Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 1 of 18 PageID #: 36
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Verizon Accused Instrumentality(ies)
`
`The Accused Instrumentality provides an internet network connecting and roaming system. It provides
`internet communication service to a data communication terminal of a user moving indoors or
`outdoors, using an outdoor wireless internet network including an antenna, a router and a location
`register, and an indoor network including an indoor gateway connectable with an internet network.
`
`Verizon provides a “Wi-Fi Calling” system and service. Verizon’s system enables “Wi-Fi Calling”
`which allows a user to “make and receive voice and video calls over a Wi-Fi connection instead of
`using [the user’s] cellular connection.”1
`
` “If [a user has] a Wi-Fi connection and [is] in an area where voice service is weak or unavailable, [the
`user may] use Wi-Fi calling to continue making voice calls.”2
`
`
`
`Claim
`
`1. An internet network connecting
`and roaming system providing
`internet communication service to
`a data communication terminal of
`a user moving indoors or
`outdoors, using an outdoor
`wireless internet network
`including an antenna, a router and
`a location register, and an indoor
`network including an indoor
`gateway connectable with an
`internet network, the system
`comprising:
`
`
`1 Verizon, https://www.verizon.com/support/wifi-calling-faqs/ (last visited Aug. 26, 2020).
`2 Id.
`
`1/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 2 of 18 PageID #: 37
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`On Verizon, a call can switch between WiFi and Advanced Calling depending on which has the better
`signal.3
`
`
`3 Verizon, https://community.verizonwireless.com/t5/iPhone-X-Xr-Xs/calls-dropping-when-switching-from-wifi-to-verizon-network/td-p/1119387;
`https://www.verizon.com/support/knowledge-base-145797/ (last visited Aug. 26, 2020).
`
`2/18
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`

`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 3 of 18 PageID #: 38
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`
`
`For example, “You are connected to the LTE/EPC network and move indoors, into your house.
`There you have a fixed broadband connection connected to a WiFi-capable home router.
`Depending on preferences, the device may in this situation switch access from LTE to WiFi.”4
`
`
`Verizon’s Wi-Fi Calling enables seamless switching or hand-off between its cellular (LTE) network and
`a Wi-Fi network.
`
`
`4 Magnus Olsson et al., EPC and 4G Packet Networks, Driving the Mobile Broadband Revolution (2d ed. 2012), at 41.
`
`3/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 4 of 18 PageID #: 39
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`Verizon’s Wi-Fi Calling system and service comprise a data communication terminal.5
`
`For example, Verizon sells mobile devices such as smartphones and tablets that support both cellular and
`Wi-Fi connectivity.
`
`
`
`a data communication terminal
`that includes an indoor wireless
`connection module and stores
`registered indoor system ID
`information, so that the data
`communication terminal may be
`connected with the indoor
`network if the registered indoor
`system ID information is received
`and by connecting with the
`outdoor wireless internet network
`if the registered indoor system ID
`information is not received;
`
`
`Examples of smartphones provided by Verizon include Alcatel Avalon, Google Pixel 4a, Apple iPhone
`11 Pro Max, Motorola Moto Z, and Apple iPhone XR:6
`
`
`
`
`5 Verizon, https://www.verizon.com/support/wifi-calling-faqs/ (last visited Aug. 26, 2020).
`6 Verizon, https://www.verizon.com/smartphones/ (last visited Aug. 26, 2020).
`
`4/18
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`

`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 5 of 18 PageID #: 40
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`
`
`An exemplary or representative example of the data communication terminal is the Apple iPhone, which
`can “[m]ake a call with Wi-Fi Calling.”7
`
`The device includes the necessary electronics to include Wi-Fi connectivity.8 For example, this device
`includes an indoor wireless connection module, such as a Wi-Fi chip or modem and a cellular chip or
`modem.
`
`The device stores registered indoor system ID information.9
`
`
`7 Make a Call with Wi-Fi Calling, APPLE (Feb. 11, 2020)., https://support.apple.com/en-us/HT203032
`8 Verizon, https://www.verizon.com/smartphones/ (last visited Aug. 26, 2020).
`9 Connect to Wi-Fi on Your iPhone, iPad, or iPod Touch, APPLE (Feb. 11, 2020), https://support.apple.com/en-us/HT202639.
`
`5/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 6 of 18 PageID #: 41
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`For example, “[w]hen your iOS device evaluates service set identifiers (SSIDs)” it “determines which
`networks to auto-join.”10
`
`
`The device stores this information so that it may be connected with the indoor network if the registered
`
`
`10 How iOS Decides Which Wireless Network to Auto-Join, APPLE (Oct. 30, 2019), https://support.apple.com/en-us/HT202831.
`
`6/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 7 of 18 PageID #: 42
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`indoor system ID information is received and by connecting with the outdoor wireless internet network if
`the registered indoor system ID information is not received.
`
`The device allows Verizon users to automatically use the outdoor wireless internet network or the indoor
`system, when available.11
`
`Verizon’s Wi-Fi Calling system and service comprise an indoor gateway.12
`
`An indoor gateway may be any Wi-Fi access point, to connect to a Wi-Fi network and the Internet via a
`wire, such as a home gateway or an integrated access device (e.g., for business), router, modem, or
`“hotspot.” A Wi-Fi access point broadcasts indoor system ID information, e.g., SSID, and makes
`wireless communications with the data communication terminal (e.g. iPhone) through the indoor wireless
`connection module.
`
`
`
`an indoor gateway that includes
`an indoor wireless connection
`module therein, broadcasts the
`indoor system ID information,
`makes wireless communications
`with the data communication
`terminal through the indoor
`wireless connection module, and
`is connected with the internet
`network via a wire;
`
`
`11 Aaron Mamiit, Apple Outs Third iOS 9.3 Beta With Support for Wi-Fi Calling for Verizon, Tech Times (Feb. 11, 2016),
`https://www.techtimes.com/articles/132621/20160211/apple-outs-third-ios-9-3-beta-with-support-for-wi-fi-calling-for-verizon.htm
`12 Verizon, https://www.verizon.com/support/knowledge-base-204165/ (last visited Aug. 26, 2020).
`
`7/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 8 of 18 PageID #: 43
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`Wi-Fi Calling is intended for use in areas where the Verizon cellular coverage is weak, e.g., indoors.13
`
`
`
`
`13 Id.
`
`8/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 9 of 18 PageID #: 44
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`a location register that stores
`location information of the data
`communication terminal received
`through the indoor network or
`outdoor wireless internet network;
`and
`
`Verizon’s Wi-Fi Calling system and service comprise at least a location register that stores location
`information of the data communication terminal received through the indoor network or outdoor wireless
`internet network, such as SSID and/or locational area information.
`
`For example, Verizon provides a 4G LTE network.
`
`Verizon’s system is based upon 3GPP (3rd Generation Partnership Project) standards,14
`
`The Verizon network uses the 3GPP Evolved Packet Core (“EPC”).15
`
`The 4G LTE network uses the 3rd Generation Partnership Project (“3GPP”) Evolved Packet Core
`(“EPC”). The EPC architecture is designed to allow interworking between different access technologies
`and, in particular LTE and Wi-Fi. In this network architecture an entity called the Home Subscriber
`Server (“HSS”) acts as a common database for all subscriber data.16
`
`
`14 Monica Alleven, Verizon Boasts First 5G Call Using 3GPP-Based Standards, Fierce Wireless (Feb. 13, 2018), https://www.fiercewireless.com/wireless/verizon-
`boasts-first-5g-call-using-3gpp-based-standards.
`15 Kelly Hill, Verizon: ‘A Glimpse of the Future’ in Cloud-Native EPC Trial with Ericsson, RCR Wireless News (Jul. 17, 2019),
`https://www.rcrwireless.com/20190717/software-defined-networking-sdn/verizon-a-glimpse-of-the-future-in-cloud-native-epc-trial-with-ericsson.
`16 Olsson et al., supra note 5, at 38, 41.
`
`9/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 10 of 18 PageID #: 45
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`The HSS “is the master user database that supports the IMS network entities that handle the
`calls/sessions . It contains user profiles, performs authentication and authorization of the user, and can
`provide information about the physical location of user.”17
`
`Within the EPC, the HSS connects to a logical node called the 3GPP AAA Server (over the SWx
`interface), which enables other logical entities within the EPC to access the set of subscriber data stored
`in the HSS.18
`
`The 3GPP standard illustrates this.19
`
`
`
`
`17 Stefano Gioia, Understanding the Home Subscriber Server (HSS) Sh Interface, ORACLE (Oct. 9, 2006), https://www.oracle.com/technetwork/testcontent/home-
`subscriber-server-083038.html.
`18 Olsson et al., supra note 5, at 38.
`19 3GPP TECH. SPECIFICATION 23.402, Release 15 (Mar. 2018), at Figure 4.2.2-1 (annotated).
`
`
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`10/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 11 of 18 PageID #: 46
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`The 3GPP AAA Server is typically implemented either as a software feature inside the HSS itself, or as
`stand-alone AAA equipment interfacing the HSS over the SWx interface.20
`
` “UE” stands for “User Equipment” or the data communication terminal (which may also be referred to
`“MS” or “mobile station”).
`
`The HSS communicates through the 3GPP AAA Server, which interfaces with logical entities in the
`EPC, including the Packet Data Network Gateway (“PDN-Gateway”) over the S6b interface; the Evolved
`Packet Data Gateway, labeled ePDG over the SWm interface; Trusted Non-3GPP IP Access Networks
`over the STa interface; and Untrusted Non-3GPP IP Access Networks over the SWa interface. The data
`communication terminal updates the network about its location on a regular basis, such that the UE can
`access the network to make or receive calls, texts, or data, as it moves around the network, e.g., between
`indoor and outdoor.21
`
`The HSS and/or 3GPP AAA Server stores location information of the data communication terminal
`received through the indoor network or outdoor wireless internet network.22
`
`
`20 Olsson et al., supra note 5, at 38.
`21 Olsson et al., supra note 5, at 121.
`22 See, e.g., 3GPP TECH. SPECIFICATION 23.002, Release 15 (Mar. 2018), at § 4.1.1 and Figure 0-a.
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 12 of 18 PageID #: 47
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`
`
`The subscriber information stored in the HSS is described in 3GPP Technical Specification 23.008.
`Table 5.2A-1 lists the data used for packet-switched network access, such as for Evolved Packet System
`(EPS) 3GPP access, which includes LTE sessions. Table 5.2A-2 of 3GPP Technical Specification 23.008
`lists the data used for packet-switched non-3GPP access, such as for Wi-Fi networks. The data includes
`location information of the data communication terminal.
`
`For example, the HSS stores a “PDN Address.”23
`
`As another example, the HSS stores the “subscribed QoS profile.”24
`
`In addition, the HSS stores an “Access Point Name (APN)” as part of each subscriber profile.25
`
`
`23 3GPP TECH. SPECIFICATION 23.008, Release 15 (Mar. 2019), at Table 5.2A-1.
`24 Id.
`25 Id. at Table 5.2A-2; Olsson et al., supra note 5, at 277.
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`12/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 13 of 18 PageID #: 48
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`A PDN Address is an IP address assigned to the UE, when the UE joins an LTE network.26
`
`An APN may be one label for the Wi-Fi access point.27
`
`Verizon’s system also uses, for example, other IP addresses, tracking areas, cell identifiers, node IDs,
`and wireless local area network identifiers.
`
`As other examples, Verizon’s system also stores location information in user equipment, Wi-Fi access
`points, eNodeBs and base stations, Mobility Management Engines, Serving Gateways, Packet Data
`Network Gateways, Evolved Packet Gateways, and other gateways, servers and network entities.
`
`Verizon can track the location of a user of a mobile phone, and record and report such information.28
`
`Verizon uses cellular data, satellite GPS data, and GPS data based on nearby identified Wi-Fi networks.
`
`Defendants’ Wi-Fi Calling system and service comprise a router that determines the location of the data
`communication terminal stored in the location register and provides roaming of voice/data signals
`provided to the user by selecting one of the indoor and the outdoor networks in accordance with the
`determined location of the data communication terminal.
`
`a router that determines the
`location of the data
`communication terminal stored in
`the location register and provides
`roaming of voice/data signals
`provided to the user by selecting
`one of the indoor and the outdoor
`networks in accordance with the
`
`26 LTE IP Address Allocation Schemes I: Basic, NETMANIAS, at 3 (Feb. 13, 2015), https://www.netmanias.com/en/post/techdocs/7246/lte/lte-ip-address-allocation-
`schemes-i-basic.
`27 See, e.g., 3GPP TECH. SPECIFICATION 23.008, supra note 23, at Table 5.2A-2, §§ 2.13.6, 3.11.1.3.
`28 Verizon, https://www.verizon.com/support/wireless-location-based-services-legal/ (last visited Aug. 26, 2020).
`
`For example, Verizon’s Wi-Fi Calling system and service provides switching the network path of the
`voice/data communications automatically and without interruption, in the manner of a seamless transition
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 14 of 18 PageID #: 49
`
`Claim
`
`determined location of the data
`communication terminal.
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Verizon Accused Instrumentality(ies)
`
`or hand-off.
`
`To use Verizon Wi-Fi calling a user must be connected to a Wi-Fi network through a Wi-Fi access point
`which routes the communications from the mobile device.29
`
`As discussed, above, the Verizon system then allows for seamless transition between calling through the
`Wi-Fi network and through cellular network.
`
`
`
`
`
`
`
`
`29 Verizon, https://www.verizon.com/support/wifi-calling-faqs/#setup-use (last visited Aug. 26, 2020).
`
`14/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 15 of 18 PageID #: 50
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`For example, Verizon’s 4G LTE Network includes a Packet Data Network Gateway, “PDN GW” or “P-
`GW.”30
`
`
`
`This is further illustrated by the 3GPP standard.31
`
`
`30 Olsson et al., supra note 5, at 41, Fig. 2.16.
`31 3GPP TECH. SPECIFICATION 23.402, supra note 23, at Figure 4.2.2-1 (annotated)
`
`15/18
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 16 of 18 PageID #: 51
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`
`
`
`
`The PDN GW is the point of interconnect between the EPC and external IP networks. IP traffic runs
`through the PDN GW. The PDN GW interfaces, for example with the 3GPP AAA Server to retrieve
`subscriber data stored in the HSS, including location information stored in the location register. 32
`
`
`32 Olsson et al., supra note 5, at 38.
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 17 of 18 PageID #: 52
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`The PDN GW routes packets to and from the various packet data networks.33
`
`The PDN GW is involved with policy, charging rules, and call session control functions.
`
`The PDN GW provides roaming for voice and data signals to the user by selecting the LTE (outdoor)
`
`network or Wi-Fi (indoor) network in accordance with the location of the data communication
`terminal.34
`
`
`
`
`
`
`
`
`33 Frédéric Firmin, The Evolved Packet Core, 3GPP, http://www.3gpp.org/technologies/keywords- acronyms/100-the-evolved-packet-core (last visited Aug. 26, 2020).
`34 Olsson et al., supra note 5, at Figs. 6.3–6.5.
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`Case 2:20-cv-00280-JRG Document 1-3 Filed 08/28/20 Page 18 of 18 PageID #: 53
`
`Exhibit B
`Claim Chart for U.S. Patent No. 6,922,728
`
`Claim
`
`Verizon Accused Instrumentality(ies)
`
`
`
`
`
`
`
`18/18
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`