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
`
`
`
`network client.
`
`
`
`10. A method as claimed in claim
`1, further comprising the steps of:
`
`See Claim 1 above.
`
`See Claim 1(a – g) above.
`
`GE determines which recipients have not yet received the message from responses
`received from grouped recipients.
`
`Outage management is a valuable example of the information used by GE system
`users when this claim is performed.
`
`
`
`
`Status notifications are sent to the network client indicating response or
`acknowledgement receipt status of the message.
`
`See Claim 1(f-g) above.
`
`See Claim 1(a-g) above.
`
`Grid IQ systems broadcast messages with message identifiers (e.g., event IDs,
`message numbers, etc.) and associate received responses with message identifiers.
`
`
`
`Stored procedure calls are associated with received responses from Grid IQ
`
`10(a) receiving responses to the
`message from the recipients having
`the selected group address and
`determining which recipients have
`not yet received the message; and
`
`10(b) sending message progress
`notifications to the network client
`indicating how many of the
`recipients corresponding to the
`selected group address need to
`acknowledge receipt of the
`message.
`
`13. A method as claimed in claim
`1,
`
`
`wherein the message
`broadcast to the recipients
`corresponding to the selected
`group address comprises a
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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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
`
`
`
`endpoints.
`
`message identifier, and
`further comprising the steps
`of:
`
`
`associating received
`responses from recipients
`having the selected group
`address with the message
`corresponding to the
`message identifier.
`
`14. A method as claimed in claim
`1, wherein the storing step
`comprises the steps of:
`
`
`See Claim 1 above.
`
`
`
`storing at least one of a
`symbolic name and a
`corresponding encryption
`key for each of a number of
`group addresses; and
`
`replicating via wireless
`transactions the at least one
`of symbolic name and a
`corresponding encryption
`key in a memory device of
`the recipient for each of the
`group addresses to which a
`
`
`
`Exhibit 1.
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 107 OF 118
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`General Electric Co. 1015 - Page 122
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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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`recipient belongs.
`
`Exhibit 1.
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 108 OF 118
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`General Electric Co. 1015 - Page 123
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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
`
`
`
`
`
`
`
`
`
`Exhibit 8.
`
`Exhibit 13.
`
`
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`’959 CHART - PAGE 109 OF 118
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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
`
`
`
`Exhibit 13.
`
`
`
`See Claim 1(a-g) above.
`
`
`
`GE Grid IQ systems include a database maintained in operation for storing data
`relating to the recipients, the groups, and correspondence between recipients and
`groups.
`
`See, e.g., Claim 1(b) above, describing how the GE system stores data relating to
`recipients.
`
`Grid IQ head-end system components, associated databases, and data repositories
`are used to maintain and store recipient data.
`
`17. A method as claimed in claim
`1, wherein the storing step further
`comprises the steps of:
`
`
`17(a) maintaining a database for
`storing data relating to the
`recipients, the groups and the
`memberships of recipients to
`various ones of the groups; and
`
`
`17(b) performing wireless
`configuration transactions to
`synchronize the memories of
`respective ones of the recipients
`
`GE Grid IQ systems perform “on-air” wireless configuration transactions and
`firmware downloads to synchronize with the GE database GE meter firmware,
`configurations, etc.
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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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 and the Accused Instrumentalities discussed above regarding the wireless
`network elements of claim 1 are used to perform wireless synchronization and
`configuration. Various Grid IQ systems may communicate with endpoints to
`configure particular functions or modules, and these steps may be carried out by
`specific parts of the Grid IQ deployment that are not publicly known.
`
`See detail for claims 1 and 17 above. GE Grid IQ systems replicate encryption keys
`to recipients and receive related acknowledgements.
`
`
`
`with the database.
`
`18. A method as claimed in claim
`17, wherein the performing step
`comprises the steps of:
`
`
`replicating at least one of
`group membership
`configuration information
`and group encryption keys to
`the recipients; and
`
`receiving confirmation
`responses from the recipients
`relating to updating of the at
`least one of group
`membership configuration
`information and group
`encryption keys in their
`respective memories.
`
`20. A method as claimed in claim
`1, wherein the transmitting step
`comprises the step of immediately
`replying to the communication
`
`See Claim 1(a-g) above and (a-c) for further detail regarding the transmitting step.
`
`Acknowledgements responsive to the communication from the network client
`confirm receipt and indicate recipients having the selected group address. The head-
`
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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
`
`
`
`end system responds to the network client with acknowledgements to the Grid IQ
`administrative console or management screen confirming transmission was initiated
`to group of endpoints.
`
`
`
`See claim 1 above including detail regarding broadcasting step. GE Grid IQ
`systems encrypt messages using encryption keys shared with group members.
`
`
`
`See claim 1 above. Grid IQ systems broadcast messages with assigned message
`sequence numbers. Grid IQ systems receive acknowledgments from recipients with
`primary address and sequence numbers. For example:
`
`
`from the network client requesting
`wireless transmission of the
`message to the selected group
`address with the identifying
`addresses of the recipients having
`the selected group address.
`
`21. A method as claimed in claim
`1, wherein the step of broadcasting
`the message comprises the step of:
`
`
`encrypting the message using
`an encryption key assigned
`to the selected group address
`and provided to the
`recipients sharing the
`selected group address.
`
`22. A method as claimed in claim
`1,
`
`
`wherein the step of
`broadcasting the message
`comprises the step of
`assigning a message
`sequence number to the
`message, and
`
`the step of receiving the
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 112 OF 118
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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
`
`
`
`acknowledgement responses
`from the recipients
`comprises the step of
`providing in at least one of
`the acknowledgment
`responses the primary
`identifying address of the
`corresponding one of the
`recipients and the message
`sequence number to uniquely
`identify a specific group
`message at the corresponding
`one of the recipients.
`
`29. A method as claimed in claim
`1, wherein the broadcasting step
`comprises the step of transmitting a
`group alert message to the
`recipients sharing the selected
`group address via the paging
`network using a single network
`transaction.
`
`
`
`See Claim 1(a-g) above and (a-c) for further detail regarding the transmitting step.
`
`“Actions” are created and performed to broadcast a group alert to a group of
`recipients in a single network transaction.
`
`’959 Patent – Claim 30 – GE Grid IQ System
`
`30 (a) An apparatus for alerting a
`group of recipients over a wireless
`network,
`
`To the extent the preamble is limiting, the GE Accused Instrumentality identified
`and detailed with respect to claim 1 above is an apparatus for alerting a group of
`recipients over a wireless network.
`
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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
`
`
`
`
`See 1(a) above. GE endpoints comprise a mobile device for communication on a
`wireless network. The particular wireless network and protocol depends upon
`the deployment. But Grid IQ and Choice Connect systems are capable of two-
`way functionality.
`
`
`
`
`
`
`See claim 1 above, including particularly claim 1(a) – 1(b).
`
`GE’s Grid IQ infrastructure includes a memory device (or an interface to an
`external memory device) for storing, for each endpoint device, an assigned
`primary identifying address.
`
`
`
`each recipient comprising a mobile
`device having a two-way wireless
`communication function, the
`apparatus comprising:
`
`30 (b) at least one of
`
`
`a memory device and
`
`
`
`an interface to an external
`memory device for storing for
`each recipient an assigned
`primary identifying address and
`
`one or more group addresses
`that are shared with selected
`ones of the other recipients;
`
`See 1(c) above.
`
`
`
`30 (c) a network client interface for
`receiving a communication from a
`network client requesting wireless
`transmission of a message to
`recipients sharing a selected one of
`the group addresses;
`
`
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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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`30 (d) a processing device connected
`to the memory device, the network
`client interface and the wireless
`communication network interface, the
`processing device being programmed
`to
`
`
`See 1(d) above.
`
`Transmissions of group communications include unique identifiers for individual
`smart meters (e.g., Device ID’s or Network Addresses.)
`
`The base station broadcasts actions to a group of smart meters via a wireless
`network.
`
`
`
`transmit a communication to
`the network client comprising
`group information relating to
`the selected group addresses,
`
`the group information
`comprising
`
`
`at least one of the number of
`the recipients having the
`selected group address and
`
`
`
`the identifying addresses of the
`recipients having the selected
`group address,
`
`
`
`
`
`30 (e) broadcast the message to the
`selected group address via the
`wireless communication network and
`the wireless communication network
`
`See 1(e) and 30 (c) above.
`
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`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 7,969,959
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`
`
`interface,
`
`
`30 (f) receive acknowledgment
`responses from the recipients sharing
`the selected group address via the
`wireless communication network in
`response to the message,
`
`
`See 1(f) above.
`
`the acknowledgement
`responses each
`comprising at least one
`of an indication of
`successful receipt of the
`message and an
`indication that the
`message was read by the
`recipient that transmitted
`the corresponding
`acknowledgement
`response,
`
`See 1(g) above.
`
`
`
`30 (g) store, for each recipient having
`the selected group address,
`
`
`a recipient identifier and
`
` a
`
` corresponding message
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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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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`
`
`alert status indicator
`indicating at least one of
`
`the message has been
`received by that
`recipient, and the
`message has been sent
`but not yet received by
`that recipient, depending
`on when that recipient
`transmitted its
`corresponding
`acknowledgement
`response, and
`
`
`
`See 1(g) above.
`
`
`
`30 (h) provide at least one of
`
`the acknowledgment responses
`and
`
`
`the stored message alert status
`indicator for each of the
`recipients to the network client
`
`to determine message
`alert status for each of
`the recipients in the
`
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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
`
`
`
`group corresponding to
`the selected group
`address including at least
`
`identifying which of the
`recipients received the
`message and which of
`the recipients have not
`yet received the message.
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE OF INFRINGEMENT CONTENTIONS - GE
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`’959 CHART - PAGE 118 OF 118
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`General Electric Co. 1015 - Page 133
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`

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`EXHIBIT B
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`General Electric Co. 1015 - Page 134
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`

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`
`
`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`GroupChatter presently asserts GE infringes claims 1, 2, 3, 4, 5, 10, 11, 12, 13, 14, 15, 16, 20, and 21,
`directly and indirectly. This chart sets forth Plaintiff’s infringement contentions relating to the ’740 Patent and the
`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 ’740 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 GE
`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.
`
`
`1. (a) A method of alerting a group of
`recipients over a wireless network and
`providing acknowledged group
`messaging, each recipient comprising a
`mobile device capable of transmitting
`and receiving data, the method
`comprising the steps of:
`
`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 and generally described by GE as “Smart Metering Systems”
`operate to perform each and every step of the claimed method of alerting
`a group of recipients over a wireless network and providing
`acknowledged group messaging with two-way endpoints.
`
`See GE claim chart – ’959 Chart at 1 (a).
`
`GE performs the method by operating Grid IQ and related systems
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 1 OF 82
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`General Electric Co. 1015 - Page 135
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`(described in the ’959 Chart) which include one or more wireless
`networks as described in the ’959 Chart. The GE systems include a
`wireless network for alerting groups of recipients. GE uses the systems to
`alert groups of recipients over the wireless network and provide
`acknowledged group messaging. Endpoints (e.g., meters) with modules
`acknowledge receipt of messages.
`
`
`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 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
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 2 OF 82
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`with partners (e.g., Silver Spring Networks, Consert, etc.).
`
`
`
`
`Exhibit 29.
`
`
`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
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 3 OF 82
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`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 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.
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 4 OF 82
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`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 INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 5 OF 82
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`
`
`Exhibit 32.
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`’740 CHART - PAGE 6 OF 82
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`General Electric Co. 1015 - Page 140
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`Exhibit 9.
`
`
`Exhibit 9.
`
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`Exhibit 24.
`
`
`
`
`Exhibit 25.
`
`
`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
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`
`
`Exhibit 34.
`
`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.
`Exhibit 34.
`
`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
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`also well suited for hard-to-read, load research, power
`quality applications, and demand response applications.
`Exhibit 34.
`
`
`
`
`
`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.
`Exhibit 35.
`
`
`
`
`Exhibit 36.
`
`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.
`Exhibit 36.
`
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`
`
`
`Exhibit 37.
`
`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.
`Exhibit 37.
`
`
`
`
`
`
`
`Exhibit 38.
`
`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`Exhibit 38.
`
`
`Exhibit 39.
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`
`
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`
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`Exhibit 39.
`
`
`
`
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`
`
`
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`
`
`Exhibit 10.
`
`
`Exhibit 10.
`
`
`
`Exhibit 10.
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`
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`
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`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`Exhibit 10.
`
`
`
`
`
`
`
`Exhibit 9.
`
`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
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`applications. SMOS supports various industry standard
`interfaces and protocols.
`Exhibit 1.
`
`
`
`
`
`
`
`Exhibit 1.
`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`Exhibit 1.
`
`
`
`
`
`
`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`Exhibit 2.
`
`
`Exhibit 4.
`
`
`
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`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`
`
`
`
`
`Exhibit 64.
`
`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
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`services, asset monitoring services and consumer portal
`services.
`
`
`
`
`
`
`
`
`
`Exhibit 4.
`
`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.
`Exhibit 4.
`
`“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.”
`
`Exhibit 29.
`
`“General Electric has been slow to announce new
`customers for the smart-grid-as-a-service offering it
`
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`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`launched in late 2011. But that doesn’t mean it’s not
`filling up its dance card with small municipal and rural
`cooperative utilities interested in a subscription-based
`smart grid -- or that the market for this kind of novel
`deployment may not be nearing an inflection point.
`Exhibit 30.
`
`
`
`
`
`“In the past three months, GE has named the municipal
`utilities of Holly Spring, Miss. and Skiatook, Okla. as
`customers, adding their names to those of flagship
`customers Norcross, Ga. and Leesburg, Fla. Three or four
`more customers are using the service, another three or
`four signed up in the fourth quarter of 2013, and an
`additional three are expected to sign up in the near
`future,”
`
`Exhibit 30.
`
`“Grid IQ Connect is a services-based program offered by
`GE’s Solution as a Service (SaaS) 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
`
`
`
`PLAINTIFF'S LPR 4.1 DISCLOSURE INFRINGEMENT CONTENTIONS
`
`
`’740 CHART - PAGE 20 OF 82
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`General Electric Co. 1015 - Page 154
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`
`
`
`GroupChatter, LLC v. GE Civil Action No. 15-cv-486-WSD
`Plaintiff’s LPR 4.1 INFRINGEMENT CONTENTION CLAIM CHART – U.S. PATENT NO. 8,199,740
`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.”
`
`
`
`
`
`
`
`Exhibit 31.
`
`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 managemen