Sprint Communications Company LP v. Vonage Holdings Corp., et al

Filing 297

MEMORANDUM IN SUPPORT of 296 MOTION in Limine to Preclude Evidence of the 301 Family Patents Under the Doctrine of Equivalents by Defendants/Counter Claimants Vonage America, Inc., Vonage Holdings Corp. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G)(Campbell, Terrence)

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Sprint Communications Company LP v. Vonage Holdings Corp., et al Doc. 297 Att. 2 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 1 of 20 EXHIBIT B Dockets.Justia.com Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 2 of 20 ffODE LABEL IIU 111111 Ill IIUI flhI IllI HUh IU hI HE U.S. PATENT APPLICATION SERIAL NUMBER FILING DATE CLASS GROUP ART UNIT 08/525897 09/08/95 455 2611 JOSEPH -J a_ H. CHRISITE SAN BRUNO CA. CONTINUING VERIFIED DATA THIS APPLN IS CIP OF 08/238605 05/05/94 ABN FOPIGN/PCT VERIFIED APPLICATIONS FOREIGN FILING LICENSE GRANTED 03/14/96 HARLEY SPRINT 8140 WARD BALL LAW DEPARTMENT PARKWAY MOKCMPO5O6 MO 64114 SYSTEM MAILSTOP KANSAS CITY BROADBAND u-I TELECOMMUNICATIONS II- This Patent is to certify that annexed Office hereto of the is true and Trademark of the application copy from the records of the United States which is identified above. By authority C0MMISSONER OF PATENTS AND TRADEMARKS Date Certifying Officer VON_866934 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 3 of 20 PATENT APPLICATION SERIAL NO U.S. DEPARTMENT AND FEE RECORD OF COMMERCE OFFICE PATENT TRADEMARK SHEET 2O 21175 TI 210765 101 09/20/95 08525897 PTO1556 5/87 VON 866935 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 4 of 20 SPT-1090 /5258W Docket CERTIFICATION Application Transmittal and UNDER 37 CF.R 1.10 the documents as referred to as enclosed therein Label is being deposited with the known on September 81995 in an envelope Assistant Commissioner of Patents Application Express Mail D.C. Mailing 20231. Number EF596040170US Washington Michael J. Setter ReNo. 37936 PATENT APPLICATION TRANSMT Hon. Assistant Commissioner D.C. of Patents Washington 20231 Dear Sirs Transmitted herewith for filing is the following patent application /-IZ Applicants JOSj1CHAEL. CHRISK SYSTEM For BROADBAND TELECOMMUNICATIONS Enclosed 12 37 14 is sheets of drawing pages of specification pages of claims page of abstract Declaration unexecuted The Commissioner calculated is hereby authorized fees to charge 37 the fees for the filing 1.16 of this application as below entire and any additional under to CFR and 1.17 which may be required during Account the pendency of the application Sprint Communications Company L.P. Deposit No. 21-0765. VO N_B 669 36 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 5 of 20 Basic Filing Fee Total $730.00 less Number of Claims 20 less 42 $22.00 $76.00 $924.00 $456.00 Number of Independent Total Filing Fee Claims $2110.00 Assignment 0.00 Fee for Recording Total $2110.00 Respectfully submitted By Date Michael Reg. No. J. Setter Patent Atty. 37936 913 624-5194 Fax 913 624-6388 Tel SPRINT COMMUNICATIONS COMPANY L.P. 40 Ward Fifth Floor Parkway MS MOKCMPO5O6 Kansas City Missouri 64 114 VON_866937 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 6 of 20 jffi/52589 BROADBAND TELECOMMUNICATIONS SYSTEM Cross-Reference This to Related Application application entitled is continuation-in-part of prior application serial number Control filed 08/238605 Method pending System and Apparatus for Telecommunications by reference into this May 1994 currently and incorporated application. Background At present 10 Asynchronous switching connections. Transfer Mode Some ATM technology is being developed to provide broadband virtual capability. ATM systems have used ATM cross-connects to process to provide Cross-connect devices do not have the capacity signaling. Signaling refers to messages that are used by telecommunications networks to on call set-up and tear down calls. Thus ATM cross-connects cannot make connections by call basis. As result connections through cross-connect systems must be pre-provisioned. cross-connect They systems circuits 15 provide have been relatively rigid switching fabric. Due to this limitation ATM primarily used to provide virtual dedicated connections such as permanent virtual PVCs call and permanent call paths PYPs. But they do not to provide circuits ATM switching virtual on by basis as required to provide in switched virtual SVCs or switched created paths 20 SVPs. Those as skilled the art are well aware of the efficiencies by using SVPs and SVCs opposed to PVCs and PVPs. SVCs and SVPs utilize bandwidth more efficiently. ATM are switches have also been used to provide basis the PVCs and PVPs. switch Since PVCs call and PVPs not established on call-by-call ATM does need to use its processing or signaling capacity. 25 ATM switches require both signaling capability In order to achieve virtual and call processing capability call to provide basis SVCs and switches SVPs. connection switching on to by call ATM are being developed for that can process calls in response signaling they to provide virtual connections each call. These systems cause problems because These must be very sophisticated volumes of calls to support transition current networks. ATM switches must process high 30 and legacy services handle from existing networks. An example would be an ATM switch that can large numbers of POTS 800 and VPN VON_866938 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 7 of 20 Claims Iclaim 1. method of operating telecommunications system to provide for call with to virtual connection wherein user places the call by sending signaling the call the telecommunications system and by transmitting for the call user information to the telecommunications an system over particular connection wherein the system comprises linked to the ATM interworking multiplexer the method and signaling processor ATM interworking multiplexer comprising for 10 receiving the signaling the call into the signaling processor processor to select the virtual processing the signaling for the call in the signaling connection generating connection new signaling in the signaling processor to identify the particular and the selected virtual connection to 15 transmitting the new signaling the the ATM call interworking multiplexer connection into the receiving the user information for from the particular ATM interworking multiplexer the user information connection converting identify the selected the from the in the particular connection into ATM in cells that virtual ATM interworking multiplexer response to 20 new signaling transmitting and the ATM cells from the ATM interworking multiplexer over the selected virtual connection. 2. The method message. of claim wherein receiving the signaling for the call comprises rceiving call 25 set-up 3. The method of claim wherein initial receiving the signaling for the call comprises receiving Signaling System SS7 address message lAM. 38 VON_866975 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 8 of 20 The method of claim wherein receiving user information from for the call from the particular -nnectiOfl comprises receiving user information DSO connection. The method of claim wherein receiving user information for the call comprises receiving --e information. The virtual method of claim based wherein on the selecting the virtual connection comprises selecting the connection dialed number 10 The virtual method of claim wherein on N00 selecting the virtual connection comprises selecting the connection based call processing The virtual method of claim wherein on virtual selecting the virtual connection call comprises selecting the connection based private network VPN processing The virtual method of claim wherein selecting the virtual connection comprises selecting the connection based on personal/terminal mobility service call processing 10 The method cells of claim wherein transmitting connection the ATM cells comprises transmitting the 20 ATM on SONET 11 The method of claim wherein processing the signaling for the call in the signaling processor further comprises for processing the signaling to determine digital signal processing further DSP 25 requirements the call wherein that generating identifies new signaling for the call comprises generating new signaling the DSP requirements for the call and call wherein the method further comprises multiplexer in implementing the to DSP requirements for the in the ATM interworking response the new signaling 12 The method for of claim 11 wherein implementing the DSP requirements comprises echo 30 control the call 39 VON_866976 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 9 of 20 13. The method the of claim 11 wherein implementing the DSP requirements comprises encrypting call. 14. The method level of claim 11 wherein implementing the DSP requirements comprises adjusting decibel for the call. 15. The method of claim wherein the particular connection and the cells virtual connection are hi-directional and other user information to the is transmitted in ATM over the virtual 10 connection ATM interworking multiplexer for transmission to the user the method further comprising receiving ATM cells for the call from the virtual connection into the ATM interworking multiplexer the other user information for the particular in the converting format ATM and cells from the virtual connection 15 into suitable connection transmitting the other user information from the ATM interworking multiplexer over the particular connection. 40 VON_866977 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 10 of 20 16. method of operating telecommunications system to provide for call with to the narrowband connection wherein user places the call by sending signaling the call telecommunications system and the telecommunications in system facilitates the call by transporting an user information ATM cells over virtual connection processor and wherein the system linked to the comprises ATM interworking multiplexer and signaling ATM interworking multiplexer the method comprising call receiving the signaling for the into the signaling in the processor to select the processing the signaling for the call signaling processor narrowband connection io generating new signing narrowband the in the signaling processor to identi the virtual connection and the selected connection signaling to transmitting receiving the interworking new the ATM interworking virtual multiplexer into the ATM cells for the call from the connection ATM multiplexer the 15 converting ATM the cells from the virtual connection into user information to the in narrowband and format in ATM interworking multiplexer in response new signaling transmitting selected the user information connection. from the ATM interworking multiplexer over the narrowband 41 ___ VON 866978 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 11 of 20 17. method of operating telecommunications system to provide for call with virtual connection wherein user places the call by sending signaling the call to the the telecommunications of telecommunications an system and by transmitting for user information the system to system over access access connection of the call wherein comprises connected plurality connections plurality ATM interworkirig multiplexers linked the to to the access connections signaling processing system the ATM interworking multiplexers and an ATM cross-connect to provide the system connected to ATM interworking multiplexers and configured plurality of virtual connections between the ATM interworkin multiplexers method comprising first 10 providing the user with access connection to first ATM interworking multiplexer receiving the signaling the signaling for the call into the signaling processing processing system system to select virtual processing connection to for the call in the signaling from the second first ATM interworking multiplexer through the second access ATM cross-connect the 15 system second ATM interworking multiplexer and connection to ATM interworking multiplexer processing generating identifies in the signaling system selected first new signal for the call that the first access connection and the virtual connection and second new signal for the call that identifies the selected virtual connection and the second access 20 connection transmitting second the first new signal to the first ATM interworking multiplexer and the new signal to the second ATM interworking multiplexer first receiving the user information for the call from the access connection into the first ATM 25 interworking multiplexer the user information connection converting the selected from the in the first access connection into ATM cells that identify virnial first ATM interworking multiplexer in response to the first new signal the transmitting ATM cells from the first ATM interworking to multiplexer through the ATM 30 cross-connect system over the selected virtual connection the second ATM interworking multiplexer 42 VON_866979 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 12 of 20 converting information the ATM cells that identify the selected in virtual connection to user for the second access connection the second ATM interworking multiplexer in response to the second new signal transmitting over the second the user information connection. from the second ATM interworking multiplexer access 18. The method set-up of claim 17 wherein receiving the signaling for the call comprises receiving call message. 10 19. The method of claim 17 wherein receiving the signaling for the call comprises receiving Signaling System 5S7 initial address message JAM. 20. The method connection of claim 17 wherein receiving user information for the call from the first access comprises receiving user information from DSO connection. 15 21. The method of claim 17 wherein receiving user information information. for the call comprises receiving voice 22. The method connection of claim 17 wherein selecting the virtual connection comprises selecting the 20 virtual based on the dialed number. 23. The method connection of claim 17 wherein selecting based the virtual connection comprises selecting the virtual on N00 call processing. 25 24. The method connection of claim 17 wherein selecting the virtual connection comprises selecting the virtual based on virtual private network VPN call processing. 25. The method connection of claim 17 wherein selecting based the virtual connection comprises selecting the virtual on personal/terminal mobility service call processing. 43 VON 866980 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 13 of 20 26. method of operating telecommunications the system to provide for call with to the virtual connection wherein user places system call by sending signaling the call telecommunications and by transmitting for the call user information to the telecommunications system over an access connection of wherein the system comprises multiplexers connected plurality of access connections plurality ATM interworking to the access connections interworking interworking plurality of signaling processors linked to each other and the ATM ATM multiplexers and an ATM cross-connect to system connected of virtual to the multiplexers and configured provide plurality connections between 10 the ATM interworking multiplexers first the method comprising first providing multiplexer the user with access connection to ATM interworking receiving first signal for the call into first signaling processor to select processing for the call the first signal in the first signaling processor multiplexer virtual connection from the second first ATM interworking through select the ATM cross-connect call 15 system to ATM interworking multiplexer and to point for the connected to the second ATM interworking second multiplexer in the first generating virtual signal signaling processor that identifies the selected connection and the point the second signal to transmitting 20 thAsecond signaling processor to select processing connection the second signal in the second signaling processor second access for the call from the second third signal selected ATM interworking multiplexer to the point the first generating connection in the first signaling processor that identifies access and the virtual connection to transmitting 25 the third signal fourth the first ATM interworking multiplexer that generating virtual signal in the second signaling processor identifies the selected connection and the second the fourth access connection the second the transmitting signal to ATM interworking first multiplexer connection into the receiving the user information for call from the access first ATM interworking multiplexer 44 yc VON 866981 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 14 of 20 converting the selected the user information from the in the first access connection into ATM cells that identify virtual connection first ATM interworking multiplexer in response to the third signal the transmitting ATM cells from the selected first ATM interworking multiplexer through the ATM cross-connect system over the virtual connection to the second ATM interworking multiplexer the converting information suitable ATM cells that identify the selected virtual connection into user for the second access connection in the second ATM interworking multiplexer 10 in response to the fourth signal and transmitting over the second the user information connection from the second ATM interworking multiplexer access to the point. 27. The method set-up of claim 26 wherein receiving the first signal for the call comprises receiving call message. 15 28. The method of claim 26 wherein initial receiving the first signal for the call comprises receiving an Signaling System SS7 address message JAM. 29. The method connection of claim 26 wherein receiving user information for the call from the first 20 access comprises receiving user information from DSO connection. 30. The method of claim 26 information. wherein receiving user information for the call comprises receiving voice 25 31. The method connection of claim 26 wherein selecting based the virtual connection comprises selecting the virtual on the dialed number. 32. The method connection of claim 26 wherein selecting based the virtual connection comprises selecting the virtual on N00 call processing. 45 // /7 V0N866982 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 15 of 20 33. The method of claim 26 wherein selecting based the virtual connection comprises selecting the virtual connection on virtual private network VPN call processing. 34. The method connection of claim 26 wherein based selecting the virtual connection comprises selecting the virtual on personal/terminal mobility service call processing. 35. telecommunications system to provide response to signaling call received over particular connection with virtual connection in for the call the system comprising call signaling processor 10 operable to receive and process the signaling for the and transmit to select the virtual connection for the call and to generate virtual new signaling that identifies the particular an connection and the selected connection to receive into user information ATM interworking convert multiplexer operable from the particular connection virtual the user information the ATM cells that identify the selected connection in response to new signaling and to transmit the connection ATM cells from the 15 ATM interworking multiplexer over the selected virtual and multiplexer link between transfer the signaling processor and the ATM interworking the operable to the new signaling from the signaling processor to ATM interworking multiplexer. 20 36. The system of claim 35 further comprising an ATM cross-connect system connected to the ATM to the interworking multiplexer and configured to provide plurality of virtual connections ATM interworking multiplexer. 46 VON 866983 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 16 of 20 37. An ATM interworking multiplexer for oviding calls with virtual connections in response to signaling for each an access interface of the calls to recei th multiplexer comprising for operable user information each call from particular connection for that call control interface operable virtual to rec ive signaling for each call that identifies the particular connection and conn cou ction for that call led an ATM adaption processor to the access interface and the control for each interface and operable to convert user informatio the virtual from the ection particular connection the conversion call into ATM 10 cells that identify con for that call occurring in response an the to the signaling interface for that call ATM cells coupled call ATM ual adaption processor for that and operable to transmit ATM for each over connection call. 38. The multiplexer of claim 37 in th access interface includes DS0 interface. 15 39. The multiplexer of claim 37 whe the access interface includes DS1 interface. 40. The multiplexer of claim 37 whe em the access interface includes DS3 interface. 20 41. The multiplexer of claim 37 wh rein the access interface includes an OC-3 interface. 42. The multiplexer of claim 37 erein the access interface includes an OC-12 interface. 43. The multiplexer of claim 37 herein the access interface includes an El interface. 25 44. The multiplexer of claim 37 herein the access interface includes an E3 interface. 45. The multiplexer for that of claim wherein the signaling for each call identifies particular DSO connection call. 47 VON_866984 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 17 of 20 46. The multiplexer of claim 37 wherein the AT interface includes an OC-3 interface. 47. The multiplexer of claim 37 wherein the AT interface includes an OC-12 interface. 48. The multiplexer call of claim 37 wherein the icular connection and the virtual connection for each are hi-directional and wherein further operable connection for receive the ATM interface is ATM cells containing user information the from the virtual ach call ATM adaption processor is er operable to convert the ATM cells from the call 10 virtual connection into user informatio itable for the particular connection for each and the access connection interface is operable the particu ans the user information nection from the virtual for each call over for that call. 15 49. An ATM interworking in multiplex si or providing naling for each calls on virtual connections with particular connections response to of the calls the multiplexer comprising an connection ATM interface operable to eceive ATM cells for each call over the virtual for that call interface 20 control connection operable connecti receive signaling for each call that identifies the virtual and particular for that call an ATM adaption processor the oupled Ils to the ATM interface and the control suitable interface and operable to convert ATM for each call into user information for the particular connection 25 for that call conversion occurring in response to the signaling for that call and access interface an coupled call the ATM adaption processor and operable call. to transmit user information for each ove he particular connection for that 48 VON_866985 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 18 of 20 50. An ATM interworking multiplexer of the for proving calls with virtual connections in response to signaling for each calls the mltiplexer comprising an connection access interface operable to receive usr information for each call from particular for that call interface control operable virtual to receive sina1ing digital for each call that identifies the particular connection connection an/I signal processing requirements for that call digital signal processor coupled to tl to/he access interface and the control for interface operable 10 to apply.digital signal processing user information each call in response to the signaling for that call an interface ATM adaption processor couplddo the digital signal processor and the control for each call and operable cells to convert user inMr/iation from the particular connection into ATM that identify the virtual cj4on for that call the conversion occurring in response 15 to the signaling for that call an the ATM cells interface coupled call to the processor for that and operable to transmit ATM for each over the vii call. 51. The multiplexer of claim digital signal processor is operable to apply echo control. 20 52. The multiplexer of claim digital signal processor is operable to apply encryption. 53. The multiplexer of claim 50 wI the digital signal processor is operable to apply digital 25 voice compression. 54. The multiplexer level of claim 50 the digital signal processor is operable to adjust the decibel for calls. 49 VON 866986 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 19 of 20 e5 telecommunications system call for transporting user information for call over virtual connection selected for the in response to first signal for the call the system comprising plurality of access of connections operable to receive and transmit user information to the access connections plurality ATM interworking multiplexers connected and operable transmit and to transmit receive and receive user information of virtual over the access connections and to and ATM cells over plurality connections interworking multiplexers an ATM cross-connect system connected of virtual to the ATM and configured to provide the plurality connections between the ATM interworking muhiplexers 10 signaling processing identify first means for receiving and processingthe used for the call first signal for the call to access connection the to identify to select first ATM interworking for the call multiplexer connected to first access connection to virtual connection from the and to 15 first ATM second interworking access multiplexer second ATM interworking multiplexer select connection connected to the second ATM interworking multiplexer signaling generation means coupled to to the signaling processing means for generating that identifies second first signal for transmission the first ATM interworking multiplexer the access connection and the virtual connection and for generating third signal for transmission 20 connection to the second ATM access interworking multiplexer that identifies the virtual and the second connection for transferring signaling transfer interworking means and for the second signal to the first ATM multiplexer multiplexer transferring the third signal to the second ATM interworking first adaption in means response in the first ATM interworking multiplexer for receiving the connection 25 second signal and into converting the virtual user information from the first access ATM cells that identify connection and converting first ATM cells from the virtual connection into user information suitable for the access connection multiplexer virtual second the third signal adaption means in the second ATM interworking cells for receiving into and in response converting the ATM from the connection 50 ic/K VON_866987 Case 2:05-cv-02433-JWL Document 297-3 Filed 08/18/2007 Page 20 of 20 user information suitable for the second into access connection and converting the virtual user information connection. from the second access connection ATM cells that identify The system message of claim %wherein the first signal is Signaling System SS7 initial address JAM. The system of claim wherein the first access connection is DSO connection. The system 10 of claim 5wherein the user information is voice information. .5The number. system of claimiwherein the virtual connection is selected based on the dialed 42 The system of claim wherein the virtual connection is selected based on NOO call processing. 31 The system network of claim wherein the virtual connection is selected based on virtual private VPN call processing. 20 The system of claim wherein mobility service the virtual connection is selected based on personal/terminal call processing. 51 VON_866988

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