Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 1 of 851
`Case 1:16-cv—02690-AT Document 121-6 Filed 08/05/16 Page 1 of 851
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 2 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`control, intelligent transportation systems (ITS), mobile finance management, building
`automation and control, factory automation and control, home automation and control,
`security and access control, and asset management. There are also a number of military and
`other governmental applications in addition to the above. Some of these will be described
`below as illustrative, not limiting. A number of major market areas have been identified,
`most notably utility monitoring and control, intelligent transportation systems (ITS), mobile
`finance management, building automation and control, factory automation and control, home
`automation and control, security and access control, and asset management. There are also a
`number of military and other governmental applications in addition to the above. Some of
`these will be described below as illustrative, not limiting.” ‘773 patent, 6:28-36.
`
`“This is accomplished by making a small percentage of the Minion devices in the field act as
`a gateway. Minion devices 120 illustrated in block diagram form in FIG. 4. …The actual
`wide area connectivity of a gateway Minion device may be provided by a terrestrial wide
`area wireless area network such as the Bell South Wireless Data Mobitex network, a cellular
`based network using CDPD, or a satellite-based data network such as Orbcomm.” ‘773
`patent, 7:6-17.
`
`Fig. 4 and col. 7:18-26.
`
`To the extent that Defendants contend that this claim limitation is not disclosed explicitly or
`inherently in the ‘773 patent, consistent with Section V of Plaintiffs’ Invalidity Contentions,
`it would have been obvious to a person ordinary skill in the art to combine the ‘773 patent
`with one or more of the additional references teaching this limitation, for example, Kahn,
`U.S. Patent No. 6,366,217 (“the ‘217 patent”), or Burchfiel.
`
`For example, Kahn discloses the following:
`
`“Functions provided within the station software installed in 1977 included: network routing
`control; a gateway to other networks; a network measurement facility which collects, stores,
`and delivers experimental statistics from any network components; a debugging facility
`which supports examining and depositing the contents of memory in the PR units; an
`information service which assists in locating and connecting to people currently using the
`PRNET; and an experiment configuration control module..” Kahn, p. 1488.
`
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 3 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`“From the station, parameters in each PR and terminal device in the network can be set
`remotely, selected elements can be halted, if appropriate, the collection of statistical data
`from selected devices may be enabled, traffic sources may be turned on or off, and data
`collection may be initiated. At the conclusion of a measurement run, the data can be
`automatically spooled over the ARPANET to a remote site (e.g., UCLA) for analysis.”
`Kahn, p. 1495.
`
`“4) Off-line measurement software-the final destination of the PRNET measurement data is
`the UCLA 360/91 computer. The data are sent from the station over the ARPANET and are
`stored at UCLA, for use by several analysis programs.” Kahn, p. 1495.
`
`The ‘217 patent discloses the following:
`
`“FIG. 21 shows the general layout of the transmitted information signal. The signal consists
`of a header, information signal, and a CRC. The header information includes a preamble and
`a sensor interface module identifier.” ‘217 patent, 13:56-59.
`
`“The preamble is designed to distinguish the transmitted information from spurious radio
`signals or background noise. The identifier information is designed to identify the specific
`sensor interface module's transmission that is being received, and to identify any other type
`of information such as meter-type, count-type or any other information specific the device
`being monitored. The information signal contains the data collected by the sensor interface
`module or the emergency code. The CRC provides a basic check-sum type signal verification
`code which is used to ensure that the signal transmission was correct.” ‘217 patent, 13:60-
`14:1.
`
`“The data collection module will send and receiving information to and from the host
`module as an Internet protocol (TCP/IP) signal. The information signal will be sent out on
`the Internet, transferred across the Internet, and received by the other module. The data
`collection module will send and receiving information to and from the host module as an
`Internet protocol (TCP/IP) signal. The information signal will be sent out on the Internet,
`transferred across the Internet, and received by the other module.” ‘217 patent, 46:11-16.
`
`“The general layout of the wide area remote telemetry system 6300 is formed from the
`premise area network 6354, the metropolitan network 6356 and the national backbone
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 4 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`network 6358. The premise area network 6354 consists of the monitored devices, the sensor
`interface modules, the data collection modules and the connections to the appropriate
`elements. The metropolitan network 6356 consists of the data collection modules, and the
`appropriate connections such as a NPCS or BPCS, or data repeater module and master data
`collection module. The national backbone network 6358 consists of the elements which
`transmit, process, store, and forward information to the end customer connections, such as a
`customer computer or a customer workstation.” ‘217 patent, 47:55-67.
`
`Burchfiel discloses the following:
`
`“A similar mechanism permits centralized collection of traffic statistics, both through
`examination of counters in PRU memory and through centralized reception of special status
`conditions such as "trace packets" moving through the network. Again, it was essential to
`centralize this function for remote, unattended repeaters.” Burchfiel, p. 248.
`
`“Once the station has collected a set of traffic statistics, it will normally forward these
`measurements to a service host for detailed statistical analysis, logging and plotting.”
`Burchfiel, p. 248.
`
`“The TELNET process in the station may also be used to specify and set up connections to
`remote server hosts via a gateway connection.” Burchfiel, p. 248.
`
`“For communication with ARPANET hosts which support a protocol congruent with the
`PRN connection protocol (the Cerf-Kahn protocol mentioned previously qualifies here), the
`station functions as an extremely simple gateway: arriving packets are simply forwarded into
`the other network after their header format is converted to that of the destination network. In
`this case, the station does not detect missing or duplicate packets, and does not reorder
`packets which arrive out of order; it is merely a packet reformatting and readdressing
`service.” Burchfiel, p. 249.
`
`“The second approach will be conversion between the host-host protocols of the two
`networks. In particular, one connection will be established from a PRN device to a station
`using the PRN connection protocol described in an earlier section. Another full-duplex
`connection will be established from the station to an ARPANET host using the current
`ARPANET host-host protocol. Data arriving from either of these connections will be
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 5 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`a plurality of wireless transceivers comprising at least a
`first wireless transceiver and a second wireless
`transceiver;
`
`a site controller in communication with at least the
`second wireless transceiver,
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`forwarded through the other connection.” Burchfiel, p. 249.
`
`“Finally, the PRN TELNET process performs the second type of gateway function described
`above: conversion between the PRN connection protocol and the ARPANET host-host
`protocol. Terminals on the PRN appear identical to the terminals attached to the PDP-11, and
`are able to access remote ARPANET service hosts in the same way.” Burchfiel, p. 250.
`
`“Each Minion device is assigned a unique serial number which is installed during
`manufacture that identifies that particular Minion device so that each Minion device is
`unique.” ‘773 patent, 17:57-60.
`
`“The basic mµMinion devices may be used as stand-alone devices which perform the
`prescribed network functions, or they may be connected to or embedded in external
`equipment or devices. For example: …Building and Factory Management and Controls--
`Heating, Ventilation, Air Conditioning and Refrigeration equipment and their controls,
`including thermostats, humidity sensors, motion detectors, occupancy sensors, exit signs,
`door locks, lighting fixtures and controls, emergency alarms, signaling devices, security
`devices.” ‘773 patent 48:50-49:2.
`
`“The µMinion is a low-cost, intelligent two-way data radio. It participates as a member of a
`self-organizing network of functionally identical nodes. Each µMinion can originate and
`receive data messages, and can act as an intermediary in forwarding messages on behalf of
`other µMinions.” ‘773 patent, 51:60-64.
`“It is an object of this invention to provide a low cost, multi-node system which hands off
`messages from node-to-node; a system of nodes which hands off messages and provides
`implicit and/or explicit acknowledgment of the hand off; a flexible, adaptable multi-node
`system which is applicable in a plurality of environments and for a plurality of uses; a multi-
`node system having stationary nodes and mobile nodes (known as "Minion.TM. devices")
`the position of which can be determined by the stationary nodes; a multi-node system which
`permits nodes to communicate with a wide area network or a global positioning system via a
`selected number of nodes; a multi-node system which operates multiple applications at each
`node; and a multi-node system which interfaces with a plurality of "gateways", e.g., wide
`area network (WAN) connections to other communications networks, whether wired or not,
`such as telephone or CATV or wireless, or satellite or terrestrial.” ‘773 patent, 1:43-59.
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 6 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`“This is accomplished by making a small percentage of the Minion devices in the field act as
`gateway Minion devices 120 illustrated in block diagram form in FIG. 4. These gateway
`Minion devices 120 act as concentrators for messages bound to and emanating from the
`centralized supervisory components of the nationwide MinionNet network. The actual wide
`area connectivity of a gateway Minion device may be provided by a terrestrial wide area
`wireless data network such as the Bell South Wireless Data Mobitex.RTM. network, a
`cellular based network using CDPD, or a satellite-based data network such as Orbcomm.”
`‘773 patent, 7:6-17.
`
`“As shown in FIG. 4, a gateway Minion device 120 comprises a µMinion device 110
`configured to interface with a wide area network (WAN) interface 400. The WAN interface
`400 would be in contact, either directly or wireless communication with other stations which
`would provide data to the .mu.Minion devices or receive data from the µMinion devices. The
`power supply options and power control of the gateway Minion device 120 will be described
`below with regard to FIG. 7.” ‘773 patent, 7:18-26.
`
`“The Data portion of a MinionNet network Standard Message with a Type Code meaning
`“Command” will contain information originating with the MinionNet network Control
`Center that causes certain operations to be performed by the Minion device and results to be
`sent back to the Control Center. This can be used to set operating modes or data throughout
`the MinionNet network.” ‘773 patent, 22:13-19.
`
`“Each Minion device is assigned a unique serial number which is installed during
`manufacture that identifies that particular Minion device so that each Minion device is
`unique.” ‘773 patent, 17:57-60.
`
`To the extent that Defendants contend that this claim limitation is not disclosed explicitly or
`inherently in the ‘773 patent, consistent with Section V of Plaintiffs’ Invalidity Contentions,
`it would have been obvious to a person ordinary skill in the art to combine the ‘773 patent
`with one or more of the additional references teaching this limitation, for example, Burchfiel,
`Kahn, the ‘491 patent, the ‘817 patent, or the ‘903 patent.
`
`For example, Burchfiel discloses the following:
`
`“A packet radio network is a digital broadcast channel, fixed and mobile digital terminals
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 7 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`which are sources and sinks of information, stations which provide centralized routing
`control and interconnections to other networks, and repeaters which provide area coverage
`for mobile terminals by performing a store-and-forward function on the radio broadcast
`channel.” Burchfiel, p. 245.
`
`“The programs which provide centralized monitoring, debugging, and statistics collection are
`located in the station, with a small (slave) routine in each repeater. These functions are
`shown in Figure 1.” Burchfiel, p. 245.
`
`“The set of functions which appear in common in a station, repeater, and terminal are
`identified in Figure 1 as a Packet Radio Unit, or PRU, which has been implemented as a
`standard piece of hardware and software by Collins Radio. It will serve standalone as a
`repeater; addition of the station interface hardware and software option converts it to a
`station; addition of the terminal interface hardware and software option converts it to a
`terminal.” Burchfiel, p. 245.
`
`Kahn discloses the following:
`
`“The functions of a station are associated with global management of the radio net [24].
`Generally speaking, each station is aware of all operational radios in the network. The
`stations discover the existence of new radios waiting to enter the net and determine when
`other radios have departed. The station determines the route to each of these radios and plays
`an active role in initializing, organizing, and maintaining the operational network.” Kahn, p.
`1477.
`
`“Functions provided within the station software installed in 1977 included: network routing
`control; a gateway to other networks; a network measurement facility which collects, stores,
`and delivers experimental statistics from any network components; a debugging facility
`which supports examining and depositing the contents of memory in the PR units; an
`information service which assists in locating and connecting to people currently using the
`PRNET; and an experiment configuration control module..” Kahn, p. 1488.
`
`“Each EPR consists of a radio unit, which transmits and receives packets, and a
`microprocessor-based digital unit, which controls the radio and provides packet header
`processing (e.g., for routing of packets between nodes). An EPR may operate as a repeater,
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 8 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`the first wireless transceiver having a first unique
`identifier, being configured to receive a first sensor data
`signal from a first remote device, and being configured
`to transmit a first original data message comprising the
`first unique identifier and the first sensor data signal;
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`or may be connected to a user’s host computer or terminal, or to a station.” Kahn, p. 1490.
`
`“From the station, parameters in each PR and terminal device in the network can be set
`remotely, selected elements can be halted, if appropriate, the collection of statistical data
`from selected devices may be enabled, traffic sources may be turned on or off, and data
`collection may be initiated. At the conclusion of a measurement run, the data can be
`automatically spooled over the ARPANET to a remote site (e.g., UCLA) for analysis.”
`Kahn, p. 1495.
`
`The ‘817 patent discloses the following:
`
`“FIG. 1 depicts an AMR system comprising, in accordance with the present invention, a
`plurality of utility meters 12A, 12B, 12C, . . . 12D (for metering electricity, gas or water).
`Each of the meters has a corresponding CEBUS RF module for receiving RF
`communications from a node, or collector, 18, or sending RF communications to the node,
`and also for communication with a CEBUS local area network (LAN) within the residence or
`business with which the meter is associated. The node 18 preferably includes a wide area
`network (WAN) interface, a digital controller, and a CEBUS RF module. The WAN
`interface, digital controller, and CEBUS RF module are not described in detail herein since
`such devices are well known in the networking and communications fields.” ‘817 patent,
`5:32-57.
`
`The ‘903 patent discloses the following:
`
`“The AMR network 14, in the embodiment of FIG. 2, includes an RF node 14A (actually a
`plurality of such nodes) and a host computer, or server, 14B (or multiple hosts, as needed).
`The node 14A includes a transceiver for normal traffic and a receiver for exception traffic, as
`discussed above. The plurality of RF nodes and host computer(s) constitute a wide area
`network (WAN).” ‘903 patent, 4:13-19.
`
`“In another form, the invention is a message having a protocol which permits the message to
`be successfully transmitted by a wireless network of transceiver nodes employing node-to-
`node messaging. A message including data is sent from a first node originating via one or
`more intermediate nodes to a last node designated by the first node as the destination of the
`message. The message comprises: data bits corresponding to the data; originating bits
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 9 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`identifying the first node from which the message originates; destination bits identifying the
`last node to which the message is destined; transmitting bits identifying the current node
`transmitting the message; and receiving bits identifying the next node intended to receive the
`message currently being transmitted.” ‘773 patent, 2:52-65.
`
`“Each Minion device is assigned a unique serial number which is installed during
`manufacture that identifies that particular Minion device so that each Minion device is
`unique.” ‘773 patent, 17:57-60.
`
`“Messages which are transmitted between Minion devices will each contain a header area
`and a data area. The header area will contain the following bit fields:
`i.
`the serial number of the Minion device generating the message (originator);
`j.
`the serial number of the Minion device transitting the message (sender);
`k.
`the serial number of the Minion device intended to receive the message (recipient);
`l.
`the serial number of the Minion device intended as the final destination of this
`message (destination); …
`j. a type code that controls the interpretation of the data portion.
`
` Type codes include but are not limited to the following: position, time, history,
`request/response, command….” ‘773 patent, 18:14-40.
`
`“The µMinion is a low-cost, intelligent two-way data radio. It participates as a member of a
`self-organizing network of functionally identical nodes. Each µMinion can originate and
`receive data messages, and can act as an intermediary in forwarding messages on behalf of
`other µMinions.” ‘773 patent, 51:60-64.
`
`“Each Minion has a unique 32-bit serial number assigned during manufacture. This gives
`over four billion numbers, although number reuse is not as big an issue in this environment
`as it is in some others. Each message will contain space for four of these serial numbers: (1)
`the message originator, (2) the message final destination, (3) the device actually transmitting
`for this hop and (4) the intended receiver for this hop. Messages also contain a set of
`standard fields for message type codes, device status bits, message priority and handling bits.
`A payload area will contain application specific data such as geolocation information,
`time/date, etc., as determined by the message type codes.” ‘773 patent, 52:40-54.
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 10 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`“The basic mµMinion devices may be used as stand-alone devices which perform the
`prescribed network functions, or they may be connected to or embedded in external
`equipment or devices. For example: …Building and Factory Management and Controls--
`Heating, Ventilation, Air Conditioning and Refrigeration equipment and their controls,
`including thermostats, humidity sensors, motion detectors, occupancy sensors, exit signs,
`door locks, lighting fixtures and controls, emergency alarms, signaling devices, security
`devices.” ‘773 patent 48:50-49:2.
`
`To the extent that Defendants contend that this claim limitation is not disclosed explicitly or
`inherently in the ‘773 patent, consistent with Section V of Plaintiffs’ Invalidity Contentions,
`it would have been obvious to a person ordinary skill in the art to combine the ‘773 patent
`with one or more of the additional references teaching this limitation, for example, Kahn,
`Jubin, U.S. Patent No. 6,366,217 (“the ‘217 patent”), U.S. Patent No. 6,100,817 (“the ‘817
`patent”), or U.S. Patent No. 5,874,903 (“the ‘903 patent”).
`
`For example, Kahn discloses the following:
`
`“An EPR may operate as a repeater, or may be connected to a user's host computer or
`terminal, or to a station.” Kahn, p. 1490.
`
`“A renewal point is a PR along the route of a packet where the route (as specified in its
`header) may be altered. In point-to-point routing, the header contains fields which identify
`the next few designated repeaters along the path to a specified destination. Every repeater on
`a point-to-point route can act as a renewal point where these fields are rewritten.” Kahn, p.
`1482.
`
`“To function as a renewal point for a point-to-point route, a repeater must have a renewal
`table containing the next few designated repeaters for that route. When a packet arrives at the
`next downstream repeater for relaying, its routing fields are rewritten in the header according
`to the current renewal table entries.” Kahn, p. 1482.
`
`Jubin discloses the following:
`
`“The routing header stays on the packet throughout its forwarding through the PRNET
`subnet. The source PR ID, sequence number, and destination PR ID created by the source PR
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 11 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`stay fixed throughout the packet's journey to the destination PR. The rest of the fields are
`updated by every intermediate packet radio.” Jubin, pp. 25, 26.
`
`“Packets are forwarded over a single path through the PRNET by each packet radio using the
`information in the packet's headers and in its own device and tier tables. Each PR uses this
`information, first, to decide whether it should be the one to transmit the packet on, second, to
`update the routing header before transmitting the packet on, and third, to update its own
`tables.” Jubin, p. 26.
`
`The ‘217 patent discloses the following:
`
`“If the data collection module is used in remote areas, access to network connections to the
`host may be few and far between. Thus, it may be necessary for the data collection module to
`receive information from both sensor interface modules and from other data collection
`modules and transmit this information towards a data collection module which is connected
`to the host module through a network system. When the data collection module is used in
`this manner it is also called a data repeater module.” ‘217 patent, 33:8-15.
`
`“In one embodiment, the data repeater module is designed to interface with high pressure gas
`equipment for the monitoring of remote gas line transmission system locations. The data
`repeater module system uses spread spectrum radio transmission to transmit information in
`an Internet protocol (IP) stack to get to an Internet or communication line for transmission to
`the host module. In this manner, each module of the data repeater module system will receive
`a packet of information and relay the information down the line until it gets to a data
`collection module with host module transmission capability. The host-module-connected
`data collection module, or root data collection module, will transmit the information to the
`host module. The data repeater module can perform both the functions of a standard data
`collection module in gathering information from sensor interface modules, and perform the
`repeater functions to get the information to a connected data collection module for
`transmission over any of a number of the commercial transmission systems for data.” ‘217
`patent, 33:15-34.
`
`The’ 817 patent discloses the following:
`
`“Copending U.S. patent application Ser. No. 08/870,640, filed Jun. 6, 1997, entitled "RF
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`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 12 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`the second wireless transceiver having a second unique
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`Repeater for Automatic Meter Reading System," and U.S. patent application Ser. No.
`08/908,728, filed Aug. 7, 1997, entitled "Energy Meter with Multiple Protocols for
`Communication with Local and Wide Area Networks" disclose related inventions concerning
`the use of fixed RF networks for AMR applications with utility meters having CEBUS
`capabilities. For example, the '640 application teaches a way to make the RF system adaptive
`to read hard to access meters within the network, by permitting any meter in the network to
`operate as a repeater. Thus, referring to FIG. 1, meter 12D may be considered "inaccessible"
`with respect to the responsible node 18. The node 18, which is coupled to the AMR server 20
`by a telephone link or some other wired or wireless link, sends information to the AMR node
`18, which then directs the information to the "inaccessible" meter 12D by routing it through,
`say, meter 12C, which in this example function as a repeater.” ‘817 patent, 6:15-35.
`
`The ‘903 patent discloses the following:
`
`“To make the RF system adaptive to read the hard to access meters within the network, it
`would be advantageous to have a method by which the node transceiver could be effectively
`moved closer to the hard to access meter. The present invention provides just such a method
`by allowing any meter in the network to be a repeater. This concept is depicted in FIG. 5,
`which schematically depicts a plurality of meters 12A, 12B, 12C, . . . , 12D, where meter
`12D is considered "inaccessible" (i.e., difficult to reach by direct RF communications) with
`respect to a responsible node 18. Node 18 is called the "responsible" node in this example
`because it has primary responsibility for communicating with meters 12A-12D, although it is
`possible for more than one node to have the ability to communicate with a given node. (Such
`redundancy may be desired in situations where the added system reliability is worth
`whatever added cost is required.) The node 18 is coupled to an AMR server 20, e.g., by a
`telephone link or some other wired or wireless communications link. With the present
`invention, information from the AMR node 18 that does not reach the "inaccessible" meter
`12D can be routed through a meter (e.g., meter 12C) that the node does reach and has the
`capability to reach the hard to access meter. This repeat function is installed with a minimum
`of additional cost to each meter.” ‘903 patent, 4:66-5:23.
`
`“The present invention provides just such a method by allowing any meter in the network to
`be a repeater.” ‘903 patent, 5:2-4.
`
`Id.
`
`73
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 13 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`identifier, being configured to receive a second sensor
`data signal from a second remote device, and is
`configured to transmit a second original data message
`comprising the second unique identifier and second
`sensor data signal,
`the second wireless transceiver being further configured
`to receive the first original data message from the first
`wireless transceiver, and to transmit a first repeated
`upstream data message including the first unique
`identifier and the first sensor data signal,
`
`U.S. Patent No. 7,027,773 (“the ‘773 Patent”)
`
`“In another form, the invention is a message having a protocol which permits the message to
`be successfully transmitted by a wireless network of transceiver nodes employing node-to-
`node messaging. A message including data is sent from a first node originating via one or
`more intermediate nodes to a last node designated by the first node as the destination of the
`message. The message comprises: data bits corresponding to the data; originating bits
`identifying the first node from which the message originates; destination bits identifying the
`last node to which the message is destined; transmitting bits identifying the current node
`transmitting the message; and receiving bits identifying the next node intended to
`receive the message currently being transmitted.” ‘773 patent, 2:52-65 (emphasis added).
`
`“Each Minion device is assigned a unique serial number which is installed during
`manufacture that identifies that particular Minion device so that each Minion device is
`unique.” ‘773 patent, 17:57-60.
`
`“Messages which are transmitted between Minion devices will each contain a header area
`and a data area. The header area will contain the following bit fields:
`a.
`the serial number of the Minion device generating the message (originator);
`b. the serial number of the Minion device transmitting the message (sender);
`c. the serial number of the Minion device intended to receive the message
`(recipient);
`the serial number of the Minion device intended as the final destination of this
`message (destination); …
`j. a type code that controls the interpretation of the data portion.
`
` Type codes include but are not limited to the following: position, time, history,
`request/response, command….” ‘773 patent, 18:14-40 (emphasis added).
`
`“The µMinion is a low-cost, intelligent two-way data radio. It participates as a member of a
`self-organizing network of functionally identical nodes. Each µMinion can originate and
`receive data messages, and can act as an intermediary in forwarding messages on behalf
`
`d.
`
`74
`
`
`
`

`

`Case 1:16-cv-02690-AT Document 121-6 Filed 08/05/16 Page 14 of 851
`
`Exhibit G – Invalidity Chart for U.S. Patent No. 7,103,511 based on U.S. Patent No. 7,027,773
`
`The ‘511 Patent – Claim
`
`U.S. Patent No. 7,027,773 (