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`AMEX 1018
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`AMEX 1018AMEX 1018AMEX 1018
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`In re Covered Business Method
`Patent Review of:
`U.S. Patent No. 5,940,510
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`For: SYSTEM FOR COMMUNICATING
`DATA SECURELY
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`
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`DECLARATION OF STEPHEN D. BRISTOW
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`
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
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`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 JP Morgan Chase &
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`Co. and JP Morgan 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 JP Morgan Chase & Co. and JP Morgan 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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`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 1010.
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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”) (Exhibit 1019) and 4,864,618 (Exhibit 1020),
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`both 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. Verifone also manufactured credit card reading terminals such
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`as those found in grocery stores. They use encryption techniques, such as
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`DES, to secure communications to and from the terminals. While at Verifone,
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`my team designed and implemented a PIN (Personal Identification Number)
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`pad to 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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`11. 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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`12. 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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`13. 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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`14. 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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`15. 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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`16. The patents that issued out of my work in smart cards include U.S. Patent No.
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`4,900,904 (Exhibit 1019), which describes a secure transaction system that
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`can be used in a smart card/terminal system. The scheme described in the
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`’904 patent uses, among other things, a challenge and response authentication.
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`In that authentication, a smart card first generates a random number and
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`encrypts it with a known algorithm using a shared key. The smart card sends
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`the encrypted number to the terminal, which decrypts the number with the
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`inverse algorithm using the same key. The terminal then re-encrypts the same
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`number using a different algorithm, which it sends back to the smart card.
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`The card decrypts using the inverse of the different algorithm, and verifies
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`that it has received the same random number that was sent. If so, the
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`transaction is authorized. See, e.g., ‘904 Patent at 3:46-66.
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`17. Through my work, I have become familiar with public-private key encryption,
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`and in particular the RSA implementation of public-private key encryption. In
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`a public-private key system, each side to a communication has both a “public”
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`key, which is made generally available, and a “private” key, which is kept
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`secret. Either key can be used to encrypt a message, which can only be
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`decrypted using the other key. The RSA system for generating public and
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`private keys was described in a paper by Rivest, Shamir, and Adelman
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`(Exhibit 1005).
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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. 5,940,510 (“the ’510 Patent”), including the claims,
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`description and prosecution history (which are identified in the Petition
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`respectively as Exhibits 1001 and 1002);
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`b.
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`c.
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`International Patent Application Publication No. WO 1983/003018 to
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`Cremin at al. (Exh. 1003; hereinafter “Cremin”);
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`Integrated Circuit Cards, Tags, and Tokens by P.L. Hawkes, et al. (Exh.
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`1004; hereinafter “Hawkes”), which includes:
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`i. Preface and Introduction by P.L. Hawkes (“Hawkes Preface &
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`Introduction”);
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`ii. Chapter 2: Smart Card Technology – A US Pioneer’s Viewpoint by
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`A.R. Lessin (hereinafter, “Hawkes Ch. 2”);
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`iii. Chapter 6: Secure Transactions with an Intelligent Token by W.L.
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`Price and Bernard J. Chorley (hereinafter, “Hawkes 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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`d. 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 (1978).
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`(Exh. 1005).
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`19. Upon reviewing the ’510 Patent, I understand that a non-provisional
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`application was filed on January 31, 1996 (Appl. No. 08/594,975), which
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`issued as the ’510 Patent. For the purposes of my analysis, based on the filing
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`date that appears on the patent, I assume the time of the purported invention to
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`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 ’510 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
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`was involved in. In particular, as described in further detail above, almost
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`ten 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
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`terminal. This solution included storing both the programming necessary to
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`process a transaction and a cash balance on the smart card, coupled with an
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`encrypted authentication and communication process between the smart
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`card and a custom integrated-circuit based printing device.
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`23. Others in the industry were also developing smart card technology well
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`before 1995. For example, as described in Hawkes Ch. 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 Ch. 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
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`can be manipulated in a secure manner to prevent tampering. For example,
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`Hawkes Ch. 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
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`communication performing known algorithms to encrypt and decrypt
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`messages using the same secret key, had already been in use for some time.
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`In 1976, Whitfield Diffie and Martin Hellman published their seminal paper
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`describing a public key cryptography system where the two parties to a
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`communication instead use different keys. See Diffie-Hellman. In a public
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`key cryptography system, each entity has two keys. Id. at 647-648. One
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`key is made public, and the other kept private; the public key can decrypt
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`information encrypted with the private key, and vice versa. Id. Diffie-
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`Hellman articulated the concept of a public key cryptography system, but
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`did not fully describe an implementation to put the concept into practice.
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`Two years later, in 1978, Rivest, Shamir, and Adelman published an
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`implementation of a public key cryptography system called “RSA.” See
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`Rivest. Within 10 years, by 1987, RSA-specific chip designs were made
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`available and marketed, and it was recognized that implementing RSA on
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`smart card chips was feasible. See, e.g., Hawkes Ch. 8, p. 151. One such
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`smart card, incorporating a math coprocessor to perform RSA calculations,
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`was developed as a prototype for a pilot program in the U.K. See Hawkes
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`Ch. 6, pp. 87-88.
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`Overview of the ’510 Patent
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`27. Based on my review of the ’510 Patent, it describes a system for
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`communicating a cash equivalent to and from a portable module. ’510
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`Patent, Abstract.
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`28. Figure 2 of the ’510 patent is an illustrative block diagram showing the
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`components of the system for communicating data securely between a
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`portable module (portable module 102) and a secure module (secure
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`microprocessor based device 108) through a portable module reader
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`(microprocessor based device 104):
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`Portable module 102 communicates with a microprocessor based device
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`104 through a communication means 106, and device 104 in turn relays
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`those communications to secure microprocessor based device 108. In
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`addition to the secure microprocessor based device 108, the device 104 can
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`be connected to a number of other systems, such as a credit card reader 114
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`or phone line 116.
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`29. The structure of a portable module 102 is shown in Figure 2 of the ’510
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`Patent:
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`Figure 2 illustrates components described in the specification that include a
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`memory 202, input/output circuit 212, timer 208, counter 206, and
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`substantially unique identification number 210. A memory circuit 204
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`controls reading and writing to and from these various components.
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`30. The “portable module” is recited as having the following components, all of
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`which are readily understood by a person of ordinary skill to be components
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`of generic computers:
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`a. The “nonvolatile memory for storing a first data” is described in the
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`specification as being “for storing and retrieving vital information
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`pertaining to the system to which the module 102 may become
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`attached to.” Id. at 3:57-60. The claim references that the
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`“nonvolatile memory” is “for storing a first data,” but does not further
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`qualify what the “first data” is. A person of ordinary skill in the art
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`would understand this to be no different than ordinary memories that
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`can be used to store data persistently on a generic computer, such as
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`read-only memories (“ROM”), or random-access memory whose
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`contents are preserved by a battery even after the main device is no
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`longer receiving power. Generic computers generally use a
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`nonvolatile memory like a ROM for storing, for example, programs or
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`data that do not need to be changed and should be the same every time
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`a computer is used.
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`b. The only disclosure in the specification related to the “real time clock
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`circuit for time stamping data transactions” is the description in the
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`specification of a “timer 102” that “may be provided in the module to
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`provide the ability to time stamp transactions performed by the
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`module.” Id. at 4:2-4 I understand the reference to “timer 102” to be
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`intended to refer to “timer 208” shown in Figure 2, although neither
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`timer is referred to anywhere else in the patent. Id. at Fig. 2. A
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`person of ordinary skill would understand that this the function of
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`“time stamping” can be provided by the real time clock typically
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`incorporated in generic computers. The “time stamping,” moreover,
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`simply refers to reading and writing a value from a clock to some
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`other data in order to mark when the data was generated. Generic
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`computers include a real time clock that can be used to time stamp
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`transactions.
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`c. The “counter for counting a transaction count” is described as being
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`“for keeping track of the number of transactions the module has
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`performed.” Id. at 3:66-4:2. A person of ordinary skill in the art
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`would understand that this functional description could refer to
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`hardware or software that keeps track of a value that can incremented
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`periodically. The person would further understand that this counter
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`can be implemented by a simple location in memory representing a
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`number. Generic computers include memory that can be used as a
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`counter.
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`d. The “input/output circuit” is described as being a circuit that “controls
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`the data flow into and out of the portable module 102.” Id. at 4:10-24.
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`A person of ordinary skill in the art would understand that generic
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`computers include hardware that allows a computer to receive data
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`input or generate data output for communication with other systems.
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`Generic computers include an input/output circuit.
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`e. The “substantially unique electronically readable identification
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`number” is described as being something that “identifies the portable
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`module from any other portable module.” Id. at 4:7-9. A person of
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`ordinary skill in the art would understand that hardware or software in
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`a generic computer can store a number that can identify a device and
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`distinguish it from other devices.
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`f. The “memory control circuit” 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. A person of ordinary skill in the art would
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`understand that generic computers include various circuits to read and
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`write contents to or from memory.
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`31. The ’510 Patent does not include a detailed description of the structure of
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`the portable module reader (microprocessor based device 104). The patent
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`instead describes that it “can be any of an unlimited number of devices.”
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`’880 Patent at 2:37-46. Examples of the kind of device it can be include a
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`“personal computer, an add-a-fare machine at a train or bus station (similar
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`to those in today's District of Columbia metro stations), a turn style, a toll
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`booth, a bank's terminal, a ride at a carnival, a washing machine at a
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`Laundromat, a locking device, a mail metering device or any device that
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`controls access, or meters a monetary equivalent, etc.” Id. The main
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`description of the device 104 is functional, describing what the device 104
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`can do instead of its structure.
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`32. The “portable module reader” is a device that mediates communication
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`between a portable module and a secure module. The “portable module
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`reader” is not described as having any components, but instead is described
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`functionally by what it is capable of doing. The portable module reader
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`both (1) can be placed in communication with a portable module, and (2)
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`can be connected to a plurality of other devices. From this description,
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`coupled with the discussion of the portable module reader in the
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`specification, a person of ordinary skill in the art would understand that any
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`generic computer can fulfill these functional roles. The specification is
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`clear that the portable module reader, which it calls “microprocessor based
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`device 104,” can be “any of an unlimited number of devices,” including “a
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`personal computer.” ’510 Patent, 2:37-45. The form of communication
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`between the portable module reader and the portable module is, moreover,
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`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,
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`infrared light, any electromagnetic means, a magnetic technique, or any
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`other similar technique.” Id. at 2:52-58. A person of ordinary skill would
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`understand that the communication is not limited to any particular structure
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`20
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`AMEX 1018 - Page 20 of 44
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`Docket No. 020358-00006-US05
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`or form of communication, and that generic computers at the time were able
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`to communicate over wired, wireless, infrared, and a variety of other ways.
`
`Since any possible form of communication was contemplated, a generic
`
`computer would be able to fulfill this role. The specification also
`
`contemplates that the “plurality of other devices” that the portable module
`
`reader can be connected to “include, but are not limited to a cash acceptor
`
`110, an automatic teller machine (ATM) 112, a credit card reader 114, and
`
`a phone line 116.” Id. at 2:66-3:2. A person of ordinary skill would
`
`understand that each of these devices would refer to systems to which a
`
`generic computer could be connected using a serial data connection,
`
`network connection, or phone connection. Generic computers at the time
`
`included a variety of ways to provide communication with external,
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`peripheral devices.
`
`33. The structure of a secure microprocessor based device 108 is illustrated in
`
`Figure 3:
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`21
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`AMEX 1018 - Page 21 of 44
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`
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`Figure 3 illustrates the components including a micro processor 12, math
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`coprocessor 18, real time clock 14, memory control 16, memory 20,
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`input/output circuit 26, and an energy circuit 34. The specification
`
`describes the structure of the secure module “can be a single integrated
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`circuit,” but “could also be a monolithic or multiple circuits combined
`
`together.” 4:25-29.
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`22
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`AMEX 1018 - Page 22 of 44
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`34. The “secure module” is recited as having the following components, all of
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`which are readily understood by a person of ordinary skill to be components
`
`of generic computers:
`
`a. The “microcontroller core” is described to be a generic
`
`microprocessor, such as “preferably an 8-bit microprocessor.” Id. at
`
`4:56-57. Generic computers include a processor to control the
`
`operation of the computer.
`
`b. The “math coprocessor” is described as being “designed and used to
`
`handle very large numbers. In particular, the coprocessor will handle
`
`the complex mathematics of RSA encryption and decryption or other
`
`types of math intensive encryption or decryption techniques.” Id. at
`
`4:61-65. A person of ordinary skill in the art would understand that at
`
`the time of the patent generic computers had regularly included
`
`circuits that operated in conjunction with a central processing unit to
`
`provide enhanced mathematical computation ability. The trend
`
`towards on-chip math coprocessors is shown by, for example,
`
`Motorola’s announcement years earlier of its 68040 chip that included
`
`an on-board math coprocessor, and it was known that they would
`
`significantly improve the performance of encryption and decryption
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`techniques. Martin Marshall, Motorola Unveils Details of 68040,
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`23
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`AMEX 1018 - Page 23 of 44
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`INFOWORLD, April 3, 1989 at 105 (Exh. 1015). Math coprocessors
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`were recognized in the field as a key component for efficiently
`
`processing encryption routines. Erik Sandberg-Diment, The
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`Executive Computer; How To Improve A PC's Math Skills, THE
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`NEW YORK TIMES, January 19, 1986 (Exh. 1016).
`
`c. The “energy circuit” is described as “necessary to maintain stored
`
`information in the memory circuitry 20 and/or aid in powering the
`
`other circuitry in the module 108.” ’510 Patent, 5:17-22. Since the
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`energy circuit is described as being used to power any circuitry in the
`
`module, a person of ordinary skill in the art would understand this
`
`disclosure to refer to any power source used by the module. Generic
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`computers run off of electricity, and have circuits to receive power
`
`from either a battery or a power main.
`
`d. The “memory circuit” is described as being able to “contain both
`
`read-only-memory and non-volatile random-access-memory” and
`
`“volatile memory, EPROM, SRAM and a variety of other types of
`
`memory circuitry might be used to create an equivalent device.” Id. at
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`5:1-4. A person of ordinary skill in the art would understand this to
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`refer to any form of memory in the module. Generic computers
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`include a memory control circuit.
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`24
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`AMEX 1018 - Page 24 of 44
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`e. As for the portable module 102, the “real time clock circuit” is
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`generally understood to be a clock that keeps track of the current date
`
`and/or time. Generic computers include a real time clock.
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`Claim Construction
`
`35. I have been asked to offer my opinion regarding the understanding of a
`
`person skilled in the art regarding certain claim terms in the ’510 Patent. I
`
`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 my review of the ‘510 Patent, it is my opinion that the terms in the ‘510
`
`Patent would be understood by a person of ordinary skill in the art to carry
`
`their plain and ordinary meaning, and do not require construction. In
`
`particular, the claims provide context to understand the structure and
`
`function of each of the two modules (by reference to their components,
`
`which a person of ordinary skill would understand to be generic computer
`
`components), and the portable module reader (by reference to its
`
`communication functions).
`
`Cremin
`
`36. Based on my review, Cremin discloses a system to securely transfer data
`
`between two portable integrated circuit cards through a coupling terminal.
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`25
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`AMEX 1018 - Page 25 of 44
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`In one embodiment of Cremin, one card is held by a “consumer” (such as a
`
`customer) wishing to make a payment and the other card held by a “trader”
`
`(such as a store) wishing to receive a payment from the consumer. Id. at
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`5:22-6:4.
`
`37. An example of the structure of the portable integrated circuit cards, which
`
`applies to both the consumer and the trader, is shown in Figure 2. Cremin
`
`states that this example can be illustrative of both the trader card and the
`
`consumer card. Id. at 6:2-4:
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`26
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`AMEX 1018 - Page 26 of 44
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`
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`Figure 2 in Cremin discloses structures recited as part of the claimed portable
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`module and secure module in the ‘510 Patent. These include a central
`
`processing unit 12 that controls reading and writing from read-only memory
`
`11, which is nonvolatile; a clock generator 15 that is used t
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