1).
`
` - 2 -
`
`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`
`D. DESIGNATION OF COUNSEL
`
`Lead Counsel for Petitioner is Jeff Toler (Reg. No. 38,342), of Toler Law
`
`Group, PC. Back-up Counsel are Aakash Parekh (Reg. No. 63,536), of Toler Law
`
`Group, PC, and Jonathan Stroud (Reg. No. 72,518), of Unified.
`
`E. SERVICE INFORMATION
`
`As identified in the attached Certificate of Service, a copy of this Petition, in
`
`its entirety, is being served to the address of the attorney of record in the United
`
`States Patent & Trademark Office (USPTO) for the ’261 Patent and to the
`
`Plaintiff’s attorney of record in the above-described suits involving the ’261
`
`Patent. Petitioner may be served at the offices of their counsel, Jeff Toler, and
`
`consents to electronic service at jtoler@tlgiplaw.com, aparekh@tlgiplaw.com, and
`
`jonathan@unifiedpatents.com.
`
`F. POWER OF ATTORNEY
`
`Powers of attorney are being filed with the designation of counsel in
`
`accordance with 37 C.F.R. § 42.10(b).
`
`II. REQUIREMENTS FOR INTER PARTES REVIEW
`
`A. GROUND FOR STANDING
`
`Petitioner certifies pursuant to 37 C.F.R. § 42.104(a) that the patent for
`
`which review is sought is available for inter partes review. Petitioner is not barred
`
` - 3 -
`
`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`or estopped from requesting an inter partes review challenging the patent claims
`
`on the grounds identified in this Petition.
`
`B. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.22(a)(1) and 37 C.F.R. § 42.104(b), Petitioner
`
`challenges claims 1–6 of the ’261 Patent.
`
`1.
`
`Prior Art References
`
`The ’261 Patent issued from a patent application filed prior to enactment of
`
`the America Invents Act (“AIA”). Accordingly, a pre-AIA statutory framework
`
`applies. The following references are pertinent to the grounds of unpatentability
`
`explained below:
`
`i. U.S. Patent 4,631,364 (“Coyne” (EX1002)) (filed on Feb. 23, 1984;
`
`issued on Dec. 23, 1986). Coyne is prior art under 35 U.S.C. § 102(b).
`
`ii. U.S. Patent 5,136,637 (“Rust” (EX1003)) (filed on Jan. 22, 1990;
`
`issued on Aug. 4, 1992). Rust is prior art under 35 U.S.C. § 102(b).
`
`iii. U.S. Patent 6,597,785 (“Burke” (EX1004)) (filed on Oct. 15, 1998;
`
`issued on Jul. 22, 2003). Burke is prior art under 35 U.S.C. § 102(e).
`
`iv. U.S. Patent 4,741,026 (“Baxter” (EX1005)) (filed on May 29, 1986,
`
`issued on Apr. 26, 1988). Baxter is prior art under 35 U.S.C. § 102(b).
`
`2. Grounds for Challenge
`
`This Petition, supported by the Expert Declaration of Joel R. Williams
`
` - 4 -
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`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`(EX1007), requests cancellation of challenged claims 1–6 as unpatentable under 35
`
`U.S.C. § 102 and/or § 103. See 35 U.S.C. § 314(a).
`
`III. OVERVIEW OF THE ’261 PATENT
`
`A. SUMMARY OF THE ALLEGED INVENTION
`
`The ’261 Patent recognizes that it was well known to identify the telephone
`
`number of a calling party, such as by using “[c]onventional caller identification
`
`techniques.” EX1001, at 4:27–39. The ’261 Patent also recognizes that it was
`
`known that “[b]y pressing [a] sequence of buttons the telephone number of a
`
`calling party is automatically dialed and displayed[.]” Id. at 1:28–30.
`
`The ’261 Patent is directed to a call recovery system for an attendant
`
`telephone set and a method for using the same to recover a lost calling party, e.g.,
`
`an inadvertently dropped call, by pushing one of multiple call appearance buttons
`
`on the set associated with an incoming call to redial the number automatically. Id.
`
`at Abstract; 1:64–2:22. The telephone set receives multiple incoming calls and
`
`assigns a call to the next available call appearance button, preferably in sequential
`
`order. Id. at Abstract. An identified telephone number associated with each
`
`incoming call is stored in a memory device. Id. In response to an attendant’s
`
`selection of one of the call appearance buttons, the stored telephone number of the
`
`calling party of the incoming call assigned to the selected call appearance button is
`
`automatically redialed. Id. Accordingly, an attendant may automatically redial the
`
` - 5 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`telephone number of the calling party of any incoming call that is currently
`
`assigned to a call appearance button on the attendant’s telephone set. Id. at 8:1–5.
`
`FIG. 1 (annotations added below) of the ’261 Patent depicts the attendant
`
`telephone set 10 including five consecutively numbered call appearance buttons
`
`11–15 and a display 5:
`
`display
`
`attendant
`telephone
`set
`
`call
`appearance
`buttons
`
`As explained in further detail below, the references cited herein describe,
`
`prior to the effective filing date of the ’261 Patent, technologies that enable a
`
`telephone set to receive multiple incoming calls, store the telephone number of a
`
`
`
` - 6 -
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`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`calling party of an incoming call, assign the incoming call to a next available call
`
`appearance button, and enable a user to select the call appearance button to
`
`automatically redial the stored telephone number of the calling party.
`
`B. LEVEL OF ORDINARY SKILL IN THE ART
`
`A person of ordinary skill in the art for the ’261 Patent would have a degree
`
`in electrical engineering, computer science, or a related subject or the equivalent,
`
`and would also have at least three years of experience working with telephone
`
`devices,
`
`telecommunications, and call processing software. See EX1007
`
`(Williams), at ¶ 13.
`
`C. PROSECUTION HISTORY
`
`The ’261 Patent includes 6 claims and corresponds to U.S. Patent
`
`Application No. 09/239,435 (“’435 Application”), filed on January 28, 1999 and
`
`including 6 originally filed claims.
`
`The USPTO issued a Non-Final Office Action on May 31, 2000 rejecting
`
`claims 1–6 under 35 U.S.C. § 103(a). The applicant of the ’435 Application filed a
`
`Response to the Non-Final Office Action on June 22, 2000. The Response
`
`emphasized that the claimed invention identified, stored, and automatically
`
`redialed the number of a calling party of an incoming call rather than an outgoing
`
`telephone number of a party being called.
`
`A Notice of Allowance was mailed on September 6, 2000. However, the
`
` - 7 -
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`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`three-month statutory period for payment of the issue fee lapsed and a Notice of
`
`Abandonment was mailed on January 23, 2001. On February 23, 2001, the
`
`applicant filed a Petition to Withdraw Notice of Abandonment on the grounds that
`
`the Notice of Allowance mailed September 6, 2000 was not received. The Office
`
`granted the Petition on December 23, 2001, and a second Notice of Allowance was
`
`mailed March 22, 2002. The issue fee was paid on June 26, 2002 and the ’261
`
`Patent issued on August 27, 2002.
`
`D. CLAIM CONSTRUCTION
`
`A patent claim of an unexpired patent during inter partes review receives the
`
`broadest reasonable construction in light of the specification of the patent in which
`
`it appears. 37 C.F.R. § 42.100(b); Cuozzo Speed Techs., LLC v. Lee, 579 U.S. ___
`
`(2016). In the following, claim terms are given their broadest reasonable
`
`interpretation in light of the specification. 37 C.F.R. § 42.100(b); Cuozzo, 579 U.S.
`
`___ (2016).
`
`IV. SPECIFIC GROUNDS FOR REVIEW
`
`Petitioner submits that the grounds raised in the following sections are
`
`independent and meaningfully distinct. For example, Coyne, Rust, and Baxter are
`
`prior art under 35 U.S.C. § 102(b), while Burke is prior art under 35 U.S.C.
`
`§ 102(e). Thus, Patent Owner would not be permitted to swear behind Coyne, Rust,
`
`or Baxter.
`
` - 8 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`
`A. Ground 1: Coyne anticipates claims 1 and 4
`
`1. Overview of Coyne
`
`Coyne discloses a station set originating and terminating telephone calls
`
`(EX1002, at Abstract), and FIG. 2 (annotations added below) of Coyne depicts a
`
`station set having a predetermined number (e.g., 10) of call appearance buttons:
`
`call appearance buttons
`
`FIG. 7 (annotations added below) of Coyne depicts processing incoming
`
`calls, including assigning a call appearance button and storing the incoming caller
`
`
`
`ID:
`
` - 9 -
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`

`
`IPR2016-01321 Petition
`Patent 6,442,261
`
`receive incoming call
`
`assign incoming call to next available CA button
`
`store caller ID of calling party at assigned CA button
`
`
`
`In FIG. 8 (annotations added below), Coyne depicts initiating a call:
`
` - 10 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`
`get caller ID from
`pressed button
`
`automatically dial
`telephone number
`
` - 11 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`
`2.
`
`Claim Chart for Ground 1
`
`As evidenced in the claim chart in Appendix A of Williams and further
`
`described herein, Coyne discloses each and every element of claims 1 and 4 of the
`
`’261 Patent. See EX1007 (Williams), at ¶ 24. Further, while Petitioner has
`
`presented Coyne as an anticipatory reference for claims 1 and 4, Petitioner submits
`
`that any differences the Board may perceive between Coyne and claims 1 or 4 of
`
`the ’261 Patent would have been obvious to a person of skill in the art in view of
`
`the disclosure of Coyne (i.e., Coyne serves as the basis for a single-reference
`
`obviousness finding with respect to claims 1 and 4 of the ’261 Patent).
`
`3.
`
`Claim 1 is anticipated by Coyne
`
`a. “method for recovering calls using an attendant telephone set
`having a predetermined number of call appearance buttons”
`Coyne discloses “a communication system and operating method wherein
`
`the manner in which all telephone calls are displayed at a station set allows
`
`uniform user operations to originate and terminate those calls.” EX1002, at
`
`Abstract (emphasis added). At FIG. 2, the station set is depicted having “10
`
`general call appearance (CA) buttons and 24 feature function (FF) buttons” Id. at
`
`5:10–12 (emphasis added). Coyne also discloses that “[w]hen a call arrives, 700,
`
`the call type and call identification are known … The system controls the visual
`
`display on LED status for that [call appearance] button, sets it to flashing, 710, and
`
`the call ID is stored in the button status table for that button, 711.” Id. at 6:18–50.
`
` - 12 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`By disclosing an operating method for originating and terminating calls using a
`
`station set having a fixed number (e.g., 10) of call appearance (CA) buttons, Coyne
`
`discloses a “method for recovering calls using an attendant telephone set having a
`
`predetermined number of call appearance buttons.”
`
`b. “receiving a plurality of incoming telephone calls from calling
`parties”
`
`
`At step 706 of FIG. 7, Coyne discloses that “the system also tries to assign a
`
`call appearance button to the incoming calls.” EX1002, at 6:32–33. Coyne
`
`discloses that “[w]hen a call arrives, 700, the call type and call identification are
`
`known … The system controls the visual display on LED status for that [call
`
`appearance] button, sets it to flashing, 710, and the call ID is stored in the button
`
`status table for that button, 711.” Id. at 6:18–50 and FIG. 7 (annotations added
`
`below).
`
` - 13 -
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`IPR2016-01321 Petition
`Patent 6,442,261
`
`receive incoming call
`
`assign incoming call to next available CA button
`
`store caller ID of calling party at assigned CA button
`
`
`
`By describing how the station set processes incoming calls, including storing
`
`the caller identifications (call IDs) of the incoming calls, Coyne discloses the
`
`station set “receiving a plurality of incoming telephone calls from calling parties.”
`
` - 14 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`c. “identifying a telephone number of the calling party of each
`incoming telephone call”1
`
`
`Coyne discloses that “[w]hen a call arrives, 700, the call type and call
`
`identification are known … The system controls the visual display on LED status
`
`for that [call appearance] button, sets it to flashing, 710, and the call ID is stored in
`
`the button status table for that button, 711.” EX1002, at 6:18–50. By disclosing
`
`that the call ID of an incoming call is known and stored at the station set, Coyne
`
`discloses “identifying a telephone number of the calling party of each incoming
`
`telephone call.”
`
`d. “assigning each incoming telephone call to a next available
`call appearance button of said predetermined number of call
`appearance buttons”
`
`
`FIG. 2 of Coyne depicts a station set that has “10 general call appearance
`
`(CA) buttons.” EX1002, at 5:10–11 (emphasis added). At step 706 of FIG. 7,
`
`Coyne discloses that “the system also tries to assign a call appearance button to
`
`the incoming calls. A search is made through the CA buttons (buttons 1-10) in the
`
`status table looking for idle call appearances … If there is more than one idle call
`
`appearance, or if there is only one idle call appearance and this is a priority call
`
`arriving at the station set STA-1, the first idle call appearance button at the station
`
`
`1 The specification of the’261 Patent admits that this feature, which is also recited in independent claim 4,
`is prior art: “a telephone number of the calling party of each incoming call is identified using well known and widely
`used caller identification techniques.” ’261 Patent at 4:38-41. Petitioner notes that this feature is also found in Coyne
`and in the combination of Burke and Baxter, as explained herein.
`
` - 15 -
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`IPR2016-01321 Petition
`Patent 6,442,261
`set is dynamically allocated.” Id. at 6:32–55 (emphases added) and FIG. 7
`
`(annotations added below).
`
`receive incoming call
`
`assign incoming call to next available CA button
`
`store caller ID of calling party at assigned CA button
`
`
`
`By describing that the station set includes a fixed number (e.g., 10) of call
`
`appearance buttons, Coyne discloses “a predetermined number of call appearance
`
`buttons.” Further, by disclosing that the station set assigns incoming calls to the
`
` - 16 -
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`

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`IPR2016-01321 Petition
`Patent 6,442,261
`first idle call appearance button, Coyne discloses “assigning each incoming
`
`telephone call to a next available call appearance button of said predetermined
`
`number of call appearance buttons.”
`
`e. “storing the identified telephone number associated with each
`incoming telephone call in a memory device”
`Coyne discloses that a “[c]all processor 10 using system configuration data
`
`(translation) and current state data (status) stored in memory 11, interprets the
`
`change of state and issues appropriate commands.” EX1002, at 3:16–19 (emphasis
`
`added). Coyne also discloses that “for each station (STA-N) a station translation
`
`table 401 and associated station button status tables 402-405 are established … The
`
`CA button translation tables (402, 403, and 404) are initialized to an idle condition
`
`with I-use set to ‘off’, status set to ‘off’, and call ID set to ‘null’.” Id. at 4:66–5:23.
`
`Coyne further discloses that “[w]hen a call arrives, 700, the call type and call
`
`identification are known … The system controls the visual display on LED status
`
`for that [call appearance] button, sets it to flashing, 710, and the call ID is stored in
`
`the button status table for that button, 711.” Id. at 6:18–50 (emphasis added) and
`
`FIG. 7 (annotations added below).
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`IPR2016-01321 Petition
`Patent 6,442,261
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`receive incoming call
`
`assign incoming call to next available CA button
`
`store caller ID of calling party at assigned CA button
`
`
`
`By describing the memory 11 storing button status tables and the call ID of
`
`an incoming call being stored in a button status table, Coyne discloses “storing the
`
`identified telephone number associated with each incoming telephone call in a
`
`memory device.”
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`IPR2016-01321 Petition
`Patent 6,442,261
`f. “automatically redialing, in response to the attendant's
`selection of one of the call appearance buttons, the stored
`telephone number of the calling party of the incoming call
`assigned to the selected call appearance button”
`At step 802 of FIG. 8, Coyne discloses that “a CA button can be used to
`
`initiate a call.” EX1002, at 6:48–49. Step 711 in FIG. 7 of Coyne illustrates storing
`
`the call ID of an incoming call in the button status table for the CA button assigned
`
`to the call. Id. at 6:55–58.
`
`Coyne further discloses that “[w]ith reference to FIGS. 4 and 8, assume that
`
`station STA-1 is now in some arbitrary state and that a button is pushed, 800, at
`
`that station. The program actions that are taken are outline[d] in FIG. 8. Once a
`
`button is pressed, it is determined if this is a feature function button … If it is a
`
`feature function button that was pressed … the program gets the call type and call
`
`ID from the button status table, 405 …as shown in step 808. Thereafter, the
`
`program searches through the button status table, 405, for that feature function
`
`button as shown in step 808. Thereafter, in step 809, the program searches … to
`
`find a call appearance button associated with that call ID … If there is a call
`
`appearance button associated with this call ID … the program treats the call as if
`
`that CA button was pressed … the program then originates a phone call, 813.” Id.
`
`at 6:64–7:23 (emphasis added). Additionally, Coyne discloses that “[a]nother case
`
`occurs when button 802 is pushed. In such a case, the appropriate normal call
`
`processing steps 804, 805, 806, 807, 812-816 are followed.” Id. at 7:29–31
`
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`IPR2016-01321 Petition
`Patent 6,442,261
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`(emphasis added) and FIG. 8 (annotations added below).
`
`By disclosing storing a call ID of an incoming call in the button status table
`
`of the call appearance button assigned to the call and originating a call responsive
`
`to a user pressing a call appearance button, Coyne discloses “automatically
`
`redialing, in response to the attendant's selection of one of the call appearance
`
`buttons, the stored telephone number of the calling party of the incoming call
`
`assigned to the selected call appearance button.”
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` - 20 -
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`

`
`2
`
`1
`
`Flow for CA button being
`initially pressed also leads
`to “Originate” 813
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`IPR2016-01321 Petition
`Patent 6,442,261
`
`get caller ID from
`pressed button
`
`“treat as if CA button
`were pressed”
`
`automatically dial
`telephone number
`
`In FIG. 8, Coyne discloses that the process flow when a feature function
`
`(FF) button is pushed includes determining the call ID stored for that button (at
`
`step 808), searching for a call appearance button associated with the call ID (at step
`
`
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`IPR2016-01321 Petition
`Patent 6,442,261
`809), and originating a call (at step 813). If a call appearance button is associated
`
`with the call ID, Coyne discloses the process flow operating as if the call
`
`appearance button were pressed (see path “1” in FIG. 8 (annotations added
`
`above)). Coyne discloses that when a call appearance button is pushed at step 802,
`
`“normal call processing steps” are followed, which can include originating a call at
`
`step 813 (see path “2” in FIG. 8 (annotations added above)). The call ID associated
`
`with a call appearance button is the call ID stored in the button status table for the
`
`call appearance button, i.e., the call ID of an incoming call that was assigned to the
`
`call appearance button, as disclosed at step 711 of Coyne.
`
`Coyne teaches that in response to a call appearance button being pressed, the
`
`previously stored telephone number (in the button status table for that CA button)
`
`is automatically dialed. Thus, by disclosing the storing of the call ID of an
`
`incoming call in the button status table for the call appearance button assigned to
`
`the call and the process flow of initiating a call in FIG. 8, Coyne discloses
`
`“automatically redialing, in response to the attendant's selection of one of the call
`
`appearance buttons, the stored telephone number of the calling party of the
`
`incoming call assigned to the selected call appearance button.”
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`IPR2016-01321 Petition
`Patent 6,442,261
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`4.
`
`Claim 4 is anticipated by Coyne
`
`a. “call recovery system for an attendant telephone set receiving
`multiple incoming telephone calls from calling parties and
`having a predetermined number of call appearance buttons to
`which the incoming telephone calls are assigned”
`Coyne discloses “a communication system and operating method wherein
`
`the manner in which all telephone calls are displayed at a station set allows
`
`uniform user operations to originate and terminate those calls.” EX1002, at
`
`Abstract (emphases added). At FIG. 2, the station set is depicted having “10
`
`general call appearance (CA) buttons and 24 feature function (FF) buttons” Id. at
`
`5:10–12 (emphasis added). Coyne also discloses that “[w]hen a call arrives, 700,
`
`the call type and call identification are known … The system controls the visual
`
`display on LED status for that [call appearance] button, sets it to flashing, 710, and
`
`the call ID is stored in the button status table for that button, 711.” Id. at 6:18–50.
`
`At step 706 of FIG. 7, Coyne discloses that “the system also tries to assign a call
`
`appearance button to the incoming calls. A search is made through the CA buttons
`
`(buttons 1-10) in the status table looking for idle call appearances … If there is
`
`more than one idle call appearance, or if there is only one idle call appearance and
`
`this is a priority call arriving at the station set STA-1, the first idle call appearance
`
`button at the station set is dynamically allocated.” Id. at 6:32–55.
`
`By disclosing a system for originating and terminating calls using a station
`
`set having a fixed number (e.g., 10) of call appearance buttons and assigning an
`
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`IPR2016-01321 Petition
`Patent 6,442,261
`incoming call to a first idle call appearance button, Coyne discloses a “call
`
`recovery system for an attendant telephone set receiving multiple incoming
`
`telephone calls from calling parties and having a predetermined number of call
`
`appearance buttons to which the incoming telephone calls are assigned.”
`
`b. “a memory device for storing the identified telephone number
`of the calling party of each incoming telephone call”
`
`
`Coyne discloses that a “[c]all processor 10 using system configuration data
`
`(translation) and current state data (status) stored in memory 11, interprets the
`
`change of state and issues appropriate commands.” EX1002, at 3:16–19 (emphasis
`
`added). Coyne also discloses that “for each station (STA-N) a station translation
`
`table 401 and associated station button status tables 402–405 are established …
`
`The CA button translation tables (402, 403, and 404) are initialized to an idle
`
`condition with I-use set to ‘off’, status set to ‘off’, and call ID set to ‘null’.” Id. at
`
`4:66–5:23. Coyne further discloses that “[w]hen a call arrives, 700, the call type
`
`and call identification are known … The system controls the visual display on LED
`
`status for that [call appearance] button, sets it to flashing, 710, and the call ID is
`
`stored in the button status table for that button, 711.” Id. at 6:18–50 (emphasis
`
`added).
`
`By describing the memory 11 storing button status tables and the call ID of
`
`an incoming call being stored in a button status table, Coyne discloses “a memory
`
` - 24 -
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`IPR2016-01321 Petition
`Patent 6,442,261
`device for storing the identified telephone number of the calling party of each
`
`incoming telephone call.”
`
`c. “a processor for identifying a telephone number of the calling
`party of each incoming telephone call”
`
`
`Coyne discloses a “[c]all processor 10 using system configuration data
`
`(translation) and current state data (status) stored in memory 11, interprets the
`
`change of state and issues