IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`UNILOC 2017 LLC and UNILOC USA, INC.,
`
`
`
`v.
`
`GOOGLE LLC,
`
`
`
`
`
`
`
`
`Civil Action No. 2:18-CV-00499-JRG-RSP
`
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Plaintiffs,
`
`Defendant.
`
`
`
`
`
`DEFENDANT’S INITIAL INVALIDITY CONTENTIONS
`AND P.R. 3-3 AND 3-4 DISCLOSURES
`
`
`
`
`
`74627033.1
`
`
`
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 1
`
`

`

`TABLE OF CONTENTS
`
`I. 
`
`PRELIMINARY MATTERS.................................................................................................. 1 
`A.  Asserted Claims .................................................................................................................. 1 
`B.  Uniloc’s Infringement Contentions ..................................................................................... 1 
`C.  Ongoing Discovery and Claim Construction ...................................................................... 5 
`D.  Prior Art Identification and Citation ................................................................................... 6 
`E.  Reservation of Rights .......................................................................................................... 8 
`II.  P.R. 3-3 DISCLOSURES AND CONTENTIONS ................................................................. 9 
`A.  P.R. 3-3(a) Disclosures: Identification of Items of Prior Art That Anticipate or Render
`Obvious Asserted Claims of the Asserted Patent ....................................................................... 9 
`1. 
`Prior Art Patents and Published Patent Applications ................................................. 10 
`2. 
`Prior Art Non-Patent Publications .............................................................................. 12 
`3. 
`Prior Art Systems ....................................................................................................... 17 
`B.  P.R. 3-3(b) Disclosures: Each Item of Prior Art that Anticipates and/or Renders Obvious
`the Asserted Claims in the Asserted Patent, and Obviousness Combinations and Motivations19 
`1. 
`Exemplary Prior Art Combinations ............................................................................ 19 
`2.  Motivations to Combine ............................................................................................. 21 
`3. 
`Additional References ................................................................................................ 27 
`C.  P.R. 3-3(c) Disclosures: Charts Identifying Where in Each Item of Prior Art Each
`Element of the Asserted Claim is Found .................................................................................. 27 
`1. 
`Prior Art Patents and Published Patent Applications Charted .................................... 28 
`2. 
`Prior Art Non-Patent Publications Charted ................................................................ 28 
`D.  P.R. 3-3(d) Disclosures: Invalidity Under 35 U.S.C. § 112 .............................................. 31 
`E.  Additional Ground for Invalidity ...................................................................................... 34 
`III.  P.R. 3-4 DISCLOSURES AND CONTENTIONS ............................................................... 35 
`A.  P.R. 3-4(a) Disclosures ..................................................................................................... 35 
`B.  P.R. 3-4(b) Disclosures ..................................................................................................... 35 
`
`
`
`
`
`
`- ii -
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 2
`
`

`

`I.
`
`PRELIMINARY MATTERS
`
`Pursuant to P.R. 3-3 and 3-4 and the Docket Control Order (ECF No. 40), Defendant
`
`Google LLC (“Google” or “Defendant”) hereby discloses its P.R. 3-3 and 3-4 disclosures
`
`(“Invalidity Contentions”) in view of Plaintiff Uniloc 2017 LLC’s (“Uniloc”) P.R. 3-1 Disclosure
`
`of Asserted Claims and Infringement Contentions (“Infringement Contentions”). Google contends
`
`that each of Uniloc’s Asserted Claims (as defined below) is invalid under at least 35 U.S.C. §§ 101,
`
`102, 103, and/or 112.
`
`A.
`
`Asserted Claims
`
`U.S. Patent No. 8,194,632 (the “’632 Patent” or the “Asserted Patent”) generally relates to
`
`a “method for establishing network connections between stationary terminals and remote devices
`
`through mobile devices.” (’632 Patent at 1:1-4.) Uniloc’s Infringement Contentions allege
`
`infringement of claims 1, 8, and 15 of the Asserted Patent by Google (collectively, the “Asserted
`
`Claims”).
`
`B.
`
`Uniloc’s Infringement Contentions
`
`Google bases these Invalidity Contentions on its current understanding of the Asserted
`
`Claims in view of Uniloc’s Infringement Contentions, which are deficient in many respects.
`
`Specifically, Uniloc failed to meet its burden under at least P.R. 3-1 subparagraphs (c), (d), and
`
`(e).
`
`First, Uniloc’s single claim chart fails to identify where each element is found within each
`
`Accused Instrumentality, as required by P.R. 3.1(c). Uniloc fails to map any of the identified
`
`products to particular limitations in claim 1, because the documents on which Uniloc relies
`
`describe a method of communication between devices that does not follow the steps of the claimed
`
`method. For example, claim element 1b requires the stationary terminal (which Uniloc alleges is
`
`the Chromecast device) to transmit “an invitation message comprising a network address relating
`
`
`
`
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 3
`
`

`

`to the stationary terminal and a remote device identifier to the proximate mobile device,” but the
`
`Chromecast procedures Uniloc cites (Uniloc Exs. I and J) state that it is the mobile device—not
`
`the alleged stationary terminal—that sends the initial message. (See Uniloc Inf. Cont. Chart at 17-
`
`18.) And, Google cannot identify what Uniloc actually contends the “invitation message” is.
`
`Similarly, claim element 1c requires that the mobile device provide the network address of
`
`the stationary terminal to the remote device, but Uniloc was unable to cite any support that
`
`Chromecast meets that limitation. Instead, Uniloc relies on nothing more than unsupportive and
`
`speculative “information and belief,” to allege “the sender (or mobile device) should also provide
`
`information related to the Chromecast, e.g. IP address (or network address related to stationary
`
`terminal) to the remote server (or, remote device).” (Uniloc Inf. Cont. Chart at 27.)
`
`Uniloc also failed to provide a separate chart identifying where it contends the additional
`
`element(s) of dependent claim 8 are found in the Accused Instrumentalities. Instead, it simply
`
`states without explanation “Refer to Claim 1Pre through 1c.” (See Uniloc Inf. Cont. Chart at 32.)
`
`This means, for instance, that Uniloc has failed to identify what it contends the “remote mobile
`
`device” is.
`
`Additionally, Uniloc relies upon “an exemplary test” allegedly conducted on Chromecast
`
`“to showcase the implementation and process flow of the cast functionality in the accused
`
`products,” but fails to provide any details regarding the parameters of this test and does not attach
`
`a copy of the “testing document” referenced and excerpted from in its chart. (See Uniloc Inf. Cont.
`
`Chart at 8-10, 15-16, 19-26, Uniloc Exs. H, M.)
`
`Second, Uniloc does not identify whether it claims each element is present literally or under
`
`the doctrine of equivalents in each Accused Instrumentality as required by P.R. 3-1(d). Instead,
`
`Uniloc makes the blanket assertion that “[a]ny claim element not literally present in the Accused
`
`
`
`2
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 4
`
`

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`Instrumentalities as set forth in the claims charts is found in those Instrumentalities under the
`
`doctrine of equivalents because any differences between such claim element and the Accused
`
`Instrumentalities are insubstantial and/or the Accused Instrumentalities perform substantially the
`
`same function, in substantially the same way to achieve substantially the same result as the
`
`corresponding claim element(s).” (Uniloc Inf. Cont. at 3.) This boilerplate language does not
`
`meet the notice requirement of the local rules. See Eolas Techs. Inc. v. Amazon.com, Inc., 2016
`
`WL 7666160, at *3 (E.D. Tex. December 5, 2016) (striking DOE contentions as insufficient under
`
`P.R. 3-1(d) based on similar blanket statements).
`
`Third, Uniloc asserts, under P.R. 3-1(e), that each of the Asserted Claims is entitled to
`
`a priority date “not later than at least one of the [following] referenced priority dates” (Uniloc
`
`Inf. Cont. at 3-4):
`
` November 28, 2005, based on the filing date of U.S. Application Serial No.
`11/288,505;
`
` July 15, 2005, based on the filing date of U.S. Application Serial No. 11/182,927;
`
` March 28, 2005, based on the filing date of U.S. Application Serial No.
`11/091,242;
`
` January 24, 2005, based on the filing date of U.S. Application Serial No.
`11/042,620;
`
` September 7, 2004, based on the filing date of U.S. Application Serial No.
`10/935,342; and
`
` April 5, 2004, based on the filing date of U.S. Application Serial No. 10/817,994.
`
`Google does not concede that any of the Asserted Claims of the Asserted Patent are
`
`entitled to Uniloc’s purported priority dates. It is, and remains, Uniloc’s burden to establish the
`
`right to priority to any earlier applications. The Asserted Patent was filed on October 1, 2010
`
`and purports to claim priority as a continuation of application No. 11/288,505, which claims
`
`priority as a continuation-in-part to five earlier-filed applications, including the earliest filed
`
`
`
`3
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 5
`
`

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`application no. 10/817,994 filed on April 5, 2004. Accordingly, Uniloc must establish a
`
`continuous chain of disclosures meeting the requirements of 35 U.S.C. § 112 for each asserted
`
`claim, reaching back to the earliest priority date claimed in their P.R. 3-1(e) disclosure.
`
`At a minimum, the Asserted Claims are not entitled to claim priority to U.S. Application
`
`Serial Nos. 11/182,927; 11/091,242; 11/042,620; 10/935,342; or 10/817,994. None of the
`
`foregoing applications provides support under § 112 for several elements of the Asserted Claims,
`
`including, but not limited to, the following:
`
` Stationary terminal;
`
` Remote device;
`
` Proximate mobile device; and
`
` Remote device identifier;
`
`Accordingly, claims 1, 8 and 15 of the Asserted Patent are not entitled to a priority date
`
`of July 15, 2005; March 28, 2005; January 24, 2005; September 7, 2004; or April 5, 2004. The
`
`earliest possible priority date for Claims 1, 8, and 15 is November 28, 2005, which is the filing
`
`date of U.S. Application Serial No. 11/288,505.
`
`The foregoing deficiencies in Uniloc’s Infringement Contentions have unduly burdened
`
`Google and frustrated its ability to understand how Uniloc is applying the claims, and thus its
`
`ability to identify all potential bases for invalidity in these contentions. In light of these
`
`deficiencies, Google reserves all rights to challenge the reasonableness and sufficiency of Uniloc’s
`
`Infringement Contentions. Uniloc has not sought leave to supplement or amend its Infringement
`
`Contentions to address any of the deficiencies noted above. Google further reserves the right to
`
`seek leave to amend or supplement and to amend or supplement these Invalidity Contentions,
`
`including by disclosing additional prior art or earlier versions or evidence of the prior art disclosed
`
`
`
`4
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 6
`
`

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`herein, if Uniloc supplements or amends its Infringement Contentions or otherwise responds to
`
`address any deficiency.
`
`C.
`
`Ongoing Discovery and Claim Construction
`
`Google also bases these Invalidity Contentions on Google’s current knowledge and
`
`understanding of the Asserted Claims and review of prior art items as of the date of these Invalidity
`
`Contentions. This case is still at an early stage, and Google’s Invalidity Contentions are made
`
`without the benefit of discovery regarding the parties’ claim construction contentions, any expert
`
`discovery, or any third-party discovery. Google intends to diligently seek discovery from third
`
`parties to demonstrate the inventions were known or used by others under 35 U.S.C. § 102(a), in
`
`public use and/or on-sale under 35 U.S.C. § 102(b), and/or earlier invention of the claimed
`
`inventions under 35 U.S.C. § 102(g). Accordingly, these Invalidity Contentions are provided
`
`without prejudice to Google’s right to revise, amend, correct, supplement, modify, or clarify these
`
`Invalidity Contentions. Google also reserves the right to complete its investigation and discovery
`
`of the facts, to produce subsequently discovered information, and to introduce such subsequently
`
`discovered information at the time of any hearing or trial in this action.
`
`Additionally, the Court has not yet construed the Asserted Claims. Google maps the prior
`
`art references to the Asserted Claims based on Uniloc’s apparent constructions, to the extent
`
`understood, of the Asserted Claims as advanced in Uniloc’s Infringement Contentions. However,
`
`nothing stated in these Invalidity Contentions or accompanying claim charts should be treated as
`
`an admission or suggestion that Uniloc’s apparent claim constructions are correct, or that any claim
`
`terms of the Asserted Claims are not invalid under 35 U.S.C. § 112 for being indefinite, failing to
`
`satisfy the written description requirement, or failing to satisfy the enablement requirement. In
`
`fact, Defendants specifically deny that Uniloc’s apparent claim constructions are proper.
`
`
`
`5
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 7
`
`

`

`Depending on the Court’s construction of the Asserted Claims of the Asserted Patent,
`
`and/or positions that Uniloc or its expert witness(es) may take concerning claim interpretation,
`
`infringement, and/or invalidity issues, the asserted prior art references may be of greater or lesser
`
`relevance. Given this uncertainty, the charts may reflect alternative applications of the prior art
`
`against the Asserted Claims. Thus, no chart or position taken by Google should be construed as
`
`an admission or a waiver of any particular construction of any claim term. Google also reserves
`
`the right to challenge any of the claim terms under 35 U.S.C. § 112, including, as discussed further
`
`in Section II.D below, by arguing that they are indefinite, not supported by the written description,
`
`and/or not enabled.
`
`D.
`
`Prior Art Identification and Citation
`
`The accompanying invalidity claim charts cite to particular teachings and disclosures of
`
`the prior art references as applied to features of the Asserted Claims. However, persons having
`
`ordinary skill in the art may view an item of prior art generally in the context of other publications,
`
`literature, products, and understanding. Accordingly, the cited portions are only exemplary and
`
`are intended to put Uniloc on notice of the basis for Google’s contentions. Google has endeavored
`
`to identify the most relevant portions of the references, but the references may contain additional
`
`support for particular claim limitations. Google reserves the right to rely on uncited portions of
`
`the prior art references, other documents, and/or operational systems, as well as fact and expert
`
`testimony, to provide context or to aid in understanding the cited portions of the references and
`
`interpreting the teachings of the prior art and to establish bases for combinations of certain cited
`
`references that render the Asserted Claims obvious. Google reserves the right to rely on any prior
`
`art system referenced, embodied, or described in any of the prior art references identified herein,
`
`or which embodies any of the prior art references identified herein. Moreover, Google reserves
`
`the right to rely on inventor admissions concerning the scope of the prior art relevant to the
`
`
`
`6
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 8
`
`

`

`Asserted Patent found in, inter alia, the prosecution histories of the Asserted Patent and related
`
`patents and/or patent applications, any testimony or declarations of the named inventor concerning
`
`the Asserted Patent or related patents, and any papers or evidence submitted by Uniloc in
`
`connection with this litigation, any other pending or future litigation brought by Uniloc involving
`
`the Asserted Patent or related patents, or inter partes review proceedings involving the Asserted
`
`Patent or related patents. Google also may establish what was known to a person having ordinary
`
`skill in the art through treatises, published industry standards, other publications, products, and/or
`
`testimony.
`
`Google’s identification in the prior art of claim elements recited in the preamble of any
`
`claims is not intended to indicate that any such preamble is limiting. All such disclosures are made
`
`only to the extent the preamble is determined to be limiting.
`
`Where the invalidity claim charts cite to a particular figure in a reference, the citation
`
`should be understood to encompass the caption of the figure and other text relating to and/or
`
`describing the figure. Similarly, where the invalidity claim charts cite to particular text referring
`
`to a figure, the citation should be understood to include the figure and related figures as well.
`
`The prior art references listed herein and in the accompanying claim charts may disclose
`
`the elements of the Asserted Claims explicitly and/or inherently. The prior art references are also
`
`relevant for their showing of the state of the art and reasons and motivations for making
`
`improvements, additions, and combinations. The suggested obviousness combinations are
`
`provided in the alternative to Google’s anticipation contentions and are not to be construed to
`
`suggest that any reference is not itself anticipatory.
`
`Further, the combinations of prior art references contained herein demonstrating the
`
`obviousness of the Asserted Patent under 35 U.S.C. § 103 are merely exemplary and are not
`
`
`
`7
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 9
`
`

`

`intended to be exhaustive. All such combinations are intended to include and be in view of the
`
`knowledge of a person of ordinary skill in the art. Additional obviousness combinations of the
`
`identified prior art references are possible, and Google reserves the right to use any such
`
`combination(s) in this action. In particular, Google is currently unaware of the extent, if any, to
`
`which Uniloc will contend that limitations of any particular claim(s) are not disclosed in the art
`
`that Google has identified as anticipatory. To the extent that Uniloc does so, Google reserves the
`
`right to identify other evidence or references that anticipate or render obvious the particular
`
`claim(s).
`
`Nothing in these Invalidity Contentions should be treated as an admission that any of
`
`Google’s accused instrumentalities meet any limitation of the Asserted Claims. Google denies
`
`infringing the Asserted Claims. To the extent that any prior art references identified by Google
`
`contain a claim element that is the same as or similar to an element in an Accused Instrumentality,
`
`based on a claim construction inferred from Uniloc’s Infringement Contentions, inclusion of that
`
`reference in Google’s Invalidity Contentions is not a waiver by Google of any claim construction
`
`or non-infringement position, nor is it an admission or suggestion by Google that any accused
`
`instrumentality satisfies the limitations of the Asserted Claims under a proper construction of those
`
`claims.
`
`E.
`
`Reservation of Rights
`
`Google reserves all rights to further supplement or modify these Invalidity Contentions,
`
`including the prior art disclosed and stated grounds of invalidity, in accordance with the Court’s
`
`Orders, the Local and Patent Rules of the Eastern District of Texas, and/or the Federal Rules of
`
`Civil Procedure as this action progresses and additional information is obtained. In addition,
`
`Google reserves the right to prove invalidity of the Asserted Claims on bases other than those
`
`required to be disclosed in these disclosures and contentions pursuant to P.R. 3-3.
`
`
`
`8
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 10
`
`

`

`Subject to the foregoing statements and qualifications, Google provides the following:
`
`II.
`
`P.R. 3-3 DISCLOSURES AND CONTENTIONS
`A.
`
`P.R. 3-3(a) Disclosures: Identification of Items of Prior Art That Anticipate or
`Render Obvious Asserted Claims of the Asserted Patent
`
`Subject to Google’s reservation of rights, the following prior art patents, printed
`
`publications, and systems, alone and/or in combination, anticipate and/or render obvious the
`
`Asserted Claims of the Asserted Patent, and/or provide evidence and background regarding the
`
`level of skill and knowledge in the art.
`
`Discovery, however, is ongoing, and Google’s prior art investigation and third party
`
`discovery are therefore not yet complete. Google reserves the right to present additional items of
`
`prior art under 35 U.S.C. §§ 102(a), (b), (e), (f) and/or (g), and/or § 103 located during the course
`
`of discovery or further investigation. For example, Google expects to issue subpoenas to third
`
`parties believed to have knowledge, documentation, and/or corroborating evidence concerning
`
`some of the prior art listed in this and the following sections and/or additional prior art. These
`
`third parties include, without limitation, the authors, inventors, or assignees of the references listed
`
`in these disclosures. In addition, Google reserves the right to assert invalidity under 35 U.S.C.
`
`§§ 102(c) or (d) to the extent that discovery or further investigation yields information forming the
`
`basis for such invalidity.
`
`Google also contends that the Asserted Claims are invalid in view of public knowledge and
`
`uses and/or offers for sale or sales of products and services that are under 35 U.S.C. § 102(a) and/or
`
`35 U.S.C. § 102(b) and/or prior inventions made in this country by other inventors who had not
`
`abandoned, suppressed, or concealed them under 35 U.S.C. § 102(g), and that anticipate or render
`
`obvious the Asserted Claims. Google reserves the right to rely upon any system, public knowledge
`
`or use embodying or otherwise incorporating any of the prior art disclosed below, alone or in
`
`
`
`9
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 11
`
`

`

`combination. Google further reserves the right to rely upon any other documents or references
`
`describing any such system, knowledge, or use. By way of example, and without limitation,
`
`Google reserves the right to rely upon any system implementing the standards, requirements
`
`documents, or specifications disclosed herein, and reserves the right to rely upon the standards and
`
`other documents describing the system to establish the operation of the system.
`
`1.
`
`Prior Art Patents and Published Patent Applications
`
`Patent No.
`
`6,580,981
`6,597,924
`6,751,677
`6,847,632
`6,883,033
`6,896,618
`6,931,249
`6,942,574
`7,006,481
`7,075,908
`7,103,333
`7,103,578
`7,113,801
`7,149,197
`7,193,987
`7,194,438
`7,216,231
`7,233,979
`
`Country
`of Origin
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`
`Issue/Publication
`Date1
`June 17, 2003
`July 22, 2003
`June 15, 2004
`January 25, 2005
`April 19, 2005
`May 24, 2005
`August 16, 2005
`September 13, 2005
`February 28, 2006
`July 11, 2006
`September 5, 2006
`September 5, 2006
`September 26, 2006
`December 12, 2006
`March 20, 2007
`March 20, 2007
`May 8, 2007
`June 19, 2007
`
`
`1 As indicated, the “date” provided is the date required to be identified by Patent Rule 3-3(a). For
`example, for patents, “date” refers to date of issue. For publications, “date” refers to the date of
`publication. Nothing in the date column is intended to be a limitation on the availability of the
`particular patent, reference, product, or knowledge as “prior art.”
`
`
`
`10
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 12
`
`

`

`Patent No.
`
`7,317,919
`7,426,271
`7,496,672
`7,526,252
`7,606,590
`7,613,425
`7,706,401
`7,840,681
`7,881,310
`7,925,212
`8,255,501
`8,639,819
`9,049,042
`9,235,839
`2002/0159569
`2002/0172191
`2002/0186683
`2004/0024879
`2004/0162976
`2004/0199649
`2004/0215974
`2004/0218575
`2005/0201357
`2005/0266826
`2006/0040656
`2006/0094411
`2006/0149811
`2007/0160030
`2008/0010676
`2008/0304440
`
`Issue/Publication
`Date1
`January 8, 2008
`September 16, 2008
`February 24, 2009
`April 28, 2009
`October 20, 2009
`November 3, 2009
`April 27, 2010
`November 23, 2010
`February 1, 2011
`April 12, 2011
`August 28, 2012
`January 28, 2014
`June 2, 2015
`January 12, 2016
`October 31, 2002
`November 21, 2002
`December 12, 2002
`February 5, 2004
`August 19, 2004
`October 7, 2004
`October 28, 2004
`November 4, 2004
`September 15, 2005
`December 1, 2005
`February 23, 2006
`May 4, 2006
`July 6, 2006
`July 12, 2007
`January 10, 2008
`December 11, 2008
`
`Country
`of Origin
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`US
`
`11
`
`
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 13
`
`

`

`Patent No.
`
`WO 2006/058553
`
`WO 2006/096538
`
`1,705,268
`2,347,829
`2,367,205
`1 077 567
`2003-22227
`2005-45805
`
`Country
`of Origin
`US
`(PCT)
`US
`(PCT)
`CN
`GB
`GB
`EU
`JP
`JP
`
`Issue/Publication
`Date1
`June 8, 2006
`
`September 14, 2006
`
`July 12, 2005
`September 13, 2000
`March 27, 2002
`February 21, 2001
`January 24, 2003
`February 17, 2005
`
`2.
`
`Prior Art Non-Patent Publications
`
`Title
`Press Release: @Road Unveils
`Technology Demo Van at CTIA
`Boingo Offers Connection to In-
`Flight Wi-Fi
`Cisco Systems Datasheet: Cisco
`3200 Series Mobile Access Router
`Implementation of a Cellular
`Framework for Spontaneous
`Network Establishment
`
`On the Benefits of Heterogeneous
`Networking and How Cellular
`Mobile Operators Can Help
`
`Author/ Publisher
`Trimble Resource
`Management
`PCWorld
`
`Publication Date
`March 14, 2005
`
`May 12, 2005
`
`Cisco Systems
`
`2003
`
`March 13-17, 2005
`
`June 14-17, 2005
`
`Marc Danzeisen,
`Torsten Braun, Simon
`Winiker, and Daniel
`Rodellar / IEEE
`Wireless
`Communications and
`Networking Conference,
`2005
`Marc Danzeisen,
`Torsten Braun, Isabel
`Steiner, and Daniel
`Rodellar / IEEE
`International Conference
`on Parallel Processing
`Workshops 2005
`
`
`
`12
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 14
`
`

`

`Title
`Press Release: New Fleet
`Applications Emerge Using Wi-Fi
`Technology
`Press Release: @RoadiWM 3150
`Approved for Use on EDGE
`Network; @Road MRM Solution
`is One of the First to Be Approved
`for Use on Cingular’s EDGE
`High-Speed Data Network
`Be Your Own Hotspot --Turn a
`backpack into a portable, solar-
`powered Wi-Fi hotspot, and share
`a high-speed connection anywhere
`King County: Metro Bus Riders
`Test County's First Rolling WiFi
`Hotspots
`Press Release: Cal-(IT)2 and
`UCSD Select Entree Wireless to
`Supply Mobile Gateways for
`Homeland Security
`Transmission Control Protocol –
`DARPA Internet Program
`Protocol Specification
`
`SIP: Session Initiation Protocol
`
`Press Release: @Road Introduces
`@Road Mobile HotSpot – Giving
`Mobile Workers Wireless On-
`Demand Connectivity to Back
`office Applications
`Press Release: Siemens Wireless
`Modules Selected for Next
`Generation @Road Mobile
`Resource Management Solution
`
`Author/ Publisher
`Mike Antich /
`Automotive Fleet
`
`Publication Date
`January 1, 2005
`
`Business Wire
`
`May 4, 2005
`
`Mike Outmesguine /
`Popular Science
`
`June 23, 2005
`
`News Report
`
`September 19, 2005
`
`UC San Diego, Jacobs
`School of Engineering
`
`April 19, 2004
`
`Information Sciences
`Institute
`University of Southern
`California
`J. Rosenber, H.
`Schulzrinne, G.
`Camarillo, A. Johnston,
`J. Peterson, R. Sparks,
`M. Handley, and E.
`Schooler / The Internet
`Society
`Business Wire
`
`September 1981
`
`June 2002
`
`October 25, 2004
`
`Automotive Fleet
`
`August 30, 2005
`
`
`
`13
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 15
`
`

`

`Title
`Press Release: Siemens Wireless
`Modules Selected for Next
`Generation @Road Mobile
`Resource Management Solution
`Untangling the hot spot backhaul
`mess
`
`Tropos Technology Overview
`UCSD high-speed internet enabled
`bus
`WiFi on the Go
`
`Multiparty Conference Signaling
`using the Session Initiation
`Protocol (SIP)
`Speak-Freely Quick Start Guide
`for Microsoft Windows
`Xten X-PRO SIP Softphone for
`Pocket PC v2.2 Brochure
`Xten Celebrates the Release of
`New SIP Softphones for Wireless
`Networks with the Launch of
`VoIPmobility.com
`Xten Ships eyebeam VoIP
`Softphone for OS X
`X-Pro for PocketPC User Guide
`
`A Scalable Distributed VoIP
`Conferencing Using SIP
`
`Unleashing the Power of Wearable
`Devices in a SIP Infrastructure
`
`Author/ Publisher
`Trimble Resource
`Management
`
`Publication Date
`August 29, 2005
`
`Daniel Briere and
`Claudia Bacco /
`Network World
`Enzo Zerbi / Tropos
`ScienceBlog
`
`May 27, 2003
`
`May 2005
`April 2002
`
`Nancy Gohring / WNN
`Wi-Fi Net News
`Igor Miadinovic and
`Johannes Stadler
`
`October 13, 2004
`
`August 2002
`
`Speak-Freely
`
`February 19, 2004
`
`Xten
`
`2004
`
`CounterPath Solutions,
`Inc.
`
`October 19, 2004
`
`Peter Cohen
`
`October 20, 2004
`
`2005
`
`2003
`
`2005
`
`CounterPath Solutions,
`Inc.
`R. Venkatesha Prasad,
`Richard Hurni, and H. S.
`Jamadagni / IEEE
`International
`Symposium on
`Computers and
`Communication
`Arup Acharya, Stefan
`Berger, and Chandra
`Narayanaswami / IEEE
`International Conference
`
`14
`
`
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 16
`
`

`

`Title
`
`White Paper: Including VoIP over
`WLAN in a Seamless Next-
`Generation Wireless Environment
`Guide to Cisco Systems’ VoIP
`Infrastructure Solution for SIP
`Version 1.0
`White Paper: Understanding VoIP
`Press Release: Avaya IP
`Telephony Applications Win
`Back-to-Back Miercom Awards
`for Best Mobility Support and IP
`Contact Center Reporting
`Bluetooth: An Enabler for
`Personal Area Networking
`
`BWIG Bluetooth Web Internet
`Gateway
`Press Release: Calyspso Wireless’
`Dual Mode WiFi/GSM-GPRS
`VoIP Cellular Phones Available
`for Demonstration
`Press Release: Calypso Wireless
`Joins the Wi-Fi Alliance
`Press Release: Calypso Wireless
`ReceivesWi-Fi Technology of the
`Year Award from Frost & Sullivan
`Press Release: Cicero Networks
`Ltd.: Cicero Networks puts VoIP
`on mobile phones
`SIP and ENUM
`
`User’s Guide HP iPAQ Pocket PC
`h6300 Series
`
`Author/ Publisher
`on Pervasive Computing
`and Communications
`Paul Struhsaker
`Texas Instruments
`
`Publication Date
`
`June 2003
`
`Cisco Systems, Inc.
`
`May 8, 2005
`
`Avaya
`PR Newswire
`
`October 2005
`October 11, 2005
`
`Per Johansson, Manthos
`Kazantzidis, Rohit
`Kapoor, and Mario
`Gerla
`IEEE
`Nicolas Rouhana, Eric
`Horlait
`GlobeNewswire, Inc.
`
`September/October
`2001
`
`February 2002
`
`July 22, 2005
`
`Business Wire
`
`February 9, 2004
`
`Business Wire
`
`September 26, 2005
`
`M2 Presswire
`
`November 17, 2005
`
`Jorg Ott
`Helsinki University of
`Technology Networking
`Laboratory
`Hewlett Packard
`
`2005
`
`June 2004
`
`
`
`15
`
`Google v. Uniloc, IPR2020-00463
`Uniloc's Exhibit 2002, Page 17
`
`

`

`Title
`IBM Research Report: Peer-to-
`Peer Instant Messaging and
`Presence Services over Wireless
`Ad Hoc Networks
`Mobile Internet Enabled Sensors
`Using Mobile Phones as Access
`Network
`Wi-Fi helps wireless carriers
`widen approach
`Mobility Goes Seamless
`Motorola, Avaya, Proxim intro
`devices to enable Wi-Fi to cellular
`roaming
`Mobile Devices Move Wi-Fi
`Cellular Closer to Convergence
`Motorola Increases Its Step-Up
`Selection
`Motorola, Proxim, Avaya Team
`for Mobility
`When Wi-Fi Meets Cellular
`Press Release: Nero’s SIPPS
`Connect: Dial, Talk, and Unite
`with Nero’s New VoIP Solution
`Press Release: Nokia
`Nokia E60, E61, and E70 Launch
`
`Where next for the handset?
`Wi-Fi/Cell Buzz Revs Up
`The All-in-One, Do Everything
`Handset
`Qualcomm to add Wi-Fi to phone
`chips
`SanDisk Product Information
`Guide
`Signaling for Multiparty Sessions
`in Peer-to-Peer Ad hoc Networks
`
`Author/ Publisher
`Nilanjan Banerjee, Arup
`Acharya, Sajal Das
`IBM
`
`Publication Date
`August 6, 2004
`
`Jerker Delsing, Per
`Lindgren, Ake Ostmark
`
`August 2004
`
`Knight Ridder Tribune
`Business News
`Marie Lingblom
`
`April 24, 2005
`
`August 2, 2004
`
`Bob Brewn
`
`August 2, 2004
`
`Joseph