IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`
`M2M SOLUTIONS LLC,
`a Delaware limited liability company,
`
`
`
`
`
`
`
`
`
`
`
`C.A. No. 12-033-RGA
`
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`Defendants.
`
`
`MOTOROLA SOLUTIONS, INC., a
`Delaware corporation, TELIT
`COMMUNICATIONS PLC, a United
`Kingdom public limited company, and TELIT
`WIRELESS SOLUTIONS INC., a Delaware
`corporation,
`
`
`EXPERT REPORT OF KIMMO SAVOLAINEN ON THE
`INVALIDITY OF U.S. PATENT NO. 8,094,010
`
`
`
`I have been retained by Telit Communications PLC (“Telit PLC”) and Telit Wireless
`
`Solutions Inc. (“Telit Wireless”) (collectively with Telit PLC, “Telit”), Motorola Solutions, Inc.
`
`and Kowatec Corporation (“Kowatec”) to serve as an expert in this lawsuit. I expect to testify at
`
`trial regarding the matters discussed in this report if asked about them by the Court or the parties’
`
`attorneys.1
`
`
`
`
`
`
`This report constitutes notice under 35 U.S.C. §282. Defendants reserve the right to rely
`1
`on prior art, invalidity contentions or information contained in the expert reports submitted by
`other defendants against which M2M asserted the ‘010 Patent.
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 1
`
`

`
`Expert Report of Kimmo Savolainen
`May 5, 2014
`
`
`TABLE OF CONTENTS
`
`Page 2 of 57
`
`Page
`
`SUMMARY OF EXPECTED TESTIMONY ..................................................................... 6
`II.
`GENERAL LEGAL PRINCIPLES ..................................................................................... 7
`III.
`TECHNICAL INTRODUCTION AND BACKGROUND .............................................. 11
`IV.
`SKILL IN THE ART ......................................................................................................... 17
`V.
`U.S. PATENT NO. 8,094,010 ........................................................................................... 18
`VI.
`VII. THE ASSERTED CLAIMS ARE INVALID .................................................................... 23
`A.
`and/or Obvious Over the Hotlink Business Case .................................................. 23
`B.
`and/or Obvious Over U.S. Patent No. 6,463,474 ................................................. 25
`C.
`and/or Obvious Over the Raven Airlink .............................................................. 33
`D.
`and/or Obvious Over GSM 11.14 ......................................................................... 37
`E.
`and/or Obvious Over Telital GM360 ................................................................... 45
`F.
`and/or Obvious Over WO 00/017021 ................................................................... 48
` RIGHT TO SUPPLEMENT OR AMEND ....................................................................... 54
`
`BACKGROUND ................................................................................................................ 3
`
`The Asserted Claims Were Anticipated By
`
`The Asserted Claims Were Anticipated By
`
`The Asserted Claims Were Anticipated By
`
`The Asserted Claims Were Anticipated By
`
`The Asserted Claims Were Anticipated By
`
`The Asserted Claims Were Anticipated By
`
`
`I.
`
`VIII.
`
`
`
`
`1.
`
`
`
`APPENDICES
`
`EXHIBIT LISTING
`A.
`Claim Chart for the Hotlink Business Case
`B.
`Claim Chart for U.S. Patent No. 6,463,474
`C.
`Claim Chart for the Raven Airlink
`D.
`Claim Chart for GSM 11.14
`E.
`Claim Chart for Telital GM360
`F.
`Claim Chart for WO 00/017021
`
`
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 2
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
`
`I.
`
`BACKGROUND
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`Page 3 of 57
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`1.
`
`From 1985 – 1990 I attended the Raahe Institute of Computer Technology, Raahe,
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`Finland where I earned a Bachelor of Science degree, with a major in electrical engineering,
`
`focused on embedded environments, and a minor in programming in embedded environments.
`
`From 1991 - 1996 I attended the University of Oulu, Finland where I earned a Master of Science
`
`degree in Computer Science.
`
`2.
`
`From November 1994 to May 2006, I was employed by Nokia. From 1994-1998,
`
`I served as Product Program Manager at Nokia’s Oulu, Finland facility. In that capacity, I
`
`successfully managed up to four simultaneous product programs in M2M (machine-to-machine)
`
`terminal product creation and related server software product creation. I also managed up to 100
`
`people in three R&D sites. During this period of time, I was involved in and supervised the
`
`development of Nokia’s wireless payphone (Ex. 1) and payphone management system,
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`including: writing “C” code for the project; designing electrical circuitry; writing technical
`
`specifications; and writing protocol specifications for the wireless transaction protocol (WTP).
`
`3.
`
`From 1994-1998, I served as an R&D Line Manager (Nokia Elektrobit Products
`
`(NEP), Oulu), Project Manager (NEP, Oulu, Finland) (including managing GSM type approval
`
`testing and certification processes, and was named as an inventor on several patent applications,
`
`two of which were approved in the US), Software Chief Designer (NEP, Oulu, Finland), and
`
`Hardware Designer (NEP, Oulu, Finland).
`
`4.
`
`From 1998-2002, I was involved in the development of Nokia’s M2M
`
`connectivity terminal, the Nokia 20, and the M2M gateway (Ex. 2). The connectivity terminal
`
`and gateway were designed to be sold together. In connection with this project, I led the design
`
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 3
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`team, wrote technical and protocol specifications, and communicated customer requirements to
`
`Page 4 of 57
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`the design team.
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`5.
`
`Also while at Nokia, I served as Business Development Manager at Nokia’s Oulu,
`
`Finland facility. In that capacity, I conducted an extensive market study of the M2M market
`
`around the world, interviewing over 100 systems integrators and vendors working on this
`
`market. I also translated market requirements to product requirements and wrote product
`
`specifications to allow Nokia to enter the market.
`
`6.
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`From 2003-2004, I served as General Manager for Nokia’s M2M business
`
`worldwide. In this capacity, I had global responsibility of the M2M business area in Nokia,
`
`including product development. I was nominated as one of the ten pioneers of the M2M industry
`
`by the M2M Magazine in July 2004. (Ex. 3)
`
`7.
`
`During this timeframe, I served as Program Manager in Nokia’s Dallas, Texas
`
`facility. In that role, I developed sales channels and collaboration networks with various
`
`companies working in the M2M business, including system integrators, hardware and software
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`vendors, distributors, consultants, and install companies. I also involved the GSM carriers in the
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`M2M business, managed the collaborator network and worked together with Nokia offices in
`
`Latin America to create the M2M market.
`
`8.
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`I also successfully managed the transfer of Nokia’s M2M business area and
`
`products to Aplicom Ltd in 2004.
`
`9.
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`From 2004-2005, I served as Senior Business Manager (Oulu) for Spain, France,
`
`Portugal and Benelux, for the Nokia 770 Internet Tablet. In this capacity, I was responsible for
`
`developing retail sales channels, cooperating with Telecom companies and partnering with ISPs.
`
`
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 4
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`Page 5 of 57
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`10. After my time at Nokia, from May 2006 to January 2008, I served as Director of
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`Business Development for Elektrobit, in Oulu, Finland and Washington, DC/Seattle, Washington,
`
`where I was responsible for overall project management. Elektrobit is a research and
`
`development company. While at Elektrobit, I oversaw a project for TerraStar Networks, in
`
`Reston, Virginia, for developing a handset capable of satellite communication as well as LTE
`
`communication.
`
`11.
`
`Since January 2008, I have been employed by Anite Plc., where I serve as Vice
`
`President of Engineering. I previously was Vice President for Sales Support and Product
`
`Management in Anite’s Oulu, Finland facility. I also served as Vice President of Technical
`
`Support and Sales Support in Anite’s Forest, Virginia facility. Anite manufactures test tools for
`
`wireless carriers such as AT&T and T-Mobile. I am responsible for, among things, global
`
`engineering activities, and process development. My curriculum vitae is attached as Exhibit 4.
`
`12.
`
`In addition to those patents referenced earlier, I am a named inventor or co-
`
`inventor on U.S. Patent No. 6,108,531, entitled “Terminal equipment providing payment data in
`
`a cellular radio system” (Ex. 5); U.S. Patent No. 6,327,466, entitled “Method and arrangement
`
`for setting the charge rate in a wireless pay phone” (Ex. 6); International Patent Publication No.
`
`WO 99/57875, entitled “Method of Updating Terminal Software in a Telephone System” (Ex. 7);
`
`International Patent Publication No. WO 99/20070, entitled “Method of Installing a Terminal,
`
`and a Wireless Telephone System” (Ex. 8); and International Patent Publication No. WO
`
`96/42175, entitled “Method and Terminal Equipment for Transmitting Information Not Relating
`
`To A Call” (Ex. 9).
`
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 5
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`Page 6 of 57
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`13.
`
`I have no publications in the last ten years. I have not previously testified as an
`
`expert at trial or at deposition.
`
`II.
`
`
`14.
`
`I am being compensated at an hourly rate of $200/hour.
`
`
`
`SUMMARY OF EXPECTED TESTIMONY
`
`15.
`
`If called to testify, I expect to testify regarding the following topics:
`
` The state of the art in the M2M field prior to the filing date of U.S. Patent No.
`
`8,094,010 (the “‘010 Patent,” Ex. 10), including technology that existed prior to the May
`
`23, 2000 Finnish priority patent application for the ‘010 Patent;
`
` The level of ordinary skill in the art;
`
` The subject matter described in the ‘010 Patent; and
`
` My opinion that the patent claims discussed below are invalid for a number of
`
`reasons.
`
`16.
`
`In forming my opinions, I have considered the materials described below
`
`including the following:
`
` The ’010 Patent and its prosecution history.
`
` Claim Construction Order dated Nov. 19, 2013 and Order on Reconsideration
`
`dated Jan. 24, 2014.
`
` The prior art listed in Appendix 1.
`
` M2M’s Preliminary Infringement Contention against Telit including M2M’s
`
`Preliminary Infringement Claim Charts, First Supplemental Preliminary Infringement
`
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 6
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`Page 7 of 57
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`Contention Claim Charts, and Second Supplemental Preliminary Infringement
`
`Contention Claim Charts.
`
` M2M’s Preliminary Infringement Contention against Kowatec including
`
`M2M’s Preliminary Infringement Claim Charts and First Supplemental Preliminary
`
`Infringement Contention Claim Charts.
`
` Transcripts of E. Wesby dated August 14, 2012 and Jan. 21, 2014 and P.
`
`Wesby dated August 15, 2012, Jan. 22, 2014 and April 1, 2014.
`
`17.
`
`I understand that Plaintiff M2M Solutions LLC (“Plaintiff”) has identified the
`
`following claims of the ‘010 Patent that it believes are infringed by Telit: claims 2, 5, 19, 26, 42,
`
`54, 57, 58, 62, 63, 64, 66, 67, 70, 71, 78, 79, 81, 93,2 94 and 97 (which depend from claims 1, 10,
`
`11, 18, 52, 80 and 96).
`
`18.
`
`I understand that Plaintiff has identified the following claims of the ‘010 Patent
`
`that it believes are infringed by Kowatec: claims 1, 2, 5, 10, 11, 18, 19, 26, 42, 52, 54, 57, 59, 62,
`
`63, 64, 66, 70, 71, 78, 80, 81, 87, 88, 94, 99, 100, and 101.
`
`
`
`III. GENERAL LEGAL PRINCIPLES
`
`
`19.
`
`I have been informed of the general legal principles for determining whether the
`
`claims of a patent are invalid over the prior art.
`
`
`I was informed that M2M did not list claim 93 as an alleged infringing claim in its letter
`2
`of December 27, 2013: “To clear up any potential confusion, the asserted claims of the ’010
`Patent are Claims 2, 5, 19, 26, 42, 54, 57, 58, 62, 63, 64, 66, 67, 70, 71, 78, 79, 81, 94, 97.”
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 7
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`Page 8 of 57
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`20. Generally, I understand that to analyze the meaning of claim terms, the Court and
`
`jury must consider them from the point of view of a person of ordinary skill in the art at the time
`
`the alleged inventions were made.
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`21.
`
`I understand the patent is presumed to be valid, and the party challenging validity
`
`is required to prove that each patent claims is invalid.
`
`22.
`
`I have been informed that a patent claim is invalid as anticipated if the claim
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`“reads on” a single prior art reference; that is, each claim limitation is disclosed expressly, or
`
`inherently in a single prior art reference.
`
`23.
`
`I also understand that material not explicitly contained in the single prior art
`
`document may still be considered for purposes of anticipation if the specific material to be
`
`incorporated into the document was clearly identified.
`
`24.
`
`I have further been informed that in the event the claim does not “read on” a prior
`
`art reference precisely, the claim may nevertheless be invalid for obviousness. A patent claim is
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`invalid for obviousness if the subject matter of the claim as a whole would have been obvious at
`
`the time the invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains.
`
`25.
`
`I understand that the following factors should be considered in determining
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`whether or not a claim would have been obvious: the level of ordinary skill in the art; the scope
`
`and content of the prior art; the differences between the prior art and the claims at issue; and
`
`whatever secondary considerations may be present.
`
`26.
`
`I understand that to the extent that there are any differences between the prior art
`
`and the claimed subject matter, the claims would have been obvious where a person of ordinary
`
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 8
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`skill in the art would have modified or combined the prior art references to arrive at the claimed
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`Page 9 of 57
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`subject matter. I understand that routine design choices and other market forces can prompt
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`modifications of technology.
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`27.
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`To the extent Plaintiff argues that certain claims were not anticipated by the prior
`
`art cited above, I may explain that any perceived differences were trivial and would have been
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`obvious to one of ordinary skill in the art.
`
`28.
`
`To the extent that Plaintiff argues the existence of secondary considerations of
`
`non-obviousness, I have considered each of the claims identified above as a whole, and at this
`
`time, I am unaware of any long-felt but unsolved needs, failure of others, unexpected results, or
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`commercial success relating to the asserted claims. The prior art references discussed below,
`
`including the Wireless Payphone and other systems I built with my colleagues at Nokia, had
`
`functionality identical to most of the asserted claims, and any differences were trivial
`
`modifications, such as, the use of GPS. I have not seen any evidence that others have tried and
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`failed to develop the claimed subject matter. Based on the references discussed below and
`
`general knowledge in the field, I also see no evidence of unexpected results of any of the claimed
`
`subject matter. If the Plaintiff points to any secondary considerations to support the claims, I
`
`may provide a response.
`
`29.
`
`I understand that the Court in this case has construed certain claim terms for the
`
`‘010 Patent, as follows:
`
`
`
`
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 9
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`
`Claim Term
`
`"permitted caller"
`
`"coded number"
`
`"a programmable interface"
`
`"processing module"
`
`"monitoring device"
`
`"wireless communications circuit for
`communicating through an antenna"
`
`"monitored technical device"
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`Page 10 of 57
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`Court’s Construction
`
`"A telephone number or IP address on a list of numbers
`that are designated to cause the programmable
`communicator to accept an incoming call received from
`that number."
`
`"A designated, unique sequence of characters."
`
`"An interface that is able to be directly programmed."
`
`"Components or units of a computer program."
`
`"A device configured to remotely monitor a
`programmable communicator device and/or a monitored
`technical device."
`
`"A complete wireless circuit that transmits and receives
`data through an antenna."
`
`The wireless communications circuit includes an
`antenna: “both the language of the patent claim and the
`specification (to wit, the abstract) require an antenna.
`The only way the wireless communications circuit has
`of communicating through an antenna is if it has an
`antenna.” (Order dated Jan. 24, 2014, footnote at 5)
`
`"A device that provides information to the remote
`monitoring device through the programmable
`communicator device."
`
`30.
`
`I understand that, in addition, the parties have agreed to the construction of the
`
`following claim term:
`
`Claim Term
`
`Agreed Construction
`
`“A programmable communicator
`device ... configured to be
`incorporated into the at least one
`monitored technical device such that
`it becomes an integrated part of the
`monitored technical device.”
`
`
`“A programmable communicator device configured to
`be physically embedded within a monitored technical
`device so as to form a single device.”
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 10
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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`31.
`
`I understand that the remaining claim terms are to be given their ordinary
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`Page 11 of 57
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`meaning.
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`
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`IV.
`
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`TECHNICAL INTRODUCTION AND BACKGROUND
`
`32.
`
`As noted above, in the mid-1990s, Nokia developed a wireless payphone and
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`management system (Ex. 1). In 1994, I was the head of the project and a contributing member.
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`My tasks included programming the firmware for the wireless payphone in the “C” programming
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`language and drafting technical and protocol specifications. The wireless payphone was
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`described in my thesis (Ex. 12),3 although some of its details were omitted for product secrecy
`
`reasons (Ex. 12, 7742).4 I submitted my thesis to the University of Oulu in 1996. My thesis was
`
`available at the University library, and I understand it was posted in the University database (e.g.,
`
`see Ex. 44, Declaration stating that the thesis was cataloged and shelved at the University library
`
`in 1996).
`
`33.
`
`The wireless payphone was used for telephone communication in areas where
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`wired connections were not possible, such as, trains, boats, and in remote or developing countries
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`without wired infrastructure (Ex. 12, 7739-7740).
`
`34.
`
`The wireless payphone was a cellular phone programmable by a control system
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`over a wireless network as shown in the figure below (Ex. 12, 7742):
`
`
`A Certified English translation of the original Finnish version.
`3
`
` 4
`
`Unless otherwise indicated, citations in this document to four-digit numbers refer to
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`DEFPRIORART production numbers.
`
`
`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 11
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`Expert RReport of Kimmmo Savolaiinen
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`The paypphone includded a wireleess circuit thhat had an “aantenna” to
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`Cellular NNetwork (Exx. 12, 7741, 7755-56).
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`Page 12
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`communicaate over the
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`GSM
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`o the
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`The wwireless payyphone monnitored securrity featuress to report ttampering t
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`35.
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`control ssystem (Ex.
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`12, 7753, 77766). The
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`wireless paayphone inclluded a “Looop Detectorr” for
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`detectingg when the hhandset cordd was brokenn, a “Voltagee Alarm” foor detecting wwhen the vooltage
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`dropped
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`below a sett level, and
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`a “Door Switch” for ddetecting wwhen the payyphone doorr was
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`opened (EEx. 12, 77477 figure copiied below, 77743 and 77553).
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 12
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`Expert RReport of Kimmmo Savolaiinen
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`May 5, 22014
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`Among oother things,, the “Proceessor” and “Memory” inn the figure
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`above weree used to pr
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`ocess
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` the processsor, if
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`alarms (ee.g., “The poower supplyy block monnitors the inpput voltage aand notifies
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`the voltage drops bellow 10V,” EEx. 12, 7748) and store aalarm messaages (e.g., inn “Last_messsage”
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`memory,
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`Ex. 12, 77778). The Proocessor commmunicated wwith the celllular telephoone (shown iin the
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`nd the tion” to senone Connectlular Telephogh the “Cellbove) throughe figure abupper-rigght side of t
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`stored allarm messagges to a moonitoring devvice when aan alarm co
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`ndition wass detected b
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`y the
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`Processor (Ex. 12, 77753). The PProcessor creeated a sign
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`al to send a
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`“Security_NNotice” as shhown
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`in the figgure below (EEx. 12, 77888):
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 13
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`Expert RReport of Kimmmo Savolaiinen
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`The “Security_Noticce” triggereed an SMS
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`message too be sent too the “WPMM_number””- the
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`telephonee number off the “Wirelless Payphone Managemment” systemm as shownn in figure bbelow
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`(Ex. 12, 77778, highlighted for claarity):
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 14
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`Expert RReport of Kimmmo Savolaiinen
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`The CControl Systtem remotelly programmmed the wirreless payphhone using
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`36.
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`messagess as shown inn the figure below (Ex. 12, 7778, higghlighted foor clarity):
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`The Conntrol System
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`programmeed the “Parammeters” in tthe figure too control thee operation oof the
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`wireless payphone inncluding for example thee following ffunctions (Exx. 12, 7745)
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`The PIN ccode of the cellular telephhone
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`4 emergenncy numbers that can be
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`toll-free nuumbers
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`banned nuumbers
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`number annalysis
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`tariff tablee
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`ads on/off
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`maintenance passwordd
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`types of caards acceptedd
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`identification codes off card types
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`initial voluume level (0 - 3)
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`handset inn use / off
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`initial langguage
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`call blockiing.
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`fn
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`ng call maximum duration of the incomin
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`downloadiing of paymeent data (oncce a day / aftfter each calll)
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`dialed withoout a card
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`control sysstem data traansfer on/offf
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`3
`7.
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`rs and one numbermitted telephoed and permety of banneluded a varie“Parammeters” incl
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`different
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`passwords.
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`was a paraameter. Parrameters couuld be enter
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`SMS
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`lessly rd,” or wirelance passwora “maintenaeypad with ald using a kery, in the fielupdated aat the factor
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`via SMS
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`from the Coontrol Systeem as shownn in the figurre above. WWhen updatinng wirelesslyy, the
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`only be chaanged to a neew WPM nuumber if the
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`programminng SMS me
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`WPM nuumber could
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 15
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`originated from the previously authorized WPM number. The wireless payphone was restricted
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`Page 16 of 57
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`to only receive incoming messages from the WPM number. The details about incoming call
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`restriction and the authentication during programming the WPM number were not published in
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`this thesis for product secrecy reasons (Ex. 12, 7742). However, a person of ordinary skill in the
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`art at the time when the thesis was written would have included these features as a matter of
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`routine engineering if the person wanted to limit access to the device, for example, to protect
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`wireless financial transactions.
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`38.
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`The first pilot build of the Nokia wireless payphone for GSM/DCS 1800 was in
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`the second quarter of 1995 (Ex. 12, 7740). Nokia’s wireless payphones offered telephony
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`services in areas without existing wired telephone infrastructure (Ex. 12, 7739).
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`39.
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`In March 1997, Nokia announced that its wireless payphones were sold in
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`Thailand and South Africa (Ex. 1).
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`40.
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`In June 1997, Nokia and SingTel introduced the first integrated wireless
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`payphones to Singapore at Asia TELECOM 97 (Ex. 13, TELIT0068228). Nokia’s phones
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`communicated over the GSM network to provide mobile communication services to users in
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`taxis, trains, limousines and ships (Ex. 13).
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`41.
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`In 1997, Nokia developed the next generation of its wireless payphone system,
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`incorporating a wireless modem with IP traffic that operated using GPRS. I was the Manager of
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`that payphone project, and a contributing member involved with writing code for the payphone.
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`IP address of management system and modem phone number were used as the authentication
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`methods for communication. Although prototype phones were built, the system was never sold.
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 16
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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`Page 17 of 57
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`42.
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`In 2001, Nokia announced the Nokia 20 M2M Connectivity terminal (Ex. 2). The
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`Nokia 20 provided M2M communication for remote management for applications, such as,
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`vending, security, automatic meter reading, elevator control, telematics, etc. (Ex. 2). The Nokia
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`20 communicated wirelessly by sending/receiving SMS messages over EGSM 900/1800
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`networks (Ex. 2), and used PIN authentication as well as GSM security (Ex. 2).
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`43.
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`Between 1999-2002, I was involved with Kone, a Finnish elevator manufacturer.
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`Kone used the Nokia 20 to build a wirelessly controlled elevator system for remote monitoring to
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`report alarms, request maintenance, remotely control machines, and for emergency telephone
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`communication for trapped passengers (e.g., see Ex. 14).
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`V.
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`SKILL IN THE ART
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`44.
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`I may testify about what a person of ordinary skill in the art pertinent to the ‘010
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`Patent would have known prior to the May 23, 2000 priority date.
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`45.
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`In determining the qualifications of a person of ordinary skill, I first considered
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`the general subject matter of the ‘010 Patent, which relates to a programmable communicator
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`which can communicate between a monitored device and a monitoring device, an application
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`sometimes called “telemetry.”
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`46.
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`Based on my experience, working with my colleagues at Nokia, in my opinion, a
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`person of ordinary skill in the art before the priority date would have at least a Bachelor’s degree
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`in computer science, or electrical engineering, with a good understanding of principles of
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`wireless telecommunications, and would have had at least four years of experience in designing
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 17
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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`and/or programming wireless communications systems utilizing GSM or other cellular networks,
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`Page 18 of 57
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`and had a good understanding of GSM standards.
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`VI. U.S. PATENT NO. 8,094,010
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`47.
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`The ‘010 Patent (Ex. 10) stated it built on prior art International Patent
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`Application No. PCT/GB98/02715 (Ex. 10, M2M0001521 at 1:33-37), the “Hotlink patent
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`application.” As the claim chart below shows, the Hotlink patent application (Ex. 15) described
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`almost all of the subject matter of the ‘010 Patent:
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`U.S. Patent No. 8,094,010 Claims
`1. A programmable communicator
`device comprising:
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`a wireless communications circuit for
`communicating through an antenna
`over a communications network;
`an identity module for storing a unique
`identifier that is unique to the
`programmable communicator device;
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`a programmable interface for
`establishing a communication link with
`at least one monitored technical device;
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`Hotlink patent application
`“[A] novel portable hot link communicating
`apparatus which comprises a preprogrammed
`identity module comprising the number of the
`mobile or fixed telephone to which the hot link
`communicating device is linked.” (Ex. 15, 0403 ll.
`30-35).
`“The hot link communicator preferably comprises a
`basic mobile telephone circuit … and antenna” (Ex.
`15, 0405 ll. 13-15; see also Ex. 15 at 420, Fig. 3).
`“[An] identity module within the GSM standard of
`mobile telephone technology, the subscriber identity
`module, or SIM card is described.” (Ex. 15, 0407 ll.
`33-35).
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`The ‘010 Patent admitted that a SIM card stored a
`PUK code identified as a “unique code” or “unique
`identifier.” (Ex. 10, M2M0001525, 9:29-31).
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`Further, the Hotlink was a GSM device (Ex. 15,
`0407, ll. 26-31) and therefore would have stored an
`IMEI number (e.g., see Ex. 20, 6454).
`The Hotlink was meant to be worn by a child using a
`wrist strap (Ex. 15, 0408 ll. 15-17).
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`At the time, it was known to monitor a child’s wrist
`strap (e.g., see Ex. 40, U.S. Patent No. 6,388,612,
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`Telit Wireless Solutions INC. and Telit Communications PLC Exh. 1239,
`Telit Wireless Solutions INC. and Telit Communications PLC v. M2M Solutions LLC
`IPR2016-01081, p. 18
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`

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`Expert Report of Kimmo Savolainen
`May 5, 2014
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`U.S. Patent No. 8,094,010 Claims
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`a processing module for authenticating
`an at least one transmission sent from a
`programming transmitter and received
`by the programmable communicator
`device, the at least one transmission
`including a coded number and at least
`one telephone number or Internet
`Protocol (IP) address corresponding to
`an at least one monitoring device,
`wherein the processing module
`authenticates the at least one
`transmission by determining if the at
`least one transmission contains the
`coded number, the processing module
`authenticating the at least one
`transmission if the transmission
`includes the coded number;
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`Page 19 of 57
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`Hotlink patent application
`showing a child’s wristband (18) monitored by the
`“child watch” monitoring station (12) in Fig. 1.
`Wristband (18) would “generate a distress signal …
`upon breaking of the circuit of the tracking unit,”
`Ex. 40, TELIT0068230, Abstract). It would have
`been obvious to monitor if the Hotlink’s wrist strap
`broke to know if the Hotlink was still attached to the
`child. E. Wesby acknowledged that a wrist strap
`was a monitored technical device (EW Tr. Jan. 21,
`2014 at 278:10-23; Ex. 10, M2M0001525, 10:23-