Exhibit A – Narrowed Terms Identified by Defendant

A. Group 1

1. ’133 Patent

Claim Term, Clause, or Phrase Claim(s)

1 “whether a congestion condition exists [on/for] the egress node” 1, 12, and 13

2 “processing the packets” 1, 12, and 13

3 “such that packets associated with egress nodes for which the 

congestion condition does not exist have a different queuing priority 

within the load balancing network than packets associated with egress 

nodes for which the congestion condition exists”

1, 12, and 13

4 “means for determining, for each packet, whether a congestion condition 

exists on the egress node”

12

5 “means for processing the packets such that packets associated with 

egress nodes for which the congestion condition does not exist have a 

different queuing priority within the load-balancing network than 

packets associated with egress nodes for which the congestion condition 

exists”

12

2. ’800 Patent

Claim Term, Clause, or Phrase Claim(s)

6 “latency cost” 1 and 13

7 “[determining/determine] an assignment objective” 1 and 13

3. ’309 Patent

Claim Term, Clause, or Phrase Claim(s)

8 “split ratio vector” 1, 11, and 16

4. ’360 Patent

Claim Term, Clause, or Phrase Claim(s)

9 “said element comprises: an element for recording whether a queue is 

empty or occupied, an element for recording the [number of data 

cells/quantity of data] contained in a queue, an element identifying a 

queue from which data is to be output, and an element identifying a 

group of queues from which data is to be output”

1 and 26

Case 6:20-cv-00478-ADA Document 84-1 Filed 02/12/21 Page 1 of 5
Exhibit A – Narrowed Terms Identified by Defendant

Claim Term, Clause, or Phrase Claim(s)

10 “expected state for said element” “predetermined state for said 

element” “expected value of said parameter” “expected states for that 

element” “expected status for said element”

“expected state of said first element”

1, 3, 12, 13,

18, 21, 24, 26,

28, 29, 48, and

49

11 “computer generated model” 1, 18, 21, 26,

44, and 45

12 “element for recording whether a queue is empty or occupied”

* * *

“an element for recording the [number of [data] cells/quantity of data] 

contained in a queue”

* * *

“an element identifying a queue from which data is to be output”

* * *

“an element [identifying/indicating] a group of queues from which data 

is to be output”

1, 5, 6, 7–9,

14–15, 20, 25,

26, 30, 33–35,

and 38

* * *

1, 5–6, 9, 14–

15, 20, 26, 30,

33–35, and 38

* * *

1, 26, 5, 20,

and 30

* * *

1, 5, 9, 14–15,

20, 26, 30, 33,

35, and 38

13 “determining means for determining an expected value of said 

paramater”

1

18

14 “detection means for detecting a state of an element”

2 1 and 24

1 Defendants contend that resolution of this dispute will apply equally to the terms “determining means for determining an 

expected state for said element based on said monitored parameter” (claim 3) and “prediction means for determining an expected 

status for said element” (claims 12 and 13); Plaintiff does not agree. 

2 Defendants contend that resolution of this dispute will apply equally to the terms “determining means for determining an 

expected state for said element based on said monitored parameter” (claim 3) and “prediction means for determining an expected 

status for said element” (claims 12 and 13); Plaintiff does not agree. 

Case 6:20-cv-00478-ADA Document 84-1 Filed 02/12/21 Page 2 of 5
Exhibit A – Narrowed Terms Identified by Defendant

Claim Term, Clause, or Phrase Claim(s)

15 “comparing means for comparing the detected state with a 

predetermined state for said element and for outputting the result of the 

comparison”3

1 and 24

B. Group 2

1. ’144 Patent

Claim Term, Clause, or Phrase Claim(s)

16 “group of communication traffic” 1, 4, 11, 12, 14

17 “V is a group identifier corresponding to the group of communication 

traffic”

1, 11, 14

2. ’921 Patent

Claim Term, Clause, or Phrase Claim(s)

18 “data plane means for forwarding packets between the nodes” (claim 1) 

/ “data plane means for forwarding packets to other nodes in the 

network” (claims 9 & 17)

1, 9, 17

19 “fast propagation” 1, 9, 17

C. Group 3

1. ’489 Patent

Claim Term, Clause, or Phrase Claim(s)

20 “the first set of port interfaces of the multi-chassis link aggregate” 1, 8, 15

2. ’020 Patent

Claim Term, Clause, or Phrase Claim(s)

21 “removing, at the network node, the protocol data of a portion of 

protocol layers from the received data stream” (claim 1) / “removes 

protocol data from a portion of protocol layers from a data stream” 

(claim 6)

1, 6

22 “a control unit which removes protocol data from a portion of 

protocol layers from a data stream received from the communication 

network via the second interface, the data stream comprising

6

3 Defendants contend that resolution of this dispute will apply equally to the terms “determining means for determining an 

expected state for said element based on said monitored parameter” (claim 3) and “prediction means for determining an 

expected status for said element” (claims 12 and 13); ; Plaintiff does not agree. 

Case 6:20-cv-00478-ADA Document 84-1 Filed 02/12/21 Page 3 of 5
Exhibit A – Narrowed Terms Identified by Defendant

23 “bus system” 1, 6

D. Group 4

1. ’435 Patent

Claim Term, Clause, or Phrase Claim(s)

24 “setting the IPPC of one of the ports of one of said bridges within the 

MSTI to a lower IPPC when said port is part of the VLAN member 

set”

1, 8, 13

25 “processing unit for setting the Internal Port Path Cost (IPPC) of one of 

the ports of one of said bridges within the MSTI...”

8

26 “ideally” 7, 11, 18

27 entirety of claims 9–11, 13–18

2. ’536 Patent

Claim Term, Clause, or Phrase Claim(s)

28 “bridge” 1, 12

29 “channel in a connection-based network” 1, 12

30 “means for reading priorities of data frames directed by the bridge to at 

least a first one of the bridge ports”

12

31 “forwarding system configured to read a priority of a data frame to be 

forwarded onto the connection-based network by way of the first one of 

the ports, identify a service interface which the map indicates 

corresponds to the read user priority and forward the data frame over 

the channel in the connection-based network associated with the 

identified service interface”

1

3. ’888 Patent

Claim Term, Clause, or Phrase Claim(s)

32 “stackable trunk port” 1, 15

33 “backbone VLAN trunk” 1, 15

Case 6:20-cv-00478-ADA Document 84-1 Filed 02/12/21 Page 4 of 5
Exhibit A – Narrowed Terms Identified by Defendant

34 “wherein the selection and association of at least one backbone VLAN 

ID with each one of the corresponding plurality of backbone VLAN 

trunks is undertaken irrespective of 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” (claim 1) / “wherein 

the association of the plurality of backbone VLAN IDs with the 

backbone VLAN trunk is undertaken irrespective of one of an in-use and 

a stand-by designation of the backbone VLAN trunk and the at least one 

stackable trunk port” (claim 15)

1, 15

4. ’129 Patent

Claim Term, Clause, or Phrase Claim(s)

35 “rate of change” 3

36 “initiating a poll of resources in the nodes of the network by the 

management station in response to reporting from the node or a time 

interval being exceeded”

3

Case 6:20-cv-00478-ADA Document 84-1 Filed 02/12/21 Page 5 of 5