001-7 Exhibit G - '047 Patent Infringement Chart

Case 2:22-cv-00166 Document 1-7 Filed 05/20/22 Page 1 of 44 PageID #: 307

Zilkr – Cisco ’047 Patent Infringement Chart
INFRINGEMENT OF U.S. PATENT NO. 9,883,047 BY CISCO

Cisco directly infringes, either literally or under the doctrine of equivalents, at least claim 1 of the ’047 Patent, for example, by making, using,
selling, and/or offering to sell Webex subscription services. In addition, Cisco knowingly induces its customers to directly infringe, either literally or
under the doctrine of equivalents, at least claim 1 of the ’047 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. 9,883,047 Webex
1. A method of provisioning a Cisco uses a method of provisioning a service for use with a group plan through Webex.
service for use with a group plan, Webex plans can be set up as enterprise accounts with all users linked to the enterprise. An
the method comprising:
administrator can configure the accounts on an enterprise-level to manage the content that the
individual users can access.
Source: https://help.webex.com/en-us/article/nuvy9lb/Enterprise-Content-Management-in-Cisco-
Webex-Control-Hub
1
Source: https://help.webex.com/en-us/article/nfia8at/Configure-Enterprise-Content-Management-
Settings-in-Cisco-Webex-Control-Hub
2
receiving, by a unified services Webex is a unified services platform system.

platform system, a subscription
Cisco describes Webex as providing “unified communications.”
request for a service for a group
plan,
Source: https://www.cisco.com/c/en/us/products/unified-communications/index.html
Cisco combined multiple communication platforms, including Jabber, into Webex, which it now calls
the Webex “unified app.”
Source: https://www.webex.com/content/dam/webex/eopi/assets/webex-launch-kits/On-Prem-to-
Webex-App-FAQ.pdf
3
Webex can receive a request from an Administrator to “globally enable for all users” (i.e., a group
plan) certain content management settings for third party apps.
4
Third-party subscription services include Microsoft, Google Drive, and Box. Cisco offers hundreds of
integrations from third-provider service providers.
5
To receive and connect with the various third-party application provider APIs, Webex uses numerous
authentication and authorization protocols, including OAuth 2.0.
6
7
Source: https://developer.webex.com/docs/api/guides/integrations-and-authorization
8
wherein the group plan comprises Cisco accounts with a group plan may add a plurality of telephone numbers. Each telephone number is
a plurality of telephone numbers, associated with a subscriber. For example, in Webex, an administrator can assign phone numbers to
wherein each telephone number of each of the users, or “Change Many Users’ Phone Numbers” at one time using a CSV file.
the plurality of telephone numbers
is associated with a subscriber, and
wherein the service is provided by
a third party application service
provider system;
Source: https://help.webex.com/en-us/article/nhk7ezbb/Set-up-your-Webex-Calling-plan-in-Account-
Management
Source: https://help.webex.com/en-us/article/nvjt3ce/Change-Users'-Phone-
Numbers#Cisco_Task.dita_c95902e7-1aed-49d2-8ae7-5bac5806dc3e
9

In Webex, services are provided by third party application service provider systems including
Microsoft, Google Drive, and Box. Cisco offers hundreds of integrations from third -provider service
providers.
10
sending, by the unified services Cisco sends an activation request for the group plan to the third party application service provider
platform system, an activation system.
request for the group plan to the On information and belief, certain portions of this claim limitation are carried out by software,
third party application service specifically, sending an activation request for the group plan to the third party application service
provider system,
provider system. For example, on information and belief, Cisco’s source code and/or technical
specifications will show that when an administrator selects a third-party service for a group, an
activiation request is sent through an API call or authorization request or similar messaging or
signaling to that service. 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.
11
For example, a third-party service can be selected by an administrator in the control hub.
12
13
14
15

An example diagram of connecting Microsoft to Webex is shown below:
Source: https://help.webex.com/en-us/article/njip7kp/Webex-%7C-Microsoft-OneDrive-and-
SharePoint-Online-Integration-Reference#id_109691
16
receiving an activation response Cisco receives an activation response from the third-party application service provider system, such as
from the third party application after a successful authentication.
service provider system; On information and belief, certain portions of this claim limitation are carried out by software,
specifically, the reception of the activation response. For example, on information and belief, Cisco’s
source code and/or technical specifications will show that an activation response can be accomplished
by sharing identifiers or tokens to enable access between Webex APIs and the APIs of the third -party
application service provider. 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.
17
18
19
20

21
associating the service with each Cisco associates the second service (e.g., a third-party app that has been authorized) with the plurality
telephone number of the plurality of telephone numbers. On information and belief, Cisco stores information to associate a particular
of telephone numbers; third-party service with the plurality of users to utilize the third-party service through an integration.
These integrations may be displayed on the user’s Webex App.
The integrated apps are displayed on the left of the user interface, such as the third party “Live Chat”
third party application.
Available at https://apphub.webex.com/applications/live-chat-social-intents
22

On further information and belief, certain portions of this claim limitation are carried out by software,
specifically, how within Webex telephone numbers are associated with third -party applications. 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 a third-party application that is being integrated for any
number of purposes, including, by way of further example, identification, call control and provisioning,
SMS messaging, etc. Zilkr reserves the right to supplement its allegations and contentions based on
23
providing access to the service for Cisco provides access to the service for each telephone number based on the associating. The
each telephone number based on integrated apps are displayed on the left of the user interface, such as the third party “Live Chat” third
the associating; party application.
specifically, how access is provided to third-party applications. For example, on information and
belief, Cisco’s source code and/or technical specifications will show that a user is provided access to a
service once it has been associated with a user’s phone number. Zilkr reserves the right to supplement
24

its allegations and contentions based on Cisco’s source code and/or technical specifications once such
information is provided.
25
receiving, by the unified services Cisco receives a subscription request for a second service from a subscriber associated with a first
platform system, a subscription telephone number of the plurality of telephone numbers, where the second service is provided by a
request for a second service from a third party.
subscriber associated with a first
telephone number of the plurality On further information and belief, certain portions of this claim limitation are carried out by software,
of telephone numbers, wherein the specifically, the reception of a subscription request for a second third-party application service. For
second service is provided by a example, on information and belief, Cisco’s source code and/or technical specifications will show that
second third party application to receive and connect with the various third-party application provider, Cisco uses numerous APIs, as
service provider system; well as authentication and authorization protocols, including OAuth 2.0. 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.
A third-party service can be selected by a user in the app store, sometimes called the App Hub. Cisco
offers hundreds of integrations from third-provider service providers. The API interfaces from each
26
developer are different, and Webex’s App Hub offers hundreds of integrations.
27
28
29
Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization
30
sending, by the unified services Cisco sends a second activation request for the service to the second third party application provider
platform system, a second system.
activation request for the service to On information and belief, certain portions of this claim limitation are carried out by software,
the second third party application specifically, sending a second activation request to the third party application service provider system.
service provider system;
For example, on information and belief, Cisco’s source code and/or technical specifications will show
that when an user selects a third-party service, an activiation request is sent through an API call or
authorization request or similar messaging or signaling to that service. 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.
31
32
33
Available at: https://developer.webex.com/docs/api/guides/integrations-and-authorization
34
receiving a second activation Cisco receives a second activation response from the second third party application service provider
response from the second third system, such as after a successful authentication.
party application service provider On information and belief, certain portions of this claim limitation are carried out by software,
system; specifically, receiving a second activation response from the third party application service provider
system. For example, on information and belief, Cisco’s source code and/or technical specifications
will show that when an user selects a third-party service and sends an activiation, an activiation
response is returned, such as by sharing identifiers or tokens to enable access between Webex APIs and
the APIs of the third-party application service provider. 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.
For example, an activation response may be accomplished by sharing identifiers or tokens to enable
access between Cisco’s APIs and the APIs of the third-party application service provider.
35
36
37
38

39
associating the second service with Cisco associates the second service with the first telephone number. On information and belief, Cisco
the first telephone number; and stores information to associate a particular third-party service with the plurality of users to utilize the
third-party service through an integration. These integrations may be displayed on the user’s Webex
App.
The integrated apps are displayed on the left of the user interface, such as the third party “Live Chat”
40

specifically, how within Webex the first telephone number is associated with a third -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 a third-party application that is being integrated for any
number of purposes, including, by way of further example, identification, call control and provisioning,
SMS messaging, etc. Zilkr reserves the right to supplement its allegations and contentions based on
41
providing access to the second Cisco provides access to the second service for the first telephone number based on the associating.
service for the first telephone These integrations may be displayed on the user’s Webex App.
number based on the associating. The integrated apps are displayed on the left of the user interface, such as the third party “Live Chat”
Webex approves apps to be placed in the App Hub and for use on the Webex platform. On information
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
42

provides access for a user to utilize the third-party application service through a graphical user
interface and other related backend functionality to connect to the third-party application through
Webex. 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.
43

001-7 Exhibit G - '047 Patent Infringement Chart

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Case 2:22-cv-00166 Document 1-7 Filed 05/20/22 Page 1 of 44 PageID #: 307

Case 2:22-cv-00166 Document 1-7 Filed 05/20/22 Page 2 of 44 PageID #: 308

INFRINGEMENT OF U.S. PATENT NO. 9,883,047 BY CISCO

U.S. Pat. No. 9,883,047 Webex

receiving, by a unified services Webex is a unified services platform system.

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

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

U.S. Pat. No. 9,883,047 Webex

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

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

U.S. Pat. No. 9,883,047 Webex

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