KIMMO SAVOLAINEN
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
`
`June 10, 2015
`1
`
`IN THE UNITED STATES COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. NO. 12-033-RGA
`
`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.
`
`~~~~~~~~N-.4~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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`AUDIO-VISUAL DEPOSITION OF
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`KIMMO SAVOLAINEN
`
`June 10, 2015
`
`9:05 a.m.
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`Foley & Lardner
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`111 Huntington Avenue
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`Boston, Massachusetts
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`Kristin M. Kelley, RPR, CRR
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` ESQUIRE
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`EX. 2011
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`1
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`M2M
`Ex. 2011
`
`
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
`
`June 10, 2015
`1
`
`IN THE UNITED STATES COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. NO. 12-033-RGA
`
`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.
`
`~~~~~~~~N-.4~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
`
`AUDIO-VISUAL DEPOSITION OF
`
`KIMMO SAVOLAINEN
`
`June 10, 2015
`
`9:05 a.m.
`
`Foley & Lardner
`
`111 Huntington Avenue
`
`Boston, Massachusetts
`
`Kristin M. Kelley, RPR, CRR
`
` ESQUIRE
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`EX. 2011
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`M2M
`Ex. 2011
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`June10,2015
`KIMMO SAVOLAINEN
`45
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
`
`
`MR. YONAY: Objection to form.
`GPRS not being available at this time and
`
`just being around the corner, it would have
`
`been obvious to go to that next, but the
`
`document itself does not mention that.
`
`And does the document describe the CELL—EYE
`
`as communicating by one of those two modes
`
`of communication that I just described,
`
`either voiceless data messages or SMS
`
`messages?
`
`It does describe those.
`
`And when it's referring to the voiceless
`
`data messages, it has data in all caps,
`
`
`
`DATA, correct?
`
`Yes.
`
`And those data messages that are in all caps
`
`are something different and distinct from
`
`the SMS messages, right?
`
`Yes. Data service and SMS are two different
`
`things.
`
`The data messages that the patent
`
`application is identifying were data
`
`messages sent over a circuit—switched
`
`telephone call, correct?
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` ESQUIR.E
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`KIMMO SAVOLAINEN
`MZM SOLUTIONS vs. MOTOROLA SOLUTIONS
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`June10,2015
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`Depends on the definition of telephone call.
`
`Well,
`
`I'm talking about a two—way
`
`circuit—switched data call.
`
`Yes,
`
`two —— two —— two—way circuit—switched
`
`data call, yes.
`
`And that is what's being referred to here in
`
`the patent application when it's talking
`
`about the voiceless data messages, right?
`
`I believe so, GPRS being the next obvious
`
`choice to go to.
`
`Well, aside from SMS messages in September
`
`of 1998,
`
`the only other way to send data
`
`messages over a GSM cellular network was by
`
`way of circuit—switched data calls, correct?
`
`So do you mean by circuit—switched data
`
`calls the service —— circuit—switched data
`
`service of GSM or using voice channel and
`
`modulating data?
`
`Yes.
`
`So I asked one of the two or in between and
`
`you said yes.
`
`Q.
`
`I see. You're describing different types of
`
`circuit—switched data calls?
`
`You can do it in various ways.
`
`So you're
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`KWMMDSAVOLAWEN
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
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`June10,2015
`47
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`talking about GSM circuit—switched data
`
`service,
`
`is that correct?
`
`I believe so.
`
`What was the question related to that?
`
`I'm asking, aside from SMS messages,
`
`the
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`only way you could send data over the GSM
`
`network in September of 1998 was by
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`circuit—switched data calls, right?
`
`Not entirely true.
`
`You could send data also
`
`using DTMN.
`
`Do we agree when the CELL—EYE application
`
`here talks about voiceless data messages
`
`it's talking about using circuit—switched
`
`data calls?
`
`I believe it does talk about that, GPRS
`
`being the obvious next choice.
`
`But GPRS not yet being available, correct?
`
`MR. YONAY:
`
`In what
`
`time frame?
`
`In
`
`what
`
`time frame?
`
`MR. HENSCHKE:
`
`I said September of
`
`1998.
`
`At that point it was under specification
`
`work in ETSI,
`
`therefore not available in the
`
`networks, yes, but being the next obvious
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`FGMNKDSAVOLNNEN
`June10,2015
`60
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
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`
`Q.
`
`So I'm looking at this remote programming
`
`paragraph. Are you able to draw any
`
`conclusions as to whether it's describing
`
`programming by way of circuit—switched data
`
`calls only?
`
`So are you still referring only to this
`
`paragraph,
`
`remote programming?
`
`Yes, sir.
`
`Sorry.
`
`I forgot the question already.
`
`Can
`
`you repeat that.
`
`Yes. Would you agree that this remote
`
`programming paragraph in Exhibit 7 describes
`
`remote programming only in terms of being
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`circuit—switched data calls?
`
`I would say it describes using data calls
`
`but doesn't exclude SMS messages.
`
`Certainly does not
`
`include SMS messages,
`
`does it?
`
`MR. YONAY: Objection.
`
`This particular paragraph does not refer to
`
`that.
`
`Does not refer to what?
`
`To SMS messages.
`
`If you look at the top line on page 3,
`
`this
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`800.211.DEPO (3376)
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`IGMNKDSAVOLMNEN
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
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`June10,2015
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`Look at Step A. This programming process
`
`begins when an incoming call from an RMU is
`
`received, right?
`
`Let's see what is the definition of RMU.
`
`Okay.
`
`So Step A, you were asking about
`
`that?
`
`Yes.
`
`The programming process begins by
`
`receiving an incoming call from an RMU,
`
`right?
`
`That's what it says.
`
`That's a reference to a circuit—switched
`
`data call, isn't it?
`
`That's one interpretation of it, yes.
`
`Is that your interpretation of it?
`
`I think that is most likely interpretation
`
`of it.
`
`If you look at Step H,
`
`that's suggesting
`
`that the programming process is ending when
`
`the call is terminated by the RMU, right?
`
`That's correct.
`
`And, again,
`
`the reference to a call being
`
`terminated is a reference to a
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`circuit—switched data call, right?
`
`I believe that's correct.
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`June10,2015
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`It's not a reference to an SMS message,
`
`is
`
`it?
`
`That's correct.
`
`So let's look at Exhibit 8, which is your
`
`Appendix F that addresses the CELL—EYE
`
`system.
`
`Okay.
`
`So I'm looking at page 1 of your chart on
`
`Exhibit 8, and in particular,
`
`to your
`
`discussion of the programmable interface
`
`claim element.
`
`So, according to your analysis,
`
`the
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`CELL—EYE system has two different
`
`programmable interfaces which would be the
`
`alarm sensor interface 13 and the vehicle
`
`immobilizer protection interface 18, right?
`
`Yes.
`
`It is referring to those two
`
`interfaces.
`
`Those,
`
`in your view, are two examples of
`
`programmable interfaces in this patent
`
`application?
`
`Yes.
`
`I believe those are two examples.
`
`Now let's turn to Figure 2 of the CELL—EYE
`
`patent.
`
`So we're now on Exhibit 7 at bates
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`June 10,2015
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`A.
`
`It is not interfaced with a monitored
`
`technical device but it is a programmable
`
`interface.
`
`And there's no teaching in the patent here
`
`that the vehicle immobilizer protection
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`actuators 19 send information to interface
`
`18, right?
`
`I believe it is the other way around.
`
`In other words,
`
`interface 18 can send
`
`information to 19 but not vice versa,
`
`correct?
`
`Well,
`
`I'm not saying it cannot, but this
`
`figure doesn't teach that.
`
`The figure shows a one way arrow going from
`
`Item 18 to Item 19, correct?
`
`Correct.
`
`And that arrow represents the flow of
`
`information, right?
`
`I believe so.
`
`Are you offering the opinion that the GSM
`
`repeater stations that are out there in the
`
`cell phone network are monitored technical
`
`devices for purposes of this patent?
`
`MR. YONAY:
`
`Is there anywhere in
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`IGMNKDSAVOLAWEN
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`June10,2015
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`the report you'd like to refer to,
`
`Mr. Henschke?
`
`Where do you think I have said that?
`
`I'm not saying you have.
`
`I'm asking.
`
`I don't think that's a reasonable
`
`interpretation, at least in this context.
`
`Does the patent application contain any
`
`disclosures or teachings about what
`
`type of
`
`interface might exist between modem 15 and
`
`controller and memory unit 14?
`
`MR. YONAY:
`
`For my benefit, could
`
`you repeat the question, please.
`
`(Reporter reads back as requested.)
`
`Well,
`
`let me go to the patent.
`
`I don't
`
`remember by heart.
`
`Maybe I can shortcut the process,
`
`Mr. Savolainen. Are you trying to argue in
`
`your invalidity opinions that the interface
`
`between modem 15 and controller and memory
`
`unit 14 qualifies as the programmable
`
`interface in the patent claims?
`
`MR. YONAY:
`
`Again,
`
`if you really
`
`want to shortcut this,
`
`you could refer to
`
`somewhere in the report that this is
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`June10,2015
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`unit.
`
`I'm sorry, sir.
`
`That suggests --
`
`Sorry.
`
`Go ahead.
`
`That suggests that once the interface has
`
`indicated an alarm then the ALU gives it the
`
`command to reset the alarm.
`
`Excuse me.
`
`Is there a particular place in
`
`Exhibit 7 that you were just reading from?
`
`Exhibit 7, yes, on page 6 under "Alarm
`
`Sensor Interface" in the second set of
`
`bullets, C.
`
`Second set of bullets.
`
`Oh,
`
`I see.
`
`Okay.
`
`And your understanding is that is
`
`describing programmability of sensor
`
`interface 13?
`
`Yes.
`
`Are there any other examples in the patent
`
`that you believe show programmability of
`
`sensor interface 13?
`
`You want me to read through the patent
`
`again?
`
`Not necessarily,
`
`but if you're aware of
`
`them, I'd like to know them.
`
`Q.
`
`A.
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`Q.
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`A.
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`KIMMO SAVOLAINEN
`M2M SOLUTIONS vs. MOTOROLA SOLUTIONS
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`June10,2015
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`record,
`
`the time is 11:43.
`
`(Recess.)
`
`
`THE VIDEOGRAPHER: We're back on
`
`
`The time is 11:52.
`the record.
`
`So back to page 6 and that item C where we
`
`were talking about the reset function of the
`
`interface 13.
`
`A. Okay.
`
`
`
`Q.
`
`Now does that reset occur any time a digital
`
`input is received from ALU 16?
`
`MR. YONAY: Objection.
`
`A.
`
`I'm sure there can be different kinds of
`
`digital inputs.
`
`I'm sure this would not be
`
`the only digital input.
`
`Q. What I'm asking is would it be the case that
`
`every time interface 13 receives a digital
`
`input from the ALU of any type that that
`
`reset function will occur?
`
`A.
`
`I don't believe there is such a statement
`
`here.
`
`Q.
`
`I'm asking what your understanding is.
`
`A. My understanding would be that reset
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`function would be one of the possible
`
`signals from the ALU.
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