UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`TELIT WIRELESS SOLUTIONS INC. &
`
`TELIT COMMUNICATIONS PLC,
`
`Petitioner,
`
`v.
`
`M2M SOLUTIONS LLC,
`
`Patent Owner.
`
`________________
`
`Inter Partes Review No. 2016-01081
`
`U.S. Patent No. 8,648,717
`
`Issued: Feb. 11, 2014
`
`Title: Programmable Communicator
`
`________________
`
`DECLARATION OF KIMMO SAVOLAINEN FOR INTER
`PARTES REVIEW OF U.S. PATENT NO. 8,648,717
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.1
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`TABLE OF CONTENTS
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`Page
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`I. INTRODUCTION……………………………………………………………..1
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`A. Engagement .............................................................................................. 1
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`B. Background And Qualifications ............................................................ 1
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`C. Compensation and Prior Testimony ...................................................... 5
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`D.
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`Information Considered .......................................................................... 6
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`II. LEGAL STANDARDS FOR PATENTABILITY ........................................ 7
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`III. THE ‘717 PATENT ....................................................................................... 10
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`A. Overview Of The ‘717 Patent ............................................................... 10
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`B.
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`Independent Claims of The ‘717 Patent .............................................. 14
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`IV. BACKGROUND RELEVANT TO THE ’717 PATENT ........................... 16
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`A. Field of the Claimed Subject Matter ................................................... 16
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`B. Person of Ordinary Skill In The Art ................................................... 17
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`C. Routine Knowledge ............................................................................... 18
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`V. CLAIM CONSTRUCTION .......................................................................... 29
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`A. “programmable” .................................................................................... 29
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`B. “interface” .............................................................................................. 30
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`C. “monitored technical device” ............................................................... 30
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`D. “monitoring device” .............................................................................. 31
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`E. “processing module” ............................................................................. 31
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`F. “coded number” ..................................................................................... 31
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.2
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`G. “the transmissions including the at least one telephone number or IP
`address and the coded number”........................................................... 32
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`H. “numbers to which the programmable communicator device is
`configured to and permitted to send outgoing wireless
`transmissions” ........................................................................................ 32
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`VI. EFFECTIVE FILING DATE OF THE ’717 PATENT ............................. 35
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`VII. PATENTABILITY ANALYSIS OF THE ‘717 PATENT ......................... 40
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`A. Ground 1: Claims 25-28 and 30 Would Have Been Obvious Over Van
`Bergen In View Of Bettstetter…………………………………...49
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`1. Claim 25 Would Have Been Obvious Over Van Bergen In View
`of Bettstetter ................................................................................... 57
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`2. Claim 26 Would Have Been Obvious Over Van Bergen In View
`Of Bettstetter ................................................................................. 61
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`3. Claim 27 Would Have Been Obvious Over Van Bergen In View
`Of Bettstetter ................................................................................. 62
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`4. Claim 28 Would Have Been Obvious Over Van Bergen In View
`Of Bettstetter ................................................................................. 63
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`5. Claim 30 Would Have Been Obvious Over Van Bergen In View
`Of Bettstetter ................................................................................. 63
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`VIII. CONCLUSION ............................................................................................ 68
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`
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`APPENDICES:
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`A. Curriculum Vitae of Kimmo Savolainen
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`B. List of Materials Considered
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`ii
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.3
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`I.
`
`INTRODUCTION
`A. Engagement
`1.
`I have been retained by Petitioners, Telit Wireless Solutions Inc. and
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`Telit Communications PLC (collectively “Telit”) to act as an expert in connection
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`with the accompanying Petition and Petitions in IPR2016-00054 and IPR2016-
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`00055 for Inter Partes Review of U.S. Patent 8,648,717 (Ex. 1201, “the ‘717
`
`Patent”), and in connection with the litigation related to a parent patent, U.S. Patent
`
`No. 8,094,010 (“the ‘010 Patent”).
`
`B.
`2.
`
`Background And Qualifications
`
`I am qualified by education and experience to testify as an expert in
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`the field of telecommunications and more specifically in its application to
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`telemetry systems. My background is outlined in my curriculum vitae, attached as
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`Appendix A, and discussed as follows.
`
`3.
`
`From 1985 – 1990 I attended the Raahe Institute of Computer
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`Technology, Raahe, Finland where I earned a Bachelor of Science degree, with a
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`major in electrical engineering, focused on embedded environments, and a minor
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`in programming in embedded environments. From 1991 - 1996 I attended the
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`University of Oulu, Finland where I earned a Master of Science degree in
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`Computer Science. At
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`that
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`time, Oulu, Finland was a center
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`for
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`telecommunications development and a research and development hub for many of
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`the world’s leading telecom companies, including Nokia and Ericsson.
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`
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`1
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`4.
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`From November 1994 to May 2006, I was employed by Nokia. From
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`
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`1994-1998, I served as Product Program Manager at Nokia’s Oulu, Finland
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`facility. In that capacity, I successfully managed at times up to four simultaneous
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`product programs in M2M (machine-to-machine) terminal product creation and
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`related server software product creation. I also managed at times up to 100 people
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`in three R&D sites. During this period of time, I was involved in and supervised
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`the development of Nokia’s wireless payphone and payphone management system,
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`including: writing “C” code for the project; designing electrical circuitry; writing
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`technical specifications; and writing protocol specifications for the wireless
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`transaction protocol (WTP).
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`5.
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`From 1994-1998, I served as an R&D Line Manager (Nokia
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`Elektrobit Products (NEP), Oulu), Project Manager (NEP, Oulu, Finland)
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`(including managing GSM type approval testing and certification processes, and
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`was an inventor on several patent applications and patents), Software Chief
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`Designer (NEP, Oulu, Finland), and Hardware Designer (NEP, Oulu, Finland).
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`6.
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`From 1998-2002, I was involved in the development of Nokia’s M2M
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`connectivity terminal, the Nokia 20, and the M2M gateway (Ex. 1221). The Nokia
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`20 provided M2M communication for remote management for applications, such
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`as, vending, security, automatic meter reading, elevator control, telematics, etc.
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`2
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.5
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`Declaration of Kimmo Savolainen in Inter
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`(Id.). The Nokia 20 communicated wirelessly by sending/receiving SMS messages
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`over EGSM 900/1800 networks (Id.), and used PIN authentication as well as GSM
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`security (Id.). In connection with this project, I led the design team, wrote technical
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`and protocol specifications, and communicated customer requirements to the
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`design team.
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`7.
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`Also while at Nokia, I served as Business Development Manager at
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`Nokia’s Oulu, Finland facility. In that capacity, I conducted an extensive market
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`study of the M2M market around the world, interviewing over 100 systems
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`integrators and vendors working on this market. I also translated market
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`requirements to product requirements and wrote product specifications to allow
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`Nokia to enter the market.
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`8.
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`From 2003-2004, I served as General Manager for Nokia’s M2M
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`business worldwide. In this capacity, I had global responsibility of the M2M
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`business area in Nokia, including product development. I was nominated as one of
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`the ten pioneers of the M2M industry by M2M Magazine in July 2004. Ex. 1222.
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`9.
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`During this timeframe, I served as Program Manager in Nokia’s
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`Dallas, Texas facility. In that role, I developed sales channels and collaboration
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`networks with various companies working in the M2M business, including system
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`integrators, hardware and software vendors, distributors, consultants, and install
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`3
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`companies. I also involved the GSM carriers in the M2M business, managed the
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`collaborator network and worked together with Nokia offices in Latin America to
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`create the M2M market.
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`10.
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`I also managed the successful transfer of Nokia’s M2M business area
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`and products to Aplicom Ltd in 2004.
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`11. From 2004-2005, I served as Senior Business Manager (Oulu) for
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`Spain, France, Portugal and Benelux, for the Nokia 770 Internet Tablet. In this
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`capacity, I was responsible for developing retail sales channels, cooperating with
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`Telecom companies and partnering with ISPs.
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`12. After my time at Nokia, from May 2006 to January 2008, I served as
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`Director of Business Development for Elektrobit,
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`in Oulu, Finland and
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`Washington, DC/Seattle, Washington, where I was responsible for overall project
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`management. Elektrobit is a research and development company. While at
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`Elektrobit, I oversaw a project for TerraStar Networks, in Reston, Virginia, for
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`developing a handset capable of satellite communication as well as LTE
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`communication.
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`13. Since January 2008, I have been employed by Anite Plc., where I
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`serve as Vice President of Engineering. I previously was Vice President for Sales
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`Support and Product Management in Anite’s Oulu, Finland facility. I also served
`
`4
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`Declaration of Kimmo Savolainen in Inter
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`as Vice President of Technical Support and Sales Support in Anite’s Forest,
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`Virginia facility. Anite manufactures test tools for wireless carriers such as AT&T
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`and T-Mobile. I am responsible for, among things, global engineering activities,
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`and process development.
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`14.
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`I am a named inventor or co-inventor on the following patents and
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`patent applications:
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` U.S. Patent No. 6,108,531, entitled “Terminal equipment providing
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`payment data in a cellular radio system”;
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` U.S. Patent No. 6,327,466, entitled “Method and arrangement for
`
`setting the charge rate in a wireless pay phone”;
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` International Patent Publication No. WO 99/57875, entitled
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`“Method of Updating Terminal Software in a Telephone System”;
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` International Patent Publication No. WO 99/20070, entitled
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`“Method of Installing a Terminal, and a Wireless Telephone
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`System”; and
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` International Patent Publication No. WO 96/42175, entitled
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`“Method and Terminal Equipment for Transmitting Information
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`Not Relating To A Call”.
`
`C. Compensation and Prior Testimony
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`5
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`Declaration of Kimmo Savolainen in Inter
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`15.
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`I am being compensated at an hourly rate of $200/hour. My
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`
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`compensation is not contingent on the outcome of this case or the testimony I
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`provide, and the opinions provided here are my own.
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`16.
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`I was deposed for the first time in a related litigation concerning the
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`‘010 Patent. I have never testified in court.
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`D.
`Information Considered
`17. My opinions are based on my years of education, research, and
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`experience, as well as my investigation and study of relevant materials. In forming
`
`my opinions, I have considered the materials listed in Appendix B to this
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`Declaration. I have been informed that the Exhibit numbers I use in this
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`Declaration are the same as those being filed with the Petition this Declaration
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`supports.
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`18. My analysis of the materials produced in this investigation is ongoing
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`and I will continue to review any new material as it becomes relevant to this case.
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`19.
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`I reserve the right to supplement and/or amend the opinions expressed
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`herein in response to positions taken by Patent Owner or experts retained on Patent
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`Owner’s behalf. To amplify what is stated herein, where necessary, and especially
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`in view of information not presently known to me or new information presented by
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`Patent Owner’s experts prior to, or during trial for Inter Partes Review in this
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`6
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`matter, I reserve the right to supplement and/or amend this report should additional
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`information be brought to my attention during the course of this proceeding.
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`II. LEGAL STANDARDS FOR PATENTABILITY
`20.
`I have been informed of the general legal principles for determining
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`whether the claims of a patent are patentable over the prior art.
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`21.
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` I understand that for an invention claimed in a patent to be found
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`patentable, it must be, among other things, new and not obvious in light of what
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`came before it, i.e., “prior art.”
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`22.
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`I understand that in this context the burden is on the party asserting
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`unpatentability to prove it by a preponderance of the evidence. I understand that "a
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`preponderance of the evidence" is evidence sufficient to show that a fact is more
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`likely than not. I understand that to institute an Inter Partes Review, the Petitioner
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`must establish a reasonable likelihood of prevailing in challenging the patentability
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`of at least one of the challenged claims.
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`23.
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`I understand that in this proceeding, the claims must be given their
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`broadest reasonable interpretation consistent with the specification. The broadest
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`reasonable interpretation may be different than the interpretation in the Court’s
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`claim construction in the ‘010 Patent litigation, and interpretations I suggested in
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`that proceeding. I understand that statements made characterizing the claims during
`
`7
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.10
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`Declaration of Kimmo Savolainen in Inter
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`the prosecution of the patent may limit the interpretation of the claims. I also
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`understand that the claims after being construed in this manner are then to be
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`compared to the prior art.
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`24.
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`I have considered the claim interpretations construed by the District
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`Court in the ‘010 Patent litigation Exs. 1219 and 1211 and the claim interpretations
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`proposed by both parties in the ‘717 Patent litigation Ex. 1212.
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`25.
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`I understand that the meaning of claim terms and whether or not the
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`claims are the same as the prior art must be considered from the point of view of a
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`person of ordinary skill in the art at the time of the patent’s earliest priority date.
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`26.
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`I understand that to be entitled to the priority date of an earlier
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`application, the earlier application must provide adequate written description to
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`convey to a person of ordinary skill in the art that the inventor had possession of
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`the claimed invention.
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`27.
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`I have been informed that a patent claim is invalid as anticipated if the
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`claim “reads on” a single prior art reference; that is, each claim limitation is
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`disclosed expressly or inherently in a single prior art reference. I understand that it
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`is acceptable to examine evidence outside the prior art reference (extrinsic
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`evidence) in determining whether a feature, while not expressly discussed in the
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`reference, is necessarily present within that reference.
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`8
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`Declaration of Kimmo Savolainen in Inter
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`28.
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`I have further been informed that in the event the claim does not “read
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`
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`on” a prior art reference precisely, the claim may nevertheless be invalid for
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`obviousness. A patent claim is invalid for obviousness if the subject matter of the
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`claim as a whole would have been obvious at the time of the patent’s earliest
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`priority date to a person having ordinary skill in the art to which the subject matter
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`pertains.
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`29.
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`I understand that the following factors should be considered in
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`determining whether or not a claim would have been obvious: the level of ordinary
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`skill in the art; the scope and content of the prior art; the differences between the
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`prior art and the claims at issue; and whatever secondary considerations may be
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`present.
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`30.
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`I understand that to the extent that there are any differences between
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`the prior art and the claimed subject matter, the claims would have been obvious
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`where a person of ordinary skill in the art would have modified or combined the
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`prior art references to arrive at the claimed subject matter. I understand that
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`routine design choices and other market forces can prompt modifications of
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`technology.
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`31.
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`I have considered each of the claims identified below as a whole, and
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`am unaware of any long-felt but unsolved needs, failure of others, unexpected
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`9
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`results, or commercial success relating to the asserted claims. The prior art
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`references discussed below had functionality identical to most of the asserted
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`claims, and any differences were trivial modifications, such as, the use of pre-
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`existing technology like GPS (Global Positioning System), GPRS (General Packet
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`Radio Service) or other packet switched communication, and using known local
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`devices (e.g., vending machines and alarms). I have seen evidence that others
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`developed the subject matter of at least some of the claims (see e.g., Ex. 1223), and
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`any differences between that evidence and other claims were trivial modifications
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`well within the ability of one of ordinary skill in the art at the time of the earliest
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`priority date of the ‘717 Patent, such as, updating the communication protocol, or
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`substituting one local device for another (e.g., substituting a battery sensor for a
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`door sensor). Based on the references discussed below and general knowledge in
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`the field, I also see no evidence of unexpected results of any of the claimed subject
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`matter. If Patent Owner points to any secondary considerations to support the
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`claims, I may provide a response.
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`III. THE ‘717 PATENT
`A. Overview Of The ‘717 Patent
`32.
`In my opinion, a person of ordinary skill in the art would have
`
`understood the ‘717 Patent to describe a “programmable communicator device,”
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`Partes Reviiew of U.SS. Patent NNo. 8,648,7
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`m a “monits data frommodem thhat collects
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`
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`tored technnical
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`
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`which iis at base aa wireless
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`device” (e.g., a ssensor) annd relays
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`the data tto a “monnitoring deevice” (e.gg., a
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`computer or mobiile phone tthat can reemotely moonitor the
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`
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`data). Ex.
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`1201 at 2
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`:1-8,
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`6:4-12,
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`
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`7:65-8:7,, 9:2-6, eemphasis
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`
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`added byy me herre and thhroughout
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`this
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`Declaraation unlesss otherwiise indicatted. Beloww is an iillustrationn I providde to
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`visualizze the elemments of thee system foor clarity:
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`33. The mmonitoredd technical
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`a “piece
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`of techniccal equipmment”
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`device is
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`(see e.g
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`g. Ex. 12011 at 2:1-8)
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`relaying “
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`“‘data’ of aany type”.
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` Ex. 12277, 49. The
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`‘717
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`Patent
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`specification is not
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`applicatioon-specific
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`and provvides manyy examplees of
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` includingcal devicesmonitorred technic
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`home applvending mmachines, h
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`iances, dooor or
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`windoww sensors,
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`pressure
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`nsors, posy level senrs, batterysensors, hheat sensor
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`ition
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`detectorrs, health mmonitoringg systems,
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`etc. See ee.g. Ex. 12001, 2:1-8,
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`3:52-61, 44:60-
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`municator able commprogramma66, 5:55-25, 6:27--29, 6:45--53, 7:47-50. The p
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`and
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`11
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.14
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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
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`monitored technical device may be “separate” or “integrated” into one device, Id.
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`at 12:19-24.
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`34. The programmable communicator
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`is connected
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`locally
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`to
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`the
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`monitored technical device (e.g., a sensor in a vending machine) via a
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`“programmable interface.” Id. at 6:4-7, 9:2-6, 10:1-4.
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` The ‘717 Patent
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`specification does not provide detail about the nature of the “programmable
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`interface”, but Patent Owner has stated that it is a wired serial interface or general-
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`purpose input/output (I/O) interface. Ex. 1203 at 2 ¶¶3-4.
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`35. The programmable communicator is also wirelessly programmable by
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`a “programming transmitter,” which may be the monitoring device Ex. 1201, 4:13-
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`17.
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` The programmable communicator communicates wirelessly with the
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`monitoring device and programming transmitter (e.g., a computer) over various
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`wireless networks that were well-known to a person of ordinary skill in the art at
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`the time of the earliest priority date, including short message service (SMS) (e.g.,
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`text), or wireless packet-switched data messages such as GPRS (e.g., IP-based). Id.
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`at 4:18-23, 9:26-32. Wireless packet-switched networks at the time of the earliest
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`priority date included CDPD (Cellular Digital Packet Data) (a packet switched
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`network available in the U.S.) and GPRS (General Packet Radio Service). See e.g.,
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`Ex. 1209, 2(left): 24-27; Ex. 1224, abstract, 4(right-col):19-20. The programmable
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`12
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.15
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`communnicator waas not prottocol-speciific, but wwas genericcally desiggned to “mmake
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`use of aany telephoone technollogy.” Ex. 1201, 12:88-16; see aalso Ex. 12216, 44:2-44.
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`36. A peerson of orrdinary skiill in the aart would hhave underrstood tha
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`t the
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`programmming trannsmitter caan remotelyy edit a lisst of outgooing numbeers of “linkked”
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`monitorring devicees that receeive monittored data.
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` Ex. 1201
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`, 8:53-56,
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`9:22-25, 99:35-
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`38. A pperson of
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`ordinary sskill in thee art wouldd have undderstood thhat, in ordeer to
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`providee security,
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`these proggramming
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`transmissiions includde a “codeed numberr” to
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`authentiicate the iincoming
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`mber tgoing numand an outmissions aprogrammming transm
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`(telephoone numbeer or IP aaddress) too add to mmemory. Idd. at 10:122-37, nummbers
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`circled bby me beloow:
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`AA person
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`n the art of ordinarry skill in
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`would haave undersstood thatt the
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`programmmable coommunicator authentticates the
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`transmisssion basedd on the cooded
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`numberr in the traansmission, for exammple, by coomparing tthe coded
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`number inn the
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`h as a communiccator such
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`nlocking kePUK (ppersonal un
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`ey) code. Idd. at 9:35-660, 10:5-3
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`7.
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`13
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.16
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`

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`
`
`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
`
`
`B.
`Independent Claims of The ‘717 Patent
`37. Claim 1 recites a programmable communicator device comprising:
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`[a] a programmable interface for establishing a communication link
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`with at least one monitored technical device,
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`[b] wherein the programmable interface is programmable by wireless
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`packet switched data messages; and
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`[c] a processing module for authenticating one or more wireless
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`transmissions sent from a programming transmitter and received
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`by the programmable communicator device by determining if at
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`least one transmission contains a coded number;
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`[d] wherein the programmable communicator device is configured to
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`use a memory to store at least one telephone number or IP address
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`included within at least one of the transmissions as one or more
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`stored telephone numbers or IP addresses if the processing module
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`authenticates the at least one of the transmissions including the at
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`least one telephone number or IP address and the coded number by
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`determining that the at least one of the transmissions includes the
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`coded number,
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`14
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.17
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`

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`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
`
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`[e] the one or more stored telephone numbers or IP addresses being
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`numbers to which the programmable communicator device is
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`configured
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`to and permitted
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`to send outgoing wireless
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`transmissions;
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`[f] wherein the programmable communicator device is configured to
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`use an identity module for storing a unique identifier that is unique
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`to the programmable communicator device; and
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`[g] wherein the one or more wireless transmissions from the
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`programming transmitter comprises a General Packet Radio
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`Service (GPRS) or other wireless packet switched data message;
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`and
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`[h] wherein the programmable communicator device is configured to
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`process data received through the programmable interface from the
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`at
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`least one monitored
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`technical device
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`in
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`response
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`to
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`programming instructions received in an incoming wireless packet
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`switched data message.
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`38. Claim 29 is identical to claim 1, with the modification that it replaces
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`packet-switched communication with SMS communication in claim element [g].
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`15
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.18
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`

`
`
`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
`
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`39. Claim 24 is broader than both claims 1 and 29, allowing any type of
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`wireless communication, omitting claim elements [b] and [g], and omitting in
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`claim element [h] that processing occurs “in response to programming instructions
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`…”
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`IV. BACKGROUND RELEVANT TO THE ’717 PATENT
`A.
`Field of the Claimed Subject Matter
`40.
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`In the late 1990’s, many of the world’s major companies in the field
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`of telecommunications had specialty sub-divisions dedicated to remote monitoring
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`or telemetry (meaning remote = tele, measuring = metry): Petitioner Telit had
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`Telital Automotive, Motorola had SCADA (supervisory control and data
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`acquisition), Siemens had Siemens Wireless Modules, Sierra Wireless had the
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`DART product line, Nokia had the Nokia M2M division (which I managed), and
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`so on. People of ordinary skill in the art that developed programmable
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`communicators at the time of the ‘717 Patent’s earliest priority date generally
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`worked in the field of telecommunications for telecom companies like these, some
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`of which focused on voice communication devices like cellular phones and others
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`which focused on telemetry products in these specialty subdivisions. (E.g., Patent
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`Owner’s expert, in the ‘010 Patent litigation, Ray Nettleton, characterized himself
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`as an expert in the “wireless telecommunications field.”)
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`16
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.19
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`

`
`
`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
`
`
`Person of Ordinary Skill In The Art
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`In determining the qualifications of a person of ordinary skill in the
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`B.
`41.
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`art, I first considered the general subject matter of the ‘717 Patent, including its
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`claims, and the literature available prior to the earliest priority date.
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`42. Based on my experience, including working with my colleagues at
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`Nokia, in my opinion, a person of ordinary skill in the art before the priority date
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`would have had at least a bachelor’s degree in computer science, or electrical
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`engineering, with
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`a good understanding of principles of wireless
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`telecommunications
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`including
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`the GSM
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`(Global System
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`for Mobile
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`Communications) standards, and would have had at least four years of experience
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`in designing and/or programming wireless communications systems utilizing GSM
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`or other cellular networks. The discussion in this Declaration applies equally to the
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`Board’s interpretation that a person of ordinary skill in the art would have been at
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`least an undergraduate degree in electrical engineering and three years of
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`experience working the development of wireless subscriber terminal systems or
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`components, or an equivalent combination of education and experience in related
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`fields. Ex. 1207 at 23, footnote.
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`17
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.20
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` DP
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`Declarationn of Kimmoo Savolainnen in Interr
`
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`Partes Reviiew of U.SS. Patent NNo. 8,648,7
`17
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`C. Routtine Knowwledge
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`43. A person of orddinary skilll in the arrt at the timme of the eearliest prio
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`C 4
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`date woould have
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`understoood that teleecommuniccations prooducts couuld be useed to
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`monitorr telemetryy products iin many diifferent appplications
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`and using
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`many diffeerent
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`communnication prrotocols:
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`444. Appllications:
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`Telemetryy divisionss in telecoom compaanies gene
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`developped telemeetry produucts that wwere not aapplicationn-specific,
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`adaptedd for use
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`in a widde range
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`of monitooring appplications.
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`Petitionner’s Telittal Autommotive divvision devveloped prroducts too monitor
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`rally
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`but couldd be
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`For exammple,
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`followinng range of applicatioons, Ex. 12230 p. 11:
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`18
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.21
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` DP
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`Declarationn of Kimmoo Savolainnen in Interr
`
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`Partes Reviiew of U.SS. Patent NNo. 8,648,7
`17
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`445. See aalso Ex. 1
`224 p. 3,
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`showing
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`an overvieew of somme of the mmost
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`commonn telemetrry applicattions moniitored overr telecommmunicationns networkks in
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`the late 1990’s:
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`446. The ttype of moonitored loocal devicee is entirelly applicatiion dependdent.
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`A persoon of ordinnary skill inn the art whho wantedd to build aa device at
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`the time o
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`f the
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`earliest
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`priority
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`date of thhe ‘717 PPatent thatt remotelyy monitorred a wasshing
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`machinee, a vendinng machinee, or a vehhicle, woulld naturallyy have loo
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`ked to connnect
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`those devices, whhich was aa matter off routine eengineeringg. At my ttime at Nookia,
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`19
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`Telit Wireless Solutions Inc. and Telit Communications PLC Exh. 1202 p.22
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`

`
`
`Declaration of Kimmo Savolainen in Inter
`Partes Review of U.S. Patent No. 8,648,717
`
`
`
`beginning in 1999, I oversaw the development of a wireless telemetry device for
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`monitoring an elevator, in which Kone (a Finnish elevator manufacturer) used the
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`Nokia 20, a wireless machine-to-machine module, to build a wirelessly controlled
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`elevator system to report alarms, request maintenance, remotely control machines,
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`and provide emergency telephone communication for trapped passengers, Ex.
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`1221. The integration of the elevator system, sensors and alarms with the Nokia 20
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`wireless communicator was a matter of routine engineering. The integration was
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`developed by a team of members from both Nokia and Kone and involved building
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`multiple prototypes including designing the products, programming software,
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`purchasing components, assembling the devices, and running tria