Case 6:22-cv-00031-ADA Document 43-13 Filed 07/19/22 Page 1 of 83
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`Exhibit 13
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`Case 6:22-cv-00031-ADA Document 43-13 Filed 07/19/22 Page 2 of 83
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`NOTE: Defendant applies the prior art in light of Defendant’s current understanding of the asserted claims and Plaintiff’s apparent
`construction of those claims, as reflected in Plaintiff’s Infringement Contentions. Defendant’s prior art invalidity contentions may reflect
`alternative positions as to claim construction and scope and do not represent any admissions or agreement by Defendant as to the
`construction meaning, scope, definiteness, function, structure, written description support for, or enablement of any claim contained
`herein. Defendant’s contentions herein are not, and should in no way be seen as, any admission that Defendant’s accused technology
`meets any limitations of the claims.
`
`
`Exhibit B-1
`
`
`
`U.S. 2011/0026468 (“Conrad”)
`vs.
`Claims of Asserted U.S. Patent Nos. 9,667,770 (“’770 Patent”), and 10,051,105 (“’105 Patent”)
`
`Asserted Patent/Claim
`’770 Patent
`[1.Preamble] A method of
`providing telephone service,
`the method comprising:
`
`Conrad
`
`
`To the extent the preamble is construed as limiting, Conrad et al. discloses “[a] method of providing
`telephone service, the method comprising[.]”
`
`“The subject matter of this specification can be implemented in, among other things, a computer-
`implemented method for centralized routing of voice communication over multiple communication
`networks including receiving at an electronic call routing system an incoming call from a calling
`device to a first telephone number of a mobile device. The method further includes selecting a calling
`address of the mobile device from among a voice over internet protocol address of the mobile device
`on an internet protocol network and a cellular telephone number of the mobile device on a cellular
`telephone network. The first telephone number is different than the cellular telephone number and
`the selection of the calling address is performed substantially without participation by the cellular
`telephone network. The method further includes connecting the incoming call to the selected calling
`address of the mobile device.” Conrad at Abstract.
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`“In general, a mobile telephone device may be assigned two contact numbers. The first number can
`be used to home the device to a network of a cellular telephone carrier. The first number may not be
`seen by the user, but can be used as a gateway to the mobile virtual network operator (MVNO) for
`the carrier. The second number is the “public number for the device and can be a universal access
`number like that provided by a service such as GRANDCENTRAL (now GOOGLE VOICE).” Id.
`at [0005].
`
`“In a first aspect, a computer-implemented method for centralized routing of voice communication
`over multiple communication networks includes receiving at an electronic call routing system an
`incoming call from a calling device to a first telephone number of a mobile device. The electronic
`call routing system is in communication with an internet protocol network and a cellular telephone
`network. The method further includes in response to receiving the incoming call to the first telephone
`number of the mobile device, selecting a calling address of the mobile device from among a voice
`over internet protocol address of the mobile device on the internet protocol network and a cellular
`telephone number of the mobile device on the cellular telephone network. The first telephone number
`is different than the cellular telephone number and the selection of the calling address is performed
`substantially without participation by the cellular telephone network. The method further includes
`connecting the incoming call to the selected calling address of the mobile device.” Id. at [0006].
`
`“In a second aspect, a computer-implemented system for centralized routing of voice communication
`over multiple communication networks includes a first interface in communication with a public
`switched telephone network connected to a cellular telephone network. The system further includes
`a second interface in communication with an internet protocol network. The system further includes
`a computerized call router that receives an incoming call from a calling device to a first telephone
`number of a mobile device, selects a calling address of the mobile device from among a voice over
`internet protocol address of the mobile device on the internet protocol network and a cellular
`telephone number of the mobile device on the cellular telephone network. The first telephone number
`is different than the cellular telephone number and the selection of the calling address is performed
`substantially without participation by the cellular telephone network.” Id. at [0008].
`
`“[A]n incoming telephone call to a mobile device can be routed through a Voice over Internet
`Protocol (VoIP) communication network if the mobile device is currently connected to an Internet
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`Protocol (IP) network or a cellular telephone network if the mobile device is currently connected to
`the cellular telephone network.” Id. at [0019].
`
`“FIG. 1 is a schematic diagram showing an example of a system 100 for routing a telephone call to
`or from a mobile device 102. The mobile device 102 is a device capable of receiving or initiating
`telephone calls over multiple wireless connection types.” Id. at [0019].
`
`“In some implementations, the cellular telephone network 104 uses a code division multiple access
`(CDMA) protocol (e.g., CDMA2000), a time division multiple access (TDMA) protocol (e.g.,
`GSM), or another cellular telephone communication protocol. The mobile device 102 may also be
`capable of communicating over multiple different such networks. The mobile device 102 can connect
`to the Internet 106 through multiple wireless network interfaces in certain implementations, such as
`a wireless local area network 108 (e.g., a Wi-Fi network) and a wireless wide area network 110 (e.g.,
`a WiMAX network).” Id. at [0021].
`
`“[T]he central call routing system 112 can receive the incoming call 114a from a telephone device
`116. The central call routing system 112 receives the incoming call 114a over a telephone network
`118, such as a public switched telephone network (PSTN). The system 100 can further include a call
`termination system 120. The call termination system 120 provides connectivity between the
`telephone network 118, the cellular telephone network 104, and the central call routing system 112.
`In some implementations, the central call routing system 112 can also receive the incoming call 114b
`to the mobile device 102 from a computer device 122. In some implementations, the central call
`routing system 112 can receive the incoming call 114b over the Internet 106.” Id. at [0022].
`
`“In some implementations, when placing a telephone call to the mobile device 102, a calling device,
`such as the telephone device 116, dials a first telephone number of the mobile device 102 that is
`directed to the central call routing system 112. For example, the telephone network 118 may direct
`the incoming call 114a to the call termination system 120. The call termination system 120 then
`directs the incoming call 114a to the central call routing system 112. The central call routing system
`112 then selects a route to the mobile device 102 over the Internet 106 or over the cellular telephone
`network 104.” Id. at [0033].
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`[1.A] associating a
`secondary telephone number
`with a primary telephone
`number in at least one
`computer memory device,
`the primary telephone
`number being assigned to a
`handset;
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions.
`Conrad et al. discloses “associating a secondary telephone number with a primary telephone number
`in at least one computer memory device, the primary telephone number being assigned to a
`handset[.]”
`
`“The subject matter of this specification can be implemented in, among other things, a computer-
`implemented method for centralized routing of voice communication over multiple communication
`networks including receiving at an electronic call routing system an incoming call from a calling
`device to a first telephone number of a mobile device. The method further includes selecting a calling
`address of the mobile device from among a voice over internet protocol address of the mobile device
`on an internet protocol network and a cellular telephone number of the mobile device on a cellular
`telephone network. The first telephone number is different than the cellular telephone number and
`the selection of the calling address is performed substantially without participation by the cellular
`telephone network. The method further includes connecting the incoming call to the selected calling
`address of the mobile device.” Conrad at Abstract.
`
`“In general, a mobile telephone device may be assigned two contact numbers. The first number can
`be used to home the device to a network of a cellular telephone carrier. The first number may not be
`seen by the user, but can be used as a gateway to the mobile virtual network operator (MVNO) for
`the carrier. The second number is the “public number for the device and can be a universal access
`number like that provided by a service such as GRANDCENTRAL (now GOOGLE VOICE).” Id.
`at [0005].
`
`“In a first aspect, a computer-implemented method for centralized routing of voice communication
`over multiple communication networks includes receiving at an electronic call routing system an
`incoming call from a calling device to a first telephone number of a mobile device. The electronic
`call routing system is in communication with an internet protocol network and a cellular telephone
`network. The method further includes in response to receiving the incoming call to the first telephone
`number of the mobile device, selecting a calling address of the mobile device from among a voice
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`over internet protocol address of the mobile device on the internet protocol network and a cellular
`telephone number of the mobile device on the cellular telephone network. The first telephone number
`is different than the cellular telephone number and the selection of the calling address is performed
`substantially without participation by the cellular telephone network. The method further includes
`connecting the incoming call to the selected calling address of the mobile device.” Id. at [0006].
`
`“FIG. 1 is a schematic diagram showing an example of a system 100 for routing a telephone call to
`or from a mobile device 102. The mobile device 102 is a device capable of receiving or initiating
`telephone calls over multiple wireless connection types.” Id. at [0019].
`
`
`
`
`“The central call routing system 112 may perform a number of different functions with respect to
`communication services provided to a user of the mobile device 102. For example, the central call
`routing system 112 may permit a user to define call routing rules to various communication devices
`that the user employs. For example, the central call routing system 112 can assign a single incoming
`telephone number to the user, and may forward incoming calls in real time to whatever device the
`user is currently in possession of. As one simple example, the user can define rules so that incoming
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`calls are routed to the user's work telephone during business hours and the user's home telephone
`outside of business hours. Also, the central call routing system 112 can perform call screening (e.g.,
`by identifying incoming calls as corresponding to telephone numbers of people with whom the user
`does not wish to speak) and other such telecommunication management functions.” Id. at [0023].
`
`“The central call routing system 112 can connect the incoming call 114a through the route 124c over
`the cellular telephone network 104 by forwarding the call to a second telephone number. The cellular
`telephone carrier that operates the cellular telephone network 104 uses the second telephone number
`to direct calls to the mobile device 102 over the cellular telephone network 104. For example, the
`central call routing system 112 redirects the call placed by the telephone device 116 to the second
`telephone number. The call termination system 120 processes the redirected call from the central call
`routing system 112. The call termination system 120 sends the redirected call to the telephone
`network 118 and/or the cellular telephone network 104. The cellular telephone network 104 passes
`the redirected call to the mobile device 102 which has been assigned the second telephone number.”
`Id. at [0034].
`
`“[A] cellular telephone number associated with the mobile device 102 can be determined by the
`central call routing system 112. Such as by recording the cellular telephone number upon issuing the
`mobile device 102 to a user or by setting the cellular telephone number of the mobile device 102.”
`Id. at [0035].
`
`“In general, the selection of a route to the mobile device 102 by the central call routing system 112
`does not substantially include participation by the cellular telephone network 104, other than to send
`a redirected call to the second (cellular) telephone number of the mobile device 102.” Id. at [0037].
`
`“In some implementations, the mobile device 102 can have multiple cellular telephone numbers. For
`example, the mobile device 102 can have a Subscriber Identity Module (SIM) card for a first cellular
`network and another SIM card for a second cellular network. In some implementations, the cellular
`telephone numbers of the mobile device 102 are only associated with a single device. In some
`implementations, the telephone number for the mobile device 102 that is first directed to the central
`call routing system 112 may be routed to multiple devices, either one at a time or concurrently.” Id.
`at [0039].
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`“FIG. 3 is a flow chart showing an example of a process 300 for routing a telephone call to a mobile
`device. The process 300 begins with receiving (302) an incoming call from a calling device to a first
`telephone number of a mobile device. For example, the central call routing system 112 can receive
`the incoming calls 114a–b from the telephone device 116 and the computer device 122 to the first
`telephone number of the mobile device 102. The first telephone number of the mobile device 102
`first directs the incoming calls 114a-b to the central call routing system 112.” Id. at [0058].
`
`
`“The mobile computing device 550 may communicate wirelessly through the communication
`interface 566, which may include digital signal processing circuitry where necessary. The
`communication interface 566 may provide for communications under various modes or protocols,
`such as GSM voice calls (Global System for Mobile communications), SMS (Short Message
`Service), EMS (Enhanced Messaging Service), or MMS messaging (Multimedia Messaging
`Service), CDMA (code division multiple access), TDMA (time division multiple access), PDC
`(Personal Digital Cellular), WCDMA (Wideband Code Division MultipleAccess), CDMA 2000, or
`GPRS (General Packet Radio Service), among others. Such communication may occur, for example,
`through the transceiver 568 using a radio-frequency. In addition, short-range communication may
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`occur, Such as using a Bluetooth, WiFi, or other such transceiver (not shown). In addition, a GPS
`(Global Positioning System) receiver module 570 may provide additional navigation- and location-
`related wireless data to the mobile computing device 550, which may be used as appropriate by
`applications running on the mobile computing device 550.” Id. at [0076].
`
`“The systems and techniques described here can be implemented in a computing system that includes
`a back end component (e.g., as a data server), or that includes a middleware component (e.g., an
`application server), or that includes a front end component (e.g., a client computer having a graphical
`user interface or a Web browser through which a user can interact with an implementation of the
`systems and techniques described here), or any combination of such backend, middleware, or front
`end components.” Id. at [0082].
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions.
`Conrad et al. discloses “acquiring first digital information from the handset over at least one data
`channel, the first digital information indicating primary call processing rules for handling calls
`directed to the primary telephone number[.]”
`
`“In a first aspect, a computer-implemented method for centralized routing of voice communication
`over multiple communication networks includes receiving at an electronic call routing system an
`incoming call from a calling device to a first telephone number of a mobile device. The electronic
`call routing system is in communication with an internet protocol network and a cellular telephone
`network. The method further includes in response to receiving the incoming call to the first telephone
`number of the mobile device, selecting a calling address of the mobile device from among a voice
`over internet protocol address of the mobile device on the internet protocol network and a cellular
`telephone number of the mobile device on the cellular telephone network. The first telephone number
`is different than the cellular telephone number and the selection of the calling address is performed
`substantially without participation by the cellular telephone network. The method further includes
`connecting the incoming call to the selected calling address of the mobile device.” Conrad at [0006].
`
`
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`[1.B] acquiring first digital
`information from the handset
`over at least one data
`channel, the first digital
`information indicating
`primary call processing rules
`for handling calls directed to
`the primary telephone
`number;
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`Case 6:22-cv-00031-ADA Document 43-13 Filed 07/19/22 Page 10 of 83
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`“[T]he central call routing system 112 can receive the incoming call 114a from a telephone device
`116. The central call routing system 112 receives the incoming call 114a over a telephone network
`118, such as a public switched telephone network (PSTN). The system 100 can further include a call
`termination system 120. The call termination system 120 provides connectivity between the
`telephone network 118, the cellular telephone network 104, and the central call routing system 112.
`In some implementations, the central call routing system 112 can also receive the incoming call 114b
`to the mobile device 102 from a computer device 122. In some implementations, the central call
`routing system 112 can receive the incoming call 114b over the Internet 106.” Id. at [0022].
`
`“The central call routing system 112 may perform a number of different functions with respect to
`communication services provided to a user of the mobile device 102. For example, the central call
`routing system 112 may permit a user to define call routing rules to various communication devices
`that the user employs. For example, the central call routing system 112 can assign a single incoming
`telephone number to the user, and may forward incoming calls in real time to whatever device the
`user is currently in possession of. As one simple example, the user can define rules so that incoming
`calls are routed to the user's work telephone during business hours and the user's home telephone
`outside of business hours. Also, the central call routing system 112 can perform call screening (e.g.,
`by identifying incoming calls as corresponding to telephone numbers of people with whom the user
`does not wish to speak) and other such telecommunication management functions.” Id. at [0023].
`
`“In some implementations, when placing a telephone call to the mobile device 102, a calling device,
`such as the telephone device 116, dials a first telephone number of the mobile device 102 that is
`directed to the central call routing system 112. For example, the telephone network 118 may direct
`the incoming call 114a to the call termination system 120. The call termination system 120 then
`directs the incoming call 114a to the central call routing system 112. The central call routing system
`112 then selects a route to the mobile device 102 over the Internet 106 or over the cellular telephone
`network 104.” Id. at [0033].
`
`“The central call routing system 112 can connect the incoming call 114a through the route 124c over
`the cellular telephone network 104 by forwarding the call to a second telephone number. The cellular
`telephone carrier that operates the cellular telephone network 104 uses the second telephone number
`to direct calls to the mobile device 102 over the cellular telephone network 104. For example, the
`central call routing system 112 redirects the call placed by the telephone device 116 to the second
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`telephone number. The call termination system 120 processes the redirected call from the central call
`routing system 112. The call termination system 120 sends the redirected call to the telephone
`network 118 and/or the cellular telephone network 104. The cellular telephone network 104 passes
`the redirected call to the mobile device 102 which has been assigned the second telephone number.”
`Id. at [0034].
`
`“[A] cellular telephone number associated with the mobile device 102 can be determined by the
`central call routing system 112. Such as by recording the cellular telephone number upon issuing the
`mobile device 102 to a user or by setting the cellular telephone number of the mobile device 102.”
`Id. at [0035].
`
`“FIG. 2 is a block diagram showing an example of a central call routing system 200 for routing a
`telephone call to or from a mobile device. The central call routing system 200 includes an interface
`202 and an interface 204. The interface 202 provides communication with an IP network. The
`interface 204 provides communication with a public switched telephone network including a cellular
`telephone network. The central call routing system 200 can receive an incoming call 206 through the
`interface 204 or an incoming call 208 through the interface 202.” Id. at [0041].
`
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`[1.C] storing the primary call
`processing rules in the at
`least one computer memory
`device;
`
`“The routing rules 216 can be stored at the central call routing system 200 or another location
`accessible by the call router 210. The routing rules 216 may be predefined by administrators of the
`central call routing system 200. In some implementations, the user of the mobile device may specify
`one or more of the routing rules 216. Such as through a webpage interface. For example, the central
`call routing system 200 can provide a web page to the user through the interface 202 that allows the
`user to access and modify the routing rules 216 to be applied to the user's mobile device.” Id. at
`[0043].
`
`“If the mobile device finds a pending incoming call in the queue, then the mobile device can take
`appropriate action, such as alerting the user with an audible ring, a flashing light, and/or a vibration.”
`Id. at [0051].
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions.
`Conrad et al. discloses “storing the primary call processing rules in the at least one computer memory
`device[.]”
`
`See ’770 Patent, 1.B, supra.
`
`“The routing rules 216 can be stored at the central call routing system 200 or another location
`accessible by the call router 210. The routing rules 216 may be predefined by administrators of the
`central call routing system 200. In some implementations, the user of the mobile device may specify
`one or more of the routing rules 216. Such as through a webpage interface. For example, the central
`call routing system 200 can provide a web page to the user through the interface 202 that allows the
`user to access and modify the routing rules 216 to be applied to the user's mobile device.” Conrad at
`[0043].
`
`“The mobile device status updater 218 stores the status updates 220 in a data storage 222.” Id. at
`[0045].
`
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`“The computing device 500 includes a processor 502 ,a memory 504, a storage device 506, a high-
`speed interface 508 connecting to the memory 504 and multiple high-speed expansion ports 510, and
`a low-speed interface 512 connecting to a low-speed expansion port 514 and the storage device 506.
`Each of the processor 502, the memory 504, the storage device 506, the high-speed interface 508,
`the high-speed expansion ports 510, and the low-speed interface 512, are interconnected using
`various busses, and may be mounted on a common motherboard or in other manners as appropriate.
`The processor 502 can process instructions for execution within the computing device 500, including
`instructions stored in the memory 504 or on the storage device 506 to display graphical information
`for a GUI on an external input/output device, such as a display 516 coupled to the high-speed
`interface 508. In other implementations, multiple processors and/or multiple buses may be used, as
`appropriate, along with multiple memories and types of memory. Also, multiple computing devices
`may be connected, with each device providing portions of the necessary operations (e.g., as a server
`bank, a group of blade servers, or a multi-processor system).” Id. at [0066].
`
`“The computing device 500 may be implemented in a number of different forms, as shown in the
`figure. For example, it may be implemented as a standard server 520, or multiple times in a group of
`such servers. In addition, it may be implemented in a personal computer Such as a laptop computer
`522. It may also be implemented as part of a rack server system 524. Alternatively, components from
`the computing device 500 may be combined with other components in a mobile device (not shown),
`such as a mobile computing device 550. Each of such devices may contain one or more of the
`computing device 500 and the mobile computing device 550, and an entire system may be made up
`of multiple computing devices communicating with each other.” Id. at [0070].
`
`“The systems and techniques described here can be implemented in a computing system that includes
`a back end component (e.g., as a data server), or that includes a middleware component (e.g., an
`application server), or that includes a front end component (e.g., a client computer having a graphical
`user interface or a Web browser through which a user can interact with an implementation of the
`systems and techniques described here), or any combination of such backend, middleware, or front
`end components.” Id. at [0082].
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
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`[1.D] acquiring second
`digital information from the
`handset over the at least one
`data channel, the second
`digital information indicating
`secondary call processing
`rules for handling calls
`directed to the secondary
`telephone number;
`
`[1.E] storing the secondary
`call processing rules in the at
`least one computer memory
`device;
`
`[1.F] receiving an incoming
`call over at least one voice
`channel at a switch, the
`switch being associated with
`a bridge telephone number
`such that calls directed to the
`bridge telephone number are
`automatically routed to the
`switch, the incoming call
`being directed to a handset-
`
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions.
`Conrad et al. discloses “acquiring second digital information from the handset over the at least one
`data channel, the second digital information indicating secondary call processing rules for handling
`calls directed to the secondary telephone number[.]”
`
`See ’770 Patent, 1.B, supra.
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions
`Conrad et al. discloses “storing the secondary call processing rules in the at least one computer
`memory device[.]”
`
`See ’770 Patent, 1.C, supra.
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses the
`limitation. To the extent this reference does not expressly or inherently disclose this limitation, it
`renders the limitation obvious in light of the reference by itself or in combination with other
`references, as described in Defendant’s invalidity contentions
`Conrad et al. discloses “receiving an incoming call over at least one voice channel at a switch, the
`switch being associated with a bridge telephone number such that calls directed to the bridge
`telephone number are automatically routed to the switch, the incoming call being directed to a
`handset-associated telephone number, the handset-associated telephone number being the primary
`telephone number or the secondary telephone number[.]”
`
`“The subject matter of this specification can be implemented in, among other things, a computer-
`implemented method for centralized routing of voice communication over multiple communication
`networks including receiving at an electronic call routing system an incoming call from a calling
`device to a first telephone number of a mobile device. The method further includes selecting a calling
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`associated telephone
`number, the handset-
`associated telephone number
`being the primary telephone
`number or the secondary
`telephone number, and;
`
`address of the mobile device from among a voice over internet protocol address of the mobile device
`on an internet protocol network and a cellular telephone number of the mobile device on a cellular
`telephone network. The first telephone number is different than the cellular telephone number and
`the selection of the calling address is performed substantially without participation by the cellular
`telephone network. The method further includes connecting the incoming call to the selected calling
`address of the mobile device.” Conrad at Abstract.
`
`“In general, a mobile telephone device may be assigned two contact numbers. The first number can
`be used to home the device to a network of a cellular telephone carrier. The first number may not be
`seen by the user, but can be used as a gateway to the mobile virtual network operator (MVNO) for
`the carrier. The second number is the “public number for the device and can be a universal access
`number like that pr