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

Filing 354

TRIAL BRIEF by Vonage America, Inc., Vonage Holdings Corp.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit E# 5 Exhibit F# 6 Exhibit G# 7 Exhibit H# 8 Exhibit I)(Campbell, Terrence)

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

Doc. 354 Att. 2

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 1 of 25

EXHIBIT B

Dockets.Justia.com

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 2 of 25

L3
Sprint Docket 1057

CERTIFICATION

UNDER
States

37

C.F.R.

1.8

fy
in

that

this

Amendment
to
Assistant

is

being

deposited

with

the

United

Postal

Service

as

First

Class

Mail postage

prepaid

on

April

16

an

ddressed

Commissioner

of Patents

Washington D.C. 20231.

01N
Applicant
Application

THE UNITED STATES PATENT AND TRADEMARK OFFICE
Joseph Michael
Christie

No.

08/56855

Filed

December

1995

Title

AND APPARATUS CONTROL TELECOMMUNICATIONS

METHOD

SYSTEM

FOR

Examiner
Art Unit

Blum
2603

R.

Hon. Assistant Commissioner Washington
D.C.

for Patents

20231

Dear Sirs

AMENDMENT
Please enter
this

amendment

to

the above-referenced

application.

Applicants

reecthillyO

request

consideration

and allowance
Terminal

of the amended

application.

Petition

for

ExtensibffJneZ

Correction of Drawings

Disclaimers

an Information
fees
is

Disclosure

Statement

PTO ForrP

1449 and

Transmittal with authorization

for the proper

also

attached.

VON_865443

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 3 of 25

In the Claims
Please

amend claims 121 139 142 147-149
Please

and

153.

Please

cancel

claims

150-152

without

prejudice.

add

new

claims

175-258.

Sl2l.

amended
receiving

method

for processing

telecommunications

signaling

that

comprises cations
user into

telecommunications

signaling

message any switch

from

teleco

signaling

processor

that

is

located

externally

to

processing

the telecommunications

signa

message
path for the

in the signaling

processor to select user
is

at

least one

characteristic

for

comm

ations

telecommunications
in the signaling

generating

new
part the

tele

municatins
least one

signaling

message

processor that

based

at

least in

the at

selected

characteristic

and that network
the

trans

ing

new

telecommunications

signaling

message and
did

to

eleme

on the communications

ath that

has not received

not generate

ecommunications

signaling

message

received

into the signaling

processor.

139.

amended
receiving

method

for processing

telecommunications

signaling

that

comprises
ications user into

telecommunications
is

signaling

message
switch

from

telecom

signaling

processor that

not directly

coupled

to

ma
in the signaling

processing

the telecommunications

signalin

essage

processor to select

connection for

communications

path
nications

telecommunications

user processor that
is

generating

new
on
the

teleco

signaling

message

in the signaling

based

at

least

in part

selected

connection

and that network

transmitt

new telecommunications
ath that did

signaling

message

to

element

communications
received into the signaling

not generate

the telecommunications

signaling

me

age

processor.

VON_865444

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 4 of 25

142.

amended
receiving

method

for processing

telecommunications signaling message
switch

that

comprises
user into

telecommunications
that is not directly

signaling

from

telecommunications

signaling

processor

coupled

to

matx._
gem
the signaling

.2

processing

the telecommunications

signaling

processor to select user processor that
is

network

element for

telecommunications

generating

new

telecoffiions
network

signaling

message

in the signaling

57

based

at

least in part

ofiieiected
the

element and
to

transm mg
network
I________

new

teleconmiunjcatjons

signaling

message

switch that
did not

one

of the
the

le1nts

on the communications

path

that

has not received

and

generate

telunications

signaling

message

received

into

the signaling

processor.

147.

amended
receiving

method

for processing

telecommunications
into

signaling

that

comprises

telecommunications
the telecommunications

signaling

message message

telecommunicatio

network
is

routing

signaling

to

signaling

essor that

located

externally

to

any switch
the telecommunications

processing

signaling

mess
for

in the signaling

processor to select user processor that
is

at

least

one

characteristic

for

communicat

ns

telecommunications
in the signaling

generating

new telecommunjcat
on
the
at

igna

ng message
teristic

based

at

least

in part

least

selected

and

transmitting

telecommunications

signaling

message and
did

to

that
the

network

element on the
teleco

munications

ath that has not received

not

generate

ications

signaling

message

that

was

received

into the telecommunications

network

an

uted

to the

signaling

processor.

VON_865445

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 5 of 25

.22.
into the

The method of
signaling

claim.2OffTurther

comprising

receiving

operational

control

information

processor and

wherein processing
at least

the first telecommunications

signaling

message

comprises processing based

in part

on the operational

control

information.

--

--

2l

The method of claim.2 wherein
an instruction not to select

receiving

the operational

control

information

comprises

receiving

particular

network

element.

--

222.

The method of claim 206
comprises generating

wherein generating System

the second

message

Signaling

sage.

--

--

223.

The met

claim 206

wherein generating
signaling

the second

telecommunications broadband
format.

signaling

mprises
--...224The

generating

the second

message

in

--

method of

claimO

wherein selecting

the characteristic

comprises selecting

physical

connection.

--

--_25. The
logical

method of claim2.0wherein
--

selecting

the characteristic

comprises selecting

connection.

222The
switch.
--

method of claim2O

wherein selecting

the characteristic

comprises selecting

--.21. The
server.
--

method of claim-2O wherein

selecting

the characteristic

comprises selecting

--2The
enhanced

method of claim..286wherein
--

selecting

the characteristic

comprises selecting

an

platform.

14

VON_865456

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 6 of 25

plurality

of network elements
that

wherein

plurality

of the

ork

elements

are switches

signaling processor

communicates

with

the

ches

only through receive operational to

telecommufliCatio1

signaling

wherein the signaling
de

cessor

is

telecommunications

from ou signaling messages
signaling

of the telecommunications
for

network communications

telecommunications process the
for telecommunications

ssages to

select

characteristics

ne
leas

sers and generate
in part

telecommunications and transmit new
characteriSticS

paths

signaling

messages
plurality

that

are base

on the selected
processor

of links

tween the

gnaling

and the network elements
to

that

are

/operational elements

to

transmi

new

from the signaling processor signaling messages do not receive and do not
enerate the
si

the network

nalin

wherei

network elements
outside

messa

es ft

of the telecommunications

network wherein the network elements

plurality

of connections

between the network elements

an

onnections

are

form the communications operational to
to

the telecommunications paths for

etwork users

in response

the

new

telecommunications

signaling messages.

VON..fl65447

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 7 of 25

that

compses
processor
first

that

is external to

any telecommunications

switch

anftls

operational to
establish

process

telecommunications

to signaling message

produciatiOfl
to

used

to

communication

the processor path wherein signaling

is

further

oi6ial

generate

second

telecommunications

message based

onIeiiormatiOn
to

and wherein the second on the

telecommunications

signaling message
that

fiansmission
and
that

network element
the
first

communications path and
signaling

did

no9QIve

did not generate

signaling

message

pfce

that

is

external to any telecommunications operational to receive telecommunications the
first

switch

that

is

directly

coupled

to

tlpessor and
to

that

is

telecommunications

signaling

messag
eleiint

transmit the second

the network signaling message to

on the communications

path.

--

176.

telecommunications

processor

that

is

external to

any telecommunications

and

compnSeS
processor
first

that

is

external

to

any telecommunicatioflSih

and

that

is

operational to
to establish

process

telecommunications

signaling

message2t
is

connection

used

communication

path wherein the processor
signaling message

hroperational
the selected

to

generate

second

connection

and wherein the second on the

telecommunications

telecommunications

signaling path that

megis

for transmission to

network element
first

communications and

drI receive
that
is

and

that

did not generate the

signaling

message

signal3gicterface coupled

external to any telecommunications operational to receive telecommunications the
first

switch

that

is

directly

tfriprocessor
to

and

that

is

telecommunications

signaling

mesagand

transmit the second

signaling

message

to

the network

4nent

on the communications

path.

--

VON_865448

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 8 of 25

.-

177.

telecommunications

processor

that

is

external to any telecommunications

that

comprises
processor
first

that

is

external to any telecommunications
to signaling message se

is

operational to

networkelement

used

to

process
establish

telecommunications

communication

path wherein the proc

or

is

further

operational to generate

second

telecommunications

signaling message

on the selected connection
is

and wherein the second

c7

telecommunications

signaling
di

mes
ot

for transmission to

network element on the
first

communications path

that

receive

and

that

did not generate the

signaling

message

/and
signali interface that
is

external to

any telecommunications
the
first

switch

that

is

directly

coupled

to

processor
to transmit

and

that

is

operational to receive telecommunications

telecommunications

signaling

mess

and

the second

signaling

message

to

the network

ment on the communications

path.

--

V0t4_865449

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 9 of 25

--Amethod
path that
is

of processing
first

telecommunications

signaling to

extend

first

communications

between

network element

and

the method second network element

comprising
receiving
first

telecommunications

into signaling message

telecommunications extension

signaling processor

wherein the

first

telecommunications

signaling message requests

of the

first

wherein the telecommunications communications path and
to

signaling processor

is

located

externally

the

first

network element network element and the second
signaling message
for extending in the telecommunications

processing

the

first

telecommunications

signaling

processor

to

select

characteristic

the

first

communications path
processor

generating

second message
identifies the selected

in the telecommunications

signaling

wherein the

second message

characteristic

and
signaling processor
to

the

transmitting

telecommunications the second message from the

second

telecommunications

the second telecommunications network element wherein

network
message.
--

element

did not generate

and did not receive the

first

telecommunications

signaling

3fF

.35
The method
into

--47

of claim

7wherein

receiving the

first

telecommunications

signaling

message

the signaling processor

comprises

receiving

Signaling

System

SS7

Initial

Address Message

lAM.

--

31

35
The method
of

--8

claim7 wherein

receiving the

first

telecommunications

signaling signaling

message message

into

the signaling processor format.
--

comprises

receiving the

first

telecommunications

in

broadband

85
The method
of claimArWhereifl based processing the
first

telecommunications

signaling

message comprises
telecommunications

processing

at least

in part

on

in the point code

first

signaling message.

--

--.The
message

method

of

claim4 wherein
based

processing
in part

the

first

telecommunications

signaling
in the
first

comprises

processing

at last

on

circuit

identification

code

telecommunications

signaling message.

--

VON_865450

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 10 of 25

The method message comprises
telecommunications

of

claimPi wherein
based
at

processing

the

first

telecommunications

signaling

processing

least in part

on

message type

in the first

signaling

message.

--

--_l84 The

method

of

claim3 wherein
based

processing

the

first

telecommunications
in the

signaling

message comprises
telecommunications

processing

at least in part

on

dialed number

first

signaling message.

--

--J5. The

method

of claim .l-wherein based

processing

the

first

telecommunications
in the

signaling

message comprises
telecommunications

processing

at least in part

on set-up information

first

signaling message.

--

43
--_1-8.

35
The method
of claim J7-8 further comprising the
first

receiving network telecommunications

status

information

into

the

signaling processor

and wherein processing
based
at least in part

signaling message
--

comprises

processing

on the network

status

information.

411/
--

43
The method
of claiml-S6

wherein receiving the network
--

status

information

comprises

receiving network loading

information.

10
--.4-8.

The

method

of c1aim.1wherein receiving the network
status.
--

status

information

comprises

receiving

connection

--l9i The
receiving an

method
error

of claim 1.8wherein
condition.
--

receiving the network

status

information

comprises

--

.l-9 The

method

of claimwherein
--

receiving the network

status

information

comprises

receiving an alarm.

VON

865451

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 11 of 25

/123

J9iThe
receiving

method

of

claim

wherein
message.

receiving the network

statuS

information

comprises

--

Signaling System

ii

--9 The
into

method

of

jmAqfurther

comprising

receiving operational

control information

the signaling processor

and wherein processing
based
at least in part

the

first

te1ecomiTnUnicat1o15

signaling
--

control information. on the operational

message comprises

processing

--

The

method an

of claim k92wherein not to
select

control information receiving the operational

comprises

receiving

instruction

particular

network element.

--

194. The

method

of claim 178

wherein generating
Signaling

the

message comprises

generating

--

195. The

of claim

178

wherein generating

the second telecommUflicat101s
in

signaling
--

sage

comprises

generating

the second

signaling message

broadband

format.

--

jThe

method

of

clain17Swhere

selecting

the characteristic

comprises

selecting

physical connection.

--

--9q. The
logical

method

of claim.l7

wherein

selecting

the characteristic

comprises

selecting

connection.

--

35
--1-9rThe method
of claim.l7w.herein
selecting

the characteristic

comprises

selecting

switch.

54
--

J99.

The
--

method of claim

wherein

selecting

the characteristic

comprises

selecting

server.

51
The method of claim
--

17

wherein

selecting

the characteristic

comprises

selecting

an

enhanced platform.

10

VON_865452

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 12 of 25

--..201

The

method
--

of claim 1-8 wherein

selecting

the characteristic

comprises

selecting

service

node.

The

method

of c1aim-F7

wherein

the second network element

is

broadband

switch.

--

--2O3.

The method

of claim

Wwherein

the second network element

is

narrowband switch.

--

35
-24.
.1
transfer

The method

of claim..Arwherein
--

the second

network element

is

an asynchronous

mode

switch.

4c
--

The

method of c1aim.l8
multiplexer.
--

wherein the second network element

is

an asynchronous

transfer

mode

11

VON_865453

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 13 of 25

--Q.
path that

method

of processing

telecommunications user and

extend signaling to

first

communications comprising

is

between

telecommunications

network element

the method

receiving

first

telecommunications

signating message into

telecommunications extension

signaling processor of the
first

wherein the

first

telecommunications

signaling message

requests

communications
to

the telecommunications path and wherein

signaling processor

is

located

externally

the telecommunications telecommunications

user and the network element
in the telecommunications signaling message

processing

the

first

signaling processor generating

to

select

characteristic

for

extending

the

first

communications
processor

path wherein the

second message
identifies

in the

telecommunications

signaling

second message

the selected

characteristic

and
signaling processor the
to

transmitting

telecommunications the second message from the did not generate

the

network element network element wherein the
te1ecommunicatiOflS signaling message.
--

and did not receive

first

II
-.217.

The

method

of

claim-O wherein

receiving the

first

telecommunications

signaling

message

into

the signaling processor

comprises

receiving

Signaling System

SS7

Initial

Address Message

lAM.

--

d5
--OThe
message message method
of

claim2whereifl

receiving the

first

telecommunications

signaling signaling

into

the signaling processor format.
--

comprises

receiving the

first

telecommunications

in

broadband

--..2O9.

The

method of claim
processing

wherein processing based
at least in part

the

first

telecommunications

signaling

message comprises
telecommunications

on

point code in the

first

signaling message.

--

--..2lThe

method

of claim.26whereifl based
at

processing
least in part

the

first

telecommunications

signaling
in the first

message comprises
telecommunications

processing

on

circuit

identification

code

signaling

message.

--

12

c-i

VON_865454

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 14 of 25

--..24T

The

method

of claim.O6wherein

processing

the

first

telecommunications
first

signaling

message comprises teleCommUnicatio1

processing

based

at least in part

on

in the message type

signaling message.

--

The

method

of

c1ainwherein
based

processing

the

first

telecommunications
in the first

signaling

message comprises
telecoflimUnications

processing

at least in part

on

dialed number

signaling message.

--

13
--

i1. The

method

of claim

Wwherein
based

processing

the

first

telecommunications

signaling

message comprises
telecommunications

processing

at least in part

on set-up information

in the first

signaling message.

--

--214.

The

method

of claim.Qfurther

comprising the
first

receiving network telecommunications

status

information

into

the

signaling processor

and wherein processing
based
at least in part

signaling message
--

comprises

processing

on the network

status

information.

--.2-t5

The

method

of claim.14

wherein receiving the network
--

status

information

comprises

receiving network loading

information.

--

.2-l.

The

method

network status of claimj-Fwhereifl receiving the
status.
--

information

comprises

receiving

connection

-i1.

The

method of claim
condition.

.2.l-4

wherein receiving the network

status

information

comprises

receiving

an error

--

15
--

.2A1 The

method
alarm.

of claim-tI

wherein receiving the network

status

information

comprises

receiving an

--

747
--2-l. The

method

of c1ain2T4

wherein receiving the network
message.
--

status

information

comprises

receiving

Signaling System

13

VON_865455

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 15 of 25

The

method

of claim..2ffTurther

comprising

receiving the
first

information operational control signaling
--

into

the signaling processor

and wherein processing
based
at least in part

telecommunications

message comprises

processing

control information. on the operational

77
--

221

The

method

of

claim.2 wherein
not to select

control information receiving the operational

comprises

receiving an

instruction

particular

network element.

--

222. The

method

of claim 206 wherein generating Signaling System

the second

telecomm
--

ns signaling

message comprises

generating

sage.

--

223. The

met

claim 206 wherein generating the second signaling

the second telecommunications

signaling
--

prises
--..224The

generating

message

in

broadband

format.

method

of claim

wherein

selecting

the characteristic

comprises

selecting

physical connection.

--

--2. The
logical

method

of claim2.O6Whereifl
--

selecting

the characteristic

comprises

selecting

connection.

722The
switch.
--

method

of claim.2O

wherein

selecting

the characteristic

comprises

selecting

--..21.

The method
--

of claim.2O

wherein

selecting

the characteristic

comprises

selecting

server.

75
--22The
method
of claini..86whereifl
selecting

the characteristic

comprises

selecting

an

enhanced platform.

--

14

VON_865456

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 16 of 25

43

-j2
service

The

method
--

of claimO6wherein

selecting

the characteristic

comprises

selecting

node.

6.3 --3O. The method of claim2Owherein
the second network element
is

broadband

switch.

--.231.

The method

of clain..2O6wherein

element the second network

is

narrowband switch.

--

Vi

--. The
transfer

method

of claim.2Owherein
--

the second network element

is

an asynchronous

mode

switch.

--3 The
transfer

method

of claim26 Wherein the second
--

network element

is

an asynchronous

mode

multiplexer.

15

VON_865457

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 17 of 25

C.

-34A method
receiving
directly

for

processmg

telecommunications

signalmg
into

that

compnses
that
is

telecommunications

signaling message

signaling processor

not

coupled

to

switch

matrix
signaling message
to in the signaling

processing
characteristic

the telecommunications

processor

to

select

first

for

first

communications path and

select

second

characteristic

for

second

communications path
generating based
first

new

telecommunications

signaling message
characteristic

in the

signaling processor

that

is

at least in part

on the

first

selected

and generating
that
is

second new
at least in part on.

telecommunications the second selected

signaling message in the signaling processor
characteristic

based

and
telecommunications signaling message

transmitting telecommunications

the

first

new

and the second new
signaling

signaling message
establish

wherein the

first

new

telecommunications

message

is

used

to

the

first

communications
is

path and the second

new
path.
--

telecommunications

signaling message

used

to

establish

the second communications

92
--.5
The method
of claini.23wherein
are

the

first

communications path and the second communications
path.
--

communications path

both used

to

form

single

--.236.

The

method

of claim-4

wherein receiving the telecommunications
receiving Signaling System

signaling message
Initial

into

the signaling processor

comprises

S57

Address

Message

lAM

--

9/

--.
into

The

method

of claim.24

wherein receiving the telecommunications
receiving the telecommunications

signaling

message
in

the signaling processor format.
--

comprises

signaling message

broadband

q_5
--...28.

The method

of

claim4-wherein
based
at least in part

processing

the telecommunications

signaling

message
signaling

comprises

processing
--

on

point code in the telecommunications

message.

16

VON_865458

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 18 of 25

--

qif
of claim .24wherein
based
at least in part

The method

processing

the telecommunications

signaling
in the

message

comprises

processing

on

circuit

identification

code

telecommunications

signaling message.

--

cr1
--e24 The method
of claim

9/
24wherein
at least in part

processing

the telecommunications

signaling message

comprises

processing
--

based

on

message type

in the telecommunications

signaling message.

--

The

method

of claim

3wherein
at least in part

processing

the telecommunications

signaling message telecommunications

comprises

processing
--

based

on

dialed number

in the

first

signaling message.

qq
--2l2. The

method of claim ..2Mwherein
processing
--

processing

the telecommunications

signaling message

comprises

based

at least in part

on set-up information

in the telecommunications

signaling message.

cf
--.243

The

method

of c1aini_ifurther

comprising

receiving network status

information

into

the

signaling processor

and wherein processing
based
at least in part

the telecommunications

signaling message information.
--

comprises

processing

on the network

status

--244

The

method of claim24

wherein

receiving

the network status

information

comprises

receiving network loading

information.

--

/a--.24-5

The

method

of claim...24 wherein
status.
--

receiving the network

status

information

comprises

receiving

connection

--24.

The method
error

of claim

4wherein
--

receiving the network status

information

comprises

receiving an

condition.

17

VON_865459

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 19 of 25

io4
The method
of receiving an alarm.
--

clain43wherein

receiving the network status

information

comprises

i0
--.248

The

method

of claim.24

wherein receiving the network
message.
--

status

information

comprises

receiving

Signaling System

iob

q\t The method of claini4
further

-24.
into

comprising

receiving operational the telecommunications

control information signaling message
--

the signaling processor based

and wherein processing
at least in part

comprises

processing

control information. on the operational

14
--

The

method

of claim..24

control information wherein receiving the operational

comprises

.7

receiving an

instruction

not to select

particular

network element.

--

/f
--..21.

qi
The method
of

claim3l

wherein

generating

the

new

telecommunications
--

signaling

messages comprises

generating

at least

one Signaling System

message.

--.The
format.

method

of claim 23wherein
generating
at least

generating

the

new

telecommunications

signaling

messages comprises
--

one of the new signaling messages

in

broadband

--25. The

method

of

claimwherein
--

selecting

the characteristics

comprises

selecting

at least

one physical connection.

jil --.25. The

method

of

claim Wherein
--

selecting

the characteristics

comprises

selecting

at least

one

logical

connection.

lip-

91
of claim

--25

The method
--

Vwherein

selecting

the characteristics

comprises

selecting

at least

one switch.

18

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Case 2:05-cv-02433-JWL

Document 354-3

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Page 20 of 25

t13.
--

The method
server.
--

of c1aim-34wherein

selecting

the characteristics

comprises

selecting

at

least

one

11i1
--...281.

The

method

of claim.2l
--

wherein

selecting

the characteristics

comprises

selecting

at

least

one enhanced platform.

115
--..28.

The method
--

of claim

4wherein

selecting

the characteristics

comprises

selecting

at.

least

one service node.

19

VON_86546l

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 21 of 25

Remarks
This Response includes the substance of the interviews
related to this application

between

Russel

Blum and Michael

Setter

on February Claims
without

25-26

1997

at the

U.S. Patent Office.

Claims 121-

149

and 153-258

are pending.

121139142
prejudice.

147-149

and 153

have been amended.

Claims 150-152
correspond

have canceled
to

and Claims 175-258 have been added

in scope

previously presented
to.

claims. of Drawings has been filed as separate

The
that

drawings includes

stand objected

Correction

paper

red-line

sketches.

copy of the paper
terms

is

attached

at the

end of this
added.

amendment.

On Figure
elements

the

descriptive

element have been point and network
are

On Figure
descriptively

and 375 328 338 340 345 360 362 364 366 370
Specifically

now

labeled.

STPs
line.

328 338 340 and 345
Switches

are

now

labeled

STP

instead

using

of the conventional labeled

diagonal

and 375 325 335 360 362 364 366 370
the conventional
triangle

are

now boxes

SWITCH

instead

of using

symbol.

Claims 150-152 were have been canceled
without

rejected

under section

112

as

single means claims.

These claims

prejudice.

Claims 121-168 and claim 171
double

of obviousness-type stand rejected under the doctrine
in

patenting.

timely filed Terminal Disclaimer

compliance with 37 C.F.R.

1.321b

and

is

enclosed

to

overcome

this rejection.

The

rejections

over

DAmato
35 U.S.C.

Claims
over

121122139142147149-155

and 166 stand rejected under
recite

102e

DAmato.

149 Claims 121 122 142 147 and In these

method

for

processing receives

telecommunications

signaling.

methods
generates

signaling processor

and processes

signaling.

The

signaling processor

also

the and transmits new signaling based on
to recite that

processing. signaling
is

149 have been amended Claims 121 122 142 147 and
transmitted to

the

new

network element

on the communications
into

path that

has

not received
for

the telecommunications

received signaling message

the signaling processor.
for

Support
lines

this

amendment

can be found throughout 18-26 page

the specification

example

at

page 10

15-30

page

27

lines

34

lines

26-3

page

40

lines

24-28.

20

VON_865462

Case 2:05-cv-02433-JWL

Document 354-3

Filed 09/05/2007

Page 22 of 25

In

DAmato
Initial

switch

130 corresponds

to the

network
to

element

on the communications
signaling

path

and the
In

Address Message
the

lAM corresponds
to

the telecommunications

message.
Figure

DAmato

lAM

is

sent

both

Sitch 130 and

Signaling Director

151.

See
call if no

and colunm
services are

lines

15-29. By receiving the
call.

1AM

switch

130 can process the
This
is

special

required on the In the invention

See column

lines

31-55.

in direct

contrast not

with the invention.

the network element

on the communications
into

path does

receive

the telecommunications

signaling message received can

the signaling processor. sophisticated if so desired. under section

This

advantageous
Applicant over

since the network element claims

now

be much

less

submits

that

121-122

142 147 and 149

are patentable

102e

DAmato.
Claim 139
recite that

the signaling processor

processes the telecommunications In

signaling 151 does

to

select

connection
connection

for the

communications
an action

path.

DAmato
either

signaling

director

not select

but selects

for switch

130

to

proceed

wait

or

deny.

See colunm
switch

lines

30-55. None

of these responses
select

is

connection.

If response

is

given

130 must process the

lAM

to

the connection.

Because

it

selects

connections

the signaling processor

of claim 139
of claim 139

is

different

than signaling
in that
it

director

151

of

DAmato.
this level

The

signaling processor complexity

is

advantageous

can

avoid

the need for

of processing

in the

switch.

Applicant

submits

that

claim

139

is

patentable

under

section

102e

over

DAmato.
without
prejudice.

Claims 150-152 Claim 153
elements.

were canceled

recites

network comprised of
receives

signaling processor

and various

network

The

signaling processor

and processes signaling from outside The
has signaling processor above.

of the network.

The network elements

do not receive

this signaling.

transmits

new

signaling to the network elements.

This limitation

been discussed
that

Claims 154 155 under

and 166
section

are

dependent over

on claim 153. Applicant

submits

claim 153

is

patentable

102e

DAmato.

The Claims 148-168
or

rejections

over

Gopal Epley and Rago
102 or section 103 over either

stand rejected

under

section

Gopal Epley by

Rago

as the primary

reference.

All three

references

teach

processor

that

is

accessed

21

VON_865463

Case 2:05-cv-02433-JWL

Document 354-3

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Page 23 of 25

switch

to

obtain

call processing

information.

In

all

three references

the switch

sends

message
the

to

the processor

and the processor by the processor. and

responds

to the switch.

Thus

the switch

generates

signaling received

See Gopal

--

column 38-58

lines

25-27
--

and column
lines

lines

51-53 colunm

Epley

--

Figures

and column

lines

Rago

column

22-29

and

lines

6-27. 153-168 and 175-178
generate
all

Claims 149
process signaling to
that

require that This

the signaling processor

receive

an

new

signaling.

new

signaling must be transmitted to
into

network element
in direct contrast

did not generate the signaling received or Rago

the signaling processor. the signaling
--

This

is

to

Gopal Epley
This

where the switch
represents

does

generate

received

into

the signaling processor.
to

distinction

powerful

advantage

the switch

does

not need the complexity claims

know when

to

invoke

an external processor. under sections method where

Applicant over

submits

that

149 153-168 and 175-177
Claim 148

are patentable

102 and 103

the cited

art.

has been amended

to

recite

in-band

signaling

is

received

by

the network element

and converted
out-of-band

to

out-of band signaling without
is

using

the signaling to
in order

generate
to select

query.

The

signaling

then provided can

to

the signaling processor
at

connection.

Support

for this

amendment

be found

page 13

line

20

to

page 14
with

line

13.

In

Gopal Epley and Rago
is

the switch

processes the call and invokes of in-band signaling to section 103

the processor out-of band over the cited

query.

This

far different

than the mere conversion
that

signaling.

Applicant

submits

claims

148

is

patentable

under

art.

The The new claims
that

new
to

claims submits

correspond

in

scope

previously

presented

claims.

Applicant

the

new

claims

are fully

supported
that

by the

specification.

New

claims

175-233

include

the

limitation

discussed

above

--

the network element

did not generate

and did not receive
to

the

first

telecommunications

signaling message. dependent claims

New

claims

234 and 235 correspond

pending
to

claims

169

and 171.

New

179-205 207-233
table.

and 236-258 correspond

pending dependent

claims

as depicted

in the following

22

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Case 2:05-cv-02433-JWL

Document 354-3

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Page 24 of 25

New
Dependent Claim
179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199

Corresponding Pending Claim

New
Dependent Claim

Corresponding Pending

Claim

122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 140 141 143 144 145 146 160 161 162 165 122 123 124 125 126 127 128 129 130 131 132 133 134 135

221

136 137 138 140 141 143 144 145 146 160 161 162 165 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 140 141 143 144 145 146

222 223 224 225 226 227 228 229 230
231

232 233 236 237 238 239 240
241

242 243 244 245 246 247 248 249 250
251

200
201

202 203 204 205 207 208 209 210
211

252
253

254 255 256 257 258

212 213 214 215 216 217 218 219 220

As

to

the admitted

prior

art cited

by the Examiner

in points

14-16

of the recent Office were

Action Applicant

agrees that

these types of networks and network elements

known

but

23

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Case 2:05-cv-02433-JWL

Document 354-3

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Page 25 of 25

Applicant
in the

submits

that

it

would not be obvious
combinations

to include

these networks

and network elements
also

context

of the inventive above

discussed claims

above.

Applicant

submits

that

changes

not discussed

that

were made

to

121 139 142 and 147-149 were made
prior art rejection. Applicant submits

to

clarify

these claims and were not

made
are

in response

to

that

claims

121-149 and 153-258
is

patentable

and requests allowance

of these claims. conclusion.

Applicant

prepared

to

cooperate

with

the Examiner in order to bring this case the undersigned

to

Applicant

respectfully

requests that
foster

the Examiner telephone

with

any comments

or suggestions

that

would

such

cooperation.

Respectfully

submitted

12
Date

By
MichaefJ. Setter Patent Attorney Reg. No. 37936

Tel

913
913

624-5194 624-6388

Fax

SPRINT

COMMUNICATIONS COMPANY

L.P.

8140 Ward Parkway
Fifth

Floor

MS

MOKCMPO5O6
64114

Kansas City Missouri
PCDOCS
19372

24

VON_865466