001-6 Exhibit F - '048 Patent Infringement Chart

Case 2:22-cv-00166 Document 1-6 Filed 05/20/22 Page 1 of 68 PageID #: 239

Zilkr – Cisco ’048 Patent Infringement Chart
INFRINGEMENT OF U.S. PATENT NO. 9,883,048 BY CISCO

Cisco directly infringes, either literally or under the doctrine of equivalents, at least claim 13 of the ’048 Patent, for example, by making, using,
selling, and/or offering to sell Webex subscription services (the “Accused Product”). In addition, Cisco knowingly induces its customers to directly
infringe, either literally or under the doctrine of equivalents, at least claim 13 of the ’048 Patent.
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. 9,883,048 Webex

13. A method of developing Cisco uses a method of developing and testing a new application service through a unified services platform.
and testing a new Cisco provides app developers with tools to integrate apps with Webex, as well as test and to solve the problems with
application service through the integration.
a unified services platform,
the method comprising:
1
Source:
https://www.webex.com/content/dam/wbx/us/documents/pdf/Turning_Cloud_Calling_into_Smarter_Collab_eBook.pdf
2
Source:
https://www.webex.com/content/dam/wbx/us/documents/pdf/Turning_Cloud_Calling_into_Smarter_Collab_eBook.pdf
3
Source: https://developer.webex.com/docs/embedded-apps
4
Source: https://developer.webex.com/docs/embedded-apps-guide
5
Source: https://developer.webex.com/docs/developer-sandbox-guide
6
Source: https://apphub.webex.com/
7
Source:
https://www.webex.com/content/dam/wbx/us/documents/pdf/Cloud_Calling_Comes_in_all_Shapes_and_Sizes_Infogra
phic.pdf
8
9
Source: https://developer.webex.com/
Cisco promotes that with Webex, “no other solution brings together so many facets of collaboration into a single,
unified platform.”
Source: https://developer.webex.com/docs/platform-introduction
10
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.
Source: https://help.webex.com/en-us/article/WBX9000033417/List-of-Cisco-Webex-Meetings-Cluster-and-Data-
Center-Location
11
Source: https://help.webex.com/en-us/article/WBX28754/Where-are-the-Webex-Data-Centers-and-iPOP-Locations?
12
Source: https://help.webex.com/en-us/article/oybc4fb/Data-Residency-in-Webex
13
establishing a plurality of service Cisco establishes a plurality of service accounts (e.g., developer accounts) for a corresponding
accounts for a corresponding plurality of application service provider systems (apps).
plurality of application service
provider systems;
Developers must have a Webex account and log in. Further, Cisco provides documents (“Go to Docs”
below) and blogs and other support for developers:
Source: https://developer.webex.com
14
Cisco promotes that it provides developers with tools to develop applications across the entire Webex
family of products and services.
Source: https://developer.webex.com/docs/platform-introduction
15
Webex provides the Code Samples, How To’s, and 24/7 support to enable developers to engage with
Webex using its APIs.
16
Webex offers its hundreds, if not thousands, of pages of documentation and blogs related to
Embedded Apps, APIs, and other ways to build on the Webex Platform.
Available at https://developer.webex.com/docs/embedded-apps
17
The Webex APIs allow service providers to use call controls and other APIs to provide services for
use in association with a telephone number.
Source: https://developer.webex.com/docs/webex-calling
18
The application service providers can reach the Webex subscribers (who use telecommunication
services) by building and publishing applications on the Webex App Hub.
19
receiving a plurality of API Webex receives a plurality of API interfaces from the plurality of application service provider
interfaces from the plurality of systems (apps) through, at least, the developer and Webex APIs functionality. The applications from
application service provider which Webex receives APIs are published and displayed in the App Hub, among other places—at
systems, wherein at least two of the least two, but in actuality dozens, of these API interfaces are different.
API interfaces are different; On information and belief, certain portions of this claim limitation are carried out by software,
specifically, the reception of various APIs from third party applications. For example, on
information and belief, Cisco’s source code and/or technical specifications will show that those APIs
received from the various third-party application providers are different. 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.
Webex has a complete platform called Webex for Developers where they instruct third-party
developers how to make use of APIs and integrations:
20
Webex offers developer documents for app developers to assist with major Webex API’s, including
call provisioning and call controls.
21
Cisco provides detailed information for each of its APIs, such as is shown below.
22
Source: https://developer.webex.com/docs/api/v1/call-controls
23
Source: https://developer.webex.com/docs/api/v1/call-controls/dial
24
The API interfaces from each developer are different, and Webex’s App Hub offers hundreds of
integrations.
25
To receive and connect with the various third-party application provider APIs, Webex uses numerous
authentication and authorization protocols, including OAuth 2.0.
26
27
Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization
28
integrating each of the plurality of Webex integrates each of the plurality of third-party APIs with a unified services platform API (e.g,
API interfaces with a unified Webex App Hub and associated backend systems and APIs).
services platform system API On information and belief, certain portions of this claim limitation are carried out by software,
interface; specifically, the integration of the various APIs with the Webex platform. For example, on information
and belief, Cisco’s source code and/or technical specifications will show that depending on the
integration, Webex passes certain information and resources between the Webex APIs and the plurality
of API interfaces (various third-party application provider APIs) to accomplish the integration. Apps
that are or can be integrated are published and displayed in at least the App Hub. 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
30
Webex provides the Code Samples, How To’s, and 24/7 support to enable developers to engage with
Webex using its APIs.
31
Webex offers developer documents for app developers to assist with major Webex API’s, including
call provisioning and call controls.
32
Cisco provides detailed information for each of its APIs, such as is shown below.
Source: https://developer.webex.com/docs/api/v1/call-controls
33
Source: https://developer.webex.com/docs/api/v1/call-controls/dial
34
The API interfaces from each developer are different, and Webex’s App Hub offers hundreds of
integrations.
35
To receive and connect with the various third-party application provider APIs, Webex uses numerous
authentication and authorization protocols, including OAuth 2.0.
36
37
Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization
38
receiving a definition of a service Webex receives a definition of a service (e.g., service/app or display name) for each of the plurality of
for each of the plurality of application service provider systems (e.g., apps).
application service provider
systems; For example, for App Developers, Cisco provides a portal at the Webex App Hub to submit an app.
To do so, Developers must comply with several submissions guidelines, including providing a clear
description of the integration.
Source: https://developer.webex.com/docs/app-hub-submission-process
39
Further, for Developers, Webex provides a portal at developer.webex.com for App Hub Submissions,
including the Application Name and Description, along with the service it works with, as shown
below. This information can be displayed on the App Hub.
Source: https://developer.webex.com/docs/api/guides/embedded-apps-guide#creating-an-embedded-
app-in-the-developer-portal
40
Those definitions are shown in the App Hub and when clicking on an app. As is shown in the
screenshots below, certain communications or actions can trigger messaging and other events within
Webex and with third party service providers.
41
Source: https://apphub.webex.com/applications/incoming-webhooks-cisco-systems-38054-23307
42
Source: https://apphub.webex.com/applications/automate-io
43
receiving one or more definitions of Webex receives one or more definitions of actions for each service. The actions comprise responses to
actions for each service for each of triggering events occurring with a telephone number.
the plurality of application service For App Developers, Webex provides various functionality and App permissions such as connecting an
provider systems, wherein the incoming call, and various other including call provisioning and call controls.
actions comprise responses to
triggering events occurring for a
telephone number;
44
For example, Webex offers integration through the App Hub. Webex has received the definitions of
actions including the triggering events such as new calls or SMS messages. Webex received further
definitions of actions such as sending SMS or outbound calling in response to the triggers.
On further information and belief, certain portions of this claim limitation are carried out by software,
specifically, the responses to triggering events occurring with a telephone number. For example, on
information and belief, Cisco’s source code and/or technical specifications will show that actions can
be triggered by making or receiving phone calls or SMS messages, which, by way of further example,
trigger API or webhook calls. 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.
Moreover, Webex allows various triggering events occurring with a telephone number.
Webex offers app developers numerous webhooks, which are used to invoke services in response to a
triggering event. By providing webhooks for telephony events, Webex associates the third-party
service systems with the subscriber’s telephone numbers.
45
46
Source: https://developer.webex.com/docs/api/guides/webhooks
As is shown in the screenshots below, certain communications or actions can trigger messaging and
other events within Webex and with third party service providers.
47
48
49
Source: https://apphub.webex.com/applications/bluip-sms-messaging-bot-bluip-inc
50
Source: https://apphub.webex.com/applications/tpxsmsapp-tpx (showing that “All messages received

from that number will also show up in this space.”).
51
testing each triggering event and Webex tests each triggering event and corresponding action for each service in a test environment to
corresponding action for each generate a response.
service in a test environment to On further information and belief, certain portions of this claim limitation are carried out by software,
generate a response; specifically, the test environment used to generate a response to triggering events. For example, on
information and belief, Cisco’s source code and/or technical specifications will show that third-party
applications utilize triggering events associated with communication events of a user’s telephone
number. 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.
52
For example, Webex provides app developers numerous test environments and sandboxes where they
can test their various apps, integrations, webhooks, and responses.
Source: https://developer.webex.com/docs/embedded-apps-guide
53
54
Webex provides resources to show developers how to use the sandbox.
55
Test tools are provided for both REST APIs (shown above) and XML APIs.
56
providing access to each service Webex provides access to each service within a working environment after performing the testing.
within a working environment after Webex approves apps to be placed in the App Hub and for use on the Webex platform. On information
performing the testing; and and belief, certain portions of this claim limitation are carried out by software. For example, on
information and belief, Cisco’s source code and/or technical specifications will show that Webex
allows for third-party applications be tested in a test environment, which are then released into a
working environment. For further example, on information and belief, Cisco’s source code and/or
technical specifications will show that before apps are released to the App Hub to be utilized by other
third-party users, the apps must first be tested in a testing environment to pass the Webex approval
process. 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.
57
Source: https://developer.webex.com/docs/embedded-apps-guide#request_approval
58
Webex provides access to approved apps through the App Hub.
59
Webex’s App Hub offers hundreds of integrations.
60
publishing, after testing, the Webex publishes, after integrating each of the plurality of third-party APIs with the unified services
definition of the service, the platform (e.g., Webex App Hub and associated back-end systems and APIs), the definitions of the
definition of the plan, and the one service, plan, and actions for each application service provider in a provisioning catalog (e.g., Webex
or more definitions of actions for App Hub).
each application service provider in On information and belief, certain portions of this claim limitation are carried out by software. For
a provisioning catalog. example, on information and belief, Cisco’s source code and/or technical specifications will show that
Webex requires third-party applications be tested in a test environment before they are released to the
App Hub to be utilized by other third-party users. 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.
61
The App Hub can be sorted into various categories, like “Productivity,” which is shown below:
Source: https://apphub.webex.com/category/productivity
In the App Hub, Webex publishes the definition of the service, the definition of the plan, and the one or
more definitions of actions for each of the apps, as shown below:
62
63
64
Source: https://apphub.webex.com/applications/bluip-sms-messaging-bot-bluip-inc
65
Source: https://apphub.webex.com/applications/tpxsmsapp-tpx (showing that “All messages received

from that number will also show up in this space.”).
66
Source: https://developer.webex.com/docs/embedded-apps-guide#request_approval
67

001-6 Exhibit F - '048 Patent Infringement Chart

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Case 2:22-cv-00166 Document 1-6 Filed 05/20/22 Page 1 of 68 PageID #: 239

Case 2:22-cv-00166 Document 1-6 Filed 05/20/22 Page 2 of 68 PageID #: 240

INFRINGEMENT OF U.S. PATENT NO. 9,883,048 BY CISCO

U.S. Pat. No. 9,883,048 Webex

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

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

Source: https://apphub.webex.com/applications/tpxsmsapp-tpx (showing that “All messages received

Webex provides resources to show developers how to use the sandbox.

Webex provides access to approved apps through the App Hub.

Webex’s App Hub offers hundreds of integrations.

Source: https://apphub.webex.com/applications/tpxsmsapp-tpx (showing that “All messages received

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