IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`GROUPCHATTER, LLC,
`
`Plaintiff,
`
`
`
`
`
`
`v.
`
`CIVIL ACTION FILE
`
`
`
` NO. 1:16-cv-00486-WSD
`
`[LEAD CASE]
`
`NO. 1:16-cv-00711-TCB
`
`NO. 1:16-cv-01800-WSD
`
`GENERAL ELECTRIC COMPANY,
`GE ENERGY MANAGEMENT
`SERVICES, INC., and GE GRID
`SOLUTIONS, LLC,
`
`
`and
`
`LANDIS+GYR TECHNOLOGIES, LLC
`and LANDIS+GYR TECHNOLOGY, INC.,
`
`and
`
`ITRON, INC.
`
`
`Defendants.
`
`
`PLAINTIFF’S LPR 4.1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS AGAINST GENERAL ELECTRIC
`COMPANY, GE ENERGY MANAGEMENT SERVICES, INC. AND GE
`GRID SOLUTIONS, LLC
`
`Plaintiff GroupChatter, LLC (“GroupChatter” or “Plaintiff”) makes the
`
`following LPR 4.1 Disclosure of Asserted Claims and Infringement Contentions to
`
`General Electric Company, GE Energy Management Services, Inc. and GE Grid
`
`General Electric Co. 1015 - Page 1
`
`

`
`Solutions, LLC (collectively “GE”) pursuant to the Local Patent Rules and the
`
`Court’s Order (Dkt. Nos. 57 & 58).
`
`These
`
`infringement contentions are based upon publicly available
`
`information describing GE products, systems, and their use. GroupChatter
`
`reserves the right to amend its infringement contentions and asserted claims as the
`
`case progresses based upon information obtained through discovery and as
`
`permitted by the Local Rules. GroupChatter reserves the right to amend its
`
`infringement contentions as permitted by the Joint Preliminary Report and
`
`Discovery Plan and reserves the right to amend its infringement contentions
`
`responsive to claim construction proceedings and claim construction rulings by the
`
`Court in this case or in any related case.
`
`LPR 4.1 (b) INFRINGEMENT CONTENTIONS.
`
`
`(1) Each claim of each patent in suit that is allegedly infringed by each
`opposing party.
`
`GE infringes, directly and indirectly, claims 1, 2, 3, 8, 10, 13, 14, 17, 18, 20,
`
`21, 22, 29 & 30 of United States Patent No. 7,969,959 (the “’959 Patent”) either
`
`literally or under the doctrine of equivalents.1 Claims 1, 2, 3, 4, 5, 10, 11, 12, 13,
`
`14, 15, 16, 20, and 21 of United States Patent No. 8,199,740 (the “’740 Patent”)
`
`1 Specific elements or steps that GroupChatter contends are met under the doctrine
`of equivalents are noted in the claim charts. GroupChatter contends that some
`elements or steps are met both literally and under the doctrine of equivalents.
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 2
`
`General Electric Co. 1015 - Page 2
`
`

`
`either literally or under the doctrine of equivalents; claims 1, 2, 3, 4, 8, 10, 11, 12,
`
`13, and 16 of United States Patent No. 9,014,659 (the “’659 Patent”) either literally
`
`or under the doctrine of equivalents; and claims 1, 2, 3, 8, 9, and 11 of United
`
`States Patent No. 8,588,207 (the “’207 Patent”) either literally or under the
`
`doctrine of equivalents.
`
`(2)
`
`Separately for each asserted claim, each accused apparatus,
`method,
`composition or other
`instrumentality
`(“Accused
`Instrumentality”) of each accused party of which the claiming
`party is aware. This identification shall be a specific as possible,
`with each apparatus identified by name or model number, if
`known, and each method identified by name if known;
`
`The Accused Instrumentality for each asserted claim is GE’s Smart Metering
`
`System that employ meter with two-way communication capability to collect and
`
`transmit meter data to support various applications and distribution automation.
`
`Generally, GE refers to these systems as Grid IQ. The Accused Instrumentalities
`
`include components, associated systems, and subsystems identified by name and
`
`functionality detailed in the accompanying infringement claim charts and any other
`
`GE messaging system having the same relevant functionality and components
`
`identified by Plaintiff in these infringement contentions. These include: Grid IQ
`
`AMI System consists of subsystems and components including RF Mesh
`
`components, Smart Metering Operations Suite, Grid IQ Connect, Grid IQ Network
`
`Communications Platform, access points, subscriber units, and endpoints (“Grid
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 3
`
`General Electric Co. 1015 - Page 3
`
`

`
`IQ”). Accused Instrumentalities also include AMI integrations by GE and Itron,
`
`Inc. (“Itron”) and/or Landis+Gyr Technologies, LLC and Landis+Gyr Technology,
`
`Inc. (“Landis+Gyr”) such as the GE document below contemplates.
`
`
`
`Plaintiff has attempted to identify each accused component of the system as
`
`is ascertainable from publically available information. To the extent that
`
`components of the system are not explicitly named or referenced in publically
`
`available information, Plaintiff reserves the right to supplement its infringement
`
`contentions or otherwise identify these products and services as their names
`
`become known.
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 4
`
`General Electric Co. 1015 - Page 4
`
`

`
`GE and third-party documents cited in GroupChatter’s infringement claim
`
`chart and further identifying the Accused Instrumentalities are being produced with
`
`these disclosures.
`
`GE performs the claimed methods when it provides (to various degrees
`
`depending upon the deployment) automated metering infrastructure (AMI)
`
`equipment and services to its customers. Services include but are not limited to
`
`project management, system design, training, software as a service, network
`
`installation, endpoint installation, field engineering (e.g., on-site field installation
`
`support and testing) integration services, system administration, daily operations
`
`support, database administration, WAN backhaul communications, configuration
`
`support, network design and site surveys,
`
`integration support, on-site
`
`commissioning, network monitoring, software license and upgrades, hosting,
`
`monitoring, technical support, and system audit services.
`
`GE Grid IQ endpoints include, as examples, electric meters, water meters,
`
`gas meters, DA devices, and load control switches that are equipped with an AMI
`
`module. Meters include hardware/software/firmware combinations that measure
`
`the supply of electricity, gas, or water provided by a customer to the customer's
`
`consumer. Network devices include collectors, routers, and radios that are often
`
`physically deployed in a customer service territory. Routers include, as examples,
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 5
`
`General Electric Co. 1015 - Page 5
`
`

`
`GE-furnished network devices that provide intermediate communication and data
`
`processing between endpoints and collectors. Routers can also communicate with
`
`other routers.
`
`GE directs and controls
`
`the operation and use of
`
`the Accused
`
`Instrumentalities. Depending on the particular deployment, GE works closely with
`
`its customers and accordingly directly infringes, indirectly infringes (based on
`
`direct infringement by the customer or end user), and/or jointly infringes the
`
`asserted claims. GE licenses (and thereby retains ownership of) firmware and
`
`software to its customers. Customers are granted licenses to use the firmware and
`
`software in connection with use of equipment that is provided by GE (e.g.,
`
`equipment used for the Grid IQ communication network). GE restricts customers,
`
`licensees, and end users from modifying the GE Grid IQ systems or using them
`
`except as authorized by GE.
`
`GE and its customers work closely to design systems that perform according
`
`to the asserted claims and restricts licensees’ use of the system per the terms of the
`
`license. In such situations, end users’ performance of steps of the claimed methods
`
`are attributable to GE. Through service agreements and contractual terms
`
`governing their relationship, GE conditions end users’ participation in and use of
`
`the GE AMI system, and the receipt of the benefit from use of the system and
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 6
`
`General Electric Co. 1015 - Page 6
`
`

`
`claimed methods, upon the end users performing certain steps of the claimed
`
`methods. GE provides on-site commissioning, optimization, orientation (including
`
`training for customers to maintain and troubleshoot RF equipment) and
`
`configuration of collector equipment and other RF equipment. GE operates system
`
`backhaul, and network operations center, and system equipment that may not be
`
`located within the customer service territory. In many cases, a GE customer uses
`
`GE equipment, firmware, field tools, and software to monitor and manage the
`
`consumer’s usage of GE customer offerings (e.g., gas, water, electricity).
`
`GE provides hardware, firmware, software, and other items purchased or
`
`licensed from GE. Hardware includes for example, collectors and endpoints.
`
`Software and hardware include for example without limitation GE Grid IQ AMI
`
`systems, Grid Solutions, Grid IQ AMI P2MP Solution, GE’s MDS wireless
`
`product portfolio, MDS PulseNET, GE Grid IQ Connect SaaS, Grid IQ Connect,
`
`GE Wireless AMI, Grid IQ Network Communications Platform, RF Mesh, Smart
`
`Grid Communications Solutions, Communications Infrastructure for Grid
`
`Applications, MDS Orbit Platform, SMOS Smart Metering Operations Suite, GE
`
`Digital Energy Grid IQ Solution, GE DRMS and related or analogous systems.
`
`Equipment provided by GE for various deployments (and accordingly, the
`
`makeup of an Accused Instrumentality) depend upon various factors for each
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 7
`
`General Electric Co. 1015 - Page 7
`
`

`
`deployment. System analysis and requirements, locations, deployment approach,
`
`customer needs, end-user consumer specifics (e.g., location), system optimization
`
`needs, and the like affect the number and type of network devices required for an
`
`AMI system to function properly. Endpoint installations are deployed so that
`
`communication routes are contiguous and endpoints are located within range of an
`
`appropriate network device to enable adequate communication. In some cases,
`
`customer requirements/requests dictate which specific equipment GE provides for
`
`a deployment. For example, a customer may provide WAN backhaul in some
`
`deployments but not others.
`
`To the extent GE, Itron and/or Landis+Gyr provide network elements or
`
`operation services that perform all steps of the asserted method claims or all
`
`elements of asserted apparatus claims, such collaboration constitutes joint
`
`infringement of the asserted claim.
`
`(3) A chart identifying specifically where each element of each asserted
`claim is found within each Accused Instrumentality, including for
`each element that such party contends is governed by 35 U.S.C. §
`112(6), the identity of the structure(s), act(s), or material(s) in the
`Accused Instrumentality that performs the claimed function;
`
`Infringement claim charts for each of the asserted patents are attached as
`
`Exhibits A through D.
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 8
`
`General Electric Co. 1015 - Page 8
`
`

`
`(4) Whether each element of each asserted claim is claimed to be
`literally present or present under the doctrine of equivalents, or
`both in the Accused Instrumentality.
`
`At this time, based upon publicly available information and without access
`
`to the GE Grid IQ protocol specifications, Plaintiff contends that each element of
`
`each asserted claim, as set forth in Exhibits A through D is literally present in the
`
`GE Grid IQ system. Plaintiff contends that certain elements or steps of claims
`
`identified in the claim charts (see, e.g., ’959 Claim 1(f)) may alternatively be met
`
`under the doctrine of equivalents.
`
`(5) For any patent that claims priority to an earlier application, the
`priority date to which each asserted claims allegedly is entitled.
`
`GroupChatter contends the Asserted Claims are entitled to a date of
`
`invention between June and August 2004. The basis of Plaintiff’s contention is the
`
`inventors’ conception of the claimed subject matter in that period of time followed
`
`by diligent reduction to practice prior to constructive reduction to practice in
`
`December 16, 2004 when the inventors filed Provisional Application Ser. No.
`
`60/363,094.
`
`LPR 4.1 (c) DOCUMENT PRODUCTION ACCOMPANYING
`DISCLOSURE.
`(1) Documents sufficient to evidence each instance of providing the
`claimed invention to a third party, by sale, offer to sell, or other
`manner of transfer, prior to the date of application for the patent in
`suit;
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 9
`
`General Electric Co. 1015 - Page 9
`
`

`
`(2) All documents evidencing the conception, reduction to practice,
`design, and development of each claim invention, which were
`created on or before the date of application for the patent in suit or
`the priority date identified pursuant in the Disclosure, whichever is
`earlier;
`(3) A copy of the file history for each patent in suit; and
`(4) A copy of all non-U.S. patents claiming a common priority with any
`patent asserted in the case, together with a copy of all prior art
`cited in such non-U.S. patent proceedings.
`
`The patents in suit and their corresponding file histories are being produced
`
`at GC000001-001169. After conducting a reasonable and diligent investigation,
`
`Plaintiff is not aware of any documents described in paragraph (1) and is producing
`
`documents described in paragraph (2). Plaintiff expects to produce non-privileged,
`
`confidential correspondence from the period prior to the inventors filing their
`
`provisional application
`
`in December 2004 showing and discussing
`
`their
`
`conception, reduction to practice, design, and development of the claimed
`
`inventions. Additional materials are available for inspection at GroupChatter’s
`
`office at 1400 Preston Road, Suite 475, Plano, Texas 75093. Plaintiff is not aware
`
`of any non-U.S. patents claiming a common priority with any asserted patent.
`
`Respectfully submitted,
`
`By:
`
`
`Cabrach J. Connor (pro hac vice)
`cconnor@taylordunham.com
`
`
`
`
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 10
`
`General Electric Co. 1015 - Page 10
`
`

`
`David E. Dunham (pro hac vice)
`ddunham@taylordunham.com
`Jennifer Tatum Lee (pro hac vice)
`jtatum@taylordunham.com
`TAYLOR DUNHAM AND RODRIGUEZ LLP
`301 Congress Ave., Suite 1050
`Austin, Texas 78701
`512.473.2257 Telephone
`512.478.4409 Facsimile
`
`and
`
`Daniel A. Kent
`Georgia Bar Number 415110
`dankent@kentrisley.com
`KENT & RISLEY LLC
`555 N Point Ctr E Ste 400
`Alpharetta, GA 30022
`Tel: (404) 585-4214
`Fax: (404) 829-2412
`
`Attorneys for Plaintiff
`
`
`
`
`
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 11
`
`General Electric Co. 1015 - Page 11
`
`

`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that all counsel of record are being served
`with a copy of this document via electronic mail this 20th day of July, 2016.
`
`
`John M. Guaragna (Pro Hac Vice)
`Email: john.guaragna@dlapiper.com
`Brian K. Erickson (Pro Hac Vice)
`Email: brian.erickson@dlapiper.com
`DLA Piper LLP (US)
`401 Congress, Suite 2500
`Austin, Texas 78701
`
`Christopher G. Campbell
`Email: christopher.campbell@dlapiper.com
`James M. Rusert
`Email: james.rusert@dlapiper.com
`DLA PIPER LLP (US)
`1201 West Peachtree Street, Suite 2800
`Atlanta, Georgia 30309-3450
`
`Counsel for Defendant Itron, Inc.
`
`
`
`Brian D. Roche
`Email: broche@reedsmith.com
`REED SMITH LLP
`10 S. Wacker Dr.
`Chicago, IL 60606
`
`David T. Pollock (pro hac vice)
`Email: dpollock@reedsmith.com
`Kirin K. Gill (pro hac vice)
`Email: kgill@reedsmith.com
`REED SMITH LLP
`101 Second Street, Suite 1800
`San Francisco, CA 94105-3659
`
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 12
`
`General Electric Co. 1015 - Page 12
`
`

`
`John W. Harbin
`Email: jharbin@mcciplaw.com
`Warren J. Thomas
`Email: wthomas@mcciplaw.com
`MEUNIER CARLIN & CURFMAN, LLC
`999 Peachtree Street, NE, Suite 1300
`Atlanta, Georgia 30309
`
`Attorney for Defendants
`General Electric Company, GE Energy
`Management Services, LLC, and GE Grid
`Solutions, LLC
`
`
`
`Natasha H. Moffitt
`Email: nmoffitt@kslaw.com
`Laura S. Huffman
`Email: lhuffman@kslaw.com
`Holmes J. Hawkins III
`Email: hhawkins@kslaw.com
`Benjamin Kent Jordan
`Email: kjordan@kslaw.com
`KING & SPALDING LLP
`1180 Peachtree Street
`Atlanta, Georgia 30309
`Facsimile: (404) 572-5100
`
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 13
`
`General Electric Co. 1015 - Page 13
`
`

`
`Melissa R. Smith
`TX Bar No.: 24001351
`Email: melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`
`COUNSEL FOR DEFENDANT
`LANDIS+GYR TECHNOLOGIES, LLC
`
`By:
`
`
`Cabrach J. Connor
`
`
`
`
`
`
`
`PLAINTIFF’S LPR 4-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS TO GE 14
`
`General Electric Co. 1015 - Page 14
`
`

`
`EXHIBIT A
`
`General Electric Co. 1015 - Page 15
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`
`GroupChatter presently asserts GE infringes claims 1, 2, 3, 8, 10, 13, 14, 17, 18, 20, 21, 22, 29, and 30
`directly and indirectly. This chart sets forth Plaintiff’s infringement contentions relating to the ’959 Patent and GE
`Accused Instrumentalities. Identification of the Accused Instrumentalities is made here with as much specificity as
`possible with model names or numbers and methods provided if known. Specific configurations and deployed
`elements of the GE Accused Instrumentalities may differ, and the specifics of each deployment are not generally
`available to the public.
`
`These contentions articulate the structure and acts that constitute direct infringement of the ’959 patent and
`identify specifically where each element of each asserted claim is found within each Accused Instrumentality. This
`disclosure is not intended to describe all acts of inducement or contributory infringement GE has and continues to
`commit by providing, developing, installing, testing, deploying, and directing the use of GE Accused
`Instrumentalities by GE customers and end users. As discovery proceeds, these contentions and the specific Itron
`components identified here as meeting certain claim elements or performing certain claim steps may change in
`view of claim construction and additional information learned through discovery.
`
`
`Claim 1 – GE Systems
`
`GroupChatter contends the preamble is not limiting. In the event the preamble is
`found to impose a meaningful limitation on the scope of the claim, the GE Accused
`Instrumentalities as described in more detail below. GE provides hardware, firmware,
`software, and other items purchased are licensed from GE. Hardware includes for
`example, collectors, transmitters, and endpoints. Accused Instrumentalities include GE
`Grid IQ AMI systems, Grid Solutions, Grid IQ AMI P2MP Solution, GE’s MDS wireless
`product portfolio, MDS PulseNET, GE Grid IQ Connect SaaS, Grid IQ Connect, GE
`Wireless AMI, Grid IQ Network Communications Platform, RF Mesh, Smart Grid
`Communications Solutions, Communications Infrastructure for Grid Applications, MDS
`Orbit Platform, SMOS Smart Metering Operations Suite, GE Digital Energy Grid IQ
`
`1 (a) A method of alerting a
`group of recipients over a
`wireless network,
`
`each recipient
`comprising
`
` a
`
` mobile device
`capable of
`transmitting and
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 1 OF 118
`
`General Electric Co. 1015 - Page 16
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`receiving data,
`
`the method
`comprising the steps
`of:
`
`Solution, GE DRMS and related or analogous systems (collectively referred to herein as
`Grid IQ, GE Grid IQ AMI, GE System(s) or similar terms). Accused Instrumentalities
`further include storage (e.g., servers, databases, etc.,), programs (e.g., applications, etc.),
`hardware (e.g., transmitters, repeaters, collectors, communication modules, endpoints)
`referred to herein (by way of example) that relate to the patent claims as outlined herein to
`provide customers with AMI products, services, and solutions. Accused Instrumentalities
`include GE Grid IQ AMI systems and related subsystems (e.g., Grid Solutions). To the
`extent the preamble is limiting, GE (and/or GE customers) performs the method, (including
`alerting groups of recipients) by making, using, selling, and operating Grid IQ AMI
`systems and analogous systems.
`
`
`
`Accused Instrumentalities include deployments operated or built with partners (e.g.,
`Silver Spring Networks, Consert, etc.).
`
`
`
`Exhibit 29.
`
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 2 OF 118
`
`General Electric Co. 1015 - Page 17
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`
`
`Exhibit 29.
`
`The Grid IQ AMI P2MP Solution has exceptional coverage and supports
`multiple applications on the same network. This single network features
`pervasive coverage for metering and distribution grid monitoring and
`sensing regardless of whether the devices are battery operated or powered.
`Each access point in the system supports thousands of connected devices
`providing unicast, downlink multicast and broadcast capabilities and
`supports group configuration and control. The ability to leverage a
`common network
`infrastructure
`for multiple applications provides
`immediate and significant ROI.
`
`Exhibit 1.
`
`
`Remote “Endpoint“ devices, such as utility smart meters or fault indicators,
`communicate directly with the “Access Points” deployed either on towers
`or utility poles allowing for flexible low cost deployments. An Endpoint a is
`device containing a small RF module designed for easy integration and
`ultra-low power operation in Smart Meters or sensors. A network of Access
`Points can provide redundant coverage for a wide area, such as a city or a
`county and has industry leading range enabling ubiquitous coverage. The
`Access Point is designed for indoor or outdoor operation and can be easily
`deployed on buildings, utility poles or communication towers enabling low
`cost pervasive coverage in the most challenging environments.
`
`Exhibit 1.
`
`from wellhead monitoring to utility substation automation, our wireless
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 3 OF 118
`
`General Electric Co. 1015 - Page 18
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`devices are packaged for industrial environments and have been rated and
`tested to harsh industrial specifications. Our wireless networks carry serial
`and IP/Ethernet traffic, plus analog and digital I/O signals connected
`directly to field devices and sensors, accommodating an extensive array of
`industrial protocols.
`
`Exhibit 16.
`
`
`Grid Solutions, a General Electric and Alstom joint venture, is serving
`customers globally with over 20,000 employees in approximately 80
`countries. Grid Solutions helps enable utilities and industry to effectively
`manage electricity from the point of generation to the point of consumption,
`helping to maximize the reliability, efficiency and resiliency of the grid.
`
`Exhibit 16.
`
`
`
`Exhibit 32.
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 4 OF 118
`
`General Electric Co. 1015 - Page 19
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`Exhibit 32.
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 5 OF 118
`
`General Electric Co. 1015 - Page 20
`
`

`
`
`
`
`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`Exhibit 9.
`
`
`Exhibit 9.
`
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
`
`
`’959 CHART - PAGE 6 OF 118
`
`General Electric Co. 1015 - Page 21
`
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
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`Exhibit 24.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 7 OF 118
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`General Electric Co. 1015 - Page 22
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
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`Exhibit 25.
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`Exhibit 34.
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`The kV2c+ with CellReader Communications Module uses digital cellular
`technology to provide public radio frequency (RF) communications coupled
`with the best available and most cost effective wireless coverage in the US
`and Canada. It features both scheduled reads and on-demand reads via a
`wireless two-way communications network and has both packet data
`transmission capabilities (faster and more reliable than traditional
`transmission modes) as well as circuit-switched data communications
`(traditional dial-up modem). The CellReader module can operate on any
`public GSM network, such as those operated by Rogers Wireless, T-Mobile
`and AT&T Wireless.
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`Exhibit 34.
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`GE Energy’s kV2c+ meter with integrated CellReader Communications
`Module from Trilliant Networks uses digital cellular technology to make all
`meter information available any time, anywhere. This solution is ideal for
`commercial and industrial meter applications that need an upgrade path
`from analog cellular and telephone line solutions to a digital cellular
`solution. This solution is also well suited for hard-to-read, load research,
`power quality applications, and demand response applications.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 8 OF 118
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`General Electric Co. 1015 - Page 23
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
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`
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`Exhibit 34.
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`GE Energy’s I-210TM Singlephase Meter with integrated Itron® 52ESS
`ERT® is an electronic watthour meter designed for measuring and
`communicating energy consumption in singlephase services to Itron
`reading systems. By developing a single board that contains the metering
`and the ERT functionality, GE Energy continues its strong tradition of
`reliability and affordability.
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`Exhibit 35.
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`Exhibit 36.
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`GE Energy’s I-210+ with integrated DCSI UMT-R (Universal Meter
`Transponder—Residential) provides remote two-way access to consumption
`and voltage data contained in the meter through the TWACS® fixed
`network power line communication system. This combined solution brings
`significant value to the marketplace.
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`Exhibit 36.
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`Exhibit 37.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 9 OF 118
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`General Electric Co. 1015 - Page 24
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`GE Energy’s I-210+ meter with integrated Silver Spring Networks (SSN)
`Network Interface Card (NIC) combines the accuracy and flexibility of our
`latest single-phase metering platform with the power and flexibility of
`SSN’s two-way Smart Energy Network. This GE/SSN I-210+ meter brings
`significant value to the market- place for today and into the future.
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`Exhibit 37.
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`Exhibit 38.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 10 OF 118
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`General Electric Co. 1015 - Page 25
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
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`Exhibit 38.
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`Exhibit 39.
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`Exhibit 39.
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`Exhibit 10.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 11 OF 118
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`General Electric Co. 1015 - Page 26
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
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`Exhibit 10.
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`Exhibit 10.
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`Exhibit 10.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 12 OF 118
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`General Electric Co. 1015 - Page 27
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
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`Exhibit 9.
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`SMOS (Smart Metering Operations Suite) provides visibility to data
`retrieved from network management services, a network of Access Points
`and devices. SMOS also provides the back-office integration functions that
`deliver data from across the network to core operational systems, such as
`Outage Management Systems and other applications. SMOS supports
`various industry standard interfaces and protocols.
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`Exhibit 1.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 13 OF 118
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`General Electric Co. 1015 - Page 28
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
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`Exhibit 1.
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`Exhibit 1.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 14 OF 118
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`General Electric Co. 1015 - Page 29
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 15 OF 118
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`Exhibit 2.
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`General Electric Co. 1015 - Page 30
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
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`Exhibit 4.
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`Exhibit 64.
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 16 OF 118
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`General Electric Co. 1015 - Page 31
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`GroupChatter, LLC v. GE, Civil Action No. NO. 1:16-cv-00486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
`
`
`
`Grid IQ Connect is a services-based program offered by GE’s Solution as a
`Service business. It offers customers incredible value from accelerated
`benefits due to the speed at which the system is deployed, technology risk
`mitigation and by providing smaller utilities access to technology otherwise
`not affordable in traditional project delivery models. The offering consists
`of five primary services to enhance the effectiveness of advanced meter
`infrastructure systems and other aspects of grid operations. These services
`include meter data services, pre-payment services, outage detection and
`notification services, asset monitoring services and consumer portal
`services.
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`Exhibit 4.
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`GE's SaaS offerings are available via three levels of delivery modes—total
`managed services, software as a service and deployment at the customer
`site. Additionally, its advanced application solutions provide municipal
`utilities with comprehensive outage management (Grid IQ Restore) and
`demand response capabilities (Grid IQ Respond). Currently, Grid IQ
`Connect is being utilized by Electric Cities of Georgia, the city of Norcross,
`Ga., and the city of Leesburg, Fla.
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`Exhibit 4.
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`“Here’s General Electric’s smart grid-as-a-service pitch. The city utility of
`Norcross, Ga. wants a smart grid, but doesn’t have the money to buy one
`for itself. GE’s Grid IQ Solutions as a Service will build it for a monthly
`fee, and then run it all from a giant cloud computing platform in Atlanta.”
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`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CH