IN THE UNITED STATES DISTRICT COURT
`
`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.
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`Plaintiff,
`
`v.
`
`SIMCOM WIRELESS SOLUTIONS CO.,
`LTD., SIM TECHNOLOGY GROUP LTD.,
`MICRON ELECTRONICS L.L.C., and
`KOWATEC CORPORATION,
`
`Defendants.
`
`C.A. No. 12-033-RGA
`
`C.A. No. 12-034-RGA
`
`REBUTTAL EXPERT REPORT OF DR. ALON KONCHITSKY
`
`RESPONSIVE TO THE SAVOLAINEN REPORT
`
`REGARDING THE ALLEGED INVALIDITY OF THE ’010 PATENT
`
`4811-1800-2204.1
`
`Telit Wireless Solutions Inc., et al. - Exh. 1135
`Telit Wireless Solutions Inc., et al. v. M2M Solutions LLC - IPR2016-00055
`p. 1
`
`

`
`
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`violation or a phone number to be used in response to a panic button depression. (Exh. 31, p.
`
`3852, l. 39 – p. 3853, l. 4). Thus, there is no transmission in WO 00/17021 that includes both a
`
`coded number and at least one telephone number or IP address.
`
`787. WO 00/17021 neither discloses nor suggests a memory module for storing at least
`
`one telephone number or IP address from an authenticated transmission as one of one or more
`
`permitted callers if the processing module authenticates the at least one transmission by
`
`determining that the at least one transmission includes the coded number. The Court has
`
`construed a “permitted caller” as “a telephone number or IP address on a list of numbers that are
`
`designed to cause the programmable communicator to accept an incoming call received from that
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`number.” Mr. Savolainen points to a portion of claim 2 of WO 00/17021 that states that “Only
`
`after the provision of a valid PIN code will the installed GSM mobile unit permit the user to …
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`change any of the stored numbers … of the system.” (Sav. Rep. at App. F, p. 4) (Exh. 31, p.
`
`3857, ll. 14-16). The stored numbers mentioned in claim 2 of WO 00/17021, however, refer
`
`back to the stored numbers mentioned in claim 1 of WO 00/17021 from which that claim 2
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`depends, and the stored numbers in claim 1 of WO 00/17021 are all numbers for outgoing calls.
`
`(Exh. 31, p. 3856, ll. 34-40). Storing a number for an outgoing call has nothing to do with
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`whether or not an incoming call is accepted. WO 00/17021 neither discloses nor suggests a list
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`of numbers that are designed to cause a programmable communicator to accept an incoming call.
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`Mr. Savolainen appears to admit that there is no disclosure in WO 00/017021 of a list of numbers
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`that are designed to cause a programmable communicator to accept an incoming call because he
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`attempts to form an obviousness combination with another document, and I refute Mr.
`
`Savolainen’s purported obviousness combination in the below section regarding Claim 1 not
`
`being obvious.
`
`4811-1800-2204.1
`
`300
`
`Telit Wireless Solutions Inc., et al. - Exh. 1135
`Telit Wireless Solutions Inc., et al. v. M2M Solutions LLC - IPR2016-00055
`p. 2
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`

`
`
`
`
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`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`Executed on July 7, 2014 in the city of Sea of Galilee, Israel.
`
`
`
`
`
` Alon Konchitsky
`
`4811-1800-2204.1
`
`373
`
`Telit Wireless Solutions Inc., et al. - Exh. 1135
`Telit Wireless Solutions Inc., et al. v. M2M Solutions LLC - IPR2016-00055
`p. 3