Exhibit B
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`IPR2019-01218
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`
`
`
`
`
`
`
`Uniloc EX2003
`Samsung v. Uniloc
`
`

`

`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 Japanese Patent Application Publication No. JP H6-
`216841 (“Matsukida”), 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”).
`
`Matsukida was filed on January 20, 1993, and was published on August 5, 1994, and is therefore prior art under at least 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:
`
`Matsukida
`To the extent the preamble is determined to be limiting, Matsukida describes a mobile device for
`making phone calls, i.e., a mobile radiotelephony device.
`
`For example:
`
`
`The present invention has as an object to provide an automatic dial lock type mobile device
`which can prevent unauthorized use by a third party in cases where the mobile device is left
`by a subscriber without configuring the dial lock settings.
`
`
`Id. at Abstract.1
`
`
`[Industrial Field of Use] The present invention relates to automatic dial lock type mobile
`devices.
`
`Id. at ¶ 1.
`
`
`1 Emphasis added unless otherwise specified.
`
`
`
`1
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`
`1(a) blocking means for
`preventing a normal operation
`of the mobile radiotelephony
`device, wherein the normal
`operation includes a
`processing of outgoing calls;
`
`
`
`The mobile device in which the secret code has been registered enters a dial lock state
`when, for example, the “#” button is pressed for a predetermined amount of time after
`pressing “F,” rendering outgoing calls impossible. If the secret code is pressed after
`turning on the power and then a communication start button is pressed, the dial lock is
`disengaged and outgoing calls become possible.
`
`Id. at ¶ 3.
`
`See FIGS. 1 and 2 (displaying a “mobile device”).
`
`Matsukida discloses this limitation. Matsukida 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:
`
`Matsukida describes a “dial lock automatic setting unit 13” that renders outgoing calls impossible
`after a predetermined elapsed time:
`
`
`[Object] The present invention has as an object to provide an automatic dial lock type
`mobile device which can prevent unauthorized use by a third party in cases where the
`mobile device is left by a subscriber without configuring the dial lock settings.
`
`[Configuration] Calculation of elapsed time by a first totaling means 7 is initiated after a
`dial lock is released by inputting a secret code via an input means 4. An automatic setting
`means 13 puts the mobile device in dial lock state when a first comparison means 11
`detects that the calculated time has exceeded a set time t1 in a third storage means 9.
`When a monitoring means 6 detects that a call is complete, a second calculation means 8
`initiates calculation of elapsed time from completion of the call. A second comparison
`means 12 compares the calculation time sent by a means 8 with a set time t2 stored in a
`
`
`
`2
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`fourth storage means 10. A means 13 stores first information in a means 2 if the calculated
`time has exceeded the time t2.
`
`Id. at Abstract.
`
`The present invention was devised in light of this problem, and has as an object to provide
`an automatic dial lock type mobile device which can prevent unauthorized use by a third-
`party even if the mobile device is left by the subscriber without setting the dial lock.
`
`
`Id. at ¶ 6.
`
`
`13 is an automatic setting means for storing information indicating a dial lock state in the
`first storage means 2 either when time excess is detected by the first comparison means 11
`or when time excess is detected by the second comparison means 12.
`
`Id. at ¶ 14.
`
`
`[Effects of the Invention] As described above, with the present invention, the effect is
`provided of being able to prevent unauthorized use by third-party because a dial lock is
`turned on automatically after a predetermined amount of time even if the mobile unit is
`left without the subscriber setting the dial lock.
`
`
`Id. at ¶ 55.
`
`
`
`3
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`
`
`Id. at Fig. 2 (showing a “dial lock automatic setting unit” and a “dial lock set” after a first elapsed
`time).
`
`See also FIG. 3.
`
`Matsukida discloses this limitation. Matsukida describes a 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.
`
`
`
`1(b) timing means for
`activating the blocking means
`in response to the mobile
`radiotelephony device being
`
`
`
`4
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`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
`
`Matsukida
`
`
`For example:
`
`Matsukida describes a “first calculation means” that calculates the elapsed time while the device is
`not locked and a “first comparison means” that compares the calculated time and a “first set time
`t1,” resulting in the device being placed in a dial lock state if the elapsed time has exceeded the
`first set time t1, which discloses “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”:
`
`Calculation of elapsed time by a first totaling means 7 is initiated after a dial lock is
`released by inputting a secret code via an input means 4. An automatic setting means 13
`puts the mobile device in dial lock state when a first comparison means 11 detects that the
`calculated time has exceeded a set time t1 in a third storage means 9.
`
`
`Id. at Abstract.
`
`
`Furthermore, the first calculation means calculates elapsed time from disengagement of
`the dial lock. Thereafter, the first comparison means compares the calculated time
`calculated by the first calculation means 7 and the first set time t1 stored in the third
`storage means 9. In this comparison, if the first comparison means 11 detects that the
`calculated time has exceeded the time t1, the automatic setting means 13 stores
`information indicating a dial lock state to the first storage means 2. The mobile device
`thereby automatically enters a dial lock state.
`
`
`Id. at ¶ 17.
`
`
`7 is a first elapsed time calculation unit which initiates calculation of elapsed time from
`disengagement of the dial lock upon receiving a calculation start instruction sent by the
`secret code cross-reference unit 5 when the dial lock is disengaged.
`
`
`
`
`5
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`9 is a first automatic set time storage unit, in which a first dial lock automatic set time t1
`from disengagement of the dial lock to automatic reengagement of the dial lock is stored
`ahead of time.
`
`11 is a first elapsed time comparison unit, and 13 is a dial lock automatic setting unit. The
`first elapsed time comparison unit 11 compares the calculated time sent by the elapsed
`time calculation unit 7 and the time t1 stored in the first automatic set time storage unit
`9, and, if the calculated time exceeds the time t1, outputs a time excess report to the dial
`lock automatic setting unit 13.
`
`The dial lock automatic setting unit 13, upon receiving the time excess report, makes the
`content of the dial lock state storage unit 2 indicate that dial lock is on.
`
`
`Id. at ¶¶ 24-27.
`
`
`Furthermore, the fact that the secret codes match causes a calculation start instruction to be
`sent from the secret code cross-reference unit 5 to the first elapsed time calculation unit 7.
`Thus, in step S6, the first elapsed time calculation unit 7 starts calculating the elapsed
`time from disengagement of the dial lock.
`
`Next, in step S7, the first elapsed time comparison unit 11 compares the calculated time
`calculated by the first elapsed time calculation unit 7 and the ten minutes which is the first
`dial lock automatic set time stored in the first automatic set time storage unit 9, and makes
`a determination as to whether or not the calculated time has exceeded ten minutes.
`
`
`
`
`Id. at ¶¶ 38-39.
`
`
`If the determination result is “no,” then the process returns to step S7, where a
`determination as to whether or not the calculated time has exceeded ten minutes is made
`once again. Assuming that the calculated time has exceeded ten minutes, the determination
`result is therefore “yes,” and the process moves to step S8.
`
`
`
`6
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`
`
`In step S8, the first elapsed time comparison unit 10 makes a time excess report to the
`dial lock automatic setting unit 13, and the dial lock out a medic setting unit 13 stores
`information in the dial lock state storage unit 2 indicating that the dial lock is on. The
`mobile device therefore enters the dial lock state of step S1.
`
`
`Id. at ¶¶ 41-42.
`
`Matsukida also describes a “second calculation means” that calculates the elapsed time from
`completion of a call and a “second comparison means” that compares the calculated time and a
`“second set time t2,” resulting in the device being placed in a dial lock state if the elapsed time has
`exceeded the second set time t2, which also discloses “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”:
`
`
`When a monitoring means 6 detects that a call is complete, a second calculation means 8
`initiates calculation of elapsed time from completion of the call. A second comparison
`means 12 compares the calculation time sent by a means 8 with a set time t2 stored in a
`fourth storage means 10. A means 13 stores first information in a means 2 if the calculated
`time has exceeded the time t2.
`
`
`Id. at Abstract.
`
`
`On the other hand, if the monitoring means 6 detects completion of a call, the second
`calculation means 8 initiates calculation of elapsed time from completion of the call.
`Thereafter, the second comparison means 12 compares the calculated time sent by the
`second calculation means 8 and the second set time t2 stored in the fourth storage means
`10.
`
`In this comparison, if the second comparison means 12 detects that the calculated time
`has exceeded the time t2, the automatic setting means 13 stores information indicating a
`
`
`
`
`
`7
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`dial lock state in the first storage means 2, and the mobile device automatically enters a
`dial lock state.
`
`
`Id. at ¶¶ 18-19.
`
`
`8 is a second elapsed time calculation unit, which initiates calculation of elapsed time
`from completion of a call upon receiving a calculation start instruction from the call
`completion monitoring unit 6 which has detected completion of a call.
`
`
`
`
`
`10 is a second automatic set time storage unit, in which a second dial lock automatic set
`time t2 from completion of a call to automatic re-engagement of the dial lock state is
`stored.
`
`12 is a second elapsed time comparison unit, which compares the calculated time sent by
`the second elapsed time calculation unit 8 and the time t2 stored in the second automatic
`set time storage unit 10, and, if the calculated time has exceeded the time t2, outputs a
`time excess report to the dial lock automatic setting unit 13.
`
`
`Id. at ¶¶ 28-30.
`
`
`In step S9, a determination is made as to whether or not an outgoing call has been placed in
`the current dial lock disengaged state. If the determination result is “yes,” the process
`moves to step S10.
`
`
`Id. at ¶ 41.
`
`
`On the other hand, if the determination result in step S9 is “yes,” then the process moves to
`step S10, where the second elapsed time calculation unit 8 is initialized, i.e. set to zero,
`and a call is placed in step S11.
`
`
`
`
`
`8
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`
`
`Matsukida
`If the call is completed in step S12, then the call completion monitoring unit 6 detects
`that the call has been completed in step S13, and a calculation start instruction is sent
`due to this detection, causing the second elapsed time calculation unit 8 to start
`calculating the elapsed time from completion of the call.
`
`Next, in step S7, the second elapsed time comparison unit 12 compares the calculated
`time sent by the second elapsed time calculation unit 8 and the two minutes which is the
`second dial lock automatic set time stored in the second automatic set time storage unit
`10, and makes a determination as to whether or not the calculated time has exceeded two
`minutes.
`
`
`Id. at ¶¶ 43-45.
`
`
`If the determination result is “no,” then the process returns to step S7, where a
`determination is made as to whether or not the calculated time has exceeded two minutes
`once again. Assuming that the calculated time has exceeded two minutes, the
`determination result is therefore “yes,” the process moves to step S8, and the dial lock
`automatic setting unit 13 stores information indicating that the dial lock is on in the dial
`lock state storage unit 2. The mobile device therefore enters the dial lock state of step S1.
`
`
`Id. at ¶ 47.
`
`Matsukida also discloses that the invention is to be used by “[a] subscriber to a mobile
`communication service [who] sets a secret code if a dial lock function is needed, when signing
`up. The service provider registers the secret code requested by the subscriber in a storage device
`in the mobile device and gives the subscriber the mobile device, after which the mobile
`communication service begins.” Id. at ¶ 2. See also ¶ 22:
`
`
`3 is a secret code storage unit in which a secret code is stored ahead of time by storage
`operation by the service provider in response to a secret code request by a subscriber. 4 is
`
`
`
`9
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`a secret code input unit, with which the subscriber inputs the secret code for disengaging
`the dial lock.
`
`
`To the extent that Matsukida does not expressly discuss “subsequent to a mounting of a linked user
`identification module inside the mobile radiotelephony device,” a POSA would have known that as
`of the priority date for the ’654 patent, a linked user identification module, e.g., a subscriber
`identification module (“SIM card”) linked to the phone was inherently required for a mobile phone
`to be in normal operation, i.e., able to make calls by using a mobile communication service.
`
`Alternatively, to the extent that Matsukida does not inherently disclose the limitation “subsequent
`to a mounting of a linked user identification module inside the mobile radiotelephony device,” 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
`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.
`
`
`
`
`
`10
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`
`Id. at ¶ 3.
`
`Alos aims to resolve 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
`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
`
`
`
`11
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`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 Matsukida and Alos such that
`the timing features in Matsukida that result in a dial lock 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
`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
`
`
`
`12
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`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.)
`
`
`Id. at 2:54-66.
`
`It would have been obvious to a POSA to combine the teachings of Matsukida and Kemppi such
`that the timing features in Matsukida that result in a dial lock 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
`
`
`
`13
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`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.
`
`
`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,
`
`
`
`14
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`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 Matsukida and Parker such
`that the timing features in Matsukida that result in a dial lock 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.
`
`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
`
`
`
`15
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`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.
`
`Pinault at 2:28-41.
`
`It would have been obvious to a POSA to combine the teachings of Matsukida and Pinault such
`that the timing features in Matsukida that result in a dial lock state after a set elapsed time of
`inactivity occurs subsequent to the mounting of a linked user identification card, e.g., a SIM card.
`
`
`
`
`16
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Matsukida
`Matsukida discloses this limitation. Matsukida describes a user-inputted code causing the mobile
`device to disengage the dial lock, which may be engaged after a first or second elapsed time
`exceeds a first or second set time, respectively, 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”:
`
`The mobile device in which the secret code has been registered enters a dial lock state
`when, for example, the “#” button is pressed for a predetermined amount of time after
`pressing “F,” rendering outgoing calls impossible. If the secret code is pressed after
`turning on the power and then a communication start button is pressed, the dial lock is
`disengaged and outgoing calls become possible.
`
`Id. at ¶ 3.
`
`
`2 is a first storage means for storing information indicating either a dial lock state or dial
`lock disengaged state. 3 is a second storage means for storing a secret code. 4 is an input
`means for inputting the secret code.
`
` 5
`
` is a cross-reference means for cross-referencing the secret code input via the input
`means 4 against a secret code stored in the second storage means 3, and outputting a dial
`lock disengage instruction to the first storage means 2 if the secret codes match.
`
`
`Id. at ¶¶ 8-9.
`
`
`With the present invention thus described, when the operation means 1 is used to carry out
`a dial lock state setting operation, information indicating a dial lock state is set in the first
`storage means 2, and the mobile device enters a dial lock state.
`
`Next, when the secret code is input via the input means 4, the cross-reference means 5
`cross-references that secret code against a secret code stored in the second storage
`
`
`
`Claim Language
`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.
`
`
`
`17
`
`Matsukida
`
`
`
`

`

`Uniloc v. Samsung, Case No. 2:18-cv-00508-JRG-RSP
`
`
`
`Claim Language
`
`Matsukida
`means 3. If the cross-reference results do not match, the dial lock state is not disengaged. If
`the results do match, however, cross-reference means 5 stores information indicating a
`dial lock disengaged state in the first storage means 2. The mobile device thereby enters a
`dial lock disengaged state.
`
`
`Id. at ¶¶ 15-16.
`
`
`When the storage unit 2 stores that the dial lock is on, the mobile device is in the dial lock
`state.
`
` 3
`
` is a secret code storage unit in which a secret code is stored ahead of time by storage
`operation by the service provider in response to a secret code request by a subscriber. 4 is a
`secret code input unit, with which the subscriber inputs the secret code for disengaging
`the dial lock.
`
` 5
`
` is a secret code cross-reference unit, in which, when the secret code is input via the
`secret code input unit 4, the secret code is cross-referenced against a secret code stored
`in the secret code storage unit 3, and if the secret codes match, a dial lock disengage
`instruction is output to the dial lock state storage unit 2, thereby disengaging the dial
`lock state. If the secret codes do not match, the dial lock is not disengaged, and the mobile
`device remains in a dial lock state.
`
`Id. at ¶¶ 21-23; see also FIG. 2.
`
`
`The dial lock automatic setting unit 13 thus makes the conte