001-5 Exhibit E - '254 Patent Infringement Chart

Case 2:22-cv-00166 Document 1-5 Filed 05/20/22 Page 1 of 30 PageID #: 209

ZILKR – CISCO ’254 PATENT INFRINGEMENT CHART
INFRINGEMENT OF U.S. PATENT NO. 9,210,254 BY CISCO
Cisco directly infringes, either literally or under the doctrine of equivalents, at least claim 1 of the ’254 Patent, for example, by making, using,
selling, and/or offering to sell Webex subscription services.
The asserted claims include elements that are implemented, at least in part, by proprietary electronics, firmware and software in the Accused
Product. The precise designs, processes, and algorithms used in the Accused Product are held secret, at least in part, and are not publicly available in
their entirety. An inspection of the Accused Product, and an analysis of Cisco’s documentation and/or source code may be necessary to fully and
accurately describe all infringing features and functionality of the Accused Product and, accordingly, Plaintiff reserves the right to supplement its
infringement allegations once such information is made available to Plaintiff. Furthermore, Plaintiff reserves the right to revise its infringement
allegations, including as discovery in the case progresses, in view of the Court's final claim construction in this action and in connection with the
provision of its expert reports.
U.S. Pat. No. Webex

9,998,607
1. A telephone Webex is a telephone system.
system
comprising:
1
Source: https://pricing.webex.com/
2
a database; and Webex has a database. Cisco has data centers and iPOP locations in only a handful of locations, including Allen, Texas,
with servers used to provide a telephone service associated with a telephone number to a user. A list of those locations
is shown below:
Source: https://help.webex.com/en-us/article/WBX9000033417/List-of-Cisco-Webex-Meetings-Cluster-and-Data-
Center-Location
3
Source: https://help.webex.com/en-us/article/WBX28754/Where-are-the-Webex-Data-Centers-and-iPOP-Locations?
4
Source: https://help.webex.com/en-us/article/oybc4fb/Data-Residency-in-Webex
5
a server coupled Cisco has servers coupled to the database, wherein the server is utilized by a first provider to provide a first service to a
to the database, first user (Cisco phone line and call functionality for a user), wherein Cisco provides a phone number and associates it
wherein the with each user.
server is utilized Cisco describes how it utilizes multiple servers in its datacenters (coupled to the database) to implement its phone
by a first service.
provider to
provide a first
service to a first
user, wherein
the first service
is telephone
service, and
wherein the
telephone
service is
associated with
a first telephone
number;
6
Source: https://www.cisco.com/c/en/us/products/collateral/conferencing/webex-control-hub/white-paper-c11-
743446.html
7
Each Cisco subscriber/user is associated with a telephone number.
8
wherein the server Cisco’s server is configured to receive requests to provision a second service to a user. A third-party service can be
is configured to: selected by a user in the app store, sometimes called the App Hub. Cisco offers hundreds of integrations from third-
provider service providers.
receive a request
to provision a On further information and belief, certain portions of this claim limitation are carried out by software, specifically, the
second service for reception of a request to provision a third-party application service. For example, on information and belief, Cisco’s
the first user, source code and/or technical specifications will show that to receive and connect with the various third-party application
wherein the provider, Cisco uses numerous APIs, as well as authentication and authorization protocols, including OAuth 2.0. Zilkr
second service is reserves the right to supplement its allegations and contentions based on Cisco’s source code and/or technical
provided by a specifications once such information is provided.
second provider,
and wherein the
second provider is
different than the
first provider;
9
The authentication and authorization protocols, including OAuth 2.0, are further shown below.
10
11
Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization
12
Webex has a complete platform called Webex for Developers where they instruct third -party developers how to make
use of APIs and integrations:
13
Webex offers developer documents for app developers to assist with major Webex API’s, including call provisioning
and call controls.
Source: https://developer.webex.com/docs/webex-calling
14
Cisco provides detailed information for each of its APIs, such as is shown below.
Source: https://developer.webex.com/docs/api/v1/call-controls
15
Source: https://developer.webex.com/docs/api/v1/call-controls/dial
16
responsive to Within Webex, responsive to receiving the request, the server is configured to create a mapping from the first telephone
receiving the number to a second identifier (ID), wherein the second ID is utilized by the second provider to identify the first user.
request:
On information and belief, Webex creates a mapping between a user’s telephone number and numerous second IDs,
create a mapping
including usernames, account number, API token, etc. On further information and belief, certain portions of this claim
from the first limitation are carried out by software, specifically, the precise mapping between the first phone number to the second
telephone identifier. For example, on information and belief, Cisco’s source code and/or technical specifications will show that
number to a when utilizing the call provisioning and call control APIs described below, Webex will map the user’s phone number
second identifier with the second identifier of the third-party application connecting with those APIs. Zilkr reserves the right to
(ID), wherein supplement its allegations and contentions based on Cisco’s source code and/or technical specifications once such
the second ID is information is provided.
utilized by the
second provider Further, the Webex APIs use any of these second IDs to identify the proper phone number from which to share
to identify the resources with a third-party app. For example, to activate a third-party service, Webex uses numerous authentication
first user; and authorization protocols, including OAuth 2.0, which include utilizing a client ID for the user.
17
18
19
20
Webex has a complete platform called Webex for Developers where they instruct third -party developers how to make
use of APIs and integrations:
21
Webex offers developer documents for app developers to assist with major Webex API’s, including call provisioning
and call controls.
Source: https://developer.webex.com/docs/webex-calling
22
Cisco provides detailed information for each of its APIs, such as is shown below.
Source: https://developer.webex.com/docs/api/v1/call-controls
23
Source: https://developer.webex.com/docs/api/v1/call-controls/dial
24
activate the second Cisco activates the second service utilizing the second ID as a user ID for the first user.
service with the On information and belief, after a third party is authenticated and verified, Cisco activates the second service using a
second provider
second identifier. The third-party apps can share and receive resources from Cisco. For example, to activate the third-
utilizing the party service, Webex uses numerous authentication and authorization protocols, including OAuth 2.0, which include
second ID as a utilizing a client ID for the user.
user ID for the
first user; and
25
26

On further information and belief, certain portions of this claim limitation are carried out by software, specifically, the
activation of the third-party application utilizing the second ID. For example, on information and belief, Cisco’s source
code and/or technical specifications will show that when Webex activates a third-party application through APIs or
authorization protocols, Webex utilizes an identifier known to the third-party application to identify the user. Zilkr
reserves the right to supplement its allegations and contentions based on Cisco’s source code and/or technical
specifications once such information is provided.
27
associate the Cisco associates the second service (e.g., a third-party app that has been authorized) with the first telephone number. On
second service information and belief, Cisco stores information to associate the second ID with a particular third-party service so that a
with the first user may utilize the third-party service through an integration. These integrations may be displayed on the App Hub or
telephone on the user’s Webex account.
number, The integrated apps are displayed on the left of the user interface, such as the third party “Live Chat” third party
wherein the first application.
telephone
number is
associated with
routing and
interworking
data necessary
to utilize the
second service.
Available at https://apphub.webex.com/applications/live-chat-social-intents
On further information and belief, certain portions of this claim limitation are carried out by software, specifically, how
within Webex the first telephone number is associated with routing and interworking data necessary to utilize a third-
28
party application. For example, on information and belief, Cisco’s source code and/or technical specifications will
show that a user’s phone number is associated with appropriate routing and interworking data when utilizing the call
provisioning and call control APIs described above, such that when a communication event occurs for that phone
number, the appropriate third-party applications are contacted or connected and the appropriate information related to
the communication event is passed to those third-party application. Zilkr reserves the right to supplement its allegations
and contentions based on Cisco’s source code and/or technical specifications once such information is provided.
29

001-5 Exhibit E - '254 Patent Infringement Chart

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Case 2:22-cv-00166 Document 1-5 Filed 05/20/22 Page 1 of 30 PageID #: 209

Case 2:22-cv-00166 Document 1-5 Filed 05/20/22 Page 2 of 30 PageID #: 210

INFRINGEMENT OF U.S. PATENT NO. 9,210,254 BY CISCO

U.S. Pat. No. Webex

Each Cisco subscriber/user is associated with a telephone number.

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

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001-5 Exhibit E - &#39;254 Patent Infringement Chart

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001-5 Exhibit E - &#39;254 Patent Infringement Chart

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Case 2:22-cv-00166 Document 1-5 Filed 05/20/22 Page 1 of 30 PageID #: 209

Case 2:22-cv-00166 Document 1-5 Filed 05/20/22 Page 2 of 30 PageID #: 210

INFRINGEMENT OF U.S. PATENT NO. 9,210,254 BY CISCO

U.S. Pat. No. Webex

Each Cisco subscriber/user is associated with a telephone number.

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization

You might also like

001-5 Exhibit E - '254 Patent Infringement Chart

001-5 Exhibit E - '254 Patent Infringement Chart