Case 6:20-cv-00267-ADA Document 1 Filed 04/02/20 Page 1 of 29
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`VOIP-PAL.COM, INC.
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`Plaintiff,
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`v.
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`FACEBOOK, INC. and WHATSAPP, INC.,
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`Defendants.
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`
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`CIVIL ACTION NO. 20-cv-267
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`JURY TRIAL DEMANDED
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff VoIP-Pal.com, Inc. (“VoIP-Pal”), for its Complaint against Defendants Facebook,
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`Inc. (“Facebook”) and WhatsApp, Inc. (“WhatsApp”) alleges as follows:
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`THE PARTIES
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`1.
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`Plaintiff VoIP-Pal.com, Inc. (“VoIP-Pal”) is a Nevada corporation with its
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`principal place of business located at 10900 NE 4th Street, Suite 2300, Bellevue, Washington
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`98004.
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`2.
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`On information and belief, Defendant Facebook, Inc. (“Facebook”) is a Delaware
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`corporation with physical addresses in this District at 607 West 3rd Street, Austin, Texas 78701
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`and 300 West Sixth Street, Austin, Texas 78701. Facebook may be served with process through
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`its registered agent, the Corporation Service Company, at 211 East 7th Street, Suite 620, Austin,
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`Texas 78701. Facebook is registered to do business in the State of Texas and has been since at
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`least April 8, 2009.
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`3.
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`On information and belief, Defendant WhatsApp, Inc. (“WhatsApp”) is a
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`Delaware corporation with a principal place of business 1601 Willow Avenue, Menlo Park,
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`California 94025. WhatsApp has physical addresses in this District at 607 West 3rd Street,
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`Austin, Texas 78701 and 300 West Sixth Street, Austin, Texas 78701. WhatsApp may be served
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`with process through its registered agent, the Corporation Service Company, at 211 East 7th
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`Street, Suite 620, Austin, Texas 78701. On information and belief, WhatsApp is a wholly-
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`owned subsidiary of Facebook.
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`4.
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`On information and belief, Facebook and WhatsApp regularly conduct and
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`transact business in the State of Texas, throughout the United States, and within this District, and
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`as set forth below, have committed and continue to commit, tortious acts of infringement within
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`and outside the State of Texas and within this District.
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`JURISDICTION AND VENUE
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`5.
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`This action is a civil action for patent infringement arising under the patent laws
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`of the United States, Title 35, United States Code (“U.S.C.”) §1 et seq., including 35 U.S.C. §§
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`271 and 281-285. This Court has exclusive subject matter jurisdiction over this case for patent
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`infringement under 28 U.S.C. §§ 1331 and 1338.
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`6.
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`This Court has personal jurisdiction over Facebook and WhatsApp by virtue of
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`their systematic and continuous contacts with this jurisdiction, as alleged herein, as well as
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`because the injury to VoIP-Pal occurred in the State of Texas and the claim for relief possessed
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`by VoIP-Pal against Facebook and WhatsApp for that injury arose in the State of Texas. On
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`information and belief, Facebook and WhatsApp have purposely availed themselves of the
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`privileges of conducting business within the State of Texas, such business including but not
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`limited to: (i) at least a portion of the infringements alleged herein; (ii) purposefully and
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`voluntarily placing one or more infringing products into the stream of commerce with the
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`expectation that they will be purchased by consumers in this forum; or (iii) regularly transacting
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`or soliciting business, engaging in other persistent courses of conduct, or deriving or attempting
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`to derive substantial revenue and financial benefits from goods and services provided to
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`individuals residing in the State of Texas and in this District. Thus, Facebook and WhatsApp are
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`subject to this Court’s specific and general personal jurisdiction under due process and the Texas
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`Long Arm Statute.
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`7.
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`Personal jurisdiction also exists specifically over Facebook and WhatsApp
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`because Facebook and WhatsApp, directly or through subsidiaries or intermediaries (including
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`customers, distributors, retailers, and others), subsidiaries, alter egos, and/or agents – ships,
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`distributes, offers for sale, sells, imports, advertises, or markets in the State of Texas and in this
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`District, one or more products that infringe the Patent-in-Suit, as described particularly below.
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`Facebook and WhatsApp have purposefully and voluntarily placed one or more of their
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`infringing products, as described below, into the stream of commerce with the awareness and/or
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`intent that these products will be purchased by consumers in this District. Facebook and
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`WhatsApp have knowingly and purposefully shipped infringing products into and within this
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`District through an established distribution channel. These infringing products have been and
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`continue to be purchased by consumers in this District.
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`8.
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`VoIP-Pal’s claim for relief for patent infringement arises directly from the
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`activities of Facebook and WhatsApp in this District.
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`9.
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`Upon information and belief, Facebook and WhatsApp maintain offices in Austin,
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`Texas, which they collectively staff with roughly 1,200 employees. See
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`https://www.bizjournals.com/austin/news/2019/09/04/first-look-facebook-headcount-swells-as-
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`social.html . The Facebook/WhatsApp office at 607 W. Third St in Austin occupies 11 floors—
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`accounting for 256,500 square feet of office space—and has room for 1,550 employees. Id.
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`Facebook and WhatsApp also occupy four floors at 300 W. 6th St., Austin. Id. Facebook has
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`additional offices within this District. Id. Facebook has maintained an office in Austin since at
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`least 2010. Id. Facebook’s and WhatApp’s offices in this District collectively house employees
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`from at least sixteen different teams, including: (1) software engineering; (2) product
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`management (3) enterprise engineering; (4) infrastructure; (5) data & analytics; (6) legal,
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`finance, facilities & admin.; (6) sales & marketing; (7) research; and (8) WhatsApp. See
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`https://www.facebook.com/careers/locations/austin/?locations[0]=Austin%2C%20TX&divisions
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`[0]=WhatsApp (last visited Mar. 20, 2020). As of March 20, 2020, open Facebook positions in
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`Austin included: engineering manager, global operations engineering; data engineer; hardware
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`systems engineer; systems project manager, solutions; technology program manager; VP of
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`partner operations; SMB marketing manager, global business marketing; and vertical marketing
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`manager, e-commerce. As of March 20, 2020, Facebook had 168 open position in Austin,
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`including four WhatsApp positions: risk analyst, trust, and safety; payment risk operations
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`manager, WhatsApp; vendor program manager, customer operations; and anti-abuse specialists,
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`WhatsApp Business – Trust & Safety. See
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`https://www.facebook.com/careers/locations/austin/?locations[0]=Austin%2C%20TX (last
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`visited March 20, 2020);
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`https://www.facebook.com/careers/locations/austin/?locations[0]=Austin%2C%20TX&divisions
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`[0]=WhatsApp (last visited March 20, 2020).
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`10. On information and belief, Facebook and WhatsApp, directly and/or through their
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`customers have transacted business in this District and has committed acts of patent
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`infringement in this District. Facebook and WhatsApp have a regular and established place of
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`business in this District. Thus, venue is proper in this District under 28 U.S.C. §§ 1391 and
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`1400(b).
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`BACKGROUND OF THE TECHNOLOGY AND THE PATENT-IN-SUIT
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`11.
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`United States Patent No. 10,218,606 (the “’606 patent”) entitled “Producing
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`Routing Messages For Voice Over IP Communications” was duly and legally issued by the
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`United States Patent and Trademark Office on February 26, 2019. A copy of the ’606 patent is
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`attached hereto as Exhibit 1.
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`12.
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`13.
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`The ’606 patent is referred to in this Complaint as the “Patent-in-Suit”.
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`The inventions of the Patent-in-Suit originated from breakthrough work and
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`development in the internet protocol communications field.
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`14.
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`VoIP-Pal has provided significant improvements to communications technology
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`by the invention of novel methods, processes and apparatuses that facilitate communications
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`across and between internet protocol based communication systems and networks, such as
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`internally controlled systems and external networks (e.g., across private networks and between
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`private networks and public networks), including the classification and routing thereof.
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`15.
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`The earliest telephone systems to receive public use within the United States
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`involved a telephone directly connected to a human operator. A portion of the phone rested on a
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`mechanical hook such that the operator was signaled when the portion was lifted from the hook.
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`A caller would then say the name of the person they wished to call to the operator. If the callee
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`was connected to the same telephone switch board the operator would physically pull out a cable
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`associated with the caller’s phone and plug the cable into a socket associated with the callee’s
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`telephone. If the callee was associated with a different switchboard, and thus out of reach of the
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`operator, a second operator would be involved to bridge the gap to the appropriate switchboard.
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`While initially very effective compared to no telephone service, this structure quickly proved
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`error prone (operators would connect the wrong party), and limiting the number of possible
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`telephones because of the physical limits of switchboards and cable to be pulled. This basic
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`system corresponds to the introduction of a Plain Old Telephone Service (“POTS”) connection to
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`the operator. In these configurations, there was a dedicated, point-to-point electrical connection
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`between the caller and the callee.
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`16.
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`Rotary dialing eventually was introduced, beginning at around the turn of the 20th
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`century, where a rotary disk was marked with numbers from zero to nine. A caller would spin the
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`wheel and a mechanical device in the telephone would cause a sequence of electrical pulses to be
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`sent to the network corresponding to the digit dialed, for example, four pulses would be sent for
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`the number four. Rather than speaking to a human operator, an electric device would count the
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`pulses and begin to route a call once an appropriate and valid sequence of digits was dialed by
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`the caller. This advancement improved reliability of call routing and reduced the time required to
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`initiate a call. But, even so, there was a dedicated, point-to-point electrical connection between
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`the caller and the callee. As multiple companies entered the market of telephone service and the
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`number of customers increased, an issue emerged where a caller would be a customer of one
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`telephone company and the callee would be a customer of another. The solution that emerged to
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`this problem was to introduce trunk lines, which connect one company to another.
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`17.
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`Eventually, as the number of companies continued to increase and telephone
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`services spread over much larger geographic areas, the notion of a Public Switched Telephone
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`Service (“PSTN”) emerged. The term derives from the notion, at least in part, that the dedicated
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`wires used to connect the caller and callee were “circuit-switched” to connect the two. The PSTN
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`developed gradually into the middle of the 20th century, still built around the notion of rotary
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`dialing and POTS connections to the individual telephones. These calls involved analog
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`communications over circuit-switched electrical connections. A circuit-switched network
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`involves assigning dedicated resources, such as switch settings and specific wires, to establish a
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`link from the caller to the callee. While the call is ongoing, these resources cannot be used for
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`any other communications.
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`18.
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`The next important advancement for consumer telephone service, introduced
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`broadly during the second half of the 20th century, was the introduction of push-button
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`telephones. With such telephones the rotary dial was replaced by a matrix of buttons, each
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`labeled with a digit from zero through nine along with the additions of ‘*’ and ‘#’. The
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`underlying signaling technology was called dual-tone multiple-frequency (“DTMF”) and
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`involves two different audible tones being sent simultaneously from the telephone into the
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`telephone network. A receiver within the network decoded these tones and formed them into a
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`sequence of digits indicating the number of the callee.
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`19.
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`Around this same time a scheme for international telephone addressing was
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`introduced, with a numeric protocol for identifying one country from another and providing
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`country-specific routing within the destination country. The E.164 standard now documents how
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`a caller anywhere in the world, for example in Ann Arbor, Michigan, can identify a telephone
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`number at any other location, such as Avignon, France. While many of these advances, such as
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`DTMF dialing and automated international routing, may have been originally introduced via ad
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`hoc methods, eventually they required multiple parties (companies and governments) to agree on
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`protocols to enable wide-spread reliable use and inter-operability among different telephone
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`communications networks. Even with all these advances, the systems still relied on circuit-
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`switched technology that dedicated resources between the caller and the callee for the duration of
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`a call. The move to take human operators out of the loop, with the introduction of rotary dialing,
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`combined with the fast increase in demand for telephone services throughout the 20th century,
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`resulted in the development of automated telephone switches. These devices comprise a set of
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`input ports, each dedicated to, and associated with a specific caller, and output ports, each
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`capable of being associated with a callee. A small local telephone system may have had a single
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`switch while a larger service would use a large number of switches that were connected to each
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`other. A switch from a local service provider would be connected to a trunk line which then
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`connected to an input switch of another service provider. These switches originally supported
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`analog voice calls initiated via rotary dialing and dedicating input and output ports as well as
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`physical wires for each circuit-switched call.
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`20.
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`Eventually analog voice services were replaced within the network with digital
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`voice. Digital voice is communicated using a sequence of chunks (or packets) of data. This
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`advancement allowed physical resources to be shared among multiple calls over short bursts of
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`time. For example, a physical wire can move a packet for one call at a specific instance in time
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`and then move a packet for a totally different call subsequently, only to later return to transfer a
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`new packet for the original call. This advance is called packet-switched communications and
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`provided an important increase in network reliability and efficiency while driving down the cost.
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`However, in most situations throughout the 20th century (and often still today), the connection to
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`the end user’s physical telephone is analog. While network switches operate via digital circuitry,
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`and often comprise programmable processors executing software, they tend to be dedicated
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`special-purpose devices. The conversion between analog and digital encoding is typically done at
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`the point where the PSTN network switch connects to the POTS handset, for example, at a
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`device called a Class-5 telephone switch, which connects the customer POTS handset to the
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`PSTN network of a service provider’s central office.
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`21.
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`The Internet became important to consumers, via broad deployment, during the
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`late 1980’s and early 1990’s. Eventually available bandwidth and reliability increased to the
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`point where pioneers began to experiment with techniques to carry voice communications over
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`the Internet. These early efforts began to focus on techniques called Voice Over Internet Protocol
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`(VOIP) and session initiation protocol (SIP). VOIP provided a consistent set of protocols and
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`mechanisms for moving digital voice packets between two callers using the Internet rather than
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`existing PSTN networks. SIP provided a mechanism for establishing and terminating
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`communication sessions such as calls between users of a VOIP service. For example, a callee
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`could register with a VOIP service so that an identifier (such as their name, email address or a
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`nickname) could be associated with the computer to which they are logged in. Eventually VOIP
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`services increased to provide interoperability with the existing PSTN services. For example, the
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`company Skype began to allow a user to call a PSTN number using a feature marketed as “Skype
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`out”. However, the user was required to explicitly classify the call as a PSTN call by specifying a
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`real physical telephone number. In this case the VOIP system must include a gateway to bridge
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`from the VOIP network to the PSTN network in order to route to the physical telephone. Calls
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`that use a proprietary non-PSTN user identifier such as an email or nickname remain within the
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`VOIP network and are not routed to the PSTN network and do not connect to a POTS telephone.
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`22.
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`The advent of VOIP technology allowed customers to physically move their
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`telephones from one location to another, even from one continent to another, with no
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`fundamental change in its operation from the point of view of a caller once a connection to the
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`Internet was established. However, the integration of network gateways to route between
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`different types of networks using VOIP, for example from a VOIP caller in Europe to a PSTN
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`callee in the United States, introduced a number of new complications. The VOIP service needed
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`to be able to distinguish between callees that were within the VOIP network and those that were
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`outside of it and thus required different methods for identifying callees and routing to them
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`depending on whether the callees were within or outside the VOIP network. One way to identify
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`callees on the VOIP network was to use a predefined proprietary user identifier such as an email
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`or nickname. The VOIP service provider also needed to interpret dialed PSTN numbers in order
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`to correctly route calls to a PSTN callee. A VOIP caller had to use different types of callee
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`identifier depending on whether or not the destination (callee) they were calling was within the
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`VOIP network or not. The caller’s choice of the type of callee identifier thus specified the
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`network of the destination to be called. However, the asserted patents disclose and claim a
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`distinct manner of call routing.
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`23.
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`Digifonica, a wholly owned subsidiary of patent owner VoIP-Pal, starting in 2004
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`eventually came to employ over a dozen top professionals (e.g., software developers, system
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`administrators, QA/test analysts) including three Ph.D.’s with engineering backgrounds, to
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`develop innovative software solutions for communications. Digifonica spent over $15,000,000
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`researching, developing, and testing a communication solution capable of seamlessly integrating
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`a private voice-over-IP (“VoIP”) communication network with an external network (i.e., the
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`“public switched telephone network” or “PSTN”), by bridging the disparate protocols,
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`destination identifiers and addressing schemes used in the two networks. By the mid-2000’s,
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`Digifonica had successfully tested intra- and inter-network communications (i.e.,
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`communications within the private Digifonica system and between the Digifonica system and the
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`PSTN) by implementing high-capacity communication nodes across three geographic regions,
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`including actual working communication nodes in Vancouver (Canada) and London (UK). See
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`’606 patent at Fig. 1 (nodes 11, 21) and 13:57-14:7. Digifonica’s R&D efforts led to a number
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`of patent grants, including U.S. Patent No. 8,542,815, to which the Patent-in-Suit claims priority.
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`24.
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`Prior to the ‘815 patent, private branch exchange (PBX) systems typically enabled
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`users to call destinations internal to the PBX by dialing an extension (i.e., “private number”) and
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`destinations external to the PBX on the public switched telephone network (PSTN) by dialing a
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`“public number.” Such PBX systems relied on a user-specified classification of the dialed
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`number to interpret the number and route the call. For example, a user placing a call to the public
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`network dialed a predefined prefix such as “9” to indicate that subsequent digits were to be
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`interpreted as a public PSTN number. If no prefix was dialed, the dialed digits were to be
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`interpreted as a private PBX extension. The number alone, as dialed, dictated how the call was
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`routed. Thus, the user made an affirmative decision when placing a call as to whether the call
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`would be routed over a public or private network.
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`25.
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`Digifonica’s system employed an approach fundamentally different from
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`traditional PBX’s: it did not rely on a caller-specified classification (e.g., a prefix digit) to
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`distinguish private calls from PSTN calls. Digifonica provided flexible, user-specific dialing
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`features and could decouple the type of number being called from the manner in which the call
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`would be handled. For example, even if a public PSTN number was dialed, Digifonica’s system
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`could determine that the call should be routed to an internal destination on its private network,
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`thus allowing the advantages of private network calling even if callers were unaware that the call
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`recipient (“callee”) was a Digifonica system subscriber. If, on the other hand, the PSTN number
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`represented a destination on an external network (e.g., the public network), the Digifonica
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`system facilitated the routing of the call to the destination through a gateway.
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`26.
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`VoIP-Pal’s/Digifonica’s technology and patents represent fundamental
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`advancements to Internet Protocol (“IP”) based communication, including improved functioning,
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`classification, routing and reliability of Voice-over-IP (VoIP) and IP-based transmission of
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`video, photographs, messages and mixed media, as well as improved interoperability of IP-based
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`private communication networks with external networks, such as the public switched telephone
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`network (PSTN), interconnected with the private communication networks via one or more
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`gateways.
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`27.
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`The Patent-in-suit provides, inter alia, improvements in routing controllers,
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`processes, networks and systems. Several illustrative examples of such improvements are briefly
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`described below, although the patented invention is not limited to these specific improvements or
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`examples.
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`28.
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`The public switched telephone network (PSTN) connected callers through nodes
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`such as central offices or exchanges. Because these nodes were limited to providing services
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`only to subscribers in a “local calling service area,” they required callers to place calls in a
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`specific manner, e.g., by requiring the use of certain dialing patterns and conventions associated
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`with that local area. See ’606 patent at 1:42-46. For example, it was known to persons of skill in
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`the field of the invention that PSTN nodes conventionally required PSTN callers to dial in a
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`manner compatible with a local numbering plan (e.g., a plan consistent with the “North
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`American Numbering Plan” or “National Numbering Plan,” in use by AT&T as early as about
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`the 1940’s and further developed in later years) as well as to dial in a manner compatible with
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`international standards such as those of the International Telecommunications Union (ITU)
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`Telecommunications Standardization Sector (ITU-T). See ’606 patent at 19:52-66. For example,
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`it is known in the field of telephony that early numbering plans assigned an “area code” of 312
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`for calling Illinois, and that this code (312) remains in use even today as an area code for
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`Chicago. To take another example, the ITU designates “44” as a “country code” for calling the
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`United Kingdom. Id. at Fig. 12 (“County Code” attribute for London user is “44”).
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`29.
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`Large organizations were able to avoid PSTN dialing constraints, at least for
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`internal calls, by using private branch exchanges (PBXs) and private numbering plans for their
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`internal private telephone networks, but these PBXs also needed to provide caller access to the
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`PSTN. See ’606 patent at 1:35-48. As Andy Valdar has explained in his textbook, “Businesses
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`which have more than a few telephones use a private branch exchange system, known as a PBX,
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`to provide call connections between each telephone (which become ‘extensions’) and links into
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`the PSTN... The PBX is really a small version of the PSTN exchanges, typically ranging in sizes
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`from 10 up to 5,000 extensions. A private numbering scheme is required to enable extension to
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`extension dialing, also special codes (e.g. ‘dial 9’) are required to enable calls to be made to the
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`PSTN. [...] In the case where a company extends over two or more sites (e.g. office or factory
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`buildings) the PBXs on each site can be linked by private circuits, thus enabling calling between
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`all the extensions. This is known as a ‘private corporate network’ (or just ‘private network’). In
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`this case the private numbering scheme extends across all the PBXs and usually each PBX is
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`linked to the PSTN.” (See Valdar, Andy, Understanding Telecommunications Networks, The
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`Institution of Engineering and Technology, London, UK, 2006, p. 38 (emphasis added)).
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`30.
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`It was well-understood, routine and conventional for PBXs to require users to dial
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`a special code (e.g., a prefix digit of “9”) if they wanted to place a call on the PSTN, as noted by
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`Valdar and numerous other sources. For example, one telecom dictionary distinguishes between
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`dialing an “internal PBX station number” and an “external number,” wherein in the latter case,
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`“the user must dial an access code in order to gain access to an external trunk connected to the
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`public switched telephone network (PSTN)... The conventional access code is nine (9) in the
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`United States and Canada, and zero (0) in most other countries”. (See Ray Horak, Webster’s
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`New World Telecom Dictionary, Wiley Publishing, Inc., Indianapolis, Indiana, 2008, p.133
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`[emphasis added]). To take another example, U.S. Patent No. 3,725,596 to Maxon et al.
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`(“Maxon”), filed in 1971, discloses an discloses an early private branch exchange (PBX) having
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`equipment for automatically generating and transmitting calling station and trunk number
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`information to a central office on outgoing calls. Maxon indicates that “a calling party at station
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`ST10... dials a prefix digit, such as the conventional prefix digit 9, to initiate an outgoing call to
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`the central office. The digit 9 is... detected by the dial 9 detector 152. Upon the detection of this
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`digit, the register control circuit 153 advises common control that the digit 9 has been dialed for
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`a central office call.” [emphasis added]. Maxon at 9:66-10:6; see also Fig. 1B (152), 8:58-68,
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`9:21, 9:38-40, 13:3-6, 14:6-7 and at 14:59. Webster’s New World Telecom dictionary and
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`Maxon both confirm that it was considered “conventional” to use a prefix digit such as “9” to
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`place a PSTN call from a PBX. The Patent-in-Suit eschewed such well-understood, routine and
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`conventional approaches to integrating these two networks.
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`31.
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`A person of skill in the art (POSITA), upon review of the Patent-in-Suit, would
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`understand that the disclosed embodiments are inherently computer based. The POSITA would
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`further appreciate that the asserted claims of the Patent-in-Suit are necessarily rooted in
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`computer technology for the operation of communication networks, and provide technical
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`improvements to overcome certain technical limitations of prior art routing processes, systems
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`and networks, viz., that the asserted claims provide technology solutions for one or more of: (1)
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`user-specific communication handling, (2) transparent routing, and (3) network resiliency and (4)
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`communication blocking.
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`Case 6:20-cv-00267-ADA Document 1 Filed 04/02/20 Page 15 of 29
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`32.
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`User-Specific Communication Handling: Many prior art communication systems
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`required users to place a call by using a specific callee identifier format or by following certain
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`dialing conventions with no opportunity for defining a user-specific manner of placing calls. For
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`example, as discussed above, PSTN nodes were typically limited to supporting only the dialing
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`conventions of their local calling service area and processed calls locally (See ’606 patent at
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`1:42-46) and did not support user-specific calling. The technology disclosed in the Patent-in-Suit
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`and recited in the asserted claims overcomes such technical limitations and supports user-specific
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`calling styles, e.g., calling styles from any continent or country based on the application of user-
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`specific attributes and network classification criteria to callee identifiers to route a call. It is
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`unnecessary for the user to do anything special to “trigger” such user-specific call processing.
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`See, e.g., ’606 patent at 15:48-60 and 19:36-51 (disclosing storing user-specific parameters in
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`association with each subscriber/user), 19:18-42 (describing a user-specific “dialing profile”
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`capable of supporting numerous global styles of dialing), and Figs. 8A-8D (disclosing steps for
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`processing a routing request based in part on user-specific parameters). By evaluating a called
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`party identifier based on profile settings or “attributes” associated with the calling party, the
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`technology provides an individually customizable manner of initiating a communication to a
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`destination party. To be clear, it is not merely a calling party’s identifier (i.e., “caller ID” or
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`“caller identifier”) that is used to evaluate the called party’s identifier (e.g., “callee identifier”);
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`rather, a caller-specific profile, identifying caller-specific parameters/attributes, is used to
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`evaluate the called party’s identifier, to determine the routing destination and to engage the
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`appropriate infrastructure for effecting the communication. A skilled person in the field of the
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`invention would recognize, in light of the patent specification, that this approach is capable of
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`fulfilling various individual service preferences among users for initiating communications (e.g.,
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`Case 6:20-cv-00267-ADA Document 1 Filed 04/02/20 Page 16 of 29
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`any desired PSTN dialing style, unconventional dialing styles, and even use of special callee
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`identifiers such as usernames). See id. at 19:36-48; 20:33-47; 22:3-23:22. To give just one
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`illustrative example, the profiles of two different users may specify different ways of dialing an
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`international call (e.g., an “IDD” attribute in the two user profiles may be set to either “011” or
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`“00”: see id. “IDD” attributes in the profiles shown in Figs. 11 and 12; compare blocks 257-259
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`in Fig. 8B). All of the asserted claims of the Patent-in-Suit enable user-specific handling of
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`communications; in particular, every claim recites user-specific attributes that are associated with
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`a user-specific profile of the calling party, used for determining and establishing routing to the
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`destination. Enabling a communication system, node, or routing controller to provide
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`customized, user-specific communication handling to individual users represents a technological
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`improvement over conventional prior art communication systems, nodes, routing controllers and
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`methods that simply imposed a “one-size-fits-all” methods of communication on all users.
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`33.
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`Routing Transparency: Some prior art communication sy