Voip Pal Com Inc (VPLM)

[GTCar]

I, William Henry Mangione-Smith, declare as follows:

Dr. Houh states “For example, Chu ’684 teaches that each subscriber
is assigned their own dial plan, a unique IP address, and a unique E.164-compliant
telephone number Ex. 1003, Chu ’684 at 3:56-64.” (Houh Declaration at paragraph
45). This statement is simply wrong. That portion of Chu ‘684 states that each IPphone,
not each subscribing enterprise, may have its own E.164 telephone number.
Furthermore, the passage states that such a telephone number, along with the IP
address and dial plan, are determined by the enterprise while the language in the
Petition suggests that these values are assigned to the enterprise by some third
party.
62. Thus, a person of ordinary skill would conclude that Chu ‘684 and
Chu ‘366 do not “teach a process in which dialed digits and caller attributes are
used to determine where the call should be routed”. More significantly Dr. Houh
has agreed with my conclusion here during his deposition testimony, thus
IPR2016-01198
Apple Inc. v. Voip-Pal
-77-
correcting a portion of his erroneous declaration and pointing to a key error in the
Petition.