IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`M2M SOLUTIONS LLC,
`
`Plaintiff,
`
`v.
`
`SIERRA WIRELESS AMERICA, INC., et al.,
`
`Defendants.
`
`C.A. No. 14-1102-RGA
`
`PLAINTIFF M2M SOLUTIONS LLC’S
`PRELIMINARY INFRINGMENT CONTENTIONS
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 1
`
`

`
`What follow are plaintiff M2M Solutions LLC’s Preliminary Infringement Contentions.
`
`BAYARD, P.A.
`
`/s/ Richard D. Kirk
`Richard D. Kirk (rk0922)
`Stephen B. Brauerman (sb4952)
`Vanessa R. Tiradentes (vt5398)
`Sara E. Bussiere (sb5725)
`222 Delaware Avenue, Suite 900
`Wilmington, DE 19801
`(302) 655-5000
`rkirk@bayardlaw.com
`sbrauerman@bayardlaw.com
`vtiradentes@bayardlaw.com
`sbussiere@bayardlaw.com
`
`Attorneys for Plaintiff,
`M2M SOLUTIONS LLC
`
`May 15, 2015
`
`Of Counsel:
`
`FOLEY & LARDNER LLP
`Marc N. Henschke
`111 Huntington Avenue, Suite 2600
`Boston, MA 02199
`(617) 342-4000
`mhenschke@foley.com
`
`Jeffrey N. Costakos
`Kadie M. Jelenchick
`Matthew J. Shin
`777 E Wisconsin Avenue
`Milwaukee, WI 53202
`(414) 271-2400
`jcostakos@foley.com
`kjelenchick@foley.com
`
`Jason J. Keener
`Jeffrey J. Mikrut
`321 North Clark Street
`Chicago, IL 60654
`(312) 832-4500
`jkeener@foley.com
`jmikrut@foley.com
`
`2
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 2
`
`

`
`Claim Element
`
`Infringement Support
`
`1.
`
`A programmable communicator
`device comprising:
`
`1.a
`
`a programmable interface for
`establishing a communication link
`with at least one monitored technical
`device, wherein the programmable
`interface is programmable by
`wireless packet switched data
`messages; and
`
`AirPrime embedded wireless module products
`are communicator devices that Sierra Wireless
`characterizes as “the industry’s broadest
`portfolio of wireless modules for mobile
`computing and M2M [communications
`applications] . . . that is just right for your
`specific connectivity needs.”
`(AirPrime Embedded Wireless Modules
`Datasheet, p. 2)
`
`Sierra Wireless provides a software suite which
`allows for the development of M2M applications
`using the module.
`
`The AR Series modules are programmable via
`ANSI C/C++ and/or Lua scripting and/or
`standard and proprietary AT commands.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`(Sierra Wireless Software Suite
`http://www.sierrawireless.com/
`productsandservices/AirPrime.aspx p. 1)
`
`The AR Series modules have several different
`interfaces identified below through which they
`can be linked to monitored technical devices,
`each of which is able to be directly programmed
`by the module’s firmware in response to certain
`supported AT commands.
`
`Each of the accused interfaces is able to be
`directly programmed, including by or in
`response to certain supported AT commands that
`constitute or result in programming instructions
`that serve to cause the configuration of control
`registers and/or data registers residing within the
`interface circuitry of the interfaces, or that serve
`to cause the interfaces to responsively return data
`values.
`
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 3
`
`

`
`Claim Element
`
`Infringement Support
`
`These interfaces are capable of forming a
`communication link with any number of
`different types of monitored technical devices
`such as sensors, switches, actuators, and
`programmable logic controllers.
`(AirVantage Platform Technical Brief.pdf, 2010,
`p. 6)
`(AirVantage Development Tools for Quick Data
`Retrieval from General Electric Meters
`Technote, 2011, p. 6)
`(ALEOS 4.4.0 Software Configuration, Rev. 1,
`p. 6)
`(AirLink GX Series Hardware User Guide, Rev.
`3, pp. 7-10, 33-43)
`
`AR Series modules have one or more serial
`interfaces designated as UART1 and UART2.
`These interfaces are programmable in Sierra
`Wireless modules via AT commands that include
`the ATE, AT&C, AT&D, and AT+IPR
`commands.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 1, pp. 167-171, 181-84)
`
`AR Series modules have multiple General
`Purpose I/O (“GPIO”) pin interfaces. These
`interfaces are programmable in Sierra Wireless
`modules via AT commands that include the
`AT+WIOW, AT+WIOM, and AT+WIPC
`commands.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 4, pp. 106-117)
`
`AR Series modules have two Analog to Digital
`Converter (“ADC1” and “ADC2”) interfaces.
`These interfaces are programmable in Sierra
`Wireless modules via AT commands that include
`the AT+ADC command.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
` (AT Commands Interface Guide For Firmware
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 4
`
`

`
`Claim Element
`
`Infringement Support
`
`7.45, Rev. 019, Vol. 4, pp. 118-120)
`
`AR Series modules have firmware that is capable
`of operating with the AirVantage Platform from
`Sierra Wireless. The AirVantage Platform
`provides the ability to remotely monitor, control,
`and upgrade the AR Series modules in the field.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`The AirVantage Platform is able to communicate
`remotely with the AR Series module over a TCP
`connection and send wireless AT commands
`which are executed by the module and the
`responses are sent back to the AirVantage
`Platform.
`
`Therefore, each of the AT commands identified
`above for programming the interface can be run
`remotely, meaning that the AR Series modules
`are able to directly process and execute these
`programming commands when received in
`incoming wireless transmissions sent to the
`modules by remote devices.
`(AT Commands Over AirVantage Management
`Services Application Note, p. 1)
`
`In addition, each of the accused interfaces is able
`to be directly programmed by having their
`control registers configured by microprocessors
`and/or reset controllers as part of various
`hardware reset processes, and/or by having their
`control registers configured or their data values
`queried by microprocessors in response to
`receiving certain API function calls from
`embedded customer applications.
`
`The AR Series modules include a software
`component of the programmable communicator
`(i.e., a “processing module”) that is capable of
`authenticating an incoming wireless transmission
`containing a programming instruction. The
`processing module authenticates the incoming
`wireless transmission by determining whether it
`contains a required coded number. If the
`
`1.b
`
`a processing module for
`authenticating one or more wireless
`transmissions sent from a
`programming transmitter and
`received by the programmable
`communicator device by
`determining if at least one
`transmissions contains a coded
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 5
`
`

`
`Claim Element
`
`number;
`
`Infringement Support
`
`processing module is able to successfully
`authenticate the incoming wireless transmission
`in this manner, then the programmable
`communicator will process and execute the
`programming instruction.
`
`AR Series modules have a SIM interface for
`connecting to and controlling a Subscriber
`Identity Module (“SIM card”).
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`SIM cards comprise a Fixed Dialing Number
`(“FDN”) phonebook which is a memory module
`for storing telephone numbers corresponding to
`remote devices, including remote monitoring
`devices. AR Series modules support the
`AT+CLCK command for applying a facility
`lock to an FDN phonebook.
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 1, pp. 216-218)
`
`AR Series modules support a combination of AT
`commands that collectively allow for the editing
`of a facility locked FDN phonebook. For
`example, to initially obtain access to the FDN
`phonebook, AR Series modules support an
`AT+CPBS command to select a phonebook if
`used in conjunction with a required PIN2
`password (i.e., a “coded number”) when the
`FDN phonebook has a facility lock applied.
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 3, pp. 6-8)
`
`AR Series modules support AirVantage Platform
`which has the capability for running AT
`commands remotely. As such, these modules
`contain firmware that is able to directly process
`and execute supported AT commands received in
`incoming wireless transmissions sent to the
`modules by remote devices. Said wireless
`transmissions can comprise TCP/IP data
`messages, including GPRS and EDGE data
`messages.
`(Sierra_Wireless_AirPrime_AR_Series_
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 6
`
`

`
`Claim Element
`
`Infringement Support
`
`Automotive_Wireless_Modules.pdf, p. 2)
`(Running AT Commands Remotely Application
`Note, Rev. 5, pp. 7-9, 18-25)
`
`The AR Series modules also support the
`AirVantage Agent that is used to communicate
`with the AirVantage Platform.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`In sum, when a AR Series module receives one
`or more incoming wireless transmissions from a
`programming transmitter containing AT
`commands relevant to a facility locked FDN
`phonebook, the module’s firmware will act as a
`processing module to authenticate these one or
`more transmissions by determining if they
`contain the required PIN2 password coded
`number.
`
`Only if a AR Series module has authenticated the
`one or more incoming wireless transmissions as
`including the PIN2 password as described above
`will its firmware then execute the relevant AT
`command.
`
`AR Series modules have a SIM interface for
`connecting to and controlling a Subscriber
`Identity Module (“SIM card”).
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`SIM cards comprise a Fixed Dialing Number
`(“FDN”) phonebook which is a memory module
`for storing telephone numbers corresponding to
`remote devices, including remote monitoring
`devices. AR Series modules support the
`AT+CLCK command for applying a facility
`lock to an FDN phonebook. A facility locked
`FDN phonebook functions as a list of the
`telephone numbers to which the module is
`configured and permitted to send outgoing
`wireless voice or data transmissions.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 1 p. 216-218)
`
`1.c
`
`wherein the programmable
`communicator device is configured
`to use a memory to store at least one
`telephone number or IP address
`included within at least one of the
`transmissions as one or more stored
`telephone numbers or IP addresses if
`the processing module authenticates
`the at least one of the transmissions
`including the at least one telephone
`number or IP address and the coded
`number by determining that the at
`least one of the transmissions
`includes the coded number, the one
`or more stored telephone numbers or
`IP addresses being numbers to
`which the programmable
`communicator device is configured
`to and permitted to send outgoing
`wireless transmissions;
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 7
`
`

`
`Claim Element
`
`Infringement Support
`
`
`AR Series modules support a combination of AT
`commands that collectively allow for the editing
`of a facility locked FDN phonebook. For
`example, to initially obtain access to the FDN
`phonebook, AR Series modules support an
`AT+CPBS command if used in conjunction with
`a required PIN2 password coded number. Once
`accessed, in order to permit writing a new
`telephone number into the FDN phonebook, AR
`Series modules support an AT+CPBW
`command which will contain the new telephone
`number in its number field.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 3, pp. 6-8, 11-16)
`
`In the case where the facility lock is enabled for
`the FDN phonebook and a AR Series module
`receives one or more incoming TCP/IP
`transmissions that contain the AT+CPBW
`command and a new telephone number to be
`written into the FDN phonebook, components of
`the module’s firmware will act as a processing
`module to authenticate at least one of the
`transmissions by determining if the at least one
`of the transmissions contains the required PIN2
`password coded number.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 1, pp. 216-218, Vol. 3, pp.
`11-16)
`
`AR Series modules support the capability for
`“running AT commands remotely.” As such,
`these modules contain firmware that is able to
`directly process and execute supported AT
`commands received in incoming wireless
`transmissions sent to the modules by remote
`devices. Said wireless transmissions can
`comprise either SMS data messages or TCP/IP
`data messages, including GPRS and EDGE data
`messages.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
` (Running AT Commands Remotely Application
`Note, Rev. 5, pp. 7-9, 18-25)
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 8
`
`

`
`Claim Element
`
`Infringement Support
`
`
`The AirVantage Platform is able to send wireless
`AT commands remotely to the AR Series
`module over a TCP connection which are
`executed by the module and the responses are
`sent back to the AirVantage Platform.
`
`Therefore, each of the AT commands identified
`above for configuring the FDN phonebook can
`be run remotely, meaning that the AR Series
`modules are able to directly process and execute
`these programming commands when received in
`incoming wireless packet switched data
`messages.
`(AT Commands Over AirVantage Management
`Services Application Note, p. 1)
`
`In sum, when a AR Series module receives one
`or more incoming wireless transmissions from a
`programming transmitter containing the
`aforementioned AT commands relevant to
`entering a new telephone number corresponding
`to a remote device into a facility locked FDN
`phonebook, the module’s firmware will act as a
`processing module to authenticate these one or
`more transmissions by determining if they
`contain the required PIN2 password coded
`number.
`
`Each AR Series module stores in an on-board
`memory module a unique identifier in the form
`of an International Mobile Equipment
`Identification (“IMEI”) number.
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 1, pp. 35-36)
`
`AR Series modules support GPRS data message
`transmissions or other data messages sent over a
`network connection.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`
`1.d
`
`1.e
`
`wherein the programmable
`communicator device is configured
`to use an identity module for storing
`a unique identifier that is unique to
`the programmable communicator
`device;
`
`and wherein the one or more
`wireless transmissions from the
`programming transmitter comprises
`a General Packet Radio Service
`(GPRS) or other wireless packet
`switched data message;
`
`1.f
`
`and wherein the programmable
`communicator device is configured
`
`
`
`Ready Agent
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 9
`
`

`
`Claim Element
`
`Infringement Support
`
`to process data received through the
`programmable interface from the at
`least one monitored technical device
`in response to programming
`instructions received in an incoming
`wireless packet switched data
`message.
`
`The AR Series modules support the AirVantage
`ReadyAgent which is used to communicate with
`the AirVantage Platform. The functionality for
`the AirVantage ReadyAgent resides in the
`firmware of each AR Series module. The
`AirVantage ReadyAgent contains a Monitoring
`Engine which can process data received from an
`at least one monitored technical device to
`determine whether a trigger has occurred and
`then execute a customizable action such as send
`events or data to the AirVantage platform based
`on that trigger.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`The AirVantage ReadyAgent contains a list of
`internal variables that are used to configure the
`Monitoring Engine and AirVantage ReadyAgent.
`The AirVantage Platform can send remote
`programming instructions contained in AWT-
`DA protocol messages wirelessly to the AR
`Series module over a TCP connection which will
`cause the AirVantage ReadyAgent to alter the
`values of these internal variables, meaning that
`the Monitoring Engine may be configured to
`process data received through the programmable
`interface from the at least one monitored
`technical device in response to programming
`instructions received in an incoming wireless
`packet switched data message.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`AR Series modules have multiple General
`Purpose I/O (“GPIO”) pin interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain GPIO
`interfaces are generally capable of monitoring
`digital inputs and generating a URC when a state
`transition occurs. They can apply a processing
`filter with programmable timing constraints to
`the inputs to determine when a valid state change
`has occurred and eliminate false triggering. The
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 10
`
`

`
`Claim Element
`
`Infringement Support
`
`inputs are typically configured using the
`AT+WIPC command.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 115-117)
`
`AR Series modules have 2 analog interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain analog
`interfaces are generally capable of receiving data
`from analog inputs using the AT+ADC
`command. They can process that data and report
`the values as either a digital value corresponding
`to the ADC result register value or as a voltage
`value scaled in millivolts.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 118-120)
`
`The AirVantage Platform is able to send wireless
`AT commands remotely to the AR Series
`module over a TCP connection which are
`executed by the module and the responses are
`sent back to the AirVantage Platform. Therefore,
`AT commands identified above for configuring
`the processing of data can be run remotely,
`meaning that the AR Series modules are able to
`directly process and execute these programming
`commands when received in incoming wireless
`packet switched data messages.
`(AT Commands Over AirVantage Management
`Services Application Note, p. 1)
`
`In sum, the Monitoring Engine can be configured
`to process data received through the
`programmable GPIO and/or ADC interfaces
`from the at least one monitored technical device
`in response to programming instructions
`received in an incoming wireless packet
`switched data message.
`
`
`Smart Automation Ready Agent
`
`
`The AR Series modules also support the
`AirVantage Smart Automation Ready Agent
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 11
`
`

`
`Claim Element
`
`Infringement Support
`
`which is a software module that resides in the
`embedded module and is used by the AirVantage
`Platform to remotely monitor, configure, and
`control monitored technical devices such as
`sensors and programmable logic controllers
`(PLCs). The Smart Automation Ready Agent
`contains a business logic engine that can filter
`data from monitored technical devices, create
`alarm thresholds and otherwise process and
`manipulate data before it is sent to the remote
`server.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2-3)
`
`AR Series modules have multiple General
`Purpose I/O (“GPIO”) pin interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain GPIO
`interfaces are generally capable of monitoring
`digital inputs and generating a URC when a state
`transition occurs. They can apply a processing
`filter with programmable timing constraints to
`the inputs to determine when a valid state change
`has occurred and eliminate false triggering. The
`inputs are typically configured using the
`AT+WIPC command.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 115-117)
`
`AR Series modules have 2 analog interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain analog
`interfaces are generally capable of receiving data
`from analog inputs using the AT+ADC
`command. They can process that data and report
`the values as either a digital value corresponding
`to the ADC result register value or as a voltage
`value scaled in millivolts.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 118-120)
`
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 12
`
`

`
`Claim Element
`
`Infringement Support
`
`The Smart Automation Ready Agent may be
`configured remotely by the AirVantage platform
`over the cellular packet switched data network
`which means that the Smart Automation Ready
`Agent may be configured to process data
`received through the programmable interface
`from the at least one monitored technical device
`in response to programming instructions
`received in an incoming wireless packet
`switched data message.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 4)
`
`In sum, the business logic engine of the Smart
`Automation Ready Agent can be configured to
`process data received through the programmable
`GPIO and/or ADC interfaces from the at least
`one monitored technical device in response to
`programming instructions received in an
`incoming wireless packet switched data message.
`
`
`Ready Agent
`
`
`The AR Series modules support the AirVantage
`ReadyAgent which is used to communicate with
`the AirVantage Platform. The functionality for
`the AirVantage ReadyAgent resides in the
`firmware of each AR Series module. The
`AirVantage ReadyAgent contains a Monitoring
`Engine which can process data received from an
`at least one monitored technical device to
`determine whether a trigger has occurred and
`then execute a customizable action such as send
`events or data to the AirVantage platform based
`on that trigger.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`The AirVantage ReadyAgent contains a list of
`internal variables that are used to configure the
`Monitoring Engine and AirVantage ReadyAgent.
`The AirVantage Platform can send remote
`programming instructions contained in AWT-
`DA protocol messages wirelessly to the AR
`Series module over a TCP connection which will
`
`2.
`
`A programmable communicator
`device according to claim 1, wherein
`the processing module is configured
`to process data received through the
`programmable interface from the at
`least one monitored technical device
`in response to programming
`instructions received in an incoming
`wireless packet switched data
`message.
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 13
`
`

`
`Claim Element
`
`Infringement Support
`
`cause the AirVantage ReadyAgent to alter the
`values of these internal variables, meaning that
`the Monitoring Engine may be configured to
`process data received through the programmable
`interface from the at least one monitored
`technical device in response to programming
`instructions received in an incoming wireless
`packet switched data message.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`AR Series modules have multiple General
`Purpose I/O (“GPIO”) pin interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain GPIO
`interfaces are generally capable of monitoring
`digital inputs and generating a URC when a state
`transition occurs. They can apply a processing
`filter with programmable timing constraints to
`the inputs to determine when a valid state change
`has occurred and eliminate false triggering. The
`inputs are typically configured using the
`AT+WIPC command.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 115-117)
`
`AR Series modules have 2 analog interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain analog
`interfaces are generally capable of receiving data
`from analog inputs using the AT+ADC
`command. They can process that data and report
`the values as either a digital value corresponding
`to the ADC result register value or as a voltage
`value scaled in millivolts.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 118-120)
`
`The AirVantage Platform is able to send wireless
`AT commands remotely to the AR Series
`module over a TCP connection which are
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 14
`
`

`
`Claim Element
`
`Infringement Support
`
`executed by the module and the responses are
`sent back to the AirVantage Platform. Therefore,
`AT commands identified above for configuring
`the processing of data can be run remotely,
`meaning that the AR Series modules are able to
`directly process and execute these programming
`commands when received in incoming wireless
`packet switched data messages.
`(AT Commands Over AirVantage Management
`Services Application Note, p. 1)
`
`In sum, the Monitoring Engine can be configured
`to process data received through the
`programmable GPIO and/or ADC interfaces
`from the at least one monitored technical device
`in response to programming instructions
`received in an incoming wireless packet
`switched data message.
`
`
`Smart Automation Ready Agent
`
`
`The AR Series modules also support the
`AirVantage Smart Automation Ready Agent
`which is a software module that resides in the
`embedded module and is used by the AirVantage
`Platform to remotely monitor, configure, and
`control monitored technical devices such as
`sensors and programmable logic controllers
`(PLCs). The Smart Automation Ready Agent
`contains a business logic engine that can filter
`data from monitored technical devices, create
`alarm thresholds and otherwise process and
`manipulate data before it is sent to the remote
`server.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2-3)
`
`AR Series modules have multiple General
`Purpose I/O (“GPIO”) pin interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain GPIO
`interfaces are generally capable of monitoring
`digital inputs and generating a URC when a state
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 15
`
`

`
`Claim Element
`
`Infringement Support
`
`transition occurs. They can apply a processing
`filter with programmable timing constraints to
`the inputs to determine when a valid state change
`has occurred and eliminate false triggering. The
`inputs are typically configured using the
`AT+WIPC command.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 115-117)
`
`AR Series modules have 2 analog interfaces.
`(Sierra_Wireless_AirPrime_AR_Series_
`Automotive_Wireless_Modules.pdf, p. 2)
`
`Sierra Wireless modules which contain analog
`interfaces are generally capable of receiving data
`from analog inputs using the AT+ADC
`command. They can process that data and report
`the values as either a digital value corresponding
`to the ADC result register value or as a voltage
`value scaled in millivolts.
`(AT Commands Interface Guide for Firmware
`7.45, Rev. 019, Vol. 4 pp. 118-120)
`
`The Smart Automation Ready Agent may be
`configured remotely by the AirVantage platform
`over the cellular packet switched data network
`which means that the Smart Automation Ready
`Agent may be configured to process data
`received through the programmable interface
`from the at least one monitored technical device
`in response to programming instructions
`received in an incoming wireless packet
`switched data message.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 4)
`
`In sum, the business logic engine of the Smart
`Automation Ready Agent can be configured to
`process data received through the programmable
`GPIO and/or ADC interfaces from the at least
`one monitored technical device in response to
`programming instructions received in an
`incoming wireless packet switched data message.
`
`Each AR Series module stores in an on-board
`
`3.
`
`A programmable communicator
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 16
`
`

`
`Claim Element
`
`Infringement Support
`
`5.
`
`device according to claim 1, wherein
`the programmable communicator
`device comprises the identity
`module.
`
`A programmable communicator
`device according to claim 1 further
`configured to request that an at least
`one monitored technical device send
`data through the programmable
`interface for processing by the
`programmable communicator device
`in response to programming
`instructions received in an incoming
`wireless packet switched data
`message.
`
`memory module a unique identifier in the form
`of an International Mobile Equipment
`Identification (“IMEI”) number.
`(AT Commands Interface Guide For Firmware
`7.45, Rev. 019, Vol. 1, pp. 35-36)
`
`
`Smart Automation Ready Agent
`
`
`The AR Series modules support the AirVantage
`Smart Automation Ready Agent which is a
`software module that resides in the embedded
`module and is used by the AirVantage Platform
`to remotely monitor, configure, and control
`monitored technical devices such as sensors and
`programmable logic controllers (PLCs). The
`Smart Automation Ready Agent contains a
`business logic engine that can filter data from
`monitored technical devices, create alarm
`thresholds and otherwise process and manipulate
`data before it is sent to the remote server.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2-3)
`
`The Smart Automation Ready Agent can receive
`wireless programming instructions over the
`cellular packet switched data network from the
`AirVantage platform which cause the module to
`update the business logic engine configuration.
`Therefore, the Smart Automation Ready Agent
`may be configured through programming
`instructions received in incoming wireless packet
`switched data messages to transmit the processed
`data to an at least one monitoring device.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2)
`
`The Smart Automation Ready Agent can include
`Modbus registers within the business logic
`engine. Modbus registers are memory locations
`within the monitored technical device which
`contain the values of process variables or other
`internal variables. To obtain the value of a
`Modbus register from the monitored technical
`device, the Smart Automation Ready Agent must
`send a “Read Input Register” command or
`
`Sierra Wireless America, Inc., Sierra Wireless, Inc., and RPX Corp. Exh. 1017 p. 17
`
`

`
`Claim Element
`
`Infringement Support
`
`similar data monitoring request to the monitored
`technical device which will execute the
`command and send the response back to the
`Ready Agent. At that time, the Ready Agent
`must process the data received from the
`monitored technical device to extract the
`Modbus register value which can then be
`processed to determine if an alarm threshold has
`been reached.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2)
`
`The Smart Automation Ready Agent can receive
`wireless programming instructions over the
`cellular packet switched data network from the
`AirVantage platform which cause the module to
`update the business logic engine configuration.
`Therefore, the Smart Automation Ready Agent
`may be configured through programming
`instructions received in incoming wireless packet
`switched data messages to transmit the processed
`data to an at least one monitoring device.
`(Sierra Wireless AirVantage Smart Automation
`Industrial Control Connectivity, p. 2)
`
`In sum, the Smart Automation Ready Agent
`within the AR Series module may be configured
`to request that an at least one monitored
`technical device send data through the
`programmable interface for processing by the
`programmable communicator device in response
`to programming instructions received in an
`incoming wireless packet switched data message.
`
`
`Ready Agent
`
`
`The AR Series modules support the AirVantage
`ReadyAge