IN UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`C.A. No. 12-030-RGA
`
`
`
`C.A. No. 12-031-RGA
`
`
`
`C.A. No. 12-032-RGA
`
`
`
`
`
`
`
`
`
`
`
`SIERRA WIRELESS AMERICA, INC., a
`Delaware corporation, and SIERRA
`WIRELESS, INC., a Canadian corporation,
`
`
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`
`
`CINTERION WIRELESS MODULES GMBH,
`a German limited liability company,
`CINTERION WIRELESS MODULES NAFTA
`LLC, a Delaware limited liability company,
`
`
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`
`
`ENFORA, INC., a Delaware corporation,
`NOVATEL WIRELESS SOLUTIONS,
`INC., a Delaware corporation, and
`NOVATEL WIRELESS, INC, a
`Delaware corporation,
`
`
`
`1
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`M2M
`Ex. 2002
`
`

`
`C.A. No. 12-033-RGA
`
`
`
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`
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`
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`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`
`
`MOTOROLA SOLUTIONS, INC., a Delaware
`corporation, TELIT COMMUNICATIONS PLC,
`a United Kingdom public limited company, and
`TELIT WIRELESS SOLUTIONS INC., a
`Delaware corporation,
`
`
`
`
`
`DEFENDANTS’ INITIAL INVALIDITY CONTENTIONS
`
`Pursuant to Paragraph 3(a)(iv) of the Coordinated Rule 16 Scheduling Order
`
`(Doc. No. 32), Defendants Motorola Solutions, Inc., Telit Communications PLC, Telit Wireless
`
`Solutions Inc., Sierra Wireless America, Inc., Sierra Wireless, Inc., Cinterion Wireless Modules
`
`GMBH, Cinterion Wireless Modules NAFTA LLC, Enfora, Inc. Novatel Wireless Solutions,
`
`Inc., and Novatel Wireless, Inc. (collectively, “Defendants”), hereby serve their Initial Invalidity
`
`Contentions for the asserted claims of U.S. Patent Nos. 7,583,197 (“the ‘197 patent”) and
`
`8,094,010 (“the ‘010 patent”) (collectively, the “Asserted Patents”) identified by Plaintiff M2M
`
`Solutions LLC (“M2M” or “Plaintiff”), as well as the related invalidating references (e.g.,
`
`publications, manuals and patents).
`
`These Initial Contentions are necessarily preliminary and are provided without
`
`prejudice to Defendants’ rights. Defendants’ initial invalidity contentions are based on
`
`information reasonably available to Defendants, and Defendants expressly reserve the right to
`
`amend, or supplement these Initial Contentions based on further investigation, discovery,
`
`- 2 -
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`2
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`M2M
`Ex. 2002
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`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that copies of:
`
`1.
`
`
`2.
`
`DEFENDANTS’ INITIAL INVALIDITY CONTENTIONS, including
`Appendices A-Z and AA-CC; and
`
`DEFPRIORART000001–DEFPRIORART003830
`
`
`
`
`
`were caused to be served on March 8, 2013 upon the following, via electronic mail containing a
`
`hyperlink, username and password to a file transfer protocol (“FTP”) window containing
`
`downloadable PDF files of all said documents:
`
`BY FTP VIA ELECTRONIC MAIL
`
`BY FTP VIA ELECTRONIC MAIL
`
`BY FTP VIA ELECTRONIC MAIL
`
`BY FTP VIA ELECTRONIC MAIL
`
`
`
`Richard D. Kirk, Esquire
`Stephen B. Brauerman, Esquire
`BAYARD, P.A.
`222 Delaware Avenue
`Suite 900
`Wilmington, DE 19801
`Attorneys for M2M Solutions LLC
`
`Marc N. Henschke, Esquire
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2600
`Boston, MA 02199
`Attorneys for M2M Solutions LLC
`
`Jeffrey N. Costakos, Esquire
`Kadie M. Jelenchick, Esquire
`Matthew J. Shin, Esquire
`FOLEY & LARDNER LLP
`777 E. Wisconsin Avenue
`Milwaukee, WI 53202
`Attorneys for M2M Solutions LLC
`
`Jason J. Keener, Esquire
`Jeffrey J. Mikrut, Esquire
`FOLEY & LARDNER LLP
`321 North Clark Street
`Suite 2800
`
`3
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`M2M
`Ex. 2002
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`

`
`Chicago, IL 60654
`Attorneys for MSM Solutions LLC
`
`
`
`
` s/ Keren Livneh
`Keren Livneh
`
`
`
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`Appendix G - U.S. Patent 5,771,455
`
`
`
`
`The following charts and references disclose how U.S. Patent No. 5,771,455 (the “‘455 patent”) discloses the subject matter of the asserted
`claims. The ‘455 patent issued on June 23, 1998 and is 102(b) prior art to the asserted patents.
`
`U.S. Patent No. 7,583,197
`
`
`No. Claim
`
`
`107 A programmable communicator device comprising:
`
`
`
`‘455 Patent
`
`
`“As shown in FIG. 2, cellular transceiver 38 is coupled to cellular
`transceiver bus 40. Cellular transceiver 38 receives and transmits signals
`across cellular antenna 42, including cellular transmission and reception of
`voice and data over the voice and data channels in network 10. Cellular
`transceiver 38 may be just a cellular transmitter equipped to transmit data
`messages or just a receiver equipped to receive data messages. It should be
`understood that further references to cellular transceiver 38 contemplate a
`transmitter, a receiver, or both.” ‘455 patent at 6:13-21
`
`“FIG. 7 illustrates a mobile unit 216 constructed according to the teachings
`of the present invention. As shown in FIG. 7, phone transceiver 238 and
`hand set 240 are coupled to cellular phone bus 242. Phone transceiver 238
`receives and transmits signals across antenna 244, including cellular
`transmission and reception of voice, data, and DTMF data, among other
`signals. The cellular phone bus 242 is coupled to processor 246 through
`phone interface drivers 248. Phone interface drivers 248 provide the
`necessary protocol for communications between the processor 246 and the
`phone transceiver 238 and hand set 240.” ‘455 patent at 13:50-60.
`“As shown in FIG. 2, cellular transceiver 38 is coupled to cellular
`transceiver bus 40. Cellular transceiver 38 receives and transmits signals
`across cellular antenna 42, including cellular transmission and reception of
`
`
`
`a wireless communications circuit having an antenna and
`configured to communicate over a communications network;
`
`
`
`
`1
`
`5
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`Ex. 2002
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`

`
`No. Claim
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`‘455 Patent
`voice and data over the voice and data channels in network 10. Cellular
`transceiver 38 may be just a cellular transmitter equipped to transmit data
`messages or just a receiver equipped to receive data messages. It should be
`understood that further references to cellular transceiver 38 contemplate a
`transmitter, a receiver, or both.” ‘455 patent at 6:13-21.
`
`“FIG. 7 illustrates a mobile unit 216 constructed according to the teachings
`of the present invention. As shown in FIG. 7, phone transceiver 238 and
`hand set 240 are coupled to cellular phone bus 242. Phone transceiver 238
`receives and transmits signals across antenna 244, including cellular
`transmission and reception of voice, data, and DTMF data, among other
`signals. The cellular phone bus 242 is coupled to processor 246 through
`phone interface drivers 248. Phone interface drivers 248 provide the
`necessary protocol for communications between the processor 246 and the
`phone transceiver 238 and hand set 240.” ‘455 patent at 13:50-60.
`
` One of ordinary skill would understand that such a transmitter would
`include an antenna. Figure 5 also illustrates an antenna on the mobile
`devices.
`
`
`
`
`2
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`6
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`M2M
`Ex. 2002
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`

`
`----
`
`-_.
`
`239
`
`
`
`No. Claim
`
`‘455 Patent
`
`----
`---
`r-------~~~~SYSTEM (1)
`
`II !
`
`/
`212
`\
`"
`I
`~I--J}-216
`I
`I@)@)
`
`III
`
`a programmable identity module having a unique identifier that is
`unique to the programmable communicator device
`
` a programmable interface connected to at least one wired or
`wirelessly attached monitoring device;
`
`
`
`
`
`
`
`
`3
`
`_
`
`_
`
`L
`
`“Every cellular phone has associated with it a mobile identification number
`("MIN") and an electronic serial number ("ESN"). These numbers are
`transmitted by the cellular phone whenever it makes a call or issues a
`feature request, such as "*19." Certain digits of the ESN are used by local
`cellular carriers” ‘455 patent at 17:22-26
`“Messaging unit 16 also allows for input of status information through
`sensor system 64. In one embodiment geosensor system 64 comprises
`sensors, controllers, and processors used to monitor various parameters of
`truck trailer 12, and operates to pass status information to processor 44.
`Sensor system 64 may monitor performance parameters of truck trailer 12,
`such as the temperature of a refrigerated compartment, battery voltage
`levels, or diagnostics of other truck trailer subsystems. Sensor system 64
`may also monitor the status of truck trailer 12 and its contents, such as
`whether truck trailer 12 is connected to a cab and whether the contents
`have been tampered with. For purposes of this description, "sensor" refers
`to any device that furnishes processor 44 with location and status
`information, including a positioning system.” ‘455 patent at 6:66-7:12.
`
`7
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`M2M
`Ex. 2002
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`

`
`‘455 Patent
`
` “
`
` For example, data messages received by messaging unit 16 may be sent
`over a data channel using MIN statusing or feature request generation, or
`over a voice channel using a data encoder, such as a modem or DTMF
`recognizer. 10 Received data messages at messaging unit 16 may serve a
`variety of functions, such as remotely programming predetermined sensor
`reporting limits, updating messaging unit 16 software, requesting
`information, or alerting the operator of the transportation system among
`others.” ‘455 patent at 12:7-14.
`
`“Mobile unit 216 allows for input of location information from a LORAN-
`C system, a global positioning satellite (GPS) system or any suitable
`system providing location information of the mobile unit. This input is
`shown by positioning system 272 in FIG. 7. The positioning system 272
`may be located within the housing of the mobile unit 216, or part or all of
`positioning system 272 may be located outside the mobile unit 216. The
`data sent to the mobile unit 216 from positioning system 272 can be either
`raw location data (for example, data directly received from LORAN-C
`system) or processed location data. Therefore, the processing of raw
`location data can occur within the positioning system 272 itself, within
`processor 246, or transmitted through phone transceiver 238 and antenna
`244 for later 50 processing at the platform 224 or central host 226 of FIG.
`5.
`
`Mobile unit 216 also allows for input of status information through
`automatic status generator 274. The automatic status generator 274
`comprises any sensors, controllers, and processors used to monitor
`performance parameters of the 55 vehicle 212, and operates to pass
`information from such monitors to the mobile unit 216. As will be
`discussed, status information may be received by the mobile unit 216 from
`
`No. Claim
`
`
`
`4
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`‘455 Patent
`either the automatic status generator 274 or the key pad 266. Block 276
`allows for the input or output of various other 60 options, such as an alarm
`input which, for example, could indicate that a vehicle on which the mobile
`unit is located has been broken into.” ‘455 patent at 14:36-62.
`
`“As discussed above, positioning system 272 may generate longitude and
`latitude information, or simply raw data, for example from a GPS system,
`to be transmitted from mobile unit 216. If only raw data is generated by a
`positioning system 272, then processor 246, the platform 224, or the
`central host 226 can generate the longitude and latitude information for
`positioning information. Likewise, automatic status generator 274 may be
`used to automatically generate status information, such as engine
`performance, trailer temperature (for example, if a refrigerated trailer
`tractor is associated with the remote unit), or other status information.”
`‘455 patent at 15:47-58.
`
`
`
`The mobile devices disclosed in Kennedy have a limited number of pre-
`programmed numbers that can be called.
`
`“The mobile unit 216 can be programmed such that only certain pre-
`programmed numbers can be called. These authorized phone numbers are
`stored in remote unit 216 and can be programmed remotely by the central
`host 226 or platform 224.” ‘455 patent at 20:28-33.
`
`These programming updates are obtained through the use of calls to the
`remote unit. ‘455 patent at 12:7-14.
`
`All calls to the remote unit require presentation of a unique key based on
`the MIN/ESN.
`
`
`5
`
`No. Claim
`
`a processing module configured to receive and authenticate an at
`least one transmission from a programming transmitter, the at least
`one transmission including a coded number and at least one
`telephone number or IP address corresponding to the at least one
`monitoring device, wherein the processing module is configured to
`authenticate the at least one transmission by determining if the at
`least one transmission contains the coded number, the processing
`module authenticating the at least one transmission if the
`transmission includes the coded number;
`
`
`
`
`
`
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`‘455 Patent
`“Platform 224 then calls the appropriate roamer access port, and dials the
`phone number. Once the call is connected and the platform and mobile unit
`modems establish data communication, the mobile unit 216 issues a
`challenge at block 330. This challenge may be, for example, a random
`number. If no challenge is received, then the platform 224 disconnects the
`call at block 331. If the platform receives a challenge, then at block 332
`the platform returns a response based on the challenge received, a key
`particular to the mobile unit, and an encryption algorithm. As noted, the
`key used in the generation of the response is a function of the mobile unit
`and may be generated from a lookup table of numbers shared by both
`mobile unit 216 and platform 224 indexed by the MIN/ESN of mobile unit
`216. The encryption algorithm, also known by both mobile unit 216 and
`platform 224 can be any appropriate mathematical algorithm, and may be
`modified periodically, as can the lookup table, to maximize security.” ‘455
`patent at 19:30-46.
`
`“The mobile unit 216 can be programmed such that only certain pre-
`programmed numbers can be called. These authorized phone numbers are
`stored in remote unit 216 and can be programmed remotely by the central
`host 226 or platform 224.” ‘455 patent at 20:28-33.
`
`The mobile unit includes a RAM for storing data related to the operation of
`the mobile unit.
`
`“Processor 246 is also coupled to a read-only memory 260 and a random
`access memory 262. These memories are for storage of instructions and
`data for operation of processor 246.” 14:22-28.
`“Mobile unit 216 allows for input of location information from a LORAN-
`C system, a global positioning satellite (GPS) system or any suitable
`system providing location information of the mobile unit. This input is
`
`
`
`No. Claim
`
`
`
`and a memory module configured to store the at least one
`telephone number or IP address from the authenticated
`transmission as one of a plurality of permitted callers if the
`processing module authenticates the at least one transmission by
`determining that the at least one transmission includes the coded
`number.
`
`110 A programmable communicator device according to claim 107
`further comprising: a GPS module configured to determine at least
`one location of the programmable communicator device and store
`
`
`
`6
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`Ex. 2002
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`

`
`No. Claim
`the at least one location into the GPS module's memory; and
`wherein the programmable communicator device is further
`configured to receive and authenticate a request and transmit the at
`least one location to at least one of the plurality of stored permitted
`callers in response to the authenticated request.
`
`‘455 Patent
`shown by positioning system 272 in FIG. 7. The positioning system 272
`may be located within the housing of the mobile unit 216, or part or all of
`positioning system 272 may be located outside the mobile unit 216. The
`data sent to the mobile unit 216 from positioning system 272 can be either
`raw location data (for example, data directly received from LORAN-C
`system) or processed location data. Therefore, the processing of raw
`location data can occur within the positioning system 272 itself, within
`processor 246, or transmitted through phone transceiver 238 and antenna
`244 for later 50 processing at the platform 224 or central host 226 of FIG.
`5.
`
`Mobile unit 216 also allows for input of status information through
`automatic status generator 274. The automatic status generator 274
`comprises any sensors, controllers, and processors used to monitor
`performance parameters of the 55 vehicle 212, and operates to pass
`information from such monitors to the mobile unit 216. As will be
`discussed, status information may be received by the mobile unit 216 from
`either the automatic status generator 274 or the key pad 266. Block 276
`allows for the input or output of various other 60 options, such as an alarm
`input which, for example, could indicate that a vehicle on which the mobile
`unit is located has been broken into.” ‘455 patent at 14:36-62.
`
`“As discussed above, positioning system 272 may generate longitude and
`latitude information, or simply raw data, for example from a GPS system,
`to be transmitted from mobile unit 216. If only raw data is generated by a
`positioning system 272, then processor 246, the platform 224, or the
`central host 226 can generate the longitude and latitude information for
`positioning information. Likewise, automatic status generator 274 may be
`used to automatically generate status information, such as engine
`performance, trailer temperature (for example, if a refrigerated trailer
`tractor is associated with the remote unit), or other status information.”
`
`
`
`7
`
`11
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`Ex. 2002
`
`

`
`‘455 Patent
`‘455 patent at 15:47-58.
`
`
`
`“One reporting event that may trigger generation of a data message is a
`time-out signal received by processor 44 from real-time clock 56.
`Therefore, messaging unit 16 may generate data messages and report
`location and status information for truck trailer 12 at a particular time
`interval, such as twice a day, every day, or every week. In addition, a
`reporting event may be an external request from a variety of sources, such
`as MTSO 20, clearinghouse 22, platform 24 and host 26, among others.”
`‘455 patent at 7:44-51.
`
`
`
`“Mobile unit 216 allows for input of location information from a LORAN-
`C system, a global positioning satellite (GPS) system or any suitable
`system providing location information of the mobile unit. This input is
`shown by positioning system 272 in FIG. 7. The positioning system 272
`may be located within the housing of the mobile unit 216, or part or all of
`positioning system 272 may be located outside the mobile unit 216. The
`data sent to the mobile unit 216 from positioning system 272 can be either
`raw location data (for example, data directly received from LORAN-C
`system) or processed location data. Therefore, the processing of raw
`location data can occur within the positioning system 272 itself, within
`processor 246, or transmitted through phone transceiver 238 and antenna
`244 for later 50 processing at the platform 224 or central host 226 of FIG.
`5.
`
`Mobile unit 216 also allows for input of status information through
`automatic status generator 274. The automatic status generator 274
`comprises any sensors, controllers, and processors used to monitor
`
`No. Claim
`
`124 A programmable communicator device according to claim 107,
`wherein the programmable communicator device is further
`configured to communicate between the at least one monitoring
`device and at least one interfaced device.
`
`
`
`8
`
`12
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`M2M
`Ex. 2002
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`

`
`No. Claim
`
`125 A programmable communicator device according to claim 124,
`wherein the interfaced device is a medical device configured to
`monitor at least one from the group consisting of body
`
`‘455 Patent
`performance parameters of the 55 vehicle 212, and operates to pass
`information from such monitors to the mobile unit 216. As will be
`discussed, status information may be received by the mobile unit 216 from
`either the automatic status generator 274 or the key pad 266. Block 276
`allows for the input or output of various other 60 options, such as an alarm
`input which, for example, could indicate that a vehicle on which the mobile
`unit is located has been broken into.” ‘455 patent at 14:36-62.
`
`“As discussed above, positioning system 272 may generate longitude and
`latitude information, or simply raw data, for example from a GPS system,
`to be transmitted from mobile unit 216. If only raw data is generated by a
`positioning system 272, then processor 246, the platform 224, or the
`central host 226 can generate the longitude and latitude information for
`positioning information. Likewise, automatic status generator 274 may be
`used to automatically generate status information, such as engine
`performance, trailer temperature (for example, if a refrigerated trailer
`tractor is associated with the remote unit), or other status information.”
`‘455 patent at 15:47-58.
`
`“One reporting event that may trigger generation of a data message is a
`time-out signal received by processor 44 from real-time clock 56.
`Therefore, messaging unit 16 may generate data messages and report
`location and status information for truck trailer 12 at a particular time
`interval, such as twice a day, every day, or every week. In addition, a
`reporting event may be an external request from a variety of sources, such
`as MTSO 20, clearinghouse 22, platform 24 and host 26, among others.”
`‘455 patent at 7:44-51.
`
`
`
`
`
`9
`
`13
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`M2M
`Ex. 2002
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`

`
`No. Claim
`temperature, blood pressure, periodic or continuous
`electrocardiogram heart rhythm, blood glucose concentration,
`blood electrolyte concentration, kidney function, liver function,
`and labor contractions.
`131 A programmable communicator device according to claim 107,
`wherein the at least one transmission can be sent using a
`messaging protocol such as a mobile telecommunications Short
`Message Service (SMS) or via a packet switching network such as
`GPRS within the telecommunications standard of GSM or
`WCDMA or US-TDMA.
`133 A programmable communicator device according to claim 107,
`wherein, the programmable communicator device is further
`configured to receive data from at least one data monitoring
`devices and transmit the received data to at least one of the
`plurality of stored permitted callers.
`
`‘455 Patent
`
`“Another communications protocol contemplated by the invention, termed
`cellular digital packet data (CDPD), sends data in packets interspersed
`between voice transmissions.” ‘455 patent at 5:36-38.
`
`“Mobile unit 216 allows for input of location information from a LORAN-
`C system, a global positioning satellite (GPS) system or any suitable
`system providing location information of the mobile unit. This input is
`shown by positioning system 272 in FIG. 7. The positioning system 272
`may be located within the housing of the mobile unit 216, or part or all of
`positioning system 272 may be located outside the mobile unit 216. The
`data sent to the mobile unit 216 from positioning system 272 can be either
`raw location data (for example, data directly received from LORAN-C
`system) or processed location data. Therefore, the processing of raw
`location data can occur within the positioning system 272 itself, within
`processor 246, or transmitted through phone transceiver 238 and antenna
`244 for later 50 processing at the platform 224 or central host 226 of FIG.
`5.
`
`Mobile unit 216 also allows for input of status information through
`automatic status generator 274. The automatic status generator 274
`comprises any sensors, controllers, and processors used to monitor
`performance parameters of the 55 vehicle 212, and operates to pass
`information from such monitors to the mobile unit 216. As will be
`discussed, status information may be received by the mobile unit 216 from
`either the automatic status generator 274 or the key pad 266. Block 276
`
`
`
`10
`
`14
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`M2M
`Ex. 2002
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`

`
`‘455 Patent
`allows for the input or output of various other 60 options, such as an alarm
`input which, for example, could indicate that a vehicle on which the mobile
`unit is located has been broken into.” ‘455 patent at 14:36-62.
`
`“As discussed above, positioning system 272 may generate longitude and
`latitude information, or simply raw data, for example from a GPS system,
`to be transmitted from mobile unit 216. If only raw data is generated by a
`positioning system 272, then processor 246, the platform 224, or the
`central host 226 can generate the longitude and latitude information for
`positioning information. Likewise, automatic status generator 274 may be
`used to automatically generate status information, such as engine
`performance, trailer temperature (for example, if a refrigerated trailer
`tractor is associated with the remote unit), or other status information.”
`‘455 patent at 15:47-58.
`
`
`
`“One reporting event that may trigger generation of a data message is a
`time-out signal received by processor 44 from real-time clock 56.
`Therefore, messaging unit 16 may generate data messages and report
`location and status information for truck trailer 12 at a particular time
`interval, such as twice a day, every day, or every week. In addition, a
`reporting event may be an external request from a variety of sources, such
`as MTSO 20, clearinghouse 22, platform 24 and host 26, among others.”
`‘455 patent at 7:44-51.
`
`
`11
`
`No. Claim
`
`
`
`
`
`15
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`M2M
`Ex. 2002
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`

`
`‘455 Patent
`
`“As shown in FIG. 2, cellular transceiver 38 is coupled to cellular transceiver bus 40.
`Cellular transceiver 38 receives and transmits signals across cellular antenna 42,
`including cellular transmission and reception of voice and data over the voice and data
`channels in network 10. Cellular transceiver 38 may be just a cellular transmitter
`equipped to transmit data messages or just a receiver equipped to receive data
`messages. It should be understood that further references to cellular transceiver 38
`contemplate a transmitter, a receiver, or both.” ‘455 patent at 6:13-21
`
`“FIG. 7 illustrates a mobile unit 216 constructed according to the teachings of the
`present invention. As shown in FIG. 7, phone transceiver 238 and hand set 240 are
`coupled to cellular phone bus 242. Phone transceiver 238 receives and transmits
`signals across antenna 244, including cellular transmission and reception of voice,
`data, and DTMF data, among other signals. The cellular phone bus 242 is coupled to
`processor 246 through phone interface drivers 248. Phone interface drivers 248
`provide the necessary protocol for communications between the processor 246 and the
`phone transceiver 238 and hand set 240.” ‘455 patent at 13:50-60.
`“As shown in FIG. 2, cellular transceiver 38 is coupled to cellular transceiver bus 40.
`Cellular transceiver 38 receives and transmits signals across cellular antenna 42,
`including cellular transmission and reception of voice and data over the voice and data
`channels in network 10. Cellular transceiver 38 may be just a cellular transmitter
`equipped to transmit data messages or just a receiver equipped to receive data
`messages. It should be understood that further references to cellular transceiver 38
`contemplate a transmitter, a receiver, or both.” ‘455 patent at 6:13-21
`
`“FIG. 7 illustrates a mobile unit 216 constructed according to the teachings of the
`present invention. As shown in FIG. 7, phone transceiver 238 and hand set 240 are
`coupled to cellular phone bus 242. Phone transceiver 238 receives and transmits
`
`
`U.S. Patent No. 8,094,010
`
`No. Claim
`52 A programmable communicator device comprising:
`
`
`
`
`
`a wireless communications circuit for communicating
`through an antenna over a communications network;
`
`
`
`12
`
`16
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`M2M
`Ex. 2002
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`

`
`No. Claim
`
`‘455 Patent
`signals across antenna 244, including cellular transmission and reception of voice,
`data, and DTMF data, among other signals. The cellular phone bus 242 is coupled to
`processor 246 through phone interface drivers 248. Phone interface drivers 248
`provide the necessary protocol for communications between the processor 246 and the
`phone transceiver 238 and hand set 240.” ‘455 patent at 13:50-60.
`
`One of ordinary skill would understand that such a transmitter would include an
`antenna. Figure 5 also illustrates an antenna on the mobile devices.
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`“Messaging unit 16 also allows for input of status information through sensor system
`64. In one embodiment geosensor system 64 comprises sensors, controllers, and
`processors used to monitor various parameters of truck trailer 12, and operates to pass
`status information to processor 44. Sensor system 64 may monitor performance
`parameters of truck trailer 12, such as the temperature of a refrigerated compartment,
`battery voltage levels, or diagnostics of other truck trailer subsystems. Sensor system
`64 may also monitor the status of truck trailer 12 and its contents, such as whether
`truck trailer 12 is connected to a cab and whether the contents have been tampered
`
`
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`a programmable interface for establishing a
`communication link with at least one monitored
`technical device;
`
`
`
`13
`
`17
`
`M2M
`Ex. 2002
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`

`
`‘455 Patent
`with. For purposes of this description, "sensor" refers to any device that furnishes
`processor 44 with location and status information, including a positioning system.”
`‘455 patent at 6:66-7:12.
`
` For example, data messages received by messaging unit 16 may be sent over a data
`channel using MIN statusing or feature request generation, or over a voice channel
`using a data encoder, such as a modem or DTMF recognizer. 10 Received data
`messages at messaging unit 16 may serve a variety of functions, such as remotely
`programming predetermined sensor reporting limits, updating messaging unit 16
`software, requesting information, or alerting the operator of the transportation system
`among others.” ‘455 patent at 12:7-14.
`
`“Mobile unit 216 allows for input of location information from a LORAN-C system, a
`global positioning satellite (GPS) system or any suitable system providing location
`information of the mobile unit. This input is shown by positioning system 272 in FIG.
`7. The positioning system 272 may be located within the housing of the mobile unit
`216, or part or all of positioning system 272 may be located outside the mobile unit
`216. The data sent to the mobile unit 216 from positioning system 272 can be either
`raw location data (for example, data directly received from LORAN-C
`system) or processed location data. Therefore, the processing of raw location data can
`occur within the positioning system 272 itself, within processor 246, or transmitted
`through phone transceiver 238 and antenna 244 for later 50 processing at the platform
`224 or central host 226 of FIG. 5.
`
`Mobile unit 216 also allows for input of status information through automatic status
`generator 274. The automatic status generator 274 comprises any sensors, controllers,
`and processors used to monitor performance parameters of the 55 vehicle 212, and
`operates to pass information from such monitors to the mobile unit 216. As will be
`discussed, status information may be received by the mobile unit 216 from either the
`automatic status generator 274 or the key pad 266. Block 276 allows for the input or
`
` “
`
`No. Claim
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`
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`14
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`18
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`M2M
`Ex. 2002
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`

`
`‘455 Patent
`output of various other 60 options, such as an alarm input which, for example, could
`indicate that a vehicle on which the mobile unit is located has been broken into.” ‘455
`patent at 14:36-62.
`
`“As discussed above, positioning system 272 may generate longitude and latitude
`information, or simply raw data, for example from a GPS system, to be transmitted
`from mobile unit 216. If only raw data is generated by a positioning system 272, then
`processor 246, the platform 224, or the central host 226 can generate the longitude and
`latitude information for positioning information. Likewise, automatic status generator
`274 may be used to automatically generate status information, such as engine
`performance, trailer temperature (for example, if a refrigerated trailer tractor is
`associated with the remote unit), or other status information.” ‘455 patent at 15:47-58.
`
`The mobile devices disclosed in Kennedy have a limited number of pre-programmed
`numbers that can be called.
`
`“The mobile unit 216 can be programmed such that only certain pre-programmed
`numbers can be called. These authorized phone numbers are stored in remote unit 216
`and can be programmed remotely by the central host 226 or platform 224.” ‘455 patent
`at 20:28-33.
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`These programming updates are obtained through the use of calls to the remote unit.
`‘455 patent at 12:7-14.
`
`All calls to the remote unit requir