`
`
`
`
`
`
`
` Exhibit A - 1
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`U.S. Patent No. 6,836,654
`The asserted claims of the ’654 patent are anticipated and/or obvious in view of the User’s Manual for the Nokia 9000i
`Communicator, Issue 1.1 (“Nokia”), either alone or combination with the knowledge of a person of ordinary skill in the art (“POSA”),
`or in combination with one or more other references disclosed in Samsung’s Invalidity Contentions, including the other charted
`references, U.S. Patent Publication No. US2002/0147028 (“Alos”), U.S. Patent No. 4,868,846 (“Kemppi”), U.S. Patent No. 5,864,757
`(“Parker”), and/or U.S. Patent No. 5,913,175 (“Pinault”).
`
`Nokia was distributed along with the 9000i Communicator device at least as of October 1997. Therefore, Nokia qualifies as prior art
`under pre-AIA 35 U.S.C. § 102(b). Alos was filed on December 11, 1998, and was published on October 10, 2002. Alos therefore
`qualifies as prior art under pre-AIA 35 U.S.C. § 102(e). Kemppi issued on September 19, 1989, and therefore qualifies as prior art
`under pre-AIA 35 U.S.C. § 102(b). Parker issued on January 26, 1999, from an application filed on December 12, 1995. Parker
`therefore qualifies as prior art under pre-AIA 35 U.S.C. §§ 102(a) and (e). Pinault was filed on December 20, 1996, and issued on
`June 15, 1999. Pinault therefore qualifies as prior art under pre-AIA 35 U.S.C. § 102(b).
`
`Claim Language
`1(pre) A mobile
`radiotelephony device,
`comprising:
`
`Nokia
`To the extent the preamble is determined to be limiting, Nokia describes a mobile device for making
`phone calls, which discloses the claimed “mobile radiotelephony device”:
`
`
`Nokia at 1-1 (displaying a mobile phone).
`
`
`
`
`1
`
`
`
`
`
`Nokia
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Id.1
`
`
`Claim Language
`
`1(a) blocking means for
`preventing a normal operation
`of the mobile radiotelephony
`device, wherein the normal
`operation includes a
`processing of outgoing calls;
`
`Nokia
`The Nokia 9000i Communicator, with a mobile phone, messaging device, Internet access
`terminal and palmtop organizer all in one compact unit, is more than just the sum of its
`components.
`
`
`For example, when placing a call from the phone interface, although you may be scrolling
`the keys on the keypad or performing a search with the communicator cover closed, the
`search engine will be searching the information within the communicator interface.
`
`The phone interface is designed for quickly making and receiving calls. It looks and
`operates like other Nokia mobile phones (except that the earpiece and microphone are on
`the backside of the device).
`
`Id. at 1-2.
`
`See also id. at Chapter 4 – Telephone.
`
`Nokia discloses this limitation. Nokia describes a blocking means for preventing a normal operation
`of the mobile radiotelephony device wherein the normal operation includes a processing of outgoing
`calls.
`
`For example, Nokia describes “locking” the communicator to “prevent outgoing calls from being
`made” and “unlocking” the communicator with a lock code. Nokia at 10-2 through 10-4.
`
`
`After the communicator has been locked, it cannot be used until the correct lock code is
`given. Incoming voice calls can, however, be answered via the phone interface.
`
`
`1 Emphasis added unless otherwise specified.
`
`
`
`2
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`
`
`Id. at 10-2.
`
`Nokia also teaches that this lock mode (which prevents outgoing calls) is initiated automatically after
`a predetermined elapsed time, or can be initiated manually:
`
`
`If autolock is on, the communicator will lock automatically after the defined inactivity
`period. Press Lock system to lock the device manually at any time.
`
`
`Id.
`
`
`Autolock period — Autolock off (default) / 1 / 2 / 5 / 10 / 15 minutes
`This setting determines the security time-out period, after which the system will lock.
`The timer is reset by any input, calls or data transfer/printing activity.
`
`
`Id. at 10-3.
`
`See also id. at 13-11 and 13-12 (“Security options,” including the “System lock”).
`
`Nokia also discloses blocking means for preventing a normal operation of the mobile radiotelephony
`device wherein the normal operation includes a processing of outgoing calls. For example, Nokia
`discloses a blocking means connected to a PIN code for the SIM card:
`
`
`IMPORTANT! If you enter the PIN code incorrectly three times in a row, you will need a
`PUK (PIN Unblocking Key) code to unblock the SIM card. When the SIM card is blocked,
`you cannot make or receive any calls (including faxes, short messages, e-mail, etc.), except
`emergency calls. Otherwise, the communicator can be used normally. If you misplace or
`forget your PIN code, contact your network operator.
`
`
`Id. at 10-3.
`
`
`
`
`3
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`1(b) timing means for
`activating the blocking means
`in response to the mobile
`radiotelephony device being
`inactive during the normal
`operation of the mobile
`radiotelephony device for a
`defined period of time
`subsequent to a mounting of a
`linked user identification
`module inside the mobile
`radiotelephony device; and
`
`Nokia
`For example, Nokia also discloses a blocking means connected to mounting a valid SIM card:
`
`
`A valid SIM card (supplied by your network operator) is required for making and receiving
`calls.
`
`The network operator may prevent the use of the communicator with any other but the
`operator’s own SIM cards. If an unacceptable SIM card is inserted, the message INVALID
`SIM CARD will be displayed. Should this happen, contact your retailer or network operator.
`
`
`Id. at 2-2; see also 4-4 (“An activated SIM card must be inserted” to make phone calls).
`
`Nokia discloses this limitation. Nokia describes timing means for activating the blocking means in
`response to the mobile radiotelephony device being inactive during the normal operation of the
`mobile radiotelephony device for a defined period of time subsequent to a mounting of a linked user
`identification module inside the mobile radiotelephony device.
`
`For example:
`
`Nokia teaches an “Autolock period” in which the device is automatically placed in the locked state
`after a period of inactivity. Nokia at 10-2 and 10-3.
`
`
`If autolock is on, the communicator will lock automatically after the defined inactivity
`period. Press Lock system to lock the device manually at any time. . . .
`
`After the communicator has been locked, it cannot be used until the correct lock code is
`given. Incoming voice calls can, however, be answered via the phone interface.
`
`
`Id.
`
`Nokia also explains that the inactivity period is a “defined period of time”:
`
`
`
`
`4
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`Autolock period — Autolock off (default) / 1 / 2 / 5 / 10 / 15 minutes
`
`This setting determines the security time-out period, after which the system will lock. The
`timer is reset by any input, calls or data transfer/printing activity.
`
`
`Id. at 10-3; see also 13-12.
`
`Further, Nokia’s timing means is only activated “subsequent to a mounting of a linked user
`identification module inside the mobile radiotelephony device.”
`
`First, Nokia teaches that a linked SIM card is required for making and receiving calls:
`
`
`A SIM (Subscriber Identity Module) card is a “smart chip” that is used with all handsets
`operating on GSM networks. The SIM contains all the information the GSM1900 network
`needs to identify the network user and also performs specific functions required by the
`network. Among other things, the SIM card contains subscriber and billing information,
`makes periodic location updates with the network, and provides enhanced security
`features.
`
`The SIM card can also store contact information. The number of contacts that can be stored
`on a SIM will vary from manufacturer to manufacturer. The SIM memory is referred to as
`Memory A, and the phone memory as Memory B. You can copy contact information from
`one memory location to the other using the phone interface Menu 8 3, see Chapter 13
`"Phone interface: Detailed menus list - Memory functions (Menu 8)" on page 13-13.
`
` A
`
` valid SIM card (supplied by your network operator) is required for making and receiving
`calls.
`
`The network operator may prevent the use of the communicator with any other but the
`operator’s own SIM cards. If an unacceptable SIM card is inserted, the message INVALID
`SIM CARD will be displayed. Should this happen, contact your retailer or network operator.
`
`
`
`
`
`5
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`Id. at 2-2; see also 4-4 (“An activated SIM card must be inserted” to make phone calls).
`
`Second, Nokia teaches that the Autolock default state is “off.”
`
`
`Autolock period — Autolock off (default) / 1 / 2 / 5 / 10 / 15 minutes
`
`Id. at 10-3. Thus, to use the timing means in Nokia, the timing means must be turned on and set to
`one of the predefined time limits by the user:
`
`
`To use the Lock system key in System security, the Autolock period setting (defined in
`System security, Settings) must be set to On.
`
`Highlight Autolock period and press Change. Enter the correct lock code (provided in the
`sales package) to change the setting status.
`
`Id.at 10-2. Because the “PIN code request” (which requests the “PIN (Personal Identity Number)” of
`the SIM card) is default “on,” the device must first have a mounted SIM card before the user can
`move to the security settings and activate the Autolock feature:
`
`
`PIN code request — On (default) / Off
`
`If you set the PIN (Personal Identity Number) code request on, the system requests the code
`every time the phone interface is turned on (by pressing []). You can also turn the PIN code
`request on or off in the phone interface Security options menu (Menu 5 1). This setting
`cannot be changed if the phone interface is switched off.
`
`Note: Some SIM cards do not allow you to turn the PIN code request off.
`
`Id. at 10-3.
`
`
`The PIN code is supplied with the SIM card (i.e., the network operator who activates your
`
`
`
`6
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`SIM will give you the PIN code). When the PIN code request is enabled, the code is required
`each time the phone interface is switched on. The PIN code request must be turned on to
`change the code.
`
`Id. at 10-4.
`
`Additionally, Nokia teaches a feature for linking particular SIM cards to a particular device
`(communicator)—“SIM change security”:
`
`
`SIM change security – On / Off (default)
`
`When active, this security option checks whether the SIM card in the communicator has
`been changed. The check is made every time the phone interface is switched on. The SIM
`change security option can also be activated in the phone interface Security options menu
`(Menu 5 2).
`
`If the SIM card has been changed and the new SIM card has not previously been used with
`your communicator, the communicator locks itself until the lock code, supplied with the
`communicator sales package, is correctly entered. The communicator recognizes five
`different SIM cards as the owner’s cards.
`
`
`Id. at 10-3.
`
`Alternatively, it would have been obvious to POSA to improve the safety of a mobile phone by
`implementing a linked user identification module, e.g., a SIM card, in view of the other references
`cited in these Invalidity Contentions which disclose this limitation, including Alos, Kemppi, Parker,
`and/or Pinault.
`
`For example, Alos teaches:
`
`Alos describes a mobile radio-telephone terminal that is only activated if used with a SIM card
`
`
`
`7
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`storing information that matches corresponding information stored on the terminal, i.e., subsequent
`to a mounting of a linked user identification module inside the mobile radiotelephony device.
`
`Alos describes problems with prior art systems that allow usage of terminals with unauthorized SIM
`cards:
`
`
`In the first place, any subscriber having misappropriated a terminal could in some cases use it
`with his own SIM card. Provision is made to input, via a keypad on the terminal, an
`identification code word for each subscriber, called a PIN (personal identification number)
`but it can control only the usage of the associated SIM card and thus be ineffective against
`fraudulent usage of a terminal.
`
`
`Id. at ¶ 3.
`
`Alos aims to solve these problems by requiring the use of a SIM card that is linked to a terminal.
`Whether the correct SIM card is inserted is determined by comparing information on the SIM card
`(e.g., PIN and/or international mobile subscriber identity (“IMSI”) number) with information on the
`terminal:
`
`
`To this end the invention relates to a mobile radiotelephone terminal comprising radio
`means arranged to be activated by a chip card, the chip card comprising memory means
`containing a subscriber identification word and connected to an input of a comparator, the
`terminal comprising means for receiving the card, which are connected to the radio means,
`means for inputting a particular identification word, associated with the card, and
`arranged to be connected to the other input of the comparator, characterised in that it
`comprises means for matching it with the card, which are arranged to control the
`activation of the radio means from the subscriber identification word.
`
`
`Id. at ¶ 6.
`
`
`In another preferred embodiment the matching means comprise memory means containing
`
`
`
`8
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`data matched with the data contained in the memory means of the card, controlling
`comparator means arranged to read the memory means of the card and to authorise
`activation of the radio means only after the said match has been verified.
`
`Id. at ¶ 14.
`
`
`The card 10 comprises a comparator 11, actually a microprocessor, connected, once the card
`10 has been connected, to an input path from the output of the unit 3 via the connectors 4
`and 14. A second input path of the comparator 11 is connected to a memory 12 of the card
`10 comprising a user identification number, PIN, referenced 121, as well as other data of
`the same type such as IMSI (international mobile subscriber identity), referenced 122. The
`output of the comparator 11 commands the activation, via the connectors 4 and 14 of a radio
`transceiver unit 7 of the terminal 1. The activation/deactivation of the radio unit 7 is,
`moreover, controlled by a comparator 6 connected at the input, on the one hand, to the
`zone 122 (IMSI) of the memory 12 of the card 10 and, on the other hand, to a memory
`zone 522 of a memory 5 of the terminal 1, also containing the IMSI data. The functions of
`the unit 3 and of the comparator 6 are, in practice, carried out by a microprocessor 9.
`
`Id. at ¶ 18.
`
`It would have been obvious to a POSA to combine the teachings of Nokia and Alos such that the
`timing features in Nokia that result in a locked state after a set elapsed time of inactivity occurs
`subsequent to the mounting of a linked SIM card.
`
`For example, Kemppi teaches:
`
`Kemppi describes a “method for locking to the user’s card in a portable radio telephone.”
`Specifically, Kemppi teaches the mounting of a linked user identification module inside the mobile
`radiotelephony device to protect the phone from unauthorized use:
`
`
`The identification data (21) of the card (1) of the user authorized to use the radio
`
`
`
`9
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`telephone concerned are recorded in the non-erasable memory (5) of the processor (4),
`whereupon the radio telephone shifts into a mode locked to this card in such a way that its
`use is possible with only a certain card (1). By means of this method, protection is achieved
`against unauthorized use of the radio telephone.
`
`
`Id. at Abstract.
`
`
`According to the invention, the radio telephone thus has, available for the user to choose, a
`locking level the activation of which locks the telephone to the magnetic card in the card
`reader at that moment. The telephone functions completely normally as long as the correct
`card in in the telephone, but if an attempt is made to use the apparatus with a wrong card,
`its operation is prevented. If the telephone locked to a card is stolen together with the card,
`calls made using the card concerned can be prevented at the system level.
`
`Id. at 1:55-64.
`
`
`After the card is fed in, the identification code on the card is compared with the identification
`code recorded in the memory, and when the card is the correct one the telephone functions
`normally but, in the case of a wrong card, operation is prevented.
`
`Id. at 2:6-10.
`
`
`The method works in such a way that, when the user wishes to lock the radio telephone
`depicted as a block diagram in FIG. 1 to a certain magnetic card 1, he feeds the card into
`the magnetic card reader 3 in the telephone, activates the locking by pressing the locking
`key 8 in the keyboard, and keys in a four-digit locking code from the keyboard 7. At this
`time the telephone number (FIG. 2) or its part 12 on the card 1 is recorded, together with
`the locking code 22, into the indelible memory 5 of the telephone. (The data contained in
`the magnetic card depicted in FIG. 2 pertain to the use of the radio telephone system, which
`is not explained here in greater detail.)
`
`
`
`
`
`10
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`
`Id. at 2:54-66.
`
`It would have been obvious to a POSA to combine the teachings of Nokia and Kemppi such that the
`timing features in Nokia that result locked state after a set elapsed time of inactivity occurs
`subsequent to the mounting of a linked user identification card.
`
`For example, Parker teaches:
`
`Parker is directed to “methods and apparatus for locking communications devices,” and specifically
`describes that the “handset is capable of receiving a readable subscriber identity module (SIM)
`having a network (or other) ID and a codeword, and its operation is to be locked and unlocked with
`respect to the entity corresponding to the ID on the SIM.” Parker at Abstract. Accordingly, Parker
`teaches the mounting of a linked user identification module inside the mobile radiotelephony device
`to prevent unauthorized use:
`
`
`The problems described in the preceding section are solved by the methods and apparatus
`according to the present invention, which permit a telecommunications handset, or other
`device, to be electronically locked to a particular service provider, to a particular network, to
`a particular reseller, or even to an individual SIM.
`
`
`Id. at 3:49-54.
`
`
`Handset 20, using available technology, should be capable of receiving a conventional SIM
`40 containing information including a subscriber identification number including a
`network ID 42 (e.g., without limitation, International Mobile Subscriber Identification
`(IMSI) (incorporating MNC)). SIM 40 also should be capable of containing an authorization
`codeword 44. Processor 22 and circuitry (not shown) of handset 20 also should be capable
`of reading such values from, and writing new ones to, SIM 40.
`
`Id. at 7:40-49.
`
`
`
`
`11
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`At the time of purchase, handset 20 remains in the locked state in which it was manufactured.
`In this state, handset 20 preferably is not enabled for anything but making emergency
`telephone calls (e.g., 911 service in most areas of the United States of America), and for
`activating the subscriber's account. Activation of a subscriber's account is a precondition to
`unlocking handset 20 according to the method of the present invention.
`
`Id. at 7:66-8:6.
`
`
`If desired, the locking scheme according to the present invention could be maintained in
`effect for a handset 20 or other device indefinitely. For example, the device might,
`according to the present invention, be locked to a particular SIM 40 in order that the
`locked device be used only by the rightful owner or operator-in possession of that SIM 40.
`
`
`Id. at 11:32-37.
`
`It would have been obvious to a POSA to combine the teachings of Nokia and Parker such that the
`timing features in Nokia that result in locked state after a set elapsed time of inactivity occurs
`subsequent to the mounting of a linked user identification card, e.g., a SIM card.
`
`For example, Pinault teaches:
`
`Pinault is directed to a “method of making the use of a terminal of a cellular mobile radio system
`more secure, and corresponding terminal and user card,” and specifically describes the use of a
`linked user identification module:
`
`
`Making the use of a terminal more secure generally consists in proposing, in addition to the
`normal operating mode, a so-called locked mode in which the terminal can be used only
`with a user card with which it is “locked”, called the linked user card. In other words, a
`link is established between the terminal and a particular user card (the linked user card).
`
`
`Id. at 2:14-21.
`
`
`
`12
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`
`
`Indeed, the ’654 patent states that Pinault discloses the mounting of a linked user identification
`module inside the mobile radiotelephony device:
`
`
`U.S. Pat. No. 5,913,175, published Jun. 15, 1999 describes a method of protecting a
`radiotelephone which permits to avoid that the lost or stolen telephone can be used
`by a third party with another user identification module. This method comprises
`establishing a link between the device and a specific user identification module and
`blocking the normal operation of the device when the user identification module that is
`placed inside the device is not the one that is linked to the device.
`
`When the device is lost or stolen with the identification module to which it is linked, the user
`is to warn the operator so that the use of his identification module is blocked at network
`level.
`
`This means that the device can be freely used until the identification module to which it is
`linked is blocked via the network. This may take a certain period of time.
`
`
`’654 patent at 1:20-37.
`
`
`In the link creation phase, the terminal reads the user identification data stored on the
`user card and Stores it in its memory.
`
`During the link verification phase the terminal reads the user identification data Stored on the
`user card with which it is cooperating and compares it with that stored in its memory during
`the link creation phase, authorizing operation of the terminal or not according to whether the
`data read and that stored are identical or not.
`
`This prior art technique therefore prevents a terminal being used with a user card other than
`that with which it has been locked. This prevents unauthorized use of a terminal lost or stolen
`without its linked user card. This contributes to reducing the number of terminal thefts.
`
`
`
`13
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Nokia
`
`1(c) deblocking means for
`permitting the normal
`operation of the mobile
`radiotelephony device in
`response to a supply of a
`deblocking code to the mobile
`radiotelephony device
`subsequent to the mounting of
`the linked user identification
`module inside the mobile
`radiotelephony device and
`subsequent to the defined
`period of time.
`
`
`Pinault at 2:28-41.
`
`It would have been obvious to a POSA to combine the teachings of Nokia and Pinault such that the
`timing features in Nokia that result in locked state after a set elapsed time of inactivity occurs
`subsequent to the mounting of a linked user identification card, e.g., a SIM card.
`
`Nokia discloses this limitation. Nokia describes a user-inputted “lock code” causing the mobile
`device to disengage the lock state, which may be engaged after a “defined inactivity period,” as
`discussed above, which discloses “deblocking means for permitting the normal operation of the
`mobile radiotelephony device in response to a supply of a deblocking code to the mobile
`radiotelephony device…subsequent to the defined period of time”:
`
`Locking the communicator
`
`To prevent outgoing calls from being made, you can lock the communicator in the Security
`application’s main view. . . .
`
`If autolock is on, the communicator will lock automatically after the defined inactivity
`period. . . .
`
`Unlocking the communicator
`
`After the communicator has been locked, it cannot be used until the correct lock code is
`given. Incoming voice calls can, however, be answered via the phone interface.
`
`Nokia at 10-2; see also id. at 10-4 (describing the “Lock code”) and 13-12 (describing the “System
`lock”).
`
`As discussed above in connection with limitation 1(b), Nokia’s timing means is only activated
`“subsequent to a mounting of a linked user identification module inside the mobile radiotelephony
`
`
`
`14
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Nokia
`device,” and thus, the deblocking means must also be only used “subsequent to a mounting of a
`linked user identification module inside the mobile radiotelephony device”:
`
`
`A SIM (Subscriber Identity Module) card is a “smart chip” that is used with all handsets
`operating on GSM networks. The SIM contains all the information the GSM1900 network
`needs to identify the network user and also performs specific functions required by the
`network. Among other things, the SIM card contains subscriber and billing information,
`makes periodic location updates with the network, and provides enhanced security
`features.
`
`The SIM card can also store contact information. The number of contacts that can be stored
`on a SIM will vary from manufacturer to manufacturer. The SIM memory is referred to as
`Memory A, and the phone memory as Memory B. You can copy contact information from
`one memory location to the other using the phone interface Menu 8 3, see Chapter 13
`"Phone interface: Detailed menus list - Memory functions (Menu 8)" on page 13-13.
`
` A
`
` valid SIM card (supplied by your network operator) is required for making and receiving
`calls.
`
`The network operator may prevent the use of the communicator with any other but the
`operator’s own SIM cards. If an unacceptable SIM card is inserted, the message INVALID
`SIM CARD will be displayed. Should this happen, contact your retailer or network operator.
`
`
`Id. at 2-2; see also 4-4, and 10-2 through 10-4, discussed above.
`
`Alternatively, it would have been obvious to POSA to improve the safety of a mobile phone by
`implementing a linked user identification module, e.g., a SIM card, in view of the other references
`cited in these Invalidity Contentions which disclose this limitation, including Alos, Kemppi, Parker,
`and/or Pinault as described above in connection with limitation 1(b). Thus, in the combination(s), a
`POSA would have recognized that providing a code would not disengage the dial lock unless the
`linked SIM card has already been mounted. As discussed above, based on the teachings of Nokia
`
`Claim Language
`
`
`
`15
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`3. The mobile radiotelephony
`device of claim 1, wherein an
`activation of the blocking
`means prevents all
`transmissions of non-
`emergency outgoing calls and
`permits all transmissions of
`emergency outgoing calls.
`
`4. The mobile radiotelephony
`device of claim 1, further
`comprising:
`
`locking means for facilitating
`an activation of the block
`means by the timing means.
`
`Nokia
`and Alos, Kemppi, Parker, and/or Pinault, a POSA would have recognized that this restriction would
`have prevented the fraudulent use of the device and the SIM card.
`
`Nokia discloses this limitation. Nokia expressly contemplates permitting outgoing emergency calls
`while in the lock state.
`
`
`Note: When the communicator is locked, it may be possible to make a call via the phone
`interface to the emergency number programmed into your phone (e.g., 911 or other official
`emergency number).
`
`
`Id. at 10-2.
`
`See also id. at 10-3 (“When the SIM card is blocked, you cannot make or receive any calls (including
`faxes, short messages, e-mail, etc.), except emergency calls.”); 10-4 (“If you enter a wrong PUK
`code ten times in succession, the SIM card is rejected and you cannot make or receive any calls,
`except emergency calls.”); 13-11 (“When call restrictions, fixed dialing, closed user group, or system
`lock is in use, calls may be possible to certain emergency numbers in some networks (e.g., 911).”)
`
`In its Infringement Contentions, Uniloc points to the “Screen Timeout feature…which activates the
`lock screen/pattern/PIN entry screen after a predefined time period” as the claimed “locking means.”
`
`Nokia discloses this limitation. For example, as discussed above with respect to claim limitation
`1(b), Nokia describes a similar feature where the mobile device engages a lock state after passing of
`a set time that requires entry of a lock code in order to disengage the lock state:
`
`
`To prevent outgoing calls from being made, you can lock the communicator in the Security
`application’s main view.
`
`To use the Lock system key in System security, the Autolock period setting (defined in
`System security, Settings) must be set to On.
`
`
`
`
`16
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`5. The mobile radiotelephony
`device of claim 1, further
`comprising:
`
`connecting means for
`establishing a link between the
`mobile radiotelephony device
`and the linked user
`identification module.
`
`Nokia
`Highlight Autolock period and press Change. Enter the correct lock code (provided in the
`sales package) to change the setting status.
`
`If autolock is on, the communicator will lock automatically after the defined inactivity
`period. . . .
`
`After the communicator has been locked, it cannot be used until the correct lock code is
`given.
`
`
`Id. at 10-2.
`
`
`Access codes
`The communicator uses several access codes to protect against unauthorized use of your
`communicator and the SIM card. You can make changes to the lock code . . . from the
`communicator interface in the Security application by pressing Settings.
`
`
`Id. at 1-2.
`
`See also analysis above for claim limitation 1(b).
`
`In its Infringement Contentions, Uniloc points to the following functionality: “During activation,
`your SIM card is loaded with your subscription details.” Uniloc also points to the ability to “view the
`ICCID (SIM card number)” from within the settings menu.
`
`Nokia discloses this limitation. For example, Nokia describes a similar functionality of linking
`particular SIM cards to a particular device (communicator) via the “SIM change security” feature.
`
`
`SIM change security – On / Off (default)
`
`When active, this security option checks whether the SIM card in the communicator has
`been changed. The check is made every time the phone interface is switched on. The SIM
`
`
`
`17
`
`Nokia
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Nokia
`change security option can also be activated in the phone interface Security options menu
`(Menu 5 2).
`
`If the SIM card has been changed and the new SIM card has not previously been used with
`your communicator, the communicator locks itself until the lock code, supplied with the
`communicator sales package, is correctly entered. The communicator recognizes five
`different SIM cards as the owner’s cards.
`
`Nokia at 10-3.
`
`
`A SIM (Subscriber Identity Module) card is a “smart chip” that is used with all handsets
`operating on GSM networks. The SIM contains all the information the GSM1900 network
`needs to identify the network user and also performs specific functions required by the
`network. Among other things, the SIM card contains subscriber and billing information,
`makes periodic location updates with the network, and provides enhanced security
`features.
`
`The SIM card can also store contact information. The number of contacts that can be stored
`on a SIM will vary from manufacturer to manufacturer. The SIM memory is referred to as
`Memory A, and the phone memory as