`FOR THE DISTRICT OF DELAWARE
`
`M2M SOLUTIONS LLC,
`
`a Delaware limited liability company,
`
`Plaintiff,
`
`V.
`
`MOTOROLA SOLUTIONS, INC., a
`Delaware corporation, TELIT
`COMMUNICATIONS PLC, a United
`Kingdom public limited company, and TELIT
`WIRELESS SOLUTIONS INC., a Delaware
`
`corporation,
`
`Defendants.
`
`CA’ No’ l2—033—RGA
`
`‘
`
`EXPERT REPORT OF KIMMO SAVOLAINEN
`
`IN REBUTTAL TO DR. NETTLETON AND MR. BLUESTEIN
`
`I have been retained by Telit Communications PLC (“Telit PLC”) and Telit Wireless
`
`Solutions Inc. (“Telit Wireless”) (collectively with Telit PLC, “Telit”) to serve as an expert in
`
`this lawsuit.
`
`I expect to testify at trial regarding the matters discussed in this report if asked
`
`about them by the Court or the parties’ attorneys.
`
`1
`
`M2M
`
`Ex. 2007
`
`1
`
`M2M
`Ex. 2007
`
`
`
`Expert Report of Kimmo Savolainen
`July 7, 2014
`
`Page 30 of 72
`
`C. Digest SMS AT RUN Service
`
`82. “By default the SMS ATRUN service is disabled” (Ex. 1, 13211, para. 11; see also
`
`Ex. 8, 09227). A user can, but is not required to, send SMS messages including AT commands to
`
`program the module using the SMS AT RUN service.
`
`83. If used, the SMS ATRUN service must be programmed locally over a wired
`
`connection: “First of all, the SMSATRUN service provided by the remote module is locally
`
`configured and enabled” (Ex. 1, 13204). Dr. Nettleton states that the SMS AT RUN service could
`
`be initiated remotely by “a special SMS data message sent from the Telit server” (Nettleton Report
`
`para. 56, referring to Ex. 1, 1321 1 para. 1 1). However, this functionality was never available in the
`
`U.S. (Ex. 29, Contento Tr. at 132, 135).
`
`84. There are two types of SMS AT RUN services: Simple AT RUN SMS and Digest AT
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`RUN SMS (Ex. 1, 13201-2).
`
`85. Simple mode allows whitelist callers to use the AT RUN service without requiring a
`
`password (Ex. 1, 13201). The message is only checked for the caller’s telephone number (Ex. 1,
`
`13201).
`
`1 do not see that M2M has accused Simple AT RUN SMS mode of infringing the ‘010
`
`Patent (Nettleton Report, para. 54).
`
`86. Digest mode (not Simple mode) is alleged to infringe the ‘O10 Patent (see modes 1 and
`
`3, Nettleton Report, para. 54). Digest mode allows messages from callers that are not on the
`
`whitelist to be treated as AT RUN messages if an MD5 digest in the message matches one that is
`
`locally calculated (Ex. 1, 13202). A permitted caller list must block non-permitted callers (see e.g.
`
`‘O10 Patent, Fig. 2, step 4). Because callers not on the whitelist can program the module using
`
`Digest AT RUN SMS service, the whitelist does not block non-whitelist callers from programming
`
`using the SMS AT RUN service, and is therefore not a permitted caller list.
`
`2
`
`M2M
`
`Ex. 2007
`
`2
`
`M2M
`Ex. 2007
`
`
`
`Expert Report of Kimmo Savolainen
`July 7, 2014
`
`Page 36 of 72
`
`or “Ellen<CR>1<CR>”:
`
`File Edit Setup Control Window Help
`ile Edit Setup Control Window Help
`
`Since two users can have the same password, e.g., 1, there is nothing in the firmware that requires
`
`the password to be unique.
`
`98. In the examples above, a password of zero characters and one character were accepted.
`
`The firmware only provides an upper limit of 50 characters (Ex. 8, 09234), but does not provide a
`
`lower limit. A password “l” having one character can certainly not be considered unique.
`
`99. The claims require “authenticating at least one transmission
`
`the at least one
`
`transmission including a coded number and at least one telephone number or lntemet Protocol (IP)
`
`address” (claims 1 and 52, emphasis added). That is, both the coded number and the telephone
`
`number or II’ address must be included in one transmission.
`
`3
`
`M2M
`
`EX2007
`
`3
`
`M2M
`Ex. 2007
`
`
`
`Expert Report of Kimmo Savolainen
`July 7, 2014
`
`Page 69 of 72
`
`Dated: July 7, 2014
`
`
`
`Kimmo Savolainen
`
`4
`
`M2M
`
`Ex. 2007
`
`4
`
`M2M
`Ex. 2007
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