Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 1 of 102
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`Exhibit 19
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 2 of 102
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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 F-1
`
`
`
`
`
`WO 2001/097494 ("Anand")
`vs.
`Claims of Asserted U.S. Patent Nos. 9,667,770 (“’770 Patent”), and 10,015,105 (“’105 Patent”)
`
`Asserted Patent/Claim
`’770 Patent
`[1.Preamble] A method of
`providing telephone service,
`the method comprising:
`
`Anand
`
`
`To the extent the preamble is construed as limiting, Anand discloses “[a] method of providing
`telephone service, the method comprising[.]”
`
`“A telecommunications system includes a terminal adapted to couple to a telecommunications
`network. A memory is configured to store control procedures and data, and a processor is coupled to
`the memory and configured to execute the control procedures to communicate with the
`telecommunications network. When a call is placed from an initiator to a destination, and when the
`destination is not available, the processor is configured to store profile data associated with the
`initiator for the destination to return the call when the destination is available. In one aspect of the
`invention, the processor is further configured to provide audio interaction to the initiator and to record
`the profile data in response to the initiator's actions. Advantages of the invention include the ability
`to track and respond to all calls in order to provide high quality communication features and customer
`service.” Anand at Abstract.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 3 of 102
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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.
`Anand 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[.]”
`
`“In an aspect of the invention, the system stores data 214 for each registered user. This data is used
`by the system to determine the priority of telephone numbers to call, the status of the call-backs, the
`type of call back notification the registered user prefers as well as language preference, marketing
`preference, disconnect preference and others. Since each of the users has a personal identification
`number (PIN), the users can each modify their respective information in a number of ways. One way
`is by calling a customer service representative and having them change the information. Another way
`is over the telephone using the PIN by pressing the keypad and then interacting with the system to
`modify or confirm the information. Still another way is over a network interface such as an Internet
`interface. This way, the user can call up a browser and interact with the system via the network. A
`personal computer browser such as Netscape or Microsoft can be used as well as a wireless browser
`such as one from Palm Computing, Phone.com or other vendor.” Anand at 4:26-5:5.
`
`“By modifying the data, the user can make it convenient for both the caller and the destination. The
`destination person will return the call to the phone or other device where the user is most-likely
`located. For example, the user might prefer to be called on a cell phone and then switch over to a
`land phone. In one aspect of the invention, the data includes a parameter that identifies the time for
`which the system will call the primary, secondary, tertiary or other number. For example, a user may
`want to be called during business hours only, or the user may prefer to be called one a cell phone or
`at home after business hours. In this case, the call is either disconnected or taken off the queue once
`those conditions are satisfied. In another example, the user can instruct the call waiter to make a
`predetermined number of attempts (e.g. redials at predetermined intervals) and then disconnect or be
`taken off the queue.” Id. at 5:6-16.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 4 of 102
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`Id. at Fig. 6.
`
`“Figure 6 depicts a call waiter for use with a small business distributor according to an embodiment
`of the invention. In this embodiment, a small business subscribes to the call waiter 200 services. The
`call waiter 200 assigns one or more telephone numbers to each of the business subscribers. When an
`initiator calls the business, the call waiter monitors the call and answers the telephone if the
`destination is not available. As soon as the destination becomes available, the call waiter notifies the
`destination and places a call to the initiator.” Id. at 6:12-18.
`
`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.
`Anand 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[.]”
`
`3
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`[1.B] acquiring first digital
`information from the handset
`over at least one data
`channel, the first digital
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 5 of 102
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`information indicating
`primary call processing rules
`for handling calls directed to
`the primary telephone
`number;
`
`
`Anand at Fig. 2.
`
`
`
`Id. at Fig. 3A.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 6 of 102
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`Id. at Fig. 3B.
`
`“Figure 2 depicts a call waiter 200 according to an embodiment of the invention. The call waiter is
`coupled to the telecommunications network, which in this case is a PSTN 120. While the PSTN 120
`is shown as a wired system, in one aspect of the invention it is implemented as a wireless system.
`Figure 3 A shows a block diagram of the call waiter 200. A memory 210 is configured to store control
`procedures 212 for execution in the processor 220. The control procedures instruct the processor how
`to behave based on various conditions such as an incoming call, message, and other conditions. The
`memory also stores data 214 that assists the processor in executing the control procedures and
`provides the processor with a location to store the caller profile data. Figure 3B shows an exemplary
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 7 of 102
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`data structure 214 for a caller. This includes the last name, first name, primary telephone number,
`primary telephone number, secondary telephone number, tertiary telephone number, status updates
`(Y/N), status updates, status update mode, phone/e-mail/web/fax,
`language preference,
`marketing/advertising (Y/N), Disconnect after x minutes, and personal identification numbers
`(PIN).” Id. at 3:29-4:11.
`
`“In an aspect of the invention, the system stores data 214 for each registered user. This data is used
`by the system to determine the priority of telephone numbers to call, the status of the call-backs, the
`type of call back notification the registered user prefers as well as language preference, marketing
`preference, disconnect preference and others. Since each of the users has a personal identification
`number (PIN), the users can each modify their respective information in a number of ways. One way
`is by calling a customer service representative and having them change the information. Another way
`is over the telephone using the PIN by pressing the keypad and then interacting with the system to
`modify or confirm the information. Still another way is over a network interface such as an Internet
`interface. This way, the user can call up a browser and interact with the system via the network. A
`personal computer browser such as Netscape or Microsoft can be used as well as a wireless browser
`such as one from Palm Computing, Phone.com or other vendor.” Anand at 4:26-5:5.
`
`“By modifying the data, the user can make it convenient for both the caller and the destination. The
`destination person will return the call to the phone or other device where the user is most-likely
`located. For example, the user might prefer to be called on a cell phone and then switch over to a
`land phone. In one aspect of the invention, the data includes a parameter that identifies the time for
`which the system will call the primary, secondary, tertiary or other number. For example, a user may
`want to be called during business hours only, or the user may prefer to be called one a cell phone or
`at home after business hours. In this case, the call is either disconnected or taken off the queue once
`those conditions are satisfied. In another example, the user can instruct the call waiter to make a
`predetermined number of attempts (e.g. redials at predetermined intervals) and then disconnect or be
`taken off the queue.” Id. at 5:6-16.
`
`“In another aspect of the invention, the parameter can be set to a specific number of call-backs before
`failing. Moreover, since the data includes a field for the preferred method of notification, e.g. by
`phone, e-mail, fax, etc., the system will try to reach the user in the way most-likely to succeed for
`that particular user. Since users are different and may prefer different types of notification, the
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 8 of 102
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`inventive system is optimized for each particular user. Finally, If there is a failure of the system to
`have the destination return the call, the call waiter can send the failure notice to the user using the
`method best for the user. In one aspect of the invention, in case of a failed call return, the system can
`give the user the option of leaving a message for the destination that describes the nature of the call.”
`Id. at 5:31-6:7.
`
`
`
`
`Id. at Fig. 6.
`
`“Figure 6 depicts a call waiter for use with a small business distributor according to an embodiment
`of the invention. In this embodiment, a small business subscribes to the call waiter 200 services. The
`call waiter 200 assigns one or more telephone numbers to each of the business subscribers. When an
`initiator calls the business, the call waiter monitors the call and answers the telephone if the
`destination is not available. As soon as the destination becomes available, the call waiter notifies the
`destination and places a call to the initiator.” Id. at 6:12-18.
`
`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.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 9 of 102
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`[1.C] storing the primary call
`processing rules in the at
`least one computer memory
`device;
`
`Anand discloses “storing the primary call processing rules in the at least one computer memory
`device[.]”
`
`“Figure 2 depicts a call waiter 200 according to an embodiment of the invention. The call waiter is
`coupled to the telecommunications network, which in this case is a PSTN 120. While the PSTN 120
`is shown as a wired system, in one aspect of the invention it is implemented as a wireless system.
`Figure 3 A shows a block diagram of the call waiter 200. A memory 210 is configured to store control
`procedures 212 for execution in the processor 220. The control procedures instruct the processor how
`to behave based on various conditions such as an incoming call, message, and other conditions. The
`memory also stores data 214 that assists the processor in executing the control procedures and
`provides the processor with a location to store the caller profile data. Figure 3B shows an exemplary
`data structure 214 for a caller. This includes the last name, first name, primary telephone number,
`primary telephone number, secondary telephone number, tertiary telephone number, status updates
`(Y/N), status updates, status update mode, phone/e-mail/web/fax,
`language preference,
`marketing/advertising (Y/N), Disconnect after x minutes, and personal identification numbers
`(PIN).” Anand at 3:29-4:11.
`
`“In an aspect of the invention, the system stores data 214 for each registered user. This data is used
`by the system to determine the priority of telephone numbers to call, the status of the call-backs, the
`type of call back notification the registered user prefers as well as language preference, marketing
`preference, disconnect preference and others. Since each of the users has a personal identification
`number (PIN), the users can each modify their respective information in a number of ways. One way
`is by calling a customer service representative and having them change the information. Another way
`is over the telephone using the PIN by pressing the keypad and then interacting with the system to
`modify or confirm the information. Still another way is over a network interface such as an Internet
`interface. This way, the user can call up a browser and interact with the system via the network. A
`personal computer browser such as Netscape or Microsoft can be used as well as a wireless browser
`such as one from Palm Computing, Phone.com or other vendor.” Id. at 4:26-5:5.
`
`“By modifying the data, the user can make it convenient for both the caller and the destination. The
`destination person will return the call to the phone or other device where the user is most-likely
`located. For example, the user might prefer to be called on a cell phone and then switch over to a
`land phone. In one aspect of the invention, the data includes a parameter that identifies the time for
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 10 of 102
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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;
`
`which the system will call the primary, secondary, tertiary or other number. For example, a user may
`want to be called during business hours only, or the user may prefer to be called one a cell phone or
`at home after business hours. In this case, the call is either disconnected or taken off the queue once
`those conditions are satisfied. In another example, the user can instruct the call waiter to make a
`predetermined number of attempts (e.g. redials at predetermined intervals) and then disconnect or be
`taken off the queue.” Id. at 5:6-16.
`
`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.
`Anand 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
`Anand 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
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 11 of 102
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`[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-
`associated telephone
`number, the handset-
`associated telephone number
`being the primary telephone
`number or the secondary
`telephone number, and;
`
`
`
`
`
`Anand 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[.]”
`
`
`Anand at Fig. 2.
`
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 12 of 102
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 12 of 102
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` Id. at Fig. 3A.
`
`
` Processor
`
`
`Id. at Fig. 3A.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 13 of 102
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`Id. at Fig. 3B.
`
`“Figure 2 depicts a call waiter 200 according to an embodiment of the invention. The call waiter is
`coupled to the telecommunications network, which in this case is a PSTN 120. While the PSTN 120
`is shown as a wired system, in one aspect of the invention it is implemented as a wireless system.
`Figure 3 A shows a block diagram of the call waiter 200. A memory 210 is configured to store control
`procedures 212 for execution in the processor 220. The control procedures instruct the processor how
`to behave based on various conditions such as an incoming call, message, and other conditions. The
`memory also stores data 214 that assists the processor in executing the control procedures and
`provides the processor with a location to store the caller profile data. Figure 3B shows an exemplary
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 14 of 102
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`data structure 214 for a caller. This includes the last name, first name, primary telephone number,
`primary telephone number, secondary telephone number, tertiary telephone number, status updates
`(Y/N), status updates, status update mode, phone/e-mail/web/fax,
`language preference,
`marketing/advertising (Y/N), Disconnect after x minutes, and personal identification numbers
`(PIN).” Id. at 3:29-4:11.
`
`
`Id. at Fig. 4.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 15 of 102
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`“Figure 4 is a flowchart 250 showing an exemplary operation of the call waiter of Figure 2. In step
`252, the initiator places the call. In step 254, the call waiter determines whether a call is incoming.
`Step 256 authenticates the caller and step 258 allows the caller to make calls and to negotiate audio
`prompts. Step 260 determines whether to initiate waiting. If not, the procedure is returned to step
`258. If so, step 262 plays a message for the destination, or operator. If the destination does not answer
`the telephone, step 264 returns the procedure to step 262. If the destination answers the telephone,
`step 266 forwards the call back to the initiator using the initiators profile data.” Id. at 4:17-25.
`
`“By modifying the data, the user can make it convenient for both the caller and the destination. The
`destination person will return the call to the phone or other device where the user is most-likely
`located. For example, the user might prefer to be called on a cell phone and then switch over to a
`land phone. In one aspect of the invention, the data includes a parameter that identifies the time for
`which the system will call the primary, secondary, tertiary or other number. For example, a user may
`want to be called during business hours only, or the user may prefer to be called one a cell phone or
`at home after business hours. In this case, the call is either disconnected or taken off the queue once
`those conditions are satisfied. In another example, the user can instruct the call waiter to make a
`predetermined number of attempts (e.g. redials at predetermined intervals) and then disconnect or be
`taken off the queue.” Id. at 5:6-16.
`
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 16 of 102
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`Id. at Fig. 6.
`
`“Figure 6 depicts a call waiter for use with a small business distributor according to an embodiment
`of the invention. In this embodiment, a small business subscribes to the call waiter 200 services. The
`call waiter 200 assigns one or more telephone numbers to each of the business subscribers. When an
`initiator calls the business, the call waiter monitors the call and answers the telephone if the
`destination is not available. As soon as the destination becomes available, the call waiter notifies the
`destination and places a call to the initiator.” Id. at 6:12-18.
`
`
`Id. at Fig. 9.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 17 of 102
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`“Figure 9 depicts a call waiter combined with an Internet communications network according to an
`embodiment of the invention. It is anticipated that all the features and functions previously described
`are equally applicable to this embodiment, for example, voice over IP, net-phone software or other
`technology that involves audio streaming over the Internet. In this embodiment, the initiator 110 is
`coupled to the Internet 420, and to an automatic call distributor 430 to a destination 440, 450. If the
`call is made from the initiator 110 to the destination 430, then the call is handled much in the same
`way described above, but with the substitution of the Internet 420 as the telecommunications
`network. In this case, a bridge 500 between the Internet 420 and the PSTN 120 can be provided to
`increase the flexibility of calling between a destination 110 coupled to the Internet 420 and the
`destination 140 coupled to the PSTN 120. All other functions are similar to those described above
`with respect to the PSTN telecommunications network.” Id. at 7:17-29.
`
`
`Id. at Fig. 10.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 18 of 102
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`[1.G] based on the primary
`call processing rules or the
`secondary call processing
`rules: transmitting pre-call
`information to the handset
`over the at least one data
`channel the pre-call
`information including the
`bridge telephone number and
`the handset-associated
`telephone number, such that
`the handset is capable of
`displaying the handset-
`associated telephone number
`to a user and, based on user
`input, accepting the
`incoming call by connecting
`with the switch over the at
`least one voice channel using
`the bridge telephone number.
`
`
`“Figure 10 depicts a call waiter combined with an Internet communications network according to
`another embodiment of the invention. In this embodiment, a call waiter 200 is coupled to the Internet
`420 to provide call waiter functions between an initiator 110 and a potential destination 140, 150,
`440, 450. The call waiter 200 performs the same functions over the Internet 420 as those described
`above with respect to the PSTN network.” Id. at 7:30-8:2.
`
`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
`Anand discloses “based on the primary call processing rules or the secondary call processing rules:
`transmitting pre-call information to the handset over the at least one data channel the pre-call
`information including the bridge telephone number and the handset-associated telephone number,
`such that the handset is capable of displaying the handset-associated telephone number to a user and,
`based on user input, accepting the incoming call by connecting with the switch over the at least one
`voice channel using the bridge telephone number[.]”
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 19 of 102
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`Anand at Fig. 2.
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`Id. at Fig. 3A.
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 20 of 102
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`Id. at Fig. 3B.
`
`“Figure 2 depicts a call waiter 200 according to an embodiment of the invention. The call waiter is
`coupled to the telecommunications network, which in this case is a PSTN 120. While the PSTN 120
`is shown as a wired system, in one aspect of the invention it is implemented as a wireless system.
`Figure 3 A shows a block diagram of the call waiter 200. A memory 210 is configured to store control
`procedures 212 for execution in the processor 220. The control procedures instruct the processor how
`to behave based on various conditions such as an incoming call, message, and other conditions. The
`memory also stores data 214 that assists the processor in executing the control procedures and
`provides the processor with a location to store the caller profile data. Figure 3B shows an exemplary
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`Case 6:22-cv-00031-ADA Document 43-19 Filed 07/19/22 Page 21 of 102
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`data structure 214 for a caller. This includes the last name, first name, primary telephone number,
`primary telephone number, secondary telephone number, tertiary telephone number, status updates
`(Y/N), status updates, status update mode, phone/e-mail/web/fax,
`language preference,
`marketing/advertising (Y/N), Disconnect after x minutes, and personal identification numbers
`(PIN).” Id. at 3:29-4:11.
`
`“In an aspect of the invention, the system stores data 214 for each registered user. This data is used
`by the system to determine the priority of telephone numbers to call, the status of the call-backs, the
`type of call back notification the registered user prefers as well as language preference, marketing
`preference, disconnect preference and others. Since each of the users has a personal identification
`number (PIN), the users can each modify their respective information in a number of ways. One way
`is by calling a customer service representative and having them change the information. Another way
`is over the telephone using the PIN by pressing the keypad and then interacting with the system to
`modify or confirm the information. Still another way is over a network interface such as an Internet
`interface. This way, the user can call up a browser and interact with the system via the network. A
`personal computer browser such as Netscape or Microsoft can be used as well as a wireless browser
`such as one from Palm Computing, Phone.com or other vendor.” Id. at 4:26-5:5.
`
`“By modifying the data, the user can make it convenient for both the caller and the destination. The
`destination person will return the call to the phone or other device where the user is most-likely
`located. For example, the user might prefer to be called on a cell phone and then switch over to a
`land phone. In one aspect of the invention, the data includes a parameter that identifies the time for
`which the system will call the primary, secondary, tertiary or other number. For example, a user may
`want to be called during business hours only, or the user may prefer to be called one a cell phone or
`at home after business hours. In this case, the call is either disconnected or taken off the queue once
`those conditions are satisfied. In another example, the user can instruct the call waiter to make a
`predetermined number of attempts (e.g. redials at predetermined intervals) and then disconnect or be
`taken off the queue.” Id. at 5:6-16.
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`“In another aspect of the invention, the parameter can be set to a specific number of call-backs before
`failing. Moreover, since the data includes a field for the preferred method of notification, e.g. by
`phone, e-mail, fax, etc., the system will try to reach the user in the way most-likely to succeed for
`that particular user. Since users are different and may prefer different types of notification, the
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`inventive system is optimized for each particular user. Finally, If there is a failure of the system to
`have the destination return the call, the call waiter can send the failure notice to the user using the
`method best for the user. In one aspect of the invention, in case of a failed call return, the system can
`give the user the option of leaving a message for the destination that describes the nature of the call.”
`Id. at 5:31-6:7.
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`Id. at Fig. 6.
`
`“Figure 6 depicts a call waiter for use with a small business distributor according to an embodiment
`of the invention. In this embodiment, a small business subscribes to the call waiter 200 services. The
`call waiter 200 assigns one or more telephone numbers to each of the business subscribers. When an
`initiator calls the business, the call waiter monitors the call and answers the telephone if the
`destination is not available. As soon as the destination becomes available, the call waiter notifies the
`destination and places a call to the initiator.” Id. at 6:12-18.
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`Id. at Fig. 9.
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`“Figure 9 depicts a call waiter combined with an Internet communications network according to an
`embodiment of the invention. It is anticipated that all the features and functions previously described
`are equally applicable to this embodiment, for example, voice over IP, net-phone software or other
`technology that involves audio streaming over the Internet. In this embodiment, the initiator 110 is
`coupled to the Internet 420, and to an automatic call distributor 430 to a destination 440, 450. If the
`call is made from the initiator 110 to the destination 430, then the call is handled much in the same
`way described above, but with the substitution of the Internet 420 as the telecommunications
`network. In this case, a bridge 500 between the Internet 420 and the PSTN 120 can be provided to
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`increase the flexibility of calling between a destination 110 coupled to the Internet 420 and the
`destination 140 coupled to the PSTN 120. All other functions are similar to those described above
`with respect to the PSTN telecommunications network.” Id. at 7:17-29.
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`Id. at Fig. 10.
`
`“Figure 10 depicts a call waiter combined with an Internet communications network according to
`another embodiment of the invention. In this embodiment, a call waiter 200 is coupled to the Internet
`420 to provide call waiter functions between an ini