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2:26-cv-00681 Documenti_ Filed 08/11/26 Page1of 89 PagelID#: 1\n\nIN THE UNITED STATES DISTRICT COURT\nFOR THE EASTERN DISTRICT OF TEXAS\nMARSHALL DIVISION\n\nSandpiper CDN, LLC,\nPlaintiff,\n\nVv.\nCivil Case No.\n\nMicrosoft Corporation,\n\nJURY TRIAL DEMANDED\nDefendant.\n\nCOMPLAINT FOR PATENT INFRINGEMENT\n\nPlaintiff Sandpiper CDN, LLC (\u201cSandpiper CDN,\u201d \u201cSandpiper,\u201d or \u201cPlaintiff\u2019) hereby\nfiles this Complaint for patent infringement against Defendant Microsoft Corporation (\u201cMicrosoft\u201d\nor \u201cDefendant\u2019), and alleges as follows:\n\nINTRODUCTION\n\n1. This case involves Microsoft\u2019s willful infringement of Sandpiper CDN\u2019s patents.\nSandpiper\u2019s patents, which cover foundational aspects of content delivery network (\u201cCDN\u201d) and\nother networking technologies, enable Microsoft\u2019s $100 billion-per-year Azure business\u2019 and other\nwildly successful Microsoft business units.\n\n2. In June 2025, Sandpiper CDN sued Microsoft in the Eastern District of Texas\nalleging that Microsoft willfully infringes six patents core to CDN and microservices technologies\n\nthrough operation of Microsoft\u2019s own CDNs for itself and through the paid Azure CDN service it\n\n' See \u201cPress Release & Webcast; Earnings Release FY26 Q4\u201d July 29, 2026\nhttps://www.microsoft.com/en-us/investor/earnings/fy-2026-q4/press-release-webcast (\u201cThis year,\n\nAzure revenue surpassed $100 billion for the first time. .. .\u201d).\n1\n\n\fCase 2:26-cv-00681 Documenti_ Filed 08/11/26 Page 2 of 89 PageID#: 2\n\nsells to others. Sandpiper CDN, LLC v. Microsoft, No. 25-664-JRG-RSP, Dkt. 1 (E.D. Tex. June\n24, 2025) (hereinafter, \u201cMicrosoft [\u2019). In Microsoft I, Sandpiper CDN explained how, in 2006,\nMicrosoft offered tens of millions of dollars for a deal in which Microsoft would have acquired all\nof the patents now owned by Sandpiper CDN, but when the bidding reached $135 million, Microsoft\ndecided to pay nothing and use the patented technology anyway. See Microsoft I, Dkt. 41, 9] 47-53.\n\n3. Microsoft\u2019s willful infringement extends to the patents in this case by other, distinct\nAzure technologies. For example, while Microsoft I did not include patents from the Intelligent\nTraffic Manager (\u201cITM\u201d) family of patents, this case does, and these ITM patents were of particular\ninterest to Microsoft even after Microsoft\u2019s failed bid in 2006 to acquire the entire patent portfolio\nnow held by Sandpiper CDN. Indeed, Level 3, after paying $135 million for these patents, operated\nits own ITM service, explaining that \u201cIntelligent Traffic Manager (ITM) is a DNS-based, web\nadministered, global load balancing service,\u201d and that Level 3 practices ITM patents in providing\nits services.\u201d A decade later, Microsoft decided to copy Sandpiper\u2019s ITM product and, by at least\n2017, released its own \u201cIntelligent Traffic Manager,\u201d explaining \u201cAzure Traffic Manager is a global\n\nload balancer\u201d that \u201cuses the Domain Name System (DNS) protocol.\u201d? And to this day, Microsoft\n\n? See Intelligent Traffic Manager (ITM) Global Load Balancing Service\nhttps://assets.lumen.com/is/content/Lumen/Service-Guide-ITM-Services-\n\n20140423 pdf? Creativeid=fof3 44ff-d8df-4717-8323-8a2039ac5 lfa; see also Level 3, \u201cLegal,\u201d\nhttps://web.archive.org/web/20141012113846/http://www.level3.com/en/legal/ (\u201cCertain Level 3\ncontent delivery services are provisioned using systems, methods, and/or functionality covered by\none or more of the following U.S. Patents: ... 7,822,871\u201d).\n\n> See \u201cMicrosoft CEO Mentions Containers and Serverless Computing in Keynote,\u201d Sept. 25, 2017,\nhttps://www.sdxcentral.com/news/microsoft-ceo-mentions-containers-and-serverless-computing-in-\nkeynote/ (\u201cAs for serverless computing, Microsoft last month added an intelligent traffic manager to\nits plans with the unveiling of its Azure Event Grid routing service.\u201d); \u201cArchitecture best practices\nfor Azure Traffic Manager,\u201d https://learn.microsoft.com/en-us/azure/well-architected/service-\nguides/azure-traffic-manager; \u201cAzure Front Door: Implementing lessons learned following October\noutages,\u201d https://techcommunity.microsoft.com/blog/azurenetworkingblog/azure-front-door-\nimplementing-lessons-learned-following-october-outages/4479416 (\u201cWe have a highly distributed\nresilient architecture, which protects against failures at the server, rack, site and even at the regional\n\nlevel. This resiliency is achieved by the use of our intelligent traffic management layer ....\u201d).\n2\n\n\fCase 2:26-cv-00681 Documenti_ Filed 08/11/26 Page 3 of 89 PageID#: 3\n\nrefers to its Azure Traffic Manager interchangeably as \u201cIntelligent Traffic Management\u201d and\n\ndepicts it architecturally in public-facing documents as its own architecture:*\n\na\n\nIntelligent Traffic Management\n| \u2014| Sprayed to Local Unicast VIP(s)\n\nPrimary ring with e.@ Traffic Spray across edge sites\n0 traffic shedding to aca Q if secondary ring protection is\nnearby edge sites & not enough\norigins\nCapacity regression scenario, traffic fallback to\n\u00ae Secondary ring\n4. As explained below, Microsoft also learned of the ITM patent family and its\n\napplication to CDN services provided by Microsoft at least through public filings in Microsoft I.\n\n5. In addition, there are multiple other infringing Microsoft technologies distinct from\nthose accused of infringement in Microsoft I, as described below. Despite all of the above, over a\nyear after the filing of Microsoft I, Microsoft still has not ceased infringing or paid for a license to\nany of the patents Sandpiper CDN owns and that Microsoft tried, and failed, to acquire rights to\n\nbefore Microsoft began its infringement. Sandpiper CDN thus files this second lawsuit to hold\n\n* See \u201cAzure Front Door: Implementing lessons learned following October outages\u201d Dec. 18, 2025\nhttps://techcommunity.microsoft.com/blog/azurenetworkingblog/azure-front-door-implementing-\n\nlessons-learned-following-october-outages/4479416.\n3\n\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 4of 89 PagelID#: 4\n\nMicrosoft accountable for its continuing and willful infringement of different Sandpiper CDN\npatents covering distinct but vitally important Microsoft technologies.\n\nNATURE OF THE ACTION\n\n6. This is a civil action against Microsoft for patent infringement arising under the\npatent statutes of the United States, 35 U.S.C. \u00a7 271, et seq., for the infringement of United States\nPatent Nos. 9,021,112, 7,822,871, 7,860,964, 10,116,738, 8,645,517, 9,660,876, 9,647,899, and\n8,156,066 (collectively, \u201cthe Asserted Patents\u201d). A true and correct copy of each Asserted Patent is\nattached to this Complaint as Exhibits A-H. Each of the Asserted Patents is owned by Plaintiff\nSandpiper CDN, and Plaintiff and/or its predecessors-in-interest have satisfied all statutory\nobligations required to collect pre- and post-filing damages for the full period allowed by law for\ninfringement of the Asserted Patents, including compliance with 35 U.S.C. \u00a7 287.\n\nPARTIES\n\n7. Plaintiff Sandpiper CDN is a Delaware limited liability company with its principal\nplace of business in Wilmington, Delaware.\n\n8. Defendant Microsoft Corporation is a Delaware corporation with a principal place of\nbusiness at One Microsoft Way, Redmond, WA 98052. Upon information and belief, Microsoft has\nbeen registered to do business in Texas since March 13, 1995, and may be served with process via its\nregistered agent: Corporation Service Company, d/b/a CSC -\u2014 Lawyers Incorporating Service\nCompany, 211 E. 7th Street, Suite 620, Austin, TX 78701.\n\nJURISDICTION AND VENUE\n\n9. This action arises under the patent statutes of the United States, Title 35 of the United\nStates Code. This Court has subject matter jurisdiction over this action under 28 U.S.C. \u00a7\u00a7 1331 and\n1338(a).\n\n10. This Court has personal jurisdiction over Microsoft in this action because Microsoft\n\n4\n\fCase 2:26-cv-00681 Documenti_ Filed 08/11/26 Page 5 of 89 PageID#: 5\n\nconducts business in and has committed acts of patent infringement within this District and the State\nof Texas and has established minimum contacts with the forum such that the exercise of jurisdiction\nover Microsoft would not offend traditional notions of fair play and substantial justice.\n\n11. Microsoft directly and/or through subsidiaries and intermediaries has engaged in\ncontinuous, systematic, and substantial activities within this State, including substantial marketing,\noffering, and sales of products and services. These products and services include Microsoft products\nand services comprising the accused Content Delivery Network (\u201cCDN\u201d) functionalities.\n\n12. Venue is proper in this District pursuant to 28 U.S.C. \u00a7\u00a7 1391(b) and (c) and/or\n1400(b). Defendant maintains regular and established places of business in the Eastern District of\nTexas and the State of Texas, regularly transacts business in the Eastern District of Texas, and has\ncommitted and continues to commit acts of patent infringement in the Eastern District of Texas.\n\n13. Personal jurisdiction over Defendant Microsoft is proper in this District because,\namong other things, Microsoft has seven corporate offices in the State of Texas and employs hundreds\nof people therein. Microsoft represents that one of those offices is in Frisco, Texas, and thus within\nthis District.\u00b0\n\n14. Additionally, Microsoft operates Microsoft Windows Stores within at least ten Best\nBuy retail locations throughout the State of Texas, including in this District. According to Microsoft,\nthese Windows Stores are a \u201ccomprehensive store-within-a-store,\u2019 with dedicated \u201cMicrosoft\n\n26\n\nspecialists\u201d serving Best Buy customers within this \u201cunique environment.\u201d\u00b0 These locations are\n\noperated by Microsoft within Best Buy stores and are regular and established places of business for\n\n> Microsoft, Microsoft U.S. Office Locations (available at https://www.microsoft.com/en-\n\nus/about/officelocator/all-offices?msockid=325270f10c6b61543e3b64490de760b4).\n\u00b0 Microsoft, Microsoft and Best Buy announce the Windows Store only at Best Buy, (available at\nhttps://news.microsoft.com/source/2013/06/13/microsoft-and-best-buy-announce-the-windows-\nstore-only-at-best-buy-2/).\n\n5\n\fCase 2:26-cv-00681 Documenti1_ Filed 08/11/26 Page 6 of 89 PageID#: 6\n\nMicrosoft. Indeed, as Microsoft\u2019s vice president of computing for Best Buy put it, \u201cThe Windows\nStore creates the kind of retail destination we all want to shop in, combining great selection, the latest\ntechnology, the best service and the lowest prices.\u201d\u2019 Microsoft maintains its distinct business identity\nat these locations, renting the space from Best Buy and holding out its Windows Stores as discrete\nretail locations.\u00ae\n\n15. Further, Microsoft owns and maintains millions of dollars of real property in Collin\nCounty, located within this District.?\n\n16. Microsoft similarly owns and maintains tens of thousands of dollars in business\npersonal property registered at several Best Buy locations in Denton County, also within this\nDistrict.!\u00b0\n\n17. Microsoft also holds approximately $2 million worth of business personal property,\nincluding data servers, at Aligned Data Center, located at 2800 Summit Avenue, Plano, TX 75074,\nwhich is within this District.\n\n18. Microsoft\u2019s website confirms that its \u201cAzure Content Delivery Network\u201d has a \u201cpoint\nof presence (POP) location[]\u201d in \u201cPlano, TX, USA.\u201d\"!\n\n19. Upon information and belief, Microsoft\u2019s Azure POP location operates out of the\n\nAligned Data Center located in this District.\n\n20. Compounding its significant connections to this District, in 2023 Microsoft\n\n1 Id.\n\n8\u2019 Microsoft, Talking Retail: The New Windows Store Only at Best Buy (June 13, 2013), (available at\nhttps://blogs.windows.com/windowsexperience/2013/06/13/talking-retail-the-new-windows-store-\nonly-at-best-buy/).\n\n? See Collin Central Appraisal District, Property Search (available at https://esearch.collincad.org)\n(search results for \u201cMicrosoft\u2019\u201d).\n\n10 See Denton Central Appraisal District, Property Search (available at\nhttps://www.dentoncad.com/property-search) (search results for \u201cMicrosoft\u2019).\n\n'l Microsoft, \u201cAzure Content Delivery Network Coverage by Metro,\u201d Sept. 27, 2024 (available at\n\nhttps:/learn.microsoft.com/en-us/azure/cdn/cdn-pop-locations).\n6\n\fCase 2:26-cv-00681 Documenti1_ Filed 08/11/26 Page 7 of 89 PageID#: 7\n\nannounced a multi-billion-dollar deal with specialist cloud computing provider CoreWeave to use its\ndatacenters for some of Microsoft\u2019s Azure AI workloads.\u2019* This deal will include Microsoft\u2019s use of\nCoreWeave\u2019s $1.6 billion datacenter in Plano, Texas, located in this District.'\u2019 Microsoft is currently\nCoreWeave\u2019s biggest customer.'*\n\n21. Courts have repeatedly found jurisdiction over Microsoft to be proper in the Eastern\nDistrict of Texas, including in numerous patent disputes where Microsoft consented to jurisdiction\nfor or litigated in this District, including in Microsoft I.\u00b0\n\n22. Microsoft has targeted and continues to direct its business activities toward this\nDistrict. Given Microsoft\u2019s substantial business and property in this District and the State of Texas,\nand because of its ongoing infringing activities in this District, Microsoft is subject to this Court\u2019s\ngeneral and specific jurisdiction pursuant to due process and the Texas Long Arm statute.\n\n23. Venue is likewise proper in this District because of Microsoft\u2019s numerous physical\nplaces of business, employees, and property ownership in this District, and because Microsoft has\n\nrepeatedly consented to litigation in this District. Moreover, as described more fully below, on\n\n'2 See Sebastian Moss, Datacenter Dynamics, \u201cMicrosoft signs multi-billion dollar deal with GPU\ncloud provider CoreWeave to meet Al needs\u201d (available at\nhttps://www.datacenterdynamics.com/en/news/microsoft-signs-multi-billion-dollar-deal-with-gpu-\ncloud-provider-coreweave-to-meet-ai-needs/).\n\n'3 See Sebastian Moss, Datacenter Dynamics, \u201cCoreWeave plans $1.6bn AI cloud data center in\nPlano, Texas\u201d (available at https://www.datacenterdynamics.com/en/news/coreweave-plans- 1 6bn-ai-\ncloud-data-center-in-plano-texas/).\n\n4 See Reinhardt Krause, CoreWeave Stock Rockets to New High Amid New Data Center Leasing\n\nDeal, Investor\u2019 s Business Daily, (available at\nhttps://www.investors.com/news/technology/coreweave-stock-new-high-nvidia-stock-applied-\ndigital/).\n\n' See, e.g., Dialect, LLC v. Microsoft Corp., 2:24-cv-01067-JRG, Dkt. 13 at paras 12-16 (E.D. Tex.\nMay 19, 2025) (admitting for purposes of this case that Microsoft is subject to personal jurisdiction\nin EDTX); VPN Tech. Holdings, LLC vy. Microsoft Corp., 2:25-cv-00001-JRG-RSP, Dkt. 12 at paras\n5-7 (Feb. 24, 2025) (admitting personal jurisdiction and specific jurisdiction in EDTX for this case);\ni4i Ltd. P\u2019ship v. Microsoft Corp., 398 F. Supp. 3d 90 (E.D. Tex. 2019) (declining to contest personal\njurisdiction in patent infringement litigation); Biscotti Inc. v. Microsoft Corp., 302 F. Supp. 3d 797\n(E.D. Tex. 2018) (declining to contest personal jurisdiction in patent infringement litigation).\n\fCase 2:26-cv-00681 Documenti_ Filed 08/11/26 Page 8 of 89 PageID#: 8\n\ninformation and belief Microsoft commits acts of infringement in this District, including by\nperforming the methods of the Asserted Claims (or at least one or more steps of these method claims)\nof the Asserted Patents through its CDN POP(s) and/or data centers in this District and otherwise\ndelivering content to end users in this District through the accused CDN services.\n\n24. Venue is also proper and convenient in this District because Sandpiper\u2019s patent\nportfolio has been litigated in this District, including specific patents asserted in this case. In\nNovember 2024, Sandpiper sued Comcast in the Eastern District of Texas, asserting patents within\nthe same portfolio as those asserted in this case, including the \u2019876 patent asserted against Microsoft\nin this case. Sandpiper CDN, LLC vy. Comcast Cable Comm\u2019s, LLC, Case No. 2:24-cv-00886-JRG\n(E.D. Tex. Nov. 1, 2024) (hereinafter, \u201cComcast\u2019). Comcast filed a motion to transfer, which was\ndenied, and then filed for mandamus with the Federal Circuit seeking to set aside denial of transfer,\nwhich was also denied.'\u00b0 The case proceeded through claim construction, fact discovery, and expert\nreports, settling during expert discovery.!\u201d\n\nSANDPIPER NETWORKS REVOLUTIONIZES NETWORKING TECHNOLOGIES\nVITAL FOR CONTENT DELIVERY\n\n25. Today, content delivery networks (\u201cCDN\u201d) enable content providers to quickly\ndeliver online information to millions of consumers simultaneously. But this has not always been the\ncase.\n\n26. In the early 1990s, the Internet rapidly evolved from burgeoning technology to\nhousehold staple in the span of a few years. This mass adoption led to data congestion issues, as a\nquickly expanding user base sought simultaneous access to Internet content. The typical computer\n\nserver in the 1990s was only capable of handling a limited number of simultaneous connections before\n\n16 Td, Dkt. 67, 82; see also in re Comcast Cable Cominc\u2019ns, LLC, et al., 26-104 (Fed. Cir. Dec. 9, 2025) available at\nhttps://fedcircuitblog.com/wp-content/uploads/2025/11/26-104_Comecast_Order.pdf\nComcast, Dkt. 113, 134 (May 4, 2026).\n\n8\n\fCase 2:26-cv-00681 Documenti_ Filed 08/11/26 Page 9 of 89 PageID#: 9\n\nit became overloaded, leading to congested network segments, overburdened servers, and sluggish\nload times. The problem was even more pronounced for Internet users who lived far from the physical\nservers hosting their content, who experienced more lag and higher latency due to the geographic\ndistance their signals traveled through physical internet cables.\n\n27. Andrew Swart and David Farber were among the first individuals to develop services\nthat allowed content providers to avoid the common congestion and performance issues that plagued\nInternet transmission in the mid-1990s. One of their solutions was to deploy CDN servers around the\nworld that would more evenly distribute where data was processed. Mr. Swart and Mr. Farber\ndeveloped infrastructure that replicated content requested from customers\u2019 origin servers to\nappropriate CDN servers and transparently rendezvoused the request to the CDN server best able to\ndeliver that content. Their invention helped transform the early Internet, making it more efficient,\nresponsive, and adaptable to users. Unsurprisingly, this service and its architecture were quickly\nimitated by many others in the industry, including Microsoft.\n\n28. The CDN technology developed by Mr. Swart and Mr. Farber connected consumers\nto an edge server with available bandwidth that was geographically closer to them. This revolutionary\napproach provided numerous technical benefits. For example, distributing content across a network\nof servers alleviated data congestion issues, while connecting consumers to nearby edge servers\u2014\nrather than distant origin servers\u2014reduced latency. Mr. Swart and Mr. Farber developed and built\nsystems and methods for propagating data from origin servers to edge servers (in one example, a\nprocess known as \u201ccaching\u201d) for storage and delivery to clients based on network demand/traffic.\n\n29. In 1996, Mr. Swart and Mr. Farber founded Sandpiper Networks Inc. (\u201cSandpiper\nNetworks\u201d) to further develop and commercialize their novel CDN concepts. By at least May 24,\n1996, the Sandpiper Networks team developed infrastructure for delivering streaming resources, such\n\nas audio and video, using Sandpiper\u2019s CDN.\n\fCase 2:26-cv-00681 Document1i Filed 08/11/26 Page 10 of 89 PagelD#: 10\n\n30. Sandpiper Networks labored not only to build and implement its CDN, but also to\nprotect its groundbreaking innovation through patent protection. Recognizing that its inventions could\nrevolutionize content delivery worldwide, Sandpiper Networks filed numerous patent applications\ndirected to its foundational CDN technology.\n\n31. From at least May 1998 and through 1999, Sandpiper Networks partnered directly\nwith content providers to cache and deliver their content to end consumers through their CDN.\nSandpiper Networks\u2019 first paying customer, the L.A. Times, paid Sandpiper Networks to host the report\nof Independent Counsel Ken Starr on his investigation of President Bill Clinton (\u201cthe Starr Report\u2019)\nbeginning on September 11, 1998.\n\n32. Sandpiper Networks continued gaining widespread notoriety and won numerous\nawards for its CDN products and services during this time. !\u00ae\n\n33. In December 1999, Sandpiper merged with Digital Island, Inc. (\u201cDigital Island\u201d) in\na deal valued at $1.1B (approximately $2.1B today, adjusting for inflation) with the aim of creating\na global computer network that would facilitate consumer e-commerce transactions.!\u201d Digital Island\nthen filed additional patent applications directed to and complementary to CDN technology.\n\n34. Following a series of acquisitions, on or about 2004, the assets of Digital Island and\n\nthe Sandpiper Networks\u2019 patents were purchased by the data center company Savvis Inc. (\u201cSavvis\u201d).\n\n'8 See Nick Wingfield, Zhe Wall Street Journal, \u201cSandpiper Networks\u2019 Footprint Takes Aim at\nInternet Traffic\u201d (June 17, 1999),\nhttps://www.wsj.com/articles/SB92957 1998724587925? st=DAy23s&reflink=desktopwebshare_per\nmalink; Karen Kaplan, Los Angeles Times, \u201cSandpiper Networks\u2019 Footprint Wins Award\u201d (May 31,\n1999), https://www.latimes.com/archives/la-xpm-1999-may-3 1-fi-42763-story.html; CBR _ Staff\nWriter, Zech Monitor, \u201cSandpiper Adds RealSystem G2 to its Content Delivery Network\u201d (Aug. 4,\n1999),\nhttps://www.techmonitor.ai/technology/sandpiper_adds realsystem_g2 to its content_delivery_net\nwork); Barbara Murphy, Los Angeles Times, \u201cSandpiper Networks Given Investor\u2019s Choice Award\u201d\n(Oct. 5, 1999) https://www.latimes.com/archives/la-xpm-1999-oct-05-me-18779-story.html.\n'? Karen Kaplan, L.A. Times, \u201cSandpiper Networks to Merge with Digital Island in $1.1-Billion Deal\u201d\n(Oct. 9, 1999) https://www.latimes.com/archives/la-xpm-1999-oct-26-f1-26295-story html.\n\n10\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page11of 89 PagelD#: 11\n\n35. In January 2007, Savvis\u2019 CDN service assets, including the CDNs and patents of\nDigital Island and Sandpiper Networks, were acquired by Level 3 Communications (\u201cLevel 3\u201d).\n\n36. Following the January 2007 acquisition of Sandpiper\u2019s CDN and patents, Level 3\ncontinued innovating upon the technologies described in the Sandpiper Networks and Digital Island\npatents. Level 3 patented these innovations and eventually became one of the foremost CDN operators\nin the U.S.\n\n37. Level 3 was acquired by CenturyLink on or about November 2017, and the combined\ncompany rebranded as Lumen Technologies, or simply \u201cLumen,\u201d in September 2020.2 Lumen is\nheadquartered in Monroe, Louisiana, which is approximately a two-hour drive from Marshall, Texas.\n\n38. Sandpiper CDN, a successor to Sandpiper Networks, now holds all rights and title to\na portfolio of more than 400 patents resulting from the many years of research and development,\nhundreds of millions of dollars in capital investment, and ingenuity of numerous engineers employed\nby Sandpiper CDN and its predecessors. Like Sandpiper Networks, Sandpiper CDN was co-founded\nand is co-owned by Mr. Swart who, in addition to licensing its foundational patent portfolio, continues\nto seek commercialization of the Footprint CDN software as well.?!\n\nMICROSOFT\u2019S INFRINGEMENT OF THE ASSERTED PATENTS\n\n39. In the early-to-mid 2000s, as demand for CDNs continued its precipitous rise,\nnumerous other companies entered the CDN market to take advantage of the increased demand. These\ncompanies commercialized their own CDNs by incorporating the foundational CDN technology\npioneered and patented by Sandpiper Networks.\n\n40. The misappropriation of Sandpiper Networks\u2019 patents capitalized on, and\n\n20 See Lumen, \u201cLevel 3 Financing completes sale of Sustainability-Linked Senior Notes,\u201d (Jan. 13,\n2021), https:/Ar.lumen.com/news/news-details/202 1/Level-3-Financing-completes-sale-of-\nSustainability-Linked-Senior-Notes/default.aspx.\n\n71 See generally, https://sandpiper-cdn.com.\n1]\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 12 of 89 PagelD#: 12\n\nundermined, the significant financial investment and years of research into CDN development and\nimplementation undertaken by Sandpiper Networks and its successors.\n\nAl. Microsoft is one such company. Beginning in the mid-2000s and throughout the\n2010s, as widely used Microsoft products such as the Office suite, the cloud computing platform\nAzure, and XBOX gaming systems expanded their online operations, Microsoft started relying\nheavily on third-party CDNs to efficiently deliver its content to consumers.\n\n42. In 2007, for example, 95% of all Microsoft\u2019s online content was delivered by third-\nparty CDNs. Level 3 provided Microsoft with CDN content delivery capabilities, including ITM\nservices, using the technology underlying its patents, including one or more of the Asserted Patents\nat this time.\n\n43. Microsoft\u2019s General Manager for the Edge Computing Network acknowledged this\nreliance on Level 3 and third-party CDNs for content delivery in his keynote address at the 2009\nContent Delivery Summit.\u201d\u201d By then, as that presentation highlighted, Microsoft was determined to\nmove its content delivery in-house. Microsoft projected that by 2010, it would drop its reliance on\nLevel 3 and other third-party CDNs to just 40% of content delivery.\n\n44. On or about February 2010, Microsoft\u2019s cloud computing platform Azure launched\nthe Azure CDN to its subscribers, using technology described and claimed by one or more of the\nAsserted Patents. At no point did Microsoft license this patented technology from Sandpiper CDN or\nits predecessors.\n\n45. From the launch of Azure CDN, and until on or about May 2018, the Azure CDN\n\ncontinued to offer CDN delivery options from third-party providers. This approach permitted users\n\n22 Jeff Cohen Keynote Address Slide Deck, Content Delivery Summit (May 11, 2009),\nhttps://conferences.infotoday.com/documents/83/CDNSummit09-Keynote-Microsoft.pdf.\n12\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page13 of 89 PagelD#: 13\n\nto choose third parties to provide content delivery through the Azure CDN network.\u201d\n\n46. Nevertheless, Microsoft continued to rely on third-party CDNs, including Level 3,\nthroughout the 2010s for most of its content delivery. For example, in 2014, as one analyst estimated,\nMicrosoft still required third-party CDNs for approximately 75% of its content delivery, including\nincreased reliance on Level 3 and the Asserted Patents.\u201d*\n\n47. On or about May 2018, Microsoft announced its own CDN, available as an individual\nprovider on the Azure network. This allowed users to select Microsoft among its third-party CDN\nprovider partners through its Azure CDN.\u201d\u00b0\n\n48. Microsoft\u2019s CDN network, however, infringed the Asserted Patents.\n\n49. Since 2018, Microsoft has greatly expanded its content delivery networks, including\nwith the launch of a public CDN and multiple tiers of Azure CDN services, as well as other Azure\nproducts and services, using technology claimed in the Asserted Patents. Moreover, Microsoft has\nnever licensed the Asserted Patents from either Sandpiper CDN or its predecessors.\n\nMICROSOFT LEARNS OF THE ASSERTED PATENTS\nAND WILLFULY INFRINGES THEM\n\n50. During at least part of Microsoft\u2019s infringement of the Asserted Patents, Microsoft\neither knew of the Asserted Patents, or was willfully blind to them, and disregarded a substantial risk\nof infringement, making Microsoft\u2019s infringement egregious and willful.\n\n51. Sandpiper Networks and its successors widely publicized the Asserted Patents, which\n\nbecame well known as fundamental patents in the CDN and related spaces.\n\n3 Microsoft Azure Blog, \u201cAnnouncing Microsoft\u2019s Own Content Delivery Network\u201d (May 7, 2018),\nhttps://azure.microsoft.com/en-us/blog/announcing-microsoft-s-own-cdn-\nnetwork/?msockid=325270f1 0c6b61543e3b64490de760b4.\n\n4 Dan Rayburn, \u201cMicrosoft Relying More on Third Party CSNs, Limelight Networks Getting More\nBusiness,\u201d Streaming Media Blog (Feb. 17, 2015),\nhttps://www.streamingmediablog.com/2015/02/microsoft-third-party-cdns. html.\n\n\u00b0 \u201cAnnouncing Microsoft\u2019s own Content Delivery Network,\u201d Microsoft Azure Blog (May 7, 2018),\n\nAnnouncing Microsoft's own Content Delivery Network | Microsoft Azure Blog.\n13\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 14 of 89 PagelD#: 14\n\n52. For example, on or about October 1999, when Sandpiper Networks announced its\nmerger with Digital Island, including merged ownership of the Sandpiper Networks\u2019 patents, shares\nof both companies soared. By the close of trade on the day of the announcement, Sandpiper Networks\nwas valued at over $1 billion, while Digital Island was valued at over $2 billion. Leo Spiegel, then\nCEO of Sandpiper Networks who became President of the combined company, estimated that given\nthe growing need for CDNs, the market opportunity for the merged companies could exceed $20\nbillion.?\u00b0\n\n53. In December 2006, Level 3 announced its acquisition of the Savvis CDN business,\nincluding the patents stemming from the inventions of Sandpiper Networks, for $135 million.?\u2019\nReports at the time said that there were multiple bidders for these assets.\u201d* Indeed, publicly filed\ndocuments describe Level 3 as \u201cthe winning bidder\u201d for these patents.\u201d\u201d The unredacted portions of\na redacted publicly filed document explains that Level 3 and Limelight both bid on these patents,\nalong with \u201cvarious third parties,\u201d noting \u201cthe substantial interest in the CDN patents shown by a\nnumber of companies\u201d and the existence of \u201cthird-party bids.\u201d\u00b0\u00b0 The unredacted portions of another\nsuch document notes the \u201ccompetition [Level 3] faced in making the purchase [of the patents],\u201d the\n\n\u201cbids and expressions of interest Limelight and other parties made on the entire Savvis CDN\n\n76 Tech Monitor, \u201cDigital Island Merges with Sandpiper Networks\u201d (Oct. 15\nhttps://www.techmonitor.ai/hardware/digital_island_merges_with_sandpiper_networks.\n\n27 LUMEN, \u201cSAVVIS Hones Strategic Focus with Sale of CDN Business Services to Level 3\nCommunications\u201d (Dec. 26, 2006), https://news.lumen.com/SA VVIS-Hones-Strategic-Focus-with-\nSale-of-CDN-Services-Business-to-Level-3-Communications.\n\n8 Gigaom, \u201cIs Savvis CDN Business For Sale?,\u201d aom/is-savvis-cdn-business-for-sale/ (noting\n\u201cIt]here have been a few bids from interested parties,\u201d that the \u201cbids ... are said to be over $100\nmillion\u201d and that \u201ca majority of its CDN business comes from Microsoft\u201d); see also Data Center\nKnowledge, \u201cReport. SAVVIS Shopping Its CDN _ Network,\u201d (Oct. 23, 2006),\nhttps://www.datacenterknowledge.com/networking/report-savvis-shopping-its-cdn-network).\n\n?\u00b0 Level 3 Communications, LLC v. Limelight Networks, Inc., 09-589, (hereinafter, \u201cLimelight\nCase\u201d), Dkt. 1 (D. Del. Dec. 17, 2007).\n\u00b0 Limelight Case, Dkt. 269, pp. 6-10.\n\n1999),\n\n2\n\n14\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page15of 89 PagelD#: 15\n\nbusiness,\u201d and that the \u201cSavvis C[DN] patents attracted many suitors when they were put up for\nsale.\u201d3! Another such document noted the various \u201cbids and expressions of interest\u201d on these assets,\nstating that \u201c[e]ach bidder had different goals, valuations, and levels of interest in the various\nassets.\u201d\u00b0?\n\n54. Further, in 2006 Mr. Andrew Swart, then employed at Savvis as a Vice President\nof Engineering, was involved with aspects of the due diligence discussions with various prospective\nbidders for the sale of Sandpiper assets discussed above. At that time, there were several competitive\nbids for the Sandpiper assets. Mr. Swart travelled to San Francisco to meet with several potential\nbuyers of the Sandpiper assets as part of those diligence discussions. In these presentations Mr.\nSwart gave to potential buyers, the Sandpiper patents were highlighted to the potential buyers.\nAround that time, Mr. Swart understood that Microsoft had made an offer to buy the Sandpiper\nassets. The Sandpiper assets, as offered for sale and eventually sold, included the Sandpiper patents.\nMr. Swart\u2019s recollection is that in the early stages of this process, bids were in the $20 million range.\nUltimately, the sale to Level 3 was for $135 million (over $223 million in today\u2019s dollars).\n\n55, At the time, Microsoft was by far the largest Savvis CDN customer. One publicly\nfiled document appears to show Savwvis\u2019s \u201cestimated monthly revenue\u201d from its CDN contract with\nMicrosoft as $1.1 million, with Savvis\u2019s other nine (anonymized) largest CDN customers totaling\n$84,100 in monthly revenue.*? As detailed throughout this Amended Complaint, Microsoft was also\n\nclearly evaluating its upcoming anticipated CDN use and exploring the possibility of building its own\n\n31 Limelight case, Dkt. 333, pp.2, 7-8.\n* Limelight Case, Dkt. 355, p. 5.\n33 Limelight Case, Dkt. 484-1, p. 6; see also id., p. 2 (\u201cAlso note that I separated the IP-related\ndiligence request - I understand the IP list is comprehensive\u201d and requesting \u201ca complete list of IP\nassets\u201d); see also Limelight Case, Dkt. 484-2, p. 4 (appearing to list Savvis\u2019s revenue from\nMicrosoft as over $22.5 million in 2004, over $14 million in 2005, and over $7.8 million in the first\ntwo quarters of 2006).\n\n15\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 16 of 89 PagelD#: 16\n\nCDN to insource much of this traffic. One October 2008 article reports that \u201cMicrosoft is building its\nown content delivery network (CDN), with Limelight providing software and engineering support.\u201d**\nAnother report from around that timeframe specifically listed Microsoft as \u201cinterested in acquiring a\nCDN.\u201d*\u00b0\n\n56. During this time, several applications to the Asserted Patents had been filed and\nmade public: (a) the ?112 patent (filed on March 18, 2008, published on Sept.25, 2008); (b) the \u2019871\npatent (filed on Sept. 30, 2002; published on Apr. 3, 2003); and (c) the \u2019964 patent (filed on Oct. 27,\n2007, published on Sept. 4, 2008). On information and belief, at least the combination of Microsoft\u2019s\ninterest in acquiring a CDN, Savvis\u2019s CDN business being for sale, Microsoft\u2019s bid on those assets\nthat included the Sandpiper patents as a highlighted asset, and Microsoft being Savvis\u2019s largest CDN\ncustomer, led Microsoft to gain actual knowledge of Sandpiper\u2019s issued patents and pending\napplications.\n\n57. Around the time of Level 3\u2019s acquisition, an executive from Level 3 explained that\nLevel 3 \u201cacquired the business primarily for its intellectual property and architecture.\u201d*\u00b0 Several other\n\npublications commented on the importance of the Sandpiper CDN intellectual property, which\n\nincludes several of the Asserted Patents and/or pending applications, to this sale.*\u2019 An executive from\n\n34 https://www.datacenterknowledge.com/hyperscalers/limelight-reworks-software-for-microsoft-\ncdn.\n\n3\u00b0 https://www.streamingmedia.com/Articles/ReadArticle.aspx? ArticleID=65394&pageNum=3.\n\n3 Rich Miller, \u201cLevel 3 Readies Launch of CDN Network,\u201d Data Center Knowledge (May 11, 2007),\nhttps://www.datacenterknowledge.com/networking/level-3-readies-launch-of-cdn-network.\n\n37\u201c See Gigaom, \u201cLevel3 Buys Savvis CDN Business,\u201d https://om.co/gigaom/level3-buys-savvis-\ncdn-business/ (noting how \u201call the intellectual property that comes with this buy\u201d could help Level 3\nbecome a top competitor in the CDN market); Rich Miller, \u201cLevel 3 Acquires Savvis CDN Network,\u201d\nData Center Knowledge (Dec. 26, 2006), https://www.datacenterknowledge.com/networking/level-\n3-acquires-savvis-cdn-network (\u201cThe deal includes network assets, customer contracts, and\nintellectual property used in Savvis\u2019 CDN business.\u201d); see also Denise Pappalardo, \u201cLevel 3\nCompletes Acquisition of Savvis\u2019 CDN _ Business,\u201d NetworkWorld (Jan. 23, 2007),\nhttps://www.networkworld.com/article/83 82 19/lan-wan-level-3-completes-acquisition-of-savvis-\ncdn-business.html (\u201cIn the cash deal Level 3 picked up network assets, customer contracts and\n\n16\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page17 of 89 PagelD#: 17\n\nMicrosoft, Microsoft\u2019s then-general manager of Global Foundation Services, also publicly\ncommented on this acquisition at the time, stating it might benefit Microsoft. Specifically, that\nMicrosoft executive stated: \u201cAs we grow our online services business, stability and control over our\nnetwork infrastructure becomes increasingly important to deliver great experiences for our customers,\npartners and advertisers. We look forward to a continued relationship with Level 3 as they embark\nupon this next phase of their network evolution.\u201d3*\n\n58. Just a few months later, in July 2007, Microsoft spent $200 million to end a co-\nlocation agreement with Savvis and become the direct lessee for two data centers. The same Microsoft\nexecutive, Microsoft\u2019s then-general manager of Global Foundation Services, publicly commented on\nthis business deal, stating: \u201cThe acquisition of these assets is an important part of our vision for a\nglobally scaled data center infrastructure that will keep pace with user demand for innovative online\nservices.\u201d\u00b0?\n\n59. Ultimately, Level 3 purchased the Savvis CDN business and Sandpiper patents, and\nMicrosoft became one of the largest customers of Level 3. On information and belief, Microsoft\nremained aware of the Sandpiper patents, including at least specifically the \u00b0112 patent, the \u00b0871\npatent, and the \u00b0964 patent, because of Microsoft\u2019s previous interest in acquiring a CDN, Microsoft\n\nhaving been Sawvis\u2019s largest customer, Microsoft\u2019s bid on the Savvis assets including the Sandpiper\n\npatents that were highlighted to potential buyers as part of that process, and Microsoft becoming one\n\n\u201cintellectual property.\u201d\u201d); Thomas, \u201cLevel 3 Completes Acquisition of SAVVIS Content Delivery\nNetwork,\u201d https://news.thomasnet.com/companystory/level-3-completes-acquisition-of-savvis-\ncontent-delivery-network-505868) (\u201cPursuant to the definitive agreement, dated December 23, 2006,\nLevel 3 has paid $132.5 million in cash to acquire certain assets, including network elements,\ncustomer contracts, and intellectual property used in SAVVIS's CDN business.\u201d).\n\n38 Brian Prince, Channel Insider, \u201cLevel 3 Communications to Buy SAVVIS CDN Division\u201d (Dec.\n27, 2006),  https://www.channelinsider.com/news-and-trends/level-3-communications-to-buy-\nsavvis-cdn-division/.\n\n3\u00b0 Rich Miller, \u201cMicrosoft Assumes Savvis Leases for $200M,\u201d Data Center Knowledge,\n\nhttps://www.datacenterknowledge.com/hyperscalers/microsoft-assumes-savvis-leases-for-200m.\n17\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 18 of 89 PagelD#: 18\n\nof Level 3\u2019s largest CDN customers, and Microsoft remained aware of Level 3\u2019s continued\nprosecution of new patents in the portfolio while Microsoft remained a customer, including the \u2019517\nPatent, the \u2019738 Patent, the \u00b0876 Patent, the \u00b0899 Patent, and the \u2019066 patent.\n\n60. Over the years, Microsoft has hired several individuals who previously worked at\none of Sandpiper CDN\u2019s predecessor companies at a time when that predecessor owned one or more\nof Sandpiper CDN\u2019s foundational CDN patents while operating a CDN. As explained above, these\npatents were widely understood to be central to the value of Sandpiper CDN and its predecessors,\nsuch that each of these employees had actual knowledge of those patents, including the Asserted\nPatents or at least the applications leading to them. For instance, one current Microsoft executive in\nthe St. Louis area was recently described on Microsoft\u2019s website (in a web page cited by Sandpiper\nin its Microsoft 1 Complaint that Microsoft has since, it appears, removed) as a \u201cDirector\u201d who helps\npartners \u201cscale their Azure business,\u201d and Microsoft touted him as \u201cbring[ing] over two decades of\nexperience in engineering leadership and cloud strategy, including 12 years at CenturyLink (formerly\nSavvis), where he served as Director of Engineering for Managed Services.\u201d*\u00b0 Microsoft, having\nacquired through these hirings the knowledge of those individuals, either knew of the Asserted Patents\nand the high likelihood that Microsoft\u2019s CDN activities infringe them, or was willfully blind to the\nsame.\n\n61. Furthermore, Sandpiper has been involved in significant, widely public litigation\nregarding infringement of its patents, including three of the Asserted Patents against Microsoft. In\naddition to the pending suit against Microsoft, these lawsuits include:\n\ne Sandpiper CDN, LLC v. Google LLC, Case No. 2:24-cv-03951-AB (C.D. Cal. May 10,\n\n\u00a9 See Microsoft I, Dkt. 41 (Second Amended Complaint, Oct. 30, 2025) at 9 54; compare\nhttps://web.archive.org/web/20250807 13 1523/https://dco.microsoft.com/(S(pzuaqe2d2sj2jxx20sutonh3))/Team.aspx\n\n(August 7, 2025 version of the web page with the language quoted in Sandpiper\u2019s Microsoft I\nfiling); with https://dco.microsoft.com/Team.aspx (rerouting, today, to https://partner.microsoft.com/en-\nUS/DCO with no such language).\n\n18\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 19 of 89 PagelD#: 19\n\n2024). In May 2024, Sandpiper sued Google in the Central District of California,\nasserting patents within the same portfolio as those asserted in this case, including the\n112 and \u00b0517 patents asserted against Microsoft in this case.\ne Sandpiper CDN, LLC v. Comcast Cable Comm\u2019s, LLC, Case No. 2:24-cv-00886-JRG\n(E.D. Tex. Nov. 1, 2024). In November 2024, Sandpiper sued Comcast in the Eastern\nDistrict of Texas, asserting patents within the same portfolio as those asserted in this\ncase, including the \u00b0876 patent asserted against Microsoft in this case.\ne Sandpiper CDN, LLC v. Cox Communications, Inc. et al, Case No. 1:26-cv-03893-ELR\n(N.D. Ga., July 11, 2026). In July 2026, Sandpiper sued Cox in the Northern District of\nGeorgia, asserting patents within the same portfolio as those asserted in this case,\nincluding the \u2019876 Patent asserted against Microsoft in this case.\n62. These lawsuits have received significant press coverage, including through press\nreleases and articles from RPX.*!\n63. On information and belief, Microsoft is a member of RPX and receives notices and\nupdates from RPX on patent litigations. \u201d\n64. On information and belief, as a member of RPX who receives notices and updates on\npatent litigations, Microsoft received notices discussing the aforementioned lawsuits from Sandpiper.\n65. On information and belief, several of these notices specifically named the U.S. Patent\n\nnumbers of the patents asserted in those cases, some of which are also Asserted Patents in this case,\n\n\u201c| See, e.g., Peter Hayes, \u201cGoogle Hit with Patent Lawsuit Over Content Delivery Network,\u201d\nBloomberg, https://news.bloomberglaw.com/litigation/google-hit-with-patent-lawsuit-over-content-\ndelivery-network-5.\n\n\u00ae See, e.g., Xockets, Inc. v. NVIDIA Corp. et al, Case No. 6:24-cv-00453-LS, Dkt. 1 at \u00a7 201 (W.D.\nTex. Sept. 5, 2024) (\u201cRPX was founded in 2008 and has more than 450 members, including . . .\nMicrosoft.\u201d); Dkt. 128 at n.3 (discussing an RPX-Microsoft Third Amendment to Membership and\n\nLicense Agreement).\n19\n\fCase 2:26-cv-00681 Document1i - Filed 08/11/26 Page 20 of 89 PagelD#: 20\n\nand give an overview of the infringement allegations in those cases.\u00b0\n\n66. Furthermore, on information and belief, Microsoft at least became aware of the\nComcast and Cox cases through monitoring the public filings in those cases, including the\nComplaints, claim constructions entered in Comcast, and became aware that Comcast ultimately\nsettled the lawsuit with Sandpiper. On information and belief, Microsoft also had knowledge of the\nsettlement agreement and its contents in Comcast before the filing of this lawsuit. As such, Microsoft\nat least had actual pre-suit knowledge of the \u2018876 patent asserted in Comcast, Cox, and this case,\nknew about Sandpiper\u2019s infringement allegations regarding Comcast and Cox\u2019s CDN networks,\nunderstood that Comcast settled its case, and appreciated the risk of its own infringement of at least\nthe \u2018876 patent based on offering its own CDN services.\n\n67. As such, Microsoft was either aware of these lawsuits, including the patents asserted\ntherein, or willfully blind to them, and never approached Sandpiper about a license prior to this\nlawsuit being filed.\n\n68. In June 2025, Sandpiper CDN sued Microsoft in the Eastern District of Texas,\nasserting patents sharing a common owner as those asserted in this case. In October 2025 Sandpiper\n\nCDN filed a First Amended Complaint in Microsoft J showing the history of these two companies\n\n43 RPX, May 12, 2024 \u201cIt\u2019s Not Every Patent Complaint That Name Checks \u2018The Starr Report\u2019 and\nBig Bad Voodoo Daddy,\u201d https:/Ansight.rpxcorp.com/news/80905-it-s-not-every-patent-complaint-\nthat-name-checks-the-starr-report-and-big-bad-voodoo-daddy (naming \u201cthe six patents (8,595,778;\n8,645,517; 8,719,886; 9,021,112; 10,924,573) now in suit against Google\u201d);\nhttps://insight.rpxcorp.com/litigation_documents/15685653 (RPX website hosting Sandpiper v\nGoogle Complaint, listing U.S. patent number of \u2018112 Patent asserted in this case and containing\nSandpiper CDN\u2019s infringement allegations in that case);\nhttps://nsight.rpxcorp.com/litigation/txedce-233870-sandpiper-cdn-v-comcast-cable-\ncommunications-llc-d-b-a-xfinity#overview (RPX website hosting docket for Sandpiper CDN v\nComcast case, with a clickable \u201cPatents-in-Suit\u201d tab indicating \u201c5 Patents-in-Suit\u201d and a \u201cView\nComplaint\u201d button); https:/Ansight.rpxcorp.com/litigation/cacdce-925901-sandpiper-cdn-v-google\n(RPX website hosting docket for Sandpiper v. Google case, with a clickable \u201cPatents-in-Suit\u201d tab\n\nindicating \u201c5 Patents-in-Suit\u201d and a \u201cView Complaint\u201d button).\n20\n\fCase 2:26-cv-00681 Document1_ Filed 08/11/26 Page 21 of 89 PagelID#: 21\n\nand of Microsoft\u2019s intense interest in acquiring rights to Sandpiper CDN\u2019s patents. Further, a now-\npublic document apparently provided by Savvis in the 2006 timeframe to potential bidders on\nSavvis\u2019s patents (such as Microsoft), titled \u201cSavvis Content Delivery Related Patents and Published\nPatent Applications,\u201d specifically listed as a separate item: \u201cITM Published U.S. Patent Application:\nUS 2003-0065762 A1.\u201d** That published application issued as the 871 patent asserted in this case.\nMoreover, the *964 Patent, the *738 Patent, and the \u00b0517 Patent each claim priority to the same\napplication and provisional for the 871 Patent. Thus, even if Microsoft were somehow not aware\nin 2006 of that patent application, its inclusion in the \u201cITM\u201d family, or its importance to \u201cContent\nDelivery\u201d networks like the one Microsoft was planning in 2006 and operates now, Microsoft was\ncertainly aware of all of this information in October 2025 when it received Sandpiper\u2019s Second\nAmended Complaint.\n\n69. Level 3, after paying $135 million for the patents now owned by Sandpiper CDN,\noperated its own ITM service, explaining that \u201cIntelligent Traffic Manager (ITM) is a DNS-based,\nweb administered, global load balancing service,\u201d and that Level 3 practices ITM patents in\nproviding its services.*\u00b0\n\n70. But at least by 2017 Microsoft decided to release its own \u201cIntelligent Traffic\n\nManager,\u201d explaining \u201cAzure Traffic Manager is a global load balancer\u201d that \u201cuses the Domain\n\n\u201c4 See Microsoft I, Dkt. 41, p. 12 n.26 (citing Level 3 Communications, LLC v. Limelight Networks,\nInc., 09-589, Dkt. 484-2 (D. Del. Feb. 18, 2009). This was the published application for patent\napplication 10/259,497, and was granted in 2010 as U.S. Patent No. 7,822,871.\n* See Intelligent Traffic Manager (ITM) Global Load Balancing Service\nhttps://assets.lumen.com/is/content/Lumen/Service-Guide-ITM-Services-\n20140423 pdf? Creativeid=for3 44ff-d8df-4717-8323-8a2039acSlfa (\u201cCenturyLink provides ITM\nService using the ITM infrastructure of Level 3 Communications.\u201d); see a/so Level 3, \u201cLegal,\u201d\nhttps://web.archive.org/web/20141012113846/http://www.level3.com/en/legal/ (\u201cCertain Level 3\ncontent delivery services are provisioned using systems, methods, and/or functionality covered by\none or more of the following U.S. Patents: ... 7,822,871\u201d).\n\n21\n\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 22 of 89 PagelD#: 22\n\nName System (DNS) protocol.\u201d*\u00b0\n\n71. To this day, Microsoft still refers to its Azure Traffic Manager as an \u201cIntelligent\nTraffic Manager\u201d in public-facing documents. For example, in response to a CDN outage Microsoft\nfaced just a few months ago, it described: \u201cWe have a highly distributed resilient architecture, which\nprotects against failures at the server, rack, site and even at the regional level. This resiliency is\nachieved by the use of our intelligent traffic management layer which monitors failures and load\nbalances traffic at server, rack or edge sites level within the primary ring, supplemented by a\nsecondary-fallback ring which accepts traffic in case of primary traffic overflow or broad regional\n\nfailures.\u201d 4\u201d Microsoft further graphically depicted its ITM system in this document. **\n\n46 See \u201cMicrosoft CEO Mentions Containers and Serverless Computing in Keynote,\u201d Sept. 25, 2017,\nhttps://www.sdxcentral.com/news/microsoft-ceo-mentions-containers-and-serverless-computing-in-\nkeynote/ (\u201cAs for serverless computing, Microsoft last month added an intelligent traffic manager to\nits plans with the unveiling of its Azure Event Grid routing service.\u201d); \u201cArchitecture best practices\nfor Azure Traffic Manager,\u201d https://learn.microsoft.com/en-us/azure/well-architected/service-\nguides/azure-traffic-manager (\u201cAzure Traffic Manager is a global load balancer that can distribute\ntraffic across multiple Azure regions, zones within a region, or datacenters within those zones. It uses\nthe Domain Name System (DNS) protocol to establish a communication path between a client and\nyour workload\u2019s endpoints.\u201d).\n\n4\u201d See \u201cAzure Front Door: Implementing lessons learned following October outages\u201d Dec. 18, 2025\nhttps://techcommunity .microsoft.com/blog/azurenetworkingblog/azure-front-door-implementing-\n\nlessons-learned-following-october-outages/4479416.\n48 See id.\n\n22\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 23 of 89 PagelD#: 23\n\n, = Management\nSprayed to Local Unicast VIP(s)\n\nPrimary ring with Traffic Spray across edge sites\n0 traffic shedding to oem Q if secondary ring protection is\nnearby edge sites & oy not enough\n\n\u201c Q sony\n\n72. Microsoft was also aware of the \u2019871 patent at least as of 2008 because Microsoft\ncited the published application of the \u2019871 patent during the prosecution of Microsoft\u2019s own patent:\nU.S. Patent No. 7,467,203, which issued in December 2008. Microsoft also cited that published\napplication in prosecuting Microsoft\u2019s U.S. Patent no. 8,236,980 (issued in December 2012) and\n8,577,892 (issued in November 2013), and 10,127,295 (issued in Nov. 2018), and 10,855,596 (issued\nin Dec. 2020, and titled \u201cLoad Balancing Among Multiple Endpoint Computing Systems of a\nDomain\u2019).\n\n73. Furthermore, in Microsoft I, Microsoft moved to dismiss Sandpiper CDN\u2019s\nallegations of willful patent infringement but the Court denied the motion, noting, among other things,\nthat \u201cthe Court finds plausible Plaintiffs pleadings that Defendant intended to infringe.\u201d Microsoft I,\nDkt. 56, p. 5, adopted at Dkt. 104.\n\n74. As demonstrated by the above, and on information and belief, in the 2006 timeframe\n23\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 24 of 89 PagelD#: 24\n\nMicrosoft was looking to build its own CDN to transition away from the services it received from\nSavvis, and would later receive from Level 3, and knew it needed to own, or obtain a license to, the\nSandpiper patents in order to avoid patent infringement. Microsoft thus conducted appropriate\ndiligence on and bid on the Sandpiper assets, including the Sandpiper patents highlighted in those\noffers (and specifically including two then-existing patent applications that were granted as patents\nasserted in this case) but ultimately was unwilling to pay what was necessary to avoid infringement,\nand decided to willfully infringe the Sandpiper patents anyway. In the years after 2006, as Microsoft\ncontinued to purchase CDN services from Level 3 while building out its own CDN, Microsoft still\nnever obtained a license to any Sandpiper patents, even though Microsoft continued to receive more\ninformation about the granted Sandpiper patents asserted in this lawsuit, and demonstrated its\nknowledge of these patents at least by its own patent prosecution efforts.\n\n75. Based at least on the foregoing, Microsoft\u2019s infringement of the Asserted Patents has\nbeen, is, and continues to be willful.\n\nSANDPIPER CDN\n\n76. Named after the company that originally pioneered and developed CDN technologies\nin the 1990s, Sandpiper CDN brings this suit to address Microsoft's ongoing and continued\ninfringement of the patented technology claimed by the Asserted Patents.\n\n77. The Asserted Patents are valid and enforceable, and the inventions claimed in the\nAsserted Patents are enabled, novel, non-obvious, unconventional, and non-routine as of their\nrespective filing dates.\n\nASSERTED PATENTS\n\n78. U.S. Patent No. 9,021,112 (\u201cthe 7112 Patent\u2019) is entitled \u201cContent Request Routing\n\nand Load Balancing for Content Distribution Networks,\u201d and it claims priority to U.S. Patent\nApplication No. 09/982,721, filed on October 18, 2001. See Ex. A.\n\n24\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 25 of 89 PagelD#: 25\n\n79. As Internet use has increased, website owners must address ever-increasing\nbandwidth needs, dynamic changes in load, and performance issues relating to browsing clients,\nincluding clients in remote or distant locations.\u201d When a server with website content, such as an edge\nserver in a content delivery network, receives multiple requests for website content, delivery of that\ncontent can be slow.\n\n80. The inventions claimed by the \u2019112 Patent provide concrete solutions to technical\nproblems facing computer networks. In certain embodiments of the \u2019112 Patent, methods are provided\nfor directing Internet users to the geographically nearest content delivery node using anycast\naddressing applied specifically and deliberately at the DNS tier, not the content delivery tier.\u00b0\u00b0 The\n\u00b0112 Patent claims are directed to a technical solution to a problem that existed in CDN architectures\nprior to the invention: anycast addressing could not be applied directly to content servers because\ndoing so caused TCP session fragmentation, as packets within a single session could be routed to\ndifferent physical machines sharing the same anycast address.\u00b0! The \u2019112 Patent\u2019s inventors\nrecognized that anycast addressing was uniquely compatible with DNS resolution which uses\nstateless UDP packets, and built a specific two-tier DNS resolution architecture around that\ncompatibility. The patent claims concrete methods in which CDN DNS servers share a common\nanycast address, use BGP to advertise that address to the surrounding network, and in some\nembodiments cause the BGP routing infrastructure itself to perform geographic selection by routing\neach DNS resolution request to the nearest CDN DNS node based on shortest-path metrics.\n\n81. Additionally, in one specific embodiment, the \u2019112 patent provides a specific two-\n\nphase resolution sequence with defined roles for each participant: first, an ISP DNS server resolves\n\n9 \u00b0112 Patent, 1:36-41.\n\u00b0\u00b0 112 Patent, 1:63-2:8.\n\u00b01>112 Patent at 8:27-45.\n25\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 26 of 89 PagelD#: 26\n\nthe subscriber's hostname to the CDN's shared anycast address, a process that does not require any\nmodification of the ISP's infrastructure; and second, one of the CDN DNS servers, selected by the\nBGP routing fabric based on network proximity, resolves that hostname to the IP address of the\ncontent server at its specific node.>\u201d\n\n82. According to one claimed solution in the \u2019112 Patent, the CDN DNS server is\nassociated with a respective plurality of content servers at its node, and requests for content are\nresolved to the DNS server, and then resolved to an IP address for one of the associated content\nservers.\u00b0* That route advertisement to the DNS server can be used as a dynamic load-balancing and\nfailover mechanism: when a node becomes overloaded, the advertisement is withdrawn,\nautomatically redirecting subsequent DNS resolution requests to the another node.** These are\nconcrete, specific implementations rooted in the technical realities of BGP routing, UDP-based DNS,\nand the incompatibility of anycast with TCP sessions, and not a generic instruction to use a content\ndelivery network for a desirable result.\n\n83. U.S. Patent No. 7,822,871 (the \u00b0871 Patent) is entitled \u201cConfigurable Adaptive\n\nGlobal Traffic Control and Management\u201d and it claims priority to U.S. Patent Application No.\n10/259,497, filed on September 30, 2002, which is a continuation of U.S. Patent Application No.\n60/325,177, filed on September 28, 2001. See Ex. B.\n\n84. The inventions claimed by the \u2019871 Patent provide concrete solutions to these\ntechnical problems facing computer networks. In one embodiment, the \u00b0871 Patent provides a means\nto distribute network traffic according to a configurable set of rules that take into account key factors\n\nsuch as server availability, specific requirements of content providers deploying the invention,\n\n>2\u00b0112 Patent at 8:49-65.\n3112 Patent at 9:3-21.\n4112 Patent at 9:3-21.\n26\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 27 of 89 PagelD#: 27\n\nincluding distribution based upon geography, position in IP address space, and load share, and the\nstate of the network at any given moment, including measures of network latency.*\u00b0\n\n85. For example, in one claimed embodiment of the \u2019871 Patent, there are three distinct,\nconcrete steps of (1) maintaining a traffic distribution policy used by a domain name server in an\nadaptive traffic control (ATC) name server network to determine the IP address of a server in response\nto a request from a client to resolve a hostname, (2) monitoring the operational status of the ATC\nname server network through a specific event-processing pipeline, and (3) maintaining and\nbroadcasting those processed operation events to domain name servers in the ATC name server\nnetwork.\u00b0\u00b0 These are specific, concrete operational steps that constitute a technical improvement to\nhow distributed DNS infrastructure is managed, and not a generic instruction to monitor or administer\na network.\n\n86. U.S. Patent No. 7,860,964 (the 964 Patent) is entitled \u201cPolicy-Based Content\n\nDelivery Network Selection,\u201d and it is a continuation-in-part claiming priority to U.S. Patent\nApplication No. 10/259,497, filed on September 30, 2002, which is a continuation of U.S. Patent\nApplication No. 60/325,177, filed on September 28, 2001. See Ex. C.\n\n87. The \u00b0964 Patent relates to network traffic management, and more specifically to\nconfigurable, adaptive, global traffic control and management in networks such as the Internet.*\u2019 As\ncontent delivery networks grew in commercial importance, content providers increasingly contracted\nwith multiple CDN operators simultaneously, providing redundancy, cost competition, and\ngeographic coverage. Prior DNS-based traffic management, however, could direct a client to only a\n\nsingle CDN provider at a time, through a statically-configured DNS record pointing to that CDN's\n\n> \u00b0871 Patent at 1:43-52.\n\u00b0\u00b0 \u00b0871 Patent, 27:39-63.\n\u00b07 \u00b0964 Patent, 1:24-27.\n27\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 28 of 89 PagelD#: 28\n\nnamespace. The invention is described in a scenario in which DNS service is provided by a third party\non behalf of a content or applications provider.\u00b0\u00ae\n\n88. The inventions claimed by the \u2019964 Patent provide concrete solutions to these\ntechnical problems facing computer networks. In one embodiment, the *964 Patent describes a\nsubscriber maintaining an even load across all subscriber servers by setting a load share value, with\ntraffic shedding to an overflow server defined by a CName for a CDN when all servers near\ncapacity.\u00b0? In another embodiment, the specification describes a concrete multi-CDN configuration\nin which an ATC is configured to return the domain name of one CDN 1.5 times as often as it returns\nthe domain name of a second CDN, thereby implementing a 1.5-to-1 load share ratio between two\ndistinct CDN providers entirely at the DNS layer.\u00b0\u00b0\n\n89, One claimed embodiment of the \u00b0964 Patent is directed to a \u201cmethod operable in a\nframework wherein resources of a content provider are delivered to clients from one of a plurality of\ndistinct content delivery network (CDN) domains distinct from a content provider domain.\u201d The\nclaim requires \u201cobtaining one or more content provider policies relating to delivery of said resources,\nat least one of said policies relating to a relative load share for each of said plurality of CDN\ndomains.\u201d\u00b0! The load share policy requirement is technically specific: the policy must quantify the\nrelative fraction of traffic that each distinct CDN domain is to receive, making it a machine-\nenforceable distribution rule. The claim further requires \u201cselecting, based at least in part on said one\nor more content provider policies, one of said plurality of CDN domains.\u201d\u00a9 And when a CDN domain\n\nis selected, the claim requires \u201cproviding the client with a domain name associated with the selected\n\n8 \u00b0964 Patent, 3:4-8.\n\n\u00b0\u00b0 \u00b0964 Patent, 27:8-15.\n6\u00b0 \u00b0964 Patent 28:7-32.\n61 \u00b0964 Patent, Claim 19.\n\n6 \u00b0964 Patent, Claim 19.\n28\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 29 of 89 PagelD#: 29\n\nCDN.\u201d\u00ae The requirement to provide a domain name is a technically significant and specific\nimplementation choice: by returning a domain name in the CDN\u2019s own namespace, the method directs\nthe client\u2019s DNS resolver to continue resolution within the selected CDN\u2019s own infrastructure,\nenabling that CDN to apply its own geographic and load-based edge selection for the final resolution\nstep.\n\n90. U.S. Patent No. 9,660,876 (the \u2019876 Patent) is entitled \u201cCollector Mechanism In\n\nContent Delivery Network\u201d and it claims priority to U.S. Application No. 13/802,440, filed March\n13, 2013, which in turn claims priority from U.S. Provisional Application No. 61/737,072, filed\nDecember 13, 2012. See Ex. D.\n\n91. As CDN technology developed, the type of the content served and delivered by\nCDNs evolved. As a result, CDNs\u2014originally configured to treat requests for all content the same\u2014\nexperienced issues as they started receiving different requests for different types of content, such as\nvideo, images, written work, or other multimedia content. Further compounding the issue was the\nchallenge in configuring CDNs to account for different types of parameters associated with delivering\ncontent, including responsibilities, security, quality, and the like.\n\n92. The inventors of the \u2019876 Patent identified these technical problems and invented\nspecific and technical solutions to address them. In particular, the inventors developed, inter alia, a\nspecific and technical solution whereby \u201cstate data are used to inform a peering policy of a set of\ncaches,\u201d where a collector system \u201cproduce[s] state data relating to and based on information\nrepresented in said event data of said multiple event streams.\u201d\u00b0* The inventors also discovered that\nusing the state data relating to the event streams to inform a peering policy empowered the\n\ncustomization of computing components in a CDN, which improves computational efficiency of the\n\n63 \u00b0964 Patent, Claim 19.\n64 \u00b0876 Patent, claim 1.\n29\n\fCase 2:26-cv-00681 Document1i Filed 08/11/26 Page 30 of 89 PagelD #: 30\n\nCDN through specialization. Moreover, the disclosed inventions of the as the inventors explained to\nthe Patent Office, \u00b0876 Patent are not abstract ideas, but are \u201capplicable and limited by the claims to\ncontent delivery networks and provide[] a concrete way to support efficient and scalable content\ndelivery in such networks . . . [and] \u2018[are] necessarily rooted in computer technology in order to\novercome a problem specifically arising in the realm of computer networks.\u2019\u201d\u00ae The technical solution\nof the \u00b0876 Patent provides CDNs with the infrastructure and logic to handle specific requests for\nspecific users in a more computationally efficient manner that was more scalable than other existing\nsystems.\n\n93, Indeed, the claims of the \u2019876 Patent include specific and technical solutions, using\nspecific structures, that were not conventional at the time, and the \u00b0876 Patent describes how the\nsolutions are implemented, as recited in the method of independent claim 1. First, using the claimed\nstate data relating to the event streams to inform a peering policy allows for the customization of\ncomputing components in a CDN to improve computational efficiency of the CDN through\nspecialization. Second, using the claimed state data to inform a peering policy for a set of peer caches\nimproves fault tolerance within a CDN to reduce outages. Third, certain CDNs implementing\nembodiments claimed by the are able to account for the ordering receiving multiple event \u2019876 Patent\nof the event streams to improve efficiency in configuring the CDNs by streams, each comprising a\ntimestamp for the event.\n\n94. U.S. Patent No. 9,647,899 (the 899 Patent) is entitled \u201cFramework Supporting\n\nContent Delivery with Content Delivery Services,\u201d and it was filed December 14, 2012, claiming\n\npriority to U.S. Provisional Application No. 61/737,072, filed December 13, 2012. See Ex. E.\n\n6\u00b0 See Applicant Arguments/Remarks Made in an Amendment dated June 2, 2016, p. 12\n(successfully traversing a Patent Office rejection under 35 U.S.C. \u00a7 101 to establish that the patent\napplication for the \u2019876 patent is directed to patent eligible subject matter) (citing DDR Holdings,\nLLC v. Hotels.Com, L.P., 7773 F.3d 1245, 1257 (Fed. Cir. 2014)).\n\n30\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 31 of 89 PagelD#: 31\n\n95. Content delivery networks are composed of multiple distinct distributed services\noperating concurrently, for example collector services for monitoring, analytics, and popularity;\nreducer services for logging, monitoring, and alarming; control services for control resource\ndistribution and localized feedback; configuration services for configuration validation and resource\ngeneration; and primary delivery services including rendezvous and caching.\u00ae A technical problem\nin CDN design was that these services operated in relative isolation, where each generated its own\noperational events and maintained its own state, but there was no systematic mechanism by which\nthe operational event data produced by one service would flow as input into other services, be\naggregated into CDN-wide state information, and be used to automatically reconfigure how those\nservices were interconnected.\n\n96. The inventions claimed by the \u2019899 Patent provide concrete solutions to this problem\nthrough a specific framework in which event output, state, and service configuration information are\nsystematically connected. As part of the operation of each service or kind of service, a service may\nproduce event information corresponding to events relating to that service, and may obtain state\ninformation from other CDN services or components and may generate state information for use by\nother CDN services or components.\u00ae\u2019 In one embodiment, a minimal CD service is both an event\nsource and a control sink, meaning that all CDN services consume control information and generate\nevents.\u00b0\u00ae This mutual interconnection enables a specific technical improvement: a closed feedback\nloop where each service generates events and receives control, and the resulting events and state flow\ncontinuously through the network.\n\n97. Claim 1 requires that some CD services in the CDN \u201cproduce event output relating\n\n66 >899 Patent at col. 11:52-12:9.\n67 >899 Patent at col. 8:18-49.\n68 \u00b0899 Patent, 9:41-53.\n31\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 32 of 89 PagelD #: 32\n\nto their respective operation, wherein at least some of said event output from at least some of said CD\nservices is provided to at least some of said CD services as event input.\u201d This cross-service event\nflow is the foundation of a claimed feedback architecture. Claim 1 also requires specific technical\nprocesses based on those interconnected event outputs, requiring the services to \u201cmaintain service\n\n99 oe\n\nconfiguration information specifying associations between CD service instances,\u201d \u201cobtain state\ninformation from said CD services,\u201d and \u201cmodify said service configuration information to produce\nmodified service configuration information based at least on the state information.\u201d\u201d The \u201cservice\nconfiguration information specifying associations between CD service instances\u201d is a technically\nspecific data structure and the claim requires that this configuration be modified based on the state\n\ninformation derived from event flows.\n\n98. U.S. Patent No. 10,116,738 (the \u2019738 Patent) is entitled \u201cDetecting anomalous\n\nconditions in a name server network,\u201d and it was filed November 30, 2015, claiming priority to U.S.\nProvisional Application No. 60/325,177, filed September 28, 2001. See Ex. F.\n\n99, The \u2019738 patent is generally directed to network traffic management and configurable\ntraffic control and management. As the volume of Internet traffic grows, content and application\nproviders increasingly need to deliver content from multiple servers at widely separated locations to\nsustain a good end-user experience under high traffic loads. This creates several challenges, including\nguaranteeing fault tolerance in the face of individual server or name server failures and maintaining\nhigh performance as network conditions change, particularly since the state of the network can shift\nat any given moment.\n\n100. The inventions claimed by the \u2019738 Patent provide concrete solutions to addresses\n\nthese challenges with a system that lets a subscriber define, through a web-based graphical user\n\n6 \u00b0899 Patent, claim 1.\n79 \u00b0399 Patent, claim 1.\n32\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 33 of 89 PagelD#: 33\n\ninterface, policies governing how service requests are distributed among the subscriber's servers,\nwhile a network of name servers responsible for resolving hostnames to those servers is continuously\nmonitored for its own operational health.\n\n101. Claim 1 requires receiving policies for distribution of service requests to one or more\nservers in a subscriber server network. The method further requires monitoring the operational status\nof name servers in a name server network that provides hostname resolution services for the servers\nin the subscriber server network. When monitoring detects an error or anomalous condition at a\nparticular name server, the system automatically creates a policy reflecting that name server's status,\nso that subsequent hostname resolution decisions across the name server network take the condition\ninto account. The subscriber is also proactively notified of the detected condition through the same\nweb-based graphical user interface used to configure policies, closing the loop between real-time\nnetwork monitoring, adaptive policy management, and subscriber visibility. This combination allows\nthe traffic-management system to respond dynamically to name server failures or anomalies without\n\nmanual intervention, while keeping the subscriber informed so they can take further action if needed.\n\n102. US. Patent No. 8,156,066 (the \u2019066 Patent) titled \u201cRule-Based Content Request\nHandling,\u201d issued on April 10, 2012, from an application claiming priority to an April 9, 2008\nprovisional application. See Ex. G.\n\n103. The inventions claimed in the \u2019066 Patent address a specific technical problem\nfacing content delivery networks: how a shared distribution infrastructure serving many\nindependent content providers could apply each provider\u2019s own, independently configured access\nand handling rules to incoming content requests, at scale, without requiring every provider to build\nand operate separate request-handling infrastructure. The \u2019066 Patent\u2019s solution involves deriving\nattribute values not directly supplied by the requester from attribute values already present in an\n\nincoming content request, such as deriving the requester\u2019s likely geographic region from the\n\n33\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 34 of 89 PagelD#: 34\n\nrequester'\u2019s Internet Protocol address. Both the originally supplied and the newly derived attribute\nvalues are evaluated against a hierarchy of decision nodes, arranged so that a request is resolved\nonly after propagating through different levels of specific logic culminating in a single decision that\ndictates whether the request is allowed, denied, or redirected.\n\n104. Claim 14 of the \u2019066 Patent recite an architecture including: (a) receiving a content\nrequest that includes a first set of attribute values; (b) using at least one attribute value from that first\nset to determine a second, distinct set of attribute values; (c) traversing a hierarchy of decision nodes,\neach implementing logic based on an attribute value from either set; and (d) yielding, from the last\nnode reached in that hierarchy, a decision dictating how the request is to be answered. Claim 14\nrequires that the request-disposition decision be reached only through a specific implementation\nmechanism: deriving a second, distinct set of attribute values from the request\u2019s original attributes\nand then routing evaluation through a defined multi-node hierarchy that connects its logic to one of\nthose two attribute generations. This defines specific technical implementation and does not simply\nrecite a desired result of deciding whether to allow, deny, or route a request based on the requester's\ncharacteristics. Claim 14\u2019s steps thus describe a specific data-transformation and control-flow\narchitecture that a computer must implement to reach the claimed decision, not merely a functional\ngoal that architecture achieves.\n\n105. US. Patent No. 8,645,517 (the \u201c\u2019517 Patent) is entitled \u201cPolicy-Based Content\n\nDelivery Network Selection.\u201d The \u2019517 Patent claims priority to U.S. Patent Application Number\n10/259,497, filed on September 20, 2002. See Ex. H.\n\n106. | When using CDN technology, challenges arise related to network traffic associated\nwith requests for content. For example, companies that want to provide their content to end users\nusing a CDN face issues regarding directing network traffic to serve end users\u2019 requests. As one\n\nexample, issues arise when trying to deliver content from multiple servers at geographically-separated\n\n34\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 35 of 89 PagelD #: 35\n\nlocation with suitable end-user experiences under high traffic loads.\n\n107. The inventors of the \u00b0517 Patent understood these challenges faced by CDN\nproviders and their customers relating to directing network traffic and end-user requests for content.\nThe inventors devised solutions utilizing Domain name Server (DNS) technology and allowing for\nthe resolution of requests to multiple CDNs based on various policies. Embodiments of the disclosed\ninvention solve network traffic issues such as server failure, and controlling the distribution of\nrequests according to economic or contractual parameters, by providing a network distribution\ninfrastructure that can be configured with network traffic rules. These rules can account for factors\nlike server availability, geolocation, load, and latency. The \u00b0517 Patent addresses specific needs in\nthe art via specific combinations, which were not conventional at the time of the invention of the \u00b0517\nPatent, and the \u00b0517 Patent describes how specific technical solutions are achieved. For instance,\ncontent providers must address how to handle requests from end users, in some cases in accordance\nwith policy constraints faced by the content providers, even as network conditions affecting the\nInternet are subject to change. The inventors of the \u00b0517 Patent developed methods to address these\nissues, including methods in which a server network implements policy-based traffic direction. For\nexample, embodiments of the invention in the \u2019517 Patent provide a specific graphical user interface\nfor obtaining at least one policy for the direction of network traffic, such as using a decision tree with\nresource and branch nodes. The various criteria that can be used may relate to IP addresses or\ngeographic zones, with answers consisting of IP addresses and CNAMEs, for example.\n\nTHE ACCUSED MICROSOFT FUNCTIONALITIES\n\n108.  Microsoft\u2019s Azure is a cloud computing platform offering a range of cloud services\nfor businesses and developers.\u2019' Core service categories include cloud computing, cloud storage,\n\ndatabases, networking, application hosting and development, and security. Microsoft additionally\n\n\u201d https://azure.microsoft.com/en-us/resources/cloud-computing-dictionary/what-is-azure/\n35\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 36 of 89 PagelD #: 36\n\noffers content delivery infrastructure and services through its Azure CDN products, as well as\nleveraging these products to deliver its own internal content, updates, and other services for Microsoft\nproducts. These Azure CDN products include Azure CDN Standard from Microsoft, Azure CDN\nStandard from Edgio, Azure CDN Premium from Edgio, and Azure Front Door Standard and\nPremium.\u201d\n\nAzure Content Delivery Network includes three products:\n\ne Azure CDN Standard from Microsoft\ne Azure CDN Standard from Edgio (formerly Verizon)\n\ne Azure CDN Premium from Edgio (formerly Verizon).\n\nhttps://learn.microsoft.com/en-us/azure/cdn/cdn-features\n\n109.  =Microsoft\u2019s Azure CDN products offer global coverage through distributed points of\npresence (PoPs) including throughout North America.\u201d Microsoft\u2019s Azure CDN products utilize\nrepeater servers (e.g., EdgeNodes or Endpoints) for replicating (e.g., caching) content from origin\nservers.\u2019* Azure CDN products include various performance features and optimizations including\nacceleration, delivery optimization, video streaming optimization, asset pre-loading, caching rules,\ncustomizable rules for content delivery, URL redirect/rewrite, custom DNS support, DDoS\n\n\u2122\u00ae Azure CDN was announced May 7, 2018 as a public\n\nprotection, authentication, and analytics.\npreview. \u201d\u00b0\n\n110. Azure Front Door is Microsoft\u2019s \u201cmodern\u201d CDN product featuring similar content\n\nreplication and delivery functionality with added scalability and performance.\u2019\u2019 Azure Front Door\n\n\u201d  ~ https://learn.microsoft.com/en-us/azure/cdn/cdn-overview; https://learn .microsoft.com/en-\n\nus/azure/frontdoor/front-door-overview.\n\n\u00ae https://azure.microsoft.com/en-us/products/cdn; https://learn.microsoft.com/en-us/azure/cdn/cdn-\npop-locations.\n\n https://learn.microsoft.com/en-us/azure/cdn/cdn-overview\n\n\u00ae https://learn.microsoft.com/en-us/azure/cdn/cdn-features\n\n7\u00a9 https://azure.microsoft.com/en-us/blog/announcing-microsoft-s-own-cdn-network/\n\n\u2122 https://learn.microsoft.com/en-us/azure/frontdoor/front-door-overview\n36\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 37 of 89 PagelD #: 37\n\nprovides autoscaling and global traffic distribution with load balancing to ensure high availability.\u201d*\n\nAzure Front Door definition\n\nAzure Front Door Standard/Premium provides the capabilities of these three products. It offers a fast, reliable, and more secure\nmodern cloud CDN by using the Microsoft glabal edge network to integrate with intelligent threat protection. Azure Front\nDoor resides in the edge locations and manages user requests to your hosted applications. Users connect to your application\nthrough the Microsoft global network. Azure Front Door then routes user requests to the fastest and most available\napplication backend.\n\n@\u00ae Note\n\nAn application backend is any internet-facing service that you host, either inside or outside Azure.\n\nThe following Azure Front door tiers are available:\n\n\u00a9 Azure Front Door (classic), which is the entry level. Existing Azure customers often bolster these features with Azure\nContent Delivery Network, and Azure Web Application Firewall.\n\n\u00a9 Azure Front Door Standard, which is optimized for seamless content delivery.\n\n\u00a9 Azure Front Door Premium, which is optimized for improved security.\n\nhttps://learn.microsoft.com/en-us/training/modules/intro-to-azure-front-door/2-what-is-azure-front-\ndoor\n\n111. Microsoft further offers Azure Policy, enabling organizations to create, assign, and\nmanage policies to enforce compliance and security across their cloud resources.\u201d Core features of\nAzure Policy include resource consistency ensuring uniform configuration across environments as\nwell as security enhancement enforcing restrictions on resource configurations and services.*\u00b0\n\n112. Microsoft further offers Azure Resource Manager, providing infrastructure\nmanagement and access control functionality in a unified management platform.*! Azure Resource\nManager was introduced in 2014.\n\n113. Microsoft further offers Azure Traffic Manager, a DNS-based traffic load balancer\nthat distributes traffic to public-facing applications across global Azure regions, providing public\n\nendpoints with high availability and quick responsiveness.\u00ae Traffic Manager uses DNS to direct\n\nclients to specific service endpoints based on configured routing methods and provides distribution\n\n78 https://learn.microsoft.com/en-us/azure/frontdoor/front-door-faq\n\n\u201d https://learn.microsoft.com/en-us/azure/governance/policy/overview\n\n8\u00b0 https://sonraisecurity.com/blog/what-is-azure-policy-all-you-need-to-know/\n\n8! https://learn.microsoft.com/en-us/azure/azure-resource-manager/management/overview\n82 https://web.archive.org/web/20161029053752/https://azure.microsoft.com/en-\nus/documentation/articles/resource-manager-deployment-model/\n\n83 https://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\n37\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 38 of 89 PagelD#: 38\n\nof traffic according to one of several routing methods, as well as continuous monitoring of endpoint\nhealth with automatic failover when endpoints fail. Traffic Manager caches DNS responses through\nconfigurable time-to-live (TTL) values which are configurable.*\n\n114. \u2014 Microsoft further offers Azure Monitor, a unified observability service for collecting,\nanalyzing, and acting on telemetry data from cloud and hybrid environments, enabling users to\nunderstand the health, performance, and reliability of Azure applications and infrastructure resources\n\nby bringing together metrics, logs, traces, and events into a single user experience.*\u00b0\n\n(*) Azure Monitor\nInsights\n\n@ oo\nW oo Mm\nApplication Kubernetes VM Network\nMetrics Visualize\nApps / Workloads w jt CS Observability\nPP: f aod agent\nInfrastructure Logs Workbooks Dashboards Grafana Power BI \u2014\nAzure Platform Analyze\nje bi\u2019 Explore\nCustom Sources recs: iil \u2014\u2014 Investigate\nMetric Explorer Log Analytics Automate\nRespond\n=a\n\ny\nmtn,\nAlerts Actions Issues Q\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/fundamentals/overview\n\nAzure Monitor collects logs and metrics from all resources across Azure services and integrates this\nmonitoring into the Azure portal for each service. Azure Monitor also proactively notifies\nsubscribers when issues are identified in collected data.\n\n115. Microsoft further offers Azure Peering Service, a networking service that enhances\nconnectivity to Microsoft cloud services such as Microsoft 365, Dynamics 365, SaaS services, Azure,\nand others. Through Azure Peering service, Microsoft partners with internet service providers\n\n(\u201cISPs\u201d) to provide reliable and high-performing public connectivity through optimal routing from\n\n84 https://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\n\n8\u00b0 https://learn.microsoft.com/en-us/azure/azure-monitor/fundamentals/overview\n38\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 39 of 89 PagelD #: 39\n\nand to the Microsoft network.*\u00b0\n\nGeographical area Geographical area f\n\nBranch office\n; a\n\nHQ ae Internet\n\nInternet\n\nDistributed cloud application can\nbe hosted in any Microsoft DC and\ncan be accessed from any location\n\nUi itagertesia (tauren\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\nThrough Azure Peering Service, Microsoft ensures traffic stays on its own high-capacity, low-latency,\nand high-reliability Microsoft global network until traffic is as close to its destination as possible.\nAzure Peering Service further provides geo-redundancy by interconnecting Microsoft\u2019s network with\nservice providers at multiple metro locations, such that is one Azure Edge has degraded performance,\ntraffic routes via alternative sites.*\u2019\n\n116. On information and belief, Microsoft operates its CDNs for both Microsoft\u2019s internal\nuse (e.g., Windows updates, its Xbox gaming ecosystem, cloud gaming, third-party gaming, Office\n365 tools, Copilot, Teams and Skype videoconferencing, Azure content delivery, delivery of apps,\ngames, and software through the online Microsoft Store, video streaming like Linkedin Learning, and\nweb services like Microsoft Edge and Bing), and for external use, with Microsoft leasing its Azure\nCDN network to third parties.\n\n117. The aforementioned products and services are collectively the \u201cAccused Microsoft\n\nFunctionalities.\u201d\n\n86 https://learn.microsoft.com/en-us/azure/peering-service/about\n\n87 https://learn.microsoft.com/en-us/azure/peering-service/about\n39\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 40 of 89 PagelD #: 40\n\nCOUNT I: INFRINGEMENT OF THE 7112 PATENT\n\n118. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n119. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 1 of the \u2019112 Patent through one or more of the Accused Microsoft\nFunctionalities. For instance, Microsoft Front Door CDN comprises a network through which\nMicrosoft provides a plurality of Domain Name System servers associated with a Content Delivery\nNetwork that share a common anycast address, and where each CDN DNS server is associated with\n\na respective plurality of content servers.\n\nTopology\n\nIn the design of this scenario, the same IP address is advertised from virtual networks in different Azure regions, where\nnetwork virtual appliances (NVAs) advertise the application's IP address through Azure Route Server. The following\ndiagram depicts two simple hub and spoke topologies, each in a different Azure region. An NVA in each region\nadvertises the same route (@.b.c.d/32 in this example) to its local Azure Route Server (the route prefix must not overlap\nwith Azure and on-premises networks). The routes are further propagated to the on-premises network through\nExpressRoute. When application users want to access the application from on-premises, the DNS infrastructure (not\ncovered by this document) resolves the DNS name of the application to the anycast IP address (a.b.c.d), which the on-\n\npremises network devices route to one of the two regions.\n\niY YY\n\u2018\n\nf- \u2014 ER Gateway i\n\ni\n/ z i\n{ On-premises bauaseetsssees\nSS network\n(INI pees\n\\ SD ONNO  eeoos\n\n~ KR\n\nNN :\nERGateway = =u Server\n\nhttps://learn.microsoft.com/en-us/azure/route-server/anycast\n\n120. Microsoft causes said plurality of CDN DNS servers to be authoritative for a\nhostname associated with a content provider by causing said common anycast address to be associated\n\nwith said hostname.\n\n40\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 41 of 89 PagelID#: 41\n\nResolution and delegation\n\nThere are two types of DNS servers:\n\n\u00ae An authoritative DNS server hosts DNS zones. It answers DNS queries for records in those zones only.\ne A recursive DNS server doesn't host DNS zones. It answers all DNS queries by calling authoritative DNS servers to\ngather the data it needs.\n\nAzure DNS provides an authoritative DNS service. It doesn't provide a public recursive DNS service. For information\nabout Azure's private DNS recursive service, see What is Azure DNS Private Resolver. By default, cloud services and VMs\nin Azure are configured to use a recursive DNS service that is provided separately as part of Azure's infrastructure. For\n\ninformation on how to change these DNS settings, see Name Resolution in Azure.\n\nDNS clients in PCs or mobile devices typically call a recursive DNS server to do any DNS queries the client applications\n\nneed.\n\nWhen a recursive DNS server receives a query for a DNS record such as ww.contoso.com, it first needs to find the\nauthoritative name server hosting the contoso.com domain. To find the name server, it starts at the root name servers,\nand from there finds the name servers hosting the com domain. It then queries the com name servers to find the name\n\nservers hosting the contoso.com domain. Finally, it's able to query these name servers for www.contoso.com,\n\nThis procedure is called resolving the DNS name. Strictly speaking, DNS resolution includes more steps such as following\nCNAMEs, but that\u2019s not important to understanding how DNS delegation works.\n\nHow does a parent zone point to the name servers for a child zone? It does this using a special type of DNS record\ncalled an NS record (NS stands for \u2018name server\u2019). For example, the root zone contains NS records for com and shows the\nname servers for the com domain. In turn, the com domain contains NS records for contoso.com that display name\nservers for the contoso.com domain. Setting up the NS records for a child zone in a parent zone is called delegating the\n\ndomain.\n\nhttps://learn.microsoft.com/en-us/azure/dns/dns-domain-delegation\n\nThe following image shows an example DNS query. The contoso.net and partners.contoso.net zones are public DNS\n\ndomains that have been delegated to Azure's authoritative DNS servers.\n\n\u2014 \u2014 <7\n\u2014 \u2014 \u2014 |\na |\ne@ a Internet |\nRoot name server\n\u2014\u2014__1\u2014__+ |\nUser \u2014\u2014\u201410 Se |\nLocal DNS server \u2122 a\u2014\n\u2014\n|\n\u2018 |\nj \u2018\nil f \\ Internet.net |\n9 \\ 6 name server |\njf \\ |\n/ \\ |\n\u2018 \\ |\n: |\n_ Legend\nWeb App TS |\nIP 1.2.3.4 |\nDNS} . ~~ . fe Oe\n\u00a37\n- il \u2014\nAzure DNS zone Azure DNS Zone\npartners.cantoso.net contosa.net -\nA Record: 1.2.3.4 NS Record: partners\n\nhttps://learn.microsoft.com/en-us/azure/dns/dns-domain-delegation\n\n4l\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 42 of 89 PagelD#: 42\n\n13.107.236.4 \u00a9 @ 5% inca @ honing Noes\n\nSummary\nLocation Redmond, Washington, Gi\nASN \u2018 Microsoft Corporatior\nHostname nst-04.azure-dns.com\nRange\nCompany Microsoft Corporation\nHosted domains 8\n\nvm\u201d HE \u201d\u201d EE EE Ee Ee EE ES\n\n[ Anycast true Anycast instances identified in 26 countries and 38 cities\n\nAbuse contact H.C 0\n\nhttps://1pinfo i0/13.107.236.4?lookup_source=search-bar\n121. Microsoft, responsive to a request for content associated with the content provider\nand issued by a client, said request including at least said hostname, causes said hostname to be\nresolved to said common anycast address by an Internet Service Provider DNS server, and then by\none of said plurality of CDN DNS servers, resolves said hostname to identify an IP address for use\nby the client to retrieve the content from a content server. For example, Microsoft causes an ISP DNS\nserver to resolve office.com to the anycast IP address of Azure DNS servers at 150.171.21.5, which\nthen in turn resolve a hostname to an Azure Front Door IP address at 13.107.6.156.\n$ dig -4 @74.40.74.40 +trace office.com\n\n. 18994 IN NS a.root-servers.net.\n\noffice.com. 172800 IN NS ns1-05.azure-dns.com.\noffice.com. 172800 IN NS ns2-05.azure-dns.net.\noffice.com. 172800 IN NS ns3-05.azure-dns.org.\noffice.com. 172800 IN NS ns4-05.azure-dns.info.\n\noffice.com. 10 IN A 13.1 a\n;; Received 55 bytes from 150.171.21.5#53(ns2-05.azure-dns.net) in 14 ms\n\n42\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 43 of 89 PagelD #: 43\n\nCOUNT IL INFRINGEMENT OF THE \u2019871 PATENT\n\n122. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n123. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 44 of the \u2019871 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Microsoft Azure Traffic Manager operates global DNS name\nservers in connection to Azure Resource Manager, Azure Portal, Azure Monitor, and related control\n\nplane management interfaces to perform a method of an adaptive traffic control framework.\n\nWhat is Azure Traffic Manager?\n\n+, Summarize this article for me\n\nAzure Traffic Manager is a DNS-based traffic load balancer that distributes traffic to your public-\nfacing applications across global Azure regions. Traffic Manager provides your public endpoints\n\nwith high availability and quick responsiveness.\n\nTraffic Manager uses DNS to direct client requests to the appropriate service endpoint based ona\ntraffic-routing method. Traffic Manager also provides health monitoring for every endpoint. The\nendpoint can be any Internet-facing service hosted inside or outside of Azure. Traffic Manager\nprovides a range of traffic-routing methods and endpoint monitoring options to suit different\napplication needs and automatic failover models. Traffic Manager is resilient to failure, including\nthe failure of an entire Azure region.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\n\n124. Microsoft Azure features a server network comprising hardware in combination with\nsoftware. For instance, Microsoft cloud datacenters include server hardware with Azure service\n\nsoftware operating on this hardware.\n\n43\n\fCase 2:26-cv-00681 Document1- Filed 08/11/26 Page 44 of 89 PagelD#: 44\n\nhttps://azure.microsoft.com/en-us/blog/the-anatomy-of-a-datacenter-how-microsofts-datacenter-hardware-\npowers-the-microsoft-cloud/\n\n125. Microsoft further maintains at least one policy used by at least one domain name server in\nan adaptive traffic control (ATC) name server network to determine the IP address of a server in a server\nnetwork in response to a request from a client to resolve a hostname. For instance, Traffic Manager name\nservers for trafficmanager.net receive DNS requests and return endpoints based on configured endpoint state,\n\nhealth, and routing method.\n\n44\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 45 of 89 PagelD #: 45\n\nHow Traffic Manager Works\n\n+, | Summarize this article for me\n\nAzure Traffic Manager enables you to control the distribution of traffic across your application\n\nendpoints. An endpoint is any Internet-facing service hosted inside or outside of Azure.\nTraffic Manager provides two key benefits:\n\ne Distribution of traffic according to one of several traffic-routing methods\n\ne Continuous monitoring of endpoint health and automatic failover when endpoints fail\n\nWhen a client attempts to connect to a service, it must first resolve the DNS name of the service to\n\nan IP address. The client then connects to that IP address to access the service.\n\nThe most important point to understand is that Traffic Manager works at the DNS level which is\nat the Application layer (Layer-7). Traffic Manager uses DNS to direct clients to specific service\nendpoints based on the rules of the traffic-routing method. Clients connect to the selected\nendpoint directly. Traffic Manager isn't a proxy or a gateway. Traffic Manager doesn't see the traffic\n\npassing between the client and the service.\n\nTraffic Manager uses profiles to control traffic to your cloud services or website endpoints. For\n\nmore information about profiles, see Manage an Azure Traffic Manager profile.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-how-it-works\n\n126. Microsoft monitors the operational status of the ATC name server network comprising\nreceiving, by an ATC network monitoring mechanism in the ATC administrative framework, events sent from\nat least one monitoring mechanism of the at least one domain name server. For instance, Azure Monitor\n\nmonitors operational status of name servers in the network.\n\n45\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 46 of 89 PagelD#: 46\n\nAzure Monitor is a comprehensive monitoring solution for collecting, analyzing, and responding to monitoring data from\nyour cloud and on-premises environments. You can use Azure Monitor to maximize the availability and performance of\nyour applications and services. It helps you understand how your applications are performing and allows you to\nmanually and programmatically respond to system events.\n\nAzure Monitor collects and aggregates the data from every layer and component of your system across multiple Azure\nand non-Azure subscriptions and tenants. It stores it in a common data platform for consumption by a common set of\ntools that can correlate, analyze, visualize, and/or respond to the data. You can also integrate other Microsoft and non-\nMicrosoft tools.\n\nCollect, route Consume\nYoU feo) Site) es) Talcciselccie\nand transform\n\nalse] elt lalccce) eagles\n\nThe diagram above shows an abstracted view of the monitoring process. A more detailed breakdown of the Azure\nMonitor architecture is shown in the High level architecture section below.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nThe following diagram shows a high-level architecture view of Azure Monitor.\n\nData Sources Data Platform Consumption\n\n@) Azure Monitor\nInsights\n\n9 eu \u00ae..\n\nnis Application Container VM Network\nou Visualize\nApps / Workloads a Eq} ] wn\nInfrastructure og Workbooks Dashboards Power8i\" Grafana*\nAzure Platform Analyze\nTraces ji \u00ae\nil ' wv\nCustom Sources = .\nMetric Log Change\nChanges\nBE Respond\n& Fs %\nAlOps Alerts and Autoscale\nActions\n\u00ae SCOM Managed Instance\nDatabases >\n\u2014$ $$$ $_$$__\u00a7_\u00a7_____ > > &\nes Ops Console* Power BI\"\n\nIntegrate\n\na \u2014 2\n\n= B&B > fA >* @B Q\nEvent Azure Managed Import / Logic Functions Azure GitHub.\nHubs Storage Partners Export APIs Apps Devops\n\n46\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 47 of 89 PagelD#: 47\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nMonitor Azure DNS\n\nArticle + 01/30/2025 + 2 contributors 4 Feedback\n\nIn this article\n\nCollect data with Azure Monitor\nUse Azure Monitor tools to analyze the data\nExport Azure Monitor data\n\nUse Kusto queries to analyze log data\n\nShow 2 more\n\nAzure Monitor collects and aggregates metrics and logs from your system to\nmonitor availability, performance, and resilience, and notify you of issues affecting\nyour system. You can use the Azure portal, PowerShell, Azure CLI, REST API, or client\nlibraries to set up and view monitoring data.\n\nDifferent metrics and logs are available for different resource types. This article\ndescribes the types of monitoring data you can collect for this service and ways to\nanalyze that data.\n\nhttps://learn.microsoft.com/en-us/azure/dns/monitor-dns\n127. As an additional example, Microsoft monitors the operational status of its DNS servers, for\n\ninstance through the Azure Service Health service.\n\nService Health notifications\n\n+, | Summarize this article for me\n\nIn this article\n\nView Service Health notifications\nService Health notification types\n\nRelated content\n\nAzure Service Health notifications are system-generated alerts that inform you about Azure\nservice problems or events that affect your resources. The subscription\u2019s Azure activity log\nrecords these notifications as part of logging many events in Azure. The Azure portal then\ndisplays them under Azure Service Health.\n\nWhen Azure needs to communicate something about service health, such as an outage,\nupcoming maintenance, or an account-specific alert, it creates a Service Health event in your\n\nactivity log.\n\nhttps://learn.microsoft.com/en-us/azure/service-health/service-health-notifications-properties\n47\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 48 of 89 PagelD#: 48\n\n128. Microsoft consolidates the events to form consolidated events, and processes the\nconsolidated events. For instance, Azure Monitor collects activity logs, resource logs, metrics, and\nother telemetry which can be routed to a Log Analytics workspace to be queried, correlated,\n\naggregated, filtered, and transformed.\n\nActivity log in Azure Monitor\n\n+, | Summarize this article for me\n\nAzure Monitor records management operations for your Azure resources through the activity log\nfeature. The activity log records operations like creating a virtual machine, changing a key vault\naccess policy, or Resource Manager deployment errors. These management operations are also\ncalled contro/ plane operations. Use the activity log to review or audit this information, or create\n\nan alert to be proactively notified when an event occurs.\n\nIn contrast to the activity log, Azure resource logs capture data plane operations performed\nwithin a resource. For example, these operations include getting a secret from a key vault or\nmaking a request to a database. Resource logs aren't collected by default and require\n\nconfiguration with a diagnostic setting.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/platform/activity-log\n129. Further, Microsoft Sentinel allows Windows DNS server logs to be streamed and\n\nfiltered via the Azure Monitor Agent.\n\n48\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 49 of 89 PagelD#: 49\n\nDNS over AMA connector reference\n- available fields and normalization\n\nschema\n\n+, Summarize this article for me\n\nMicrosoft Sentinel allows you to stream and filter events from your Windows Domain Name\nSystem (DNS) server logs to the ASimDnsActivityLog normalized schema table. This article\ndescribes the fields used for filtering the data, and the normalization schema for the Windows\n\nDNS server fields.\n\nThe Azure Monitor Agent (AMA) and its DNS extension are installed on your Windows Server to\nupload data from your DNS analytical logs to your Microsoft Sentinel workspace. You stream and\n\nfilter the data using the Windows DNS Events via AMA connector.\n\nhttps://learn.microsoft.com/en-us/azure/sentinel/dns-ama-fields\n\n49\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 50 of 89 PagelD #: 50\n\nASIM normalized DNS schema\n\nThis table describes and translates Windows DNS server fields into the normalized field names as\n\nthey appear in the DNS normalization schema.\n\n\u201c2 Expand table\n\nWindows DNS __ Normalized field Type Description\n\nfield name name\n\nEventiD EventOriginalType String The original event type or ID\n\nRCODE EventResult String The outcome of the event (success, partial, failure,\nNA).\n\nRCODE parsed EventResultDetails String The DNS response code as defined by IANA.\n\nInterfacelP DvclpAdrr String The IP address of the event reporting device or\ninterface.\n\nAA DnsFlagsAuthoritative Integer Indicates whether the response from the server was\nauthoritative\n\nAD DnsFlagsAuthenticated Integer Indicates that the server verified all of the data in\n\nthe answer and the authority of the response,\naccording to the server policies.\n\nRQNAME DnsQuery String The domain needs to be resolved.\n\nQTYPE DnsQueryType Integer The DNS resource record type as defined by IANA.\nPort SrcPortNumber Integer Source port sending the query.\n\nSource SrclpAddr IP The IP address of the client sending the DNS\n\naddress request. For a recursive DNS request, this value is\ntypically the reporting device's IP, in most cases,\n\n127.0.0.1.\nElapsedTime DnsNetworkDuration Integer The time it took to complete the DNS request.\nGUID DnsSessionld String The DNS session identifier as reported by the\n\nreporting device.\n\nhttps://learn.microsoft.com/en-us/azure/sentinel/dns-ama-fields\n\n130. In maintaining the at least one policy, Microsoft receives, by an adaptive traffic\ncontrol (ATC) policy management mechanism of an administrative master agent (AMA) in the ATC\nadministrative framework, the at least one policy from at least one source. For instance, Azure Traffic\nManager provides adaptive policy-based domain name service (DNS) using Traffic Manager routing\n\nmethods, which are policies that determine how DNS queries are answered.\n\n50\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 51 of 89 PagelD#: 51\n\nTraffic Manager routing methods\n\n+, Summarize this article for me\n\nAzure Traffic Manager supports six traffic routing methods that determine how to route network\ntraffic to service endpoints, helping you optimize traffic flow and improve application availability.\nEach Traffic Manager profile applies one routing method to DNS queries: Priority, Weighted,\nPerformance, Geographic, Multivalue, or Subnet. The routing method determines which endpoint\n\nto return in the DNS response.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\n131. Traffic Manager routing methods are defined using the Azure Portal.\n\nManage an Azure Traffic Manager\nprofile\n\n+, Summarize this article for me\n\nTraffic Manager profiles use traffic-routing methods to control the distribution of traffic to your\ncloud services or website endpoints. This article explains how to create and manage these\n\nprofiles.\n\nCreate a Traffic Manager profile\n\nYou can create a Traffic Manager profile by using the Azure portal. After creating your profile, you\ncan configure endpoints, monitoring, and other settings in the Azure portal. Traffic Manager\nsupports up to 200 endpoints per profile. However, most usage scenarios require only a few of\n\nendpoints.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-manage-profiles\n132. In maintaining the at least one policy, Microsoft further broadcasts the received at least one\n\npolicy to the at least one domain name server in the ATC name server network.\n\nCOUNT Ul: INFRINGEMENT OF THE 7964 Patent\n\n133. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\n\n51\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 52 of 89 PagelD #: 52\n\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n134. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 19 of the \u2019964 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Azure Front Door and/or CDN, and Azure Traffic Manager\nperform a method operable in a framework wherein resources of a content provider are delivered to\nclients from one of a plurality of distinct content delivery network domains distinct from a content\n\nprovider domain.\n\nApproach\n\nA third-party CDN can be integrated into your Azure solution to provide isolation from Microsoft's infrastructure.\nThis isolation provides a high degree of resiliency from disaster scenarios. If an outage or disaster occurs, traffic\nis automatically shifted between Azure Front Door and the alternative CDN. You can use Azure Traffic Manager to\n\ndetect an outage and redirect traffic to the alternative CDN.\n\n\u00a9 Note\n\nMicrosoft offers a CDN interconnect service to route your origin traffic to another CDN with zero data\ntransfer fees. For more information, see Routing preferences.\n\nThe following diagram shows how traffic flows between the CDNs:\n\nRegion 1\n___, TrafficManager \u2122, Azure \u2018 > = ,\n> : > \u00a2\u20ac > Front Door \u2014~ _ i Origin application server\nClient ce \\\nX\n\\\nWeighted mode \\ o- -\nAlways serve Other CDN \u2014 & Origin application server\n\nRegion 2\n\nhttps://learn.microsoft.com/en-us/azure/architecture/guide/networking/global-web-applications/mission-\ncritical-content-delivery\n\n52\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 53 of 89 PagelD #: 53\n\nKey features\n\nIncrease application availability\n\nTraffic Manager monitors your endpoints and provides automatic failover when an endpoint goes\n\ndown, delivering high availability for your critical applications.\n\nImprove application performance\n\nTraffic Manager improves your application's responsiveness by directing traffic to the endpoint\nwith the lowest latency for each user.\n\nService maintenance without downtime\n\nPerform planned maintenance on your applications without downtime. Traffic Manager directs\ntraffic to alternative endpoints while maintenance is in progress.\n\nCombine hybrid applications\n\nTraffic Manager supports external, non-Azure endpoints, enabling hybrid cloud and on-premises\ndeployments including burst-to-cloud, migrate-to-cloud, and failover-to-cloud scenarios.\n\nDistribute traffic for complex deployments\n\nCombine multiple traffic-routing methods with nested Traffic Manager profiles to create\n\nsophisticated and flexible rules that scale to larger, more complex deployments.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\n\nMission-critical global content delivery\n\n+, | Summarize this article for me\n\nContent delivery networks (CDNs) offer a range of capabilities to optimize performance for users, including\nglobal layer 7 load balancing and optimized network routing. Caching is also a common way to reduce load on\nthe backend services and provide further resiliency to a range of issues. CDNs, including Azure Front Door,\n\nprovide caching at the network edge.\n\nCDNs are an essential component in some solution architectures, so it\u2019s an industry best practice for mission-\ncritical workloads to use multiple CDNs to achieve a higher level of uptime. If one CDN experiences outage or\ndegraded performance, your traffic is automatically diverted to another CDN.\n\nAs mentioned in the previous article in this series, Azure Front Door is designed to provide the utmost resiliency\nand availability not only for our external customers, but also for multiple properties across Microsoft. While\nMicrosoft offers an industry-leading service level agreement (SLA) for Azure Front Door\u2019, if you have a mission-\ncritical application that demands even higher SLA, you will need to rely on multiple CDNs. Consider the\nimplications of this approach. Each CDN provides a separate network path to your application servers, and you\n\nneed to configure and test each CDN separately.\n\nThis article describes an approach for using Azure Front Door with another CDN. This approach is suitable for\nsolutions that rely heavily on caching for delivering static content delivery, media, and high-scale eCommerce\n\napplications.\n\nhttps://learn.microsoft.com/en-us/azure/architecture/guide/networking/global-web-applications/mission-\ncritical-content-delivery\n\n135. Further, Microsoft obtains content provider policies relating to delivery of resources\n\n53\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 54 of 89 PagelD#: 54\n\nwhere those policies relate to a relative load share for each of the plurality of CDN domains.\n\nTraffic Manager routing methods\n\n+, Summarize this article for me\n\nAzure Traffic Manager supports six traffic routing methods that determine how to route network\ntraffic to service endpoints, helping you optimize traffic flow and improve application availability.\nEach Traffic Manager profile applies one routing method to DNS queries: Priority, Weighted,\nPerformance, Geographic, Multivalue, or Subnet. The routing method determines which endpoint\nto return in the DNS response.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\nThe following traffic routing methods are available in Traffic Manager:\n\ne Priority: Select Priority routing when you want to use a primary service endpoint for all\ntraffic. You can provide multiple backup endpoints in case the primary endpoint or one of the\nbackup endpoints is unavailable.\n\n\u00a2 Weighted: Select Weighted routing when you want to distribute traffic across a set of\nendpoints based on their weight. Set the weight the same to distribute evenly across all\nendpoints.\n\ne Performance: Select Performance routing when you have endpoints in different geographic\nlocations and you want users to use the closest endpoint for the lowest network latency.\n\n\u00a2 Geographic: Select Geographic routing to direct users to specific endpoints (Azure, External,\nor Nested) based on the geographic location of their DNS queries. This routing method helps\nyou comply with scenarios such as data sovereignty mandates, localization of content and\nuser experience, and measuring traffic from different regions.\n\ne Multivalue: Select MultiValue for Traffic Manager profiles that can only have IPv4/IPv6\naddresses as endpoints. When this profile receives a query, it returns all healthy endpoints.\n\ne Subnet: Select Subnet traffic-routing method to map sets of user IP address ranges to a\nspecific endpoint. When Traffic Manager receives a request, it returns the endpoint mapped\n\nto that request's source IP address.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\n136. Microsoft further selects one of the plurality of CDN domains based on the content\n\nprovider policies, and provides clients with a domain name associated with the selected CDN.\n\n54\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 55 of 89 PagelD #: 55\n\nWhat is Azure Traffic Manager?\n\n+, | Summarize this article for me\n\nAzure Traffic Manager is a DNS-based traffic load balancer that distributes traffic to your public-\nfacing applications across global Azure regions. Traffic Manager provides your public endpoints\n\nwith high availability and quick responsiveness.\n\nTraffic Manager uses DNS to direct client requests to the appropriate service endpoint based on a\ntraffic-routing method. Traffic Manager also provides health monitoring for every endpoint. The\nendpoint can be any Internet-facing service hosted inside or outside of Azure. Traffic Manager\nprovides a range of traffic-routing methods and endpoint monitoring options to suit different\napplication needs and automatic failover models. Traffic Manager is resilient to failure, including\n\nthe failure of an entire Azure region.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\ne Traffic Manager uses weighted routing mode, has two endpoints, and is configured to always serve traffic.\nDuring normal operations, Traffic Manager sends all requests through Azure Front Door.\n\nIf Azure Front Door becomes unavailable, turn off the Azure Front Door endpoint. Traffic Manager then\n\nsends all requests through the alternative CDN.\n\ne Azure Front Door processes and routes most of your application traffic. Azure Front Door routes traffic to\nthe appropriate origin application server, and it provides the primary path to your application. If Azure\n\nFront Door is unavailable, traffic is automatically redirected through the secondary path.\ne An alternative CDN is configured to send traffic to each origin server.\n\ne Your origin application servers need to be ready to accept traffic from both Azure Front Door and another\n\nCDN, at any time.\n\nhttps://learn.microsoft.com/en-us/azure/architecture/guide/networking/global-web-applications/mission-\ncritical-content-delivery\n\nCOUNT IV: INFRINGEMENT OF THE \u2019899 PATENT\n\n137. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n138. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 1 of the \u2019899 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Azure Front Door and/or CDN provides content delivery\n\nsystems with a plurality of computers configured to run CD services.\n\n55\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 56 of 89 PagelD #: 56\n\nAV AUI g-m Cola} 111 DL-IIV Tava (1A ol ag\n\nLets aCe) Reel cues pa ae anime Lee Cre}\n\nTry Azure for free eer ace es ect\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nAzure Content Delivery Network offers a globa\u2019 solution \u2018or rapidly delivering content. Save bandwidth and improve responsiveness when\nIncrease speed and scalability for an optimal encoding or distributing gaming softwere, firmware updates, and loT endpoints. Reduce load times for weksites, mobile apps, and streaming\nuser experience media to increase user satisfaction globally.\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\n* I a\n\n2: Z| i a\nStream media and downlozc large tiles quickly with Provide a scalable sclution to handle worldwide trattic Integrate seamlessly with your Azure services to Protect content with custom domain HTTPS, DDoS,\noptimized delivery, spikes and instantaneous high loads. activate within \u201cninutes. anc WAF protection.\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nWith Azure CDN from Microsoft, you can monitor resources in the following ways to help you\n\ntroubleshoot, track, and debug issues.\n\n\u00a9 Raw logs provide rich information about every request that CDN receives. Raw logs differ from\nactivity logs. Activity logs provide visibility into the operations done on Azure resources.\n\n\u00a9 Metrics, which display four key metrics on CDN, including Byte Hit Ratio, Request Count, Response\nSize and Total Latency. It also provides different dimensions to break down metrics.\n\n\u00a9 Alert, which allows customer to set up alert for key metrics\n\n* More metrics, which allow customers to use Azure Log Analytics to enable more metrics of value.\n\nWe also provide query samples for a few other metrics under Azure Log Analytics.\n\nhttps://learn.microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n\n56\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 57 of 89 PagelD #: 57\n\nConfiguration - Azure portal\n\nTo configure Raw logs for your Azure CDN from Microsoft profile:\n1. From the Azure portal menu, select All Resources > > <your-CDN-profile>.\n2. Under Monitoring, select Diagnostics settings.\n\n3. Select + Add diagnostic setting.\n\nai myCDN | Diagnostic settings + & x\n\nSearch (Ctrl+ C) Refresh () Provide feedback\n\n@ Overview\n\nare used to configure streaming expert of platform logs and metrics for a resource to the destination of\nfe tic settings to send differant logs and metrics to independent\n\nGl Activity log\n\nFa Access control (IAM)\n\nDiagnostics settings\n\n@ Tags Name Storage account Event hub Log Analytics works... Edit setting\n\n& Diagnose and solve problems No diagnostic settings defined\n\nserings\n\nI! Properties Click \u201cAdd Disgnostic se\n\nnfigure the collection of the following data:\n\nQuickstart \u00a9 AzureCdnAccessLog\n\u00a9 AllMetrics\nBi Locks\n\nMonitoring\n\nMB Alerts\n\nG Diagnostic settings\n\n\u00a9 Logs\n\nhttps://learn.microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n\nMetrics\n\nAzure CDN from Microsoft is integrated with Azure Monitor and publishes four CDN metrics to help track,\n\ntroubleshoot, and debug issues.\n\nThe Metrics are displayed in charts and accessible via PowerShell, CLI, and API. The CDN metrics are free\nof charge.\n\nAzure CDN from Microsoft measures and sends its metrics in 60-second intervals. The metrics can take up\n\nto 3 mins to appear in the portal.\n\nFor more information, see Azure Monitor metrics.\n\nhttps://learn.microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n\n57\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 58 of 89 PagelD #: 58\n\nMetrics supported by Azure CDN from Microsoft\n\n.> Expand table\n\nMetrics Description Dimensions\nBytes Hit The percentage of egress from CDN cache, computed against the total egress. Endpoint\nratio*\n\nRequestCount The number of client requests served by CDN. Endpoint\n\nClient country.\nClient region.\nHTTP status.\nHTTP status\ngroup.\n\nResponseSize The number of bytes sent as responses from CDN edge to clients. Endpoint\nClient country.\nClient region.\nHTTP status.\nHTTP status\n\ngroup.\nTotalLatency The total time from the client request recetved by CDN until the last response Endpoint\nbyte send from CDN to client. Client country.\n\nClient region.\nHTTP status.\n\nHTTP status\ngroup.\nhttps://learn.microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n139. These CD services produce event output relating to their respective operations, and\n\nthat output is provided to CD services. Microsoft\u2019s Azure Front Door and/or CDN also obtains event\ninput from CD services, and produces, as respective state output, state information based on the event\n\ninput from the CD services.\n\n58\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 59 of 89 PagelD #: 59\n\nMetrics configuration\n1. From the Azure portal menu, select All Resources > > <your-CDN-profile>.\n2. Under Monitoring, select Metrics:\n\n3. Select Add metric, select the metric to add:\n\ni myCDN | Metrics x\n\niti\n+ Newchart \u00a9) Refresh [eP Share \\ (5) Feedback <7 focal Tirme: Last 24 hour\nChart Tithe\n\u2018Be Add metric | *y [& Line chan (2D) few alert rule x Pin to dashboard\nScope Metric Namespace fic Aggregation \u00b0\n\nfii Metrics\n\nDiagnostic settings\n\nhttps://learn microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n\nMetrics\n\nAzure CDN from Microsoft is integrated with Azure Monitor and publishes four CDN metrics to help track,\n\ntroubleshoot, and debug issues.\n\nThe Metrics are displayed in charts and accessible via PowerShell, CLI, and API. The CDN metrics are free\nof charge.\n\nAzure CDN from Microsoft measures and sends its metrics in 60-second intervals. The metrics can take up\n\nto 3 mins to appear in the portal.\n\nFor more information, see Azure Monitor metrics.\n\nhttps://learn microsoft.com/en-us/azure/cdn/monitoring-and-access-log\n\n140. Further, Microsoft\u2019s Azure Front Door and/or CDN maintains service configuration\ninformation specifying associations between CD service instances, obtains state information from\nsaid CD service instances, and modifies said service configuration information to produce modified\n\nservice configuration information based on the state information.\n\n59\n\fCase 2:26-cv-00681 Document1i Filed 08/11/26 Page 60 of 89 PagelD #: 60\n\nAzure Monitor is a comprehensive monitoring solution for collecting, analyzing, and responding to monitoring data from\nyour cloud and on-premises environments. You can use Azure Monitor to maximize the availability and performance of\nyour applications and services. It helps you understand how your applications are performing and allows you to\n\nmanually and programmatically respond to system events.\n\nAzure Monitor collects and aggregates the data from every layer and component of your system across multiple Azure\nand non-Azure subscriptions and tenants. It stores it in a common data platform for consumption by a common set of\ntools that can correlate, analyze, visualize, and/or respond to the data. You can also integrate other Microsoft and non-\nMicrosoft tools.\n\nCollect, route Consume\nCe) ts) <= Telesis el csie\nand transform \u2014\n\nlaitee Flea al e8) Ooi:\n\nThe diagram above shows an abstracted view of the monitoring process. A more detailed breakdown of the Azure\nMonitor architecture is shown in the High level architecture section below.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nHigh level architecture\n\nAzure Monitor can monitor these types of resources in Azure, other clouds, or on-premises:\n\nApplications\n\nVirtual machines\n\u00ae Guest operating systems\n\nContainers including Prometheus metrics\n\u00ae Databases\n\nSecurity events in combination with Azure Sentinel\n\nNetworking events and health in combination with Network Watcher\n* Custom sources that use the APIs to get data into Azure Monitor\n\nYou can also export monitoring data from Azure Monitor into other systerns so you can:\n\n\u00a9 Integrate with other third-party and open-source monitoring and visualization tools\n* Integrate with ticketing and other ITSM systems\n\nif you're a System Center Operations Manager (SCOM) user, Azure Monitor now includes Azure Monitor SCOM Managed\nInstance (SCOM Ml). Operations Manager MI is a cloud-hosted version of Operations Manager and allows you to move\nyour on-premises Operations Manager installation to Azure.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\n60\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 61 of 89 PagelID#: 61\n\nThe following diagram shows a high-level architecture view of Azure Manitor.\n\nData Sources Data Platform Consumption\n\n\u00a9 Azure Monitor\n\n= Insights\nge Re\nMetrics Application Container VM Network\no Visualize\nApps / Workloads a | Y\nco\nLogs\nTe i Workbooks Dashboards PowerBl*  Grafana*\nAzure Platform Analyze\n\u00bb\nTraces \u2018il ol) s\nCustom Sources Bw oo = v\nMetric Log Change\nExplorer Analytics Analysis\nChanges\n\nEB} Respond\n& -- %\n\nAlOps Alerts and Pleased\nActions\n= SCOM Managed Instance\n\nDatabases a |\n\ni Ops Console\" Power BI\"\n\nIntegrate\n\u2014 or\n= G \u00bb - 38 QO\n* sa\nEvent Azure Managed Import / Logic Functions Azure GitHub,\nHubs Storage Partners Export APIs = Apps Devops\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nData sources\n\nAzure Monitor can collect data from multiple sources.\n\nThe diagram below shows an expanded version of the data source types that Azure Monitor can gather monitoring data\n\nfrom.\n\nCustom Apps\n\nBD @ & Apps/Workloads\nlaaS Workloads\n\nContainer\n\nAa Infrastructure\nOperating System\n\nAzure Resources\nA Azure Platform Azure Subscription\n\nAzure Tenant\n\nAa Hi Custom Sources Custom Sources\n\nKey A a a\n\nIn Other On-\nAzure Clouds premises Q\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\n61\n\fCase 2:26-cv-00681 Document1 _ Filed 08/11/26 Page 62 of 89 PagelD #: 62\n\nCOUNT V: INFRINGEMENT OF THE \u00b0876 PATENT\n\n141. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n142. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 1 of the \u2019876 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Microsoft Azure Front Door and/or CDN, Azure Monitor,\n\nAzure Peering Service comprise a CDN with multiple CD services with a collector system.\n\nPAVAU c-M@olale=111 LIV LAV Lane 4\n\naol le Rennes sme aan eer)\n\nTry Azure for free Cee eee eed\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nAzure Content Delivery Network offers a globa\u2019 solution \u2018or rapidly delivering content. Save bandwidth and improve responsiveness when\nIncrease speed and scalability for an optimal encoding or distributing gaming softwere, firmware updates, and loT endpoints. Reduce load times for websites, mobile apps, and streaming\nuser experience media to increase user satisfaction glokally.\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nand downlozc large files quickly with rovi\nspike:\n\nclution to handle worldwide taffic Integr\nneous high leads.\n\nsstom domain HTTPS, DDUS.\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\n62\n\fCase 2:26-cv-00681 Document1 _ Filed 08/11/26 Page 63 of 89 PagelD #: 63\n\n\u2018Geographical area Geographical area =\n\nBranch office\n1 aca\n\nHO = Internet\n\nInternet\n\nDistributed cloud application can\nNeed etree be hosted in any Microsoft DC and\ncan be accessed from any location\n\nCustomers can also opt for Peering Service telemetry such as user latency\nmeasures to the Microsoft network and BGP route monitoring by registering the\nPeering Service connection in the Azure portal.\n\nTo use Peering Service, customers aren't required to register with Microsoft. The\nonly requirement is to contact a Peering Service partner to get the service. To opt\nin for Peering Service telemetry, customers must register for it in the Azure\n\nportal.\n\nFor instructions on how to register a Peering Service, see Create, change, or\n\ndelete a Peering Service connection using the Azure portal.\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\nWhat is Peering Service?\n\nPeering Service is:\n\ne An IP service that uses the public internet.\n\ne Acollaboration platform with service providers and a value-added service\nthat's intended to offer optimal and reliable routing via service provider\npartners to the Microsoft cloud over the public network.\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\n63\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 64 of 89 PagelD#: 64\n\nMonitoring platform\n\nService monitoring is offered to analyze user traffic and routing. The following\nmetrics are available in the Azure portal to track the performance and availability\n\nof your Peering Service connection:\ne Ingress and egress traffic rates\ne BGP session availability\n\u00ab Packet drops\n\u00ab Flap events\n\u00ae Latency\n\n\u00ab Prefix events\n\nPeering Piatform\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\n143. Azure Front Door and/or CDN, Azure Monitor, Azure Peering Service further\nreceive multiple event streams of event data, said multiple event streams comprising event data from\na plurality of CD services in the CDN, and said plurality of CDN services including a first CD\nservices, each event of said event stream comprising a timestamp for said event and information\n\nrelating to said event.\n\n64\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 65 of 89 PagelD #: 65\n\nView metrics for an internet\npeering\n\nArticle = 11/22/2024 = 1 contributor \u00a2} Feedback\n\nIn this article\n\nView received routes\nView peering metrics\nView registered prefix latency\n\nView customer prefix latency\n\nShow 2 more\n\nIn this article, as an internet peering partner (direct or exchange) in Azure\nPeering Service, you learn how to use the Azure portal to view metrics associated\n\nwith a direct peering or an exchange peering.\n\nhttps://learn.microsoft.com/en-us/azure/internet-peering/walkthrough-monitoring-telemetry\n\nView received routes\n\nYou can view routes that are announced to Microsoft by using the Azure portal.\n1. In the Azure portal, go to the peering.\n2. On the service menu under Settings, select Received Routes.\n\nFa Demo Peering | Received routes\n\nSearch\n\nvere a\n- One 6B For Peering Senice partrers. prefores smaller than /24 would appear here cry if they are tagged with the MARS\niN Tey\n\n#1 t P\nDiagnose and soe problems\n: Received UTC Prefix AS path Next hop\nSontings\niS inderwation 203.0. 13.024 1111 2222\n203,.0.115. 0/24 WV 2222\n22/2023 196.571.100.024 1111 2222 92.1160.Cual\n\nhttps://learn.microsoft.com/en-us/azure/internet-peering/walkthrough-monitoring-telemetry\n\n144. Microsoft further produces state data relating to and based information represented\nin said event data of the multiple event streams, and asynchronously responds to queries relating to\n\nsaid state data.\n\n65\n\fCase 2:26-cv-00681\n\nDocument 1 Filed 08/11/26 Page 66 of 89 PageID#: 66\n\nView peering metrics\n\nYou can view the following metrics for a peering on the Connections pane of a\npeering:\n\nSession availability\nIngress traffic rate\nEgress traffic rate\nFlap events count\n\nPacket drop rate\n\n=, DemaPeering | Connection\n\nli li lisse lic liz li .\n\nhttps://learn.microsoft.com/en-us/azure/internet-peering/walkthrough-monitoring-telemetry\n\nView Peering Service metrics\n\nAll Peering Service resources display the session availability metrics for their\nPeering Service on the overview pane of a Peering Service resource:\n\nProvider primary peering session availability: Indicates the state of the\nBorder Gateway Protocol (BGP) session between the Peering Service\n\nprovider and Microsoft at the primary peering location.\n\nProvider backup peering session availability: Indicates the state of the BGP\nsession between the Peering Service provider and Microsoft at the backup\n\npeering location if one is selected for the Peering Service resource.\n\na myPeering &\n\n66\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 67 of 89 PagelD #: 67\n\nhttps://learn.microsoft.com/en-us/azure/internet-peering/walkthrough-monitoring-telemetry\n\nData Collection,\nData Sources Routing, and Transform Data Platform Consumption\n\n(\u201c) Azure Monitor\nInsights\n\n9 &\naap\nvo ;\n\u2018Custom Apps \u2018App SDK ee Application Container VM Network\nWah Apo Workionas w\nJaaS Workloads ce\nAgents) u Visualize\nContainer 7 a\nA QE Infrastructure \u2014 Der = Workbooks Dashboards Power BI\" Grafana\n\u2018Opersting System wu\nAnalyze\nies Setings mise iM i Ss\nReows i as v\n5 Ze Metric Log Change\nA Azure Platform Azure Subscription cae ee haste a\nAzure Tenant 7\nsure Tenan =\n5 =\nA. @E Custom Sources Custom Sources &\nAlOps Alerts and Autoscale\nActions\nIntegrate\n= 6s 1 Pp G\nEvent Arare Managed Inpoet Logie Fupetom Azure Gitta\nHubs Storage Partners Export APIs Apps Devops\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/fundamentals/data-platform\n145. \u2014 Microsoft further, in response to queries from CD services relating to said state data,\nprovides said state data to said first CD service, wherein said state data are used to inform a peering\n\npolicy of a set of peer caches.\n\nBackground\n\nMicrosoft 365, Dynamics 365, and any other Microsoft SaaS services are hosted\nin multiple Microsoft datacenters and can be accessed from any geographic\nlocation. The Microsoft global network has Microsoft Edge point-of-presence\n(PoP) locations around the world where it can connect to an end user via their\nservice providers.\n\nMicrosoft and partner service providers ensure that the traffic for the prefixes\nregistered with a Peering Service connection enters and exits the nearest\nMicrosoft Edge PoP locations on the Microsoft global network. Microsoft ensures\nthat the networking traffic egressing from the prefixes registered with Peering\nService connections takes the nearest Microsoft Edge PoP locations on the\nMicrosoft global network.\n\n55+Regions\n10-100s of branches\n\nar curtorner 150 * Locations =\n200+ Peering locations ==>\n35004 Natworks\n\n1+ \u2014 \u00a9\newok Front Door -\nA nae Ne Public Service\nIsP Microsoft Global\n\nMobile Network\n\nt--------------------------4 isp Se\nCustomer Branch i\n\n6 Public Se-vicas or Sa cen be hosted in any Microsoft DC and cen be sccessed\nfrom arty location: Office 365, Dynamics 365 or any SaaS service running on Azure\n\nPr eer iaicbet set Eniencer. Cymnertc Sie Aceaternson)\n\nEdge Point of Presence\n\nCc Microsoft Global Networic one of the largest private network designed to\navailability. capacity, and the flexibility ta meet any demand\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\n67\n\fCase 2:26-cv-00681\n\nWhy use Peering Service?\n\nDocument 1\n\nFiled 08/11/26\n\nPage 68 of 89 PagelD #: 68\n\nEnterprises looking for internet-first access to the cloud or considering SD-WAN\n\narchitecture or with high usage of Microsoft SaaS services need robust and high-\n\nperforming internet connectivity. Customers can make that transition happen by\n\nusing Peering Service. Microsoft and service providers partnered to deliver\n\nreliable and performance-centric public connectivity to the Microsoft cloud.\n\nSome of the key customer features are listed here:\n\n\u00ae Best public routing over the internet to Microsoft Azure Cloud Services for\n\noptimal performance and reliability.\n\n* Ability to select the preferred service provider to connect to the Microsoft\n\ncloud.\n\n* Traffic insights such as latency reporting and prefix monitoring.\n\n\u00ab Optimum network hops (AS hops) from the Microsoft cloud.\n\ne Route analytics and statistics: Events for BGP route anomalies and\n\nsuboptimal routing.\n\nhttps://learn.microsoft.com/en-us/azure/peering-service/about\n\nRouting architecture overview\n\n*, | Summarize this article for me\n\nSelect the Azure Front Door tier:\n\nStandard/Premium | Classic\n\nAzure Front Door traffic routing takes place over multiple stages. First, traffic is routed from the\n\nclient to the Front Door. Then, Front Door uses your configuration to determine the origin to\n\nsend the traffic to. The Front Door web application firewall, routing rules, rules engine, and\n\ncaching configuration can all affect the routing process.\n\nThe following diagram illustrates the routing architecture:\n\nName resolution by Azure Front Door\nATM profile returns unicast IP of PoP\n\n\u2019\n\nConnect to Azure Front Door edge\nlocation unicast IP\n\n*\n\nMatch to Azure Front Door profile,\nestablish TLS connection\n\n+\nEvaluate WAF rules\n+\nMatch to Azure Front Door route,\nselect origin group\n+\nEvaluate rules engine rules\n+\nRetum cached content\n+\n\nSelect origin from origin group\n\nForward request to origin\n\nhttps://learn.microsoft.com/en-us/azure/frontdoor/front-door-routing-architecture\n\n68\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 69 of 89 PagelD #: 69\n\nDelivery of modern apps and architectures\nModernize your internet-first applications on Azure with cloud-native experiences:\n\n\u00a2 Integrate with DevOps-friendly command-line tools across SDKs of different languages,\n\nBicep, Azure Resource Manager templates, the Azure CLI, and PowerShell.\n\u00a2 Define your own custom domain with flexible domain validation.\n\n\u00a2 Load balance and route traffic across origins. Use intelligent health probe monitoring across\n\napps or content hosted in Azure or anywhere.\n\n\u00a2 Integrate with other Azure services, such as Azure DNS, the Web Apps feature of Azure App\n\nService, Azure Storage, and many more for domain and origin management.\n\n\u00a2 Move your routing business logic to the edge with enhanced rules engine capabilities,\n\nincluding regular expressions and server variables.\n\n\u00a2 Analyze built-in reports with an all-in-one dashboard for both Azure Front Door and\n\nsecurity patterns.\n\n\u00a2 Monitor your Azure Front Door traffic in real time, and configure alerts that integrate with\n\nAzure Monitor.\n\n\u00a2 Log each Azure Front Door request and failed health probes.\n\nhttps://learn.microsoft.com/en-us/azure/frontdoor/front-door-overview\n\nCOUNT VI: INFRINGEMENT OF THE 7066 PATENT\n\n146. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n147. \u2014_ Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 14 of the \u2019066 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Azure Web Application Firewall (\u201cWAF\u2019\u201d) functionality is\nimplemented in software running on Microsoft\u2019s global edge network and evaluates incoming\nrequests against configured rules. For instance, Web Application Firewall receives content requests\nincluding first sets of attribute values and uses at least one of the attribute values from the first set of\n\nattribute values to determine a second set of attribute values.\n\n69\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 70 of 89 PagelD #: 70\n\nWhat is Azure Web\nApplication Firewall?\n\n+, Summarize this article for me\n\nApplies to: V Application Gateway V Front Door Standard/Premium V Front Door (classic)\nCDN Standard from Microsoft (classic)\n\nAzure Web Application Firewall provides centralized protection of your web applications from\ncommon exploits and vulnerabilities. Web applications increasingly encounter malicious attacks\nthat exploit commonly known vulnerabilities. SQL injection and cross-site scripting are among the\n\nmost common attacks.\n\nhttps://learn.microsoft.com/en-us/azure/web-application-firewall/overview\n\na RRM\n\n@\nEdge 1 | Vv Vv\nx x x Global WAF policy\nCustom Access Control\nWAF Rate Limit\nee OWASP TOP 10 Protection\n\na a\n\nMicrosoft Public\n\nGlobal Network ; Network\nv v\n\ntj \u00a9\nAB \u00a9\na \u00b0\u00b0 a a,\n\nOne or More Other Cloud On-premises\nAzure Regions\n\nhttps://learn.microsoft.com/en-us/azure/web-application-firewall/overview\n\nExample\n\nIn the following diagram, WAF policies get processed first. Then the rule set configuration\nappends a response header. The header changes the max-age of the cache control if the match\n\ncondition is true.\n\nEdge Location Response Header Action: Cache Control\n\nE_G)- #\u2014 \u00bb ==\u2014-&\n\nWaF Origin Group\n\n3\n\nRule Set\n\n|\n\nResponse Heoder Action \u00bb Cache Control\n\nMatch Condition = True\n\noto aes\ner opes Tosno\n\nwewnm.contoso.com\n\nPi Azure Front Door Standard/Premivem\n\nBX Microsot Global Network\n\n70\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 71 of 89 PagelID#: 71\n\nhttps://learn.microsoft.com/en-us/azure/frontdoor/front-door-rules-engine\n\ne Match condition\n\nDefines a match variable, an operator, and a match value. Each rule can contain multiple\nmatch conditions. A match condition might be based on -location, client IP addresses\n(CIDR), size, AS Number, Client Fingerprint, Service Tag, or string match. String match can be\n\nagainst a list of match variables.\nhttps://learn.microsoft.com/en-us/azure/web-application-firewall/afds/waf-front-door-custom-rules\n\nRemote address\n\nThe remote address match condition identifies requests based on the requester's location or IP\n\naddress. You can specify multiple values to match, which can be combined using OR logic.\n\ne Use CIDR notation when specifying IP address blocks. The syntax for an IP address block is\nthe base IP address followed by a forward slash and the prefix size. For example:\n\no IPv4 example: 5.5.5.64/26 matches any requests that arrive from addresses 5.5.5.64\nthrough 5.5.5.127.\n\no IPv6 example: 1:2:3:/48 matches any requests that arrive from addresses 1:2:3:0:0:0:0:0\nthrough 1:2:3: ffff-ffff-fffF: FFF: FFF.\n\ne When you specify multiple IP addresses and IP address blocks, \u2018OR\u2019 logic is applied.\n\no IPv4 example: if you add two IP addresses 1.2.3.4 and 10.20.30.40, the condition is\nmatched for any requests that arrive from either address 1.2.3.4 or 10.20.30.40.\n\no IPv6 example: if you add two IP addresses 1:2:3:4:5:6:7:8 and\n10:20:30:40:50:60:70:80, the condition is matched for any requests that arrive from\neither address 1:2:3:4:5:6:7:8 or 10:20:30:40:50:60:70:80.\n\n\u00a2 The remote address represents the original client IP that is either from the network\nconnection or typically the X-Forwarded-For request header if the user is behind a proxy.\nUse the socket address match condition (available in Standard/Premium), if you need to\n\nmatch based on the TCP request's IP address.\n\nhttps://learn.microsoft.com/en-us/azure/frontdoor/rules-match-conditions\n\nhostname The host name in the request from the client.\nTo access this server variable in a match condition, use Host name.\n\ngeo_country Indicates the requester's country/region of origin through its\ncountry/region code.\nTo access this server variable in a match condition, use Remote\naddress and configure the Operator to Geo Match or Geo Not\nMatch.\n\nhttp_method The method used to make the URL request, such as GET or POST.\nTo access this server variable in a match condition, use Request\nmethod.\n\nhttps://learn.microsoft.com/en-us/azure/frontdoor/rule-set-server-variables\n148. Web Application Firewall further traverses a hierarchy of decision nodes, where each\n\ndecision node implements business logic based on one of the attribute values from the first set of\n71\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 72 of 89 PagelD#: 72\n\nattribute values or the second set of attribute values; and yields a decision from a last node in the\n\nhierarchy, wherein the decision dictates how to respond to the content request.\n\nPriority, action types, and match conditions\n\nYou can control access with a custom WAF rule that defines a priority number, a rule type, an\n\narray of match conditions, and an action.\nPriority\n\nA unique integer that describes the order of evaluation of WAF rules. Rules with lower-\npriority values are evaluated before rules with higher values. The rule evaluation stops on\n\nany rule action except for Log. Priority numbers must be unique among all custom rules.\n\n\u00a2 Action\n\nDefines how to route a request if a WAF rule is matched. You can choose one of the\n\nfollowing actions to apply when a request matches a custom rule.\n\n\u00a9 Allow: The WAF allows the request to process, logs an entry in WAF logs, and exits.\n\n\u00a9 Block: Request is blocked. The WAF sends a response to a client without forwarding the\nrequest further. The WAF logs an entry in WAF logs and exits.\n\n\u00a9 Log: The WAF logs an entry in WAF logs and continues to evaluate the next rule in the\npriority order.\n\n\u00a9 Redirect: The WAF redirects the request to a specified URI, logs an entry in WAF logs, and\n\nexits.\ne Match condition\n\nDefines a match variable, an operator, and a match value. Each rule can contain multiple\nmatch conditions. A match condition might be based on geo-location, client IP addresses\n(CIDR), size, AS Number, Client Fingerprint, Service Tag, or string match. String match can be\n\nagainst a list of match variables.\n\nhttps://learn.microsoft.com/en-us/azure/web-application-firewall/afds/waf-front-door-custom-rules\n\nUse custom rules\n\nAfter you identify what's causing a WAF rule match, you can use custom rules to adjust how the\nWAF responds to the event. Custom rules are processed before managed rules. They can contain\n\nmore than one condition, and their actions can be Allow, Deny, Log, or Redirect.\n\nA Warning\n\nWhen a request matches a custom rule, the WAF engine stops processing the request.\nManaged rules won't be processed for this request and neither will other custom rules with a\n\nlower priority.\n\nThe following example shows a custom rule with two conditions. The first condition looks for the\ncomment value in the request body. The second condition looks for the /api/Feedbacks/ value\nin the request URI.\n\nhttps://learn.microsoft.com/en-us/azure/web-application-firewall/afds/waf-front-door-tuning\n\n72\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 73 of 89 PagelD#: 73\n\nCOUNT VIL: INFRINGEMENT OF THE \u00b0738 PATENT\n\n149. __ Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n150. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 1 of the \u2019738 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Azure Traffic Manager, Azure Monitor, and Azure Service\nHealth receive from subscribers, via a web-based graphical user interface, one or more policies for\n\ndistribution of service requests to one or more servers in a subscriber server network.\n\nThe Azure portal\n\nThe Azure portal is a web-based, unified console that provides an alternative to command-line tools. With the Azure\nportal, you can manage your Azure subscription using a graphical user interface. You can build, manage, and monitor\neverything from simple web apps to complex cloud deployments in the portal. The Monitor section of the Azure portal\nprovides a visual interface that gives you access to the data collected for Azure resources and an easy way to access the\ntools, insights, and visualizations in Azure Monitor.\n\n>) Monitor | Overview\n\nInsights\n\n@ sopication insghs iis Gonsdoecincas B vurwigts\n\norkloadg\n\nBus (previe\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\n73\n\fCase 2:26-cv-00681 Document1i - Filed 08/11/26 Page 74 of 89 PagelD#: 74\n\nAzure Monitor is a comprehensive monitoring solution for collecting, analyzing, and responding to monitoring data from\n\nyour cloud and on-premises environments. You can use Azure Monitor to maximize the availability and performance of\n\nyour applications and services. It helps you understand how your applications are performing and allows you to\n\nmanually and programmatically respond to system events.\n\nAzure Monitor collects and aggregates the data from every layer and component of your system across multiple Azure\n\nand non-Azure subscriptions and tenants. It stores it in a common data platform for consumption by a common set of\n\ntools that can correlate, analyze, visualize, and/or respond to the data. You can also integrate other Microsoft and non-\n\nMicrosoft tools.\n\nCollect, route Consume\nNYe)UI ca on NS} Ce) (=) <= Naltaselccie\nand transform \u2014\n\nfi css elo) a6)\n\nTaltsre] felts Alto) Ooi f-1 ec\n\nThe diagram above shows an abstracted view of the monitoring process. A more detailed breakdown of the Azure\n\nMonitor architecture is shown in the High level architecture section below.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nHigh level architecture\n\nAzure Monitor can monitor these types of resources in Azure, other clouds, or on-premises:\n\nApplications\n\nVirtual machines\n\nGuest operating systems\n\nContainers including Prometheus metrics\n\nDatabases\n\nSecurity events in combination with Azure Sentinel\n\nNetworking events and health in combination with Network Watcher\nCustom sources that use the APIs to get data into Azure Monitor\n\nYou can also export monitoring data from Azure Monitor into other systems so you can:\n\nIntegrate with other third-party and open-source monitoring and visualization tools\nIntegrate with ticketing and other ITSM systems\n\nIf you're a System Center Operations Manager (SCOM) user, Azure Monitor now includes Azure Monitor SCOM Managed\nInstance (SCOM Ml). Operations Manager MI is a cloud-hosted version of Operations Manager and allows you to move\n\nyour on-premises Operations Manager installation to Azure.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\n74\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 75 of 89 PagelD#: 75\n\nData Sources Data Platform Consumption\n\n\u201c) Azure Monitor\n\nInsights\nSD\nene Application Container VM Network\nou Visualize\nApps / Workloads 4\ninicexketaee wy Workbooks Dashboards Power BI Grafana\nAzure Platform Anal\nTraces ee \u00ae\nCustom Sources yy nl \u2014\nMetric Log Change\nExplorer Analytics Analysis\nChanges\nRespond\na mw \u00ae%\nAlOps Alerts and Autoscale\nActions\nOM Managed Instance\nDatabases\n= |\naD Ops Console Power Bl\nIntegrate\ntd > 4 * QO QO\nEvent Azure Managed Import / Logic Functions Azure GitHub\nHubs Storage Partners Export APIs Apps Devops Q\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n151. Azure Traffic Manager, Azure Monitor, and Azure Service Health further monitor\n\noperational statuses of some of a plurality of name servers in a name server network that provide\nhostname resolution service for the one more server in the subscriber server network. Azure further,\nbased on said monitoring, when an error or anomalous condition is detected at a particular name\nserver of the name server network, creates policies to indicate the status of the particular name server,\n\nwherein the policy is taken into account when resolving hostnames using the name server network.\n\n75\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 76 of 89 PagelD #: 76\n\nData Type Description and subtypes\n\nApp/Workloads App- Application performance, health, and activity data.\n\nWorkloads - laaS workloads such as SQL server, Oracle or SAP running on a hosted Virtual Machine.\n\nInfrastructure Container - Data about containers, such as Azure Kubernetes Service, Prometheus, and the applications running\ninside containers.\n\nOperating system - Data about the guest operating system on which your application is running.\n\nAzure Platform Azure resource - Data about the operation of an Azure resource from inside the resource, including changes.\nResource Logs are one example.\n\nAzure subscription - The operation and management of an Azure subscription, and data about the health and\noperation of Azure itself. The activity log is one example.\n\nAzure tenant - Data about the operation of tenant-level Azure services, such as Microsoft Entra ID.\n\nCustom Data that gets into the system using the\nSources - Azure Monitor REST API\n- Data Collection API\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\nCollection method Description\n\nApplication Application Insights is enabled through either Auto-Instrumentation (agent) or by adding the Application\ninstrumentation Insights SDK to your application code. In addition, Application Insights is in process of implementing Open\nTelemetry. For more information, reference How do | instrument an application?.\n\nAgents Agents can collect monitoring data from the guest operating system of Azure and hybrid virtual machines.\n\nData collection Use data collection rules to specify what data should be collected, how to transform it, and where to send it.\n\nrules\n\nZero Config Data is automatically sent to a destination without user configuration. Platform metrics are the most common\nexample.\n\nDiagnostic settings | Use diagnostic settings to determine where to send resource log and activity log data on the data platform.\n\nAzure Monitor REST The Logs Ingestion API in Azure Monitor lets you send data to a Log Analytics workspace in Azure Monitor Logs.\nAPI You can also send metrics into the Azure Monitor Metrics store using the custom metrics API.\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/overview\n\n76\n\fCase 2:26-cv-00681 Document1 _ Filed 08/11/26 Page 77 of 89 PagelD#: 77\n\nMonitor Azure DNS\n\nArticle \u00bb 01/30/2025 + 2 contributors \u00a2) Feedback\n\nIn this article\n\nCollect data with Azure Monitor\nUse Azure Monitor tools to analyze the data\nExport Azure Monitor data\n\nUse Kusto queries to analyze log data\n\nShow 2 more\n\nAzure Monitor collects and aggregates metrics and logs from your system to\nmonitor availability, performance, and resilience, and notify you of issues affecting\nyour system. You can use the Azure portal, PowerShell, Azure CLI, REST API, or client\n\nlibraries to set up and view monitoring data.\n\nDifferent metrics and logs are available for different resource types. This article\ndescribes the types of monitoring data you can collect for this service and ways to\nanalyze that data.\n\nhttps://learn.microsoft.com/en-us/azure/dns/monitor-dns\n\nDNS proxy log\n\nThe DNS proxy log is saved to a storage account, streamed to Event hubs, and/or sent to Azure\nMonitor logs only if you enable it for each Azure Firewall. This log tracks DNS messages to a DNS\nserver configured using DNS proxy. The data is logged in JSON format, as shown in the following\nexamples:\n\nConsole 0 Copy\n\nCategory: DNS proxy logs.\n\nTime: log timestamp.\n\nProperties: currently contains the full message.\n\nnote: this field will be parsed to specific fields in the future, while maintaining backwai\n\nee &\nhttps://learn.microsoft.com/en-us/azure/firewall/monitor-firewall\n\n77\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 78 of 89 PagelD#: 78\n\nService Health notifications\n\n*, \u00a9 Summarize this article for me\n\nIn this article\n\nView Service Health notifications\nService Health notification types\n\nRelated content\n\nAzure Service Health notifications are system-generated alerts that inform you about Azure\nservice problems or events that affect your resources. The subscription\u2019s Azure activity log\nrecords these notifications as part of logging many events in Azure. The Azure portal then\n\ndisplays them under Azure Service Health.\n\nWhen Azure needs to communicate something about service health, such as an outage,\nupcoming maintenance, or an account-specific alert, it creates a Service Health event in your\n\nactivity log.\n\nhttps://learn.microsoft.com/en-us/azure/service-health/service-health-notifications-properties\n\n152. Azure Traffic manager further sends alerts regarding the error or anomalous\ncondition detected at a particular name server to the subscriber via the web-based graphical user\n\ninterface.\n\n78\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 79 of 89 PagelD #: 79\n\nAzure Monitor Alerts notify you of critical conditions and can take corrective action. Alert rules can be based on metric\nor log data.\n\ne Metric alert rules provide near-real-time alerts based on collected metrics.\ne Log search alert rules based on logs allow for complex logic across data from multiple sources.\n\nAlert rules use action groups, which can perform actions such as sending email or SMS notifications. Action groups can\nsend notifications using webhooks to trigger external processes or to integrate with your IT service management tools.\nAction groups, actions, and sets of recipients can be shared across multiple rules.\n\n* Subscription @ Resource group @ Time Range @\n\nContoso IT - demo v mms-eus v Past Hour v\nContoso IT - demo\nTotal Alerts Smart Groups \u00a9 Total Alert Rules Learn More\n2 9 1 1 5 About Alerts\nSince 8/1/2018, 4:38:39 PM 96.55% Reduction Enabled 13\n\nSEVERITY TOTAL ALERTS NEW ACKNOWLEDGED CLOSED\n\nIsev1 0 0 o 0\n\nSev2 3; Zz 3 0 0\n\nIsev3 0 0 0 0\n\n[sev 4 0 \u00b0 \u00b0 0 qe\n\nPW et Se I ss be Na Sh hn et eee\n\nhttps: /Nearn.microsoft.com/en-us/azure/azure-monitor/overview\n\nAlerts help you detect and address issues before users notice them by proactively\nnotifying you when Azure Monitor data indicates there might be a problem with your\n\ninfrastructure or application.\nYou can alert on any metric or log data source in the Azure Monitor data platform.\n\nThis diagram shows you how alerts work.\n\neS Alert Rules @ Fired Alerts\nndition bet\n+ +\n\u00b0 \u00b0\n\nScredules 7%\nEvahuabon\n\noO Azure Resources\n\nmo .\n\nNerts boundary ee\n\nExternal boundary\n\nhttps://learn.microsoft.com/en-us/azure/azure-monitor/alerts/alerts-overview\n\n79\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 80 of 89 PagelD #: 80\n\nPost Incident Review (PIR) \u2014 Azure Storage \u2014 Unreachable Blob\n\n. . . Tracking ID: PSM0O-BQ8 mw\nand Data Lake storage accounts in multiple regions\n\nWatch our \u2018Azure Incident Retrospective\u2019 video about this incident: https://aka.ms/AIR/PSMO0-BQ8\nWhat happened?\n\nBetween 00:50 UTC and 12:30 UTC on 13 November 2024, a subset of Azure Blob Storage and Azure Data Lake\nStorage accounts experienced connectivity errors. The issue manifested as loss of access to Blob and Data Lake\nstorage endpoints of the affected storage accounts, and subsequent unavailability of downstream services that\ndepended on these storage accounts. Since many of the impacted storage accounts were used by other Azure\nservices and major software vendor solutions, the customer impact was widespread. Although unavailable to\naccess, the data stored in these storage accounts was not impacted during this incident. Impacted downstream\nservices included:\n\n\u00a2 Azure Storage: Impacted customers may have experienced name (DNS) resolution failures when interacting\nwith impacted storage accounts in Australia East, Australia Southeast, Brazil South, Brazil Southeast, Canada\nCentral, Canada East, Central India, Central US, East Asia, East US, East US 2, East US 2 EUAP, France Central,\nGermany West Central, Japan East, Japan West, Korea Central, North Central US, North Europe, Norway East,\nSouth Africa North, South Central US, South India, Southeast Asia, Sweden Central, Switzerland North, UAE\nNorth, UK South, UK West, West Central US, West Europe, West US, West US 2, West US 3.\n\nAzure Container Registry: Impacted customers using the East US region may have experienced intermittent\n\n5xx errors while trying to pull images from the registry.\n\nAzure Databricks: Impacted customers may have experienced failures with launching clusters and serverless\ncompute resources in Australia East, Canada Central, Canada East, Central US, East US, East US 2, Japan East,\nSouth Central US, UAE North, West US, and/or West US 2.\n\nAzure Log Analytics: Impacted customers using the West Europe, Southeast Asia, and/or Korea Central\nregions may have experienced delays and/or stale data when viewing Microsoft Graph activity logs.\n\nhttps://azure.status.microsoft/status/history/?trackingId=PSM0-BQ8\n\nCOUNT VU: INFRINGEMENT OF THE \u2019517 PATENT\n\n153. Plaintiff hereby incorporates by reference each of the allegations in the foregoing\nparagraphs as though fully set forth herein, and further alleges as follows.\n\n154. Microsoft directly infringes, either individually or jointly through the direction and\ncontrol of others, at least claim 1 of the \u00b0517 Patent through operation of one or more of the Accused\nMicrosoft Functionalities. For instance, Azure Front Door and Azure CDN, and Azure Traffic\n\nManager provide an adaptive traffic control network.\n\n80\n\fCase 2:26-cv-00681 Document1 - Filed 08/11/26 Page 81 of 89 PagelD#: 81\n\nVAN c-M@olah 111 PY-IIV LAV 1 aU ola 4\n\naol le Rennes sme aan eer)\n\nTry Azure for free leer eT Seed\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nAzure Content Delivery Network offers a globa\u2019 solution \u2018or rapidly delivering content. Save bandwidth and improve responsiveness when\nIncrease speed and scalability for an optimal encoding or distributing gaming softwere, firmware updates, and loT endpoints. Reduce load times for weksites, mobile apps, and streaming\nuser experience media to increase user satisfaction globally.\n\nhttps://azure.microsoft.com/en-us/products/cdn\n\nWhat is Traffic Manager?\n\nArticle + 08/15/2023 + 12 contributors \u00a2 Feedback\n\nIn this article\n\nIncrease application availability\nImprove application performance\nService maintenance without downtime\nCombine hybrid applications\n\nShow 3 more\n\nAzure Traffic Manager is a DNS-based traffic load balancer. This service allows you to distribute traffic to your public\nfacing applications across the global Azure regions. Traffic Manager also provides your public endpoints with high\navailability and quick responsiveness.\n\nTraffic Manager uses DNS to direct client requests to the appropriate service endpoint based on a traffic-routing\nmethod. Traffic manager also provides health monitoring for every endpoint. The endpoint can be any Internet-facing\nservice hosted inside or outside of Azure. Traffic Manager provides a range of traffic-routing methods and endpoint\nmonitoring options to suit different application needs and automatic failover models. Traffic Manager is resilient to\nfailure, including the failure of an entire Azure region.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-overview\n\n81\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 82 of 89 PagelD #: 82\n\nTraffic Manager routing methods\n\nArticle - 08/08/2024 + 15 contributars & Feedback\n\nIn this article\n\nPriority traffic-routing method\nWeighted traffic-routing method\nPerformance traffic-routing method\nGeographic traffic-routing method\n\nShow 3 more\n\nAzure Traffic Manager supports six traffic-routing methods to determine how to route network traffic to the various\nservice endpoints. For any profile, Traffic Manager applies the traffic-routing method associated ta it to each DNS query\n\nit receives. The traffic-routing method determines which endpoint is returned in the DNS response.\n\nThe following traffic routing methods are available in Traffic Manager:\n\nPriority: Select Priority routing when you want to have a primary service endpoint for all traffic. You can provide\n\nmultiple backup endpoints in case the primary or one of the backup endpoints is unavailable.\n\nWeighted: Select Weighted routing when you want to distribute traffic across a set of endpoints based on their\n\nweight. Set the weight the same to distribute evenly acrass all endpoints.\n\nPerformance: Select Performance routing when you have endpoints in different geographic locations and you\nwant end users to use the \"closest\" endpoint for the lowest network latency.\n\nGeographic: Select Geographic routing to direct users to specific endpoints (Azure, External, or Nested) based on\n\nwhere their DNS queries originate from geographically. With this routing method, it enables you ta be in\n\ncompliance with scenarios such as data sovereignty mandates, localization of content & user experience and\n\nmeasuring traffic from different regions.\n\n\u00ab Multivalue: Select MultiValue for Traffic Manager profiles that can only have IPv4/IPv6 addresses as endpoints.\nWhen a query is received for this profile, all healthy endpoints are returned.\n\n* Subnet: Select Subnet traffic-routing methad to map sets of end-user IP address ranges to a specific endpoint.\n\nWhen a request is received, the endpoint returned will be the one mapped for that request\u2019s source IP address.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\n155. Azure Front Door/CDN and Traffic Manager performs a method in which an\nadaptive traffic control name server network implements policy-based traffic direction, where Azure\nFront Door/CDN and Traffic Manager provides a graphical user interface (GUI) and uses said GUI\nto obtain at least one policy for direction of network traffic, wherein the GUI supports the setting of\n\nsaid at least one policy using a decision tree representing rules.\n\nView and manage all of your applications in one unified hub\u2014including web apps,\ndatabases, virtual machines, virtual networks, storage, and Visual Studio team\nprojects. Enjoy the flexibility of using the Azure portal's graphical experience or the\nintegrated command-line experience provided by Cloud Shell. Get an overview,\nand see which Azure services can be managed with the Azure portal.\n\nView one portal, manage all\nyour apps\n\nhttps://azure microsoft.com/en-us/get-started/azure-portal\n\n82\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 83 of 89 PagelD #: 83\n\nPersonalize your experience\n\n= = Imagine a single easy-to-use console built just for\nyou, your team, and your projects. This unified hub\nsignificantly simplifies building, deploying, and\nmanaging your cloud resources. Organize your portal\nto custom-fit your work and your work style. Stay on\ntop of the things that matter most by pinning them\nto your dashboard. Resize tiles to show just the right\namount of detail, and share insights across apps and\n\nresources.\n\nUse fine-grained access control = a\n\nRole-based access control lets you select exactly who oo\ncan manage what. Grant explicit management and _\naccess rights to the account, service, and operation \u2014\nlevels for individuals and groups. =\n\nhttps://azure microsoft.com/en-us/get-started/azure-portal\n\nCreate a Traffic Manager profile\n\nCreate a Traffic Manager profile that directs user traffic based on endpoint priority.\n\n1. On the upper-left side of the screen, select Create a resource. Then search for Traffic Manager profile and select\nCreate.\n\n2. In the Create Traffic Manager profile, enter, or select these settings:\n\n<3 Expand table\n\nSetting Value\n\nName Enter a unique name for your Traffic Manager profile.\n\nRouting Select Priority.\n\nmethod\n\nSubscription Select the subscription you want the traffic manager profile applied to.\n\nResource Select myResourceGroupTM 1.\n\ngroup\n\nLocation This setting refers to the location of the resource group. It has no effect on the Traffic Manager profile that will\n\nbe deployed globally.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\n83\n\fCase 2:26-cv-00681\n\nDocument 1\n\nFiled 08/11/26\n\nPage 84 of 89 PagelID #: 84\n\nHome > Create a resource > Marketplace > Traffic Manager profile\nCreate Traffic Manager profile x\nNarne *\n| myTMprofile |\nctrafficmanagernet\n\nRouting method\n\nPriority ~ |\nSubscription *\n\nAzure Subscription v\n\nResource group *\n\nmyResourceGroupTMt\n\nCreate new\n\nRe: roup location @\n\nautomation options\n\n3. Select Create.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\n4, Enter, or select, these settings:\n\nSetting\n\nType\n\nName\n\nTarget resource type\nTarget resource\n\nPriority\n\nValue\n\nSelect Azure endpoint.\n\nEnter myPrimaryEndpoint.\n\nSelect App Service.\n\nSelect Choose an app service > East US.\n\nSelect 1. All traffic goes to this endpoint when it's healthy.\n\n@ Add endpoint x\nmyTMprofile\n\nType* \u00a9\n\nAzure endpoint v\n\nName *\n\nmyPrimaryEndpoint \u201c\n\nTarget resource type\n\nApp Service \u00a5\n\nTarget resource *\n\nmyWebAppEastUS (East US) v\n\nPriority *\n\n[i\n\nCustom Header settings \u00a9\n\n(Aad as disabled\n\n[2 Expand table\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\n84\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 85 of 89 PagelD #: 85\n\n6. To create a failover endpoint for your second Azure region, repeat steps 3 and 4 with these settings:\n\n{] Expand table\n\nSetting Value\n\nType Select Azure endpoint.\n\nName Enter myFailoverEndpoint.\n\nTarget resource type Select App Service,\n\nTarget resource Select Choose an app service > West Europe.\n\nPriority Select 2. All traffic goes to this failover endpoint if the primary endpoint is unhealthy.\n7. Select Add.\n\nWhen you're done adding the two endpoints, they're displayed in Traffic Manager profile. Notice that their monitoring\n\nstatus is Online now.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\n156. Azure Front Door/CDN and Traffic Manager further provides said at least one policy\nto the name server network, wherein the decision tree comprises one or more resource nodes, and one\nor more branch nodes, wherein the one or more resource nodes specify one or more answers to be\nprovided in response to a Domain Name Service (DNS) request, and wherein the one or more branch\nnodes specify one or more decision criteria to be applied, and wherein the GUI supports the\nspecification of: (i) one or more answers for the one or more resource nodes, and (ii) one or more\ndecision criteria for the one or more branch nodes, wherein the one or more criteria are selected from\ncriteria related to: world zones, countries, states, time zones, and blocks of Internet Protocol (IP)\naddresses, and wherein the one or more resource nodes are selected from: IP addresses, canonical\nname (CNAME) records, mail exchange (MX) records, name server (NS) records, and load sharing\n\nserver sets; and wherein the answers are selected from: IP addresses and CNAMEs.\n\nmy TMprofile\nJ \u00a5\n\nmyPrimaryEndpoint \u00a9 ? myFailoverEndpoint\nal myAppServicePlanEastUS sl myAppServicePlanWestEurope\n~~ as,\nwe myWebAppEastUS (& myWebAppWestEuropaay\n\n85\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 86 of 89 PagelD #: 86\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\nCreate a Traffic Manager profile\n\nCreate a Traffic Manager profile that directs user traffic based on endpoint priority.\n\n1, On the upper-left side of the screen, select Create a resource. Then search for Traffic Manager profile and select\nCreate.\n\n2, In the Create Traffic Manager profile, enter, or select these settings:\n\ni Expand table\n\nSetting Value\n\nName Enter a unique name for your Traffic Manager profile.\n\nRouting Select Priority.\n\nmethod\n\nSubscription Select the subscription you want the traffic manager profile applied to.\n\nResource Select myResourceGroupTM 1,\n\ngroup\n\nLocation This setting refers to the location of the resource group, It has no effect on the Traffic Manager profile that will\n\nbe deployed globally.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\nHome > Create a resource Marketplace Traffic Manager profite\nCreate Traffic Manager profile ~ *\nName *\n\nmyTNiprofile\n\ntrafficmanager.net\n\nRouting method\n\nPriority wv\nSubscription *\n\n\u2018Azure Subscription w\n\nResource group *\n\nmyResourceGroupTMt =\non\n\nRe:\n\ngroup location \u00a9\n\n3. Select Create.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\n86\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 87 of 89 PagelD #: 87\n\nTest Traffic Manager profile\n\nIn this section, you'll check the domain name of your Traffic Manager profile. You'll also configure the primary endpoint\nto be unavailable. Finally, you get to see that the web app is still available. It's because Traffic Manager sends the traffic\n\nto the failover endpoint.\n\nCheck the DNS name\n\n1. In the portal\u2019s search bar, search for the Traffic Manager profile name that you created in the preceding section.\n2. Select the traffic manager profile. The Overview appears.\n\n3. The Traffic Manager profile displays the DNS name of your newly created Traffic Manager profile.\n\n@ myTMprofile\n\nattic Manager profile\n\nSearch (Ctrl+/) \u00ab \u00a9& Disable profile () Refresh \u2014> Move W Delete profile\n\n\u201d Essentials\n\n@ overview\n\nEE Activity log\n\n\u00aep. Access control (JAM) Status\n\nEnabled\n@ tags\n\n@ Diagnose and solve problems\nSubscription ID\n\nSettings\n\nSi Configuration\n\n\u00ae Real user measurements\n\n# Search endpoints\n\n\u00a9 traffic view\n\n@ ind Name Ty, Status Monitor status TL Type Ty Priority\nndpeints\n\n\" . myPrimaryEndpoint Enabled Online Azure endpoint 1\n\nI} Properties 7 yendp\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/quickstart-create-traffic-manager-profile\n\nTraffic Manager routing methods\n\nArticle \u00bb 06/08/2024 = 15 contributors & Feedback\n\nIn this article\n\nPriority traffic-routing method\nWeighted traffic-routing method\nPerformance traffic-routing method\n\nGeographic traffic-routing method\n\nShow 3 more\n\nAzure Traffic Manager supports six traffic-routing methods to determine how to route network traffic to the various\nservice endpoints. For any profile, Traffic Manager applies the traffic-rauting method associated to it to each DNS query\n\nit receives. The traffic-routing method determines which endpoint is returned in the DNS response.\n\nThe following traffic routing methods are available in Traffic Manager:\n\nPriority: Select Priority routing when you want to have a primary service endpoint for all traffic. You can provide\nmultiple backup endpoints in case the primary or one of the backup endpoints is unavailable.\n\nWeighted: Select Weighted routing when you want to distribute traffic across a set of endpoints based on their\nweight. Set the weight the same to distribute evenly across all endpoints.\n\nPerformance: Select Performance routing when you have endpoints in different geographic locations and you\nwant end users to use the \"closest\" endpoint for the lowest network latency.\n\nGeographic: Select Geographic routing to direct users to specific endpoints (Azure, External, or Nested) based on\nwhere their DNS queries originate from geographically. With this routing method, it enables you ta be in\ncompliance with scenarios such as data sovereignty mandates, localization of content & user experience and\n\nmeasuring traffic from different regions.\n\nMultivalue: Select MultiValue for Traffic Manager profiles that can only have IPv4/IPv6 addresses as endpoints.\nWhen a query is received for this profile, all healthy endpoints are returned.\n\nSubnet: Select Subnet traffic-routing method to map sets of end-user IP address ranges to a specific endpoint.\nWhen a request is received, the endpoint returned will be the one mapped for that request\u2019s source IP address.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\n87\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 88 of 89 PagelD#: 88\n\nAll Traffic Manager profiles have health monitoring and automatic failover of endpoints. For more information, see Traffic\nManager Endpoint Monitoring. Within a Traffic Manager profile, you can only configure one traffic routing method at a\ntime. You can select a different traffic routing method for your profile at any time. Your changes will be applied within a\nminute without any downtime, You can combine traffic routing methods by using nested Traffic Manager profiles.\nNesting profiles allows for sophisticated traffic-routing configurations that meet the needs of larger and complex\n\napplications. Far more information, see nested Traffic Manager profiles.\n\nhttps://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods\n\nfollows:\n\nPRAYER FOR RELIEF\n\nWherefore, Plaintiff requests entry of judgment in its favor and against Microsoft as\n\nA. Judgment that Microsoft has directly infringed one or more claims of each of\nthe Asserted Patents pursuant to 35 U.S.C. \u00a7 271;\n\nB. An award of lost profits and/or reasonable royalty damages to compensate\nPlaintiff for Microsoft\u2019s infringement, including damages pursuant to 35\nU.S.C. \u00a7 284, as well as prejudgment and post-judgment interest;\n\nC. An award of costs and expenses in this action, including an award of\nPlaintiffs reasonable attorneys\u2019 fees pursuant to 35 U.S.C. \u00a7 285;\n\nD. A permanent injunction restraining and enjoining Microsoft, and its\nrespective officers, agents, servants, employees, attorneys, and those\npersons in active concert or participation with Microsoft who receive actual\nnotice of the order by personal service or otherwise, from any further sales\nor use of their infringing products and/or services and any other\n\ninfringement of the Asserted Patents;\n\nE. A finding that Microsoft has willfully infringed one or more claims of the\nAsserted Patents;\nF. A finding that this is an exceptional case, and awarding treble damages due\n\nto Microsoft\u2019s deliberate and willful conduct, and ordering Microsoft to pay\n\n88\n\fCase 2:26-cv-00681 Document1 Filed 08/11/26 Page 89 of 89 PagelD #: 89\n\nPlaintiffs costs of suit and attorneys\u2019 fees; and\nG. Any such other and further relief as the Court may deem just, proper, and\nequitable under the circumstances.\n\nJURY DEMAND\n\nPlaintiff respectfully demands a trial by jury on all claims and issues so triable.\n\nDated: August 11, 2026 Respectfully submitted,\n\n/8/ Ryan D. Dykal\n\nRyan D. Dykal (MO State Bar No. 60905)\nJordan T. Bergsten (DC Bar No. 90032105)\nMark D. 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