IN UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`C.A. No. 12-030-RGA
`
`
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`C.A. No. 12-031-RGA
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`
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`C.A. No. 12-032-RGA
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`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
`
`M2M
`Ex. 2002
`
`

`
`C.A. No. 12-033-RGA
`
`
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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
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`information reasonably available to Defendants, and Defendants expressly reserve the right to
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`amend, or supplement these Initial Contentions based on further investigation, discovery,
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`- 2 -
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`2
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`M2M
`Ex. 2002
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`

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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
`
`
`
`
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`were caused to be served on March 8, 2013 upon the following, via electronic mail containing a
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`hyperlink, username and password to a file transfer protocol (“FTP”) window containing
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`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
`
`

`
`Chicago, IL 60654
`Attorneys for MSM Solutions LLC
`
`
`
`
` s/ Keren Livneh
`Keren Livneh
`
`
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`
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`4
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`M2M
`Ex. 2002
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`

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`Appendix X - US Patent No. 6,900,737 (“Ardalan”)
`
`
`
`
`The following charts and references disclose how US Patent No. 6,900,737 (“Ardalan”), incorporating GSM 03.02 version 5.5.0 (published
`March 1996), disclosed the subject matter of the asserted claims. Ardalan has a priority date of February 12, 1997 and is prior art to the asserted
`patents under 35 U.S.C. §102(a).
`
`U.S. Patent No. 7,583,197
`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`107 A programmable communicator device comprising:
`
`“The present invention provides an automatic meter reading (AMR) system
`that collects readings from multiple or individual meters or sets parameters
`in individual or multiple meters using the Short Message Service (SMS) in
`digital cellular networks” (col. 1 ll. 33-37).
`
`“Meters can also be programmed by SMS packets from the AMR server”
`(col. 7 lines 54-55).
`“A single meter 21 … with its own wireless access module to the SMS of
`the DCN [Digital Cellular Network] 10 can receive SMS packets and return
`the results to the originator of the SMS packet via the DCN” (col. 7 lines 1-
`4); “providing each meter with a direct interface to the DCN 10 so that
`every meter can send and receive SMS packets” (col. 3 ll. 55-58). DCN is a
`“digital cellular network” (col. 1 ll. 46-47).
`
` A
`
` direct interface to a Digital Cellular Network (DCN) inherently includes
`an antenna.
`“The meters 21 … may send may send the following types of messages …
`Reading of the unique 32-bit meter ID” (col. 4 ll. 14-15 and 24).
`
`“the meters … send the following types of messages to the AMR server: (1)
`notification of meter tampering; (2) notification of power outages; (3)
`
`
`
`
`
`
`
`a wireless communications circuit having an antenna and
`configured to communicate over a communications network;
`
`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
`
`5
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`M2M
`Ex. 2002
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`

`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`
`
`wirelessly attached monitoring device;
`
`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; 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
`
`
`
`
`
`
`
`reading of current power usage; (4) reading of current rate of power usage”
`(col. 2 ll. 22-26).
`
`“The meter application encapsulates the meter reading along with its ID into
`a SMS packet. The phone number of the meter's AMR communications
`gateway is dialed and the SMS packet is sent back via the SMS” (col. 7
`lines 26-29).
`“the AMR server sends the following types of messages to the meters: …
`notification of a new phone number or numbers with which to reach the
`AMR communications gateway” (col. 3 line 63 – col. 4 line 9); “The
`messages from the AMR server to the []meters … includes the
`following: A 32-bit identifier of the recipient of the message” (col. 4 line
`34), i.e., a coded number (col. 4 line 24); see also “The AMR server sends
`and receives packets that refer to meters using the 32-bit IDs” (col. 5 lines
`6-8).
`
`See also: “The messages from the AMR server to the node/meters … are all
`encoded as strings of 0 and 1 bits” (col. 4 ll. 28-30) – As per M2M’s
`infringement contention, any encrypted number is a coded number that is
`authorized.
`“1. The meter receives a SMS packet and unpacks it to examine the meter
`ID contained in the user data portion. … 2. If the ID contained in the packet
`does not match the ID of the meter or the special broadcast ID, then the
`packet is ignored.” (Col. 7 lines 6-12.)
`
`“Each … ([] meter 21 in the case where each meter has a direct interface to
`the SMS) stores the phone number it uses to communicate back to the AMR
`server 23. [A] … ([] meter) may store multiple phone numbers in the event
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`M2M
`Ex. 2002
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`

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`
`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`at least one transmission includes the coded number.
`
`that the first phone number is out of service” (col. 5 lines 40-44).
`
`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 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.
`
`“It is also possible for meters to self-initiate the transfer of data to the AMR
`server. Such self-initiation can be used in the event of exception conditions
`detected by a meter” (col. 7 ll. 50-53). “the meters … send the following
`types of messages to the AMR server: (1) notification of meter tampering;
`(2) notification of power outages” (col. 2 ll. 22-25).
`Since meters are not generally portable, there was no need for a GPS
`module in the remote unit, since the location of the device could be changed
`manually if the meters were to be moved.
`
`However, at the time of filing of the ‘197 Patent, portable devices for
`providing alerts and GPS location over a digital cellular network were
`known. See, e.g., U.S. Pat. No. 5,742,233 (Personal security and tracking
`system), which has as its object to “combine the advantages of long-range
`navigation systems, such as [GPS]… with extensive communication
`capabilities of a wireless communication system, such as cellular telephone
`system,… to yield a practical personal security and tracking system with…
`emergency assistance capabilities.” (Col. 5, lines 39-48).
`
`It would have been obvious to implement the remote programming system
`of Ardalan in a portable device such as disclosed by U.S. Pat. No.
`5,742,233, and to include a GPS module to determine and communicate the
`location of the device in order to alert a monitoring individual to the
`location of the device when an alert for device tampering was triggered.
`
`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.
`
`See also “The AMR server 23 may send the following types of messages to
`the meters:
`3. Commands to shut-down appliances.
`4. Commands to apply power to appliances.”
`
`- 3 -
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`7
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`M2M
`Ex. 2002
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`

`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`
`
`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
`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.
`
`(col. 3 line 63 – col. 4 line 1)
`
`“The invention is more particularly intended for, although not limited to,
`use in an electronic meter” (col. 1 ll. 17-19).
`At the time of the filing of the ‘197 Patent, devices and systems for
`remotely monitoring medical or physiological parameters were known. See,
`e.g., PCT International Application Publication No. WO 99/56262 (Control
`system for building automation controlled by human physiological signals);
`U.S. Pat. No. 5,997,476 (Networked system for interactive communication
`and remote monitoring of individuals).
`WO 99/56262 disclosed sensors for monitoring heart rate. (p. 5, lines 9-14);
`U.S. Pat. No. 5,997,476 disclosed monitoring physiological parameters such
`as blood glucose, respiratory flow, blood pressure, weight, and pulse rate.
`(Col. 4, line 64 – Col. 5, line 13).
`It would have been obvious to use remote monitoring disclosed by Ardalan
`in a health monitoring system for communicating monitored health data to
`programmed numbers in order to expand monitoring applications to the
`medical industry.
`“the present invention offers … the ability to set and read parameters in
`individual and multiple meters using digital cellular technology including
`CDMA, TDMA and GSM; [] the ability to set and read parameters in
`individual and multiple meters using digital cellar technology using the
`Short Messaging Service (SMS)” (col. 8 ll. 23-28).
`
`“providing each meter with a direct interface to the DCN 10 so that every
`meter can send and receive SMS packets” (col. 3 lines 56-58). “An SMS is
`available in systems following the CDMA, TDMA and GSM standards”
`(col. 2 ll. 55-64).
`
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`- 4 -
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`M2M
`Ex. 2002
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`

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`
`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`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.
`
`“the meters … send the following types of messages to the AMR server: (1)
`notification of meter tampering; (2) notification of power outages; (3)
`reading of current power usage; (4) reading of current rate of power usage”
`(col. 2 ll. 22-26).
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`- 5 -
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`M2M
`Ex. 2002
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`

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`U.S. Patent No. 8,094,010
`
`No. Claim limitation
`
`
`
`US Patent No. 6,900,737
`
`52
`
`A programmable communicator device comprising:
`
`See claim 107 of the ‘197 Patent above.
`
`
`
`
`
`
`
`
`
`
`
`
`
`a wireless communications circuit for communicating through an
`antenna over a communications network;
`
`See claim 107 of the ‘197 Patent above.
`
`a programmable interface for establishing a communication link
`with at least one monitored technical device;
`
`“The meter application will query the meter electronics to find the current
`reading.” (col. 7 lines 24-25).
`
`a processing module for authenticating an at least one
`transmission sent from a programming transmitter and received
`by the programmable communicator device,
`
`the at least one transmission including a coded number and at
`least one telephone number or Internet Protocol (IP) address
`corresponding to an at least one monitoring device,
`
`wherein the processing module authenticates 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;
`
`wherein the programmable communicator device uses a memory
`module for storing the at least one telephone number or IP
`address from the authenticated transmission as one of one or
`more permitted callers if the processing module authenticates the
`at least one transmission by determining that the at least one
`transmission includes the coded number;
`
`See claim 107 of the ‘197 Patent above.
`
`See claim 107 of the ‘197 Patent above.
`
`See claim 107 of the ‘197 Patent above.
`
`See claim 107 of the ‘197 Patent above.
`
`- 6 -
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`10
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`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`
`
`
`
`54
`
`57
`
`wherein the programmable communicator device uses an identity
`module for storing a unique identifier that is unique to the
`programmable communicator device; and
`
`wherein the at least one transmission from a programming
`transmitter comprises a Short Message Service (SMS) data
`message, or a General Packet Radio Service (GPRS) or other
`packet switched data message.
`
`A programmable communicator device according to claim 52
`wherein the programmable interface is programmable via
`wireless transmissions.
`
`A programmable communicator device according to claim 52
`wherein the at least one transmission from a programming
`transmitter comprises a GPRS data message.
`
`
`
`US Patent No. 6,900,737
`
`See claim 107 of the ‘197 Patent above.
`
`“the present invention offers … the ability to set and read parameters in
`individual and multiple meters using digital cellular technology including
`CDMA, TDMA and GSM; [] the ability to set and read parameters in
`individual and multiple meters using digital cellar technology using the
`Short Messaging Service (SMS)” (col. 8 ll. 23-28).
`
`“Meters can also be programmed by SMS packets from the AMR server to
`periodically dump their data over the DCN” (col. 7 lines 54-56). DCN is a
`“digital cellular network,” which is wireless (col. 1 ll. 46-47).
`
`“the present invention offers … the ability to set and read parameters in
`individual and multiple meters using digital cellular technology including
`CDMA, TDMA and GSM; [] the ability to set and read parameters in
`individual and multiple meters using digital cellar technology using the
`Short Messaging Service (SMS)” (col. 8 ll. 23-28).
`
`At the time of the filing of the ‘010 Patent, General packet radio service
`(GPRS) was known to be a faster alternative to the SMS packet service used
`by Ardalan. For example, the GSM and Personal Communications
`Handbook disclosed, “SMS provides a packet transfer mode, but for
`evolving mobile packet systems the capacity of SMS is insufficient. GPRS
`provides a solution to a growing demand for packet-oriented data services.
`Because this service also requires higher data rates, the average size of data
`packages tends to grow with time and GPRS allows for data rates of up to
`170Kbps” (pp. 199-200).
`
`It would have been obvious to use GPRS to operate the GSM standard to
`
`- 7 -
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`11
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`M2M
`Ex. 2002
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`

`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`
`
`58
`
`59
`
`62
`
`63
`
`A programmable communicator device according to claim 52
`wherein each permitted caller has a corresponding stored
`telephone number or IP address from which the programmable
`communicator device
`is permitted
`to
`receive
`incoming
`transmissions for processing.
`
`A programmable communicator device according to claim 52
`wherein each permitted caller has a corresponding stored
`telephone number or IP address to which the programmable
`communicator device is permitted to send outgoing
`transmissions.
`
`A programmable communicator device according to claim 52
`configured to receive data through the programmable interface
`from an at least one monitored technical device.
`
`A programmable communicator device according to claim 62
`configured to process the data received through the
`programmable interface from an at least one monitored technical
`
`increase the speed of data transmissions in Ardalan’s Digital Cellular
`Network DCN 10.
`
`“the meters … send the following types of messages to the AMR server: (1)
`notification of meter tampering” (col. 2 ll. 22-24).
`At the time of filing of the ‘010 Patent, it was known to allow incoming
`transmissions from only a limited group of callers. See, e.g., U.S. Patent
`No. 6,567,671: “In accordance with an aspect of this invention, a cellular
`telephone includes a memory for storing a screening list specifying calling
`party numbers and associated call handling, and a processor for responding
`to an incoming call in accordance with the screening list.” (1:36-41).
`Ardalan permits communication between meters and the AMR server (col. 7
`ll. 20-29). It would have been obvious to limit the parties who can call the
`meters to the programmed AMR numbers in order prevent unauthorized
`intervention resulting in “meter tampering” (col. 2 ll. 22-24).
`“Each … ([] meter 21 in the case where each meter has a direct interface to
`the SMS) stores the phone number it uses to communicate back to the AMR
`server 23. [A] … ([] meter) may store multiple phone numbers in the event
`that the first phone number is out of service” (col. 5 lines 40-44).
`
`“The meter application will query the meter electronics to find the current
`reading” (col. 7 ll. 24-25).
`
`“The meter application encapsulates the meter reading along with its ID into
`a SMS packet” (col. 7 ll. 26-27).
`
`- 8 -
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`12
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`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`device.
`
`
`
`US Patent No. 6,900,737
`
`A programmable communicator device according to claim 63,
`wherein the processing module processes the received data.
`
`Ibid. A meter running a meter application inherently uses a processing
`module to encapsulate the meter reading and its ID into a SMS packet.
`
`“The phone number of the meter's AMR communications gateway is dialed
`and the SMS packet is sent back via the SMS” (col. 7 ll. 27-29).
`
`Periodically: “Meters can also be programmed by SMS packets from the
`AMR server to periodically dump their data over the DCN” (col. 7 ll. 53-
`54).
`
`Request Initiated: “the command requests the meter to find and return its
`current reading. []The meter application will query the meter electronics to
`find the current reading. [] The meter application encapsulates the meter
`reading along with its ID into a SMS packet. The phone number of the
`meter's AMR communications gateway is dialed and the SMS packet is sent
`back via the SMS” (col. 7 ll. 20-29).
`
`See also: “The AMR server 23 may send the following types of messages to
`the meters: 1. Commands to send their current usage reading” (col. 3 ll. 63-
`65). “The meters 21 … may send the following types of messages to the
`AMR server: 3. Reading of current power usage” (col. 4 ll. 14-15 and 19).
`“The phone number of the meter's AMR communications gateway is dialed
`and the SMS packet is sent back via the SMS” (col. 7 ll. 27-29).
`
`The meter inherently uses a processing module to operate the meter
`application (col. 7 ll. 20-29).
`“It is also possible for meters to self-initiate the transfer of data to the AMR
`server. Such self-initiation can be used in the event of exception conditions
`
`- 9 -
`
`64
`
`66
`
`A programmable communicator device according to claim 63
`further configured to transmit the processed data to an at least one
`monitoring device either periodically or in response to a request
`initiated by the monitoring device.
`
`67
`
`A programmable communicator device according to claim 66,
`wherein the processing module causes the processed data to be
`transmitted to the at least one monitoring device.
`
`70
`
`A programmable communicator device according to claim 63
`wherein the received data is processed to determine whether it
`
`13
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`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`indicates a change in status of the at least one monitored technical
`device that crosses a threshold parameter, or that otherwise
`indicates an alarm condition.
`
`
`
`US Patent No. 6,900,737
`
`detected by a meter” (col. 7 ll. 50-53)
`
`71
`
`78
`
`79
`
`80
`
`81
`
`82
`
`A programmable communicator device according to claim 70
`further configured to send an at least one transmission for alerting
`an at least one monitoring device of said change in status or other
`alarm condition.
`
`Ibid.
`
`A programmable communicator device according to claim 52
`configured to process an at least one data monitoring or data
`collection request contained in an at least one transmission
`received from an at least one monitoring device.
`
`A programmable communicator device according to claim 78,
`wherein the processing module processes the at least one data
`monitoring or data collection request.
`
`A programmable communicator device according to claim 52
`wherein the communications network is a cellular mobile
`telecommunications network.
`
`A programmable communicator device according to claim 80
`wherein the cellular mobile telecommunications network utilizes
`GSM air interface standards.
`
`“The meter application will examine the data to see what action is being
`requested. In this example, assume the command requests the meter to find
`and return its current reading” (col. 7 ll. 20-23).
`
`“When all pieces of the segmented packet are received, the entire data
`portion of the original command is extracted. [] The meter application will
`examine the data to see what action is being requested. In this example,
`assume the command requests the meter to find and return its current
`reading” (col. 7 ll. 17-22).
`
`“A single meter 21 … with its own wireless access module to the SMS of
`the DCN 10 can receive SMS packets and return the results to the originator
`of the SMS packet via the DCN” (col. 7 lines 1-4). DCN is a “digital
`cellular network” (col. 1 ll. 46-47).
`
`“An SMS is available in systems following the … GSM standards” (col. 2
`ll. 58-59).
`
`A programmable communicator device according to claim 80
`wherein the cellular mobile telecommunications network utilizes
`
`“the present invention offers … the ability to set and read parameters in
`individual and multiple meters using digital cellular technology including
`
`- 10 -
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`14
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`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`CDMA air interface standards.
`
`CDMA, TDMA and GSM” (col. 8 ll. 23-25).
`
`
`
`87
`
`A programmable communicator device according to claim 52
`wherein a user identity card utilized by the programmable
`communicator device to access a cellular mobile
`telecommunications network comprises the memory module for
`storing the at least one telephone number or IP address from the
`authenticated transmission.
`
`GSM 03.02 version 5.50 (cited in col. 1 ll. 59-64 of the ‘737 Patent)
`discloses a “Subscriber Identity Module (SIM)” (p. 15 section 3.11), which
`was known to store numbers.
`
`At the time of the filing of the ‘010 Patent, it would have been obvious to
`store the new number or numbers in the SIM, to provide added security
`afforded by the SIM, including multiple password protection (e.g., PIN1,
`PIN2 and PUK password codes), authentication results and ciphering keys
`(The GSM and Personal Communication Handbook, pp. 306-309). Further,
`storing the numbers on the SIM instead of a memory integral to the meter
`would allow the card to be transferred between devices to retain all the
`programmed numbers in the SIM when the meters are replaced or out of
`service.
`
`88
`
`93
`
`94
`
`A programmable communicator device according to claim 87,
`wherein the user identity card is a SIM card.
`
`Ibid.
`
`A programmable communicator device according to claim 52
`configured to communicate between the at least one monitored
`technical device and the at least one monitoring device.
`
`A programmable communicator device according to claim 52
`configured to be incorporated into the at least one monitored
`technical device such that it becomes an integrated part of the
`monitored technical device.
`
`“The meter application will query the meter electronics to find the current
`reading. [] The meter application encapsulates the meter reading along with
`its ID into a SMS packet. The phone number of the meter's AMR
`communications gateway is dialed and the SMS packet is sent back via the
`SMS” (col. 7 ll. 24-29).
`“Embedding a SMS interface within a meter 21” (col. 3 ll. 22).
`
`“The meter application will query the meter electronics to find the current
`reading” (col. 7 lines 24-25).
`
`- 11 -
`
`15
`
`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`96
`
`97
`
`99
`
`A programmable communicator device according to claim 52
`further comprising a location processing module for determining
`an at least one location of the programmable communicator
`device, and wherein the programmable communicator device
`responds to an at least one transmission initiated by an at least
`one monitoring device requesting that said location data be sent
`to the monitoring device.
`
`A programmable communicator device according to claim 52
`wherein the location processing module comprises a Global
`Positioning System (GPS) module.
`
`A programmable communicator device according to claim 52
`wherein the monitored technical device is a health monitoring
`system.
`
`100 A programmable communicator device according to claim 99
`wherein the programmable communicator device receives data
`from the health monitoring system through the programmable
`interface representing at least one of body temperature, blood
`pressure, periodic or continuous electrocardiogram heart rhythm,
`blood glucose concentration, blood electrolyte concentration,
`kidney function, liver function, and labor contractions.
`
`101 A programmable communicator device according to claim 52
`wherein the monitored technical device is a vending machine.
`
`
`
`US Patent No. 6,900,737
`
`See claim 110 of the ‘197 Patent above.
`
`See claim 110 of the ‘197 Patent above.
`
`See claim 125 of the ‘197 Patent above.
`
`See claim 125 of the ‘197 Patent above.
`
`“The invention is more particularly intended for, although not limited to,
`use in an electronic meter” (col. 1 ll. 17-19).
`
`At the time of the filing of the ‘010 Patent, devices and systems for
`remotely monitoring vending machines were known. See, e.g., WO
`
`- 12 -
`
`16
`
`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`US Patent No. 6,900,737
`
`
`
`95/05609 (“Eldredge”), which discloses “A system for remotely monitoring
`a plurality of vending machines from a central computer.” (Abstract). See
`also, US Patent No. 6,038,491 (“McGarry”), which discloses “A vending
`machine capable of communicating with a central station using any one of
`multiple cellular carriers includes a telemetry device” (Abstract).
`
`It would have been obvious to use the meter monitoring system disclosed by
`Ardalan to monitor vending machines in order to expand applications of
`remote monitoring to a wider range of devices and parameters, such as,
`vending operation and controls in the vending machine industry.
`See claim 52 above.
`
`104 A programmable communicator device comprising:
`
`
`
`
`
`
`
`
`
`
`
`a wireless communications circuit for communicating through an
`antenna over a communications network;
`
`See claim 52 above.
`
`a programmable interface for establishing a communication link
`with at least one monitored technical device;
`
`See claim 52 above.
`
`an authentication module for authenticating a data message
`contained in an at least one transmission sent from a
`programming transmitter and received by the programmable
`communicator device,
`
`See claim 52 above.
`
`the data message including a coded number and a least one
`telephone number or Internet Protocol (IP) address corresponding
`to an at least one monitoring device,
`
`See claim 52 above.
`
`wherein the authentication module authenticates the data message
`by determining if the data message contains the coded number,
`
`See claim 52 above.
`
`- 13 -
`
`17
`
`M2M
`Ex. 2002
`
`

`
`No. Claim limitation
`
`the authentication module authenticating the data message if it
`includes the coded number;
`
`a permitted callers programming module for causing a memory
`module to store the at least one telephone number or IP address
`from the authenticated data message as one of one or more
`permitted callers if the authentication module authenticates the
`data message by determining that it includes the coded number;
`
`
`
`US Patent No. 6,900,737
`
`See claim 52 above.
`
`See claim 52 above.
`
`
`
`
`
`
`
`
`
`wherein the programmable communicator device uses an identity
`module for storing a unique identifier that is unique to the
`programmable communicator device; and
`
`See claim 52 above.
`
`wherein the data message contained in the at least one
`transmission from a programming transmitter is a Short Message
`Service (SMS) data message, or a General Packet Radio Service
`(GPRS) or other packet switched data message.
`
`See claim 52 above.
`
`109 A programmable communicator device according to claim 104
`wherein the at least one transmission from a programming
`transmitter comprises a GPRS data message.
`
`127 A programmable communicator device according to claim 104
`wherein the communications network is a cellular mobile
`telecommunications network.
`
`129 A programmable communicator device according to claim 127
`wherein the cellular mobile telecommunications network utilizes
`
`See claim 57 above.
`
`“A single meter 21 … with its own wireless access module to the SMS of
`the DCN [Digital Cellular Network] 10 can receive SMS packets and return
`the results to the originator of the SMS packet via the DCN” (col. 7 lines 1-
`4); “providing each meter with a direct interface to the DCN 10 so that
`every meter can send and receive SMS packets” (col. 3 ll. 55-58). DCN is a
`“digital cellular network” (col. 1 ll. 46-47).
`See claim 82 ab