Case 2:12-mc-00244-JFC Document 642-24 Filed 08/14/13 Page 1 of 64
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
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`IN RE: MAXIM INTEGRATED
`PRODUCTS, INC. MDL No. 2354
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`This Document Relates to: All Actions
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`)
`)
`)
`)
`)
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`Master Docket
`Misc. No. 12-244
`MDL No. 2354
`CONTI, District Judge
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`DECLARATION OF DR. STUART G. STUBBLEBINE IN SUPPORT OF OPPOSING
`PARTIES’ RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`1
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`Maxim Exhibit 2011 - Groupon, CBM2014-00090 – Page 2011-001
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`Case 2:12-mc-00244-JFC Document 642-24 Filed 08/14/13 Page 2 of 64
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`Table of Contents
`Background ......................................................................................................................... 4
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`Claim Construction ............................................................................................................. 8
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`I.
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`II.
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`III.
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`Claim Terms For Which The Opposing Parties Have Proposed a Construction ................ 9
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`A.
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`“math coprocessor . . . for processing encryption calculations” (510, claim
`1); “math coprocessor . . . for handling complex mathematics of
`encryption and decryption” (013, claim 1); “modular exponentiation
`accelerator circuit . . . for performing encryption and decryption
`calculations” (013, claim 9) .................................................................................... 9
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`(a)
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`(b)
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`(c)
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`(d)
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`(e)
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`“distinct from” requirement ...................................................................... 11
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`“works concurrently with” requirement .................................................... 16
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`“dedicated” requirement ........................................................................... 18
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`“to handling the complex mathematics of modular exponentiation” ........ 20
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`“for encryption and decryption” ............................................................... 22
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`“real time clock circuit” (510, claim 1); “real time clock” (013, claim 1);
`“clock circuit” (013, claim 9); “timing circuit” (095, claim 1) ............................. 25
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`“storing” (880, claim 1); (095, claims 1, 5); “store” (095, claim 1);
`“storing” (013 patent, claim 9) .............................................................................. 28
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`“challenge number” (095 patent, claim 1) ............................................................ 30
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`“adjust said first data object according to said second data object” (095
`patent, claim 1) ...................................................................................................... 34
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`“time stamp” (013, claim 9); (095, claim 1) ......................................................... 36
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`“time stamping data transactions” (510, claim 1) ................................................. 43
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`“certificate” (095, claim 1) ................................................................................... 45
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`“packet” (702, claim 1); (510, claim 3) ................................................................ 53
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`B.
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`C.
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`D.
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`E.
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`F.
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`G.
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`H.
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`I.
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`IV.
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`Terms Identified by Opposing Parties as Indefinite ......................................................... 56
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`A.
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`“store a transaction script, the transaction script including at least a
`representation of the time stamp generated by the timing circuit” (095,
`claim 1) ................................................................................................................. 56
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`2
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`B.
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`C.
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`“substantially unique electronically readable identification number” (510,
`claim 1) ................................................................................................................. 58
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`“responsive to a verification signal from said electronic device” (095,
`claim 1) ................................................................................................................. 61
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`D.
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`“time stamping a predetermined function” (013, claim 1) ................................... 62
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`3
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`I, Stuart G. Stubblebine, hereby declare under penalty of perjury:
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`1.
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`Counsel for the Opposing Parties1 have retained me as an expert in connection
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`with an ongoing litigation in the Western District of Pennsylvania to offer opinions regarding
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`certain claim construction issues for U.S. Patent Nos. 5,805,702 (“the 702 patent”), 5,940,510
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`(“the 510 patent”), 5,949,880 (“the 880 patent”), 6,105,013 (“the 013 patent”), and 6,237,095
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`(“the 095 patent”).
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`2.
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`If called to testify at a deposition, hearing, or trial in this matter, I anticipate
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`providing the opinions summarized in this declaration, as well as responding to positions taken
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`by any and all expert witnesses or fact witnesses called by Maxim Integrated Products, Inc.
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`(“Maxim”).
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`3.
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`I submit this declaration based on my personal knowledge and in support of the
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`Opposing Parties’ Claim Construction Brief. If called upon as a witness, I could competently
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`testify to the truth of each statement herein.
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`I.
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`Background
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`4.
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`I am a research scientist and consultant and Stubblebine Consulting, LLC and
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`Stubblebine Research Labs, LLC, where I specialize in computer and network security,
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`evaluations, detailed design, and formal analysis.
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`5.
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`I earned a B.S. in Computer Science & Mathematics as a double major from
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`Vanderbilt University in 1983, a M.S. in Electrical Engineering with a focus on Computer
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`Engineering from the University of Arizona in 1988, and a Ph.D. in Electrical Engineering from
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`the University of Maryland in 1992 with focus on Computer Engineering.
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`1 Dr. Stubblebine submits this Declaration on behalf of all Opposing Parties. Certain Opposing
`Parties have also filed further briefing regarding the “certificate” term. Vanguard joins except to
`the extent any positions set forth herein differ from the positions set forth in Vanguard’s
`Responsive Claim Construction Brief.
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`4
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`6.
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`A copy of my curriculum vitae is attached to this Declaration. My CV includes a
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`list of publications I have authored or co-authored. I have experience in smart card technology,
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`electronic payment and credit card processing, cryptographic protocols, software engineering,
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`computer networks and their protocols, computer and network security, and among other
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`technical areas.
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`7.
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`Through Stubblebine Research Labs, LLC, I have conducted fundamental
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`research under the sponsorship of the National Science Foundation. My funded research includes
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`work in the area of authenticating users subject to automated password guessing attacks, and I
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`also worked in the area of location privacy and digital rights management.
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`8.
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`In addition to founding Stubblebine Consulting, LLC and Stubblebine Research
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`Labs, LLC, I have previously worked at the University of California-Davis as a professional
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`researcher, a full professor level position, in the areas of security, cryptography, and secure
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`software engineering.
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`9.
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`I was the Vice President and Cryptographer at CertCo, Inc., where I designed
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`banking protocols involving the use of smart cards for authenticating and authorizing user
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`initiated transactions involving multiple party banking transactions using public key technology.
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`My work further involved conducting research, design, and analysis of public key cryptography
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`protocols, smart cards, and authentication and authorization protocols.
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`10. While a Principal Member of the technical staff at AT&T Labs, formerly Bell
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`labs, I consulted extensively with developers and business units on the security design and
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`analysis of electronic commerce applications. This work included provisioning phone service
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`using security hardware embedded in set top boxes. I also led the design and analysis of internet-
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`based credit card processing technology involving multi-party protocols involving consumer,
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`5
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`merchant, and credit card processor. I also led the design of protocols for the offering an
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`electronic document notarization service using public key technology and an associated digital
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`archiving service that protected the confidentiality of archived documents. I designed automated
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`analysis tools that discovered vulnerabilities in the IPSEC protocol.
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`11. While an adjunct faculty member at University of Southern California I was the
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`principal investigator for the National Security Agency’s University Research Program contract
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`for designing techniques to protect the identity of networked communicants based on traffic
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`analysis. I also evaluated the public key certification authority architecture for the US
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`Government.
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`12.
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`As Director of Secure Systems Engineering at Commcrypt I directed the design of
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`network and file server architectures, automated key management utilizing smart cards, secure
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`electronic mail utilizing smart cards, piracy countermeasures, smart card based systems for
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`protecting the confidentiality of files on disk. I participated in establishing national standards for
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`programming for the National Institute of Standards and Technology NIST.
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`13.
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`I also worked at IBM Federal Systems Division, where I developed a theory and
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`technique for analysis of cryptographic protocols. I discovered vulnerabilities many of the
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`standard security protocols at the time including protocols for secure electronic mail, computer to
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`computer communication, user and system authentication protocols. My work showed that some
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`of the most often used security standards at the time were vulnerable including IETF’s Kerberos,
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`IETF/US Government’s Privacy Enhanced Electronic Mail, and OSF’s Distributed Computing
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`Environment. My work also showed that the integrity of the cryptographically protected location
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`information from GPS (the Global Positioning System) was vulnerable to attack.
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`14.
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`I also worked at University of Arizona, the University of Maryland, and the US
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`Army, among others, in various teaching, research, and management position related to smart
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`card systems for trusted applications, communication systems, security, computer science,
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`communication protocols, and other areas.
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`15.
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`I am an inventor or co-inventor of thirteen U.S. Patents, including inventions
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`related to security and cryptographic services, electronic transactions, and distributed systems.
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`16.
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`I have taught various courses in systems analysis and design, programming logic,
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`programming languages, and software analysis.
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`17.
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`I have extensive industry research experience in smart card technology, electronic
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`payment and credit card processing, cryptographic protocols, software engineering, computer
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`networks and their protocols, and computer and network security.
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`18.
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`I have served as associate editor for ACM Transactions on Information and
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`System Security, invited editor for Software Engineering and Security for ACM Transactions on
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`Software Engineering and Methodology, and have served on numerous program committees as
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`the chairperson and as a member.
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`19.
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`I have reviewed the 702 patent, the 510 patent, the 880 patent, the 013 patent, the
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`095 patent, along with their associated file histories, and the U.S. Provisional App. No.
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`60/004,510. I have also reviewed the extrinsic evidence cited herein.
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`20.
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`I have reviewed the Opposing Parties’ and Maxim’s proposed claim
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`constructions, filed with the Court on June 7, 2013. I have also reviewed Maxim’s Opening
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`claim construction brief and associated materials and exhibits, including the Declarations of Dr.
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`Tygar and Dr. Alpert, filed on August 9, 2013. I also attended, by phone, the depositions of Dr.
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`Tygar and Dr. Alpert taken in connection with these claim construction proceedings, and
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`reviewed the transcripts from those depositions.
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`21.
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`I am not a legal expert and offer no opinions on the law. However, I have been
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`informed by counsel for Opposing Parties of the various legal standards that apply and I have
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`applied those standards in arriving at my conclusions.
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`II.
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`Claim Construction
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`22.
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`I understand that claim construction begins with the words of the claim and
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`focuses on determining how a person of ordinary skill in the art would have understood the claim
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`terms at the time of the invention. I also understand that the patent and its prosecution history
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`usually provide the technological and temporal context for the court to determine the meaning of
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`the claim to one of ordinary skill in the art at the time of the invention.
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`23.
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`I understand that a person of ordinary skill in the art reads the claim terms not
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`only in the context of the particular claim in which the term appears, but also in the context of
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`the entire patent. I understand that a patent’s specification is highly relevant to the claim
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`construction analysis and, for example, statements in the specification that state that certain
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`features are part of the “present invention,” may indicate that the patent claims include those
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`features.
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`24.
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`I also understand that the patent’s “prosecution history” consists of the complete
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`record of the proceedings before the PTO and includes communications between the patent
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`applicant and the PTO. I understand that the prosecution history is important in determining the
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`scope of the claims. For example, the prosecution history can demonstrate how the inventor
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`understood the invention, whether the applicant made any representations regarding the scope of
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`the claims, and whether the applicant narrowed the scope of the claims in the course of
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`prosecution.
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`25. While I understand that the intrinsic evidence—the claims, the specification of the
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`patent, and its prosecution history—is of primary importance in construing patent claims, I also
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`understand that courts may also consider extrinsic evidence to educate themselves regarding the
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`field of the invention and to determine what a person of ordinary skill in the art would
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`understand claim terms to mean. I also understand that extrinsic evidence is considered in the
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`context of the intrinsic evidence. Dictionary definitions, for example, may be used to provide
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`guidance as to the manner in which one of ordinary skill in the art would interpret particular
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`claim language as of the relevant time.
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`26.
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`After considering the types of problems encountered in the art, the prior solutions
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`to those problems, the rapidity with which innovations are made, the sophistication of the
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`technology, the level of education of active workers in the field, and my own experience working
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`with those of skill in the art, in my opinion, a person of ordinary skill in the art of 702 patent, the
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`510 patent, the 880 patent, the 013 patent, and the 095 patent, would have a bachelor’s degree or
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`equivalent in the field of computer engineering, electrical engineering, or computer science, and
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`at least two to three years of experience relating to computer systems engineering and secure
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`data transactions.
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`III. Claim Terms For Which The Opposing Parties Have Proposed a Construction
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`A.
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`“math coprocessor . . . for processing encryption calculations” (510, claim 1);
`“math coprocessor . . . for handling complex mathematics of encryption and
`decryption” (013, claim 1); “modular exponentiation accelerator circuit . . .
`for performing encryption and decryption calculations” (013, claim 9)
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`27.
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`I have been asked to give my opinion on how one of ordinary skill in the art at the
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`time of the invention would understand the terms “math coprocessor . . . for processing
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`encryption calculations” in claim 1 of the 510 patent, “math coprocessor . . . for handling
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`complex mathematics of encryption and decryption” in claim 1 of the 013 patent, and “modular
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`exponentiation accelerator circuit . . . for performing encryption and decryption calculations” in
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`claim 9 of the 013 patent. One of ordinary skill in the art at the time of the invention would
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`understand that each of these terms refers to a type of coprocessor. (See also Alpert Dep. 87:22-
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`88:4 (agreeing that a modular exponentiation accelerator is a type of coprocessor).)
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`28.
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`I understand Opposing Parties have proposed that each of these coprocessor terms
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`be construed the same way to mean “a processor that is distinct from and works concurrently
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`with the microcontroller core and is dedicated to handling the complex mathematics of modular
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`exponentiation for encryption and decryption.”
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`29.
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`I also understand Maxim proposes different constructions for each term. Maxim
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`proposes that “math coprocessor . . . for processing encryption calculations” (510, claim 1) be
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`construed to mean “a processor that works with another processor processing complex
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`mathematics of encryption”; that “math coprocessor . . . for handling complex mathematics of
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`encryption and decryption” (013, claim 1) be construed to mean “a processor that works with
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`another processor handling complex mathematics of encryption and decryption”; and that
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`“modular exponentiation accelerator circuit . . . for performing encryption and decryption
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`calculations” (013, claim 9) be construed to mean “a processor that works with another
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`processor handling complex mathematics of modular exponentiation and encryption and
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`decryption calculations.”
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`30.
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`I agree with Opposing Parties that each of these coprocessor terms require “a
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`processor that is distinct from and works concurrently with the microcontroller core and is
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`dedicated to handling the complex mathematics of modular exponentiation for encryption and
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`decryption.” This construction reflects the understanding that one of ordinary skill in the art at
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`the time of the invention would assign to these terms in view of the relevant intrinsic and
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`extrinsic evidence.
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`31.
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`As an initial matter, I understand the parties agree that these coprocessor terms
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`require at least “a processor that works with another processor handling complex mathematics of
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`encryption.” (Maxim Br. 10.) Based on this agreement, it is apparent that the parties do not
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`actually dispute that each claimed coprocessor (a) is distinct from another processor and (b) is at
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`least capable of working concurrently with another processor. The distinct and concurrently
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`requirements are both inherent in a “a processor that works with another processor,” and these
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`requirements are fully supported by the relevant intrinsic and extrinsic evidence, including the
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`testimony of Maxim’s expert Dr. Alpert, as discussed in greater detail below. The parties’
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`disagreement focuses on whether the intrinsic record imposes additional requirements on the
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`coprocessors terms; that is, whether each claimed coprocessor is (c) “dedicated” (d) “to handling
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`the complex mathematics of modular exponentiation” (e) “for encryption and decryption.”
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`(a)
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`“distinct from” requirement
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`32.
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`Regarding the “distinct from” requirement, I understand the parties agree that the
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`coprocessor terms at least require “a processor that works with another processor.” (Maxim Br.
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`10.) In other words, each claimed coprocessor is not the same as and is a different structure from
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`the other processor required in the claims. The testimony of Maxim’s expert Dr. Alpert fully
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`supports the “distinct” requirement because it shows that each claimed coprocessor is a different
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`structure from another processor:
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`Q. Now, this math coprocessor in Claim 1 of the ‘510 patent is a separate
`processor from the microcontroller core; is that correct?
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`MR. NELSON: Objection; vague.
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`THE WITNESS: You know, it -- it's a distinct structure. I'm not trying to
`push back on the question. I just -- I don't understand, you know, what
`"separate" might mean.
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`MR. DOWNS: All right.
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`Q. So how would a person of ordinary skill in the art distinguish between
`what is a microcontroller core and what is a math coprocessor, based on
`this language?
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`A. Well, a microcontroller core would be the microprocessor of the
`microcontroller, and a math coprocessor would be – would be a different
`structure that, in fact, as – let me just see what it says. That would be for
`handling complex – that would be handling complex mathematics of
`encryption and decryption.
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`(Alpert Dep. 64:16-65:10.)
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`Q. So the math coprocessor in Claim 1 of the '013 patent is a separate
`processor from the microcontroller core; is that correct?
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`MR. NELSON: Objection; misstates the prior testimony. It's also vague.
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`THE WITNESS: Yeah, I'd say it’s a different structure. I don’t know what
`– you know, what might – what you might mean by “separate.”
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`MR. DOWNS: All right.
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`Q. It's a different structure. It's a different processor; is that fair?
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`A. Yes, a different structure.
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`(Alpert Dep. 60:17-61:15.)
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`12
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` Is it a different processor from the microcontroller core?
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` It --
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`MR. NELSON: Objection; vague.
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`THE WITNESS: -- it is different. I think, you know, what I'm just
`thinking is to say that there -- there could be some portions of the circuitry
`that were in common, so they don't have to be completely separate. But it
`is certainly a -- a structure, a processor that's different from -- from the
`processor, which would actually be the microcontroller core.
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`MR. DOWNS: Q. What is a modular exponentiation accelerator circuit?
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`A. Well, the construction in this case that Maxim has proposed and I've
`agreed with is a processor that works with another processor, handling
`complex mathematics of modular exponentiation and encryption and
`decryption calculations.
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`Q. And that is a -- I'm trying to remember the word you used -- different
`processor than the processor that is the microcontroller core; is that
`correct?
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`MR. NELSON: Objection; vague.
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`THE WITNESS: Yeah. I believe it's a different structure.
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`(Alpert Dep. 72:7-20.)
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`33.
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`The “distinct” requirement also is fully supported by the intrinsic evidence. The
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`510 and 013 specifications both describe the coprocessor as being a structurally distinct and
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`separate unit from the other required processor. As shown below, Figure 3 of the 510 patent and
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`Figure 1 of the 013 patent both illustrate the distinct coprocessor as item 18.
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`Both specifications teeach that theese figures shhow a “moddule.” (E.g., 0013 patent 22:6, 2:34-36,
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`3:22-23; 510 patent 22:16-17, 5:388-39.) In thee 510 patent,, the modulee of Figure 3
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`ased module“a micropprocessor ba
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`,” “secure mmicroprocess
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`or e device’),” oor based devvice (‘secure
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`is also calleed a
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`“secure mmodule” to ddistinguish itt from the poortable moduule shown inn Figure 2 off the 510 pattent.
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`(Cf. 510 patent 2:16-17, 4:26-27,, 5:38-39, Fiig. 3, with idd. 2:14-15, 3::40-41, Fig.
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`2.)
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`Both sspecificationns teach that the module
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`of Figure 3
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`4.
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`in the 510 aand Figure 1
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`of
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`the 013 hhas “a micropprocessor 122” and “a maath coprocesssor 18.” (51
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`0 patent 4:229-34; 013 paatent
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`2:39-42.)) The “math coprocessorr 18” is described as a diifferent struccture from thhe
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`“microprrocessor 12,”” which is thhe other proccessor in thesse modules.
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`Both speciffications alsoo
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`refer to thhe same moddule as beingg microcontrroller-based d and again ddescribes thee “math
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`coprocessor 18” as being structurrally differennt from the oother proces
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`sor. (510 paatent 5:38-422; 013
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`patent 3:21-26.) Both specifications explain the microcontroller-based module has “a general-
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`purpose, 8051-compatible micro controller 12 or a reasonably similar product” and “a high-
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`speed modular exponentiation accelerator for large integers (math coprocessor) 18.” (510 patent
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`5:38-42; 013 patent 3:21-26; see also 510 patent 4:61-65 (explaining that the “math coprocessor
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`18” is a modular exponentiation accelerator, i.e., handles the complex mathematics of RSA
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`encryption and decryption); 013 patent 2:54-57 (same).) In the microcontroller-based module,
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`the microcontroller 12 contains the main processor (i.e., the core of the microcontroller is the
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`main processor) and the “a high-speed modular exponentiation accelerator for large integers
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`(math coprocessor) 18” is a structurally distinct coprocessor.
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`35.
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`Contemporaneous technical definitions of “math coprocessor” also show that a
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`person of ordinary skill in the art at the time of the invention would have understood the claimed
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`coprocessors to be “distinct from” another processor. For example, the Microsoft Press
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`Computer Dictionary defines a “coprocessor” as “a processor, distinct from the main
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`microprocessor, that performs additional functions or assists the main microprocessor.” (Ex. 4,
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`Microsoft Press Computer Dictionary 98 (2nd ed. 1994).) This definition uses the word
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`“distinct” to distinguish the math coprocessor from the main microprocessor also referenced in
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`the definition. The IBM Dictionary of Computing defines “math coprocessor” as “[i]n a
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`personal computer, a microprocessor on an expansion board that supplements the operations of
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`the processor in the system unit, enabling a personal computer to perform complex mathematical
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`operations in parallel with other operations.” (Ex. 9, IBM Dictionary of Computing 150 (1994).)
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`In this definition, the math coprocessor is on a separate “expansion board” and is again distinct
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`from the “processor” that the definition says is in the system unit (i.e., the other processor in this
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`definition).
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`36.
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`I understand that Maxim’s brief argues that because a coprocessor may be built
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`into the same chip as the main processor, a “distinct” coprocessor is not required. (Maxim Br.
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`14-15; see also Alpert Decl. ¶29.) I disagree. Even when a coprocessor is built into a single chip
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`with the main processor, the coprocessor is still a distinct, structurally separate processor. In
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`other words, the coprocessor would not be the same processor as the main processor. Maxim’s
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`expert Dr. Alpert even agreed that “a single processor on its own wouldn’t be a coprocessor.”
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`(Alpert Dep. 57:6-7.)
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`(b)
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`“works concurrently with” requirement
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`37.
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`Regarding the “works concurrently with” requirement, I understand the parties
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`agree that the coprocessor terms at least require “a processor that works with another processor.”
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`(Maxim Br. 10.) Maxim also states that “processors at the time of the invention would wait for
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`the result from a coprocessor or process other tasks.” (Id. 14 (emphasis added).) In other words,
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`each claimed coprocessor must at least be capable of working concurrently with another
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`processor because the main processor could process other tasks while the coprocessor is working
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`in parallel. Maxim’s expert Dr. Alpert agreed with this. (Alpert Dep. 53:5-11.) As Dr. Alpert
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`testified, it is true that a coprocessor “could be waiting for the other [processor],” but the
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`coprocessor also “can be operating at the same time” as the other processor. (Id.) In other words,
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`a coprocessor must be able to work concurrently with another processor.
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`38.
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`To a person of ordinary skill in the art at the time of the invention, the plain
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`meaning of “co” in coprocessor would require the coprocessor to be able to work concurrently
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`with another processor. At the time of the invention this was well known, as reflected in
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`numerous technical definitions of “coprocessor.” For example, the IBM Dictionary of
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`Computing defines a “coprocessor” as “a supplementary processor that performs operations in
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`conjunction with another processor” and “math coprocessor” as “[i]n a personal computer, a
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`microprocessor on an expansion board that supplements the operations of the processor in the
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`system unit, enabling a personal computer to perform complex mathematical operations in
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`parallel with other operations.” (Ex. 9, IBM Dictionary of Computing 150 (1994).) The
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`McGraw-Hill, Dictionary of Scientific and Technical Terms defines “coprocessor” as “a
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`processing unit that works together with a primary central processing unit to speed a computer’s
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`execution of time-consuming operations.” (Ex. 18, McGraw-Hill, Dictionary of Scientific and
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`Technical Terms 461 (5th ed. 1994).) The Dictionary of Computing defines “coprocessor” as an
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`“extra, specialized processor, such as an array or numerical processor that can work with a main
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`CPU to increase execution speed.” (Ex. 19, Dictionary of Computing 69 (2nd ed. 1994).) The
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`Webster’s New World Dictionary of Computer Terms defines “coprocessor” as “[a] device that
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`performs specialized processing in conjunction with the main microprocessor of a system. It
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`works in tandem with another central processing unit to increase the computing power of a
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`system. An extra microprocessor to handle some things faster than the main processor, such as a
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`MATH COPROCESSOR or a GRAPHICS COPROCESSOR.” (Ex. 20, Webster’s New World
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`Dictionary of Computer Terms 131 (5th ed. 1994).) In each of these definitions, the coprocessor
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`is described as being able to work concurrently with another processor.
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`39.
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`The “concurrently” requirement also is fully supported by the intrinsic evidence.
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`The 510 and 013 specifications both define the math coprocessor as a “high-speed modular
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`exponentiation accelerator for large integers (math coprocessor)” and explain that this
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`“coprocessor will handle the complex mathematics of RSA encryption and decryption or other
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`types of math intensive encryption or decryption techniques.” (013 patent 2:55-57, 3:24-26; 510
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`patent 4:61-65, 5:41-42.) Consistent with the specifications’ teachings, the applicants for the 510
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`patent informed the PTO during prosecution that use of “[t]he math co-processor circuit greatly
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`enhances the speed for which the secure microcontroller can process encrypted calculations.”
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`(JX-4, 510 file history 244MAX1122.) This speed increase occurs in part because the
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`coprocessor works concurrently with the main processor to perform the RSA encryption and
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`decryption. At the time of the invention, a coprocessor that works concurrently with a main
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`processor would have been required to, as applicants stated, “greatly enhance[] the speed” of the
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`module. This is because RSA encryption and decryption or other types of math intensive
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`encryption or decryption techniques are by their nature computationally intensive, and at the time
`
`of the invention it would have taken a relatively long time (e.g., a few seconds to a few minutes)
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`for a main processor to perform these intensive encryption and decryption calculations by itself.
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`(See, e.g., Ex. 21, Schneier, Applied Cryptography 181 (1994).) If the main processor of a device
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`was required to perform these computationally intensive calculations alone, the user of that
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`device would have to wait for the main processor to finish its work before the device could
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`perform other tasks. (See, e.g., id.) On the other hand, if a high-speed modular exponentiatio