Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 1 of 92
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`Exhibit 26
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 2 of 92
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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 R-1
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`
`
`BroadWorks
`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:
`
`BroadWorks
`
`
`To the extent the preamble is construed as limiting, BroadWorks discloses “[a] method of providing
`telephone service, the method comprising[.]”
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 3 of 92
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`- Broadworks User Guide at 11.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 4 of 92
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`- BroadWorks Service Guide at 142.
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`- BroadWorks Service Guide at 62.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 5 of 92
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`- BroadWorks Overview.
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`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 6 of 92
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`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.
`BroadWorks 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[.]”
`
`
`[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;
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 7 of 92
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`- Broadworks User Guide at 11.
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`- BroadWorks Service Guide at 96.
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`- BroadWorks Service Guide at 142.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 8 of 92
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`- Broadworks User Guide at 11.
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`- BroadWorks Service Guide at 18.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 9 of 92
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`- BroadWorks Service Guide at 18.
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`- BroadWorks Service Guide at 28.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 10 of 92
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`- BroadWorks Service Guide at 50.
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`- BroadWorks Service Guide at 62.
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`- BroadWorks Service Guide at 107.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 11 of 92
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`- BroadWorks Features Overview at 1.
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`- BroadWorks Overview.
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`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 12 of 92
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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;
`
`
`
`
`
`
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`
`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.
`BroadWorks 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[.]”
`
`
`- Broadworks User Guide at 9.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 13 of 92
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`- Broadworks User Guide at 19.
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`- BroadWorks Service Guide at 21.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 14 of 92
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`- BroadWorks Service Guide at 49.
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`- BroadWorks Service Guide at 28.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 15 of 92
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`- BroadWorks Service Guide at 54.
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`- BroadWorks Service Guide at 56.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 16 of 92
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`- BroadWorks Service Guide at 62.
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`- BroadWorks Service Guide at 89.
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`- BroadWorks Service Guide at 90.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 17 of 92
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`- BroadWorks Feature Overview at 1.
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`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`
`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 43-26 Filed 07/19/22 Page 18 of 92
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`[1.C] storing the primary call
`processing rules in the at
`least one computer memory
`device;
`
`BroadWorks discloses “storing the primary call processing rules in the at least one computer memory
`device[.]”
`
`See ‘770 Patent, 1.B, supra.
`
`
`- BroadWorks Overview
`
`
`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 43-26 Filed 07/19/22 Page 19 of 92
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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;
`
`BroadWorks 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
`BroadWorks 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 43-26 Filed 07/19/22 Page 20 of 92
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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;
`
`
`
`
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`BroadWorks 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[.]”
`
`See 1.A, supra.
`
`Second, when placing a call with a traditional phone, every dialed digit is processed, one at a time,
`by the telephone switch. So, if you hit the wrong digit, you must hang up and re-dial. On an IP
`phone, all of the dialed digits are sent to the telephone switch at once. So, if you hit the wrong digit
`on an IP phone, you can delete that digit and correct your mistake, without hanging up and re-
`dialing (an example of that is shown below).
`
`
`- Broadworks User Guide at 1.
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`- Broadworks User Guide at 15.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 21 of 92
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`- Broadworks User Guide at 18.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 22 of 92
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`- Broadworks User Guide at 17.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 23 of 92
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`- BroadWorks Service Guide at 145.
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`- BroadWorks Service Guide at 40.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 24 of 92
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`- BroadWorks Service Guide at 49.
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`- BroadWorks Service Guide at 62.
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`- BroadWorks Service Guide at 107.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 25 of 92
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`- BroadWorks Feature Overview at 2.
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`- BroadWorks Overview.
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`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 43-26 Filed 07/19/22 Page 26 of 92
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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.
`
`
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`
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`BroadWorks 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[.]”
`
`See ‘770 Patent, 1.A, 1.B, 1.F, supra.
`
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`- BroadWorks Service Guide at 18.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 27 of 92
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`- BroadWorks Service Guide at 37.
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`- BroadWorks Service Guide at 44.
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`- BroadWorks Service Guide at 49.
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`- BroadWorks Feature Overview at 4.
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`- BroadWorks Feature Overview at 4.
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`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 43-26 Filed 07/19/22 Page 28 of 92
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`[2] The method of claim 1,
`wherein the handset-
`associated telephone number
`is the secondary telephone
`number, and the pre-call
`information is transmitted
`based on the secondary call
`processing rules.
`
`[3] The method of claim 1,
`wherein the pre-call
`information includes a
`plurality of call handling
`choices for display by the
`handset and selection via the
`user input.
`
`BroadWorks discloses “[t]he method of claim 1, wherein the handset-associated telephone number
`is the secondary telephone number, and the pre-call information is transmitted based on the
`secondary call processing rules.”
`
`See ’770 Patent, 1.A, 1.B, 1.G, 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.
`BroadWorks discloses “[t]he method of claim 1, wherein the pre-call information includes a plurality
`of call handling choices for display by the handset and selection via the user input.”
`
`See ’770 Patent, 1.G, supra.
`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`
`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 43-26 Filed 07/19/22 Page 29 of 92
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`[4.A] The method of claim 1,
`further comprising: receiving
`an outgoing call request from
`the handset over the at least
`one data channel, the
`outgoing call request
`including an originating
`telephone number and a
`contact telephone number to
`be called, the originating
`telephone number being the
`primary telephone number or
`the secondary telephone
`number;
`[4.B] connecting with the
`handset at the switch over
`the at least one voice channel
`using the bridge telephone
`number; and
`
`BroadWorks discloses “[t]he method of claim 1, further comprising: receiving an outgoing call
`request from the handset over the at least one data channel, the outgoing call request including an
`originating telephone number and a contact telephone number to be called, the originating telephone
`number being the primary telephone number or the secondary telephone number[.]”
`
`See 1.A, 1.F, 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.
`
`BroadWorks discloses “connecting with the handset at the switch over the at least one voice channel
`using the bridge telephone number[.]”
`
`See ‘770 Patent 1.E, 1.F, 1.G, supra.
`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`
`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 43-26 Filed 07/19/22 Page 30 of 92
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`[4.C] transmitting an
`outgoing call over the at
`least one voice channel from
`the switch, the outgoing call
`being directed to the contact
`telephone number and
`indicating the originating
`telephone number.
`
`[5] The method of claim 1,
`wherein the at least one data
`channel includes an Internet
`protocol (IP) channel.
`
`BroadWorks discloses “transmitting an outgoing call over the at least one voice channel from the
`switch, the outgoing call being directed to the contact telephone number and indicating the
`originating telephone number.”
`
`See ‘770 Patent, 1.G, 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.
`BroadWorks discloses “The method of claim 1, wherein the at least one data channel includes an
`Internet protocol (IP) channel.”
`
`
`- BroadWorks Service Guide at 37.
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`- BroadWorks Service Guide at 51.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 31 of 92
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`- BroadWorks Service Guide at 107.
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`- BroadWorks Feature Overview at 2.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 32 of 92
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`- BroadWorks Overview.
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`- BroadWorks Service Guide at 116
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`- BroadWorks Service Guide at 165
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 33 of 92
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`
`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.
`BroadWorks discloses “The method of claim 5, wherein the at least one voice channel is established
`in accordance with at least one of a Code Division Multiple Access (CDMA) standard and a Global
`System for Mobiles (GSM) standard.”
`
`See ‘770 Patent, 1.Preamble, 1.A, 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.
`
`[6] The method of claim 5,
`wherein the at least one
`voice channel is established
`in accordance with at least
`one of a Code Division
`Multiple Access (CDMA)
`standard and a Global
`System for Mobiles (GSM)
`standard.
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 34 of 92
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`’105 Patent
`[1.Preamble] A method of
`providing telephone service,
`comprising:
`
`[1.A] automatically storing
`electronic information that
`indicates an association of a
`secondary telephone number
`and a primary telephone
`number with a telephone
`handset in a computer
`memory associated with a
`server;
`
`[1.B] automatically storing
`electronic information that
`indicates a selection of call
`processing rules for the
`primary telephone number in
`the computer memory;
`
`
`To the extent the preamble is construed as limiting, BroadWorks discloses “[a] method of providing
`telephone service, comprising[.]”
`
`See ’770 Patent, 1.Preamble, 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.
`BroadWorks discloses “automatically storing electronic information that indicates an association of
`a secondary telephone number and a primary telephone number with a telephone handset in a
`computer memory associated with a server[.]”
`
`See ’770 Patent, 1.A, 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.
`BroadWorks discloses “automatically storing electronic information that indicates a selection of call
`processing rules for the primary telephone number in the computer memory[.]”
`
`See ’770 Patent, 1.B, 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.
`
`33
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 35 of 92
`
`[1.C] automatically storing
`electronic information that
`indicates a selection of call
`processing rules for the
`secondary telephone number
`in the computer memory;
`
`BroadWorks discloses “automatically storing electronic information that indicates a selection of call
`processing rules for the secondary telephone number in the computer memory[.]”
`
`See ’770 Patent, 1.D, 1.E, supra.
`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`
`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 43-26 Filed 07/19/22 Page 36 of 92
`
`[1.D] receiving an electronic
`indication of an incoming
`call to the secondary
`telephone number at the
`server, said electronic
`indication of an incoming
`call being received from a
`switch associated with the
`server;
`
`[1.E] automatically
`accessing the call processing
`rules for the secondary
`telephone number under the
`control of the server
`responsive to the receipt of
`the electronic indication of
`the incoming call to the
`secondary telephone number;
`
`BroadWorks discloses “receiving an electronic indication of an incoming call to the secondary
`telephone number at the server, said electronic indication of an incoming call being received from a
`switch associated with the server[.]”
`
`See ’770 Patent, 1.F, supra.
`
`See also, e.g.,
`● Simultaneous Ringing T48G Broadsoft,
`https://www.youtube.com/watch?v=eBWDNyiSAW4
`● T46 BroadSoft Anywhere, https://www.youtube.com/watch?v=FZ5znKKMlvw
`● IPitimi Broadworks Anywhere Tutorial, https://www.youtube.com/watch?v=2Qbx8rjfV3M
`● Quick Phone Feature Tutorial: Simultaneous RIng,
`https://www.youtube.com/watch?v=BGcK3VY_FKs
`
`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.
`BroadWorks discloses “automatically accessing the call processing rules for the secondary telephone
`number under the control of the server responsive to the receipt of the electronic indication of the
`incoming call to the secondary telephone number[.]”
`
`See ’770 Patent, 1.G, 2, 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 43-26 Filed 07/19/22 Page 37 of 92
`
`[1.F] automatically handing
`the incoming call in
`accordance with the accessed
`call processing rules for the
`secondary telephone number;
`
`[1.G] transmitting pre-call
`information via a data
`channel to the handset under
`the control of the server, said
`pre-call information
`including a bridge telephone
`number for connecting the
`handset to the incoming call
`at the switch; and
`
`[1.H] receiving, at the server
`via the data channel, an
`electronic indication of a
`selection of a call processing
`rule for handling the
`incoming call to the
`secondary telephone number,
`or establishing a voice
`channel connection between
`the handset and the switch as
`a result of the handset calling
`the switch using the bridge
`telephone number.
`
`
`
`
`
`BroadWorks discloses “automatically handing the incoming call in accordance with the accessed call
`processing rules for the secondary telephone number[.]”
`
`See ’770 Patent, 1.G, 2, 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.
`BroadWorks discloses “transmitting pre-call information via a data channel to the handset under the
`control of the server, said pre-call information including a bridge telephone number for connecting
`the handset to the incoming call at the switch[.]”
`
`See ’770 Patent, 1.G, 3, 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.
`BroadWorks discloses “receiving, at the server via the data channel, an electronic indication of a
`selection of a call processing rule for handling the incoming call to the secondary telephone number,
`or establishing a voice channel connection between the handset and the switch as a result of the
`handset calling the switch using the bridge telephone number.”
`
`See ’770 Patent, 1.F, 1.G, 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 43-26 Filed 07/19/22 Page 38 of 92
`
`[2.Preamble] A method for
`providing telephone service
`to a telephone handset
`having a primary telephone
`number assigned to the
`telephone handset, wherein
`at least a secondary
`telephone number is
`associated with the primary
`telephone number assigned
`to the telephone handset, the
`method comprising:
`[2.A] in response to an
`incoming call to the
`secondary telephone number
`received by a switch,
`retrieving, by a server from a
`database, a first bridge
`telephone number to be used
`for completion of the
`incoming call to the
`secondary telephone number,
`wherein the first bridge
`telephone number is
`associated with the switch
`such that calls to the first
`bridge telephone number are
`automatically routed to the
`switch; and
`
`
`
`
`
`To the extent the preamble is construed as limiting, BroadWorks discloses “A method for providing
`telephone service to a telephone handset having a primary telephone number assigned to the
`telephone handset, wherein at least a secondary telephone number is associated with the primary
`telephone number assigned to the telephone handset, the method comprising[.]”
`
`See ’105 Patent, 1.Preamble, 1.A, 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.
`
`BroadWorks discloses “in response to an incoming call to the secondary telephone number received
`by a switch, retrieving, by a server from a database, a first bridge telephone number to be used for
`completion of the incoming call to the secondary telephone number, wherein the first bridge
`telephone number is associated with the switch such that calls to the first bridge telephone number
`are automatically routed to the switch[.]”
`
`See ’770 Patent, 1.F, 1.G, 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.
`
`37
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`Case 6:22-cv-00031-ADA Document 43-26 Filed 07/19/22 Page 39 of 92
`
`[2.B] transmitting, from the
`server to the telephone
`handset via at least one data
`channel, pre-call information
`including the first bridge
`telephone number, whereby
`the pre-call information
`allows the telephone handset
`to accept the incoming call
`to the secondary telephone
`number by making a first
`bridge call using the first
`bridge telephone number to
`connect the incoming call to
`the telephone handset via the
`switch.
`[3.A] The method of claim 2,
`wherein: the incoming call is
`from a calling tel