Free Redacted Document - District Court of Delaware - Delaware


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Case 1:07-cv-00442-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE _________________________________________ X : : Plaintiff, : v. : : QWEST COMMUNICATIONS CORP., et al., : : Defendants. : __________________________________________X RATES TECHNOLOGY INC.,

Civil Action No. 07-442 JJF PUBLIC VERSION

EXHIBITS A AND B TO DECLARATION OF ROBERT L. EPSTEIN Mary B. Matterer (#2696) MORRIS JAMES LLP 500 Delaware Avenue, Suite 1500 Wilmington, Delaware 19801 302.888.6800 [email protected] OF COUNSEL: Robert L. Epstein Epstein Drangel Bazerman & James, LLP 60 East 42nd Street, Suite 820 New York, NY 10165 212.292.5390 [email protected] Attorneys for Plaintiff RATES TECHNOLOGY INC. Original Dated: October 5, 2007 Redacted Version: October 15, 2007

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EXHIBIT A

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QUEST ONEFLEX SYSTEMS CLAIM CHART A device for routing telephone calls along a least cost route originating from a first telephone to a second telephone having an associated telephone number The system is a "device" that routes telephone calls along LCR from a calling phone to a called phone with a telephone number via a "network". The "network" is the PSTN. via a network having a plurality of alternate communication switch paths corresponding to different carriers which can be chosen to route the call The network has different communication switch paths (including carriers) to the called phone, when the called phone is outside the system.

and normally providing a current to said first telephone when said first telephone is in use, comprising

The "device" includes an ATA. The ATA normally provides a current to the calling phone when the calling telephone is in use.

a housing forming an enclosure and comprising first jack means for connection to said first telephone and second jack means for connection to said network

The ATA has an enclosure and includes a first jack for connection to the calling phone. The "device" also includes gateways (GWs). Each GW has a second jack for connection to the network.

switch means operatively connected to said first jack means for disconnecting said first telephone from said network,

The "switch means" includes the ATA, which is connected to the first jack, and also includes relays which control the PSTN GWs to disconnect the calling phone from the network when the called phone is in the system (is IP capable) and to connect the calling phone to the network when the called phone is outside of the system.

means operatively connected to said switch means for generating a current through said switch means to the first telephone, corresponding to a current provided by said network,

The ATA (part of the "switch means") is connected to a 120v wall outlet which is the "means" for generating current through the switch means (ATA) to the calling phone. That

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current corresponds to the current provided by the network. database means for storing billing rate parameters for determining a least cost communication path for call corresponding to said telephone number, The system includes a call processing center which has a central database that stores (a) the IP addresses of all system phones and (b) phone-route tables which map area codes and country codes for selecting routes to the PSTN COs local to the called phone, as well as ordered "back-up" routes in case the selected route is unavailable (has insufficient available capacity) or is inoperative. The central processing center includes means (circuits) connected to the ATA (part of the switch means) for detecting and storing the called number, addressing the central database which identifies possible routes (switch paths) through the network to the (non-system) called phone and the cost of each route.

means operatively connected to said switch means for detecting and storing said telephone number originating from the first telephone means for addressing said database means for identifying a plurality of communication switch paths to said second telephone and the cost rate of each path,

means for comparing the cost rate of each path so as to determine a least cost route, and

The central processing center compares the cost rate of each route and selects a route based on cost. The routes in the phone-route table are based on rates and availability.

means operatively connected to said switch means and said second jack means for generating a number sequence corresponding to a desired carrier so that said call is routed through said second jack means to the selected communication path and carrier to establish a switched connection between said first telephone and said second telephone phone.

The PSTN GWs, which are connected to the relays of the "switch means" and to the second jack, generate a number sequence corresponding to the selected route to the PSTN CO local to the calling telephone such that the call is routed through the second jack via the selected route to establish a switched communication between the calling phone and the called phone.

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EXHIBIT B

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