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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`GOOGLE LLC,
`Petitioner
`
`v.
`
`FLYPSI, INC.,
`Patent Owner
`
`_________________
`
`Patent No. 11,218,585
`_________________
`
`
`DECLARATION OF DR. BILL LIN
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 11,218,585
`
`
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`
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`Page 1 of 88
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`GOOGLE EXHIBIT 1002
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`

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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
`
`V.
`
`
`TABLE OF CONTENTS
`
`I.
`INTRODUCTION .......................................................................................... 1
`BACKGROUND AND QUALIFICATIONS ................................................ 2
`II.
`III. MATERIALS REVIEWED ........................................................................... 5
`IV. PERSON OF ORDINARY SKILL IN THE ART AND THE TIME OF
`THE ALLEGED INVENTION ...................................................................... 7
`TECHNICAL BACKGROUND .................................................................... 9
`A.
`Telecommunications Signaling ............................................................ 9
`B.
`The Public Switched Telephone Network (PSTN) ............................ 14
`VI. THE ’585 PATENT ...................................................................................... 17
`A. Description ......................................................................................... 17
`VII. OVERVIEW OF THE PRIOR ART ............................................................ 22
`A.
`Backhaus ............................................................................................ 22
`B.
`Saksena ............................................................................................... 30
`VIII. CLAIM CONSTRUCTION ......................................................................... 33
`IX. THE PRIOR ART DISCLOSES AND/OR SUGGESTS ALL
`RECITED FEATURES OF CLAIMS 1-4 OF THE ’585 PATENT ............ 34
`A.
`Backhaus Discloses the Limitations of Claims 1, 2, and 4 ................ 34
`1.
`Claim 1 ..................................................................................... 34
`i)
`[1.pre] “A method of providing telephone service,
`comprising:” .................................................................. 34
`[1.a] “automatically storing electronic information
`that indicates an association of a secondary
`telephone number and a primary telephone number
`with a mobile device in a computer memory
`associated with a server;” .............................................. 41
`[1.b] “automatically transmitting information that
`indicates an access telephone number to the mobile
`device via a data channel;” ............................................ 46
`
`ii)
`
`iii)
`
`
`
`
`
`i
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`iv)
`
`
`
`a primary
`associating
`“automatically
`[1.c]
`telephone number and access telephone number
`pairing with a corresponding secondary telephone
`number and contact telephone number pairing in the
`computer memory;” ....................................................... 54
`[1.d] “receiving, at a switch associated with the
`server, an outgoing call from the mobile device to
`the access telephone number via a second channel;”
` ....................................................................................... 61
`[1.e] “receiving, at the server, information from the
`switch indicating the outgoing call is being made to
`the access telephone number from the primary
`telephone number; and” ................................................. 67
`[1.f] “receiving, at the switch, information from the
`server directing the switch to: (a) connect the
`outgoing call to the contact telephone number of the
`secondary telephone number and contact telephone
`number pairing, and (b) identify a telephone number
`from which the outgoing call is being made as the
`secondary telephone number.” ...................................... 69
`Claim 2: “The method of claim 1, wherein the data
`channel is an Internet protocol (IP) channel.” ......................... 73
`Claim 4: “The method of claim 1, wherein the second
`channel is not an Internet Protocol (IP) channel.” ................... 74
`Backhaus in View of Saksena Discloses and/or Suggests Claim
`3 .......................................................................................................... 75
`1.
`Claim 3: “The method of claim 2, wherein the second
`channel is established in accordance with a CDMA or
`GSM standard.” ........................................................................ 75
`Each of the Above Prior Art Combinations in view of Taylor
`Discloses and/or Suggests the Challenged Claims ............................ 79
`CONCLUSION ............................................................................................. 84
`
`v)
`
`vi)
`
`vii)
`
`2.
`
`3.
`
`B.
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`C.
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`X.
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`ii
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
`
`
`
`I, Bill Lin, declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained as an independent expert consultant in this
`1.
`
`proceeding before the United States Patent and Trademark Office (“PTO”) regarding
`
`U.S. Patent No. 11,218,585 (“the ’585 patent”) (Ex. 1001).1 I have been asked to
`
`consider whether prior art references disclose or suggest the features recited in
`
`claims 1-4 (“the challenged claims”) of the ’585 patent. My opinions are set forth
`
`below.
`
`2.
`
`I am being compensated at my standard consulting rate for my work in
`
`this proceeding. My compensation is in no way contingent on the nature of my
`
`findings, the presentation of my findings in testimony, or the outcome of this or any
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`other proceeding. I have no other interest in this proceeding.
`
`
`
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`
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`1 In this Declaration, I refer to exhibits that I understand are to be attached to the
`
`petition for Inter Partes Review of the ’585 patent.
`
`
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`1
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`II. BACKGROUND AND QUALIFICATIONS
`3. My qualifications are stated more fully in my curriculum vitae, which
`
`is attached as Ex. 1003. Below is a summary of my education, work experience, and
`
`other qualifications.
`
`4.
`
`I am currently a Professor of Electrical and Computer Engineering at
`
`the University of California, San Diego (UCSD).
`
`5.
`
`I received a Bachelor of Science in Electrical Engineering and
`
`Computer Sciences from University of California, Berkeley in May 1985; a Master’s
`
`of Science in Electrical Engineering and Computer Sciences from the University of
`
`California, Berkeley in May 1988; and a Ph.D. in Electrical Engineering and
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`Computer Sciences from the University of California, Berkeley in May 1991.
`
`6.
`
`I joined UCSD in 1997, and I have been a tenured professor since 1999.
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`My teaching and research focus on computer architecture and computer network
`
`problems, including the design of high-performance switches and routers, high-
`
`speed packet processors, wireless networks, data networks, and various hardware
`
`accelerators for networking applications. I regularly teach a senior-level design
`
`course on the design of advanced processors, and I have taught graduate courses and
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`advanced special topics in computer architecture and computer networks.
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`
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`2
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`7.
`
`At UCSD, I am a Principal Investigator in the UCSD Center for
`
`Networked Systems (CNS). CNS brings together researchers to work on a range of
`
`challenges in the design of future networked systems. My contribution to CNS has
`
`been expertise in the design of computer architecture solutions for packet processing,
`
`computer networking, and network measurements. I am also a Principal Investigator
`
`in the UCSD Center for Wireless Communications (CWC). CWC brings together
`
`researchers to work on a range of challenges in the design of future wireless
`
`communications systems. My contribution to CWC has been expertise in the design
`
`of computer architecture solutions for wireless networking and mobile computing.
`
`8.
`
`Prior to joining UCSD, I was the Head of the Systems and
`
`Communications Group at IMEC in Leuven, Belgium, where I led a team of
`
`researchers who worked on a range of computer design problems, including
`
`specialized processors for wireless communications and computer networking.
`
`9.
`
`During my career, I have received or worked on research efforts that
`
`received millions of dollars in research funding from both government agencies and
`
`industry, including funding for research in packet processing, computer networks,
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`network measurements, and wireless communications.
`
`
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`3
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`10.
`
`I have served as an Associate or Guest Editor for several journals
`
`published by the Association for Computing Machinery (“ACM”) and the Institute
`
`of Electrical and Electronics Engineers (“IEEE”). I have also served as General
`
`Chair of several ACM/IEEE conferences, and on the Organizing or Steering
`
`Committees of many ACM/IEEE conferences, and I have served on the Technical
`
`Program Committees of numerous ACM/IEEE conferences. I am the author of over
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`190 top-tier peer-reviewed publications in the field of computer engineering dating
`
`to the 1980s, including journal articles, conference papers, book chapters, technical
`
`reports, and invited papers. A number of these publications have received best paper
`
`awards or distinguished paper citations. I have also given numerous invited and
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`keynote talks around the world.
`
`11.
`
`I am a named inventor on five patents in the fields of computer design
`
`and computer networking: U.S. Patent Nos. 8,443,444, 7,860,004, 7,672,005,
`
`5,870,588, and 5,748,487.
`
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`4
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
`
`
`III. MATERIALS REVIEWED
`12. The opinions contained in this Declaration are based on the documents
`
`I reviewed, my professional judgment, as well as my education, experience, and
`
`knowledge regarding systems and processes in the field of online advertising.
`
`13.
`
`In forming my opinions expressed in this Declaration, I reviewed the
`
`following materials:
`
`Ex. 1001 U.S. Patent No. 11,218,585 to Zhidov et al. (“the ’585 patent”)
`
`Ex. 1003 Curriculum Vitae of Bill Lin, Ph.D.
`
`Ex. 1004
`
`Prosecution History of the ’585 Patent
`
`Ex. 1005 U.S. Patent Publication No. 2013/0295892 to Backhaus et al.
`
`Ex. 1006 U.S. Pat. App. No. 61/660772 Backhaus Provisional
`
`Ex. 1007 U.S. Patent Publication No. 2009/0052437A1 to Taylor
`
`Ex. 1008 U.S. Patent Publication No. 2006/0077956A1 to Saksena
`
`Ex. 1011
`
`Signaling System No. 7 (SS7/C7) Protocol, Architecture, and
`Services (excerpts)
`
` also considered any other documents and materials I refer to in this Declaration.
`
` I
`
`14. My opinions contained in this declaration are based on the documents
`
`I reviewed and my knowledge and professional judgment. My opinions have also
`
`been guided by my appreciation of how a person of ordinary skill in the art would
`
`
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`5
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`have understood the state of the art, the prior art, and the claims and the specification
`
`of the ’585 patent at the time of the alleged invention, which I discuss below.
`
`15.
`
`I have been asked to initially consider that the time of the alleged
`
`invention of the ’585 patent was around 2013 (including and up to July 17, 2013),
`
`which corresponds to the filing date of the earliest patent application associated with
`
`the ‘585 patent. (Ex. 1001, Cover.)
`
`16. Based on my experience and expertise, it is my opinion that certain
`
`references disclose and/or suggest all the features recited in challenged claims of the
`
`’585 patent, as I discuss in detail below.
`
`
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`6
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`IV. PERSON OF ORDINARY SKILL IN THE ART AND THE TIME OF
`THE ALLEGED INVENTION
`I am familiar with the level of ordinary skill in the art regarding the
`17.
`
`’585 patent as of what I understand to be around July 17, 2013, which is the filing
`
`date of the earliest patent application associated with the ‘585 patent. (Ex. 1001,
`
`Cover.) Considering the ’585 patent, the technology, the educational level and
`
`experience of workers in the field relating to the patent, and problems and solutions
`
`in that field, and drawing on my own experience, I believe a person of ordinary skill
`
`in the art at the time of the alleged invention (around July 17, 2013) would have had
`
`an undergraduate degree in electrical engineering, computer engineering, computer
`
`science or a related field along with two years of work experience in the field of
`
`telecommunication. More education can supplement practical experience and vice
`
`versa. (See ’585 patent (Ex. 1001) at 1:29-34 (“The present invention relates to
`
`systems and methods for setting up and connecting telephone calls, and delivering
`
`information related to such telephone calls using an Internet Protocol (IP) or other
`
`data channel while delivering the voice portion of the call in accordance with
`
`CDMA, GSM or like voice channel delivery standards.”).)
`
`18. My opinions in this Declaration regarding the ’585 patent and the
`
`prior art (including the state of the art) are from the perspective of one of ordinary
`
`
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`skill in the art as I defined above, during the relevant timeframe (e.g., the time of
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`the alleged invention), which I discussed above as being around July 17, 2013.
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`V. TECHNICAL BACKGROUND
`19. Below, I present a brief overview of certain aspects of systems and
`
`processes relating to telecommunication and associated features prior to and at the
`
`time of the alleged invention for the ’585 patent. The functionalities and concepts I
`
`describe below in this technical background section reflect the state of the art that a
`
`person of ordinary skill in the art would have had knowledge of and understood prior
`
`to and at the time of the alleged invention of the ’585 patent. I rely on, and
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`incorporate as applicable (even if not expressly mentioned below in Section IX), the
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`following disclosures and opinions to support my opinions in this Declaration,
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`including those opinions relating to how the prior art discloses and/or suggests the
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`challenged claims of the ’585 and how and why a person of ordinary skill in the art
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`would have been motivated to consider and combine the disclosures and suggestions
`
`from that prior art as I explain below in Section IX. The concepts below would have
`
`been within the knowledge and mindset of a person of ordinary skill in the art at the
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`time.
`
`A. Telecommunications Signaling
`20. A telecommunication network is formed by a conglomerate of many
`
`different components (e.g., servers, switches, and terminal devices), and in order to
`
`efficiently provide telecommunication services (e.g., call routing and call forwarding
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`through these various components), the network components must indicate or signal
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`information to each other so as to coordinate amongst the components to provide the
`
`intended services. (Ex. 1011, 6 (“In telecommunications, the network’s components
`
`must indicate (that is, signal) certain information to each other to coordinate
`
`themselves for providing services. As such, the signaling network can be considered
`
`the telecommunications network’s nervous system. It breathes life into the
`
`infrastructure.”).) In fact, it was generally known that:
`
`Without signaling, networks would be inert and passive
`aggregates of components. Signaling is the bond that
`provides dynamism and animation, transforming inert
`components into a living, cohesive and powerful medium.
`
`(Ex. 1011, 6.)
`
`21. For instance, if a telecommunication service subscriber (e.g., a
`
`subscriber to AT&T’s telephone services) intends to place a telephone call, the call
`
`must be signaled to a switch, which provides an access point to the
`
`telecommunication network. (Id., 6; Ex. 1007, [0004] (“[e]xternal digital
`
`communication systems typically communicate with the PSTN by interfacing with
`
`[local exchanges or switches 12].”)) Such a switch is also known as a local switch
`
`or a local exchange. (Ex. 1011, 6; see also id., 6-7 (describing that calls are
`
`
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`established and routed by switches across the PSTN, including a calling party’s local
`
`switch and a destination’s local switch), 11, 15, 82 (disclosing that a local
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`exchange/switch “provides network access for the subscriber”).) Once the called
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`party’s number is received by the local switch, it begins signaling to other
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`nodes/components of the network to establish a communication path, formed by the
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`interconnected components, between the calling and called parties to provide a bi-
`
`directional communication. (Id., 6-7.)
`
`22.
`
`In addition to providing an access point to a network for a subscriber’s
`
`device, a local switch may also be an access point to a network for a server. For
`
`example, Ex. 1007 shows a server 50 that communicates with the Public Switched
`
`Telephone Network (PSTN, discussed further below) through a local switch 12. (Ex.
`
`1007, [0008]; see also id., [0004] (“External digital communication systems
`
`typically communicate with the PSTN by interfacing with an exchange such as [local
`
`switch] 12”), FIG. 1A (showing a local switch 12 that is in communication with
`
`server 50).)
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`U.S. Patent No. 11,218,585
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`(Ex. 1007, FIG. 1A (annotated).) In particular, as shown in Figure 1 above,
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`server 50 may be configured to interface via a PSTN interface 52 with an
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`exchange 12 to receive and process calls pertaining to a predefined set of telephone
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`numbers on the PSTN, where the server “executes telephony applications that can
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`provide custom services such as interactive voice response, customer service or help
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`desk for an organization.” (Id., [0008].)
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`U.S. Patent No. 11,218,585
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`23. While the main function of telecommunication signaling is to set up
`
`and clear calls, signaling may take place even when there is not a call in place, which
`
`is used to transfer data between network nodes. For example, telecommunication
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`signaling may be used for “query and response with telecommunications databases
`
`to support cellular networks, intelligent networks, and supplementary services.”
`
`(Ex. 1011, 7.)
`
`The main function of signaling is still that of circuit
`supervision: setting up and clearing down circuits (that
`is, trunks). Traditionally, once a circuit was set up, no
`other signaling was performed apart from releasing the
`call; therefore, all calls were simple, basic telephone
`service calls. However, modern telephone networks can
`perform signaling while a call is in progress, especially
`for supplementary services—for example, to introduce
`another called party into the call, or to signal the
`arrival of another incoming call (call waiting) to one of
`the parties. In fact, since the 1980s, signaling can take
`place even when there is not a call in place. This is
`known as non-circuit related signaling and is simply used
`to transfer data between networks nodes. It is primarily
`used for query and response with telecommunications
`databases
`to support cellular networks,
`intelligent
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`networks, and supplementary services. For example, in
`Public Land Mobile Networks (PLMNs), the visitor
`location register (VLR) that is in charge of the area into
`which the subscriber has roamed updates the home
`location register (HLR) of the subscriber’s location.
`PLMNs make much use of non-circuit-related signaling,
`particularly to keep track of roaming subscribers. Chapter
`13, “GSM and ANSI-41 Mobile Application Part (MAP),”
`covers this topic in more detail.
`
`(Ex. 1011, 7.)
`
`The Public Switched Telephone Network (PSTN)
`B.
`24. One of the well-known telecommunication networks is the PSTN.
`
`Consistent with as discussed above (that a network is formed by many different
`
`components),
`
`the PSTN
`
`includes various equipment and
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`interconnecting
`
`components that provide phone services to the public. (Ex. 1011, 81.) The PSTN
`
`began in the 19th century with a manual mechanical switchboard that connected
`
`different parties and allowed them to carry on a conversation. (Id.) In modern days,
`
`the PSTN is “a network of computers and other electronic equipment that converts
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`speech into digital data and provides a multitude of sophisticated phone features,
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`data services, and mobile wireless access,” and the PSTN also transports speech or
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`voice-band data, which is data that has been modulated to voice frequencies. (Id.)
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`25. The PSTN is known to be providing reliable communications to its
`
`subscribers and operates using the Signaling System No. 7 (SS7) protocol, which
`
`provides control signaling for the network (like I discussed above regarding network
`
`signaling to coordinate amongst the network components) and “is the most advanced
`
`and widely used
`
`signaling
`
`system
`
`for both cellular and
`
`fixed-line
`
`telecommunications networks.” (Id., 5 (“Signaling System No. 7. Today, Signaling
`
`System No. 7 is the most advanced and widely used signaling system for both
`
`cellular and fixed-line telecommunications networks”), 81-82 (“SS7 provides
`
`control signaling for the PSTN”), 103-105 (discussing the use of SS7 protocol in the
`
`PSTN since the 1990s).)
`
`SS7/C7 is the protocol suite that is employed globally,
`across
`telecommunications networks,
`to provide
`signaling; it is also a private, “behind the scenes,” packet-
`switched network, as well as a service platform. Being a
`signaling protocol, it provides the mechanisms to allow the
`telecommunication network elements to exchange control
`information…. SS7/C7 is the key enabler of the public
`switched telephone network (PSTN), the integrated
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`services digital network (ISDN), intelligent networks
`(INs), and public land mobile networks (PLMNs).
`
`(Ex. 1011, 43.)
`
`26. The core of the PSTN are digital switches, which are also known as
`
`signal switching points (SSPs). (Ex. 1011, 81 (“At the core of the PSTN are digital
`
`switches”).) A SSP “is a voice switch” that “processes voice-band traffic.” (Id., 62-
`
`63; see also Ex. 1007, [0004] (describing that “[t]elephone service is traditionally
`
`carried by the PSTN,” which “includes a network of interconnected local exchanges
`
`or switches 12;” “[v]oice or data is carried from a source node to a destination node
`
`on the network by establishing a circuit path along the PSTN effected by
`
`appropriately switching the interconnecting exchanges;” and “[e]xternal digital
`
`communication systems typically communicate with the PSTN by interfacing with
`
`an exchange such as 12.”) As such, it has been known that a switch is responsible
`
`for connecting a voice channel to create a conversation path between the calling and
`
`the called parties. (Ex. 1011, 99 (“The switch is responsible for many tasks, but one
`
`of its primary function is connecting voice channel to create a bi-directional
`
`conversation path between two phone subscribers…. Once a circuit is set up
`
`between the two subscribers, the connection remains for the duration of the call.”).)
`
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`Declaration of Dr. Bill Lin
`U.S. Patent No. 11,218,585
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`VI. THE ’585 PATENT
`A. Description
`27. The ’585 patent generally describes setting up and connecting phone
`
`calls using a data channel, and delivering voice portions of the call using a voice
`
`channel. (Ex. 1001, 1:29-34.) As an example, the ’585 patent explains with
`
`reference to Figure 3 (reproduced below) communications between a handset 340
`
`and a server 100 may utilize a data channel (e.g., the Internet 316). (Id., 4:49-54.)
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`(Ex. 1001, FIG. 3.) “Conversely, communications between the switch 110 and the
`
`handset over the PSTN 310 may be transmitted and received in accordance with
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`CDMA, GSM or like standards as opposed to using IP. Such CDMA, GSM or like
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`governed communications, when used to carry voice information, are referred to
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`herein as being conducted over a ‘voice channel.’” (Id., 4:54-60.)
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`28. For instance, a user may subscribe to a handset application 342 using
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`the data channel connection between handset 340 and server 100, and a handset
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`application 342 may be transmitted to the handset from the server 100 to be installed
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`on the handset. (Id., 4:66-5:10.) Through the handset application 342, a user may
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`“select one or more secondary telephone numbers to be referenced to a primary
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`telephone number for the handset.” (Id., 5:11-16.)
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`29. Using the handset 340, a user may transmit call processing rules via the
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`data channel to the server 100 by “select[ing] call processing rules for handling
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`incoming and outgoing voice channel calls to and from the handset 340.” (Id., 5:29-
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`32.) Call processing rules may provide call routing based on locational information,
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`caller ID, and temporal data. (Id., 6:23-32 (“The call processing rules may govern
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`how calls are handled and may provide automated call routing or call dropping based
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`on location data of the calling and/or called party. The call processing rules may
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`further govern handling calls based on incoming caller ID, which may identify a
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`calling party as being on an accepted caller ID list or a non-accepted caller ID list.
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`The call processing rules may further provide call routing based on weekday,
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`weekend, holiday, time of day, biometrics data, and accelerometer data
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`information.”).) Additionally, call processing rules may include preset responses for
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`incoming calls including custom voicemail or text message responses. (Id., 5:45-
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`53.)
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`30. Figure 3 of the ’585 patent also depicts the call routing process for
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`receiving an incoming call to or placing an outgoing call from a secondary telephone
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`number. (Id., 5:65-6:2, 7:35-38.) For incoming calls to a secondary telephone
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`number, the call is routed over PSTN 310 to switch 110. (Id., 6:2-13.) In response
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`to the incoming call, applications (e.g., call manager 104 as shown in Figure 3)
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`associated with server 100 may access certain call processing rules in database 120
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`to determine how to handle the incoming call. (Id.)
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`31.
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`If the call processing rules allow receiving the incoming call, then call
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`manager 104 may transmit pre-call notification information to handset 340 via the
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`data channel, where such information includes a bridge telephone number and other
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`information (e.g., calling party’s number/name and the called secondary number to
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`be displayed on handset 340). (Id., 6:46-58.) If the user opts to accept the call,
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`handset 340 calls the bridge number over the voice channel, which is then routed to
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`switch 110. (Id., 7:9-14.) Switch 110 then bridges the call directed to the bridge
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`number (which is from handset 340) with the incoming call (that calls the secondary
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`number associated with handset 340) in order to connect the calling party to handset
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`340 via the voice channel. (Id., 7:15-7:25; see also id., FIG. 2, FIG. 4.)
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`32. The ’585 patent also describes processes for placing outgoing calls,
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`where a bridge number is used to connect the outgoing call, and the user may choose
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`a secondary telephone number as the originating telephone number. (Id., 7:35-9:2.)
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`33. The alleged invention includes features that were well known to a
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`person of ordinary skill in the art before the time of the alleged invention, such as
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`using the PSTN as a voice channel, the Internet as a data channel, uses of primary
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`and secondary telephone numbers, uses of a switch and a bridge telephone number
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`to connect to calls. (See generally Ex. 1004.) As demonstrated below, the claimed
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`features were either disclosed and/or suggested by the prior art or prior art
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`combination.
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`VII. OVERVIEW OF THE PRIOR ART
`A. Backhaus
`34. Backhaus discloses a method for routing calls between a third party
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`telecommunication device (“TD”) and a subscriber TD through a communication
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`network. (Ex. 1005, Abstract, [0009].) Backhaus discloses a relationship number
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`that may be used to, e.g., route calls to a service platform. (Id., Abstract.)
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`35. Backhaus discloses with reference to Figure 1 a high-level diagram of
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`an exemplary system 100 that includes a second line service (“SLS”) platform 115
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`(highlighted in red), which provides the SLS to a subscriber operating TD 110
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`(highlighted in green). (Id., [0031].)
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`(Ex. 1005, FIG. 1 (annotated).) System 100 also includes a communication network
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`125 (highlighted in yellow), where calls directed from third party TD 120
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`(highlighted in blue) to subscriber TD 110 are transmitted via communication
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`network 125. (Id., [0032] (“any call[s]…are transmitted from a third party TD 120
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`to the subscriber TD 110 by way of communications network 125.”).)
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`36. Backhaus discloses that subscriber TD 110 is associated with a primary
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`phone number that is assigned to it by a primary service provider. (Id., [0031].)
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`Subscriber TD 110 is also associated with a secondary phone number (or SLS
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`number) provided by SLS platform 115. (Id.) A subscriber to the SLS “may receive
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`calls at TD 110 that are directed to either of the primary phone…or the secondary
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`phone number.” (Id. (“TD 110 is…associated with a primary phone number
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`assigned to it by a primary service provider…. A subscriber to a [SLS]…may
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`receive calls at TD 110 that are directed to either of the primary phone number…or
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`the secondary phone number…provided, serviced and or facilitated by the SLS
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`platform 115.”).) Backhaus explains that since subscriber TD 110 is associated with
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`multiple phone numbers, e.g., primary and SLS phone numbers, it allows the
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`subscriber to separately manage communications on each number, e.g., separating a
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`personal number from a business number. (Id., [0008] (“providing a plurality of
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`dedicated phone numbers to a single telecommunications device in such a manner
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`that the user of the device can separate and manage communications on each”); see
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`also id., [0003]-[0007] (describing known use of multiple numbers with a
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`telecommunication device to separate personal from business phone numbers).)
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`37. Consistent with Second Line Service Master ID Table 305 of Figure 3A
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`(reproduced below and annotated), Backhaus discloses that “the primary
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`number…assigned to the subscriber TD 110…is associated with [the subscriber] and
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`his SLS number.” (Id., [0044], FIG. 3A; see also id., [0044] (“The SLS service
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`provider…has a group of SLS numbers…and are provided to subscribers of the SLS
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`service.”), [0050] (“The relationship between the subscriber’s primary number and
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`the SLS number is reflected in Second Line Service Master ID Table 305 of FIG.
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`3A.”), [0060] (“SLS platform 115…may recognize that…subscriber’s primary
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`number…(which is associated with the subscriber’s SLS number”).)
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