` SIERRA WIRELESS, INC. & RPX CORP.
`v.
`M2M SOLUTIONS LLC
`Case IPR2015-01823
`U.S. Patent 8,648,717
`
`M2M Solutions’ Demonstratives
`for Oral Hearing
`
`Judge Kalyan K. Deshpande
`Judge Justin T. Arbes
`Judge Daniel J. Galligan
`
`December 5, 2016
`
`M2M Ex. 2021
`
`Sierra Wireless v. M2M
`Case IPR2015-01823
`
`
`
`M2M’s Issued Claim 1
`
`1. A programmable communicator device comprising:
`[a] a programmable interface for establishing a communication link with at least one
`monitored technical device,
`[b] wherein the programmable interface is programmable by wireless packet
`switched data messages; and
`[c] a processing module for authenticating one or more wireless transmissions sent
`from a programming transmitter and received by the programmable communicator
`device by determining if at least one transmission contains a coded number;
`[d] wherein the programmable communicator device is configured to use a memory
`to store at least one telephone number or IP address included within at least one of
`the transmissions as one or more stored telephone numbers or IP addresses if the
`processing module authenticates the at least one of the transmissions including the
`at least one telephone number or IP address and the coded number by determining
`that the at least one of the transmissions includes the coded number, the one or
`more stored telephone numbers or IP addresses being numbers to which the
`programmable communicator device is configured to and permitted to send
`outgoing wireless transmissions;
`[e] wherein the programmable communicator device is configured to use an identity
`module for storing a unique identifier that is unique to the programmable
`communicator device; and
`[f] wherein the one or more wireless transmissions from the programming
`transmitter comprises a General Packet Radio Service (GPRS) or other wireless packet
`switched data message; and
`[g] wherein the programmable communicator device is configured to process data
`received through the programmable interface from the at least one monitored
`technical device in response to programming instructions received in an incoming
`wireless packet switched data message.
`
`2
`
`Ex. 1001 col. 12-13
`
`
`
`Ground 1 – Whitley in View of SIM Specification
`
`Whitley
`
`3
`
`Ex. 1003
`
`
`
`Ground 1 – Whitley in View of SIM Specification
`
`Element 1(b):
`
`“a programmable interface for
`establishing a communication link with at
`least one monitored technical device,
`wherein the programmable interface is
`programmable by wireless packet
`switched data messages;”
`
`
`4
`
`Ex. 1001
`
`
`
`Element 1(b) – Claim Construction
`
`• Element 1(b): “wherein the
`programmable interface is
`programmable by wireless packet
`switched data messages”
`
`• Petitioners contend “programmable
`interface” should be given its plain and
`ordinary meaning
`• Petition at 15
`
`5
`
`
`
`Element 1(b) – Claim Construction
`
`6
`
`PO Response at 8; Ex.
`2008 at n. 4
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(b))
`
`7
`
`Pet. Reply at 9; Ex.
`1003 at 8:27-9:8
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(b))
`
`8
`
`Pet. at 21; Ex. 1003 at
`17:1-15
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(b))
`
`9
`
`Reply at 10
`
`
`
`Element 1(d) – Claim Construction
`
`“numbers to which the
`programmable communicator
`device is configured to and
`permitted to send outgoing
`wireless transmissions”
`
`• The claim language itself requires that the
`programmable communicator can only transmit to
`numbers to which it is “configured to and permitted
`to” send outgoing transmissions
`• Petitioners have previously construed this phrase to
`require a restrictive outbound calling list
`
`10
`
`PO Response at 14-15
`
`
`
`Element 1(d) – Claim Construction
`
`11
`
`Ex. 1001 at 9:61-67,
`10:5-12
`
`
`
`Element 1(d) – Claim Construction
`
`12
`
`Ex. 1001 at 2:17-33
`
`
`
`Element 1(d) – Claim Construction
`
`13
`
`Ex. 1001 at 5:47-62,
`9:12-15, 10:13-37
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`14
`
`Pet. at 32, 25
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`15
`
`Ex. 1004 at 83; PO
`Response at 27
`
`
`
`GSM SIM-ME (GSM 11.11) & AT Command Set (GSM 07.07)
`
`16
`
`Ex. 1004; Ex. 1007
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`17
`
`Ex. 1007 at 40-41; PO
`Response at 28
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`18
`
`Ex. 2015 at 11; PO
`Response at 33
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`19
`
`Ex. 1009 at 91-92; PO
`Response at 33
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`20
`
`Ex. 1004 at 120; PO
`Response at 40-41
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(d))
`
`21
`
`Ex. 1004 at 121; PO
`Response at 41
`
`
`
`Ground 1 – Whitley in View of SIM Specification (1(g))
`
`Element 1(g):
`
`“wherein the programmable
`communicator device is configured to
`process data received through the
`programmable interface from the at least
`one monitored technical device in
`response to programming instructions
`received in an incoming wireless packet
`switched data message.”
`
`
`22
`
`Ex. 1001
`
`
`
`Claims 6 and 10
`
`Claim 6: “A programmable communicator
`Claim 5: “A programmable communicator device
`device according to claim 1 further configured
`according to claim 1 further configured to request that
`to transmit the processed data to an at least
`an at least one monitored technical device send data
`one monitoring device in response to
`through the programmable interface for processing by
`programming instructions received in an
`the programmable communicator device in response
`incoming wireless packet switched data
`to programming instructions received in an incoming
`message.”
`wireless packet switched data message.”
`
`Claim 10: “A programmable communicator
`device according to claim 1 further configured to
`determine whether the processed received data
`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 in response to programming
`instructions received in an incoming wireless
`packet switched data message.”
`
`
`23
`
`PO Response at 50-52
`
`
`
`Claim 23
`
`Claim 5: “A programmable communicator device
`Claim 23: “A programmable communicator device
`according to claim 1 further configured to request that
`according to claim 1 wherein the monitored
`an at least one monitored technical device send data
`technical device is at least one of a door status
`through the programmable interface for processing by
`monitoring device, a window status monitoring
`the programmable communicator device in response
`device, a proximity detector device, and a fire
`to programming instructions received in an incoming
`alarm device.”
`wireless packet switched data message.”
`
`24
`
`PO Response at 52-53
`
`
`
`Claims 16 and 17
`
`Claim 16: “A programmable communicator device according to
`claim 1 further comprising a location processing module
`Claim 5: “A programmable communicator device according to claim 1
`configured to determine an at least one location of the
`further configured to request that an at least one monitored technical
`programmable communicator device, and wherein the
`device send data through the programmable interface for processing by
`programmable communicator device is configured to respond to
`the programmable communicator device in response to programming
`an at least one transmission initiated by an at least one
`instructions received in an incoming wireless packet switched data
`monitoring device requesting that said location data be sent to
`message.”
`the monitoring device in response to programming instructions
`received in an incoming wireless packet switched data message.”
`
`
`Claim 17: “A programmable communicator device according to
`claim 16 wherein the location processing module comprises a
`Global Positioning System (GPS) module.”
`
`25
`
`PO Response at 53-56
`
`
`
`Claims 19-21
`
`Claim 19: “A programmable communicator device according to
`claim 1 wherein the monitored technical device is a health
`monitoring system.”
`
`Claim 20: “A programmable communicator device according to
`claim 19 wherein the programmable communicator device is
`Claim 5: “A programmable communicator device according to claim 1
`configured to receive data from the health monitoring system
`further configured to request that an at least one monitored technical
`through the programmable interface representing at least one of
`device send data through the programmable interface for processing by
`body temperature, blood pressure, periodic or continuous
`the programmable communicator device in response to programming
`electrocardiogram health rhythm, blood glucose concentration,
`instructions received in an incoming wireless packet switched data
`blood electrolyte concentration, kidney function, liver function, and
`message.”
`labor contractions in response to programming instructions
`received in an incoming wireless packet switched data message.”
`
`Claim 21: “A programmable communicator device according to
`claim 1 wherein the monitored technical device is a vending
`machine.”
`
`26
`
`PO Response at 56-61