Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TELIT WIRELESS SOLUTIONS INC.
`
` and
`
` TELIT COMMUNICATIONS PLC,
`
` Petitioner
`
` v.
`
` M2M SOLUTIONS LLC
`
` Patent Owner
`
` Case IPR2016-00055
`
` Patent 8,648,717 B2
`
` DEPOSITION of KIMMO SAVOLAINEN, an
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`expert witness on behalf of Petitioners, held at
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`the Law Office of Pearl Cohen Zedek Latzer
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`Baratz, 1500 Broadway, 12th Floor, New York, New
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`York, on July 7, 2016, commencing at 9:27 a.m.,
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`and before Helene Gruber, CSR, a Notary Public of
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`the State of New York.
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`1
`
`M2M
`Ex. 2010
`
`
`
`New York, NY
`
`July 7, 2016
`
`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TELIT WIRELESS SOLUTIONS INC.
`
` and
`
` TELIT COMMUNICATIONS PLC,
`
` Petitioner
`
` v.
`
` M2M SOLUTIONS LLC
`
` Patent Owner
`
` Case IPR2016-00055
`
` Patent 8,648,717 B2
`
` DEPOSITION of KIMMO SAVOLAINEN, an
`
`expert witness on behalf of Petitioners, held at
`
`the Law Office of Pearl Cohen Zedek Latzer
`
`Baratz, 1500 Broadway, 12th Floor, New York, New
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`York, on July 7, 2016, commencing at 9:27 a.m.,
`
`and before Helene Gruber, CSR, a Notary Public of
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`the State of New York.
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`1
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`M2M
`Ex. 2010
`
`
`
`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
`
`Page 2
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`A P P E A R A N C E S :
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`PEARL COHEN ZEDEK LATZER BARATZ
`
`Attorneys for Petitioner
`
` 1500 Broadway, 12th Floor
`
` New York, New York 10036
`
`BY: DAVID A. LOEWENSTEIN, ESQ.
`
`FOLEY & LARDNER LLP
`
`Attorneys for Patent Owner
`
` 111 Huntington Avenue, Suite 2600
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` Boston, Massachussetts 02199
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`BY: MARC N. HENSCHKE, ESQ.
`
`Mhenschke@foley.com
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`ALSO PRESENT:
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`MILO EADAN, Patent Agent
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`Alderson Court Reporting
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`2
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`M2M
`Ex. 2010
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`
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`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
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`Page 3
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` INDEX TO TESTIMONY
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`WITNESS BY PAGE
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`Kimmo Savolainen Mr. Henschke 4
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` Mr. Loewenstein 76
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` INDEX TO EXHIBITS
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`SAVOLAINEN DESCRIPTION PAGE
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`1: Patent Owner's Notice of Deposition 4
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`2: GSM 4.11 specification 51
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` EXHIBITS PREVIOUSLY MARKED AND REFERRED TO
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` NUMBER PAGE
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` 1105: 4
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` 1113: 5
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` 1130: 15
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`Alderson Court Reporting
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`3
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`M2M
`Ex. 2010
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 4
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` KIMMO SAVOLAINEN,
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`Having first been duly sworn, testified as
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`follows:
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` EXAMINATION
`
`BY MR. HENSCHKE:
`
` Q. Would you please state your full name
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`and residential address for the record.
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` A. Kimmo Olavi Savolainen,
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`Muottaajanpiha #10, Kempele, Finland 90450.
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` MR. HENSCHKE: As an initial
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` housekeeping matter, I would like to mark and
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` introduce as Savolainen Exhibit 1 the Patent
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` Owner's Notice of Deposition of Kimmo
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` Savolainen that has brought us here today.
`
` (Patent Owner's Notice of Deposition
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` marked Savolainen Exhibit 1.)
`
` Q. Let me show you a document that has
`
`been marked as Exhibit 1105 in the IPR
`
`proceedings, and that bears the title Declaration
`
`of Kimmo Savolainen for inter partes review of
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`U.S. patent number 8,648,717.
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` MR. LOEWENSTEIN: Are you going to mark
`
` it?
`
` MR. HENSCHKE: I am not going to mark
`
` it. We will refer to it by its exhibit
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`4
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`M2M
`Ex. 2010
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`
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 5
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` number from the IPR proceedings, which is
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` 1105.
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` Q. Do you recognize this, Mr. Savolainen,
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`as the declaration that you submitted in these IPR
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`proceedings?
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` A. I believe it is. Yes.
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` Q. So for purposes of our deposition
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`today, I am going to be referring to this as
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`either the Savolainen declaration or as Exhibit
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`1105. Is that clear?
`
` A. It's clear.
`
` Q. Let me show you another document that
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`has already been marked and submitted in these IPR
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`proceedings as Exhibit No. 1113, and this is a PCT
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`patent application with the inventor Van Bergen,
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`and it bears numbers WO 00/17021.
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` MR. LOEWENSTEIN: Off the record.
`
` (Discussion off the record.)
`
` Q. Mr. Savolainen, today I am going to be
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`referring to this as either Van Bergen or as
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`Exhibit 1113. Is that clear?
`
` A. That's clear.
`
` Q. Let me turn your attention to figure
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`2 in the Van Bergen patent application. Are you
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`familiar with the disclosures in Van Bergen about
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`Ex. 2010
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`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
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`Page 6
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`the subsystem that is called ALU 16?
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` A. Yes, I am.
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` Q. And ALU 16 is also referred to as the
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`GSM mobile unit in Van Bergen, correct?
`
` A. I believe that's correct.
`
` Q. Would a person of ordinary skill
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`understand ALU 16 as being capable of generating
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`digital outputs that it could transmit to other
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`subsystems in the Cell-Eye system?
`
` MR. LOEWENSTEIN: Object to the form.
`
` Can you put a date on that?
`
` A. Yes. The ALU 16 needs to
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`communicate through the modem with the
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`controller, and that would be using digital
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`signals.
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` Q. Is ALU 16 able to transmit digital
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`outputs to modem 15?
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` A. Digital outputs? There is some form
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`of communication, and most likely there is a
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`digital serial port in between the two.
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` Q. Is ALU 16 able to transmit digital
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`outputs to controller and memory unit 14?
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` A. I believe through the modem, yes, it
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`is.
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` Q. Is ALU 16 able to transmit digital
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Ex. 2010
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`Kimmo Savolainen
`
`New York, NY
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`July 7, 2016
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`Page 7
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`outputs to the alarm sensor interface 13?
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` A. Through the chain, the modem and the
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`controller relaying information from the ALU, I
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`believe it is possible that that there are
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`digital signals that are passed through the
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`modem and controller to the alarm sensor
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`interface.
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` Q. So these digital outputs from ALU 16
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`that we have been discussing, would they be
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`considered digital inputs to the other subsystems
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`that receive them?
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` A. You could call them that.
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` Q. Would you call them that?
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` A. Yes, I could call them that.
`
` Q. So are these digital outputs that ALU
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`16 can generate and transmit digital electronic
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`signals?
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` A. Yes. They would either be digital
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`electronic signals, or you could potentially
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`also use technologies like bluetooth to
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`transfer them wirelessly.
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` Q. So are there different types or
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`categories of digital electronic signals that ALU
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`16 could generate and transmit?
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` MR. LOEWENSTEIN: Objection to the
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 8
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` form.
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` You could answer if you understand.
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` A. I'm not sure I follow you. Can you
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`say that question again?
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` Q. I am trying to figure out if it is the
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`case that there are different types of digital
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`electronic signals that ALU 16 can transmit and
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`generate. Would you consider there to be
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`different types or categories of those signals?
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` MR. LOEWENSTEIN: Same objection.
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` Compound.
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` A. There can be different signals,
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`different commands, as an example, through the
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`serial port.
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` Q. Would some of the --
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` MR. HENSCHKE: Strike that.
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` Q. Would some of the digital electronic
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`signals that ALU 16 could generate and transmit be
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`data streams?
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` MR. LOEWENSTEIN: I think I am going to
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` object to the form of the question. I am not
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` sure that term is used in the patent or has
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` been defined in this IPR.
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` A. I was going to ask you to define
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`data stream, because that could be many things.
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 9
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` Q. Well, I believe it would be a digital
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`electronic signal that was principally data or
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`carrying data?
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` MR. LOEWENSTEIN: Are we excluding
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` voice data? Voice, not voice?
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` Q. Talking about a digital electronic
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`signal and whether ALU 16 can issue one that is a
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`data stream.
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` MR. LOEWENSTEIN: My objection stands.
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` If you understand it, you can answer.
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` A. Well, it does send short bursts of
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`data, which can include commands, instructions.
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`If you can consider something like that a data
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`stream, yes, it is possible.
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` Q. Would some of the digital electronic
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`signals that ALU 16 is capable of generating and
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`transmitting be control signals?
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` MR. LOEWENSTEIN: Objection to the
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` form.
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` You can answer.
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` A. Well, in terms of generating control
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`signals, I believe it does not make decisions
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`on issuing control signals. Those control
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`signals would come from somewhere else, but it
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`can relay such control signals that it receives
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Ex. 2010
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`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
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`Page 10
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`through the GSM network from the RMU in the
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`system.
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` Q. What, if anything, is the difference
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`between digital electronic signals that are data
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`outputs as opposed to digital electronic signals
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`that are control signals?
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` MR. LOEWENSTEIN: I am going to object
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` to the form.
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` You can answer.
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` A. Can you say that again? I'm not
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`sure I follow that question.
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` Q. We have talked about two different
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`types of digital electronic signals, one which is
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`issuing data or data stream, and then a second
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`category that we have called control signals, and
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`I am trying to figure out what the difference is
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`between those two types of digital electronic
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`signals, if any.
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` A. Well --
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` MR. LOEWENSTEIN: Object to the form.
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` You can answer.
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` A. The control signal is a subcategory
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`of those data streams, but -- yeah. Those
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`control signals are coming through the GSM
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`network from the RMU and go through the ALU
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 11
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`into the controller or alarm sensory interface.
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` Q. Do you consider the control signals to
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`be a type of digital data?
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` A. Yes, you can consider those to be a
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`type of digital data.
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` Q. Do you consider that to be a -- that
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`control signal to be a binary output as
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`distinguished from a data stream?
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` MR. LOEWENSTEIN: Object to the form.
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` A. Well, data stream would also be
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`binary data.
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` Q. Would be or could be?
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` A. Most likely would be, and definitely
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`could be.
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` Q. Are there any other types of digital
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`electronic signals that we haven't discussed so
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`far that ALU 16 would be capable of generating and
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`transmitting?
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` A. Well, the ALU is a GSM mobile unit;
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`hence, it does operate as one, so it is a
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`communication device, and it does also send or
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`could, at least, send sort of a status data --
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`status of the communication.
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` As an example, if it goes out of
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`coverage of the cell network, it could send a
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`Alderson Court Reporting
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 12
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`notification about that to the controller.
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` It could send a notification when it
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`returns to said coverage.
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` If there is an SMS message that
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`arrives, it would notify the controller that such
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`an SMS has arrived, and it can be read from the
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`memory of the ALU, or it could automatically
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`forward that SMS message to the controller.
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` Q. Is there a technical term that you
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`would use to describe these types of status
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`notifications?
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` A. Well, I think status notification is
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`a fairly good description.
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` Q. Would what you are calling status
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`notifications be referred to as result codes?
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` A. In AT commands, the result codes
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`would be inside of those notifications so the
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`result code itself would not be a notification,
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`but it would be part of the notification, or it
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`could be part of the notification.
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` Q. What type of interface would ALU 16
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`have for transmitting these digital electronic
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`signals we have been discussing?
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` A. Most likely it would be an
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`asynchronous serial port.
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`Ex. 2010
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 13
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` Q. That is your understanding of what kind
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`of interface ALU 16 would have as shown there in
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`Figure 2?
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` A. Yes, I believe so. There was even
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`something said about that somewhere in this.
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` Q. For instance, if I direct your
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`attention to page 7, lines 25 through 31, does
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`that help?
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` A. Yes. That is referring to
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`asynchronous mode serial communication, which
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`could refer either to the communication --
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`serial communication between those blocks or
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`modules in Figure 2, or it could also be
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`referring to the cellular communication. Both
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`are serial and asynchronous.
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` Q. Does this suggest for the Figure 2
`
`embodiment, ALU 16 is sending electronic signals
`
`as hard wire serial transmissions?
`
` A. Could be hard wire, or hard wire
`
`could be replaced by a bluetooth, as an
`
`example.
`
` Q. Is there any disclosure of bluetooth
`
`communication in the Van Bergen patent
`
`application?
`
` A. I do not think there is in this
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`Alderson Court Reporting
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`13
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`M2M
`Ex. 2010
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 14
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`reference, but there was another reference, I
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`believe it was called the Sonera reference,
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`that was discussing bluetooth as an alternative
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`for hard wire serial.
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` Q. I am just asking you now about what Van
`
`Bergen teaches with respect to Figure 2. There is
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`no teaching of a bluetooth transmission or the
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`presence of a bluetooth transceiver in any of
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`those subsystems, correct?
`
` MR. LOEWENSTEIN: Object to the form.
`
` You can answer.
`
` A. I believe you are correct. This
`
`particular reference does not discuss bluetooth
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`as an alternative means for hard wire serial
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`communication.
`
` Q. Van Bergen teaches that one example of
`
`what could serve as ALU 16 in Figure 2 is a Falcom
`
`A2 GSM mobile unit, correct?
`
` A. That I believe is correct.
`
` Q. In fact, if I direct your attention
`
`back to page 7 of Van Bergen at lines 33 to 34.
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` A. Can you say the lines again?
`
` Q. I am on page 7 of Van Bergen at lines
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`33 to 34.
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` A. It does refer to Falcom A2 GSM
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 15
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`mobile unit.
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` Q. And it says that is an example of what
`
`could serve as the ALU 16 in the Figure 2
`
`embodiment, right?
`
` A. I believe you are correct.
`
` Q. Let me show you another exhibit that
`
`has already been previously marked in the IPR
`
`proceedings. This is a user manual for the Falcom
`
`A2 GSM mobile unit. This has been marked in the
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`IPR proceedings as Exhibit 1130.
`
` Mr. Savolainen, is this Falcom A2 GSM
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`mobile unit that is discussed in Exhibit 1130 the
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`same as the one that is referred to in the Van
`
`Bergen patent application on page 7?
`
` A. I believe it is.
`
` MR. LOEWENSTEIN: You might want to ask
`
` the witness about the dates on the respective
`
` documents.
`
` A. Although I believe the PCT patent
`
`application was originally for this -- yes.
`
`The PCT patent application was filed before the
`
`date of this document.
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` Q. But you would agree, Mr. Savolainen,
`
`that the Falcom A2 that is shown in Exhibit 1130
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`is either the same or very similar to the Falcom
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 16
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`that is referenced in the Van Bergen patent
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`application, correct?
`
` MR. LOEWENSTEIN: I am going to object
`
` to the form of the question.
`
` A. The dates are indicating that at
`
`least this document would not be the same that
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`the PCT application is referring to, but it is
`
`possible that it is similar.
`
` Q. In fact, you relied upon it in your IPR
`
`analysis as being the same or similar, didn't you?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. Let me check it what I said about
`
`that. I don't remember by heart.
`
` If you do remember where I did refer to
`
`Falcom A2 --
`
` MR. LOEWENSTEIN: It looks like it is
`
` on page 95.
`
` A. I believe I did indeed refer to this
`
`document.
`
` Q. You relied upon Exhibit 1130 in your
`
`analysis to show what kind of features and
`
`capabilities the Falcom unit referenced and Van
`
`Bergen had, right?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. I believe I did -- do refer to this
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`Page 17
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`document.
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` Q. And you refer to it in the manner I
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`just described, as showing what capabilities and
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`features the Falcom unit that is referenced in Van
`
`Bergen had, right?
`
` A. I believe I did.
`
` Q. Let me turn you to page 64 of Exhibit
`
`1130, the Falcom user manual. So this shows on
`
`page 64 that the Falcom A2 embodiment of ALU 16
`
`would have had a nine-pin serial port interface,
`
`right?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. That is one of the interfaces.
`
` Q. And with regard to this serial port
`
`interface in particular, could any of the nine
`
`pins have been used by ALU 16 for outputting
`
`digital electronic signals?
`
` A. Yes. There are several signals here
`
`that can be used to -- outputting digital
`
`signals.
`
` Q. Which of the serial port pins shown
`
`here on page 64 could have been used to output
`
`digital electronic signals?
`
` A. Pin 2 and pin 3 are used for serial
`
`communication. This does not exactly tell
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`Kimmo Savolainen
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`New York, NY
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`July 7, 2016
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`Page 18
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`which one is output and which one is input,
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`because there are two sides of the RS232
`
`specification. One of them is an output, as
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`well as some of the handshaking signals, DTR,
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`DSR, RTS and CTS.
`
` Depending on which RS232 definition
`
`this uses, some of those are outputs and some of
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`those are inputs.
`
` Q. Let's take these in order, then. I am
`
`trying to figure out with you which of these pins
`
`could be used to output digital electronic
`
`signals.
`
` If we look at pin 1, that is the DCD
`
`pin, which would stand for data carrier detect,
`
`correct?
`
` A. That is correct.
`
` Q. And could that pin be used by the
`
`Falcom A2 to output a data carrier detect control
`
`signal?
`
` MR. LOEWENSTEIN: Can I hear that
`
` question back?
`
` (Record read.)
`
` A. Yes, I believe it could.
`
` Q. In the Figure 2 embodiment from Van
`
`Bergen, could ALU 16 use this data carrier detect
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`control signal to indicate to the controller 14
`
`when a remote call had been successfully connected
`
`or later terminated?
`
` A. That is one possible use for such a
`
`signal.
`
` Q. If we look at page 15 of the Falcom
`
`user manual, Exhibit 1130, we see that that
`
`possible use actually does apply here to this
`
`Falcom A2 unit, right?
`
` A. I believe that's correct.
`
` Q. We see on page 15 that an AT&C command
`
`could be used to configure the Falcom so it would
`
`send this data carrier detect control signal,
`
`right?
`
` A. I believe you are correct.
`
` Q. And the data carrier detect control
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`signal is a signal that is generated by the Falcom
`
`unit itself, right?
`
` A. Yes. That is an indication of the
`
`status of communication.
`
` Q. And it is a control signal that ALU 16
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`or the Falcom version of it would generate, right?
`
` A. Well, I think in this context,
`
`control signal would be a wrong description. I
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`would rather call it an indication.
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`New York, NY
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`July 7, 2016
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`Page 20
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` Q. An indication. You would consider the
`
`data carrier detect signal to be an indication
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`signal?
`
` A. Yes. It indicates that a call has
`
`been connected, and the data carrier is
`
`present.
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` Q. And it is the Falcom A2 that is making
`
`that determination and generating that indication
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`signal, right?
`
` A. Yes. Based on the status in the
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`cellular network, it indicates to the
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`controller that I have now a data call on.
`
` Q. Let's turn back to page 64 of
`
`Exhibit 1130, the discussion of the serial port in
`
`the Falcom A2. I want to talk with you now about
`
`the second serial port pin that is listed there.
`
`It is called pin 2. It is abbreviated as TXD, and
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`what that stands for is a transmit data pin,
`
`correct?
`
` A. Yes. T stands for transmit.
`
` Q. And the Falcom A2 could use this pin 2
`
`to transmit out a stream of data in the form of a
`
`digital electronic signal, right?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. I believe it can send bursts of data
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`Page 21
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`according to the RS232 specification.
`
` Q. Let me turn your attention to page 14
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`of Exhibit 1130. I am looking at the middle of
`
`the page, Section 1.4.2, which is the discussion
`
`of the ATO command. Do you see that?
`
` A. I see that.
`
` Q. What this indicates is the Falcom A2
`
`embodiment of ALU 16 could be programmed so that
`
`one of the types of data it would be able to
`
`output over the TXD pin and transmit to the
`
`controller would be result codes, correct?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. Yes. I believe that is correct.
`
` Q. And in the instance where the Falcom A2
`
`was transmitting result codes out over pin 2,
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`those result codes would have been generated by
`
`the Falcom A2 unit itself, right?
`
` A. Yes. Those would be responses to AT
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`commands, and depending on the success
`
`particularly, a result code would tell you the
`
`success of executing that AT command, so the
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`Falcom A2 being a communication unit receiving
`
`an AT command, depending on whether the command
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`was executed successfully, it would indicate to
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`the command controller unit whether whatever it
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`Page 22
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`was told to the A2 to do was executed properly.
`
` Q. And in that instance, the Falcom unit
`
`would itself generate the result code, right?
`
` A. Based on whether the operation that
`
`it was told to do was successful or not, yes,
`
`that's correct. It determines whether
`
`something was executed or not, and based on
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`that, it sends a result code as part of the
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`response to the controller.
`
` Q. You would consider those result codes
`
`to be a type of digital data, correct?
`
` A. They are digital data. They are
`
`indications whether a command was executed
`
`properly.
`
` Q. And they would be a digital data output
`
`from the Falcom A2 unit, right?
`
` A. Yes. They would be digital output
`
`and, more specifically, indication whether the
`
`command that A2 was told to do by the AT
`
`command was executed successfully.
`
` Q. So let's now take a look at page 35 of
`
`the same Exhibit 1130. I am looking now at the
`
`Section 1.9.4 that is in the middle of page 35.
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`Do you see that?
`
` A. Yes, I do see that.
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`July 7, 2016
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`Page 23
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` Q. In the ALU 16 Falcom embodiment, ALU 16
`
`could send a digital electronic signal to
`
`controller 14 that contained a +CMGS result code
`
`to indicate that an outbound SMS transmission had
`
`been successfully received by the SMS service
`
`center, right?
`
` MR. LOEWENSTEIN: I am going to object
`
` to the form.
`
` A. Yes. It can send such a response as
`
`an indication that the message was delivered
`
`successfully to the SMSC.
`
` Q. And this is a particular kind of result
`
`code that would provide that indication?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. Yes. This is an indication that can
`
`be -- yes. I think it can be described as a
`
`result code, an indication.
`
` Q. And in the Falcom A2 embodiment, ALU 16
`
`would be able to transmit that result code to
`
`controller 14, correct?
`
` A. Yes. It could transmit the
`
`indication to controller 14.
`
` Q. Let's now take a look at page 18 of
`
`Exhibit 1130.
`
` Before we leave page 35, the particular
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`Page 24
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`result code that we are discussing, the +CMGS
`
`result code, that would be a result code that was
`
`generated by the Falcom A2 unit, right?
`
` MR. LOEWENSTEIN: Can I hear the
`
` question back?
`
` (Record read.)
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. The result code itself was generated
`
`by the Falcom A2 as a response to getting an
`
`acknowledgment from the SMSC that it had
`
`received the message.
`
` Q. Let's then go to page 18 of
`
`Exhibit 1130. Now I am looking at the section
`
`1.5.1 at the top of page 18. Do you see that one?
`
` A. I see that one.
`
` Q. This indicates that in the Falcom A2
`
`embodiment, ALU 16 would have been able to send a
`
`digital electronic signal to controller 14 that
`
`contained an "okay" result code to indicate that
`
`an outbound call had been placed and successfully
`
`established, correct?
`
` MR. LOEWENSTEIN: Object to form.
`
` A. I believe that is correct. It can
`
`send an "okay" as an indication that it did
`
`connect the call through the GSM network to the
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`other end.
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` Q. And in that instance, the "okay" would
`
`be a result code, right?
`
` A. Yes. You could consider that to be
`
`a result code, although this particular text
`
`does not say it is a result code. It just says
`
`possible responses.
`
` Q. Would the "okay" result code be
`
`something that was generated by the Falcom A2 unit
`
`itself?
`
` MR. LOEWENSTEIN: Object to the form.
`
` He just said it wasn't a result code.
`
` A. The response "okay" would be
`
`generated as a result of the call connecting
`
`through the GSM network so as the
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`acknowledgment from the network side tells the
`
`Falcom A2 that the call was successfully
`
`connected to the other end, then the Falcom A2
`
`would send an "okay" response to the
`
`controller.
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` Q. In that instance, would a person of
`
`ordinary skill consider the "okay" response to be
`
`a result code?
`
` A. Well, it certainly is a response,
`
`because this text does describe it as such.
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`16
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`17
`
`18
`
`19
`
`20
`
`21
`
`22
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`23
`
`24
`
`25
`
` Whether you call it a response or a
`
`result code, not much of a difference between the
`
`two.
`
` Q. In fact, all of the previous result
`
`codes we have been discussing so far today have
`
`also been described as possible responses in the
`
`A2 user manual, right?
`
` MR. LOEWENSTEIN: Object to the form.
`
` A. Page --
`
` Q. Page 15.
`
` A. I believe, yes, they have been
`
`described as possible responses.
`
` Q. So let's turn back, then, to page 64 of
`
`Exhibit 1130, which is the discussion of the
`
`serial port pins. We talked about so far pins 1
`
`and 2. I am curious, are you able to identify any
`
`other pins between pin 3 and pin 9 as being output
`
`pins that the Falcom A2 could have used to output
`
`digital electronic signals?
`
` A. There are also some handshake
`
`signals, and some of those are outputs, and
`
`some of those are inputs.
`
` MR. LOEWENSTEIN: While there is a lull
`
` in the action, Mr. Henschke, my recollection
`
` is that the board did not institute the IPR
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`26
`
`M2M
`Ex. 2010
`
`
`
`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
`
`Page 27
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` based on the Falcom reference, and Mr.
`
` Savolainen didn't discuss each one of these
`
` individual pins in his declaration, so I am
`
` willing to give you some leeway, but we have
`
` been going probably for 15, 20 minutes, and I
`
` am hoping we come to an end reasonably soon.
`
` It is your time, obviously.
`
` MR. HENSCHKE: I will come to an end on
`
` this topic when I deem that to be
`
` appropriate, and this is obviously within the
`
` scope of the Van Bergen reference and Mr.
`
` Savolainen's opinions on same.
`
` Q. Let me try to narrow my question a
`
`little bit. While this Falcom A2 is being used as
`
`the ALU 16 from Van Bergen, are there any other
`
`pins, pin 3 through pin 9, that could be used by
`
`ALU 16 to output a digital control signal to
`
`controller 14?
`
` MR. LOEWENSTEIN: Object to the form.
`
` It is compound, and it assumes a fact that is
`
` not in evidence.
`
` A. There are digital signals in this
`
`interface that could be used also as
`
`indications. They are called handshake
`
`signals, but naturally Falcom A2 doesn't
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`27
`
`M2M
`Ex. 2010
`
`
`
`Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
`
`Page 28
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`
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