Petitioner’s Demonstratives
`
`Google LLC
`v.
`Uniloc 2017 LLC
`
`IPR2020-00463
`
`May 13, 2021
`
`GOOGLE EXHIBIT 1029
`GOOGLE v. UNILOC
`IPR2020-00463
`
`Page 1 of 34
`
`
`
`Google LLC
`v.
`Uniloc 2017 LLC
`
`IPR2020-00463
`
`May 13, 2021
`
`GOOGLE EXHIBIT 1029
`GOOGLE v. UNILOC
`IPR2020-00463
`
`Page 1 of 34
`
`
`
`’632 Patent Establishes Network Connections
`
`Stationary terminal 125
`(e.g., laptop, desktop, workstation)
`
`Remote mobile device 115
`(e.g., smart phone or PDA)
`
`Proximate mobile device 110
`
`Petition (Paper 1) at 4-6;
`Von Herzen Declaration (Ex. 1012) ¶ 21;
`’632 Patent (Ex. 1001) at Figure 1 (annotated); see also id. at 1:25-31, 2:29-30, 2:40-41, 2:51-56.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`2
`
`Page 2 of 34
`
`
`
`’632 Patent Establishes Network Connections
`
`Claim 1
`[1pre] A method for establishing a data communications session
`between a stationary terminal and a remote device, the method
`comprising:
`[1a] establishing a communication link through a short-range
`wireless technology between the stationary terminal and a
`proximate mobile device wherein the proximate mobile device
`operates within a cellular wireless network system;
`[1b] transmitting, by the stationary terminal, an invitation
`message comprising a network address relating to the stationary
`terminal and a remote device identifier to the proximate mobile
`device through the established communication link;
`[1c] whereupon the proximate mobile device establishes
`communication with the remote device using the remote device
`identifier and provides the network address of the stationary
`terminal to the remote device; and
`[1d] establishing a connection between the stationary terminal
`and the remote device for data communications based upon an
`initial communication by the remote device through use of the
`network address of the stationary terminal provided to the remote
`device by the proximate mobile device.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 4-6;
`Von Herzen Declaration (Ex. 1012) ¶¶ 22-23;
`’632 patent (Ex. 1001) at 6:25-48.
`
`3
`
`Page 3 of 34
`
`
`
`Challenged Claims: ’632 Patent
`
`[1pre] A method for establishing a data communications session between a stationary terminal and a
`remote device, the method comprising:
`[1a] establishing a communication link through a short-range wireless technology between the
`stationary terminal and a proximate mobile device wherein the proximate mobile device operates
`within a cellular wireless network system;
`[1b] transmitting, by the stationary terminal, an invitation message comprising a network
`address relating to the stationary terminal and a remote device identifierto the proximate
`mobile device through the established communication link;
`[1c] whereupon the proximate mobile device establishes communication with the remote device
`using the remote device identifier and provides the network address of the stationary terminal to
`the remote device; and
`[1d] establishing a connection between the stationary terminal and the remote device for data
`communications based upon an initial communication by the remote device through use of the
`network address of the stationary terminal provided to the remote device by the proximate mobile
`device.
`A non-transitory computer-readable medium including instructions that, when executed by a
`processor of a stationary terminal, causes the processor to establish a data communications session
`between the stationary terminal and a remote mobile device, by performing all the steps of claim 1.
`A computer system configured to initiate a data communications session with a remote device, the
`computer system comprising a processor configured to perform all the steps of claim 1.
`Petition (Paper 1) at 14-59;
`’632 Patent (Ex. 1001) at 6:26-48, 6:63-67, 8:1-4.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`4
`
`Claim 1
`
`Claim 8
`
`Claim 15
`
`Page 4 of 34
`
`
`
`Instituted Grounds of Unpatentability
`
`Ground 1: Claims 1, 8, and 15 would have been
`obvious over Conleyalone
`Ground 2: Claims 1, 8, and 15 would have been
`obvious over Conleyand RFC 3261
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Institution Decision (Paper 13) at 6, 20-38.
`
`5
`
`Page 5 of 34
`
`
`
`Instituted Grounds of Unpatentability
`
`Ground 1: Claims 1, 8, and 15 would have been
`obvious over Conleyalone
`Ground 2: Claims 1, 8, and 15 would have been
`obvious over Conleyand RFC 3261
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Institution Decision (Paper 13) at 6, 20-38.
`
`6
`
`Page 6 of 34
`
`
`
`[1pre] Conley Establishes Secondary Channel
`
`[1pre] A method for establishing a data communications session between a stationary
`terminal and a remote device, the method comprising:
`
`First device 140
`(e.g., laptop or tabletop computer)
`
`Second device 142 and/or
`telephonic device 112
`
`Petition (Paper 1) at 18-21;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id. at Abstract, ¶¶ 21, 24, 26, 27.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`7
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`Page 7 of 34
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`
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`[1pre] Conley Establishes Secondary Channel
`
`[1pre] A method for establishing a data communications session between a stationary
`terminal and a remote device, the method comprising:
`
`Conley
`
`’632 Patent
`
`Telephone 112 and device 142 can be a single cellphone:
`
`Conley ¶ 21: “[I]f the telephone and device are a single,
`integrated unit, such as a cellular phone with built-in
`Personal Data Assistant (PDA), . . .”
`
`Conley ¶ 26: “The computer/phone interface 234 may
`also be a direct connection if the computer and phone are
`a single, integrated device.”
`
`Conley ¶ 27: “[A] computer device and telephone device
`may be a single, integrated device, . . .”
`
`Conley Claim 11: “[A]t least one of the computing
`devices comprises a personal digital assistant having cell
`phone and Internet connectivity.”
`
`Petition (Paper 1) at 18-21;
`Conley (Ex. 1002) at Figure 1 (excerpted and annotated); see also id.at Abstract, Claim 11, ¶¶ 21, 24, 26, 27;
`’632 Patent (Ex. 1001) at Figure 1 (excerpted and annotated).
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`8
`
`Page 8 of 34
`
`
`
`[1a] Conley’s First Device Establishes Communication Link
`
`[1a] establishing a communication link through a short-range wireless technology
`between the stationary terminal and a proximate mobile device wherein the
`proximate mobile device operates within a cellular wireless network system;
`
`CONLEY Telephonic device 110
`
`Can be a “cellular telephone”
`
`Bluetooth
`Connection
`
`CONLEY First device 140
`(e.g., laptop or tabletop computer)
`
`Petition (Paper 1) at 21-23;
`Von Herzen Declaration (Ex. 1012) ¶¶ 51-53;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id. at Abstract, Claims 2, 20, ¶¶ 21, 22, 24, 26, 27, 30, 34, 36, 40.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`9
`
`Page 9 of 34
`
`
`
`[1b] ’632 Patent’s “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier to
`the proximate mobile device through the established communication link;
`
`’632 Patent
`
`SMS containing IP
`Address sent to cellphone
`number of remote device
`
`Bluetooth Connection
`– sends its IP Address
`and cellphone number
`of remote device
`
`Petition (Paper 1) at 26;
`’632 Patent (Ex. 1001) at Figure 1 (annotated); see also id. at 4:47-56;
`Petitioner’s Reply (Paper 19) at 1-4.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`10
`
`Page 10 of 34
`
`
`
`[1b] Conley’s First Device Transmits “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier to the
`proximate mobile device through the established communication link;
`
`CONLEY Cellphone
`
`SMS containing IP
`Address sent to cellphone
`number of remote device
`
`Bluetooth Connection –
`sends its IP Address and
`cellphone number of
`remote device
`
`CONLEY Computer
`
`CONLEY
`Cellphone/PDA
`
`Petition (Paper 1) at 23-27;
`Institution Decision (Paper 13) at 26-29;
`Petitioner’s Reply (Paper 19) at 1-4;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id.at Abstract, ¶¶ 21-23, 26, 27, 30, 34, 36, 40.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`11
`
`Page 11 of 34
`
`
`
`[1b] Conley’s First Device Transmits “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier
`to the proximate mobile device through the established communication link;
`
`• Conley discloses first device 140 transmits a “small amount of information” via telephonic device
`110 (across established communication link) to second device 142
`
`• “This information could, for example, include the IP address of the sender…” Conley ¶ 23.
`
`Petition (Paper 1) at 25-26;
`Von Herzen Declaration (Ex. 1012) ¶¶ 54-57;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id.at Abstract, ¶¶ 21-24, 26, 27, 30, 34, 36, 40.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`12
`
`Page 12 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`Google’s Unrebutted Expert Testimony:
`
`1. A person of skill would have understood that the stationary terminal
`would have provided the information necessary to forward the IP address
`to the remote device:
`Because Conley stationary terminal (first device 140) sends the information to the remote
`device (second device 142), Conley, ¶ 23, 30, 34, a person of skill would have both understood
`and found it obvious that Conley’s stationary terminal (first device 140) also sends a remote
`device identifier (e.g., an identifier for second device 142) to the proximate mobile device
`(telephonic device 110), which would, in turn, allow the proximate mobile device to forward
`the IP address to the remote device (second device 142).
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 26-27;
`Von Herzen Declaration (Ex. 1012) ¶ 57;
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`
`13
`
`Page 13 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`Google’s Unrebutted Expert Testimony:
`
`2. A person of skill would understand have understood that SMS messages
`require destination addresses:
`For example, Conley discloses that “if the primary channel 160 is a data channel such as SMS,
`devices 140 and 142 have a communication channel established between them, since they can
`send data to their respective telephones 110 and 112, which is then transmitted to the other
`telephone and sent to the other computer.” Conley, ¶ 22. In my opinion, a person of skill in the
`art would have understood that the minimum set of information required to send an SMS
`message includes the address of the recipient, which in this case would be the remote device. Ex.
`1019, p. 43 (“The minimal SMS-SUBMIT header consists of 13 bytes including the 8-byte
`destination address”)).
`
`Petition (Paper 1) at 26-27;
`Von Herzen Declaration (Ex. 1012) ¶ 57 (emphasis added);
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`14
`
`Page 14 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`This is confirmed by unrebutted textbook evidence:
`
`Petition (Paper 1) at 26-27;
`Ex. 1019 at 43;
`Von Herzen Declaration (Ex. 1012) ¶ 57;
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`
`15
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Page 15 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`Google’s Unrebutted Expert Testimony:
`
`3. A person of skill would have understood that when a computer sends an
`SMS message via a connected telephone, the computer provides the
`telephone with the SMS_Submit Transfer Protocol Data Unit along with a
`command to send the message:
`And it is also my opinion that a person of skill would have understood that, when a computer is
`connected to a handset via Bluetooth, that the computer (here the stationary device) sends the
`SMS message to the handset over Bluetooth for transmission on the cellular network. This is
`because a person of skill would have understood that, when a computer sends an SMS message
`via a connected telephone, the computer provides the telephone with the SMS_Subimt
`Transfer Protocol Data Unit along with a command to send the message. Ex. 1019, pp. 21-23,
`25-29.
`
`Petition (Paper 1) at 26-27;
`Von Herzen Declaration (Ex. 1012) ¶ 57 (emphasis added);
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`16
`
`Page 16 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`This is confirmed by unrebutted textbook evidence:
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 26-27;
`Von Herzen Declaration (Ex. 1012) ¶ 57;
`Ex. 1019 at 21-23, 25-29;
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`
`17
`
`Page 17 of 34
`
`
`
`[1b] “Invitation Message” Includes Remote Device Identifier
`
`This is confirmed by unrebutted textbook evidence:
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 26-27;
`Von Herzen Declaration (Ex. 1012) ¶ 57;
`Ex. 1019 at 21-23, 25-29;
`Institution Decision (Paper 13) at 28-29;
`Petitioner’s Reply (Paper 19) at 1-4.
`
`18
`
`Page 18 of 34
`
`
`
`[1c] Conley Uses Remote Identifier to Establish
`Communication
`[1c] whereupon the proximate mobile device establishes communication with the
`remote device using the remote device identifier and provides the network address of
`the stationary terminal to the remote device
`
`CONLEY Cellphone
`
`SMS Data
`Channel
`
`CONLEY Computer
`
`CONLEY
`Cellphone/PDA
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 18, 28-30;
`Conley (Ex. 1002) at Figure 1 (annotated);
`Petitioner’s Reply (Paper 19) at 10-12;
`Von Herzen Declaration (Ex. 1012) ¶¶ 58-59.
`
`19
`
`Page 19 of 34
`
`
`
`Instituted Grounds of Unpatentability
`
`Ground 1: Claims 1, 8, and 15 would have been
`obvious over Conleyalone
`Ground 2: Claims 1, 8, and 15 would have been
`obvious over Conleyand RFC 3261
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Institution Decision (Paper 13) at 6, 20-38.
`
`20
`
`Page 20 of 34
`
`
`
`RFC 3261 Establishes Channel
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 37-39, 47-49;
`RFC 3261 (Ex. 1003) at 8-9, 11-18;
`Von Herzen Declaration (Ex. 1012) ¶¶ 69-72, 85-87.
`
`21
`
`Page 21 of 34
`
`
`
`[1b] Conley’s First Device Transmits “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier to the
`proximate mobile device through the established communication link;
`
`• Conley discloses first device 140 transmits a “small amount of information” via telephonic device
`110 (across established communication link) to second device 142
`
`• “This information could, for example, include the IP address of the sender…” Conley ¶ 23.
`
`Petition (Paper 1) at 25-26;
`Von Herzen Declaration (Ex. 1012) ¶¶ 54-57;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id.at Abstract, ¶¶ 21-24, 26, 27, 30, 34, 36, 40.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`22
`
`Page 22 of 34
`
`
`
`[1b] RFC 3261 First Device Transmits “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier to the
`proximate mobile device through the established communication link;
`
`•
`
`SIP uses invitation messages:
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 37-39, 50-54;
`RFC 3261 (Ex. 1003) at 8-9, 11-18;
`Von Herzen Declaration (Ex. 1012) ¶¶ 69-72, 89-94.
`
`23
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`Page 23 of 34
`
`
`
`[1b] Conley/RFC Combination
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier to the
`proximate mobile device through the established communication link;
`
`•
`
`SIP invitation messages can
`be used as the small amount
`of information in Conley:
`
`CONLEY Cellphone
`
`CONLEY Computer
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`CONLEY
`Cellphone/PDA
`
`Petition (Paper 1) at 37-39, 50-54;
`RFC 3261 (Ex. 1003) at 8-9, 11-18;
`Conley (Ex. 1002) at Figure 1 (annotated)
`Von Herzen Declaration (Ex. 1012) ¶¶ 69-72, 89-94.
`
`24
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`Page 24 of 34
`
`
`
`[1b] “Invitation Message”
`
`[1b] transmitting, by the stationary terminal, an invitation message comprising a
`network address relating to the stationary terminal and a remote device identifier
`to the proximate mobile device through the established communication link;
`
`Remote device identifier
`
`Network address relating to
`the stationary terminal
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 37-39, 50-54;
`RFC 3261 (Ex. 1003) at 8-9, 11-18;
`Von Herzen Declaration (Ex. 1012) ¶¶ 69-72, 89-94.
`
`25
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`Page 25 of 34
`
`
`
`[1c] Conley/RFC Combination
`
`[1c] whereupon the proximate mobile device establishes communication with the
`remote device using the remote device identifier and provides the network address of
`the stationary terminal to the remote device
`
`Forward SIP INVITE
`using SIP URI for
`remote device
`
`CONLEY Cellphone
`
`Send SIP
`INVITE
`
`CONLEY Computer
`
`CONLEY
`Cellphone/PDA
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 55-57;
`Conley (Ex. 1002) at Figure 1 (annotated);
`Petitioner’s Reply (Paper 19) at 10-12;
`Von Herzen Declaration (Ex. 1012) ¶¶ 95-98.
`
`26
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`Page 26 of 34
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`
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`Motivation to Combine Conley and RFC 3261
`
`Google’s Unrebutted Expert Testimony:
`
`To make Conley work with the SIP standard, a person of skill would have used the
`RFC 3261 invitation message
`– It is my opinion that a person of skill would have found it obvious to use the message types standardized
`by RFC 3261 for the handshake in Conley used to exchange connection information. … In my opinion, a
`person of skill would have understood that using a standardized message format provided the additional
`benefit on making Conley compliant with a well-known standard. . . .
`
`– As discussed above, it is my opinion that one skilled in the art would have been motivated to combine
`RFC 3261’s standardized message types into Conley’s process because it was a published standard for
`exchanging information to set up a connection. A person of skill would have been motivated to do so by
`the efficiencies of using a standardized process.
`
`– Moreover, because SIP was a well-known protocol at the time, it is my opinion that a person of skill also
`would have been motivated to implement Conley using SIP because doing so would allow Conley’s
`system to have increased operability with other systems also using SIP or other compatible protocols.
`Indeed, looking to a standard would have been a predicable way for a person of skill in the art to
`implement Conley’s system.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 36, 39-46, 50-54, 57-59;
`Institution Decision (Paper 13) at 34-38;
`Petitioner’s Reply (Paper 19) at 12-17;
`Von Herzen Declaration (Ex. 1012) ¶¶ 74, 81, 94.
`
`27
`
`Page 27 of 34
`
`
`
`Motivation to Combine Conley and RFC 3261
`
`Google’s Unrebutted Expert Testimony:
`
`The combination is suggested by Conley’s disclosure of using IP telephony
`– Conley discloses establishing the communication session “using any type of telephone network
`infrastructure, including Internet Protocol (IP) telephony. . . .” Conley, ¶ 27. One of the well-known
`protocols for establishing communications sessions in IP telephony was the Session Initiation Protocol
`(SIP), disclosed in RFC 3261. RFC 3261 at 9 (disclosing using the SIP protocol to “establish, modify, and
`terminate multimedia sessions (conferences) such as Internet telephony calls.”). …
`
`– Moreover, Conley suggests the use of RFC 3261 because it discloses that the primary channel—which is
`used for establishing the session over the secondary channel—can use “any type of telephone network
`infrastructure, including Internet Protocol (IP) telephony…” Conley, ¶ 27. In my opinion, a person of skill
`would have understood that SIP, as described in RFC 3261, provided a well-known protocol for
`establishing the very communications sessions described in Conley using the IP telephony network
`infrastructure also disclosed in Conley. See RFC 3261 at 9 (“SIP . . . can establish, modify, and terminate
`multimedia sessions (conferences) such as Internet telephony calls.”). It is also my opinion that a person of
`skill would have been motivated to use messages compliant with RFC 3261’s SIP protocol to implement
`the session initiation procedure described in Conley, especially because Conley provides an express
`suggestion for doing so by referring to the use of “any type of telephone network infrastructure, including
`[IP] telephony.” Conley, ¶ 27.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 36, 39-46, 50-54, 57-59;
`Institution Decision (Paper 13) at 34-38;
`Petitioner’s Reply (Paper 19) at 12-17;
`Von Herzen Declaration (Ex. 1012) ¶¶ 68, 73, 77.
`
`28
`
`Page 28 of 34
`
`
`
`Motivation to Combine Conley and RFC 3261
`
`Google’s Unrebutted Expert Testimony:
`
`The combination is suggested by Conley’s efficiency requirements
`– As previously discussed, a person of skill would have been motivated to do so by the efficiencies of
`sending an invitation message that includes two pieces of information necessary to establish a
`communication session between first device 140 and second device 142, namely identifying information
`for each device. Conley expressly suggests the need to capitalize on such efficiencies and thus provides
`express motivation for the combination because Conley explains that the primary channel connection has
`limited bandwidth, Conley, ¶ 22, thus making it desirable to transfer only small amounts of information
`over the primary channel.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 36, 39-46, 50-54, 57-59;
`Institution Decision (Paper 13) at 34-38;
`Petitioner’s Reply (Paper 19) at 12-17;
`Von Herzen Declaration (Ex. 1012) ¶¶ 81, 93.
`
`29
`
`Page 29 of 34
`
`
`
`Motivation to Combine Conley and RFC 3261
`
`Google’s Unrebutted Expert Testimony:
`
`Conley and RFC 3261 would have worked together:
`1. Directed to same type of multimedia communications sessions
`
`•
`
`In my opinion, a person of skill generally would have found it obvious to combine the teachings of
`Conley with those of RFC 3261 because both references are directed to establishing the same types
`of multimedia communication sessions and employ similar technology. See supra Sections V.A,
`VI.A. Conley discloses that the resulting communications sessions between first device 140 and
`second device 142 include video phone, file sharing, and instant messaging. E.g., Conley, ¶ 43; see
`also id. at ¶¶ 29, 33, 35, 39. RFC 3261 similarly explains that SIP “establish[es] … multimedia
`sessions” and works in concert with protocols that “carry various forms of real-time multimedia
`session data such as voice, video, or text messages.” RFC 3261 at 8-9; see also id. at 1 (“These
`sessions include Internet telephone calls, multimedia distribution, and multimedia conferences.”).
`These references are also analogous to the ’632 patent, which relates to a “method for establishing
`network connections between stationary terminals and remote devices through mobile devices.” Ex.
`1001, Title.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 36, 39-46, 50-54, 57-59;
`Institution Decision (Paper 13) at 34-38;
`Petitioner’s Reply (Paper 19) at 12-17;
`Von Herzen Declaration (Ex. 1012) ¶ 76.
`
`30
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`Page 30 of 34
`
`
`
`Motivation to Combine Conley and RFC 3261
`
`Google’s Unrebutted Expert Testimony:
`
`Conley and RFC 3261 would have worked together:
`2. Employ similar technologies
`
`•
`
`In my opinion, a person of skill also would have recognized that both Conley and RFC 3261 disclose establishing
`data communication sessions between first and second devices via intermediary devices using handshake protocols,
`and would have been motivated and found it obvious to combine the teachings of the SIP handshake process with the
`teachings of Conley.
`
`• Moreover, because using the RFC solutions would only change what information is transmitted in a message over a
`link that must already be capable of transmitting similar information (e.g., an IP address), a person of skill would
`have had a reasonable expectation of success. Thus, using an RFC message for the same purpose they are being used
`for in the RFC (e.g., as an invitation to set up a communication link) is nothing more than combining know elements
`according to known methods to yield predictable results.
`
`3.
`
`Focus on interrelated layers of the system
`
`• This is because the references focus on different layers of the system through which a connection is established.
`
`• Conley focuses on the paths over which messages are transported between devices to set up a connection. …
`
`• The RFC focuses on what information is exchanged to set up a connection. …
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition (Paper 1) at 36, 39-46, 50-54, 57-59;
`Institution Decision (Paper 13) at 34-38;
`Petitioner’s Reply (Paper 19) at 12-17;
`Von Herzen Declaration (Ex. 1012) ¶¶ 78-80, 93.
`
`31
`
`Page 31 of 34
`
`
`
`Appendix Page 32 of 34
`
`Page 32 of 34
`
`
`
`Two-Way Authentication Embodiment
`
`CONLEY Cellphone
`
`SMS message with IP address,
`security token, etc. for stationary
`terminal – authenticating one way
`
`SMS message with IP address, security
`token, etc. for remote device –
`authenticating the other way
`
`Channel over which two-way
`authentication connection is
`established
`
`Petitioner’s Reply (Paper 19) at 8-10;
`Von Herzen Declaration (Ex. 1012) ¶ 57;
`Ex. 1019 at 21-23, 25-29, 43
`
`33
`
`CONLEY Computer
`
`CONLEY Cellphone/PDA
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Page 33 of 34
`
`
`
`[1d] Conley Establishes Secondary Communication Channel
`
`[1d] establishing a connection between the stationary terminal and the remote device for data communications
`based upon an initial communication by the remote device through use of the network address of the stationary
`terminal provided to the remote device by the proximate mobile device.
`
`CONLEY Cellphone
`
`CONLEY Computer
`
`CONLEY Cellphone/PDA
`
`Petition (Paper 1) at 30-33;
`Conley (Ex. 1002) at Figure 1 (annotated); see also id.at ¶¶ 23, 30, Fig. 4.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`34
`
`Page 34 of 34
`
`
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