UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PLAID TECHNOLOGIES INC.
`Petitioner
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`v.
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`YODLEE, INC.
`Patent Owner
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`Case IPR2016-00273
`Patent 6,317,783
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`PATENT OWNER’S PRELIMINARY RESPONSE
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`Plaid Technologies Inc.
`Exhibit 1011
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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`TABLE OF CONTENTS
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`I. 
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`INTRODUCTION ........................................................................................ 1 
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`II.  STATEMENT OF RELIEF REQUESTED ................................................. 2 
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`III.  CLAIM CONSTRUCTION ......................................................................... 2 
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`A. 
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`B. 
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`“non-public personal information” (Claims 1, 18, 20) ............. 2 
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`“intermediary web site” (Claims 14, 33) .................................. 5 
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`IV.  THE BOARD SHOULD NOT INSTITUTE PETITIONER’S
`CHALLENGES ............................................................................................ 6 
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`A. 
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`Claim 1 ...................................................................................... 6 
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`1.  [1.1]: A method for delivering non-public personal
`information relating to an end user via a wide-area
`computer network to an end user .............................................. 9 
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`2.  [1.2]: from at least one of a plurality of information
`providers securely storing the personal information .............. 12 
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`3.  [1.5]: (b) for a selected end user, the processor retrieving
`personal information for the selected end user from the
`connected at least one information provider .......................... 13 
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`4.  [1.7]: the information accessible to the processor using
`the protocol also being accessible by the end user via
`the network independently of the system for delivering
`personal information; and ...................................................... 13 
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`5.  [1.8]: (c) the processor storing the retrieved personal
`information in a personal information store for access
`by the selected end user. ......................................................... 14 
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`B. 
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`C. 
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`D. 
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`E. 
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`Claims 6, 7, 10-12, and 14-17 ................................................ 14 
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`Claim 18.................................................................................. 14 
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`Claim 20.................................................................................. 15 
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`Claims 25, 26, 28-31, and 33-36 ............................................ 15 
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`V.  CONCLUSION .......................................................................................... 15
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`Case IPR2016-00273
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`TABLE OF AUTHORITIES
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` Page(s)
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`Cases
`Cohesive Techs., Inc. v. Waters Corp.,
`543 F.3d 1351 (Fed. Cir. 2008) ....................................................................... 6
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`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) ................................................................................... 8, 12
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`Statutes
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`35 U.S.C. § 103 ..................................................................................................... 8
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`35 U.S.C. § 314 ................................................................................................... 15
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`Case IPR2016-00273
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`EXHIBIT LIST
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`Exhibit No. Description
`2001
`ESPN Insider: Benefits, WayBackMachine June 22, 2001
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`iii
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`Pursuant to 37 C.F.R. § 42.107(a), the Patent Owner, Yodlee, Inc.
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`(“Yodlee” or “Patent Owner”), hereby submits the following Preliminary
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`Response in opposition to the Petition for Inter Partes Review (“IPR”) of U.S.
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`Patent No. 6,317,783 (“the ʼ783 Patent”) numbered IPR2016-00273, filed by
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`Plaid Technologies, Inc. (“Plaid” or “Petitioner”).
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`I.
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`INTRODUCTION
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`The ’783 Patent is entitled “Apparatus and Methods For Automated
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`Aggregation and Delivery of and Transactions Involving Electronic Personal
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`Information or Data.” As the specification makes clear, the ’783 Patent is
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`directed to overcoming specific problems that plagued early personalization
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`technologies. Ex. 1001 at 4:22-51. Every claim (and in fact, almost every
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`limitation of many of the claims) requires technology that operates on non-
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`public personal information – specialized technology that is designed to enable
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`the storage, retrieval, and use of non-public personal information. See, e.g.,
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`independent claim 1. As described below, the term “personal information” is
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`even specifically described within the body of the ’783 Patent itself and the file
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`history.
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`While Petitioner acknowledges the focus on non-public personal
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`information in both the specification and the file history of the ’783 Patent, the
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`Petition lacks any detail regarding how the cited grounds would disclose or
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`suggest it. As described below, Petitioner focuses solely on the prior art
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`disclosure of public information and never shows the prior art disclosure of the
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`required “non-public personal information.” In fact, even accepting Petitioner’s
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`assertion as correct, it only alleges the prior art to disclose “non-public”
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`information and then asserts that the information is “personal” by virtue of it
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`being non-public. Petitioner is flawed on both accounts and its arguments
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`cannot stand.
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`II.
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`STATEMENT OF RELIEF REQUESTED
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`Patent Owner respectfully requests that this Board deny this Petition for
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`IPR of the ’783 Patent with regard to all claims (1-36).
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`III. CLAIM CONSTRUCTION
`A.
`“non-public personal information” (Claims 1, 18, 20)
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`Petitioner proposes that the term “non-public” be construed. However,
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`the term “non-public” only appears in the claims as part of the larger phrase
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`“non-public personal information.” In proposing and applying its construction,
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`Petitioner effectively seeks to remove the word “personal” from the claims by
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`asserting that any information which meets Petitioner’s proposed construction
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`of “non-public,” is also “non-public personal information.” See Petition at 12.
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`The specification makes clear that this is not the case. Moreover, the
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`specification makes it clear that “non-public personal information” has a
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`specific meaning.
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`Petitioner’s proposed construction (and in fact its entire argument for
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`invalidity) appears to hinge on the incorrect assumption that any information for
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`which a login is required is “non-public personal information.” This argument
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`completely misses the point of the inventive system. As shown below, the prior
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`art systems upon which Petitioner relies are systems that use logins as a means
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`to extract payment from a user. For example, the ESPN Insider system, which
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`purportedly shown in Exhibit 1011 and relied upon by Petitioner’s expert,
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`required users to pay a fee to access news reports on sporting events. Ex. 2001,
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`ESPN Insider: Benefits, WayBackMachine, June 22, 2001. This information,
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`however, is no different from the stories published in the local newspaper. Like
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`the ESPN Insider system, a reader must pay a fee to access the news stories
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`(e.g., the one dollar purchase price for the paper), but regardless of how they are
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`financed, news stories are not “non-public” much less “personal” information,
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`as the ’783 Patent uses that term.
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`As the specification of the ’783 Patent describes, “‘Personal Information’
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`is all of the data that companies, information providers, have that is specific or
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`unique to each person such as monthly bills, bank account balances,
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`investments information, health care benefits, email, voice and fax messages,
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`401(k) holdings or potentially any other information pertinent to a particular
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`end user.” Ex. 1001 at 4:15-21. The file history confirms that “the essence of
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`personal information is that it is not accessible to the general public, i.e., other
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`end users; rather, each information provider protects personal information
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`relating to a specific end user against access by persons other than that end
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`user or one acting under the authority of that end user.” Ex. 1003 at 168.
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`Anyone who pays a fee can access a pay-for-news provider, such as
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`ESPN Insider. That website is accessible to the general public. On the
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`contrary, regardless of fee, no other person can (or at least should not be able to)
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`access another person’s bank
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`records, stock portfolio, etc., without
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`authorization. As the intrinsic evidence makes clear, this is “the essence” of the
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`claimed system. The public cannot access it regardless of fee – it is personal to
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`the user.
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`While “pay for play” content and “non-public personal information” may
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`use similar security features, such as a login, the security features used to
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`protect non-public personal information do not somehow convert that claim
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`limitation to include all information regardless of whether it is public or
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`personal into “non-public personal information.”1 This construction is further
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`1 For example, Petitioner relies on the language “such as by logging onto a Web
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`site” to support its construction of “non-public.” However, that statement was
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`made in the context of how a user could access personal information
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`“independently of the invention.” This corresponds to another aspect of the
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`claim, particularly that the information is “accessible by the end user via the
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`network independently of the system for delivering personal information.” See
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`Ex. 1001, ’783 Patent, claim 1. This language does not inform the meaning of
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`“non-public.”
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`confirmed by claim 1’s recitation of “securely storing” as a requirement
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`separate and apart from “non-public personal information.” If, as Petitioner
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`asserts, all information that is protected by a login and password were “non-
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`public personal information,” there would be no need to separately recite
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`“securely storing” in the claims. The recitation of “securely storing” would
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`render the “non-public personal” recitation wholly redundant.
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`Accordingly, in line with the specification, Patent Owner proposes that
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`the broadest reasonable construction of “non-public personal information” is
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`“information relating to a specific end user that is not intended for access by
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`persons other than that end user or those authorized by that end user.”
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`B.
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` “intermediary web site” (Claims 14, 33)
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`Petitioner argues that an “intermediary web site” must be served by a web
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`server not running on the end user’s computer and not running on the
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`“processor” of the claims. However, in the passage that Petitioner relies upon,
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`the ’783 Patent states that “[t]he intermediary Web site 510 contacts the PI
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`engine 240 across the Internet 230 and directly receives the end user's PI
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`updated as required from the PI provider Web sites 250.” Ex. 1001, ’783 Patent
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`at 12:18-21. Thus, the intermediary Web site is directly in contact with the PI
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`engine and directly receives information from the PI provider, which are both
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`running on the claimed “processor” – the intermediary Web site is “served” by
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`the “processor” itself. Petitioner’s argument that the intermediary web site must
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`be served by a server not running on the “processor” is unsupported and
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`contradicted by the disclosure in the specification. The proper construction of
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`the “intermediary web site” should therefore be: “a Web site that obtains an end
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`user’s personal information from the “processor” for display to that end user.”
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`Patent Owner has addressed the claim terms addressed by Petitioner and
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`those relevant to the arguments made in this preliminary response. To the
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`extent that this case is instituted, Patent Owner reserves the right to address
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`additional claim construction issues that arise with respect to its further
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`arguments to be made in the Patent Owner’s Response.
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`IV. THE BOARD SHOULD NOT INSTITUTE PETITIONER’S
`CHALLENGES
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`In order to make a showing of obviousness, Petitioner must show that a
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`proposed combination of references discloses all limitations of the challenged
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`claims. See Cohesive Techs., Inc. v. Waters Corp., 543 F.3d 1351, 1364 (Fed.
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`Cir. 2008). Petitioner has failed to make such a showing here and thus the
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`Petition should be denied in full. Particularly, Petitioner has failed to show
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`evidence that the “non-public personal information” limitation recited in each of
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`the challenged claims is present in any of the alleged prior art references or in
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`the combinations of the prior art references relied upon by Petitioner.
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`A. Claim 1
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`Claim 1 of the ’783 Patent contains numerous limitations that involve
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`“non-public personal information.” Each of those limitations (identified using
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`Petitioner’s numbering system) is reproduced below:
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`[1.1]: A method for delivering non-public personal
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`information relating to an end user via a wide-area
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`computer network to an end user
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`[1.2]: from at least one of a plurality of information
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`providers securely storing the personal
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`information
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`[1.5]: (b) for a selected end user, the processor
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`retrieving personal information for the selected
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`end user from the connected at least one
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`information provider
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`[1.6]: based on end user data associated with the
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`selected end user and information provider data
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`associated with the connected one or more
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`information providers, the end user data including
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`information identifying the plurality of information
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`providers securely storing the personal
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`information relating to the end user, the provider
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`data including a protocol for instructing the
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`processor how to access the securely stored
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`personal information via the network,
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`[1.7]: the information accessible to the processor
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`using the protocol also being accessible by the end
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`user via the network independently of the system
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`for delivering personal information; and
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`[1.8]: (c) the processor storing the retrieved personal
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`information in a personal information store for
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`access by the selected end user.
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`Petitioner has wholly failed to establish that “non-public personal
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`information” is disclosed by the combination of references upon which
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`Petitioner relies. As described below, Petitioner identifies only public
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`information in the prior art and fails to identify any prior art that discloses non-
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`public, personal information.
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`In fact, nowhere in the Petition does Petitioner ever appear to even
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`acknowledge the “personal” aspect of the claim. Instead, Petitioner merely
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`repeats the claim language, without ever identifying any “personal information”
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`much less the “non-public personal information” required by the claims. Such
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`conclusory allegations are insufficient as a matter of law to prove obviousness
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`under 35 U.S.C. § 103. See KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418
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`(2007) (obviousness analysis “should be made explicit. . . . ‘[R]ejections on
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`obviousness grounds cannot be sustained by mere conclusory statements;
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`instead, there must be some articulated reasoning with some rational
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`underpinning to support the legal conclusion of obviousness.’”)
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`Petitioner’s specific failure to prove this element is discussed separately
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`below for each claim element in which “personal information” is recited.
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`1.
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`[1.1]: A method for delivering non-public personal
`information relating to an end user via a wide-area
`computer network to an end user
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`With respect to limitation [1.1], Petitioner fails to ever specifically
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`identify what allegedly discloses the “personal information” aspect of the claim
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`language. As noted above, Petitioner’s argument is essentially limited to the
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`“non-public” aspect of the claim language. Petitioner alleges that Brandt
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`discloses information protected with a user name and password. Petition at 29.
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`Based solely on this reasoning, Petitioner then asserts that the combination of
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`Sugiarto and Brandt “would obtain ‘non-public personal information.’” Id.
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`However, as noted above in the claim construction section, while
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`protection by a login may be relevant to the “securely storing” aspect of the
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`claims, it is irrelevant to the question of whether a prior art reference discloses
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`non-public personal information, as recited in the claims. Moreover, Brandt is
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`not even directed to protecting information but rather to protecting access to a
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`piece of software. As Petitioner even notes in describing Brandt “access to a
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`protected software application 342 is only granted after gateway 332 supplies
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`the user’s user name and password.” Petition at 29, citing Ex. 1005 12:15–36;
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`Ex. 1008, Mowry Decl., ¶ 78. The word “information” is never even used in
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`Brandt. For each of these reasons, the disclosure of Brandt cannot possibly
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`teach the required “non-public personal information.”
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`To overcome this deficiency in Brandt, Petitioner seeks to rely on
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`Sugiarto’s disclosure of collecting public information from a webpage. In
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`particular, Petitioner points to Figure 7 of Sugiarto, which displays information
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`taken from CNN, ESPN, and the NASDAQ stock exchange. Petitioner then
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`appears to argue that the public information sources disclosed in Sugiarto would
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`somehow become non-public personal information if they were placed behind
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`Brandt’s password system.
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`This argument is fundamentally flawed. News stories, sports scores, and
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`stock market quotes do not become non-public personal information simply
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`because one needs to pay money to access them. For example, the Petition
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`mentions ESPN Insider, a subscription service that offers access to various news
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`articles, audio recordings, charts, or statistics about sports. See Ex. 1011 at 3.
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`The ESPN Insider service – which is never actually mentioned in the cited prior
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`art – appears to require a login to enable payment for the content. See Ex. 2001,
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`ESPN Insider: Benefits, WayBackMachine June 22, 2001. The content is still
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`clearly intended for the public – for anyone willing to pay the $4.95 per month
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`to access it. While this may only be a few hundred thousand people, these
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`sports scores are public, not personal. In fact, ESPN Insider could not exist if it
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`were reporting for an audience of one. By its very nature, the ESPN Insider
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`service is information for any member of the public willing to pay the monthly
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`fee.
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`Moreover, even if one were to incorrectly conclude that professional
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`sports information, news stores, or stock quotes could somehow qualify as
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`“non-public,” they certainly cannot qualify as “personal information.” For
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`example, every subscriber of ESPN Insider would obtain access to the same
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`content precisely because the information is not “personal” to any individual
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`user. Nor does Petitioner or its expert assert that it would somehow be obvious
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`for one of ordinary skill in the art to modify the disclosures of Brandt and
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`Sugiarto to include the recited “non-public personal information.”2 Thus, even
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`accepting Petitioner’s allegation that it was proper to combine Brandt or
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`Sugiarto, the combination of those references is wholly insufficient to disclose
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`the “non-public personal information,” recited in claim 1.
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`Finally, because Petitioner has failed to identify the alleged “personal
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`information,” it has not shown that the remainder of the claim language is
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`satisfied. For example, the claim recites “personal information relating to an
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`end user.” Because Petitioner has not identified the personal information, it
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`cannot prove anything about the content of that information, including whether
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`it “relat[es] to an end user.” Petitioner attempts to argue this limitation by
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`saying that the end user “is the person ‘to whom the personal information
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`relates’ because the personalized Web page is based on the user’s configuration
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`file.” Petition at 28. However, that argument fails to identify the “personal
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`2 Neither Petitioner nor its expert provided any reason or motivation that would
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`compel or suggest such a modification to one of ordinary skill. Thus, there is
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`no factual basis in the record to support such a combination – even if it were
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`asserted.
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`information” and thus fails to explain how the content of the information itself
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`relates to the user. The fact that the configuration file determines what content
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`is presented and how does not establish that the information being retrieved is
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`itself “personal information relating to an end user.”
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`Petitioner simply does not explain how Brandt (or the proposed
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`combination of Sugiarto and Brandt) discloses “non-public personal
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`information” that satisfies the full language of limitation [1.1]. Merely
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`repeating
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`the claim
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`language
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`in conclusory statements cannot satisfy
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`Petitioner’s burden to explicitly show how the references allegedly disclose this
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`limitation of the ’783 Patent. See KSR, 550 U.S. at 418.
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`2.
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`[1.2]: from at least one of a plurality of information
`providers securely storing the personal information
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`Here again, Petitioner fails to specifically identify the alleged “the
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`personal information” (antecedent basis to the recited “non-public personal
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`information”) or establish that it satisfies the remaining claim language, namely
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`that the alleged personal information is “securely stor[ed]” by the “information
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`providers.” Petitioner simply refers back to its deficient analysis of limitation
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`[1.1]. Petition at 30. Indeed, Petitioner does not even allege that the
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`information is securely stored, instead alleging that the combination would
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`“obtain information from secure content providers” without explaining how that
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`satisfies the claim language. This analysis is insufficient to make a showing of
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`obviousness. See KSR, 550 U.S. at 418 (“there must be some articulated
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`reasoning with some rational underpinning to support the legal conclusion of
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`obviousness”). Nor could Petitioner make a showing of obviousness, given that
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`Petitioner has failed to identify the alleged “personal information” and thus
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`cannot say anything about how that information is stored by the alleged
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`information providers.
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`3.
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`[1.5]: (b) for a selected end user, the processor retrieving
`personal information for the selected end user from the
`connected at least one information provider
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`For limitation [1.5], Petitioner again exclusively refers back to its
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`deficient analysis for limitation [1.1]. Tellingly, however, Petitioner only
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`alleges that the modules “retrieve information from respective secure content
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`providers.” Petition at 32. Here, Petitioner does not even allege that the
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`information retrieved is “personal information.”
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`4.
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` [1.7]: the information accessible to the processor using
`the protocol also being accessible by the end user via the
`network independently of the system for delivering
`personal information; and
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`Petitioner makes no further argument in its analysis of limitation [1.7]
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`relating to the “system for delivering personal information,” i.e. the entirety of
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`claim 1. Thus, for each of the reasons discussed above, Petitioner fails to show
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`evidence that this limitation is disclosed by the cited prior art.
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`5.
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`[1.8]: (c) the processor storing the retrieved personal
`information in a personal information store for access by
`the selected end user.
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`Petitioner’s argument with respect to limitation [1.8] is directed entirely
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`toward how information is stored by the prior art combination. Petitioner
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`makes no further argument with respect to what information is stored and
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`simply refers to it using the claim language “personal information.” Thus,
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`Petitioner has failed to prove that limitation [1.8] is shown in the prior art for
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`each of the reasons discussed above.
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`B. Claims 6, 7, 10-12, and 14-17
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`Petitioner groups its analysis of these claims, each of which recites
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`“personal information.” However, Petitioner makes no further analysis of what
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`qualifies as “personal information.” Instead, Petitioner’s arguments relate to
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`how the information is allegedly output and/or displayed. Thus, the analysis of
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`these claims does not show that the prior art discloses the “personal
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`information” limitation.
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`C. Claim 18
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`Independent claim 18 also includes numerous limitations reciting
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`“personal information”: limitations [18.1], [18.2], [18.5], [18.7], and [18.8].
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`Petitioner makes no independent analysis of claim 18, but instead solely refers
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`back to its analysis of claim 1. See Petition at 51. Thus, Petitioner fails to show
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`that claim 18 is rendered obvious by the proposed combination, for the same
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`reasons Petitioner failed to show that claim 1 is rendered obvious.
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`D. Claim 20
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`Independent claim 20 also includes numerous limitations reciting
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`“personal information”: [20.1], [20.3], [20.5], [20.7], [20.8], [20.9], [20.12], and
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`[20.13]. For each of these limitations, Petitioner makes no independent
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`analysis, but instead solely refers back to its analysis of claim 1. See Petition at
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`52-53. Thus, Petitioner fails to show that claim 20 is rendered obvious by the
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`proposed combination, for the same reasons Petitioner failed to show that claim
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`1 is rendered obvious.
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`E. Claims 25, 26, 28-31, and 33-36
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`Dependent claims 25, 26, 28-31, and 33-36 each recite “personal
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`information.” For dependent claims 25, 26, 28-31, and 33-36, Petitioner makes
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`no independent analysis but solely refers back to its analysis of claims 6, 7, 9-
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`12, and 14-17 respectively. Thus, for the same reasons, Petitioner has failed to
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`establish that the “personal information” limitation is shown in the prior art.
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`V. CONCLUSION
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`The Petitioner has the burden to show that institution is warranted in
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`these cases at all. 35 U.S.C. § 314. Petitioner has not met that burden and the
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`Petition should be denied in full.
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`Dated: March 11, 2016
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`Respectfully submitted,
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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` By: /David M. Hoffman/
` David M. Hoffman
`Reg. No. 54,174
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`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`T: (512) 226-8154
`F: (512) 320-8935
`Email: IPR12233-0047IP1@fr.com
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`Counsel for Patent Owner
`Yodlee, Inc.
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4), the undersigned certifies that on March
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`11, 2016, a complete and entire copy of this Patent Owner’s Preliminary
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`Response was provided via electronic service to the Petitioner, by serving the
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`correspondence address of record as follows:
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`Brian Buroker
`Omar Amin
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
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`E-mail: bburoker@gibsondunn.com
` oamin@gibsondunn.com
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` /Jessica K. Detko/
`Jessica K. Detko
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(612) 337-2516
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