Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 1 of 178 PagelD#: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`FAR NORTH PATENTS, LLC,
`CIVIL ACTION NO. 4:19-cv-945
`
`Plaintiff,
`ORIGINAL COMPLAINT FOR
`Vv. PATENT INFRINGEMENT
`RIBBON COMMUNICATIONS INC. and JURY TRIAL DEMANDED
`
`SONUS NETWORKS, INC. d/b/a RIBBON
`COMMUNICATIONS OPERATING
`COMPANY,
`
`Defendants.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Far North Patents, LLC (‘Far North Patents” or “Plaintiff”’) files this original
`complaint against Defendants Ribbon Communications Inc. and Sonus Networks, Inc. d/b/a
`Ribbon Communications Operating Company, (collectively, “Ribbon” or “Defendants’’),
`alleging, based on its own knowledge as to itself and its own actions and based on information
`and belief as to all other matters, as follows:
`
`PARTIES
`
`1. Far North Patents is a limited liability company formed under the laws of the
`State of Texas, with its principal place of business at 18383 Preston Rd Suite 250, Dallas, Texas,
`75252.
`
`2. Defendant Ribbon Communications Inc. is a corporation organized and existing
`under the laws of Delaware. Ribbon Communications Inc. may be served through its registered
`
`agent, Corporation Service Company, at 251 Little Falls Drive, Wilmington, Delaware 19808.
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`3. Defendant Sonus Networks, Inc. d/b/a Ribbon Communications Operating
`Company is a corporation organized and existing under the laws of Delaware. Sonus Networks,
`Inc. d/b/a Ribbon Communications Operating Company may be served through its registered
`agent, Corporation Service Company, at 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`4. The Defendants identified in paragraphs 2-3 above (collectively, “Ribbon’’) are
`companies which together comprise one of the world’s largest providers of real-time
`communications and networking services, software, and hardware.
`
`5. The Ribbon defendants named above are part of the same corporate structure and
`distribution chain for the making, importing, offering to sell, selling, and/or using of the accused
`devices in the United States, including in the State of Texas generally and this judicial district in
`particular.
`
`6. The Ribbon defendants named above share the same management, common
`ownership, advertising platforms, facilities, distribution chains and platforms, and accused
`product lines and products involving related technologies.
`
`7. Thus, the Ribbon defendants named above operate as a unitary business venture
`and are jointly and severally liable for the acts of patent infringement alleged herein.
`
`JURISDICTION AND VENUE
`
`8. This is an action for infringement of United States patents arising under 35 U.S.C.
`§§ 271, 281, and 284-85, among others. This Court has subject matter jurisdiction of the action
`under 28 U.S.C. § 1331 and § 1338(a).
`
`9. This Court has personal jurisdiction over Ribbon pursuant to due process and/or
`the Texas Long Arm Statute because, inter alia, (1) Ribbon has done and continues to do
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`business in Texas; and (11) Ribbon has committed and continues to commit acts of patent
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 3 of 178 PagelID#: 3
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`infringement in the State of Texas, including making, using, offering to sell, and/or selling
`accused products in Texas, and/or importing accused products into Texas, including by Internet
`sales and sales via retail and wholesale stores, inducing others to commit acts of patent
`infringement in Texas, and/or committing a least a portion of any other infringements alleged
`herein.
`
`10. Venue is proper in this district as to Ribbon Communications Inc. and Sonus
`Networks, Inc. d/b/a Ribbon Communications Operating Company pursuant to 28 U.S.C. §
`1400(b). Venue is further proper because Ribbon has committed and continues to commit acts of
`patent infringement in this district, including making, using, offering to sell, and/or selling
`accused products in this district, and/or importing accused products into this district, including
`by Internet sales and sales via retail and wholesale stores, inducing others to commit acts of
`patent infringement in this district, and/or committing at least a portion of any other
`infringements alleged herein in this district. Ribbon also has a regular and established place of
`business in this district, including at 3605 E. Plano Pkwy., Plano, TX 75074 (as shown in the
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`below screenshots from Ribbon’s website, https://ribboncommunications.com/company/about-
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`us/locations and from Google Maps Street View).
`
`fatereyeya| SOLUTIONS PRODUCTS SERVICES PARTNERS COMPANY SUPPORT Q
`Get Help Contact Us - Locations Email Sign-up Glossary How to Buy >
`Support: 1-833-742-2661 Support: 1-833-742-2661 919-457-9660
`
`Support: 1-833-742-2661
`
`Ottawa, Canada Texas, USA
`
`500 Palladium Drive 3605 E. Plano Pkwy.
`Suite 2100 Plano, TX 75074
`Ottawa, ON K2V 1C2 United States
`
`Phone: 1-877-412-8867 or local 1- Phone: 1-877-412-8867
`613-699-9611 Fax: 1-972-265-3600
`Support: 1-833-742-2661 Support: 1-833-742-2661
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 4 of 178 PagelD#: 4
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`BACKGROUND
`
`11. The patents-in-suit generally pertain to communications networks and other
`technology used in the provision of wireless services, Voice over Internet Protocol (“VoIP”)
`phone systems, high speed networking, and other advanced communication services. The
`technology disclosed by the patents was developed by personnel at MCI WorldCom
`(“WorldCom”), Path! Network Technologies Inc. (“Pathl Network Technologies”), Robelight
`LLC (“Robelight”), and BellSouth Corporation (“BellSouth”).
`
`12. | WorldCom was a leading telecommunications service provider in the late 1990s
`and early 2000s. Verizon acquired WorldCom in 2005. The patents developed at WorldCom
`(“the Hardy patents”) are related to Quality of Service (“QoS”) evaluation in telecommunications
`systems.
`
`13. The inventor of the Hardy patents, former principal analyst for quality
`measurement and analyses at WorldCom Dr. William C. Hardy, was at the forefront of QoS in
`telecommunications systems. Dr. Hardy developed, disclosed, and patented a solution for
`efficiently and consistently evaluating QoS. In fact, Dr. Hardy literally wrote the book on QoS
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`in telecommunications systems. See Hardy, William C., QoS Measurement and Evaluation of
`Telecommunications Quality of Service (Wiley 2001).
`
`14. Dr. Hardy has received considerable praise for his work in QoS. Luis Sousa
`Cardoso, Quality of Service Development Group Chairman, left little doubt regarding the esteem
`with which he holds Dr. Hardy: “William C. ‘Chris’ Hardy is unquestionably among the leading
`lights in the field of QoS[.]” Dr. Hardy’s book was reviewed in JEEE Communications
`Magazine, Vol. 40, No. 2, Feb. 2002, which stated that the book “provides a straightforward and
`very accessible approach to measurement and evaluation of QoS in telecommunications
`networks. ..strongly recommended for all people, either experiences professionals or graduates,
`involved in the area of networking[.]” He is even an honorary member of the Russian Academy
`of Science.
`
`15. The Hardy patents (or the applications leading to them) have been cited during
`patent prosecution hundreds of times, by numerous leading companies in the computer
`networking and telecommunications industries industry, including Adtran, Alcatel-Lucent, Arris,
`AT&T, Avaya, Cisco, Deutsche Telekom (T-Mobile), Dolby Laboratories Licensing
`Corporation, Empirix, Ericsson, Genband, General Electric, IBM, Juniper, Microsoft, Motorola,
`NEC, Oracle, Panasonic, Ringcentral, Sharp, Siemens, Sprint, USAA, and Verizon.
`
`16. Path] Network Technologies is a provider of video over IP services and solutions.
`The patents developed at Path] Network Technologies (“the Fellman patents’’) relate to
`providing service guarantees for time sensitive signals in computer networks. The inventors of
`these patents include Dr. Ronald D. Fellman and Dr. Rene L. Cruz. Drs. Fellman and Cruz, both
`former professors of electrical and computer engineering at the University of California at San
`
`Diego, were pioneers in network technology. Dr. Fellman was an IEEE Senior Member, and his
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`work was published in several IEEE Transactions journals, including IEEE Transactions on
`Networking, IEEE Transactions on Parallel and Distributed Systems, IEEE Transactions on
`Systems, Man, and Cybernetics, IEEE Transactions on Signal Processing, IEEE Transactions on
`Very Large Scale Integration (VLSI) Systems, IEEE Transactions on Acoustics, Speech and
`Signal Processing. He was also a co-founder of Path Network Technologies and of Qvidium
`Technologies. Dr. Cruz, a distinguished scholar in the field of communication networks, was
`said to have established the field of Network Calculus. In Dr. Cruz’s election to be a Fellow of
`the IEEE in 2003, he was “cited for his expertise in the area of Quality-of-Service guarantees in
`packet-switched networks.”
`
`http://jacobsschool.ucsd.edu/news/news_releases/release.sfe?id=1385.
`
`17. The Fellman patents (or the applications leading to them) have been cited during
`patent prosecution hundreds of times, by numerous leading companies in the computer
`networking and telecommunications industries, including ABB Research, AMD, Amazon,
`AT&T, Atheros Communications, Avaya, Bose, Broadcom, Canon, Centurylink, Chi Mei
`Optoelectronics, Ciena, Cox Communications, Dell, FS Networks, Fujitsu, Hitachi, Honeywell,
`Intel, IBM, Lucent, Lutron, Microsoft, National Instruments, National Semiconductor, NEC,
`Nortel Networks, Oceaneering, Phillips, Qualcomm, Robert Bosch, Samsung, Siemens, Sonos,
`Sony, Symantec, Texas Instruments, Toshiba, Ubiquiti Networks, Verizon, and Viasat.
`
`18. The patents developed at Robelight (“the Light patents”) relate to obtaining
`presence information over a network. Inventors Elliot D. Light and Jon L. Roberts are named
`inventors on over 30 patents combined. The Light patents (or the applications leading to them)
`have been cited during patent prosecution over a hundred times, by numerous leading companies
`
`in the computer networking and telecommunications industries, including Alcatel-Lucent, Apple,
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`AT&T, Avaya, Google, LG Electronics, Nortel Networks, Qualcomm, Rockstar Consortium,
`SAP, Shoretel, Vonage, and ZTE.
`
`19. BellSouth, founded in 1983 as one of the seven original Regional Bell Operating
`Companies after the breakup of AT&T, was a giant in the telecommunications industry.
`BellSouth was active in both broadband and wireless, operating in the southern United States as
`well as in Argentina, Australia, Chile, Colombia, Ecuador, Guatemala, New Zealand, Nicaragua,
`Panama, Peru, Uruguay, and Venezuela. BellSouth was acquired by AT&T in 2006 for
`approximately $86 billion.
`
`20. The patents developed at BellSouth (“the Easley patents’) relate to providing a
`calling name service for mobile phones. Larry Scott Easley, the inventor of the Easley patents,
`was a prolific inventor for BellSouth—he was a named inventor on ten United States Patents.
`The Easley patents (or the applications leading to them) have been cited during patent
`prosecution over a hundred times, by numerous leading companies in the computer networking
`and telecommunications industries, including Alcatel-Lucent, AT&T, Ericsson, Genesys, Lucent,
`Nortel Networks, Siemens, Sprint, and Sybase 365.
`
`COUNT I
`
`DIRECT INFRINGEMENT OF U.S. PATENT NO. 8,689,105
`
`21. On April 1, 2014, United States Patent No. 8,689,105 (“the ‘105 Patent’) was
`duly and legally issued by the United States Patent and Trademark Office for an invention
`entitled “Real-Time Monitoring of Perceived Quality of Packet Voice Transmission.”
`
`22. Far North Patents is the owner of the ‘105 Patent, with all substantive rights in
`and to that patent, including the sole and exclusive right to prosecute this action and enforce the
`
`‘105 Patent against infringers, and to collect damages for all relevant times.
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`23. Ribbon made, had made, used, imported, provided, supplied, distributed, sold,
`and/or offered for sale products and/or systems including, for example, its Sonus VX400
`platform and Sonus/Ribbon SBC 1000/2000 session border controller families of products that
`
`include advanced quality monitoring capabilities (collectively, “accused products’).
`
`Introducing VX400
`
`— Overview
`
`The VX400 platform supports analog, digital, and native IP voice, as well as port and
`trunk side serial data, making it a compelling solution for any government agency
`looking to deploy IP-based voice and data solutions. The product line combines the
`functionality of a media gateway, signaling control point, H.323/SIP inter-working device,
`media server and voice/data mux in a single chassis. As a port side interface, the
`optional serial data card enables legacy equipment to take advantage of the IP
`backbone, realizing full convergence.
`
`Features
`
`The VX400 uses dynamic flow control technology to overcome the challenges of
`maintaining secure VoIP calls in a degraded environment. The platform will keep secure
`calls connected even when the network experiences slow traffic flow and significant
`packet loss. Other implementations “relay” secure traffic as a normal (high bit rate)
`compressed audio call. Any lost, late or corrupt packets often result in the modem
`carrier slipping, causing the modem to retrain which typically results in a dropped call.
`The VX SERIES can withstand significant packet loss and jitter, and still keep the calls
`connected. FNBDT calls on VX400 can withstand complete network failure for up to 10
`seconds without failing the call.
`
`(Source : https://support.sonus.net/display/VXDOC/Introducing+VX400)
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`Basic RTCP Voice over IP Metrics
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`RTP control protocol (RTCP as per RFC 3550) measures the call quality and generates a report
`based on key metrics such as Packet loss rate/discard rate, Max*Jitter, Mean*Jitter, Average Round
`Trip Delay, Max Round Trip Delay, Burst length/density and gap length/density. RTCP is based on the
`periodic transmission of contro! packets to all participants in the session, using the same distribution
`mechanism as the data packets. The underlying protocol provides multiplexing of the data and control
`packets, for example using separate port numbers with UDP.
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`The primary function of RTCP involves providing feedback on the quality of the data distribution and
`sending reception feedback reports to all participants, which in turn will allow the QOS administrator to
`evaluate whether problems are local or global.
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`RTCP support on VX supports RFC 3550 and RFC 3611 with exception to the parameters listed under
`Sec 2.2 RFC Compliance. Following functionality is supported on VX:
`
`¢ Building and Sending RTCP SR and RR report as per RFC 3550.
`Transmission interval for sending RTCP packets will be configurable.
`Receiving RTCP packets and extracting SR and RR report as per RFC 3550. VX will generate
`=a COR based report based on the metrics calculated
`e} Receiving RTCP*XR packet and extracting Statistical Summary and VoIP metrics as per RFC
`3611.
`* Sending of RICP*XR packets Will be supported with exceptions to the parameters listed under
`Sec 2.2 RFC Compliance.
`« RTCP functionality will be supported for SIP transport only. For other protocols, VX will not
`process RTCP but will send and receive RTCP.
`« RTCP metrics logs CDRs on per call basis.
`
`(Source : https://support.sonus.net/display/VXDOC/Features+Added+in+VX+Release+4.3)
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`Sonus SBC 1000™ Session Border Controller
`
`The award-winning SBC 1000 Session Border Controller delivers all of
`the functionality of the SBC 2000 in a solution right-sized for medium
`businesses and branch offices (up to 160 concurrent sessions).
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`The SBC 1000 delivers built-in media transcoding, network security
`(encryption, authentication, DoS protection, etc.), robust SIP | ll
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`interworking, intelligent call routing, multi-vendor interoperability
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`and 24/7/365 survivability. The Sonus SBC 1000 and the Sonus SBC 2000 Session Border Controllers are the
`only SBC solutions available which offer Microsoft Lync survivability through either a 3G/4G or PSTN connection
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`to provide reliability in the event of a wide area network (WAN) failure.
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`|
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`Features/Benefits
`* Lowest cost of entry-session-based licensing allows enterprises to get high-end SBC features at a low entry price
`* TDM interconnect for trunking and analog connections, including fax machines, lobby phones, etc.
`* Get started quickly—both the SBC 2000 and SBC 1000 can be provisioned and operational in as little as one hour
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`* Microsoft Lync quality of experience (QoE) monitoring—the SBC 1000 and SBC 2000 are the only SBCs on the
`market that monitor the entire call flow
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`(Source :
`
`http://www.exertisgoconnect.nl/products/images/files/brochure_Sonus_ SBC _Portfolio.pdf)
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`Sonus SBC 2000™ Session Border Controller
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`The Sonus SBC 2000 Session Border Controller is an advanced SBC
`designed to help medium-sized enterprise networks safely and
`cost-effectively embrace the new multi-vendor world of SIP-based
`communications, such as Voice over IP (VoIP) and Unified
`Communications. The SBC 2000 delivers all of the features you —
`would expect in an enterprise-class SBC, including security, built-in
`media transcoding, SIP interworking and intelligent call routing. The Sonus SBC 2000 also has a unique
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`feature not found in other solutions: survivable branch appliance (SBA) functionality that enables the SBC
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`to complete voice calls over the PSTN should the enterprise WAN go down.
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`Features/Benefits
`+ Low cost of entry-session-based licensing allows enterprises to start small and scale as they grow (up to
`600 concurrent sessions) without high upfront costs
`* Performance you can trust-combines SBA features in an SBC device for 24/7/365 communications even during
`IP network outages
`~_TDM interconnect for trunking and analog connections, including fax machines, lobby phones, etc.
`
`Microsoft Lync quality of experience (QoE) monitoring—the SBC 1000 and SBC 2000 are the only SBCs on the
`market that monitor the entire call flow
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`(Source :
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`http://www.exertisgoconnect.nl/products/images/files/brochure Sonus SBC Portfolio.pdf)
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`rliod0on
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`2 Ribbon Technical Publications Spaces ~
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`=] SBC 1000/2000 5.0.x vy Pages /... / Working with System Settings
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`Configuring Quality of Experience (QoE) Settings
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`SPACE SHORTCUTS
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`(2) Release 8.0.x Documentation
`(x) Release 7.0.x Documentation
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`>) Release 6.1.x Documentation
`
`Note
`Related Documents
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`7) Release 6.0.x Documentation QoE Reporting must be enabled in the SIP Channels and Routing Panel of the relevant SIP Signaling group
`>) Release 4.1.x Documentation before statistics can be collected.
`* Configuring the QoE
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`») API Reference Feature
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`») PDF Versions
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`Q Search Space Overview
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`PAGE TREE The SBC Quality of Experience (QoE) feature collects data about call RTP streams, generates MOS information, and sends them to a MS Lync QoE
`server.
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`Sonus SBC 1000-2000 User's Guide
`For more information about RTCP and MOS see the following
`Getting to Know the Sonus SBC 1000-21
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`- REC 3611
`
`wean ¢ pinion Score and Menics
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`Troubleshooting Sonus SBC 1000-2000
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`(Source :
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`https://support.sonus.net/display/UXDOCS50/Configuring+Quality+of+Experience+%28Q0E%2
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`9+Settings)
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`The Ribbon Communications
`SBC 1000™ Gateway
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`Protocol Support
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`(Source :
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`https://www.voipsupply.com/downloads/dl/file/id/37491/sbc 1000 gateway datasheet.pdf)
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`The Ribbon Communications
`SBC 2000™
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`Protocol Support
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`(Source : https://www.voipsupply.com/downloads/dl/file/id/37471/sbc_2000_datasheet.pdf)
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`RFC 3611 RTCP XR November 2003
`
`References
`
`Normative References
`
`[1] Bradner, S., “Key words for use in RFCs to Indicate Requirement
`Levels", BCP 14, RFC 2119, March 1997.
`
`[2] Crocker, D., Ed. and P. Overell, “Augmented BNF for Syntax
`Specifications: ABNF", RFC 2234, November 1997.
`
`[3] ETSI, "Quality of Service (QoS) measurement methodologies", ETSI
`TS 101 329-5 V1.1.1 (2000-11), November 2000.
`
`[4] Handley, M. and V. Jacobson, "SDP: Session Description
`Protocol", RFC 2327, April 1998.
`
`[5] Hovey, R. and S. Bradner, "The Organizations Involved in the
`IETF Standards Process", BCP 11, RFC 2028, October 1996.
`
`[6] ] ITU-T, “The E-Model, a computational model for use in
`transmission planning", Recommendation G.107, January 2003.
`
`[7] Narten, T. and H. Alvestrand, “Guidelines for Writing an IANA
`Considerations Section in RFCs", BCP 26, RFC 2434, October 1998.
`
`(Source : https://tools.ietf.org/html/rfc3611)
`
`MOS-CQ: 8 bits
`The estimated mean opinion score for conversational quality
`(MOS-CQ) is defined as including the effects of delay and other
`effects that would affect conversational quality. The metric
`may be calculated by converting an R factor determined
`according to ITU-T G.107 [6] or ETSI TS 101 329-5 [3] into an
`estimated MOS using the equation specified in G.107. It is
`expressed as an integer in the range 10 to 50, corresponding to
`MOS x 10, as for MOS-LQ.
`
`A value of 127 indicates that this parameter is unavailable.
`Values other than 127 and the valid range defined above MUST
`not be sent and MUST be ignored by the receiving system.
`
`(Source : https://tools.ietf.org/html/rfc3611)
`
`24. By doing so, Ribbon has directly infringed (literally and/or under the doctrine of
`equivalents) at least Claims | and 23 of the ‘105 Patent. Ribbon’s infringement in this regard is
`ongoing.
`
`25. Ribbon has infringed the ‘105 Patent by using the accused products and thereby
`
`practicing a method that includes obtaining, by a network device, a reference matrix based on
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`estimates of perceived audio quality of at least portions of one or more first packetized audio
`messages, the reference matrix modeling values of a plurality of characteristics associated with a
`particular quality level. For example, the accused products are used by Ribbon to implement the
`ITU-T G.107 Recommendation. The quality of audio in VoIP networks (packet switched
`networks) are calculated using MOS (Mean Opinion score) values according to ITU-T G.107
`Recommendation E-model. The E-model computes a transmission rating value R, which is a
`combinational effect of all the transmission parameters in an audio conversation. The E-model
`uses a reference table (“reference matrix”) based on the estimates of perceived audio
`conversational/audio quality. The reference table includes modelling values like MOS-CQE
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`(Mean Opinion Score — Estimated Conversational Quality), each associated with a quality level.
`
`7 Target services
`
`This Recommendation gives guidelines for QoE assessment of various telecommunication services
`mainly utilizing audio and visual media.
`
`7.1 Audio
`
`- Conversational voice and voice messaging
`Speech communication services such as mobile telephony and voice over Internet protocol
`(VoIP), as well as conventional public switched telephone network (PSTN) and integrated
`services digital network (ISDN) services, are important targets of this Recommendation.
`The speech bandwidth can be either narrowband (NB) (300-3400 Hz) or wideband
`(WB) (100-7000 Hz).
`
`(Source: https://www..itu.int/rec/dologin_pub.asp?lang=e&id=T-REC-G.1011-201506-S!!PDF-
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`E&type=items)
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`8.5 Planning models
`
`The input for planning models (Figure 8-5) includes the quality planning parameters of networks or
`terminals. It usually requires prior knowledge about the system under test. Such models can be applied
`to network planning and terminal/application design.
`
`Quality design Input Planning Output
`parameters model A.V,M)
`
`Planning
`assumptions
`
`G.1011(10)_F8-5
`
`Figure 8-5 — Planning model
`
`Standard examples of such models are [ITU-T G.107] for speech and [ITU-T G.1070] for videophone.
`
`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=e&id=T-REC-G.1011-201506-S!!PDF-
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`E&type=items)
`Recommendation ITU-T G.107
`
`The E-model: a computational model for use in transmission planning
`
`1 Scope
`
`This Recommendation describes a computational model, known as the E-model, that has proven
`useful as a transmission planning tool for assessing the combined effects of variations in several
`transmission parameters that affect conversational! quality of 3.1 kHz handset telephony. This
`computational model can be used, for example, by transmission planners to help ensure that users
`will be satisfied with end-to-end transmission performance whilst avoiding over-engineering of
`networks. It must be emphasized that the primary output from the model is the "rating factor" R but
`this can be transformed to give estimates of customer opinion. Such estimates are only made for
`transmission planning purposes and not for actual customer opinion prediction (for which there is no
`agreed-upon model recommended by the ITU-T).
`
`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 15 of 178 PagelD #: 15
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`7 Structure and basic algorithms of the E-model
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`The E-model is based on the equipment impairment factor method, following previous transmission
`rating models. It was developed by an ETSI ad hoc group called "Voice Transmission Quality from
`Mouth to Ear".
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`The reference connection, as shown in Figure 1, is split into a send side and a receive side. The model
`estimates the conversational quality from mouth to ear as perceived by the user at the receive side,
`i Iker
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`. OLR .
`Send side SLR 7" RLR > Receive side
`. OdBr point oe,
`Ds-factor | oo A Dr-tq
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`Weighted echo
`path loss WEPL
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`Room noise Pr
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`Room noise Ps Round-rip delay Tr
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`| +
`ee | Coding/ decoding t—
`|
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`Circuit noise Ne Equipment impairment factor I
`referred to 0 dBr 4 Packet-loss robustness factor Bil
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`Sidetone masking
`rating STMR
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`Listener sidetone
`rating LSTR
`(LSTR = STMR + Dr)
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`' Packet-loss probability Ppl
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`Mean one-way delay T
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`Absolute delay Ta .
`some ee) Talker echo
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`loudness rating TELR
`
`a
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`Quantizing distortion qdu
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`'
`'
`'
`e
`@
`'
`'
`'
`'
`'
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`Expectation factor A G.107(06)_FO1
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`Figure 1 — Reference connection of the E-model
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 16 of 178 PagelD #: 16
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`7.1 Calculation of the transmission rating factor, R
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`According to the equipment impairment factor method, the fundamental principle of the E-model is
`based on a concept given in the description of the OPINE model (see [b-ITU-T P-Sup.3]).
`
`Psychological factors on the psychological scale are additive.
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`The result of any calculation with the E-model in a first step is a transmission rating factor R, which
`combines all transmission parameters relevant for the considered connection. This rating factor R is
`composed of:
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`R= Ro-—Is—Id —Ie-eff + A (7-1)
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`Ro represents in principle the basic signal-to-noise ratio, including noise sources such as circuit noise
`and room noise. Factor /s is a combination of all impairments which occur more or less
`simultaneously with the voice signal. Factor /d represents the impairments caused by delay and the
`effective equipment impairment factor /e-eff represents impairments caused by low bit-rate codecs.
`It also includes impairment due to randomly distributed packet losses. The advantage factor A allows
`for compensation of impairment factors when the user benefits from other types of access to the user.
`The term Ro and the Js and /d values are subdivided into further specific impairment values. The
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`following clauses give the equations used in the E-model.
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`An estimated mean opinion score (MOScoe) for the conversational situation in the scale 1-5 can be
`obtained from the R-factor using the equations:
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`For R < 0: MOXo8 =!
`For0<R<100: MOS o¢= 1+0.035R + R(R—60)(100— R)7-10°° (B-4)
`For R > 100: MO ok = 4.5
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 17 of 178 PagelD #: 17
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`In some cases, transmission planners may not be familiar with the use of quality measures such as the
`R rating factor obtained from planning calculations, and thus provisional guidance for interpreting
`calculated R factors for planning purposes is given in Table B.13. This table also contains equivalent
`transformed values of R into estimated conversational MOScgr, GoB and PoW.
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`Table B.1 — Provisional guide for the relation between R-value and user satisfaction
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`R-value MOScor GoB (%) PoW (%) :
`User
`(lower (lower (lower (upper tisfacti
`limit) limit) limit) limit) satistaction
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`90 4.34 97 ~0 Very satisfied
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`80 4.03 89 ~0 Satisfied
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`70 3.60 73 6 Some users dissatisfied
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`60 3.10 50 17 Many users dissatisfied
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`50 2.58 27 38 Nearly all users dissatisfied
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
`7.2.3 MOS-CQE
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`The score is calculated by a network planning model which aims at predicting the quality in a
`conversational application situation. Estimates of conversational quality carried out according to
`[ITU-T G.107], when transformed to mean opinion score, give results in terms of MOS-CQE.
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`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=e&id=T-REC-P.800.1-201607-I!!PDF-
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`E&type=items)
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`26. The methods practiced by Ribbon’s use of the accused products include receiving,
`by the network device, one or more second packetized audio messages and evaluating, by the
`network device, at least portions of one or more of the one or more second packetized audio
`messages to obtain measurements associated with the plurality of characteristics. For example,
`the accused products are used by Ribbon to implement the ITU-T G.107 Recommendation. The
`E-model is applied to a real-time voice call (“second packetized audio messages”) for measuring
`its voice quality by calculating the R value. The R value can be converted into a MOS value. The
`R value represents the combinational effect of all transmission parameters in an audio
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`conversation. The E-Model estimates the MOS-CQE/audio quality of the speech signals.
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`Case 4:19-cv-00945-SDJ Document1 Filed 12/26/19 Page 18 of 178 PagelD #: 18
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`7.1 Calculation of the transmission rating factor, R
`
`According to the equipment impairment factor method, the fundamental principle of the E-model is
`based on a concept given in the description of the OPINE model (see [b-ITU-T P-Sup.3]).
`
`Psychological factors on the psychological scale are additive.
`
`The result of any calculation with the E-model in a first step is a transmission rating factor R, which
`combines all transmission parameters relevant for the considered connection. This rating factor R is
`composed of:
`
`R= Ro-Is—Id —Ie-eff + A (7-1)
`
`Ro represents in principle the basic signal-to-noise ratio, including noise sources such as circuit noise
`and room noise. Factor /s is a combination of all impairments which occur more or less
`simultaneously with the voice signal. Factor /d represents the impairments caused by delay and the
`effective equipment impairment factor /e-eff represents impairments caused by low bit-rate codecs.
`It also includes impairment due to randomly distributed packet losses. The advantage factor A allows
`for compensation of impairment factors when the user benefits from other types of access to the user.
`The term Ro and the /s and /d values are subdivided into further specific impairment values. The
`
`following clauses give the equations used in the E-model.
`
`(Source: https://www.itu.int/rec/dologin_pub.asp?lang=s&id=T-REC-G.107-201402-S!!PDF-
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`E&type=items)
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`| Pagameters )
`Auditory Equipment
`Speech in System Speech out test impairment
`library factor
`.
`ween ene Objective Appendix I to 7
`Calibration measure ITU-T G.113 ITU-T G.107
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`R
`Je 4- | fC een==- a LS _~=i'+tS----------:
`ITU-T P.83