i 

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

VOIP-PAL.COM, INC., § 

Plaintiff, § 

§ 

§ 6:20-CV-00272-ADA 

v. § 

§ 

AMAZON.COM, INC.; § 

AMAZON.COM SERVICES LLC; and § 

AMAZON WEB SERVICES, INC., §

Defendants. § 

PLAINTIFF VOIP-PAL.COM’S OPPOSED MOTION FOR PARTIAL 

RECONSIDERATION OF CLAIM CONSTRUCTION ORDER 

 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 1 of 16
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TABLE OF CONTENTS 

I. INTRODUCTION...................................................................................1 

II. FACTUAL BACKGROUND.....................................................................2 

III. LEGAL STANDARD..............................................................................3 

IV. ARGUMENT........................................................................................4 

A. A Routing Message Does Not Require A TTL Field. .....................................4 

B. Considering The Intrinsic Record As A Whole Shows That A Routing Message 

Does Not Require A TTL Field. ............................................................6 

V. CONCLUSION....................................................................................9 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 2 of 16
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TABLE OF AUTHORITIES 

Cases

Asetek Holdings, Inc. v. Coolit Sys., No. C-12-4498 EMC, 2013 U.S. Dist. LEXIS 170488 (N.D. 

Cal. Dec. 3, 2013)............................................................................................................................ 8 

Atser Research Techs., Inc. v. Raba-Kistner Consultants, Inc., No. SA-07-CA-93-H, 2009 U.S. 

Dist. LEXIS 25294 (W.D. Tex. Mar. 2, 2009) ................................................................................ 8 

Clare v. Chrysler Grp., LLC, 819 F.3d 1323 (Fed. Cir. 2016) ........................................................... 8 

Curtiss-Wright Flow Control Corp. v. Velan Inc., 438 F.3d 1374 (Fed. Cir. 2006) .......................... 8 

eTool Dev., Inc. v. Nat’l Semiconductor Corp., 881 F. Supp. 2d 745 (E.D. Tex. 2012) .................... 3 

Ferring B.V. v. Watson Labs., Inc., 3:11-cv-00481-RCJ-VPC, 2013 U.S. Dist. LEXIS 17536 (D. 

Nev. Feb. 6, 2013) ........................................................................................................................... 8 

Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir. 2014) ............................................ 9 

In re Benjamin Moore & Co., 318 F.3d 626 (5th Cir. 2002) .............................................................. 3 

Interdigital Commuc’ns., Inc. v. ZTE Corp., 1:13-cv-00009-RG, 2014 U.S. Dist. LEXIS 113316 

(D. Del. Aug. 8, 2014) ..................................................................................................................... 8 

Jack Guttman, Inc. v. Kopykake Enters., Inc., 302 F.3d 1352 (Fed. Cir. 2002) ................................. 3 

Liebel- Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir. 2004).............................................. 9 

Mediatek Inc. v. Freescale Semiconductor, Inc., No. 11-cv-5341 YGR, 2014 U.S. Dist. LEXIS 

31461 (N.D. Cal. Mar. 5, 2014) ...................................................................................................... 3 

Pressure Prods. Med. Supplies, Inc. v. Greatbatch Ltd., 599 F.3d 1308 (Fed. Cir. 2010) ................. 3 

Serverside Grp. Ltd. v. Tactical 8 Techs., L.L.C., 927 F. Supp. 2d 623 (N.D. Iowa 2013) ................ 9 

Tyco Healthcare Grp. LP v. Ethicon Endo-Surgery, Inc., 440 F. Supp. 2d 120 (D. Conn. 2006) ..... 3 

WI-Lan, Inc. v. Acer, Inc., No. 2:07-CV-473-TJW-CE, 2010 U.S. Dist. LEXIS 138111 (E.D. Tex. 

Dec. 30, 2010) ................................................................................................................................. 3 

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Wright Asphalt Prods. Co., LLC v. Pelican Ref. Co., LLC, No. H-09-1145, 2012 U.S. Dist. LEXIS 

73901 (S.D. Tex. May 29, 2012)..................................................................................................... 3 

Yeti Coolers, LLC v. RTIC Coolers, LLC, No. A-15-CV-597-RP, 2017 U.S. Dist. LEXIS 11163, at 

*9 (W.D. Tex. Jan. 27, 2017) .......................................................................................................... 3 

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TABLE OF ABBREVIATIONS 

ABBREVIATION TERM 

VoIP-Pal Plaintiff VoIP-Pal.com, Inc. 

Amazon Amazon.com, Inc., Amazon.com Services, 

LLC, and Amazon Web Services, Inc. 

Defendant Amazon 

The ’606 patent or the patent-in-suit U.S. Patent No. 10,218,606 

The ’005 patent U.S. Patent No. 9,179,005 

The ’864 patent U.S. Patent No. 11,171,864 

TTL Time to Live 

PCT Patent Cooperation Treaty 

 

 

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I. INTRODUCTION 

VoIP-Pal respectfully requests that the Court reconsider and refine its construction of the 

term “routing message” because part of the construction is clearly erroneous. The Court adopted 

Amazon’s proposed construction of this term and construed it to mean “a message that includes a 

callee user name field, a route field, and a time to live field.”1 While VoIP-Pal disagrees with this 

construction as a whole, by this Motion, VoIP-Pal only asks that the Court fine-tune this 

construction by removing the requirement that a routing message must have “a time to live field.” 

In the ’606 patent, a routing message is not defined by a TTL field. Indeed, the TTL field has 

nothing to do with the routing—it has to do with billing. It “holds a value representing the number 

of seconds the call is permitted to be active, based on subscriber available minutes and other billing 

parameters.”2 Not only does the specification of the ’606 patent expressly distinguish between 

routing and billing, but the entirety of the intrinsic record, which includes eleven other family 

members of the ’606 patent, makes it abundantly clear that the TTL field is not a requirement of a 

routing message. The Court’s construction, however, would work a manifest injustice because it 

would require that all 12 U.S. patents in the family be limited to a routing message that has a TTL 

field even though several of those patents expressly claim TTL as an optional feature of a routing 

message. 

The Court admitted that the parties’ arguments for their respective constructions were 

closely counterposed, requiring the Court to go “back and forth ... to try and get [the construction] 

right.”3 What should not be open to debate, however, is the portion of Amazon’s proposed 

1

 Dkt. No. 87 at 2. 

2

 Dkt. No. 1-1 at 21:55-60. 

3

 Ex. 1 at 25:23-24. All exhibits refer to exhibits to the Declaration of Lewis E. Hudnell, III. 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 6 of 16
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construction, which the Court adopted, that requires a routing message to have a TTL field. 

Accordingly, VoIP-Pal respectfully requests that the Court reconsider and modify its construction 

of “routing message” to be “a message that includes a callee user name field and a route field.” 

II. FACTUAL BACKGROUND 

The Court conducted a Claim Construction Hearing on February 15, 2023 at which the parties 

only argued one term—“routing message.” The following table depicts the parties’ proposals and the 

Court’s constructions (preliminary and final): 

Term VoIP-Pal’s 

Proposal 

Defendants’ 

Proposal 

Court’s 

Preliminary 

Construction 

Court’s 

Final 

Construction 

“routing 

message” 

Plain and 

ordinary 

meaning 

“a message that 

includes a callee 

user name field, a 

route field, and a 

time to live 

field.”

Plain and 

ordinary 

meaning 

“a message that 

includes a callee 

user name field, a 

route field, and a 

time to live 

field.”

Although the Court initially agreed with VoIP-Pal’s proposed construction, the Court ultimately 

adopted Amazon’s proposed construction. Yet the Court remained undecided as to the proper 

construction during the hearing, commenting that “every time [Amazon’s counsel] finished I thought 

[he was] right. And every time [VoIP-Pal’s counsel] finished I thought he was right.”4

 Before the 

hearing, the Court’s clerk advised the parties that “it is generally unlikely that the Court will select a 

party’s originally proposed construction over the preliminary construction. As such, the Court believes 

that making arguments to fine-tune the preliminary construction may be more helpful.”5

 In concluding 

its arguments, VoIP-Pal briefly argued that, at a minimum, the TTL filed should be excluded from the 

construction.6

 The parties, however, did not focus their arguments on whether the TTL field should be 

excluded from the final construction of “routing message.” VoIP-Pal respectfully submits that such 

4

 Ex. 1 at 26:11-13. 

5

 Ex. 2. 

6 Id. at 24:10-25:6. 

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fine-tuning is not only more accurate but is necessary in this situation to avoid manifest injustice. 

III. LEGAL STANDARD 

 Rule 54(b) of the Federal Rules of Civil Procedure provides that an order “that adjudicates 

fewer than all the claims or the rights and liabilities of fewer than all the parties does not end the 

action as to any of the claims or parties and may be revised at any time before the entry of a judgment 

adjudicating all the claims and all the parties’ rights and liabilities.”7 This Court may grant a motion 

for reconsideration if there is “the need to correct a clear error of law or prevent manifest injustice.”8 

Several district courts, including district courts in this Circuit, have granted reconsideration of claim 

construction orders.9

 In addition, the Federal Circuit has repeatedly endorsed “rolling claim construction” by 

district courts—that is, the practice of “revisit[ing] and alter[ing]” the court’s “interpretation of the 

claim terms as its understanding of the technology evolves.”10 Rolling claim construction is 

especially necessary “where issues involved are complex, either due to the nature of the technology 

or because the meaning of the claims is unclear from the intrinsic evidence.”11 Indeed, Amazon 

admitted at the beginning of the Claim Construction Hearing that the issues concerning the term 

7 See eTool Dev., Inc. v. Nat’l Semiconductor Corp., 881 F. Supp. 2d 745, 748 (E.D. Tex. 2012). 

8 See In re Benjamin Moore & Co., 318 F.3d 626, 629 (5th Cir. 2002). 

9 See, e.g., Wright Asphalt Prods. Co., LLC v. Pelican Ref. Co., LLC, No. H-09-1145, 2012 U.S. Dist. 

LEXIS 73901 (S.D. Tex. May 29, 2012); WI-Lan, Inc. v. Acer, Inc., No. 2:07-CV-473-TJW-CE, 

2010 U.S. Dist. LEXIS 138111 (E.D. Tex. Dec. 30, 2010); Tyco Healthcare Grp. LP v. Ethicon 

Endo-Surgery, Inc., 440 F. Supp. 2d 120 (D. Conn. 2006). 

10 See Pressure Prods. Med. Supplies, Inc. v. Greatbatch Ltd., 599 F.3d 1308, 1316 (Fed. Cir. 

2010) (citing cases). 

11 See Jack Guttman, Inc. v. Kopykake Enters., Inc., 302 F.3d 1352, 1361 (Fed. Cir. 2002); see also 

Yeti Coolers, LLC v. RTIC Coolers, LLC, No. A-15-CV-597-RP, 2017 U.S. Dist. LEXIS 11163, at 

*9 (W.D. Tex. Jan. 27, 2017) (quoting Mediatek Inc. v. Freescale Semiconductor, Inc., No. 11-cv5341 YGR, 2014 U.S. Dist. LEXIS 31461, at *9 (N.D. Cal. Mar. 5, 2014)) (“Accordingly, the final 

determination of the construction of any claim occurs at the close of trial and manifests itself in the 

form of jury instructions.”). 

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“routing message” address “a highly technical area, the area of voice-over IP calling.”12 Thus, 

reconsideration in this case is warranted. 

IV. ARGUMENT 

A. A Routing Message Does Not Require A TTL Field. 

The Court should remove the TTL field from the construction of the term “routing message” 

because the use of a TTL field concerns a billing-related concept, independent from the callee and 

route fields. The TTL field has nothing to do with routing a communication and is not claimed in 

the ’606 patent. As the specification states, “[t]he time to live field 362 holds a value representing 

the number of seconds the call is permitted to be active, based on subscriber available minutes and 

other billing parameters.”13 The TTL field relates to the billing aspects of the overall system 

disclosed in the specification and is not an essential aspect of routing a call. Indeed, there is an 

entire section of the specification devoted to determining TTL that has nothing to do with routing.14

The specification states that the TTL field is used in one embodiment of the invention to 

determine a permissible length of a communication session: “[i]n accordance with another aspect 

of the invention, there is provided a method for determining a time to permit a communication 

session to be conducted.”15 The TTL section of the specification explains that the TTL field is set 

based on the cost of a communication in comparison to the funds balance of the caller’s account. 

For example, in one embodiment, if a caller’s funds balance or free time balance are not greater 

than 0, then TTL is set to 0 and the call is denied.16 In other cases, such as a network or crossdomain call, calling may be free, and TTL is set to 99999, in which case the call is treated as having 

12 Ex. 1 at 3:13-14. 

13 Dkt. No. 1-1 at 21:55-60. 

14 Id. at 28:45-31:40. 

15 Id. at 6:51-62; see also id. at 28:45-29:5 (“Referring to FIGS. 33A and 33B, a process for 

determining a time to live value for any of blocks 642 in FIG. 8C, 350 in FIG. 8A or 564 in FIG. 8D 

above is described.”). 

16 Id. at 30:26-35; see also id. at 31:26-37, Fig. 33A (746, 748). 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 9 of 16
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an effectively unlimited duration.17 In some scenarios, TTL may be appended to specific paths 

(routes) to limit communication session duration, but a routing message need not limit session 

duration in order to specify a path (route).18 The determination and use of the TTL field is a separate 

aspect of the invention, not related to routing, and is not an essential feature of a “routing message.” 

In contrast to the TTL field, other fields in the routing message are explicitly used for 

routing. For example, the section of the specification entitled “Subscriber to Subscriber Calls 

Between Different Nodes,” in which the example in Fig. 16 is discussed, explains the processing of 

the callee identifier in the routing message to route the call over a private network.19 There is no 

discussion in this section of computing the TTL—the call is free.20 In contrast, in the specification 

section entitled “Subscriber to Non-Subscriber Calls,” in which the example of Fig. 25 is discussed, 

routing paths in a routing message to route the call over a public network are time-limited according 

to each path’s cost.21 Regardless of the type of routing message used, the specification explains that 

the callee user name field and the route field are used to route a message, not the TTL field: 

Referring back to FIG. 1, the routing message whether of the type shown in FIG. 16, 

25 or 32, is received at the call controller 14 and the call controller interprets the 

receipt of the routing message as a request to establish a call. ... 

Where a routing message of the type shown in FIG. 32 is received by the call 

controller 14, the routing to gateway routine 122 shown in FIG. 4 may direct the 

processor 102 [sic] cause a message to be sent back through the internet 13 shown in 

FIG. 1 to the callee telephone 15, knowing the IP address of the callee telephone 15 

from the user name [in the callee user name field]. 

Alternatively, if the routing message is of the type shown in FIG. 16, which identifies 

a domain associated with another node in the system [in the route field], the call 

controller may send a SIP invite message along the high speed backbone 17 connected 

to the other node. The other node functions as explained above, in response to receipt 

17 Id. at Figs. 33A-B (700, 702, 730, 732, 752, 753), 28:63-66; see also id. at 29:60-30:1; 30:40-46. 

18 Id. at 27:25-39, Fig. 8C (642-646), Fig. 32. 

19 Id. at 21:10-23:49 (emphasis added). 

20 Id. at 21:25-34 (discloses TTL is set to an arbitrary “maximum” value, “99999, for example”, to 

effect a free call; however, the route is determined by the routing message including a “caller [sic: 

callee] identifier” and an “identifier of a node on the private network”; compare id. at 2:5-8, 3:5-8). 

21 Id. at 23:50-25:60. 

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of a SIP invite message.22

Thus, unlike these other fields, the TTL field should not be included in the construction of “routing 

message” because it has nothing to do with routing and is not required to route a communication. 

Selecting a route for a call is distinct from choosing whether or not to limit a call session duration. 

B. Considering The Intrinsic Record As A Whole Shows That A Routing Message 

Does Not Require A TTL Field. 

When viewed in the context of the entirety of the intrinsic record, it is apparent that the 

inventors did not intend the TTL field to be a required field of a “routing message” and that the TTL 

field is not required to route a message. The ’606 patent is directed to inventive methods of “routing 

and billing.”23 Indeed, VoIP-Pal has obtained multiple patents distinctly focused on either routing

or billing, based upon the same specification as the ’606 patent, as shown in the following table: 

’606 Patent Family Member Title 

8,542,815 Producing routing messages for voice over IP communications 

8,774,378 Allocating charges for communications services 

9,137,385 Determining a time to permit a communications session to be 

conducted

9,179,005 Producing routing messages for voice over IP communications 

9,537,762 Producing routing messages for voice over IP communications 

9,813,330 Producing routing messages for voice over IP communications 

9,826,002 Producing routing messages for voice over IP communications 

9,935,872 Producing routing messages for voice over IP communications 

9,948,549 Producing routing messages for voice over IP communications 

9,998,363 Allocating charges for communications services 

10,218,606 Producing routing messages for voice over IP communications 

22 Id. at 27:40-59. 

23 Id. at 1:21-24. 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 11 of 16
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11,171,864 Determining a time to permit a communications session to be 

conducted

Notably, while all the patents in the ’606 patent family share the same specification, they do not 

share the same title. The ’606 patent is titled “Producing routing messages for voice over IP 

communications.” But other family members are titled “Allocating charges for communications 

services” or “Determining a time to permit a communications session to be conducted.” The 

different titles reflect the different inventions disclosed in the specification. Indeed, the claims of 

U.S. Patent No. 11,171,864 are specifically directed to producing a routing message that includes a 

TTL field for holding a maximum allowable time for a communications session to be conducted. 

These distinct inventions are evident early in the intrinsic record. The PCT parent application of 

the ’606 patent, before entering national stage as App. No. 12/513,147, was determined by PCT 

authorities to lack unity of invention because its “Group I” routing claims (operating a call routing 

controller to produce a routing message) were considered distinct from its “Group III” billing claims 

(determining a time to permit a communications session to be conducted).24

 More importantly, the components of the routing message are claimed three different ways 

in the patent family: (1) a routing message with no mention of TTL in any claim (e.g., in the ’606 

patent); (2) a routing message recited in an independent claim and a TTL value recited in a 

dependent claim (e.g., in the ’005 patent); and (3) a routing message and a TTL value in the same 

independent claim (e.g., in the ’864 patent). The following table illustrates these three scenarios: 

(1) U.S. Patent No. 10,218,606 

(claim 1) 

(2) U.S. Patent No. 9,179,005 

(claims 1 and 18) 

(3) U.S. Patent No. 11,171,864 

(claim 1) 

1. A method for routing communications in a 

packet switched communication system 

between a first participant device associated 

with a first participant and a second participant 

device associated with a second participant, the 

1. A process for producing a routing message 

for routing communications between a caller 

and a callee in a communication system, the 

process comprising: 

... 

1. In a telecommunications network, a 

computer-implemented method of determining 

a time to permit a communication session by 

first and second participants to be conducted, 

the method comprising: 

24 See Ex. 3, Written Opinion, PCT/CA2007/001956, Box IV (in file history of U.S. Patent No. 

8,542,815). 

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first and second participant devices being 

associated with first and second network 

elements of the communication system, 

respectively, the method comprising: 

... 

when the second network element is 

determined to be the same as the first network 

element, producing a routing message 

identifying a first network address associated 

with the first network element, using at least 

one processor; and 

when the second network element is 

determined not to be the same as the first 

network element, producing a routing message 

identifying a second network address 

associated with the second network element, 

using at least one processor; 

wherein the packet switched communication 

system attempts to establish the 

communication from the first participant 

device to the second participant device based 

on at least one network address identified in the 

routing message.25

when at least one of said calling attributes and 

at least a portion of a callee identifier 

associated with the callee meet private network 

classification criteria, producing a private 

network routing message for receipt by a call 

controller, said private network routing 

message identifying an address, on the private 

network, associated with the callee; and 

when at least one of said calling attributes and 

at least a portion of said callee identifier meet 

a public network classification criterion, 

producing a public network routing message 

for receipt by the call controller, said public 

network routing message identifying a 

gateway to the public network.26

... 

producing a routing message that includes the 

maximum time to permit the communication 

session to be conducted, and sending the 

routing message to a controller to establish the 

communication session between a first 

communication device associated with the first 

participant and a second communication 

device associated with the second participant 

for a duration of up to the maximum time 

included in the routing message; and 

... .27

18. The process of claim 17, further 

comprising causing said public network 

routing message to include a time value and 

a timeout value.28

Under the Court’s claim construction, however, all of these claims require the routing message to 

have a TTL field despite the fact that the ’864 patent’s claims and some ’005 patent claims already 

require as much. Applying the Court’s claim construction renders claim language directed to TTL 

fields superfluous, which is improper.29 Applying the Court’s claim construction to the ’005 patent 

violates the claim differentiation doctrine because independent claim 1 is not limited to a routing 

message including a time value.30 Moreover, the Federal Circuit has held that claim differentiation 

25 Dkt. No. 1-1 at claim 1. 

26 Ex. 4 at claim 1. 

27 Id. at claim 18. 

28 Ex. 5 at claim 1. 

29 See Interdigital Commuc’ns., Inc. v. ZTE Corp., 1:13-cv-00009-RG, 2014 U.S. Dist. LEXIS 

113316, at *6 (D. Del. Aug. 8, 2014); Asetek Holdings, Inc. v. Coolit Sys., No. C-12-4498 EMC, 

2013 U.S. Dist. LEXIS 170488, at *13 (N.D. Cal. Dec. 3, 2013); Ferring B.V. v. Watson Labs., Inc., 

3:11-cv-00481-RCJ-VPC, 2013 U.S. Dist. LEXIS 17536, at *22 (D. Nev. Feb. 6, 2013); Atser 

Research Techs., Inc. v. Raba-Kistner Consultants, Inc., No. SA-07-CA-93-H, 2009 U.S. Dist. 

LEXIS 25294, at *31-32 (W.D. Tex. Mar. 2, 2009). 

30 See Curtiss-Wright Flow Control Corp. v. Velan Inc., 438 F.3d 1374, 1380 (Fed. Cir. 2006) (stating 

the claim differentiation “refers to the presumption that an independent claim should not be construed 

as requiring a limitation added by a dependent claim.”). 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 13 of 16
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can apply across patents in the same family.31 The claims for the ’005 and ’864 patents show that 

the inventors knew how to claim a routing message that holds a time value for how long a 

communication session can be conducted. Thus, the fact that the claims of the ’606 patent do not 

recite a TTL value and other patents in the same patent family do evidences an intent by the 

inventors not to limit the routing message claimed in the ’606 patent to having a TTL field. The 

PCT routing claims, too, recited a time-dependent element only in the dependent claims.32

Finally, it bears emphasis that “[e]ven when the specification describes only a single 

embodiment, the claims of the patent will not be read restrictively unless the patentee has 

demonstrated a clear intention to limit the claim scope using words or expressions of manifest 

exclusion or restriction.”33 Although VoIP-Pal disputes that the specification discloses a single 

embodiment of a routing message, even if it did, Amazon presented no evidence demonstrating a clear 

intent on the part of the inventors to limit a routing message to having a TTL field using words or 

expressions of manifest exclusion or restriction. Indeed, the above comparison of claims across 

different patents in the same patent family as the ’606 patent shows otherwise. Amazon invites the 

Court to commit clear error by incorporating a billing-related feature of an exemplary embodiment—

a TTL field—into the term “routing message” that has nothing to do with routing and consequently 

implies that an entire family of patents directed to different features should be limited to a single 

embodiment of a routing message. Such a result is manifestly unjust and should be corrected. 

V. CONCLUSION 

In conclusion, VoIP-Pal respectfully requests that the Court reconsider its final 

31 See Clare v. Chrysler Grp., LLC, 819 F.3d 1323, 1330 (Fed. Cir. 2016) (applying the doctrine of 

claim differentiation across different patents); see also Serverside Grp. Ltd. v. Tactical 8 Techs., 

L.L.C., 927 F. Supp. 2d 623, 686 (N.D. Iowa 2013) (“The doctrine of claim differentiation supports 

the conclusion that independent claims of related patents that use different claim terms must have 

different scope.”). 

32 Ex. 6 at claims 27 and 57. 

33 See Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367, 1372 (Fed. Cir. 2014) (quoting LiebelFlarsheim Co. v. Medrad, Inc., 358 F.3d 898, 906 (Fed. Cir. 2004)) (alteration in original) (internal 

quotation marks omitted). 

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construction of the term “routing message” and construe the term to mean “a message that includes 

a callee user name field and a route field.” Nothing more is needed for routing a communication. 

Dated: March 10, 2023 

/s/ Lewis E. Hudnell, III 

HUDNELL LAW GROUP P.C. 

Lewis E. Hudnell, III 

lewis@hudnelllaw.com 

Nicolas S. Gikkas 

nick@hudnelllaw.com

800 W. El Camino Real Suite 180 

Mountain View, California 94040 

T: 650.564.3698 

F: 347.772.3034 

ATTORNEYS FOR PLAINTIFF 

VOIP-PAL.COM, INC. 

Case 6:20-cv-00272-ADA Document 89 Filed 03/10/23 Page 15 of 16
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CERTIFICATE OF SERVICE 

I certify that on March 10, 2023, I electronically filed the foregoing Plaintiff VoIP-Pal.com’s Opposed 

Motion for Partial Reconsideration of Claim Construction Order with the Clerk of Court using the CM/ECF 

system, which will send notification of such filing to all counsel of record. 

/s/ Lewis E. Hudnell, III 

Lewis E. Hudnell, III 

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