`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SIERRA VWRELESS AMERICA, INC.; SIERRA WIRELESS, INC.;
`
`and RPX CORP.,
`
`Petitioners,
`
`V.
`
`M2M SOLUTIONS LLC,
`Patent Owner.
`
`Case IPR2O 1 5-01 823
`
`Patent 8,648,717
`
`SECOND DECLARATION OF MICHELLE A. MORAN
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1450
`
`Alexandria, VA 22313-1450
`
`
`
`Declaration of Michelle A. Moran
`
`Inter Partes Review of U.S. Patent No. 8,648,717
`
`1. 1, Michelle A. Moran, resident of Waukesha, WI, hereby declare as
`
`follows:
`
`2. I am an attorney at Foley & Lardner LLP and one of the attorneys for the
`
`patent owner in this inter partes review.
`
`3. On information and belief, the Exhibits submitted with the Patent Owner’s
`
`Response for the above-referenced inter partes review as Exhibits 2008-2015,
`
`2017, and 2019 are true and correct copies of the original documents and Exhibits
`
`2016 and 2018 are true and correct copies of excerpts of the original documents as
`
`show in the table below.
`
`Exhibit
`
`
`
`2009
`
`
`
`
`
`
`
`V2010
`
`201 1
`12012
`
`2013
`
`Memorandum Opinion Denying Sierra’s Summary Judgment
`Motion, dated March 31, 2016, M2M Solutions LLC V. Sierra
`Wireless America, et al., Case No. 12-030—RGA (DED)
`’010 Markmcm Opinion dated November 12, 2013, M2M Solutions
`LLC v. Sierra Wireless America, et al., Case No. 12—030—RGA
`
`
`
`(DED)
`Joint Claim Construction Statement filed on August 14, 2015,
`M2M Solutions LLC V. Sierra Wireless America, et al., Case No.
`
`1 :14—01001—RGA (DED)
`__TEx ert Declaration of Joel R. Williams, dated May 25, 2016
`ISO/IEC 7816-3
`
`3G TS 22.038, SIM Application Toolkit (SAT); Service
`Description; V. 20.0 (1999-10)
`Supplemental Amendment during prosecution of application that
`became the ’717 atent, dated November 8, 2013
`3rd Generation Partnership Project; Point—to—Point (PP) Short
`Message Service (SMS) Support On Mobile Radio Interface; 3G
`TS 24.011 V3.2.0 (2000—03 Release 1999)
`Excerpts of the deposition of Dr. Negus, M2M Solutions LLC v.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sierra Wireless America, et al., Case No. 12-030-RGA (DED),
`dated 5/21/15
`
`Transcript of deposition of Dr. Negus, M2M Solutions LLC V.
`Sierra Wireless America, et al., Case No. 12—030—RGA (DED),
`dated 5/17/16
`
`Excerpts of the Negus Invalidity Expert Report, M2M Solutions
`LLC V. Sierra Wireless America, et al., Case No. 12-030-RGA
`
`(DED), dated 5/5/14
`U.S. Patent No. 8,094,010
`
`2017
`
`2018
`
`2019
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statement made
`
`of my own knowledge are true and that all statements made on information and
`
`belief are believed to be true.
`
`I understand that willful false statements and the like
`
`are punishable by fine or imprisonment, or both (18 U.S.C. § 1001).
`
`Executed this 25”‘ day of May, 2016
`
`,
`
`~~
`)
`/V 1/ ‘/V
`//,0 K
`,
`._,
`Michelle A. Moran
`
`’
`
`//
`
`/ Va’
`(/1
`/L
`// /
`
`)
`
`.,
`
`if
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