Ixi Mobile (R&D) Ltd. et al v. Samsung Electronics Co., Ltd. et al

Northern District of California, cand-4:2015-cv-03752

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0 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE In re Reexamination of: Patent No. 7, 295, 532 Examiner: Scott L. Weaver Inventor: Amit Haller et al. Art Unit: 3992 Reexamination Control No .: 90 / 014, 119 Attorney Docket No .: 143498. 00011 Reexamination Filing Date: April 3, 2018 Confirmation No .: 4776 Title: SYSTEM, DEVICE AND COMPUTER READABLE MEDIUM FOR PROVIDING NETWORKING SERVICES ON A MOBILE DEVICE VIA EFS - WEB Mail Stop Ex Parte Reexam ATTN: Central Reexamination Unit Commissioner for Patents United States Patent & Trademark Office P. O. Box 1450 Alexandria, VA 22313 - 1450 SUPPLEMENTAL RESPONSE AND AMENDMENT UNDER 37 CFR 1. 111 Dear Commissioner: Pursuant to 37 C. F. R. 1. 111, Patent Owner submits the following Supplemental Response and Amendment to the Office Action dated September 25, 2018 in connection with the above referenced ex parte reexamination ofU.S. Patent 7, 295, 532 ("the ' 532 Patent) . Patent Owner additionally submits herewith Exhibits OTH - F (Rule 132 Declaration of Dr. Samir Soliman), OTH - G (Support for Amendments) and Exhibit OTH - H (Comparison of Original Claims 1 and 2 and New Independent Claims), as well as Exhibits OTH - I, OTH - J, OTH - K, OTH - L, OTH - M, and OTH - N otherwise referenced herein. Amendments to the Claims begins on page 2 of this paper. Status of All Claims begins on page 11. Remarks begin on page 12. 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver AMENDMENTS TO THE CLAIMS 2. (Canceled) 3. (Canceled) 6. (Canceled) 10. (Original) The hand - held device of claim 1, wherein the router software component includes a local routing software component to route an IP packet between a first wireless device in the wireless local area network and a second wireless device in the wireless local area network. 11. (Original) The hand - held device of claim 1, wherein the first network service software component is a pairing management software component to determine whether a first wireless device, which is connected to the wireless local area network, is responsive to a signal from the one or more devices connected to the one or more cellular networks. 32 - 63. (Canceled) 64. (New) A hand - held cellular telephone for enabling communication between one or more devices connected to one or more cellular networks and one or more programmable devices connected to a wireless local area network, the hand - held cellular telephone comprising: a touchscreen; a graphical user interface; a first transceiver having a cellular network address, the first transceiver configured to communicate with the one or more devices connected to said one or more cellular networks by sending and receiving cellular signals; a second transceiver configured to communicate with the one or more programmable devices connected to the wireless local area network by sending and receiving short - range radio signals; a storage device configured to store: 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver a router software component configured to transfer a plurality of data packets between the one or more devices connected to the one or more rea cellular networks and the one or more programmable devices connected to the wireless local area network by the cellular signals and the short - range radio signals, wherein said plurality of data packets includes an internet Protocol ("IP") packet; and an interface software component configured to add a first network service software component configured to provide one or more network services to the wireless local area network, the first network service software component loaded into the storage device from the one or more devices connected to the one or more cellular networks, and one or more processors connected to the storage device and configured to process the cellular signals and the short - range radio signals, wherein the one or more cellular networks include a plurality of public IP addresses and the wireless local area network includes a plurality of private IP addresses, wherein the router software component is configured to translate a first IP address in the plurality of public IP addresses to a second IP address in the plurality of private IP addresses, wherein the one or more programmable devices connected to the wireless local area network comprises a wearable device having at least one processor, and wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by at least one manager server CON connected to the hand - held cellular telephone. 65. (New) The hand - held cellular telephone of Claim 64, wherein the wearable device comprises a watch having a touchscreen. 66. (New) The hand - held cellular telephone of Claim 65, wherein the storage device is further configured to store an access software component configured to enable at least 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver the watch to gain access to the hand - held cellular telephone over the wireless local area network to access a phone book or to initiate a call. 67. (New) The hand - held cellular telephone of Claim 65, wherein the one or more programmable devices connected to the wireless local area network further comprises a second wearable device having a processor coupled to a memory and to a speaker, and wherein the second wearable device is configured to be programmed over the wireless local area network. 68. (New) The hand - held cellular telephone of Claim 64, wherein the wearable device comprises a headset. 69. (New) The hand - held cellular telephone of Claim 64, wherein the first network service software component is added to the hand - held cellular telephone without user intervention 70. (New) The hand - held cellular telephone of Claim 69, wherein the first network service software component is added to the hand - held cellular telephone during manufacture of the hand - held cellular telephone. 71. (New) The hand - held cellular telephone of Claim 64, wherein the first network service software component is added to the hand - held cellular telephone in response to receiving notification that the first network service software component is newly available. 72. (New) The hand - held cellular telephone of Claim 64, wherein the first network service software component is configured to manage applications on the one or more programmable devices connected to the wireless local area network. are c mana Os C one or more 73. (New) The hand - held cellular telephone of Claim 64, wherein the first network service software component is a statistics software component configured to collect usage information of the wireless local area network. 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver 74. (New) The hand - held cellular telephone of Claim 64, the storage device further configured to store a software component configured to enable programming of the one or more programmable devices including the wearable device on the wireless local area network. 75. (New) The hand - held cellular telephone of Claim 64, wherein the one or more programmable devices connected to the wireless local area network includes a web pad having a web browser, wherein one of the plurality of private IP addresses is associated with a domain naming service (DNS), and wherein the hand - held cellular telephone provides one of the plurality of private IP addresses associated with the DNS to the web pad. 76. (New) The hand - held cellular telephone of Claim 64, wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by the at least one manager server connected to the hand - held cellular telephone over the Internet. 77. (New) The hand - held cellular telephone of Claim 64, wherein the manager server is coupled to the Internet. server 1 78. (New) The hand - held cellular telephone of Claim 64, wherein the manager server is coupled to a private network. 79. (New) The hand - held cellular telephone of Claim 64, wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by the at least one manager server connected to the hand - held cellular telephone over the one or more cellular networks. 80. (New) The hand - held cellular telephone of Claim 64, wherein the hand - held cellular telephone comprises a messaging software component configured to enable one of the one or more programmable devices connected to the wireless local area network to send messages. 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver 81. (New) The hand - held cellular telephone of Claim 80, wherein the messaging software component comprises a short message system (SMS) software component, and wherein the router software component, the interface software component, and the messaging software component are stored in the storage device during manufacture of the hand - held cellular telephone COL VICE nan omm ser LUI no TUI 82. (New) A hand - held cellular telephone for enabling communication between one or more devices connected to one or more cellular networks and one or more programmable devices connected to a wireless local area network, the hand - held cellular telephone comprising: a touchscreen; a graphical user interface; a first transceiver having a cellular network address, the first transceiver configured to communicate with the one or more devices connected to said one or more cellular networks by sending and receiving cellular signals; a second transceiver configured to communicate with the one or more programmable devices connected to the wireless local area network by sending and receiving short - range radio signals; a storage device configured to store: a router software component configured to transfer a plurality of data packets between the one or more devices connected to the one or more cellular networks and the one or more programmable devices connected to the wireless local area network by the cellular signals and the short - range radio signals, wherein said plurality of data packets includes an internet Protocol ("IP") 71 ces Con area TOIT S cei ces packet; and an interface software component configured to add a first network service software component configured to provide one or more network services to the wireless local area network, the first network service software component loaded into the storage device from the one or more devices connected to the one or more cellular networks; and 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver one or more processors connected to the storage device and configured to process Esses a ea nerv OTK the cellular signals and the short - range radio signals, wherein the one or more cellular networks include a plurality of public IP addresses and the wireless local area network includes a plurality of private IP addresses, wherein the router software component is configured to translate a first IP address in the plurality of public IP addresses to a second IP address in the plurality of private IP addresses, wherein the one or more programmable devices connected to the wireless local area network comprises a web pad having one or more processors, a touch screen, and a web browser, and wherein the hand - held cellular telephone is configured to enable programming of the web pad over the wireless local area network by at least one manager server connected to the hand - held cellular telephone. 83. (New) The hand - held cellular telephone of Claim 82, wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by the at least one manager server connected to the hand - held cellular mm wea ce o telephone over the Internet. 84. (New) The hand - held cellular telephone of Claim 82, wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by the at least one manager server connected to the hand - held cellular telephone over the one or more cellular networks. US in a rea + monitori 85. (New) A system for use by an operator in a wide area network for monitoring and managing devices or applications in a wireless local area network communicating with a hand - held wireless device, the system comprising: at least one manager server; a hand - held cellular telephone for enabling communication between one or more devices connected to one or more cellular networks and one or more programmable devices connected to the wireless local area network, wherein the one or more cellular networks includes 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver a plurality of public IP addresses and wherein the wireless local area network includes a plurality of private IP addresses, the hand - held cellular telephone comprising: a touchscreen configured to provide a graphical user interface; a microphone; a speaker; a first transceiver having a cellular network address, the first transceiver configured to communicate with the one or more devices connected to the one or more cellular networks by sending and receiving cellular signals; a second transceiver configured to communicate with the one or more programmable devices connected to the wireless local area network by sending and receiving short - range radio signals; a storage device configured to store: a router software component configured to transfer a plurality of data packets between the one or more devices connected to the one or more cellular networks and the one or more programmable devices a seco ansceiver C commui le or mor connected to the wireless local area network by the cellular signals and the short - range radio signals, wherein the router software component is configured to translate a first IP address in the plurality of public IP addresses to a second IP address in the plurality of private IP addresses, wherein the plurality of data packets includes an internet Protocol ("IP") packet; and an interface software component configured to add a first network service software component configured to provide one or more network services to the wireless local area network, the first network service software component loaded into the storage device from the one or more devices connected to the one or more cellular networks; an e are compo Ser are C and one or more processors connected to the storage device and configured to process the cellular signals and the short - range radio signals, and 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver wherein the one or more programmable devices connected to the local area network includes at least one wearable device comprising: at least one processor; a memory coupled to the at least one processor; a transceiver coupled to the at least one processor; and a speaker; wherein the at least one wearable device is configured to be programmed over the wireless local area network via the hand - held cellular telephone by the at least one manager server connected to the hand - held cellular telephone. 86. (New) The system of Claim 85 wherein the at least one wearable device comprises a watch having a touch screen. 87. (New) The system of Claim 85 wherein the at least one wearable device comprises a headset. 88. (New) The system of Claim 85 wherein the one or more programmable devices connected to the local area network further comprises at least one web pad having a web browser. 89. (New) The system of Claim 85 wherein the hand - held cellular telephone comprises a messaging software component configured to enable one of the one or more programmable devices connected to the wireless local area network to send messages. 90. (New) The system of Claim 89 wherein the messaging software component COL les a 2 CS comprises a short message system (SMS) software component, and wherein the router software component, the interface software component, and the messaging software component are stored in the storage device during manufacture of the hand - held cellular telephone. 91. (New) The system of Claim 85 wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network 0 Reexam Control No .: 90 / 014, 119 Docket No .: 143498. 00011 Art Unit: 3992 Examiner: S. Weaver by the at least one manager server connected to the hand - held cellular telephone over the Internet. 92. (New) The system of Claim 85 wherein the manager server is coupled to a private network. 93. (New) The system of Claim 85 wherein the hand - held cellular telephone is configured to enable programming of the wearable device over the wireless local area network by the at least one manager server connected to the hand - held cellular telephone over the one or more cellular networks. 94. (New) The system of Claim 85 wherein the first network service software component comprises a pairing management software component that is loaded into the storage device from the one or more devices connected to the one or more cellular networks, and wherein the pairing management component is configured to enable the at least one wearable device to connect to the local area network. 95. (New) The system of Claim 94 wherein the pairing management software component is configured to enable pairing the at least one wearable device with another of the one or more programmable devices connected to the local area network. 96. (New) The system of Claim 94 wherein the pairing management software component is configured to enable the at least one wearable device to synchronize with another of the one or more programmable devices connected to the local area network. e we е 97. (New) The system of Claim 85 wherein the first network service software component is configured to enable accessing the user interface of the hand - held cellular telephone for interacting with the at least one wearable device. 98. (New) The system of Claim 97 wherein the first network service software component is configured to enable a user to approve the at least one wearable device for pairing with the hand - held cellular telephone. n 10