Paper No. __________
`Filed March 14, 2014
`
`
`Filed on behalf of:
`By:
`James C. Yoon
`
`Matthew A. Argenti
`WILSON SONSINI GOODRICH & ROSATI
`650 Page Mill Road
`Palo Alto, California 94304
`Tel.: 650-493-9300
`Fax: 650-493-6811
`Email: jyoon@wsgr.com
`Email: margenti@wsgr.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`
`Groupon Inc.
`Petitioner
`
`v.
`
`Maxim Integrated Products, Inc.
`Patent Owner
`
`_____________________________
`
`Patent No. 5,805,702
`
`_____________________________
`
`
`DECLARATION OF PAUL C. CLARK, DSc.
`
`
`
`
`
`GROUPON - EXHIBIT 1002
`
`

`

`
`
`
`
`I.
`
`II.
`
`Table of Contents
`
`QUALIFICATIONS ........................................................................................ 1
`
`SCOPE OF WORK AND COMPENSATION ............................................... 4
`
`III. LEVEL OF ORDINARY SKILL AND RELEVANT TIME ......................... 4
`
`IV. TECHNICAL BACKGROUND ..................................................................... 5
`
`V. OVERVIEW OF THE ’702 PATENT ............................................................ 8
`
`VI. CLAIM CONSTRUCTION .......................................................................... 11
`
`VII. EACH AND EVERY ELEMENT OF CLAIMS 1-2 AND 6-8 IS
`DISCLOSED IN JONES ............................................................................... 11
`
`VIII. EACH AND EVERY ELEMENT OF CLAIMS 1-2 AND 6-8 IS
`DISCLOSED BY JONES IN VIEW OF ISHIGURO................................... 27
`
`IX. EACH AND EVERY ELEMENT OF CLAIMS 1-2 AND 6-8 ARE
`DISCLOSED BY HERRING IN VIEW OF RIVEST .................................. 52
`
`X.
`
`CONCLUDING STATEMENTS .................................................................. 67
`
`APPENDIX B – TABLE OF CITED DOCUMENTS ............................................ 68
`
`
`i
`
`

`

`1.
`2.
`
`
`
`I, Paul C. Clark, DSc., declare as follows:
`
`The following declaration is based on my personal knowledge and all
`
`facts and statements contained herein are true and accurate to the best of my
`
`knowledge, information and belief.
`
`In preparing this declaration, I have reviewed U.S. Patent No.
`
`5,805,702 (hereinafter “the ’702 patent”) (submitted as Ex. 1001), the prosecution
`
`history to date and cited references. I have also relied upon my personal
`
`knowledge and experience of over 30 years. My curriculum vitae is attached as
`
`I.
`
`3.
`
`Appendix A, and also as Exhibit 1003.
`
`QUALIFICATIONS
`
`I earned a Bachelor of Science in Mathematics from the University of
`
`University.
`
`4.
`
`California, Irvine in 1986. In 1988, I earned a Master of Science in Electrical
`
`Engineering and Computer Science from the University of Southern California. In
`
`1994, I earned my Doctorate of Science in Computer Science with a concentration
`
`in Security, Graphics, and Intellectual Property Law from The George Washington
`
`I am currently the President and Chief Technology Officer of
`
`SecureMethods Inc. and Paul C. Clark LLC. in Bethesda, Maryland. I have held
`
`this position for over 14 years. In these roles, I serve as managing director where I
`
`manage the operation, sales, and commercial product development staff.
`
`SecureMethods provides a comprehensive scalable, COTS-based secure
`
`architecture, implemented through the use of the SM Gateway. The SM Gateway is
`
`a next-generation security appliance developed by SecureMethods that is available
`
`on UNIX-based platforms using commercial, government, and Type I
`
`cryptography, implemented in both hardware and software. In my capacity as
`
`President and Chief Technology Officer of SecureMethods, I have technical and
`
`1
`
`

`

`
`operational oversight of all projects and corporate technical operations. I provide
`
`guidance to senior technical personnel relating to design, implementation, and
`
`troubleshooting for a wide range of systems both internal and external. My work
`
`includes network systems and security, cryptographic applications, certification,
`
`key management, authentication, and integrity strategies for network applications.
`
`I also provide a wide range of high end technical and legal consulting services. My
`
`firm specializes in complex software and hardware systems for commercial and
`
`Department of Defense (“DoD”) clients.
`
`Prior to SecureMethods, Inc., I was a Chief Scientist at DynCorp
`
`Networks Solutions from 1995 to 1999, where I designed and deployed the next
`
`generation of architecture for high volume network database and storage systems
`
`for customers such as the DoD.
`
`Prior to my tenure at DynCorp, I was a Senior Security Engineer at
`
`Trusted Information Systems, where I was involved in the implementation of
`
`Privacy Enhanced Mail (PEM) with public and secret key encryption, NIST’s
`
`Smartcard API (SCAPI) which incorporated cryptographic operations for PEM,
`
`among other encryption-related technological and product development. I also
`
`designed and implemented high assurance security systems, including trusted
`
`operating systems and applications for the NSA and the defense Advanced
`
`5.
`6.
`
`7.
`
`Research Projects Agency (“DARPA”). My work at Trusted Information Systems
`
`involved cryptography, multilevel operating systems, smartcards, and other
`
`security technologies.
`
`From 1989 to September 1990, as more fully set forth in my
`
`curriculum vitae, I worked as a Technical Lead at GTE Government Systems.
`
`While at GTE, I designed and implemented network and load generators for OS/2
`
`LAN Manager to measure network performance load metrics for the Central
`
`2
`
`

`

`
`Intelligence Agency (“CIA”). I also developed X Windows interfaces for a large-
`
`scale event-driven network system for the NSA.
`
`From 1985 to 1989, I worked as a Systems Engineer at Ultrasystems
`
`8.
`
`Defense and Space. As more fully set forth in my curriculum vitae, at Ultrasystems
`
`I designed and implemented large-scale simulation and network-based systems for
`
`the United States Department of Defense (“DoD”). A high-speed database server I
`
`designed and implemented was used for realtime intelligence collection by the
`
`National Security Agency (“NSA”).
`
`In addition, I am currently an Adjunct Professor in the Electrical
`
`Engineering and Computer Science Department at The George Washington
`
`University where I teach doctoral level cryptography and computer security
`
`9.
`10.
`
`courses.
`
`I was also a member of the Federal Advisory Committee for Key
`
`Management Infrastructure (KMI) and was Chairman of the Interoperability
`
`Working Group for Cryptographic Key Recovery from approximately 1996 to
`
`1998. I also served as a Cooperative Research and Development Agreements
`
`11.
`
`(CRADA) partner to bring development of elements of a Public Key Infrastructure
`
`(PKI) through combined efforts with the National Institute of Standards and
`
`Technology (NIST).
`
`I have also been an invited speaker at a number of conferences
`
`including: the RSA Security Conference in 1994 where I presented on Random
`
`Number Threats to Cryptographic Systems and a Keynote Speaker for the
`
`Washington, D.C. Bar Association on Security for Networked computing
`
`12. Lastly, I have co-authored a number of publications in the computer
`
`environments.
`
`and security areas. A representative list of my publications is included in my
`
`3
`
`

`

`
`curriculum vitae. I am also a named inventor on two United States Patents, U.S.
`
`Patent Nos. 5,448,045 and 5,892,902.
`
`II.
`
`13.
`
`SCOPE OF WORK AND COMPENSATION
`
`I have been retained as a technical expert witness on behalf of
`
`Groupon Inc. (hereinafter “Groupon”) in connection with the above-captioned
`
`matter. I understand that this matter involves the ’702 patent. I have been asked
`
`by counsel for Groupon to offer an expert opinion on the validity of claims 1, 2,
`
`and 6-8 of the ’702 patent.
`
`In addition to the ’702 patent and its file history, I have also reviewed
`
`and considered various other documents in arriving at my opinions, and may cite to
`
`them in this declaration. For convenience, documents cited in this declaration are
`
`listed in Appendix B.
`
`14.
`15. Further, I am being compensated at my rate of $590 per hour. My
`III. LEVEL OF ORDINARY SKILL AND RELEVANT TIME
`16. The ’702 patent is entitled “Method, Apparatus, and System for
`
`compensation is not dependent on the substance of my opinions, my testimony or
`
`the outcome of this post-grant proceeding.
`
`Transferring Units of Value.” I have been advised that the ’702 patent was filed on
`
`January 31, 1996 and issued on September 8, 1998. I have also been advised that
`
`the ’702 patent claims priority to U.S. Provisional Application No. 60/004,540,
`
`which was filed on September 29, 1995. I have further been advised that the
`
`priority date of the ’702 patent is September 29, 1995. However, I have been
`
`advised that the ’702 patent may not have been entitled to the September 29, 1995
`
`priority date. Whether or not the ’702 patent is given the earlier priority date does
`
`not affect the substance of my technical opinions.
`
`4
`
`

`

`17.
`
`
`
`In determining the characteristics of a person of ordinary skill in the
`
`art of the ’702 patent at the time of the respective claimed inventions, I considered
`
`several factors, including the type of problems encountered in the art, the solutions
`
`to those problems, the rapidity with which innovations are made in the field, the
`
`sophistication of the technology, and the education level of active workers in the
`
`field.
`
`18.
`
`I also placed myself back in the 1995 timeframe and considered the
`
`students and professionals with whom I had worked at that time. In my opinion, a
`
`person of ordinary skill in the art would have been a person with (1) a Master of
`
`Science in computer science, or similar technical fields; (2) a detailed knowledge
`
`of cryptography; and (3) two to four years of experience in the design and
`
`19. Based on my education, training, and professional experience in the
`
`implementation of cryptographic systems.
`
`field of the invention as described in the qualifications section, I am familiar with
`
`the level and abilities of a person of ordinary skill in the art at the time of the
`
`invention and was a person of skill in the art by the earliest priority date available
`
`IV. TECHNICAL BACKGROUND
`20. Ever since the advent of the written word, there has been a need to
`
`to the ’702 patent.
`
`keep written information secure—i.e., inaccessible from those who are not
`
`authorized, while allowing those authorized access to the information.
`
`Cryptography is a mechanism to provide this security service. Before the advent of
`
`computers, cryptography was quite elementary, usually involving simply changing
`
`the order of words or characters to “scramble” a message. Only those who know
`
`how the message had been “scrambled” and had the “key” could “unscramble” the
`
`message.
`
`5
`
`

`

`21. After the invention of computers, however, cryptography became
`
`
`
`much more sophisticated, allowing for intricate ways of scrambling and
`
`unscrambling data with keys. In the early 1970s, the U.S. Government recognized
`
`that a standard public algorithm for data encryption was needed for commercial
`
`systems. The National Bureau of Standards, in cooperation with the National
`
`Security Agency, selected IBM’s Lucifer algorithm as the basis for the new Data
`
`Encryption Standard (“DES”). The publication of DES lead to the development of
`
`other more secure secret key algorithms, such as RC4 and Triple DES prior to the
`
`priority date of the ‘702 patent.
`
`22.
`
`In the 1970’s and 1980’s multiple public key algorithms were also
`
`developed to facilitate both cryptographic key exchange and digital signatures for
`
`transactions. By 1995, RSA, Diffie Hellman, and the Digital Signature Standard
`
`from the National Institute of Standards and Technology were all published and
`
`commercially available and implemented in both hardware and software. In
`
`particular, the well-known RSA encryption scheme was the subject of U.S. Patent
`
`No. 4,405,829 (hereinafter “Rivest”; submitted as Ex. 1006). The scheme
`
`described therein was the basis for the RSA standard in place today. Thus, prior to
`
`the filing of the application that would become the ’702 patent a variety of
`
`cryptographic methods and algorithms were already in use for assuring the
`
`23. The use of SALT and other techniques to ensure that encryption of a
`
`confidentiality, integrity and authenticity of transmitted and stored data.
`
`particular plaintext does not always result in the same ciphertext were likewise
`
`known and included in published standards long before 1995. The use of
`
`initialization vectors in block ciphers and serial numbers in digital certificates are
`
`only two examples.
`
`6
`
`

`

`24.
`
`
`
`In addition, these cryptographic methods were well known to those
`
`developing standards for electronic financial transactions like ANSI X9 for the
`
`American Banker’s Association in the 1980’s. By 1995, cryptographic systems for
`
`financial transactions to which the ’702 patent is directed had been known and
`
`available for several years. Systems from IBM, RSA, GemPlus, Datakey and
`
`25. Prior to 1995 I had utilized smartcards capable of both public key and
`
`Trusted Information Systems had already been deployed and were in use. See, e.g.,
`
`Ex. 1010).
`
`secret key operations for a variety of applications. In particular, I programmed and
`
`integrated the ASACS smartcards for Privacy Enhanced Mail while working for
`
`Trusted Information Systems (TIS). As described in the ’702 patent, the systems I
`
`used were based on published standards and provided most if not all of the claimed
`
`features of the ’702 patent. Moreover, the use of hardware and software
`
`cryptography for financial transactions was well known, the subject of federal and
`
`international standards and widely utilized prior to 1995. See, e.g., Ex. 1011 ( FIPS
`
`26. The creation of truly random numbers from a deterministic computer
`
`171).
`
`was also a recognized problem in computer science. Absent special purpose
`
`hardware, most computers rely on pseudorandom numbers calculated from a
`
`randomly generated seed. The randomness or entropy contained in the seed is
`
`27. When random numbers are used in cryptography, it is important that
`
`measured in the number unpredictable bits it contains.
`
`the amount of entropy in the seed significantly exceed the number of bits in the
`
`pseudorandom number being generated, to avoid weakening the cryptosystem.
`
`This includes techniques for adding SALT to encrypted quantities as discussed
`
`above.
`
`7
`
`

`

`28. For the reasons discussed below, it is my opinion each and every
`
`
`
`element of claims 1-2 and 6-8 is disclosed in the prior art references. The
`
`independent claims of these patents are simply a combination of well-known
`
`cryptographic functions and techniques yielding predictable results. Likewise the
`
`dependent claims add non-inventive features, each of which is found in at least one
`
`V. OVERVIEW OF THE ’702 PATENT
`29. The ’702 patent is entitled “Method, Apparatus, and System for
`
`prior art reference from the same field.
`
`Transferring Units of Value.” The ’702 patent is generally directed to “transferring
`
`money or its equivalent electronically.” Ex. 1001 at 1:6-10. In particular, the
`
`patent relates to “provid[ing] secure data transfers or to authorize monetary
`
`transactions.
`
`transactions.” Id. The ’702 Patent discloses methods for electronic cash transfer
`
`30. Challenged claim 1 of the ’702 Patent is directed to one embodiment
`
`of the invention, and provides a method for adding a monetary equivalent to an
`
`electronic module (digital cash purse). Claim 1 recites the following steps:
`
`1. A method for adding a monetary equivalent to an electronic
`module, comprising the steps of:
`a. placing the module in communication with an electronic
`device;
`b. indicating an amount requested to said electronic device;
`c. communicating a random number from said module to said
`electronic device;
`d. combining said random number and said amount requested
`thereby creating a first data packet in said electronic device;
`e. encrypting said first data packet with a first key thereby
`creating a signed certificate in said electronic device;
`f. communicating said signed certificate from said electronic
`device to said module;
`
`8
`
`

`

`
`
`g. decrypting said signed certificate in said module with a second
`key thereby creating a decrypted random number and a decrypted
`amount requested;
`h. comparing said random number with said decrypted random
`number and determining if they match in said module; and
`i. adding said decrypted amount requested to a money register in said
`module.
`
`
`31. Challenged claims 2 and 6-8 are each dependent on Claim 1.The
`
`specification refers to the embodiment as the “Digital Cash Replenishment”
`
`embodiment, which is shown in Fig. 8, covered by Challenged claims 1-2 and 6-8.
`
`Id. at 10:18-53.
`
`Id. at Fig. 8.
`
`
`
`
`9
`
`

`

`32. Fig. 8 provides a method for adding money to a module. The
`
`
`
`“Service Provider reads the unique lasered registration number (ID number) of the
`
`module F1, F2.” Id. at 10:28-32. The module then creates a random number and
`
`provides the random number to the Service Provider F3. Id. at 10:32-34. The
`
`Service Provider places the random number in a packet “along with the amount of
`
`money to be added and the unique lasered registration number of the module 10
`
`and then encrypts the resulting packet with the Service Provider’s private key F4.
`
`Id. at 10:36-40. The Service Provider evokes script 44, shown in Fig. 11, “which
`
`decrypts the contents of the input data object with the Service Provider’s public
`
`key and then checks the unique lasered registration number” and the random
`number against the original random number. Id. at 10:43-47. If the random
`
`numbers match, “the money amount is extracted from the packet and added to the
`
`value of the money object in module F5. Id.at 10:47-49.
`
`33.
`
`In my opinion, and as explained in further detail below, the claims of
`
`the ’702 patent fail to identify anything new or inventive from what was already
`
`known to individuals of skill in the field prior to the filing of the application of the
`
`’702 patent. As described above, the use of public and secret key cryptographic
`
`systems for financial systems as well as the use of random numbers was already
`
`included in multiple industry standards before the earliest priority date available to
`
`34. For these reasons, and as described in greater detail below, it is my
`
`the ’702 patent.
`
`opinion that the method for adding a monetary equivalent to an electronic module
`
`in claims 1-2 and 6-8 was well known in the field as of the earliest priority date for
`
`the ’702 patent.
`
`10
`
`

`

`VI. CLAIM CONSTRUCTION
`35.
`
`
`
`I have been informed by counsel that claim terms are given their
`
`ordinary and accustomed meaning as understood by one of ordinary skill in the art.
`
`I have also been informed by counsel that a patent claim subject to post-grant
`
`review receives the broadest reasonable construction in light of the specification of
`
`the patent in which it appears.
`
`I have been instructed to apply specific constructions for certain claim
`
`36.
`
`terms found in the ’702 patent. Those constructions are set forth below:
`
`Term
`
`Construction
`
`“signed certificate”
`
`an encrypted certificate
`
`“money register”
`
`“decrypted amount requested”
`
`“adding said decrypted amount
`requested to a money register”
`“monetary equivalent”
`
`an object that is used to represent money
`or some other form of credit
`a decrypted version of the amount
`requested
`increasing the amount of a money register
`by the decrypted amount requested
`Is a limitation
`
`VII. EACH AND EVERY ELEMENT OF CLAIMS 1-2 AND 6-8 IS
`37.
`
`DISCLOSED IN JONES
`
`International PCT Application No. W? 91/16691 to Timothy Jones, et
`
`al. (“Jones”, attached as Ex. 1004), entitled “Value Transfer System,” was
`
`published on October 31, 1991, prior to the priority date of the ’702 patent. I have
`
`been informed by counsel that Jones qualifies as prior art in relation to the ’702
`
`Patent. In my opinion, Jones teaches each and every feature of claims 1-2 and 6-8
`
`38.
`
`of the ’701 patent.
`
`Jones discloses a value transfer system that allows for monetary
`
`values to be exchanged between electronic purses using a secure connection. Ex.
`
`11
`
`

`

`
`1004 at Abstract. The secure connection is established through the use of public
`
`39. The following claim chart explains in further detail how Jones
`
`and private keys. Id. at 13:15-29; 14:3-4, 12-17.
`
`discloses each and every element of claims 1-2 and 6-8 of the ’702 Patent. The
`
`claim chart below identifies exemplary disclosure of Jones relevant to the
`
`corresponding claim elements, and is not meant to be exclusive.
`
`’702 Patent
`
`1. A method for
`adding a monetary
`equivalent to an
`electronic module,
`comprising the
`steps of:
`
`a. placing the
`module in
`communication
`with an electronic
`device;
`
`Jones
`
`Jones discloses a method for adding a monetary equivalent
`(e.g., value) to an electronic module (e.g., receiving purse).
`See, e.g., Ex. 1004 at Abstract; 10:6-24:
`
`“A value transfer system which allows value to be transferred
`between electronic purses comprises computer which controls
`the loading of purses with value and the redemption of value
`from purses, a specific build purse or purses and a value meter
`securely linked thereto which registers the total net value issued
`to the build purse or purses. Draw-down of value and
`redemption of value transactions are effected with the bulk
`purses.” (Abstract).
`
`“Each bank has a bulk purse lc, 2c, 3c which is connected to the
`respective value meter and which has a memory with a purse
`value record. Terminals 5 are connected by telephone
`selectively to computers 1, 2 and 3. . . . By making appropriate
`requests at the keyboard of the terminal, a consumer may be
`connected to the computer of his bank, 1, 2 or 3 and may
`request a value record to be loaded to his purse. If the bank
`authorises the request, the bulk purse is instructed to institute a
`draw-down of value to load purse value record 7 with the value
`requested. The card is now ready for use.”(10:6-24)
`Jones discloses placing the module (e.g., receiving purse) in
`communication with an electronic device (e.g., sending
`purse). See, e.g., Ex. 1004 at 7:19-22; 13:33-14:1.
`
`“Purses may communicate with each other for the transfer of
`
`12
`
`

`

`
`
`’702 Patent
`
`
`
`b. indicating an
`amount requested
`to said electronic
`device;
`
`
`Jones
`
`values by means of communication devices. These may have
`slots for two purses or may each hold a purse and communicate
`with each other by infra-red light or electromagnetic radiation,
`for example.” (7:19-22).
`
`“Two-way communication between the purses is established,
`perhaps locally by direct connection or by infra-red link or the
`like or remotely by modem and telephone” (13:33-14:1).
`Jones discloses indicating an amount (e.g., value V)
`requested to said electronic device (e.g., sending purse).
`See, e.g., Ex. 1004 at 4:5-10; 10:6-8; 10:18-24; 10:25-36
`16:32-34; Fig. 4; see also 14:9-17.
`
`“. . . the microprocessors being programmed so that in each off-
`line transaction the purse value record in the sending purse is
`decreased by a chosen and variable transaction value and the
`purse value record in the receiving purse is increased by the
`same transaction value.” (4:5-10).
`
`“Each bank has a bulk purse lc, 2c, 3c which is connected to the
`respective value meter and which has a memory with a purse
`value record.” (10:6-8).
`
`“The cards have contacts 8, whereby the cards can interact with
`terminals 5 via card readers 9. By making appropriate requests
`at the keyboard of the terminal, a consumer may be connected
`to the computer of his bank, 1, 2 or 3 and may request a value
`record to be loaded to his purse. If the bank authorises the
`request, the bulk purse is instructed to institute a draw-down of
`value to load purse value record 7 with the value requested. The
`card is now ready for use.” (10:18-24).
`
`“Further electronic purses are contained in terminals 10, 11
`which are equipped with IC card readers 9, located at different
`points-of-sale. To use his card the consumer presents it to the
`retailer where it is inserted into reader 9. The required value of
`the transaction is keyed in and by agreement the total held in
`
`13
`
`

`

`
`
`’702 Patent
`
`Jones
`
`c. communicating
`a random number
`from said module
`to said electronic
`device;
`
`
`the purse value record of the purse 6 is reduced by the amount
`of the transaction. The purse value record of the purse held
`within the terminal 10 or 11 is increased by the same
`transaction value.” (10:25-35).
`
`“7. The sending purse decrements the value V from its purse
`value record and sends the message [VR]*DESc to the
`receiving purse.” (16:32-34).
`Jones discloses communicating a random number (e.g, R)
`from said module (e.g., receiving purse) to said electronic
`device (e.g., sending purse). See, e.g., Ex. 1004 at 4:25-29;
`4:31-5:1; 13:31-33; 16:7-10, 25-27; see also14:3-4; see also,
`Fig. 4 (annotated below).
`
`“Preferably the purses have means whereby a transaction
`between a pair of purses is given a unique identifier and the
`microprocessors are programmed to respond to the identifiers to
`prevent a given transaction being repeated.” (4:25-29).
`
`“In claiming to redeem value the computer is accessed and it
`will be possible to determine whether the same claim is being
`made twice, either directly or, since a claim may be simply
`another transaction, by means of a transaction identifier.”
`(4:31-5:1).
`
`“[A] transaction identifier number R … is derived from a
`combination of the receiving purse identity and a transaction
`sequence number for that purse.” (13:30-33).
`
`“The first step in the transaction procedure is for the receiving
`purse to issue a transaction identifier R as in the embodiment of
`Figure 3.” (16:7-10).
`
`“5. The receiving purse transmits the message [R]*DESc which
`is the transaction identifier R encrypted with DES integrity
`algorithm.” (16:25-27).
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`See also FIG. 4 (e.g., "[R]*DESc" sent from the receiving purse
`to the sending purse) below. Fig. 4 shows that the random
`number R is transmitted from the module (e.g., receiving purse
`RS) to the electronic device (e.g., sending purse CS), as
`indicated by the block dashed box.
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`d. combining said
`random number
`and said amount
`requested thereby
`creating a first
`data packet in said
`electronic device;
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`Jones
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`Jones discloses combining said random number (e.g. R) and
`said amount (e.g., value V) requested thereby creating a
`first data packet (e.g., [VR]), which can be combined with
`DES, in said electronic device (e.g., sending purse). See,
`e.g., Ex. 1004 at 16:32-34; see also 14:9-17.
`
`“7. The sending purse decrements the value V from its purse
`value record and sends the message [VR]*DESc to the
`receiving purse.” (16:32-34).
`
`See also Fig. 4 below, which shows that the random number
`(e.g., R) is combined with the amount (e.g., value V) before the
`VR data packet is encrypted, as indicated by that dashed black
`box.
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`e. encrypting said
`first data packet
`with a first key
`thereby creating a
`signed certificate
`in said electronic
`device;
`
`
`Jones discloses encrypting said first data packet (e.g., [VR])
`with a first key (e.g., DESc) thereby creating a signed
`certificate in said electronic device (e.g., sending purse).
`See, e.g., Ex. 1004 at 5:13-20; 5:32-34; 6:23-34; 13:13-28;
`15:3-6; 15:15-27; 15:35-16:4; 16:32-34; see also 14:9-17.
`
`“Security can be enhanced by using electronically certified
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`data, for example digitally signed data, in the transaction
`process. Each purse on issue will be allocated a characteristic
`number and will have that number signed by the secret key of
`an asymmetrical global cryptographic system. The result will
`be a global signing of the number and this is stored in the purse.
`All purses will carry the public key of the global pair so that on
`receipt of another's globally signed number it will be possible to
`verify that it is valid. The numbers can be regarded as globally
`certified.” (6:23-34).
`
`“The most effective cryptographic techniques are asymmetrical
`in that they require different keys to encrypt and decrypt
`information. One well-known and suitable cryptographic
`technique is that attributed to Rivest, Shamir and Adleman,
`known as the RSA system. It is envisaged that both purses of a
`communicating pair may employ the RSA system equally in a
`balanced way for algorithmic processing.” (5:13-20).
`
`“Messages to another are encrypted using the other's (remote)
`public key which is made available, perhaps by a key exchange
`procedure.” (5:32-34).
`
`“Both purses have full RSA asymmetrical cryptographic
`capability. The sending purse has a store SS which holds an
`accumulative value record Svr and the following RSA keys:
`sender public and secret keys Pks and Sks and global public
`key Pkg. In addition there is a certified data message
`[Pks]*Skg. This is the sender purse's unique public key signed
`by the master computer with its global secret key Skg. The
`public key Pks is thus electronically certified as valid by the
`system. The receiver purse has a store RS which holds an
`accumulative value record Rvr and the receiver purse's own
`RSA public and secret keys Pkr, Skr, the global public key Pkg
`and a certified public key data message [Pkr]*Skg.” (13:15-29).
`
`“RSA encryption and decryption require calculation
`of the expression xY mod n where y is different for
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`encryption and decryption.” (15:3-5)
`
`“The embodiments illustrated in Figures 4 and 5 provide
`arrangements which allow one of the pair of communicating
`purses to be of lower computing power, and therefore less
`expensive, than the other. In these arrangements some purses of
`the system (retailer purses) have full RSA capability
`(encryption and decryption capability) whereas the remainder
`(consumer purses) include a symmetrical key cryptographic
`system for transmitting transaction value record messages. A
`suitable symmetrical key cryptographic system is the DES
`system. This requires for encryption and decryption a level of
`computing power similar to the power required for RSA
`encryption.” (15:15-27).
`
`“In addition, there is a DES key DESc and a certified data
`message [DESc]*Skg which is the sending purse’s unique DES
`key signed by the master computer with its global secret key
`Skg.” (15:35-16:4).
`
`“7. The sending purse decrements the value V from its purse
`value record and sends the message [VR]*DESc to the
`receiving purse.” (16:32-34).
`
`See Fig. 4 below where this step is highlighted by the dashed
`black box.
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`Jones discloses communicating said signed certificate from
`said electronic device (e.g., sending purse) to said module
`(e.g., receiving purse). See, e.g., Ex. 1004 at 16:32-34; see
`also 14:12-17.
`
`
`f. communicating
`said signed
`certificate from
`said electronic
`device to said
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`module;
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`“7. The sending purse . . . sends the message [VR]*DESc to
`the receiving purse.” (16:32-34).
`
`See Fig. 4 below where this step is highlighted. [VR]*DESc,
`e.g., a signed certificate, was encrypted in the electronic device
`(e.g., sending purse) transmitted from the electronic device
`(e.g., sending purse) to the module (e.g., receiving purse).
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`g. decrypting said
`signed certificate
`in said module
`with a second key
`thereby creating a
`decrypted random
`number and a
`decrypted amount
`requested;
`
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`Jones
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`Jones discloses decrypting said signed certificate in said
`module with a second key (e.g., Pkr) thereby creating a
`decrypted random number (e.g., R) and a decrypted
`amount requested (e.g., value V). See, e.g., Ex. 1004 at 5:13-
`20;13:13-28; 16:35-17:1; see also 14:18-22.
`
`“The most effective cryptographic techniques are asymmetrical
`in that they require different keys to encrypt and decrypt
`information. One well-known and suitable cryptographic
`technique is that attributed to Rivest, Shamir and Adleman,
`known as the