Kimmo Savolainen
`
`New York, NY
`
`July 7, 2016
`
`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TELIT WIRELESS SOLUTIONS INC.
`
` and
`
` TELIT COMMUNICATIONS PLC,
`
` Petitioner
`
` v.
`
` M2M SOLUTIONS LLC
`
` Patent Owner
`
` Case IPR2016-00055
`
` Patent 8,648,717 B2
`
` DEPOSITION of KIMMO SAVOLAINEN, an
`
`expert witness on behalf of Petitioners, held at
`
`the Law Office of Pearl Cohen Zedek Latzer
`
`Baratz, 1500 Broadway, 12th Floor, New York, New
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`York, on July 7, 2016, commencing at 9:27 a.m.,
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`and before Helene Gruber, CSR, a Notary Public of
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`the State of New York.
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 1
`
`

`
`Kimmo Savolainen
`
`New York, NY
`
`Page 2
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`July 7, 2016
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`Page 4
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` KIMMO SAVOLAINEN,
`Having first been duly sworn, testified as
`follows:
` EXAMINATION
`BY MR. HENSCHKE:
` Q. Would you please state your full name
`and residential address for the record.
` A. Kimmo Olavi Savolainen,
`Muottaajanpiha #10, Kempele, Finland 90450.
` MR. HENSCHKE: As an initial
` housekeeping matter, I would like to mark and
` introduce as Savolainen Exhibit 1 the Patent
` Owner's Notice of Deposition of Kimmo
` Savolainen that has brought us here today.
` (Patent Owner's Notice of Deposition
` marked Savolainen Exhibit 1.)
` Q. Let me show you a document that has
`been marked as Exhibit 1105 in the IPR
`proceedings, and that bears the title Declaration
`of Kimmo Savolainen for inter partes review of
`U.S. patent number 8,648,717.
` MR. LOEWENSTEIN: Are you going to mark
` it?
` MR. HENSCHKE: I am not going to mark
` it. We will refer to it by its exhibit
`
`Page 5
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`A P P E A R A N C E S :
`PEARL COHEN ZEDEK LATZER BARATZ
`Attorneys for Petitioner
` 1500 Broadway, 12th Floor
` New York, New York 10036
`BY: DAVID A. LOEWENSTEIN, ESQ.
`
`FOLEY & LARDNER LLP
`Attorneys for Patent Owner
` 111 Huntington Avenue, Suite 2600
` Boston, Massachussetts 02199
`BY: MARC N. HENSCHKE, ESQ.
`Mhenschke@foley.com
`
`ALSO PRESENT:
`MILO EADAN, Patent Agent
`
`Page 3
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` INDEX TO TESTIMONY
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`WITNESS BY PAGE
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`Kimmo Savolainen Mr. Henschke 4
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` Mr. Loewenstein 76
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` INDEX TO EXHIBITS
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`SAVOLAINEN DESCRIPTION PAGE
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`1: Patent Owner's Notice of Deposition 4
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`2: GSM 4.11 specification 51
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` EXHIBITS PREVIOUSLY MARKED AND REFERRED TO
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` NUMBER PAGE
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` 1105: 4
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` 1113: 5
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` 1130: 15
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` number from the IPR proceedings, which is
` 1105.
` Q. Do you recognize this, Mr. Savolainen,
`as the declaration that you submitted in these IPR
`proceedings?
` A. I believe it is. Yes.
` Q. So for purposes of our deposition
`today, I am going to be referring to this as
`either the Savolainen declaration or as Exhibit
`1105. Is that clear?
` A. It's clear.
` Q. Let me show you another document that
`has already been marked and submitted in these IPR
`proceedings as Exhibit No. 1113, and this is a PCT
`patent application with the inventor Van Bergen,
`and it bears numbers WO 00/17021.
` MR. LOEWENSTEIN: Off the record.
` (Discussion off the record.)
` Q. Mr. Savolainen, today I am going to be
`referring to this as either Van Bergen or as
`Exhibit 1113. Is that clear?
` A. That's clear.
` Q. Let me turn your attention to figure
`2 in the Van Bergen patent application. Are you
`familiar with the disclosures in Van Bergen about
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`2 (Pages 2 to 5)
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 2
`
`

`
`Kimmo Savolainen
`
`New York, NY
`
`Page 6
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`July 7, 2016
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`the subsystem that is called ALU 16?
` A. Yes, I am.
` Q. And ALU 16 is also referred to as the
`GSM mobile unit in Van Bergen, correct?
` A. I believe that's correct.
` Q. Would a person of ordinary skill
`understand ALU 16 as being capable of generating
`digital outputs that it could transmit to other
`subsystems in the Cell-Eye system?
` MR. LOEWENSTEIN: Object to the form.
` Can you put a date on that?
` A. Yes. The ALU 16 needs to
`communicate through the modem with the
`controller, and that would be using digital
`signals.
` Q. Is ALU 16 able to transmit digital
`outputs to modem 15?
` A. Digital outputs? There is some form
`of communication, and most likely there is a
`digital serial port in between the two.
` Q. Is ALU 16 able to transmit digital
`outputs to controller and memory unit 14?
` A. I believe through the modem, yes, it
`is.
` Q. Is ALU 16 able to transmit digital
`
`Page 7
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`outputs to the alarm sensor interface 13?
` A. Through the chain, the modem and the
`controller relaying information from the ALU, I
`believe it is possible that that there are
`digital signals that are passed through the
`modem and controller to the alarm sensor
`interface.
` Q. So these digital outputs from ALU 16
`that we have been discussing, would they be
`considered digital inputs to the other subsystems
`that receive them?
` A. You could call them that.
` Q. Would you call them that?
` A. Yes, I could call them that.
` Q. So are these digital outputs that ALU
`16 can generate and transmit digital electronic
`signals?
` A. Yes. They would either be digital
`electronic signals, or you could potentially
`also use technologies like bluetooth to
`transfer them wirelessly.
` Q. So are there different types or
`categories of digital electronic signals that ALU
`16 could generate and transmit?
` MR. LOEWENSTEIN: Objection to the
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` form.
` You could answer if you understand.
` A. I'm not sure I follow you. Can you
`say that question again?
` Q. I am trying to figure out if it is the
`case that there are different types of digital
`electronic signals that ALU 16 can transmit and
`generate. Would you consider there to be
`different types or categories of those signals?
` MR. LOEWENSTEIN: Same objection.
` Compound.
` A. There can be different signals,
`different commands, as an example, through the
`serial port.
` Q. Would some of the --
` MR. HENSCHKE: Strike that.
` Q. Would some of the digital electronic
`signals that ALU 16 could generate and transmit be
`data streams?
` MR. LOEWENSTEIN: I think I am going to
` object to the form of the question. I am not
` sure that term is used in the patent or has
` been defined in this IPR.
` A. I was going to ask you to define
`data stream, because that could be many things.
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`Page 9
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` Q. Well, I believe it would be a digital
`electronic signal that was principally data or
`carrying data?
` MR. LOEWENSTEIN: Are we excluding
` voice data? Voice, not voice?
` Q. Talking about a digital electronic
`signal and whether ALU 16 can issue one that is a
`data stream.
` MR. LOEWENSTEIN: My objection stands.
` If you understand it, you can answer.
` A. Well, it does send short bursts of
`data, which can include commands, instructions.
`If you can consider something like that a data
`stream, yes, it is possible.
` Q. Would some of the digital electronic
`signals that ALU 16 is capable of generating and
`transmitting be control signals?
` MR. LOEWENSTEIN: Objection to the
` form.
` You can answer.
` A. Well, in terms of generating control
`signals, I believe it does not make decisions
`on issuing control signals. Those control
`signals would come from somewhere else, but it
`can relay such control signals that it receives
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`3 (Pages 6 to 9)
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 3
`
`

`
`Kimmo Savolainen
`
`July 7, 2016
`
`New York, NY
`
`Page 10
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`Page 12
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`through the GSM network from the RMU in the
`system.
` Q. What, if anything, is the difference
`between digital electronic signals that are data
`outputs as opposed to digital electronic signals
`that are control signals?
` MR. LOEWENSTEIN: I am going to object
` to the form.
` You can answer.
` A. Can you say that again? I'm not
`sure I follow that question.
` Q. We have talked about two different
`types of digital electronic signals, one which is
`issuing data or data stream, and then a second
`category that we have called control signals, and
`I am trying to figure out what the difference is
`between those two types of digital electronic
`signals, if any.
` A. Well --
` MR. LOEWENSTEIN: Object to the form.
` You can answer.
` A. The control signal is a subcategory
`of those data streams, but -- yeah. Those
`control signals are coming through the GSM
`network from the RMU and go through the ALU
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`notification about that to the controller.
` It could send a notification when it
`returns to said coverage.
` If there is an SMS message that
`arrives, it would notify the controller that such
`an SMS has arrived, and it can be read from the
`memory of the ALU, or it could automatically
`forward that SMS message to the controller.
` Q. Is there a technical term that you
`would use to describe these types of status
`notifications?
` A. Well, I think status notification is
`a fairly good description.
` Q. Would what you are calling status
`notifications be referred to as result codes?
` A. In AT commands, the result codes
`would be inside of those notifications so the
`result code itself would not be a notification,
`but it would be part of the notification, or it
`could be part of the notification.
` Q. What type of interface would ALU 16
`have for transmitting these digital electronic
`signals we have been discussing?
` A. Most likely it would be an
`asynchronous serial port.
`
`Page 13
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`Page 11
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`into the controller or alarm sensory interface.
` Q. Do you consider the control signals to
`be a type of digital data?
` A. Yes, you can consider those to be a
`type of digital data.
` Q. Do you consider that to be a -- that
`control signal to be a binary output as
`distinguished from a data stream?
` MR. LOEWENSTEIN: Object to the form.
` A. Well, data stream would also be
`binary data.
` Q. Would be or could be?
` A. Most likely would be, and definitely
`could be.
` Q. Are there any other types of digital
`electronic signals that we haven't discussed so
`far that ALU 16 would be capable of generating and
`transmitting?
` A. Well, the ALU is a GSM mobile unit;
`hence, it does operate as one, so it is a
`communication device, and it does also send or
`could, at least, send sort of a status data --
`status of the communication.
` As an example, if it goes out of
`coverage of the cell network, it could send a
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` Q. That is your understanding of what kind
`of interface ALU 16 would have as shown there in
`Figure 2?
` A. Yes, I believe so. There was even
`something said about that somewhere in this.
` Q. For instance, if I direct your
`attention to page 7, lines 25 through 31, does
`that help?
` A. Yes. That is referring to
`asynchronous mode serial communication, which
`could refer either to the communication --
`serial communication between those blocks or
`modules in Figure 2, or it could also be
`referring to the cellular communication. Both
`are serial and asynchronous.
` Q. Does this suggest for the Figure 2
`embodiment, ALU 16 is sending electronic signals
`as hard wire serial transmissions?
` A. Could be hard wire, or hard wire
`could be replaced by a bluetooth, as an
`example.
` Q. Is there any disclosure of bluetooth
`communication in the Van Bergen patent
`application?
` A. I do not think there is in this
`
`4 (Pages 10 to 13)
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 4
`
`

`
`Kimmo Savolainen
`
`July 7, 2016
`
`New York, NY
`
`Page 14
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`reference, but there was another reference, I
`believe it was called the Sonera reference,
`that was discussing bluetooth as an alternative
`for hard wire serial.
` Q. I am just asking you now about what Van
`Bergen teaches with respect to Figure 2. There is
`no teaching of a bluetooth transmission or the
`presence of a bluetooth transceiver in any of
`those subsystems, correct?
` MR. LOEWENSTEIN: Object to the form.
` You can answer.
` A. I believe you are correct. This
`particular reference does not discuss bluetooth
`as an alternative means for hard wire serial
`communication.
` Q. Van Bergen teaches that one example of
`what could serve as ALU 16 in Figure 2 is a Falcom
`A2 GSM mobile unit, correct?
` A. That I believe is correct.
` Q. In fact, if I direct your attention
`back to page 7 of Van Bergen at lines 33 to 34.
` A. Can you say the lines again?
` Q. I am on page 7 of Van Bergen at lines
`33 to 34.
` A. It does refer to Falcom A2 GSM
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`that is referenced in the Van Bergen patent
`application, correct?
` MR. LOEWENSTEIN: I am going to object
` to the form of the question.
` A. The dates are indicating that at
`least this document would not be the same that
`the PCT application is referring to, but it is
`possible that it is similar.
` Q. In fact, you relied upon it in your IPR
`analysis as being the same or similar, didn't you?
` MR. LOEWENSTEIN: Object to the form.
` A. Let me check it what I said about
`that. I don't remember by heart.
` If you do remember where I did refer to
`Falcom A2 --
` MR. LOEWENSTEIN: It looks like it is
` on page 95.
` A. I believe I did indeed refer to this
`document.
` Q. You relied upon Exhibit 1130 in your
`analysis to show what kind of features and
`capabilities the Falcom unit referenced and Van
`Bergen had, right?
` MR. LOEWENSTEIN: Object to the form.
` A. I believe I did -- do refer to this
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`mobile unit.
` Q. And it says that is an example of what
`could serve as the ALU 16 in the Figure 2
`embodiment, right?
` A. I believe you are correct.
` Q. Let me show you another exhibit that
`has already been previously marked in the IPR
`proceedings. This is a user manual for the Falcom
`A2 GSM mobile unit. This has been marked in the
`IPR proceedings as Exhibit 1130.
` Mr. Savolainen, is this Falcom A2 GSM
`mobile unit that is discussed in Exhibit 1130 the
`same as the one that is referred to in the Van
`Bergen patent application on page 7?
` A. I believe it is.
` MR. LOEWENSTEIN: You might want to ask
` the witness about the dates on the respective
` documents.
` A. Although I believe the PCT patent
`application was originally for this -- yes.
`The PCT patent application was filed before the
`date of this document.
` Q. But you would agree, Mr. Savolainen,
`that the Falcom A2 that is shown in Exhibit 1130
`is either the same or very similar to the Falcom
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`document.
` Q. And you refer to it in the manner I
`just described, as showing what capabilities and
`features the Falcom unit that is referenced in Van
`Bergen had, right?
` A. I believe I did.
` Q. Let me turn you to page 64 of Exhibit
`1130, the Falcom user manual. So this shows on
`page 64 that the Falcom A2 embodiment of ALU 16
`would have had a nine-pin serial port interface,
`right?
` MR. LOEWENSTEIN: Object to the form.
` A. That is one of the interfaces.
` Q. And with regard to this serial port
`interface in particular, could any of the nine
`pins have been used by ALU 16 for outputting
`digital electronic signals?
` A. Yes. There are several signals here
`that can be used to -- outputting digital
`signals.
` Q. Which of the serial port pins shown
`here on page 64 could have been used to output
`digital electronic signals?
` A. Pin 2 and pin 3 are used for serial
`communication. This does not exactly tell
`
`5 (Pages 14 to 17)
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 5
`
`

`
`Kimmo Savolainen
`
`July 7, 2016
`
`New York, NY
`
`Page 18
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`which one is output and which one is input,
`because there are two sides of the RS232
`specification. One of them is an output, as
`well as some of the handshaking signals, DTR,
`DSR, RTS and CTS.
` Depending on which RS232 definition
`this uses, some of those are outputs and some of
`those are inputs.
` Q. Let's take these in order, then. I am
`trying to figure out with you which of these pins
`could be used to output digital electronic
`signals.
` If we look at pin 1, that is the DCD
`pin, which would stand for data carrier detect,
`correct?
` A. That is correct.
` Q. And could that pin be used by the
`Falcom A2 to output a data carrier detect control
`signal?
` MR. LOEWENSTEIN: Can I hear that
` question back?
` (Record read.)
` A. Yes, I believe it could.
` Q. In the Figure 2 embodiment from Van
`Bergen, could ALU 16 use this data carrier detect
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` Q. An indication. You would consider the
`data carrier detect signal to be an indication
`signal?
` A. Yes. It indicates that a call has
`been connected, and the data carrier is
`present.
` Q. And it is the Falcom A2 that is making
`that determination and generating that indication
`signal, right?
` A. Yes. Based on the status in the
`cellular network, it indicates to the
`controller that I have now a data call on.
` Q. Let's turn back to page 64 of
`Exhibit 1130, the discussion of the serial port in
`the Falcom A2. I want to talk with you now about
`the second serial port pin that is listed there.
`It is called pin 2. It is abbreviated as TXD, and
`what that stands for is a transmit data pin,
`correct?
` A. Yes. T stands for transmit.
` Q. And the Falcom A2 could use this pin 2
`to transmit out a stream of data in the form of a
`digital electronic signal, right?
` MR. LOEWENSTEIN: Object to the form.
` A. I believe it can send bursts of data
`
`Page 21
`
`Page 19
`
`control signal to indicate to the controller 14
`when a remote call had been successfully connected
`or later terminated?
` A. That is one possible use for such a
`signal.
` Q. If we look at page 15 of the Falcom
`user manual, Exhibit 1130, we see that that
`possible use actually does apply here to this
`Falcom A2 unit, right?
` A. I believe that's correct.
` Q. We see on page 15 that an AT&C command
`could be used to configure the Falcom so it would
`send this data carrier detect control signal,
`right?
` A. I believe you are correct.
` Q. And the data carrier detect control
`signal is a signal that is generated by the Falcom
`unit itself, right?
` A. Yes. That is an indication of the
`status of communication.
` Q. And it is a control signal that ALU 16
`or the Falcom version of it would generate, right?
` A. Well, I think in this context,
`control signal would be a wrong description. I
`would rather call it an indication.
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`according to the RS232 specification.
` Q. Let me turn your attention to page 14
`of Exhibit 1130. I am looking at the middle of
`the page, Section 1.4.2, which is the discussion
`of the ATO command. Do you see that?
` A. I see that.
` Q. What this indicates is the Falcom A2
`embodiment of ALU 16 could be programmed so that
`one of the types of data it would be able to
`output over the TXD pin and transmit to the
`controller would be result codes, correct?
` MR. LOEWENSTEIN: Object to the form.
` A. Yes. I believe that is correct.
` Q. And in the instance where the Falcom A2
`was transmitting result codes out over pin 2,
`those result codes would have been generated by
`the Falcom A2 unit itself, right?
` A. Yes. Those would be responses to AT
`commands, and depending on the success
`particularly, a result code would tell you the
`success of executing that AT command, so the
`Falcom A2 being a communication unit receiving
`an AT command, depending on whether the command
`was executed successfully, it would indicate to
`the command controller unit whether whatever it
`
`6 (Pages 18 to 21)
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 6
`
`

`
`Kimmo Savolainen
`
`July 7, 2016
`
`New York, NY
`
`Page 22
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`Page 24
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`was told to the A2 to do was executed properly.
` Q. And in that instance, the Falcom unit
`would itself generate the result code, right?
` A. Based on whether the operation that
`it was told to do was successful or not, yes,
`that's correct. It determines whether
`something was executed or not, and based on
`that, it sends a result code as part of the
`response to the controller.
` Q. You would consider those result codes
`to be a type of digital data, correct?
` A. They are digital data. They are
`indications whether a command was executed
`properly.
` Q. And they would be a digital data output
`from the Falcom A2 unit, right?
` A. Yes. They would be digital output
`and, more specifically, indication whether the
`command that A2 was told to do by the AT
`command was executed successfully.
` Q. So let's now take a look at page 35 of
`the same Exhibit 1130. I am looking now at the
`Section 1.9.4 that is in the middle of page 35.
`Do you see that?
` A. Yes, I do see that.
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`result code that we are discussing, the +CMGS
`result code, that would be a result code that was
`generated by the Falcom A2 unit, right?
` MR. LOEWENSTEIN: Can I hear the
` question back?
` (Record read.)
` MR. LOEWENSTEIN: Object to the form.
` A. The result code itself was generated
`by the Falcom A2 as a response to getting an
`acknowledgment from the SMSC that it had
`received the message.
` Q. Let's then go to page 18 of
`Exhibit 1130. Now I am looking at the section
`1.5.1 at the top of page 18. Do you see that one?
` A. I see that one.
` Q. This indicates that in the Falcom A2
`embodiment, ALU 16 would have been able to send a
`digital electronic signal to controller 14 that
`contained an "okay" result code to indicate that
`an outbound call had been placed and successfully
`established, correct?
` MR. LOEWENSTEIN: Object to form.
` A. I believe that is correct. It can
`send an "okay" as an indication that it did
`connect the call through the GSM network to the
`
`Page 25
`
`Page 23
`
` Q. In the ALU 16 Falcom embodiment, ALU 16
`could send a digital electronic signal to
`controller 14 that contained a +CMGS result code
`to indicate that an outbound SMS transmission had
`been successfully received by the SMS service
`center, right?
` MR. LOEWENSTEIN: I am going to object
` to the form.
` A. Yes. It can send such a response as
`an indication that the message was delivered
`successfully to the SMSC.
` Q. And this is a particular kind of result
`code that would provide that indication?
` MR. LOEWENSTEIN: Object to the form.
` A. Yes. This is an indication that can
`be -- yes. I think it can be described as a
`result code, an indication.
` Q. And in the Falcom A2 embodiment, ALU 16
`would be able to transmit that result code to
`controller 14, correct?
` A. Yes. It could transmit the
`indication to controller 14.
` Q. Let's now take a look at page 18 of
`Exhibit 1130.
` Before we leave page 35, the particular
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`other end.
` Q. And in that instance, the "okay" would
`be a result code, right?
` A. Yes. You could consider that to be
`a result code, although this particular text
`does not say it is a result code. It just says
`possible responses.
` Q. Would the "okay" result code be
`something that was generated by the Falcom A2 unit
`itself?
` MR. LOEWENSTEIN: Object to the form.
` He just said it wasn't a result code.
` A. The response "okay" would be
`generated as a result of the call connecting
`through the GSM network so as the
`acknowledgment from the network side tells the
`Falcom A2 that the call was successfully
`connected to the other end, then the Falcom A2
`would send an "okay" response to the
`controller.
` Q. In that instance, would a person of
`ordinary skill consider the "okay" response to be
`a result code?
` A. Well, it certainly is a response,
`because this text does describe it as such.
`
`7 (Pages 22 to 25)
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1236,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 7
`
`

`
`Kimmo Savolainen
`
`July 7, 2016
`
`New York, NY
`
`Page 26
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`Page 28
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` Whether you call it a response or a
`result code, not much of a difference between the
`two.
` Q. In fact, all of the previous result
`codes we have been discussing so far today have
`also been described as possible responses in the
`A2 user manual, right?
` MR. LOEWENSTEIN: Object to the form.
` A. Page --
` Q. Page 15.
` A. I believe, yes, they have been
`described as possible responses.
` Q. So let's turn back, then, to page 64 of
`Exhibit 1130, which is the discussion of the
`serial port pins. We talked about so far pins 1
`and 2. I am curious, are you able to identify any
`other pins between pin 3 and pin 9 as being output
`pins that the Falcom A2 could have used to output
`digital electronic signals?
` A. There are also some handshake
`signals, and some of those are outputs, and
`some of those are inputs.
` MR. LOEWENSTEIN: While there is a lull
` in the action, Mr. Henschke, my recollection
` is that the board did not institute the IPR
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`necessarily need to use this interface so --
`but could be used.
` But those would be handshake signals,
`not control signals.
` Q. Would those be handshake signals that
`ALU 16 would communicate to controller 14?
` MR. LOEWENSTEIN: Object to the form.
` A. Handshake signals could be used to
`indicate certain statuses to the controller 14,
`but those would not be controller signals;
`those would be handshake signals and used for
`indication purposes.
` Q. Would you agree that those are digital
`electronic signals?
` A. They are digital electronic signals.
` Q. You say they could be used to indicate
`the statuses of things to controller 14. What in
`particular --
` MR. HENSCHKE: Strike that.
` Q. The statuses of what could be
`communicated to controller 14?
` A. As an example, pin 9, which is RI,
`stands for ring indicator, that could be used
`to indicate to the controller that the GSM
`network has a call that is coming in, which has
`
`Page 29
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`Page 27
`
` based on the Falcom reference, and Mr.
` Savolainen didn't discuss each one of these
` individual pins in his declaration, so I am
` willing to give you some leeway, but we have
` been going probably for 15, 20 minutes, and I
` am hoping we come to an end reasonably soon.
` It is your time, obviously.
` MR. HENSCHKE: I will come to an end on
` this topic when I deem that to be
` appropriate, and this is obviously within the
` scope of the Van Bergen reference and Mr.
` Savolainen's opinions on same.
` Q. Let me try to narrow my question a
`little bit. While this Falcom A2 is being used as
`the ALU 16 from Van Bergen, are there any other
`pins, pin 3 through pin 9, that could be used by
`ALU 16 to output a digital control signal to
`controller 14?
` MR. LOEWENSTEIN: Object to the form.
` It is compound, and it assumes a fact that is
` not in evidence.
` A. There are digital signals in this
`interface that could be used also as
`indications. They are called handshake
`signals, but naturally Falcom A2 doesn't
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`been at that time communicated by the GSM
`network to the Falcom A2 through the control
`channel, and telling the A2 that there is a
`call coming in; hence the A2 would indicate to
`the controller that there is a call coming in
`so that the controller can make the decision
`whether to answer that call or not.
` Q. That would be a telephone call?
` MR. LOEWENSTEIN: Object to the form.
` A. It could be a telephone call. I
`don't remember by heart what their ring
`indicator would also indicate, other types of
`calls.
` In general, ring indicator in RS232 is
`used for indicating an incoming call.
` Q. What other examples can you explain of
`where any of pins 3 through 9 could be used by ALU
`16 to output a status indication to controller 14?
` A. The handshake signals DTR, DSR, RTS
`and CTS are used, for example, to tell the
`controller if the controller is sending data
`to -- through A2 and through the GSM network
`that, for example, the buffer of the A2 for
`data is full, and it is indicatin