UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`
`KONINKLIJKE KPN N.V.,
`Patent Owner.
`
`__________
`
`Case IPR2016-00808
`Patent 8,886,772
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`
`
`DECLARATION OF REGIS J. “BUD” BATES
`IN SUPPORT OF PATENT OWNER
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`
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`KPN EXHIBIT 2002.001
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`Case IPR2016-00808
`Patent 8,886,772
`Declaration of Regis J. “Bud” Bates
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`TABLE OF CONTENTS
`I.
`INTRODUCTION ............................................................................................... 1
`II. QUALIFICATIONS ............................................................................................ 1
`III. PRIOR TESTIMONY ......................................................................................... 5
`IV. MATERIALS CONSIDERED ............................................................................ 5
`V. LEGAL STANDARDS ....................................................................................... 6
`a.
`Burden of proof ..................................................................................... 6
`b.
`Claim construction ................................................................................ 6
`c.
`Obviousness ........................................................................................... 7
`d.
`Level of ordinary skill in the art ............................................................ 8
`VI. THE ’772 PATENT ............................................................................................. 8
`VII. CLAIM CONSTRUCTION ............................................................................. 16
`VIII. ANALYSIS OF THE REFERENCES ............................................................ 21
`a.
`Bates ....................................................................................................21
`b.
`Bauchot ................................................................................................32
`IX. BATES DOES NOT RENDER THE INDEPENDENT CLAIMS OBVIOUS 33
`a.
`Bates does not disclose “wherein the ACSMD is configured,
`responsive to receiving the request, to: identify the manageable
`electronic device by comparing at least a portion of the request with
`the information for the identification of electronic devices of the at
`least one database” ..............................................................................33
`i. An SGSN does not identify a mobile station by comparing an
`IMSI with identification information from an HLR in response
`to receiving a GPRS attach request .........................................34
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`b.
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`c.
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`ii. An SGSN does not identify a mobile station by comparing a
`PDP type, PDP address or APN with identification information
`locally stored in the SGSN in response to receiving a GPRS
`attach request ...........................................................................35
`iii. One of ordinary skill in the art would not include the IMEI in
`the activate PDP context request message ...............................37
`Bates does not disclose “wherein the ACSMD is configured,
`responsive to receiving the request, to…identify an ACS from the
`plurality of ACSs in accordance with the identification of the
`manageable electronic device . . . .” ....................................................38
`Petitioner conflates the separate and distinct GPRS attach and activate
`PDP context transactions .....................................................................39
`X. THE COMBINATION OF BATES AND APPLICANT’S ADMITTED
`PRIOR ART DOES NOT RENDER CLAIM 9 OBVIOUS ............................. 42
`XI. THE COMBINATION OF BATES, APPLICANT’S ADMITTED PRIOR
`ART, AND BAUCHOT DOES NOT RENDER CLAIM 9 OBVIOUS ........... 43
` XII. RESERVATION OF RIGHTS ...................................................................... 44
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`Case IPR2016-00808
`Patent 8,886,772
`Declaration of Regis J. “Bud” Bates
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`INTRODUCTION
`I.
`1. My name is Regis J. “Bud” Bates, and I have been retained as an
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`expert witness by Patent Owner Koninklijke KPN N.V. (“Patent Owner”) for the
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`Inter Partes Review of claims 1-2 and 8-16 (the “challenged claims”) of U.S.
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`Patent No. 8,886,772 (“the ’772 patent”). More specifically, I have been asked to
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`render opinions regarding the validity of the ’772 patent with respect to the Petition
`
`for Inter Partes Review (“Petition”) filed by Samsung Electronics Co., Ltd.,
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`Samsung Electronics America, Inc., and SmartThings, Inc. (“Petitioner”).
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`2.
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`This report contains statements of my opinions formed to date and the
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`bases and reasons for those opinions. I may offer additional opinions based on
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`further review of materials in this case, including opinions and/or testimony of
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`other expert witnesses.
`
`II. QUALIFICATIONS
`This section summarizes my career history, education, publications,
`3.
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`and other relevant qualifications. My full curriculum vitae is attached as Appendix
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`A to this report.
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`4.
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`I have been involved in and with the telecommunications industry for
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`50 years and have seen the development and growth of the various technologies,
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`infrastructure, legal, regulatory, and technical services.
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`5.
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`Notably, I am the author of the book GPRS, McGraw-Hill (2002),
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`
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`which has been submitted by Petitioner as Exhibit No. 1003 (“Bates”), and is the
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`sole or primary reference used by Petitioner to contend that certain claims of the
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`’772 patent are invalid. As author of this book, I am uniquely situated to opine
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`upon its contents, as well as the conclusions that both parties in this proceeding
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`draw therefrom.
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`6.
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`I am the founder and president of TC International Consulting, Inc.
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`(TCIC), based in Heber, Arizona. I have held this position since the inception of
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`the company in October 1989. TCIC is a full service consulting and training firm
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`specializing in communications and computer convergence.
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`7. My role is to assist our client companies with the analysis of options,
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`selection of vendors or products to meet their strategic goals, and training for
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`technologies including voice, telephone systems, data networks, video, Internet,
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`wireless, wireless local area networks (LAN), voice over Internet Protocol (VoIP)
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`systems and services, fiber optics, and infrastructure. We have been responsible
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`for selecting and implementing over 100 private branch exchange (PBX) systems
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`for our client companies. TCIC develops and conducts training for corporate
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`users, manufacturers, and carriers.
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`8.
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`From September 1986 to October 1989, I was the chief information
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`
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`officer at Pepper, Hamilton, and Scheetz in Philadelphia, PA. My responsibilities
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`included the complete automation of the law firm’s multiple offices around the
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`country.
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`9.
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`From September 1979 to September 1986, I was the
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`telecommunications manager at Air Products and Chemicals, Inc. My
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`responsibilities were to design, select, analyze and implement voice and data
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`communications projects at U.S. and international sites.
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`10. From April 1977 to September 1979, I was the senior
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`telecommunications manager for manufacturing and international sites at Data
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`General Corporation in Westboro, MA. I was responsible for selecting
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`telecommunications equipment for sites across the world, selecting services (voice,
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`data and fax traffic) from common carriers, and selecting appropriate means and
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`protocols to use these goods and services.
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`11. From September 1974 to April 1977, I was the manager of
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`administrative services at a retail chain in Canton, MA called Hills Department
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`Stores. There, I was responsible for communications matters including voice, data,
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`fax, telex, and teletype.
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`12. From April 1972 to September 1974, I worked as the
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`
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`telecommunications and facilities manager at Damon Corporation, a conglomerate
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`that included medical-biological development, veterinary products, clinical labs,
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`security manufacturing, and hobby craft. My responsibilities included voice and
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`data communications for a variety of locations across the country.
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`13. From September 1966 to April 1972, I was a captain in the U.S. Army
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`Signal Corps. My assignments took me to many locations, including a deployment
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`in Vietnam, where I worked in mobile and fixed-site communication environments
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`using radio-based troposcatter systems.
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`14.
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`In addition to these formal roles, I have consulted for and provided
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`training courses to over 20 major organizations, including Cisco, Motorola
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`Solutions, Nortel Networks, the University of California at Berkeley, and Fidelity
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`Investments, as well as the U.S. Army, Central Intelligence Agency, Federal
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`Bureau of Investigation, and National Security Agency.
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`15.
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`I received a Business Management Degree in 1979 from Stonehill
`
`College in Easton, MA with additional work towards my Masters of Business
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`Administration from Lehigh University in Bethlehem, PA and St. Joseph’s College
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`in Philadelphia, PA. I completed all the coursework but not the thesis for an MBA.
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`16.
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`I have authored or co-authored 15 books on telecommunications
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`
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`technologies, and have authored 9 magazine articles.
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`III. PRIOR TESTIMONY
`17. The following represents a list of all other cases in which, during the
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`previous 4 years, I testified as an expert at trial or by deposition:
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`• Adrienne Andros Ferguson et al. v. The Estate of Campana et al.:
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`Testified on behalf of NTP.
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`• Mosaid Techs., Inc. v. Cisco Sys., Inc. (ITC): Testified on behalf of
`
`Mosaid.
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`• British Telecomm., PLC v. Comcast et.al.: Testified on behalf of
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`Comcast.
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`• Pine Tel. Co. v. Alcatel Lucent USA, Inc.: Testified on behalf of
`
`Alcatel-Lucent.
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`• Enter. Sys. Techs. v. Samsung, et al.: Testified on behalf of
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`Enterprise Systems Technologies.
`
`IV. MATERIALS CONSIDERED
`I have considered information from various sources in forming my
`18.
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`opinions herein, including:
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`• the ’772 patent and its prosecution history;
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`• Petitioner’s Petition for Inter Partes Review of the ’772 patent (the
`
`“Petition”), as well as the references cited therein;
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`• the declaration of Dr. Reiher, submitted by Petitioner as Exhibit 1006;
`
`and
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`• all documents and other materials cited to herein.
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`19.
`
`I have reviewed Patent Owner’s Preliminary Response to the Petition,
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`to which this Declaration is being submitted as Exhibit No. 2002, and I agree with
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`both its analysis and conclusions. I have also reviewed and considered each of the
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`exhibits to the Preliminary Response in forming my opinions.
`
`V. LEGAL STANDARDS
`I have applied the following legal principles provided to me by
`20.
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`counsel in arriving at the opinions set forth in this report.
`
`a. Burden of proof
`I understand that Petitioner has the burden to prove that the ’772
`21.
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`patent is invalid by a preponderance of the evidence.
`
`b. Claim construction
`I understand that Patent Owner has brought an action for infringement
`22.
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`of the ’772 patent against Petitioner in the U.S. District Court of the Eastern
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`District of Texas (Case No. 2:14-cv-01165-JRG, Koninklijke KPN N.V. v. Samsung
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`Electronics America, Inc. et al.).
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`23.
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`I understand that the Patent Trial and Appeals Board (“PTAB”)
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`
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`applies the broadest reasonable interpretation (“BRI”) of the claims presented for
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`review in a petition for Inter Partes Review, which may differ from the
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`construction standard used by the district court. As such, I understand that the
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`construction of a claim term by the PTAB may differ from the proposed
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`construction of a claim term in the district court.
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`24. Further, I understand that, even under BRI, the interpretation of a
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`claim is limited by the claim language itself and the disclosure of its specification.
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`Thus, a construction can be found unreasonable if the claims or the specification
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`would teach one of ordinary skill in the art that a narrower meaning was intended.
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`c. Obviousness
`I understand that a patent claim is obvious if the differences between
`25.
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`the claimed invention and the prior art are such that the subject matter of the
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`claimed invention, when viewed as a whole, would have been obvious to a person
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`of ordinary skill in the art at the time the invention was made.
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`26.
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`I understand that, in order for a claim to be found obvious, the party
`
`contending the claim’s obviousness must establish a prima facie case thereof. To
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`do so, the obviousness contentions cannot be conclusory – instead, the party must
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`clearly articulate its reasoning. Further, this party must show that the prior art
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`references teach or suggest each element of the claim, and/or that one of ordinary
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`skill in the art would be reasonably and logically led to the claimed invention by
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`these references.
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`27.
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`I further understand that a claim is not obvious over a combination of
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`prior art references if that combination would render one of those references
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`inoperable for its intended purpose.
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`d. Level of ordinary skill in the art
`28. With respect to the ’772 patent, a person of ordinary skill in the art at
`
`the time of the invention (which I take to be July 2008) would have at least a
`
`bachelor’s degree in electrical engineering, computer science, or a related field, as
`
`well as at least 2-3 years of experience with computer networks. A person with
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`less formal education, but more practical experience, may also be of “ordinary skill
`
`in the art.”
`
`VI. THE ’772 PATENT
`I have reviewed the ’772 patent, which is titled “Method and System
`29.
`
`for Remote Device Management.” The ’772 patent discloses scalable solutions for
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`management of remote devices (i.e., “manageable electronic devices”). These
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`manageable electronic devices may be “any type of electronic device capable of
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`digital communication,” including “a personal computer, a gateway or router, an
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`electronic appliance such as a set-top box, a television set, an IP based telephone,
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`etc.” that is deployed at a customer’s premises. ’772 patent at 1:26-33. Among
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`other features, such devices allow for remote management, which “relates to auto-
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`configuration and dynamic service provisioning, software management, status and
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`performance monitoring and diagnostics.” Id. at 1:34-37. They also can obtain
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`service level settings from an auto-configuration server (ACS). Id. at 1:42-45.
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`These settings instruct the manageable electronic devices to operate in the proper
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`fashion on customer premises.
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`30. As stated in the ’772 patent, typically an “ACS is dedicated either to a
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`certain level of service (e.g. premium, best effort), a type of device (e.g., Home
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`Gateway, Voice over IP telephone, Set TopBox) or a specific customer group (e.g.,
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`business or residential).” Id. at 1:46-49. These ACSs can be reachable to the
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`manageable electronic devices over a wide-area network (“WAN”). Id. at Fig. 1;
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`3:64-67.
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`31. Figure 1 of the ’772 patent, reproduced above, shows an example of
`
`such an arrangement in the prior art. See, e.g., id. at 3:46-47. In Figure 1, a
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`manageable electronic device 1 connects a local area network (“LAN”) to a WAN.
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`Id. at 3:64-67. The LAN communicatively couples devices 2, 3, and 4 (which may
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`also be manageable electronic devices) with manageable electronic device 1. Id. at
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`3:65-4:4. The LAN may be a home network or an office network, but can be
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`distributed over multiple geographic locations. Id. at 4:5-8.
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`32. The WAN may be the Internet. Id. at 4:10-13. In this example, the
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`WAN communicatively couples auto-configuration server 1 (ACS1) and auto-
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`configuration server 2 (ACS2) to manageable electronic device 1. Id. at 4:22-29,
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`4:35-39. In Figure 1, for example, ACS1 and ACS2 contain configuration data for
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`manageable electronic device 1 and manageable electronic device 2, respectively.
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`Id. at 4:22-29. This auto-configuration data may have been delivered to ACS1 and
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`ACS2 by one or more of provisioning systems P1, P2, P3, P4, P5, and P6. Id. at
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`4:30-32.
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`33. A manageable electronic device, (such as manageable electronic
`
`devices 1 and 2) may require configuration data from a dedicated auto-
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`configuration server (ACS 1 in the case of manageable electronic device 1 and
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`ACS 2 in the case of manageable electronic device 2). Id. at 4:22-29, 40-43. In
`
`order to communicate with the appropriate ACS, in this example, the manageable
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`electronic device is pre-configured, prior to installation in the LAN, with the IP
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`address or URL of the proper ACS. Id. at 4:48-50, 4:55-57.
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`34. The pre-configuring of IP addresses or URLs of ACSs in this
`
`example, however, is time consuming and sensitive to errors and mistakes. Id. at
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`1:53-60. Given the large number of manageable electronic devices on various
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`networks (this could reach into the millions) and the time required for pre-
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`configuring, the errors and mistakes that result therefrom have a deleterious impact
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`on the efficient operation of the these devices.
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`35. The ’772 patent discloses methods, devices, and systems for remote
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`
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`device management that include an auto-configuration server managing device
`
`(ACSMD), at least one database, and a plurality of ACSs. Id. at Abstract. These
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`components may be communicatively coupled with one another by a network. Id.
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`The database holds information for identification of manageable electronic
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`devices. Id.
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`36. Figure 2 of the ’772 patent, reproduced above, shows an example of
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`such an arrangement. See, e.g., id. at 4:62-63. Figure 2 uses the same reference
`
`numerals as Figure 1 to refer to corresponding entities. Id. at 4:64-65. But, Figure
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`2 also includes, in the WAN, a digital subscriber line access multiplexer (DSLAM)
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`15, a domain name system (DNS) server, an auto-configuration server managing
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`device (ACSMD) 25, and databases 26, 27, and 28. Id. at 4:66-5:3. Further, a
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`service activation device manager (SADM) may provide an Internet service
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`provider (ISP) and/or other entities access to the ACSs. Id. at 5:22-26.
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`37.
`
`In the example of Figure 2, manageable electronic device 1 includes
`
`an IP address or URL for the ACSMD 25. Id. at 5:51-55. Accordingly, in this
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`embodiment, the manageable electronic device 1 transmits a request for
`
`configuration data to ACSMD 25. Id. at 5:56-59; see also Fig. 5 (M1). In this
`
`embodiment, the request includes identifying information of manageable electronic
`
`device 1, such as an IP address of manageable electronic device 1. Id. at 6:5-6.
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`After receiving the request, ACSMD 25 compares identifying information of
`
`manageable electronic device 1 to a database (e.g., database 26). For example, the
`
`database may contain IP addresses that are valid for access to ACSMD 25. Id. at
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`6:10-15. In such an embodiment, if the IP address of manageable electronic device
`
`1 matches one of the IP addresses in the database, the auto-configuration process
`
`continues; otherwise it terminates. Id. at 6:19-24.
`
`38. Next, ACSMD 25 can determine the appropriate ACS, based on
`
`identifying information of manageable electronic device 1, by way of a lookup in
`
`one or more other databases (e.g., databases 27 and/or 28). Id. at 6:29-43. Thus,
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`an ACS may be selected for auto-configuration based on identifying information
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`of manageable electronic device 1, such as an IP address of manageable electronic
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`device 1. Id. In this manner, ACSMD 25 can select an ACS that meets the
`
`configuration needs of manageable electronic device 1. Id. at 6:51-55
`
`39. Then, the ACSMD 25 can relay the request to the selected ACS,
`
`receive a reply from the ACS containing configuration data for manageable
`
`electronic device 1, and transmit the reply to manageable electronic device 1. Id.
`
`at 6:63-7:3, 8:25-31; see also Fig 5 (M5, M6, M7, respectively). Manageable
`
`electronic device 1 may use the configuration data to configure itself. Id. at 8:33-
`
`37.
`
`40. These procedures improve over the prior art by eliminating
`
`complexities related to pre-configuring manageable electronic devices.
`
`Particularly, instead of pre-configuring an IP address or URL of a particular ACS
`
`into the each device, these devices can be configured with an address of the
`
`ACSMD instead. This dramatically reduces complexity and errors inherent in the
`
`prior art. Notably, the one address of the ACSMD replaces the multiple addresses
`
`of the ACSs, significantly simplifying the configuration of the manageable
`
`electronic devices.
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`VII. CLAIM CONSTRUCTION
`41. For purposes of this declaration and my opinions regarding the
`
`challenged claims, I have interpreted the claims under BRI. I understand that the
`
`U.S. District Court of the Eastern District of Texas construed a number of claim
`
`terms in its Claim Construction Order of May 6, 2016. See Ex. 2003. I further
`
`understand that that, under BRI, the construction of claim terms may be the same
`
`as that of the District Court, but not narrower. Thus, I have interpreted the
`
`challenged claims in a fashion that is consistent with both BRI and the Claim
`
`Construction Order.
`
`42.
`
`I understand that Petitioner has proposed claim constructions for two
`
`claim terms in the Petition. Pet. at 17-20. These proposed constructions are
`
`compared to those of the Claim Construction Order in the table below.
`
`Claim Term
`
`“a plurality of auto-
`configuration servers
`(ACSs)”
`
`Petitioner’s Proposed
`Construction
`“two or more computers
`in the WAN, each of
`which automatically
`provides configuration
`data to a manageable
`electronic device in
`response to a request from
`
`District Court’s
`Construction
`“two or more systems of
`hardware and/or software,
`each of which is capable
`of automatically
`configuring a manageable
`electronic device”
`
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`“auto-configuration server
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`“hardware and/or
`software that relays
`configuration requests to
`the auto-configuration
`servers”
`
`it for configuration data”
`“computer in the WAN
`which, in response to a
`request for configuration
`data, relays the request to
`the dedicated ACS,
`receives a reply with the
`requested configuration
`data from the dedicated
`ACS and transmits the
`reply to a manageable
`electronic device”
`
`
`43.
`
`It is my understanding that Petitioner’s proposed constructions are
`
`narrower than the District Court’s constructions. For each term, Petitioner
`
`proposed that it be limited to computer hardware in a specified location (i.e., “two
`
`or more computers in the WAN” and a “computer in the WAN”). The District
`
`Court, however, construed these terms to be “hardware and/or software” with no
`
`particular location. Petitioner’s proposed constructions also require the additional
`
`functionality of providing “configuration data to a manageable electronic device in
`
`response to a request from it for configuration data” and receiving “a reply with
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`the requested configuration data from the dedicated ACS and transmit[ting] the
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`reply to a manageable electronic device,” respectively (emphasis added).
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`Declaration of Regis J. “Bud” Bates
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`44. Since Petitioner’s proposed constructions are narrower than those of
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`the District Court, counsel has instructed me that they can be disregarded for
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`purposes of claim construction in this proceeding.
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`45. To the extent that neither the district court nor the Patent Owner
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`provide a claim construction for a particular claim term or element, I used the
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`ordinary and customary meaning of the words, as would be understood by a person
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`of ordinary skill in the art in the context of the field of the invention at the time of
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`the invention, to construe such a claim term or element.
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`46. Ultimately, as set forth herein, I find the challenged claims
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`nonobvious and valid, regardless of whether the ordinary and customary meaning,
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`the construction of the district court, or the construction of Patent Owner is
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`applied.
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`47. Furthermore, based on my analysis of the ’772 patent, one of ordinary
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`skill in the art would understand the following claim term to have the meaning set
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`forth below. This term has not been construed by the District Court.
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`48. All independent claims recite the following claim term, or one similar
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`to it: “wherein the ACSMD is configured, responsive to receiving the request, to:
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`identify the manageable electronic device…and identify an ACS.”1
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`49. The plain language of the claims dictate that this term should be
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`interpreted as requiring that a manageable electronic device and an ACS both be
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`identified responsive to the ACSMD receiving a request, since claim 1 and the
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`other independent claims recite just one “request for configuration data”
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`transmitted to the ACSMD.
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`50. To that point, Figures 3B and 5 of the ’772 patent, at reference
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`numerals 101 and M1 respectively, each depict exactly one request being received
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`by an ACSMD. In action 101, “the auto-configuration server manager receives the
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`request from the manageable electronic device 1.” ’772 patent, at 6:3-4 (emphasis
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`added); see also Figure 3B (labeling action 101 as “Receive request”); Id. at 8:4-5
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`(“The first message M1 is received by the auto-configuration server manager 25.”).
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`51.
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`In response to message M1 containing “a valid request,” “[t]he auto-
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`configuration server manager 25 [i.e., the ACSMD] carries out the actions 101-
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` 1
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` Independent claims 1 and 15 use the term “ASCMD,” while independent
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`claims 10 and 12 use the term “computer.”
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`105.” Id. at 8:4-6. The ’772 patent describes an example embodiment as
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`Patent 8,886,772
`Declaration of Regis J. “Bud” Bates
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`“[t]ypically, the request comprises the IP address of the manageable electronic
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`device 1 and information on the type or function of the manageable electronic
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`device 1.” Id. at 6:5-7 (emphasis added).
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`52. Action 102 involves identifying the manageable electronic device
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`based on information in the request, namely, identifying information such as the IP
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`address of the manageable electronic device. Id. at 6:10-15 (“[T]he auto-
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`configuration server manager 25 compares the received IP address of the
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`manageable electronic device with a first database 26.”).
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`53. Action 105 involves identifying the ACS, also based on identifying
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`information of the manageable electronic device received in the request. Id. at
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`6:35-39. For instance, ACSMD 25 can resolve “an IP address ACSID” of the
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`dedicated ACS “from at least one of”:
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`(i)
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`the identity of the service provider ISPID, which the ACSMD
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`resolved in action 104 using “the IP address of the manageable
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`electronic device” received from the request; or
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`(ii)
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`the “received IP address of the manageable electronic device,”
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`received from the request. Id.
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`54. Moreover, there is simply no suggestion in the specification or
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`drawings that the manageable electronic device and ACS are identified in response
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`to multiple requests.
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`55. Thus, given the plain meaning of the claims, as well as the
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`specification’s clear teaching, this term should be interpreted to mean “the
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`manageable electronic device and the ACS both are identified responsive to the
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`ACSMD receiving a single request.”
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`VIII. ANALYSIS OF THE REFERENCES
`a. Bates
`56. Petitioner has cited my book (GPRS, McGraw-Hill (2002), submitted
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`by Petitioner as Exhibit 1003) against all of the challenged claims.
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`57. The General Packet Radio Service (GPRS) is a data communication
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`service that operates on Global Systems for Mobile (GSM) cellular networks. Ex.
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`1003 at 22. In cellular networks, the wireless coverage of an operator is divided
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`into cells. Id. at 25. By way of the air interface of a cell, a mobile station can
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`communicate wirelessly with a base station. Id. at 36.
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`58. The mobile stations (e.g., cellular telephones or “cell phones”) that
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`use GPRS networks consist of two parts: physical equipment (e.g., the radio
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`transceiver, display, and digital signal processors), and a removable smart card
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`called the subscriber identity module (SIM). Id. at 37. As I explained:
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`The SIM provides personal mobility, so that the user can have access
`to all subscribed services irrespective of both the location of the
`terminal and the use of a specific terminal. By inserting the SIM card
`into another GSM cellular phone, as shown in Figure 1-11, the user is
`able to receive calls at that phone, make calls from that phone, or
`receive other subscribed services. The International Mobile
`Equipment Identity (IMEI) uniquely identifies the mobile equipment.
`The SIM card contains the International Mobile Subscriber Identity
`(IMSI), identifying the subscriber, a secret key for authentication, and
`other user information. The IMEI and the IMSI are independent,
`thereby providing personal mobility. A password or personal identity
`number may protect the SIM card against unauthorized use.
` Id. at 38.
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`59. Thus, the IMSI is a subscriber identifier that is stored in the SIM card,
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`while the mobile station is identified by the IMEI. This is a critical distinction,
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`because use of both the IMSI and IMEI provides personal mobility. Id. (“The
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`IMEI and the IMSI are independent, thereby providing personal mobility.”). The
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`subscriber (user) can remove his or her SIM card from one mobile station and
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`insert it into another mobile station, then use this mobile station (with the SIM card
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`therein) to make calls and receive other services. Id. at 38.
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`60. The overall GPRS system architecture is shown in Figure 3-5 of my
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`book, which is reproduced above. Id. at 107. To send or receive data, a mobile
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`station (MS) searches for the strongest radio signal that it can find from nearby
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`base transceiver stations (BTSs, or “base stations”). Id. at 86. Once this base
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`station is found, the mobile station informs the network of its selection and listens
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`to transmissions from the base station. Id.
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`61. Before a mobile station can communicate with other endpoints (e.g.,
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`servers on the Internet or a private network), however, th