Voip Pal Com Inc (VPLM)

[GTCar]

Grounds 1 and 2 fail because the Petition fails to show how
the combination of Nadeau and Kelly “produc[es] a public
network routing message for receipt by the call controller,
said public network routing message identifying a gateway
to the public network” ....................................................................... 12
1. The “routing instructions” in Nadeau do not identify
a gateway to the public network ............................................. 14
2. The Petitioner’s assertion that the “routing
instructions” in Nadeau “must” include an
identification of the IP-PSTN Gateway is
unsupported ............................................................................. 16
3. The Petitioner fails to explain how Nadeau would be
modified such that a public network routing message
is produced which identifies a gateway to the public
network as recited in the claims .............................................. 21
a. Petitioner proposes to use the call packet
produced by Kelly’s gateway selection process
as routing instructions in Nadeau ................................. 24

-iib.
Petitioner fails to explain how modifying
Nadeau’s SLC to produce a call packet as
taught by Kelly, leads to “producing a public
network routing message for receipt by [a] call
controller, said public network routing
message identifying a gateway to [a] public
network” as claimed ..................................................... 25
i. The Petition has not indicated where the
call packet would be sent ................................... 26
ii. The Petition fails to explain how the call
packet would be modified such that the
proposed combination produces a public
network routing message for receipt by
the call controller, ... identifying a
gateway to the public network ........................... 27

Ground 2 fails because the Petitioner has failed to identify a
structure in Nadeau that is functionally equivalent to the
“means” recited in Claims 50 and 73 ..............

The Petitioner’s rationale for combining Nadeau-Kelly is
simplistic and incomplete, and is not fairly based upon the
cited arts’ teaching ............................................................................. 35
1. Petitioner overlooks that Nadeau does not need
Kelly’s solution to perform least cost routing, thus
there is no motivation to combine ........................................... 37
2. Petitioner fails to explain why a POSITA would have
been motivated to modify Nadeau in a manner that is
unsupported by the cited art’s teachings ................................. 41

-iii-
3. Petitioner’s analysis of the modifications required is
too truncated and simplistic to establish a reasonable
expectation of success