`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`In re Covered Business Method
`Patent Review of:
`U.S. Patent No. 5,949,880
`
`For: TRANSFER OF VALUABLE
`INFORMATION BETWEEN A SECURE
`MODULE AND ANOTHER MODULE
`
`
`
`
`DECLARATION OF STEPHEN D. BRISTOW
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`I, Stephen D. Bristow, hereby declare and state as follows:
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`1.
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`I have been retained as a technical consultant on behalf of JPMorgan Chase &
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`Co. and JPMorgan Chase N.A., the petitioner in the present proceeding, and I
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`am being compensated at my usual and customary hourly rate. The petition
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`names JPMorgan Chase & Co. and JPMorgan Chase N.A. as real parties-in-
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`interest. I have no financial interest in, or affiliation with, the petitioner, real
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`parties-in-interest, or the patent owner, which I understand to be Maxim
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`Integrated Products, Inc. My compensation is not dependent upon the
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`Docket No. 020358-00006-US06
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`outcome of, or my testimony in, the present covered business method patent
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`review or any litigation proceedings.
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`Background
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`2. My background, qualifications, and experience relevant to the issues in
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`proceeding are summarized below. My curriculum vitae as related to the
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`issues in this proceeding is submitted herewith as Exhibit 1012.
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`3.
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`I am currently Chief Technology Officer of Cloudastructure, an Internet-based
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`video security service, and am currently on retainer to advise, consult with,
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`and maintain Parkinson’s disease testers for the Andy Grove Foundation of
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`Los Altos, California.
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`4.
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`I have a Bachelor of Science degree in Electrical Engineering and Computer
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`Science as a Regent’s Scholar from the University of California at Berkeley. I
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`also have a Master of Science degree in Electrical Engineering from the
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`University of Santa Clara, in Santa Clara, California. During my studies, I
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`took courses in integrated circuit design, communications theory, computer
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`architecture, programming languages such as machine language, assembly
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`language, compiled and interpreted language, as well as programming
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`language theory. I have also attended numerous ongoing continuing
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`education and technical training classes since graduation, which include
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`training in the programming, capabilities, technological limitations, and uses
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`of smart cards by Micro Card Technologies, Inc., a subsidiary of Bull.
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`5. Beginning in 1973, I had the position of Vice President of Engineering for
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`Atari. At that time, Atari’s arcade video games operated on a cash basis, and
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`the company was interested in finding out ways to, and developing the
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`technology to, make it easier for customers to play their video games.
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`Traditional coin-operated games require a large amount of coins, which are
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`bulky and inconvenient for consumers, and need to be periodically emptied
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`and deposited, which can be a burden for arcade operators. Paper currency
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`also has drawbacks, as bill acceptors and change machines at the time had
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`complicated mechanics and electronics, and were expensive. Credit card
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`technologies were also not appropriate, since relatively expensive phone lines
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`would be required for each credit card reader. There was therefore a
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`recognized benefit from having an inexpensive stored-value medium where
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`value could be deposited by the consumer and debited by an arcade machine
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`without communicating with a central authority.
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`6. Through my work at Atari, I began to follow developments in technologies
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`related to cash cards, including magnetic strip paper cards such as those used
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`for mass transit. In the mid-1980s, I became aware of the development of
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`integrated-circuit based “smart cards” which provided persistent storage
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`coupled with a processing capability that could implement sophisticated
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`security protocols.
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`7. Around 1986, I began working with my former Atari colleague Christopher
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`Wright to develop a smart card-based solution for postage-printing stations.
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`Mr. Wright and I started Wright Technologies to research and implement this
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`technology. Larger companies at the time used postage-printing stations to
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`generate U.S. mail postage stamps in-house. This was done using heavy
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`sealed metal boxes that included mechanical levers to set postage amounts,
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`which would use mechanicals to set a stamp imprint. Also included was a
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`mechanical balance calculator, which would decrement as postage stamps
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`were generated. In order to refill the stored value, the box would need to be
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`carried to a postal service branch to be physically opened and configured with
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`additional value. We had the idea of using the secure storage capability of
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`smart cards in conjunction with an intelligent printing device in order to
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`generate secure printed postage value. This work resulted in applications for
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`patents filed by myself and Mr. Wright, which include issued U.S. Patent Nos.
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`4,900,904 (the “’904 patent”) (Exh. 1013) and 4,864,618 (Exh. 1014), both
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`filed October 17, 1988.
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`8. Starting in 1986, Wright Technologies completed working prototypes of a
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`postage terminal that used a smart card to securely store and transmit in an
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`interactive basis financial information between a printing device and a smart
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`card based on user inputs. The smart card stored a running balance and
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`multiple secret “keys” used to secure the transaction with the printing device.
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`A user would enter a desired postage amount into the terminal, which would
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`be transmitted to the smart card. The smart card would then send to a smart
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`printing element within the printing device an encrypted communication that
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`included a request for printing, the amount of the postage to be printed, as
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`well as a challenge number to be used for authentication. The print head
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`would then decrypt the communication and respond to the challenge with the
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`same number encrypted using a different secret key. The smart card would
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`decrypt the response to confirm that the print head is a valid print head. In
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`turn, the print head would send its own encrypted challenge, which the smart
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`card would need to decrypt and re-encrypt using a different secret key. The
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`print head would decrypt the postage amount, and in response print the
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`appropriate amount, and respond with a message indicating the print was
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`successful. Only at this point would the smart card deduct from its balance
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`the amount of the postage.
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`9.
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`In parallel with my work at Wright Technologies, I served as Director of
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`Engineering at Verifone from 1989 to 1991. In that capacity I was responsible
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`for Verifone’s engineering in California and Taiwan. While there we
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`developed a cash card system making use of secure financial transaction data
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`which was produced and used in a number of locations. The terminals for this
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`system were designed to read the contents of the cash card and communicate
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`with a server to complete the transaction.
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`10. One aspect of my work at Verifone included securing transactions against
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`“skimming,” which is the fraudulent duplication of a card to create an
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`identical copy that could then also be used to spend the same value. A cash
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`card system can be vulnerable to a skimming attack when the communication
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`between the cash card and a terminal includes a transaction amount, but no
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`information that uniquely identifies the card as opposed to a copy of the card.
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`One solution we devised to address skimming attacks was to recognize that
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`the magnetic encoding of content on individual cards bears a unique
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`“watermark” that could not be copied by then-existing techniques. This
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`watermark served as an additional piece of unique information that could be
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`used to determine whether a card being presented is the same physical card, or
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`a different physical card, than one presented earlier with the same identifying
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`information.
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`11. Verifone also manufactured credit card reading terminals such as those found
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`in grocery stores. They use encryption techniques, such as DES, to secure
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`communications to and from the terminals. While at Verifone, my team
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`designed and implemented a PIN (Personal Identification Number) pad to
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`allow users to enter their PIN into the Verifone terminal. The PIN pad
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`encrypted the user’s PIN using DES encryption.
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`12. In 1994, Wright Technologies licensed the secure smart card transaction
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`patents that grew out of our postage metering product to Pitney-Bowes, and
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`were retained by Pitney-Bowes to develop production versions of a postage
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`metering system based on our prototype. We ultimately completed a
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`production system which was rolled out and marketed. We ceased our work
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`with Pitney-Bowes in 1998, and I continued to develop further smart card-
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`based applications including an office telephone that used a smart card to
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`retain a user’s identity in a mobile office situation. In this system, office
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`telephones were configured to accept a smart card, and would read the
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`contents of the card. The phone would then communicate with the office
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`phone network so that calls would be routed to a user’s current location, as
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`well as having autodial and other preferences carried with a user rather than
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`tied to a specific phone.
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`13. Through work related to smart cards I have also become aware of how smart
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`cards are used in the satellite broadcast field, in particular, the use of smart
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`cards to store subscriber information and permissions, and to control the
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`encryption and decryption of secure broadcasts.
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`14. During the time period above, and through the present, I have regularly
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`attended trade shows, including the Consumer Electronics Show (“CES”) and
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`the National Association of Broadcasters (“NAB”) trade show. At these trade
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`shows I would observe other companies’ developments in the area of smart
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`cards and stored value card, in particular as they related to stored value and
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`security permission and authentication.
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`15. I am also a member of the Institute for Electrical and Electronics Engineers
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`(“IEEE”), and have been a member of the Administrative Committee for the
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`Consumer Electronics Society for the IEEE, as well as a member of the
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`Society for Motion Picture and Television Engineers (“SMPTE”), the
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`Program Committee for the Society for Information Display (“SID”), and
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`other relevant professional organizations. Through my work with these
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`organizations, I have also become familiar with the state of the art of smart
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`cards on a continuing basis.
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`16. My work in the smart card field included implementing security features.
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`These included mechanical security features of devices themselves; optical
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`security in the form of ensuring that, for example, printed postage stamps
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`were proof against copying, as well as electronic security to ensure the
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`integrity of the smart card interaction.
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`17. The patents that issued out of my work in smart cards include U.S. Patent No.
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`4,900,904 (Exh. 1013), which describes a secure transaction system that can
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`be used in a smart card/terminal system. The scheme described in the ’904
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`patent uses, among other things, a challenge and response authentication. In
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`that authentication, a smart card first generates a random number and encrypts
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`it with a known algorithm using a shared key. The smart card sends the
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`encrypted number to the terminal, which decrypts the number with the inverse
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`algorithm using the same key. The terminal then re-encrypts the same number
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`using a different algorithm, which it sends back to the smart card. The card
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`decrypts using the inverse of the different algorithm, and verifies that it has
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`received the same random number that was sent. If so, the transaction is
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`authorized. See, e.g., ‘904 Patent at 3:46-66. Encryption, according to
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`methods of the time, generally consisted of applying known mathematical
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`operations to a piece of information, where the mathematical operations take
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`the encryption/decryption key as an argument. The mathematical operations
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`can then be reversed by using the same key (in the case of shared key
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`systems) or an inverse key (in the case of public-key cryptographic systems).
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`Materials Considered
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`18. I have reviewed each of the following:
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`a. U.S. Patent No. 5,949,880 (“the ’880 Patent”), including the claims,
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`description and prosecution history (which are identified in the
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`Petition respectively as Exhibits 1001 and 1002);
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`b. U.S. Patent No. 5,940,510 (“the ’510 Patent”), which is the parent of
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`the ’880 Patent (Exh. 1003);
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`c. U.S. Patent No. 5,428,684 to Akiyama et al. (Exh. 1004; hereinafter
`
`“Akiyama”).
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`d. Integrated Circuit Cards, Tags, and Tokens by P.L. Hawkes, et al.
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`(Exh. 1005; hereinafter “Hawkes”), which includes:
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`i. P.L. Hawkes, Preface & Introduction (“Hawkes Preface &
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`Introduction”);
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`ii. Chapter 2: Smart Card Technology – A US Pioneer’s Viewpoint
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`by A.R. Lessin (hereinafter, “Hawkes Chapter 2”);
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`iii. Chapter 6: Secure Transactions with an Intelligent Token by
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`W.L. Price and Bernard J. Chorley (hereinafter, “Hawkes
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`Chapter 6”); and
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`iv. Chapter 8: Cryptography and the Smart Card by D.W. Davies
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`(hereinafter, “Hawkes Chapter 8”).
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`e. Whitfield Diffie and Martin Hellman, New Directions in
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`Cryptography, IEEE TRANS. INFORM. THEORY IT-22, 6 (Nov.
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`1976), 644-654 (Exh. 1015, hereinafter, “Diffie-Hellman”)
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`f. Rivest, et al., A method for obtaining digital signatures and public key
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`crypto-systems, Communications of ACM, Volume 21, Number 2
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`(1978) (Exh. 1016, hereinafter, “Rivest”).
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`19. Upon reviewing the ’880 Patent, I understand that a non-provisional
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`application was filed on November 26, 1997 (Appl. No. 08/978,798) as a
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`divisional from application number 08/594,975, itself filed on January 31,
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`1996. Application number 08/978,798 issued as the ’880 Patent. For the
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`purposes of my analysis, based on the filing date that appears on the patent, I
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`assume the time of the purported invention to be January, 1996.
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`Level of Ordinary Skill in the Art
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`20. It is my opinion that a person of ordinary skill in the art at the time of the
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`inventions claimed in the ’880 Patent would have had at least a B.S. degree in
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`electrical engineering or computer engineering with at least two years of
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`practical or post-graduate work in the areas of secure financial transactions
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`and real-time microcontroller programming, or, alternatively, an additional
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`year (at least three years) of postgraduate or professional experience in
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`computer systems engineering related to secure data transactions, or the
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`equivalent. I was a person of at least ordinary skill in this art in January,
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`1996.
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`State of the Art in 1995
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`21. The development and rapid proliferation of computing technology in the
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`1990’s, and in particular its application to financial transactions, created a
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`requirement for computerized mechanisms for secure communications.
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`22. In discussing my background, I explained developments in this area that I was
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`involved in. In particular, as described in further detail above, almost ten
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`years prior to 1995 I was personally involved in developing a smart card
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`solution to completing financial transactions with a postage metering terminal.
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`This solution included storing both the programming necessary to process a
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`transaction and a cash balance on the smart card, coupled with an encrypted
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`authentication and communication process between the smart card and a
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`custom integrated-circuit based printing device.
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`23. Others in the industry were also developing smart card technology well before
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`1995. For example, as described in Hawkes Chapter 2, Roland Moreno
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`obtained patents on smart card technology in 1975 that were licensed to
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`companies such as Honeywell Bull, Schlumberger and Philips by 1978.
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`Hawkes Chapter 2, p. 26.
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`24. By 1985, financial services companies such as Visa were developing smart
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`card technology. Id. at 26. By 1987, France was using smart cards as bank
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`cards. Id. at 27.
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`25. The Hawkes Chapters, published in 1990, disclose various aspects of
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`integrated circuit devices holding data, such as monetary equivalents, that can
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`be manipulated in a secure manner to prevent tampering. For example,
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`Hawkes Chapter 6 discloses an “intelligent token.” Figure 6.3 shows a block
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`diagram of the “intelligent token.”
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`26. Encryption technology as it relates to smart cards was mature by 1995.
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`Shared key encryption schemes, which rely on two parties to a communication
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`performing known algorithms to encrypt and decrypt messages using the same
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`secret key, had already been in use for some time. In 1976, Whitfield Diffie
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`and Martin Hellman published their seminal paper describing a public key
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`cryptography system where the two parties to a communication instead use
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`different keys. See Diffie-Hellman, Exh. 1015. In a public key cryptography
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`system, each entity has two keys. Id. at 647-648. One key is made public,
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`and the other kept private; the public key can decrypt information encrypted
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`with the private key, and vice versa. Id. Diffie-Hellman articulated the
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`concept of a public key cryptography system, but did not fully describe an
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`implementation to put the concept into practice. Two years later, in 1978,
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`Rivest, Shamir, and Adelman published an implementation of a public key
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`cryptography system called “RSA.” See Rivest. Within 10 years, by 1987,
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`RSA-specific chip designs were made available and marketed, and it was
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`recognized that implementing RSA on smart card chips was feasible. See,
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`e.g., Hawkes Chapter 8, p. 151. One such smart card, incorporating a math
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`coprocessor to perform RSA calculations, was developed as a prototype for a
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`pilot program in the U.K. See Hawkes Chapter 6, pp. 87-88.
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`Overview of the ’880 Patent
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`27. Based on my review of the ’880 Patent, it describes a method for
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`communicating valuable data from one module to another module via an
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`interface that enables a user to fill a module with a unit of exchange and to use
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`or transfer the units to other modules. ’880 Patent, Abstract.
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`28. The main disclosure in the specification relevant to the claims of the ’880
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`Patent is of the communication of data between two modules to handle
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`debiting the cost of a train fare on a stored value card. ’880 Patent at 7:8-9:16.
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`The user of one module 102 puts it into communication with the electronic
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`device 104. ’880 Patent at 7:28-35. The microprocessor based device 104
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`receives information from the module 102. In the specification this data can
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`include “the portable module's serial number, transaction count, and the
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`encrypted data packet,” although the claim merely requires a “first value
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`datum.” Id. at 7:36-39. The “encrypted data packet” is described as
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`containing the ID number, transaction count, and account balance. Id. at 7:23-
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`27. The electronic device 104 then passes this information to the other
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`module 108, which performs a sequence of mathematical operations that
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`include decrypting the encrypted data found in the first data, making a few
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`comparisons to make sure that the data received is authentic as between the
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`non-encrypted data and the encrypted data packet. Id. at 7:43-54. The second
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`module 108 then “subtracts the first value, the train fare, from the monetary
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`value” that was received from the first module and decrypted. Id. at 7:61-65.
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`29. The second module 108 then creates a data packet, a second data, which the
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`specification describes, but the patent does not claim, as comprising at least
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`“the portable module's serial number, the incremented transaction count, and
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`the reduced monetary value of the portable module 102.” Id. at 7:66-8:7. The
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`packet is then encrypted and returned to the first module, which stores the
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`packet. Id. at 8:6-13.
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`30. The communication of data described in the ’880 Patent occurs between two
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`“modules” and through an “electronic device,” which are shown in Figure 1 of
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`the ’880 Patent:
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`Module 102, which is described in the specification as being a “portable
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`module” but is not claimed as such, communicates with an electronic device
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`104 through a communication means 106, and device 104 in turn relays those
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`communications to another module 108, which is described in the
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`specification as being a secure microprocessor based device 108.
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`Fundamentally, the ’880 Patent is directed to exchanging, modifying, and
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`updating records stored in memory. Those records are used to represent items
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`of value.
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`31. I have reviewed the ’510 Patent, which is the parent of the ’880 Patent. The
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`’510 Patent claims the “portable module 102” and “secure module 108”
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`described in the specification. Since the claims of the ’880 Patent use the
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`more general term “module,” rather than “portable module” and “secure
`
`module,” it is my opinion that a person of ordinary skill in the art would
`
`understand that the module includes a basic set of structures and features
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`required to carry out the functions claimed in the method of the ’880 Patent.
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`For illustrative purposes, Figures 2 and 3 of the ’880 Patent illustrate the
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`structure of the non-claimed portable module and secure module:
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`Based on the descriptions of the portable module and secure module, it is my
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`understanding that a person of ordinary skill in the art would not interpret the
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`term “module” to refer to either the “portable module” or the “secure module”
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`specifically, but instead to a broader category of hardware that can perform
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`the recited functions. For example, the generic “module” does not need to
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`include a math coprocessor, since only the secure module 108, and not the
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`portable module 102, includes a math coprocessor. ’880 Patent at 3:40-4:25,
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`4:26-5:35. Both of the described modules include an input/output circuit and,
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`because the claim recites communication between the modules and the
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`electronic device, it is my opinion that a person of ordinary skill in the art
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`would understand the module to also include hardware for communicating.
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`The claimed first module recites being able to store a value, therefore the first
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`module must contain a memory. Since the claimed second module can
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`receive and operate on data, ’880 Patent at 4:27-39, 7:45-8:7, a person of
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`ordinary skill would also understand the second module to contain a memory.
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`While the portable module 102 and secure module 108 both have an ID
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`number and clock circuit, neither of these structures are required by the claims
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`of the ’880 Patent. Since the claims only require the ability to send and
`
`receive data, to mathematically operate on data, and to store data, it is my
`
`opinion that the only structures that a person of ordinary skill in the art would
`
`understand the ’880 Patent to require are a memory control circuit or
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`processor, memory, and input/output circuit.
`
`32. The specification describes the components of the “module” as follows:
`
`a. The two modules described in the specification are both described as
`
`having a “memory.” In the portable module, the memory is described
`
`as being “for storing and retrieving vital information pertaining to the
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`system to which the module 102 may become attached to.” Id. at
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`3:57-60. For the secure module, the memory is described as being
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`“both read-only memory and non-volatile random-access-memory”
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`and that “one of ordinary skill in the art would understand that volatile
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`memory, EPROM, SRAM and a variety of other types of memory
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`circuitry might be used.” Id. at 4:66-5:4. A person of ordinary skill in
`
`the art would understand this to be no different than ordinary
`
`memories that can be used to store data on a generic computer, such
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`as read-only memories (“ROM”) or andom-access memory. Generic
`
`computers generally use a nonvolatile memory like a ROM for
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`storing, for example, programs or data that do not need to be changed
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`and should be the same every time a computer is used.
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`b. The two modules in the specification are both described as having
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`their own “input/output circuit” which is described as a circuit that
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`either “controls the data flow into and out of the portable module
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`102,” in the case of the one, or that “enables bidirectional
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`communication.” Id. at 4:10-24; 5:7-8. A person of ordinary skill in
`
`the art would understand that generic computers include hardware that
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`allows a computer to receive data input or generate data output for
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`communication with other systems. Generic computers include an
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`input/output circuit.
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`c. The two modules in the specification are described as having circuits
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`for controlling the contents of memory. One module has a “memory
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`control circuit” which is described as a memory controller that
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`“controls the reading and writing of data into and out of the memory
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`202.” Id. at 4:4-6. The other module has a “microcontroller core”
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`that is described to be a generic microprocessor, such as “preferably
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`an 8-bit microprocessor.” Id. at 4:56-57. A person of ordinary skill in
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`the art would understand that generic computers include circuits, such
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`as processors, to read and write contents to or from memory.
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`33. The use of smart cards to fulfill the role of a “module” as described above was
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`well-known in the prior art at the time of the invention. As described in
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`Hawkes Chapter 6, for example, existing smart cards had a memory,
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`processor, and input/output circuits. The exemplary card included a
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`“TMS7000 series of 8-bit microprocessors,” “32 K bytes of program
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`memory,” “8K bytes of battery backed RAM,” and “[c]ommunication
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`between the token and the outside world . . . by way of a three-wire serial
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`interface.” Hawkes Chapter 6, p. 87; Fig 6.3. A person of ordinary skill in
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`the art would understand that the claims of the ’880 Patent are not limited to
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`smart cards or other portable devices, as, for example, the specification
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`describes an embodiment where the first module can be attached to cargo,
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`’880 Patent, 3:50-56, and where the second module can be incorporated into
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`“a computer.” Id. at 4:36.
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`34. The ’880 Patent does not include a detailed description of the structure of the
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`“microprocessor based device 104.” Instead it broadly states that that
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`electronic device 104 “can be any of an unlimited number of devices.” ’880
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`Patent at 2:37-38. Examples include a “personal computer, an add-a-fare
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`machine at a train or bus station (similar to those in today's District of
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`Columbia metro stations), a turn style, a toll booth, a bank's terminal, a ride at
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`a carnival, a washing machine at a Laundromat, a locking device, a mail
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`metering device or any device that controls access, or meters a monetary
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`equivalent, etc.” Id. at 2:38-45. The main description of the device 104 is
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`functional, describing what the device 104 can do instead of what it is. The
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`electronic device both (1) can receive data from the first module and provide
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`it to the second module, and (2) receive data from the second module and
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`provide it to the first module. From this description, a person of ordinary skill
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`in the art would understand that the ’880 Patent conceives of any generic
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`computer fulfilling these functional roles. Moreover, the form of
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`communication between the portable module reader and the portable module
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`is described as being “preferably via a single wire or contact connection,” but
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`could instead be “multiple wires, a wireless communication system, infrared
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`light, any electromagnetic means, a magnetic technique, or any other similar
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`technique.” Id. at 2:52-58. A person of ordinary skill would understand that
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`the communication is not limited to any particular structure or form of
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`communication, and that generic computers at the time were able to
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`communicate over wired, wireless, infrared, and a variety of other ways.
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`Since any possible form of communication was contemplated, a generic
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`computer would be able to fulfill this role.
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`35. The electronic device 104 could also be met by a device that is integrated into
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`one of the two modules. There is nothing in the claim or specification that
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`mandates that either of the modules be separate from the electronic device
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`104. Indeed, Figure 1 above shows the secure module 108 and
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`microprocessor based device 104 surrounded by a hashed line. This is
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`emphasized by the specification explicitly referring to the communication
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`means 106 on Figure 1 as being wired or wireless, while only mentioning
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`wired communication as between the secure module 108 and microprocessor
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`based device 104. Moreover, a person of ordinary skill would understand that
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`for the types of microprocessor based devices 104 described in the ’880
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`Patent—for example a Laundromat, mass transit fare turnstyle, or mail
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`metering device—it would be practical to include the secure module inside the
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`device for added physical security of the secure module. Because the ’880
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`Patent does not claim a “portable” module and a “secure” module, the recited
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`electronic device could be integrated into either recited module.
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`Claim Construction
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`36. I have been asked to offer my opinion regarding the understanding of a person
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`skilled in the art regarding certain claim terms in the ’880 Patent. I
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`understand that in the present proceeding, claim terms are interpreted as the
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`broadest reasonable construction consistent with the specification. Based on
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`my review of the ’880 Patent, it is my opinion that the terms below should be
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`construed to clarify the scope of the terms as it would be understood by a
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`person of ordinary skill in the art. Other terms would carry their plain and
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`ordinary meaning, and do not require construction.
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`37. Based on my review, the ’880 Patent does not require that the “electronic
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`device” be distinct from either the first module or second module under the
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`broadest reasonable construction. Since it is defined functionally, any
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`electronic structure that can perform that function could meet the limitation.
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`For example, an input/output interface like a wireless, wired, conductive, or
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`other kind of interface on one of the two modules, or an integrated computer
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`that includes both the module and a communication interface for the module,
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`could meet this limitation.
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`“Module” (Claim 1)
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`38. The term “module” should be construed. Unlike in the ’510 Patent, which in
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`the claims identifies the elements of a “portable module” and “secure
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`module,” the ’880 Patent does not claim any constituent elements of the
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`“module.” Although the specification describes components of the portable
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`module and secure module, the ’880 Patent does not claim a portable module
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`or a secure module. The ’880 Patent only claims two “modules.” Because the
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`’510 Patent used the special terms “porta