UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`GOOGLE INC.,
`
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`
`Patent Owner.
`
`________________________
`Case CBM2015-00126
`Patent 8,118,221 B2
`________________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
`
`
`
`
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`GOOGLE INC.,
`
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`
`Patent Owner.
`
`________________________
`Case CBM2015-00126
`Patent 8,118,221 B2
`________________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`
`Statement of Precise Relief Requested ............................................................ 1
`I.
`Patent Owner Smartflash Timely Objected to Petitioner’s Exhibits ............... 1
`II.
`III. Argument ......................................................................................................... 1
`A.
`Exhibit 1002 Lacks Foundation, is Unreliable, and Relies on
`Irrelevant Exhibits ................................................................................. 1
`Exhibits 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1022, 1023, and
`1024 are Not Alleged to be Invalidating Prior Art and thus are
`Irrelevant ............................................................................................... 8
`Exhibit 1015 is Irrelevant, Inadmissible Other Evidence of the
`Content of a Writing, and Cumulative ................................................ 11
`IV. Conclusion ..................................................................................................... 13
`
`
`B.
`
`C.
`
`i
`
`
`
`
`
`
`I.
`
`Statement of Precise Relief Requested
`
`Pursuant to 37 C.F.R. §§ 42.62 and 42.64(c), Patent Owner Smartflash LLC
`
`moves to exclude Exhibits 1002, 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1015
`
`1022, 1023, and 1024.
`
`II.
`
`Patent Owner Smartflash Timely Objected to Petitioner’s Exhibits
`
`Patent Owner Smartflash LLC timely objected to CBM2015-00126 Exhibits
`
`1002, 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1015 1022, 1023, and 1024 by
`
`filing Patent Owner’s Objections to Admissibility of Evidence. Paper 10.
`
`III. Argument
`Pursuant to 37 C.F.R. § 42.64(c), the Federal Rules of Evidence apply in
`
`Covered Business Method Review (“CBM”) proceedings.
`
`A. Exhibit 1002 Lacks Foundation, is Unreliable, and Relies on
`Irrelevant Exhibits
`
`Patent Owner moves to exclude Exhibit 1002, Declaration of Dr. Justin
`
`Douglas Tygar Regarding the ’221 Patent (“Tygar Declaration”), in its entirety as
`
`the Tygar Declaration does not demonstrate that Dr. Tygar is an expert whose
`
`testimony is relevant to the issue of patent eligibility under 35 U.S.C. § 101, the
`
`only issue on which this CBM was instituted. Whether claims are directed to
`
`statutory subject matter is “an issue of law.” Institution Decision, CBM2015-
`
`00129, Paper 8, page 18. When asked if he intended any of his opinions in this
`
`matter to be considered legal opinions, Dr. Tygar responded “absolutely not.”
`
`
`
`1
`
`
`
`
`
`Exhibit 2105, Tygar Deposition at 7:4-7. Thus, Dr. Tygar’s opinions on whether
`
`claims of the ‘221 Patent are directed to statutory subject matter, a question of law,
`
`are irrelevant, and his Declaration should be excluded.
`
`Moreover, given that patent eligibility under § 101 is a purely legal issue,
`
`opinions such as those rendered by Dr. Tygar on the ultimate question of patent
`
`eligibility in ¶¶ 54-67 of his declaration constitute testimony on United States
`
`patent law or patent examination practice. Such testimony is inadmissible under
`
`37 C.F.R. § 42.65 (“testimony on United States patent law or patent examination
`
`practice will not be admitted”).
`
`Further, Dr. Tygar has not shown that his opinions are proper expert
`
`opinions upon which the PTAB can rely. There is no assurance that Dr. Tygar’s
`
`methodologies used to render his opinions in this case are reliable as required by
`
`FRE 702. In Daubert v. Merrell Dow Pharmaceuticals, Inc., 113 S.Ct. 2786, 509
`
`U.S. 579 (1993), the Supreme Court set forth standards for the admissibility of
`
`expert testimony. The Supreme Court noted that:
`
`Faced with a proffer of expert scientific testimony … the
`trial judge must determine at the outset, pursuant to Rule
`104(a), whether the expert is proposing to testify to (1)
`scientific knowledge that (2) will assist the trier of fact to
`understand or determine a fact in issue. This entails a
`preliminary assessment of whether the reasoning or
`methodology underlying the testimony is scientifically
`2
`
`
`
`
`
`
`
`valid and of whether that reasoning or methodology
`properly can be applied to the facts in issue. We are
`confident that federal judges possess the capacity to
`undertake this review. Many factors will bear on the
`inquiry, and we do not presume to set out a definitive
`checklist or test. But some general observations are
`appropriate. Ordinarily, a key question to be answered
`in determining whether a theory or technique is
`scientific knowledge that will assist the trier of fact will
`be whether it can be (and has been) tested.
`
`Daubert v. Merrell Dow Pharmaceuticals, Inc., 113 S.Ct. 2786, 2796, 509 U.S.
`
`579, 592-93 (1993) (emphasis added).
`
`Dr. Tygar did not employ any scientifically valid reasoning or methodology
`
`in reaching his opinions. In fact, when asked given what his methodology was,
`
`what his “false-positive rate would be for analyzing patents under 101,” Dr. Tygar
`
`responded that “to measure false-positive, one has to have ground truth, and I am
`
`not aware of any generally accepted ground truth of -- [f]or these sorts of
`
`questions. Courts can differ in their opinion.” Exhibit 2105, Tygar Deposition at
`
`15:5-13. He further testified that “to define false-negative as to define false-
`
`positive, one needs ground truth, and I'm not aware of any generally accepted
`
`ground truth for 101 questions.” Id. at 16:23-17:1. This is an admission that Dr.
`
`Tygar does not know, or cannot apply, the standards for evaluating patent
`
`
`
`3
`
`
`
`
`
`eligibility under § 101. Dr. Tygar’s testimony did not employ any scientific
`
`reasoning or methodology, but simply put Dr. Tygar in the position of a tribunal
`
`making the same legal assessment.
`
`Dr. Tygar also did nothing to test the method he used in arriving at his
`
`opinions in this case to ensure that his method was repeatable and reliable. For
`
`example, Dr. Tygar did not test his method against known decisions finding
`
`subject matter either eligible or ineligible under § 101. Dr. Tygar did not read any
`
`Supreme Court opinions in formulating his opinions for this case. Exhibit 2105,
`
`Tygar Deposition at 12:3-18. Nor did he look at any Federal Circuit Court of
`
`Appeals decisions. Id. at 12:19-22. In preparing his declaration in this case, Dr.
`
`Tygar did not look at any patent decisions that found that a computer-implemented
`
`invention was not an abstract idea. Id. at 41:4-8. Nor did Dr. Tygar look at any
`
`guidelines on statutory subject matter issued by the U.S. Patent and Trademark
`
`Office. Id. at 41:9-13.
`
`Dr. Tygar did not apply his methodology to any other (i.e., non-Smartflash)
`
`patents as a test of his methodology. Id. at 12:23-13:5. Importantly, Dr. Tygar did
`
`not review any patent that was the subject of a § 101 decision by the Federal
`
`Circuit and use it to test his method. He did not “read a patent that had a [Federal
`
`Circuit] decision without reading the decision, determine for [him]self whether or
`
`not [he] thought that the patent … was an abstract idea or was statutory subject
`
`
`
`4
`
`
`
`
`
`matter for some other reason, and then cross-check[] it with what the Federal
`
`Circuit said about the same case.” Id. at 14:15-22. More specifically, Dr. Tygar
`
`“did not apply [his] method … to DDR Holdings.” Id. at 14:23-15:4.
`
`In describing his methodology, Dr. Tygar states that he looked at claim 3 of
`
`the ‘221 Patent and concluded that it was directed to the abstract idea of
`
`controlling access based on payment. Id. at 65:25-67:9. But Dr. Tygar did not
`
`consider any other possible abstract ideas. Id. at 67:10-11. Dr. Tygar did not
`
`consider whether the abstract idea of claim 3 “could have been controlling access
`
`to a data item stored by a data supplier.” Id. at 35:2-8.
`
`Dr. Tygar acknowledged on cross examination a potentially different
`
`“starting point for an abstract idea, but that's not where I started. I started here and
`
`then, having found it was directed to an abstract idea, applied part 2.” Id. at 67:13-
`
`17. Dr. Tygar admitted, however, “You know, it's possible that if I started at
`
`another place, I may or may not have reached a conclusion.” Id. at 67:18-20. Dr.
`
`Tygar’s admission that if he started with a different abstract idea for his analysis he
`
`may not have reached a conclusion that claim 3 is directed to patent ineligible
`
`subject matter should give the Board pause. It shows that how the witness defined
`
`the abstract idea, an arbitrary step in the process, can change the outcome.
`
`Arguably, if Dr. Tygar had defined the abstract idea as merely “controlling access
`
`to a data item stored by a data supplier,” then the claim elements relating to
`
`
`
`5
`
`
`
`
`
`payment data and payment validation data could amount to “significantly more.”
`
`For example, Dr. Tygar testified that one could “implement a data access terminal
`
`that retrieves data from a data supplier and provides the retrieved data to the data
`
`carrier that does not read payment data from the data carrier and forward the
`
`payment data to a payment validation system” as required by claim 3 if one
`
`“ma[d]e the material available for free,” to be downloaded. Id. at 36:24-37:6
`
`(emphasis added). In that situation, one could construct a data access terminal
`
`where material could be downloaded without payment, but still “could control the
`
`access using some other method, such as password protection.” Id. at 37:7-14.
`
`Adding “code to read payment data,” “code to receive payment data,” and “code
`
`responsive to payment data” such as required by claim 3 would be significantly
`
`more if the abstract idea was defined differently.
`
`Further, the Tygar Declaration does not disclose the underlying facts on
`
`which Dr. Tygar’s opinions are based and is, therefore, entitled to no weight.
`
`37 CFR § 42.65 (“Expert testimony that does not disclose the underlying facts or
`
`data on which the opinion is based is entitled to little or no weight.”). More
`
`specifically, the Tygar Declaration does not state the evidentiary weight standard
`
`(e.g., substantial evidence versus preponderance of the evidence) that Dr. Tygar
`
`used in arriving at his conclusions. Given that there is no evidence that Dr. Tygar
`
`even knows how much weight need be relied upon to show that a claim is non-
`
`
`
`6
`
`
`
`
`
`statutory (Exhibit 2105, Tygar Deposition at 195:13-196:13; 202:21-204:18), the
`
`PTAB should afford no weight to the testimony and exclude it. To do otherwise
`
`would be to accept his opinions without knowing “the underlying facts ... on which
`
`the opinion is based” (i.e., how much evidence he thinks supports any of his
`
`opinions discussed therein).
`
`Similarly, the Board cannot assess under FRE 702 whether Dr. Tygar’s
`
`opinion testimony is “the product of reliable principles and methods” or if Dr.
`
`Tygar “reliably applied the principles and methods to the facts of the case” given
`
`that Dr. Tygar did not disclose the standard against which he measured the
`
`evidence in arriving at his opinions. For example, when Dr. Tygar “considered
`
`each of the documents cited” in his declaration (Tygar Declaration at ¶ 6) and
`
`opined that “[i]t is my opinion that claim 3 of the ’221 patent is directed to the
`
`abstract idea of controlling access based on payment” (id. at ¶ 56) and “[i]t is my
`
`opinion that claim 3 does not add anything of significance to the underlying
`
`abstract idea of controlling access based on payment” (id. at ¶ 59) are those
`
`opinions based on less than a preponderance of the evidence, or more? Without
`
`Dr. Tygar having disclosed what evidentiary standard he used in forming his
`
`opinions, and given that there is no evidence that he even knew what evidentiary
`
`standard he was supposed to be using, the PTAB cannot rely on his opinions.
`
`
`
`7
`
`
`
`
`
`Paragraphs of the Tygar Declaration should be excluded to the extent that
`
`any paragraph relies upon an exhibit that is objected to herein for the reasons set
`
`forth in those objections. Any paragraph in the Tygar Declaration that relies upon
`
`any exhibit not relied upon by the PTAB to institute this proceeding is further
`
`objected to as not being relevant and therefore being inadmissible under FRE 401
`
`and 402.
`
`B. Exhibits 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1022, 1023, and 1024
`are Not Alleged to be Invalidating Prior Art and thus are Irrelevant
`
`Petitioner cites Exhibits 1004 (PCT Publication No. WO 99/07121)
`
`(“Fetik”), 1005 (U.S. Patent No. 5,790,423)(“Lau”), 1006 (SOFTBOOK PRESS—
`
`Secure Information Delivery to a Distributed Workforce, CIO Magazine, Aug. 1,
`
`1999), 1007 (Kevin Maney, Electronic Books to Hit the Shelves, New Straits
`
`Times (Computimes), Aug. 24, 1998 ), 1008 (Liquid Audio, Music on the Net—A
`
`Topographic Tour of the Online Music World (1997)), 1009 (Liquid Audio Indie
`
`1000 Program, http://www.liquidaudio.com (archived Feb. 11, 1998)), 1014 (A.M.
`
`Turing, On Computable Numbers, with an Application to the
`
`Entscheidungsproblem, Proceedings of the London Mathematical Society, Vol.
`
`42:2, pp. 230-265 (Nov. 12, 1936)), 1022 (Roger A. Cunningham et al., The Law
`
`of Property (2d ed. 1993) (excerpted)), 1023 (Michael H. Harris, History of
`
`Libraries in the Western World (4th ed. 1999) (excerpted), and 1024 (David
`
`Broderick, The First Toll Roads—Ireland’s Turnpike Roads 1729-1858 (2002)
`
`
`
`8
`
`
`
`
`
`(excerpted)). Although cited, neither the Petition nor the Tygar Declaration assert
`
`that any of these Exhibits (“the Unasserted Exhibits”) are potentially invalidating
`
`prior art, either alone or in combination with any other reference. The PTAB
`
`Decision did not base any of its analysis on the Unasserted Exhibits. Thus, the
`
`Unasserted Exhibits do not appear to make a fact of consequence in determining
`
`this action more or less probable than it would be without the Unasserted Exhibits.
`
`As such, the Unasserted Exhibits do not pass the test for relevant evidence under
`
`FRE 401 and are not admissible per FRE 402.
`
`In a related CBM on a patent in the same family, CBM2015-00016, the
`
`Board declined to exclude similarly unasserted exhibits, finding “these exhibits are
`
`relevant to the state of the art—whether the technical limitations of the challenged
`
`claim were well-known, routine, and conventional—and thus, to our § 101
`
`analysis.” CBM2015-00016, Paper 56 at 26. Whether the technical limitations of
`
`the challenged claim were well known, routine, and conventional is only relevant
`
`after finding that a claim is directed to an abstract idea and the analysis moves to
`
`the second step of whether the claims contain an “inventive concept.” Mayo
`
`Collaborative Services v. Prometheus Laboratories, Inc., 132 S. Ct. 1289, 1294
`
`(2012). Here, the claims at issue are not directed to an abstract idea. Patent
`
`Owner’s Response, Paper 21 at 22-25. The Federal Circuit recently “[found] it
`
`relevant to ask whether the claims are directed to an improvement to computer
`
`
`
`9
`
`
`
`
`
`functionality versus being directed to an abstract idea, even at the first step of the
`
`[Mayo/]Alice analysis. Enfish, LLC v. Microsoft Corp., 2016 WL 2756255, at *4
`
`(Fed. Cir. May 12, 2016) (citing Alice Corp. Pty Ltd. v. CLS Bank Int’l, 134 S.Ct.
`
`2347 (2014)). In Enfish, the Federal Circuit concluded that the claims were
`
`directed to an improvement to computer functionality and that “the claims are
`
`directed to a specific implementation of a solution to a problem in the software
`
`arts. Accordingly, we find the claims at issue are not directed to an abstract idea.”
`
`Id. at *8. Like the claims in Enfish, the Smartflash claims are “directed to an
`
`improvement to computer functionality” and a “specific solution to a problem” in
`
`computer networks – the problem of data piracy. Patent Owner’s Response, Paper
`
`21 at 2, 21, 22-36. As such, there is no need to reach the second step of
`
`Mayo/Alice to determine if there is an “inventive concept,” so the Board’s previous
`
`rationale is moot. Moreover, in determining whether there is an “inventive
`
`concept” the relevant analysis is whether there is an “inventive concept” over the
`
`abstract idea (if one is found) and not whether there is an “inventive concept” over
`
`the prior art. The question of whether there is an “inventive concept” over the
`
`prior art is a question of patentability under 35 U.S.C. §§ 102 and 103, and not
`
`subject matter eligibility under 35 U.S.C. § 101.
`
`Exhibits 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1022, 1023, and 1024
`
`are not relevant and should be excluded.
`
`
`
`10
`
`
`
`
`
`C. Exhibit 1015 is Irrelevant, Inadmissible Other Evidence of the
`Content of a Writing, and Cumulative
`
`Patent Owner moves to exclude Exhibit 1015 (Plaintiffs’ Original Complaint
`
`for Patent Infringement, Smartflash LLC v. Apple Inc., No. 6:13-cv-447, Dkt. 1
`
`(E.D. Tex. May 29, 2013)) on grounds that it is: inadmissible under FRE 402
`
`because it fails the test for relevance set forth in FRE 401; inadmissible other
`
`evidence of the content of a writing under FRE 1004; and, even if relevant, is
`
`unnecessary cumulative evidence under FRE 403.
`
`Petitioner cites to Exhibit 1015 as support for the ‘221 Patent being
`
`“financial in nature” and thus CBM review eligible. Petition at 6-7. Specifically,
`
`the Petition cites Exhibits 1015 for the sole purpose of showing Patent Owner’s
`
`characterization of the ‘221 Patent as “generally cover[ing] a portable data carrier
`
`for storing data and managing access to the data via payment information and/or
`
`use status rules.” Petition at 7 (citing Ex. 1015 ¶ 1).
`
`Patent Owner’s description of the ‘221 Patent in Exhibit 1015 is not relevant
`
`to any of the issues here.
`
`In related CBM2015-00016, the Board declined to exclude the same or
`
`similar exhibit because “[Patent Owner’s] characterization of the … patent in prior
`
`proceedings is relevant to the credibility of its characterization of the … patent in
`
`this proceeding.” CBM2015-00016, Paper 56 at 24. The Board’s reasoning that a
`
`Patent Owner’s characterization of the patent, or the Patent Owner’s credibility in
`
`
`
`11
`
`
`
`
`
`doing so, is relevant to the analysis of whether a patent qualifies for CBM review
`
`under § 18(a) of the Leahy-Smith America Invents Act (“AIA”) is contrary to
`
`Federal Circuit authority. As noted by the Federal Circuit, Ҥ 18(d)(1) [of the
`
`AIA] directs us to examine the claims when deciding whether a patent is a CBM
`
`patent.” Blue Calypso, LLC v. Groupon, Inc., 815 F.3d 1331, 1340 (Fed. Cir.
`
`March 1, 2016) (emphasis original). The claims are delineated in the ‘221 Patent,
`
`which is in evidence as Exhibit 1001. That is all the Board needs for its analysis.
`
`Moreover, there are no credibility issues here that render Exhibit 1015 relevant.
`
`There is nothing about Patent Owner’s characterization of the ‘221 Patent in this
`
`proceeding – that claims 1 and 3 “do not recite a ‘financial product or service’” in
`
`the way Congress intended (Patent Owner’s Preliminary Response, Paper 7 at 30-
`
`35) – that is contradicted by Exhibit 1015 such that the credibility of Patent
`
`Owner’s characterization is at issue. As such Exhibit 1015 is irrelevant and
`
`inadmissible.
`
`Further, Petitioner’s expert Dr. Tygar does not cite to Exhibit 1015 in the
`
`Tygar Declaration, Exhibit 1002. The Board’s November 16, 2015 Decision –
`
`Institution of Covered Business Method Patent Review 37 C.F.R. § 42.208 (“PTAB
`
`Decision”), Paper 8, does not cite Exhibit 1015. Exhibit 1015 therefore does not
`
`appear to make a fact of consequence in determining this action more or less
`
`probable than it would be without Exhibit 1015. As such, Exhibit 1015 does not
`
`
`
`12
`
`
`
`
`
`pass the test for relevant evidence under FRE 401 and is not admissible per FRE
`
`402.
`
`Petitioner does not need to cite to Exhibit 1015 to characterize the ‘221
`
`Patent when Exhibit 1001, the actual ‘221 Patent, is in evidence. Under FRE 1004,
`
`other evidence of the content of a writing (here the ‘221 Patent) is admissible if the
`
`original is lost, cannot be obtained, has not been produced, or the writing is not
`
`closely related to a controlling issue. None of those conditions apply here, given
`
`that the ‘221 Patent is in evidence and is the subject of the trial.
`
`Even if Exhibit 1015 was found to be relevant, it should also be excluded
`
`under FRE 403 as cumulative of the ‘221 Patent, Exhibit 1001.
`
`IV. Conclusion
`For these reasons, Patent Owner Smartflash, LLC respectfully requests that
`
`the Board exclude Exhibits 1002, 1004, 1005, 1006, 1007, 1008, 1009, 1014, 1015
`
`1022, 1023, and 1024.
`
`Dated: June 13, 2016
`
`/ Michael R. Casey /
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist
`
`Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`13
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S MOTION
`
`TO EXCLUDE EVIDENCE in CBM2015-00126 was served today, by agreement
`
`of the parties by emailing a copy to counsel for the Petitioner as follows:
`
`
`
`QE-SF-PTAB-Service@quinnemanuel.com
`raynimrod@ quinnemanuel.com
`kevinsmith@ quinnemanuel.com
`
`
`
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist
`
`Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: June 13, 2016
`
`
`
`
`
`
`
`14
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
