EXHIBIT 7

Case 6:20-cv-00475-ADA Document 88-7 Filed 03/17/21 Page 1 of 19
Serial No. 10/227,863 

Art Unit 2616 

Response to Office Action mailed June 21, 2007 

PATENT 

Agent's Docket No. 13598-US 

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE 

In re Application of 

ZABIHI, Attaullah et al. 

Serial No: 10/227,863 

Filed: August 27, 2002 

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Art Unit: 2616 

Examiner: LY, Anh Vu H. 

For: STACKABLE VIRTUAL LOCAL AREA NETWORK PROVISIONING IN 

BRIDGED NETWORKS 

October 19, 2007 

Commissioner for Patents 

U.S. Patent and Trademark Office 

Alexandria, VA 22313-1450 

RESPONSE TO OFFICE ACTION MAILED JUNE 21, 2007 

Sir: 

In response to the Office Action dated June 21, 2007, please amend this application 

as follows: 

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AMENDMENTS TO THE CLAIMS 

1. ( currently amended) A method of provisioning a backbone Virtual Local Area 

Network (VLAN) comprising the steps of: 

a. obtaining at least one backbone VLAN IDentifier; 

b. selecting a plurality of backbone VLAN trunks; and 

c. associating the backbone VLAN ID with each one of the plurality of 

backbone VLAN trunks_;_ 

the selection and association of the backbone VLAN ID with each one of the plurality of 

backbone VLAN trunks being undertaken irrespective of [[a]] one of an in-use and a standby designation of each one of the plurality of backbone VLAN trunks. 

2. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, the method further comprising [[a step of:]] tracking previously obtained 

backbone VLAN IDs. 

3. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, the method further comprising [[ a step of:]] generating the at least one backbone 

VLANID. 

4. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 3, wherein generating the at least one backbone VLAN ID, the method further 

comprises a step of: generating a unique backbone VLAN ID. 

5. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, wherein selecting the plurality of backbone VLAN trunks, the method further 

comprises a step of: selecting all managed backbone VLAN trunks. 

6. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 5, wherein selecting all managed backbone VLAN trunks, the method further 

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comprises a step of: selecting all managed backbone VLAN trunks in an associated realm 

of management. 

7. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 5, wherein selecting all managed backbone VLAN trunks, the method further 

comprises a step of: further comprising de-selecting at least one backbone VLAN trunk. 

8. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, wherein associating the backbone VLAN ID with the plurality of backbone VLAN 

trunks, the method further comprises steps of: 

a. determining a plurality of stackable trunk ports corresponding to the 

plurality of backbone VLAN trunks; and 

b. associating the backbone VLAN ID with each one of the plurality of 

stackable trunk ports; 

the association of the backbone VLAN ID with each on of the plurality of stackable trunk 

ports being undertaken irrespective of [[ a]] one of an in-use and a stand-by designation of 

each one of the plurality of backbone VLAN trunks and each one of the plurality of 

stackable trunk ports. 

9. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 8, wherein determining the plurality of stackable trunk ports, the method further 

comprises a step of: selecting all managed stackable trunk ports. 

10. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 9, wherein selecting all stackable trunk ports, the method further comprises a step of: 

selecting all managed stackable trunk ports in the associated realm of management. 

11. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 9, wherein selecting all stackable trunk ports, the method further comprises a step of: 

further comprising de-selecting at least one selected stackable trunk port. 

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12. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 8, wherein associating the backbone VLAN ID with each one of the plurality of 

stackable trunk ports, the method further comprises a step of: issuing commands to the 

plurality of stackable trunk ports to enable support for backbone VLAN ID associated 

communications. 

13. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, further comprising steps of: 

a. selecting at least two tunnel access ports; and 

b. associating the backbone VLAN ID with the selected tunnel access ports. 

14. ( currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 13, wherein associating the backbone VLAN ID with the selected tunnel access ports, 

the method further comprises a step of: issuing commands to the selected tunnel access 

ports to enable support for backbone VLAN ID associated communications. 

15. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, further comprising a step of issuing commands to determine a backbone VLAN 

provisioning status associated with at least one of a backbone VLAN, a backbone VLAN 

trunk, a stackable trunk port, a tunnel access port, and a VLAN access port. 

16. (currently amended) A method of provisioning a backbone VLAN as claimed in 

claim 1, further comprising a step of: defining at least one switching rule by specifying [[a]] 

one of: 

1. a VLAN access port to VLAN access port binding; 

11. a VLAN access port to VLAN trunk port binding; 

111. a VLAN access port to stackable trunk port binding; 

1v. a VLAN trunk port to VLAN trunk port binding; and 

v. a tunnel access port to stackable trunk port binding. 

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17. ( currently amended) A method of provisioning a backbone VLAN trunk 

comprising steps of: 

a. obtaining a plurality of backbone VLAN IDs associated with a 

corresponding plurality of provisioned backbone VLANs; and 

b. associating the plurality of backbone VLAN IDs with the backbone VLAN 

trunk; 

the association of the plurality of backbone VLAN IDs with the backbone VLAN trunk 

being undertaken irrespective of [[a]] one of an in-use and a stand-by designation of the 

backbone VLAN trunk. 

18. ( currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 17, wherein obtaining the plurality of backbone VLAN IDs, the method 

further comprises a step of: obtaining backbone VLAN IDs associated with all provisioned 

backbone VLANs. 

19. (currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 17, wherein obtaining backbone VLAN IDs associated with all 

provisioned backbone VLANs, the method further comprises a step of: obtaining 

backbone VLAN IDs associated with all provisioned backbone VLANs in a realm of 

management. 

20. (currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 1 7, wherein subsequent to obtaining the plurality of backbone VLi"i.N IDs, 

the method further comprises a step of: disregarding at least one backbone VLAN ID 

further comprising disregarding at least one backbone VLAN ID subsequent to obtaining 

the plurality of backbone VLAN IDs. 

21. ( currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 17, wherein associating the plurality of backbone VLAN IDs with the 

backbone VLAN trunk, the method further comprises steps of: 

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Response to Office Action mailed June 21, 2007 

a. determining at least one stackable trunk port corresponding to the backbone 

VLAN trunk; and 

b. associating the backbone VLAN ID§. with the at least one stackable trunk 

port; 

the association of the backbone VLAN ID§. with the at least one stackable trunk port being 

undertaken irrespective of [[a]] one of an in-use and a stand-by designation of the backbone 

VLAN trunk and the at least one stackable trunk port. 

22. ( currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 21, wherein associating the backbone VLAN ID with the at least one 

stackable trunk port, the method further comprises a step of: issuing at least one command 

to the at least one stackable trunk port to enable support for backbone VLAN ID associated 

communications. 

23. ( currently amended) A method of provisioning a backbone VLAN trunk as 

claimed in claim 1 7, further comprising a step of issuing commands to determine a 

backbone VLAN provisioning status associated with at least one of a backbone VLAN, a 

backbone VLAN trunk, and a stackable trunk port. 

24. ( currently amended) 

steps of: 

A method of provisioning a stackable trunk port comprising 

a. obtaining a plurality of backbone VLAN IDs associated with a 

corresponding plurality of provisioned backbone VLAN s; and 

b. associating the plurality of backbone VLAN IDs with the stackable trunk 

port; 

the association of the plurality of backbone VLAN IDs with the stackable trunk port being 

undertaken irrespective of [[a]] one of an in-use and a stand-by designation of the stackable 

trunk port. 

25. (currently amended) A method of provisioning a stackable trunk port as claimed in 

claim 24, wherein obtaining the plurality of backbone VLAN IDs, the method further 

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comprises a step of: obtaining backbone VLAN IDs associated with all provisioned 

backbone VLANs. 

26. ( currently amended) A method of provisioning a stackable trunk port as claimed in 

claim 24, wherein obtaining backbone VLAN IDs associated with all provisioned backbone 

VLANs, the method further comprises a step of: obtaining backbone VLAN IDs 

associated with all provisioned backbone VLANs in a realm of management. 

27. (currently amended) A method of provisioning a stackable trunk port as claimed in 

claim 24, 1.vherein subsequent to obtaining the plurality of backbone VLf,},J" IDs, the 

method further comprises a step of: further comprising disregarding at least one backbone 

VLAN ID subsequent to obtaining the plurality of backbone VLAN IDs. 

28. ( currently amended) A method of provisioning a stackable trunk port as claimed in 

claim 24, wherein associating the backbone VLAN ID§. with the stackable trunk port,-the 

method further comprises a step of: issuing at least one command to the stackable trunk 

port to enable support for backbone VLAN ID associated communications. 

29. ( currently amended) A method of provisioning a stackable trunk port as claimed in 

claim 24, further comprising a step of issuing commands to determine a backbone VLAN 

provisioning status associated with at least one of a backbone VLAN, and a stackable trunk 

port. 

30. ( currently amended) 

comprising: 

A backbone VLAN provisioning human-machine interface 

a. a backbone VLAN ID selector for selecting a plurality of backbone VLAN 

IDs; 

b. a backbone VLAN trunk selector for selecting a plurality of backbone 

VLAN trunks; and 

c. an activator for committing associations between the plurality of backbone 

VLAN IDs and the plurality of backbone VLAN trunks; 

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the associations between the plurality of backbone VLAN IDs and the plurality of backbone 

VLAN trunks being undertaken irrespective of [[a]] one of an in-use and a stand-by 

designation of each one of the plurality of backbone VLAN trunks. 

31. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the backbone VLAN ID selector is further operable to select the plurality 

of backbone VLAN IDs corresponding to all backbone VLAN s provisioned in a managed 

communications network. 

32. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the backbone VLAN ID selector is further operable to de-select at least 

one backbone VLAN ID from the plurality of selected backbone VLAN IDs. 

33. (original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the backbone VLAN trunk selector is further operable to select all 

backbone VLAN trunks provisioned in a managed communications network. 

34. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the backbone VLAN trunk selector is further operable to de-select at 

least one backbone VLAN trunk from the plurality of selected backbone VLAN trunks. 

35. (original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the activator is further operable to initiate the issuing of at least one 

command to effect the associations between the plurality of backbone VLAN IDs and the 

plurality of backbone VLAN trunks. 

36. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, wherein the backbone VLAN trunk selector further comprises a stackable trunk 

port selector operable to select at least one stackable trunk port. 

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Response to Office Action mailed June 21, 2007 

37. (original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 36, wherein stackable trunk port selector operable to select all stackable trunk ports in 

a managed communications network. 

38. (original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 37, wherein stackable trunk port selector is further operable to de-select at least one 

stackable trunk port. 

39. (original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 37, wherein the activator is further operable to initiate the issuing of at least one 

command to effect the associations between the plurality of backbone VLAN IDs and the 

plurality of stackable trunk ports. 

40. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 30, further comprising a tunnel access port selector for selecting at least two tunnel 

access ports. 

41. ( currently amended) A backbone VLAN provisioning human-machine interface as 

claimed in claim 40[[;]].. the activator further being operable to effect associations between 

the plurality of backbone VLAN IDs and the at least two tunnel access ports. 

42. ( original) A backbone VLAN provisioning human-machine interface as claimed in 

claim 41, wherein the activator is further operable to issue at least one command to effect 

the associations between the plurality of backbone VLAN IDs and the at least two tunnel 

access ports. 

43. (currently amended) A backbone VLAN provisioning human-machine interface as 

claimed in claim 30, further being operable to display comprising means for displaying a 

backbone VLAN provisioning status for at least one of a backbone VLAN, a backbone 

VLAN trunk, a stackable trunk port, a VLAN access port and a tunnel access port. 

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44. ( currently amended) A backbone VLAN provisioning human-machine interface as 

claimed in claim 30, further being operable to define comprising means for defining at least 

one switching rule by specifying a one of: 

1. a VLAN access port to VLAN access port binding; 

11. a VLAN access port to VLAN trunk port binding; 

111. a VLAN access port to stackable trunk port binding; 

1v. a VLAN trunk port to VLAN trunk port binding; and 

v. a tunnel access port to stackable trunk port binding. 

45. (currently amended) A network management system using the human-machine 

interface claimed defined in claim 30 to effect backbone VLAN provisioning in a managed 

communications network. 

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Art Unit 2616 

Response to Office Action mailed June 21, 2007 

REMARKS 

Claims 1-30 and 41, and 43-45 have been amended solely to improve language by 

correcting grammatical errors and punctuation errors. No new subject matter has been 

added. The scope of the claims has not been changed in any way. 

The Examiner has objected to claims 1, 8, 17, 21, 24, 28, and 30-45 as containing 

various specified informality errors. The claims have been amended to correct most of the 

alleged errors. However, the words "human-machine" have not been removed from the 

preamble of claims 30-45, as the Applicant does not feel that these words are incorrect. If 

the Examiner insists that these words be removed, the Examiner is kindly asked to provide 

an explanation as to why these words should be removed. 

The Examiner has objected to claims 1-45 under 35 U.S.C. §102(e) as being 

anticipated by U.S. Patent 6,678,241 issued to Gai et al. 

Gai teaches a method of route redundancy for VLANs. Each VLAN is considered a 

logical VLAN, designated by an ID (in Gai's example of FIG. 2 and FIG. 5c, these are 

RED, GREEN, BLUE, and YELLOW). Each "logical" VLAN is assigned a number of 

actual, "physical" VLANs. For each logical VLAN, one of the physical VLANs is 

designated as "active", and the remaining physical VLANs are designated as "stand-by" or 

"unusable" (FIG. 5c, and column 12 lines 25-42). If a link within the active physical 

VLAN for a logical VLAN fails, then the various switches and routers can quickly switch 

to one of the stand-by physical VLANs for that logical VLAN (abstract, column 5 lines 17-

51). No active VLANs are grouped in any way. What appears as a grouping of multiple 

physical VLANs into a single logical VLAN is really the other way around; for a particular 

VLAN required by a customer, several physical VLANs are designated in order to provide 

stand-by routes in case of link failure. 

This is completely different from the present invention. The present invention, as 

claimed, is directed to a method of increasing the number of possible actual VLANs beyond 

the usual 4096 (or 4094, if the reserved VLAN IDs are ignored) limit. Backbone VLANs 

are defined, each with a backbone VLAN ID. A VLAN has its usual VLAN ID and in 

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addition has a backbone VLAN ID. Backbone VLANs travel over backbone VLAN trunks, 

which are defined between stackable trunk ports on core routers. The association between 

the backbone VLAN IDs and the backbone VLAN trunks is irrespective of whether the 

backbone trunks are designated as stand-by or in-use. An interface is provided which 

ensures that each VLAN and VLAN ID combination is unique, and allows relatively easy 

provisioning of backbone VLANs, backbone VLAN trunks, and stackable trunk ports. 

The differences between Gai and the present invention will be seen clearly be 

considering the individual elements of the claims. 

Claim 1 is directed to a method of provisioning a backbone VLAN. Gai does not 

teach such a method. Gai teaches a method of providing stand-by VLANs for an active 

VLAN by assigning a plurality of physical VLANs to an actual VLAN. One of these 

plurality ofVLANs is designated as active (step 408 of FIG. 4), and the others are 

designated as stand-by or unusable (FIG. 5). This is in no way equivalent to provisioning a 

backbone VLAN. A backbone VLAN is a path through the core of a network, defined by 

the switching rules for the stackable trunk ports, which is able to carry a number ofVLANs. 

The backbone VLAN uses a field which is in addition to the usual VLAN ID field in order 

that the various core routers through which the backbone VLAN passes are able to switch 

packets to appropriate stackable trunk ports. Gai does not teach backbone VLANs in any 

way. 

Claim 1 also includes the limitation of obtaining at least one backbone VLAN ID. 

This is a limitation not taught by Gai. Nowhere does Gai discuss backbone VLAN IDs. 

The Examiner has equated the ID of the logical VLANs of Gai (e.g. RED) with the 

backbone VLAN IDs when considering an earlier limitation of the claim. As discussed 

above with reference to the overall teachings of Gai, the ID of a logical VLAN ( e.g. RED) 

is the ID of a single actual VLAN. This single actual VLAN then has several distinct 

physical VLANs assigned to it, each distinct physical VLAN being over a different path in 

order to provide redundancy for the actual VLAN. This is in no way equivalent to a 

backbone VLAN ID, since a backbone VLAN ID identifies a backbone VLAN which, as 

explained above, may carry a multitude ofVLANs over a single trunk. 

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Claim 1 also includes the limitation of selecting a plurality of backbone VLAN 

trunks. This is a limitation not taught by Gai. The Examiner states that Gai teaches this 

limitation as the links 428 of Figure 2. The Applicant respectfully submits the mere 

presence of the links 248 does not teach selecting the links, especially in the context of a 

provisioning method. In order to teach this limitation of claim 1, the Examiner must show 

where Gai teaches selecting one of the links as part of a provisioning method. 

Furthermore, column 6 lines 19-23 of Gai explain that the links 428 are "trunks or 

links 248, such as point-to-point links. Link 248 basically represent communication paths 

for transporting messages, such as data frames, between various network components". 

The links 248 are therefore simply generic links between network switches, and no 

suggestion at all is given that these are backbone VLAN trunks. 

Claim 1 also includes the limitation of associating the backbone VLAN IDs with 

each one of the plurality of backbone VLAN trunks. This is a limitation not taught by Gai. 

The Examiner has stated that Gai teaches this limitation at column 7 lines 10-15. However, 

as discussed above, Gai does not teach backbone VLAN IDs or backbone VLAN trunks. 

Furthermore, this passage recites the normal use ofVLAN designations for VLANs. As 

stated at column 6 lines 53-65, the VLAN designations are the usual VLAN IDs used for 

normal VLANs, namely numeric values having values between O and 4095. These are 

clearly not backbone VLAN IDs, which are designed deliberately to get around the hard 

limit of 4096 ( 4094 if reserved IDs are not used) possible unique VLAN designations. 

Claim 1 also includes the limitation that the selection and association of the 

backbone VLAN IDs with the backbone VLAN trunks is undertaken irrespective of an inuse and a stand-by designation of the backbone VLAN trunks. This is a limitation not 

taught by Gai. As discussed above, Gai does not teach backbone VLAN IDs or backbone 

VLAN trunks. More importantly, the Examiner states that "each physical VLAN is 

designated as ACTIVE, STAND-BY, and UNUSABLE. This implies that the trunks in the 

physical VLANs associated with each logical VLAN are undertaken irrespective of a one 

in-use and/or stand-by designation". This is actually contrary to the limitation of claim 1. 

Because each logical VLAN (which the Examiner has equated with a backbone VLAN by 

equating the ID RED with a backbone VLAN ID) deliberately has one active physical 

VLAN associated with it and a number of stand-by physical VLANs, the association cannot 

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be said to be irrespective of whether the trunk is in-use or stand-by. In fact, if Gai's 

association was irrespective of whether the trunks were in-use or stand-by, then the method 

taught by Gai would not work because the entire point of Gai is to have exactly one in-use 

physical VLAN and one or more stand-by physical VLANs to act as redundant VLANs 

should the active VLAN fail. 

Claims 2-16 are dependent on claim 1 and include the same limitations discussed 

above. Because Gai does not teach each and every element of the claims, the Applicant 

respectfully submits that claims 1-16 are not anticipated by Gai. 

Claim 17 is directed to a method of provisioning a backbone VLAN trunk. As 

discussed above with reference to claim 1, Gai does not teach backbone VLAN trunks, nor 

a method of provisioning a backbone VLAN trunk. Gai at most teaches a method of 

provisioning redundant VLANs. In any event, the Examiner has not shown where Gai 

teaches such a method. 

Claim 17 also includes the limitation of obtaining a plurality of backbone VLAN 

IDs associated with a corresponding plurality of provisioned backbone VLAN s. This is a 

limitation not taught by Gai. The Examiner states that Gai teaches this in Figure 5c as the 

IDs RED, BLUE, etc. However, as discussed above with reference to claim 1, these are 

IDs associated with logical VLANs and are not IDs associated with backbone VLANs. 

Furthermore, the mere presence of IDs is not sufficient to show a step of obtaining the IDs, 

certainly not in the context of a method of provisioning. 

Claim 17 also includes the limitation of associating the plurality of backbone VLAN 

IDs with the backbone VLAN trunk. This is a limitation not taught by Gai. The Examiner 

states that Gai teaches this at column 7 lines 10-15. However, as discussed above with 

reference to claim 1, this passage teaches the usual use of normal VLAN IDs, which are 

different from backbone VLAN IDs. 

Claim 17 also includes the limitation that the association of the plurality of 

backbone VLAN IDs with the backbone VLAN trunk is undertaken irrespective of the inuse or stand-by designation of the backbone VLAN trunk. Gai does not teach backbone 

VLAN IDs or a backbone VLAN trunk. Regarding the association being irrespective of the 

in-use or stand-by designation, as discussed above with reference to claim 1 Gai expressly 

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takes into account whether a physical VLAN is active or stand-by in making the 

association, and is therefore the opposite of "irrespective". 

Claims 18-23 are dependent on claim 17 and include the same limitations discussed 

above. Since Gai does not teach each and every element of the claims, the Applicant 

respectfully submits that claims 17-23 are not anticipated by Gai. 

Claim 24 is directed to a method of provisioning a stackable trunk port. The 

Examiner has not shown where Gai teaches a method of provisioning a stackable trunk 

port. 

Claim 24 includes the limitation of obtaining a plurality of backbone VLAN IDs 

associated with a corresponding plurality of provisioned backbone VLANs. This is a 

limitation not taught by Gai. The Examiner states that Gai teaches this in Figure 5c as the 

IDs RED, BLUE, etc. However, as discussed above with reference to claim 17, these are 

IDs associated with logical VLANs and are not IDs associated with backbone VLANs. 

Furthermore, the mere presence of IDs is not sufficient to show a step of obtaining the IDs, 

certainly not in the context of a method of provisioning. 

Claim 24 also includes the limitation of associating the plurality of backbone VLAN 

IDs with the stackable trunk port. This is a limitation not taught by Gai. The Examiner 

states that Gai teaches this as the association between trunk ports 302a-302c with the RED 

identifier. However, as discussed above, the RED identifier is not a backbone VLAN ID. 

Claim 24 also includes the limitation that the association of the plurality of 

backbone VLAN IDs with the stackable trunk port is undertaken irrespective of the in-use 

or stand-by designation of the stackable trunk port. However, as discussed above with 

reference to claims 1 and 17, Gai expressly takes into account whether a physical VLAN is 

active or stand-by in making the association, and is therefore the opposite of "irrespective". 

Claims 25-29 are dependent on claim 24 and include the same limitations discussed 

above. Since Gai does not teach each and every element of the claims, the Applicant 

respectfully submits that claims 24-29 are not anticipated by Gai. 

Claim 30 is directed to a backbone VLAN provisioning human-machine interface. 

The limitations of the claims include selectors and activators for effecting specified actions. 

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The Examiner has not shown where Gai teaches such a human-machine interface. The 

Examine has treated claim 30 the same as claim 1, but these are different categories of 

claims and comprise different limitations. For example, addresses the preamble of claim 30 

by stating that Gai discloses a method of provisioning a backbone VLAN in Figure 4. 

However, Figure 4 in no way discloses a human-machine interface as recited in claim 30. 

This ignores a major aspect of the invention, which is a NMS interface with specified 

functionality buttons which simplifies provisioning of backbone VLANs. 

Claim 30 includes the limitation of a backbone VLAN ID selector for selecting a 

plurality of backbone VLAN IDs. As discussed above, Gai does not teach backbone VLAN 

IDs. In addition, the Examiner has not shown where Gai teaches such a selector within a 

human-machine interface. 

Claim 30 also includes the limitation of a backbone VLAN trunk selector for 

selecting a plurality of backbone VLAN trunks. As discussed above, Gai does not teach 

backbone VLAN trunks. In addition, the Examiner has not shown where Gai teaches such 

a selector within a human-machine interface. 

Claim 30 also includes the limitation of an activator for committing associations 

between the plurality of backbone VLAN IDs and the plurality of backbone VLAN trunks. 

As discussed above, Gai does not teach backbone VLAN IDs or backbone VLAN trunks. 

In addition, the Examiner has not shown where Gai teaches such an activator within a 

human-machine interface. 

Claim 30 also includes the limitation that the associations between the plurality of 

backbone VLAN IDs and the plurality of backbone VLAN trunks is undertaken irrespective 

of the in-use or stand-by designation of the backbone VLAN trunks. However, as discussed 

above with reference to claims 1 and 17, Gai expressly takes into account whether a 

physical VLAN is active or stand-by in making the association, and is therefore the 

opposite of "irrespective". 

Claims 31-44 are dependent on claim 30 and include the same limitations discussed 

above. Claim 45 is directed to an NMS which includes the limitations of claim 30. Since 

Gai does not teach each and every element of the claims, the Applicant respectfully submits 

that claims 30-45 are not anticipated by Gai. 

16 

Case 6:20-cv-00475-ADA Document 88-7 Filed 03/17/21 Page 17 of 19
Serial No. 10/227,863 

Art Unit 2616 

Response to Office Action mailed June 21, 2007 

The Examiner is kindly asked to consider the aspect of the invention reflected in 

claims 30-45, namely the NMS interface whose inventive elements simplify provisioning of 

backbone VLANs. 

In view of the foregoing, it is believed that the claims at present on file and as 

amended herein are in condition for allowance. Reconsideration and action to this end is 

respectfully requested. 

MARKS & CLERK 

P.O. Box 957, Station B 

Ottawa, ON KIP 5S7 (613)236-9561 

17 

Respectfully submitted, 

S. Mark Budd 

Registration No. 53,880 

Agent of Record 

Case 6:20-cv-00475-ADA Document 88-7 Filed 03/17/21 Page 18 of 19
REPLACEMENT SHEET 

i Lower Layer~ I Standard I ' Higher Layer 1 

1 __ H~~d~~ __ 1 VLAN Header : Headers J Data Packet Payload I 

'Lower Layer~ I Standard I Extended I HigherCayer -1 l 

: __ H~~d~~ - _1 VLAN Header VLAN Header : Headers J Data Packet Payload I 

IEEE 802.1Q Riverstone 

Header Solution 

FIG. 2 

'------200 

PRIOR ART 

Access 

Side 

306 

) Core 

Side 306 

~-- 130~04~ 

--:-::-f1J AP 

VLAN30,2 

~ 

80~ VLAN3 

VLAN4 

802~04.h. ~ 

VLAN30,5 

VLAN20,6 

FIG. 6 

I 104 130 104 

rfi"-----<--~ ~AP AP't:!J 

VLAN2 VLAN2 

£202 8022 20Z"b 

~-TP-------'---T~ 

VLAN2 VLAN2 

VLAN3 VLAN3 

VLAN4 VLAN4 

202 

Pl5 TP 

VLAN2 

VLAN3 

VLAN4 

802 

(302 \308 

304 

TAP 

VLAN2 

VLAN3 

VLAN4 

STP -------------J VLAN30,5 

VLAN20,6 

VLAN30,2 

STP 

VLAN30,5 '••• 

VLAN20,6 

VLAN30,2 

Case 6:20-cv-00475-ADA Document 88-7 Filed 03/17/21 Page 19 of 19