PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`In the Inter Partes Review of U.S. Patent No. 7,797,717
`Trial No.: Not Yet Assigned
`Issued: September 14, 2010
`Filed: May 23, 1995
`Inventors: John Christopher Harvey, et al.
`Assignee: Personalized Media Communications, LLC
`Title: SIGNAL PROCESSING APPARATUS AND METHODS
`
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`SUPPLEMENTAL PETITION FOR INTER PARTES REVIEW
`UNDER 37 C.F.R. § 42.100
`
`This Supplemental Petition for Inter Partes Review is filed in response to
`
`the Notice of Filing Date Accorded to Petition and Time for Filing Patent Owner
`
`Preliminary Response, which requires correction of Petitioner’s identification of
`
`related matters. Section VI.B has been supplemented to include identification of
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`copending Inter Partes Review proceedings for related patents.
`
`On behalf of Zynga Inc. (“Zynga” or “Petitioner”) and in accordance with 35
`
`U.S.C. § 311 and 37 C.F.R. § 42.100, inter partes review is respectfully requested
`
`

`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
`
`for claims 1-7 and 9 of U.S. Patent No. 7,797,717 (“the Harvey ‘717 Patent”),
`
`attached hereto as Exhibit 1001.
`
`The undersigned representative of Petitioner authorizes the Patent Office to
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`charge the $27,200 Petition Fee, along with any additional fees, to Deposit
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`Account 501432, ref: 479204-620005. Eight claims are being reviewed, so no
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`excess claim fees are required.
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`

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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`Table of Contents
`
`Page
`
`IV. 
`V. 
`
`B. 
`
`C. 
`
`D. 
`
`Introduction ...................................................................................................... 1 
`I. 
`II.  Grounds for Standing Pursuant to 37 C.F.R. § 42.104(a) ............................... 2 
`III.  Background Information for the Harvey ‘717 Patent ...................................... 2 
`A.  Overview of the Harvey ‘717 Patent and Prosecution History ............. 2 
`The Earliest Possible Priority Date for Claims 1-7 and 9 of the
`B. 
`Harvey ‘717 Patent Is September 11, 1987 ........................................... 4 
`Identification of Challenge Pursuant to 37 C.F.R. § 42.104(b) ...................... 6 
`There Is a Reasonable Likelihood That at Least One Claim of the
`Harvey ‘717 Patent Is Unpatentable ................................................................ 9 
`Claims 1-6 and 9 Are Anticipated by Lockwood (U.S. Patent No.
`A. 
`4,567,359) .............................................................................................. 9 
`Claims 1-6 and 9 Are Anticipated by Humble (U.S. Patent No.
`4,825,045) ............................................................................................ 24 
`Claims 1-6 and 9 Are Rendered Obvious by Lockwood in View
`of Bakula (U.S. Patent No. 4,204,206) ............................................... 38 
`Claim 7 Is Rendered Obvious by Lockwood in View of Lemon
`(U.S. Patent No. 4,674,041) ................................................................ 41 
`Claim 7 Is Rendered Obvious by Lockwood in View of Bakula
`and Lemon ........................................................................................... 43 
`Claims 1-6 and 9 Are Rendered Obvious by Humble in View of
`Lockwood and Bakula ......................................................................... 44 
`Claim 7 Is Rendered Obvious by Humble in View of Lemon ............ 46 
`Claim 7 Is Rendered Obvious by Humble in View of Lockwood,
`Bakula, and Lemon.............................................................................. 47 
`VI.  Mandatory Notices Pursuant to 37 C.F.R. § 42.8(a)(1) ................................ 48 
`
`E. 
`
`F. 
`
`G. 
`H. 
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`
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`i
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`VII.  Conclusion ..................................................................................................... 49 
`
`
`
`ii
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`

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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`I.
`
`Introduction
`
`The Harvey ‘717 Patent is currently being wielded by the patent owner,
`
`Personalized Media Communications, LLC (“PMC”), in an attempt to cover long-
`
`known computer programming and networking techniques that are far afield from
`
`the alleged invention described in the patent.
`
` (See Personalized Media
`
`Communications, LLC v. Zynga Inc., U.S. District Court for the Eastern District of
`
`Texas, Civil Action No. 2:12-cv-68-JRG.) PMC’s aggressive litigation campaign
`
`is made possible by an overly-expansive claim scope that results from a long and
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`tortured prosecution history dating back to an original filing in November 1981,
`
`and includes approximately 300 related applications filed in 1995 in an effort to
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`extend the patent term well beyond what is justifiable.
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`Most of the near 300 applications filed in 1995, including the originally filed
`
`claims of the Harvey ‘717 Patent, were directed to television and radio technology,
`
`as described in the specification of the Harvey ‘717 Patent. Also related to
`
`television and radio technology were most of the thousands of prior art references
`
`cited by the patent owner during prosecution, including a single IDS citing over
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`700 references.
`
`The allowed claims are being asserted against online computer gaming
`
`technology in a way that extends far beyond the television technology disclosed in
`
`the specification of the Harvey ‘717 Patent and the prior art considered by the
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`
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`-1-
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`

`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`Patent Office. (See, e.g., PMC Infringement Contentions against Zynga, attached
`
`as Ex. 1002.) This type of computer technology was well known before the 1987
`
`priority date of the Harvey ‘717 Patent, however, as demonstrated by the teachings
`
`of the Lockwood, Humble, Lemon, and Bakula references cited herein. Petitioner
`
`submits that had these more-relevant references been considered by the Patent
`
`Office during prosecution, at least claims 1-7 and 9 of the Harvey ‘717 Patent
`
`would not have issued, and therefore this petition for inter partes review should be
`
`granted.
`
`II. Grounds for Standing Pursuant to 37 C.F.R. § 42.104(a)
`
`Petitioner certifies that the Harvey ‘717 Patent is available for inter partes
`
`review and that Petitioner is not barred or estopped from requesting inter partes
`
`review challenging the patent claims on the grounds identified herein.
`
`III. Background Information for the Harvey ‘717 Patent
`
`A. Overview of the Harvey ‘717 Patent and Prosecution History
`The Harvey ‘717 Patent was filed on May 23, 1995, and issued on
`
`
`
`September 14, 2010. The Harvey ‘717 Patent claims priority to a series of
`
`continuation and continuation-in-part applications dating back to November 3,
`
`1981, but, as detailed below, is entitled to an effective filing date no earlier than
`
`September 11, 1987 (the filing date of U.S. Patent No. 4,965,825).
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`-2-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`The Harvey ‘717 Patent includes 288 columns of specification, all detailing
`
`
`
`various examples of a system for adding personalized content to a television or
`
`radio broadcast. (See, e.g., Harvey ‘717 Patent at col. 241, line 45 to col. 265, line
`
`51, describing “Exotic Meals of India” television program; see also id. at col. 10,
`
`line 43 to col. 15, line 14, describing “Wall Street Week” television program.)
`
`
`
`Similarly, the claims that were originally filed with the Harvey ‘717 Patent
`
`in 1995 were also directed to television and radio broadcast technology. (See, e.g.,
`
`Ex. 1003, ‘717 File History, Preliminary Amendment dated May 23, 1995 at 1,
`
`adding claim 2 that recites a “method of processing signals . . . based on a
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`broadcast or cablecast transmission.”) The pending claims were later amended so
`
`as to extend the claim scope beyond the disclosed television and radio broadcast
`
`technology, and a Notice of Allowance and Examiner’s Amendment were issued
`
`on April 8, 2010, allowing claims 2-5, 9-14, 16, and 18-21, and cancelling the
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`remaining claims. (Ex. 1004, ‘717 File History, Notice of Allowance, disclosing
`
`Office’s Reasons for Allowance, which note that the closest art “fails to teach,
`
`suggest, or make obvious a receiver device, in a television broadcast system, [that]
`
`performs the generation of the output, where the output is specialized for the
`
`particular subscriber to recommend a product or a service,” emphasis added.) The
`
`allowed claims were then renumbered and issued as claims 1-15 of the Harvey
`
`‘717 Patent.
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`-3-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`B.
`
`
`
`The Earliest Possible Priority Date for Claims 1-7 and 9 of the
`Harvey ‘717 Patent Is September 11, 1987
`
`The application that issued as the Harvey ‘717 Patent was filed on May 23,
`
`
`
`
`
`1995, claiming priority to seven parent applications, with the earliest of the parent
`
`applications being filed on November 3, 1981. To claim a pre-1995 priority date,
`
`however, the claims at issue must be directed to subject matter disclosed in the
`
`prior application(s) in the manner provided by 35 U.S.C. § 112, ¶ 1, such that the
`
`prior application(s) include a sufficient written description of the claimed
`
`invention. See, e.g., Vas-Cath Inc. v. Mahurkar, 935 F.2d 1555, 1562-63 (Fed. Cir.
`
`1991).
`
`
`
`The patent owner has conceded that the Harvey ‘717 Patent is only entitled
`
`to priority to U.S. Application No. 07/096,096 (Patent No. 4,965,825), filed as a
`
`continuation-in-part on September 11, 1987, and not to the earlier priority date of
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`November 3, 1981. In the co-pending litigation in the U.S. District Court for the
`
`Eastern District of Texas (identified below in Section VI), the patent owner has
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`acknowledged the September 11, 1987 priority date for the Harvey ‘717 Patent.
`
`Specifically, in the Plaintiff’s Disclosure of Asserted Claims and Infringement
`
`Contentions (attached here as Ex. 1005), PMC has admitted that “[t]he priority
`
`date for . . . Claims 1, 2, 3, 4, 5, 6, 7, and 9 from U.S. Patent No. 7,797,717 is
`
`September 11, 1987.” (Ex. 1005 at 3.) Accordingly, there is no dispute that claims
`
`1-7 and 9 of the Harvey ‘717 Patent should be afforded a priority date no earlier
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`
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`-4-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`than September 11, 1987 for the purpose of assessing patentability under 35 U.S.C.
`
`§§ 102 and 103.
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`
`
`The September 11, 1987 priority date is also supported by patent owner
`
`admissions made during prosecution of the Harvey ‘717 Patent. Specifically, in an
`
`Office Action dated September 6, 2002, the claims at issue were rejected under 35
`
`U.S.C. § 112, ¶ 1, for failure to provide adequate written description support. (Ex.
`
`1006, ‘717 File History, Office Action dated September 6, 2002 at 57-61.) To
`
`overcome this rejection, in a subsequent response and amendment, Applicants
`
`provided an Appendix B, which allegedly provided written description support by
`
`citing to pages 534-556 of the specification and the “Farm Plans of Europe”
`
`example contained therein. (Ex. 1007, ‘717 File History, Amendment dated March
`
`6, 2003 at Appendix B.) This portion of the specification was not included in any
`
`of the applications filed prior to the September 11, 1987 application. The
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`Applicants acknowledged this in the March 6, 2003 Amendment, noting that
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`“applicants have demonstrated specification support below only with respect to the
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`1987 specification.” (Id. at 7.)
`
`
`
`Moreover, counsel for Petitioner has reviewed the specifications of the
`
`Harvey applications filed prior to September 11, 1987, and these earlier
`
`specifications do not support the claims of the Harvey ‘717 Patent. For example,
`
`the 1981 specification does not provide support for at least the following elements
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`
`
`-5-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`of independent claim 1: “generating a benefit datum in response to said first
`
`control signal by processing subscriber specific data at said receiver station” and
`
`“said information content and said benefit datum [that] explain a benefit of
`
`acquiring said product or service specific to said subscriber.”
`
`
`
`For at least these reasons, the Harvey ‘717 Patent should be given a priority
`
`date of no earlier than September 11, 1987.
`
`IV.
`
`Identification of Challenge Pursuant to 37 C.F.R. § 42.104(b)
`
`A.
`
`
`37 C.F.R. § 42.104(b)(1): Claims for Which Inter Partes Review
`Is Requested
`
`
`
`Inter Partes review is requested for claims 1-7 and 9 of the Harvey ‘717
`
`Patent.
`
`37 C.F.R. § 42.104(b)(2): The Prior Art and Specific Grounds on
`B.
`Which the Challenge to the Claims Is Based
`
`Inter Partes review is requested in view of the following prior art references:
`
` U.S. Patent No. 4,567,359 to Lockwood (“Lockwood”) (Exhibit 1008).
`
`Lockwood was filed on May 24, 1984, and issued on January 27, 1986.
`
`Lockwood is therefore prior art to the Harvey ‘717 Patent under 35
`
`U.S.C. § 102(b). Lockwood was cited in an IDS by the applicant during
`
`prosecution of the Harvey ‘717 Patent, along with thousands of other
`
`references, but was not applied by the Examiner during prosecution.
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`-6-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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` U.S. Patent No. 4,825,045 to Humble (“Humble”) (Exhibit 1009).
`
`Humble was filed on July 24, 1986, and issued on April 25, 1989.
`
`Humble is therefore prior art to the Harvey ‘717 Patent under 35 U.S.C.
`
`§ 102(e).
`
` U.S. Patent No. 4,204,206 to Bakula (“Bakula”) (Exhibit 1010). Bakula
`
`was filed on August 30, 1977, and issued on May 20, 1980. Bakula is
`
`therefore prior art to the Harvey ‘717 Patent under 35 U.S.C. § 102(b).
`
` U.S. Patent No. 4,674,041 to Lemon (“Lemon”) (Exhibit 1011). Lemon
`
`was filed on September 15, 1983, and issued on June 16, 1987. Lemon is
`
`therefore prior art to the Harvey ‘717 Patent under 35 U.S.C. §§ 102(a)
`
`and (e).
`
`The specific statutory grounds on which the challenge to the claims is based
`
`and the patents relied upon for each ground are as follows:
`
`a) Claims 1-6 and 9 are anticipated by Lockwood under 35 U.S.C. § 102(b);
`
`b) Claims 1-6 and 9 are anticipated by Humble under 35 U.S.C. § 102(e);
`
`c) Claims 1-6 and 9 are unpatentable under 35 U.S.C. § 103(a) over
`
`Lockwood in view of Bakula;
`
`d) Claim 7 is unpatentable under 35 U.S.C. § 103(a) over Lockwood in
`
`view of Lemon;
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`
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`-7-
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`

`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`
`
`e) Claim 7 is unpatentable under 35 U.S.C. § 103(a) over Lockwood in view
`
`of Bakula and Lemon;
`
`f) Claims 1-6 and 9 are unpatentable under 35 U.S.C. § 103(a) over Humble
`
`in view of Lockwood and Bakula;
`
`g) Claim 7 is unpatentable under 35 U.S.C. § 103(a) over Humble in view
`
`of Lemon; and
`
`h) Claim 7 is unpatentable under 35 U.S.C. § 103(a) over Humble in view
`
`of Lockwood, Bakula, and Lemon.
`
`C.
`
`37 C.F.R. § 42.104(b)(3): Claim Construction
`
`Pursuant to 37 C.F.R. § 42.100(b), and solely for the purposes of this
`
`review, Petitioner construes the claim language such that the claims are given their
`
`broadest reasonable interpretation in light of the specification of the Harvey ‘717
`
`Patent. Petitioner submits that, for the purposes of this review, each claim be
`
`construed in accordance with its plain and ordinary meaning under the required
`
`broadest reasonable interpretation. Because the standard for claim construction at
`
`the Patent Office is different than that used during a U.S. District Court litigation,
`
`see In re Am. Acad. Of Sci. Tech Ctr., 367 F.3d 1359, 1364, 1369 (Fed. Cir. 2004);
`
`MPEP § 2111, Petitioner expressly reserves the right to argue a different claim
`
`construction in litigation for any term of the Harvey ‘717 Patent as appropriate in
`
`that proceeding.
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`
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`-8-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`D.
`
`
`37 C.F.R. § 42.104(b)(4): How the Construed Claims are
`Unpatentable
`
`
`
`
`
`
`
`
`A detailed explanation of how claims 1-7 and 9 are unpatentable, including
`
`the identification of how each claim element is found in the prior art, is set forth
`
`below at Section V.
`
`E.
`
`37 C.F.R. § 42.104(b)(5): Supporting Evidence
`
`An Appendix of Exhibits supporting this Petition is attached. Included at
`
`Exhibit 1012 is a Declaration of Charles J. Neuhauser, Ph.D. under 37 C.F.R.
`
`§ 1.68. In addition, the relevance of the evidence to the challenged claims,
`
`including an identification of the specific portions of the evidence supporting the
`
`challenge, is included in Section V.
`
`V. There Is a Reasonable Likelihood That at Least One Claim of the
`Harvey ‘717 Patent Is Unpatentable
`A. Claims 1-6 and 9 Are Anticipated by Lockwood (U.S. Patent No.
`4,567,359)
`
`
`
`
`
`1.
`
`Claim 1
`
`The Lockwood patent discloses “a system for automatically dispensing
`
`information, services, and products to customers in a self-service fashion.”
`
`(Lockwood at col. 1, lines 6-8.) The system may be used, for example, “to give
`
`personalized insurance quotations.” (Id. at col. 3, line 42.)
`
`As recited in claim 1, Lockwood discloses “receiving information content
`
`and a first control signal in said at least one information transmission at said
`
`
`
`-9-
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`

`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`receiver station, said information content describing at least one of a product and a
`
`service.” Lockwood discloses that information content is received at a system for
`
`dispensing insurance quotations (i.e., a receiver station), where the system includes
`
`a central data processing center and one or more user terminals. (Id. at col. 4, lines
`
`1-2.) The information content is received at the system from remote terminals
`
`operated by various insurance companies and includes “information on insurance
`
`policies and prices for various insurance companies.” (Id. at col. 5, lines 39-43.)
`
`Fig. 1, reproduced below, illustrates remote terminals 4, operated by “AAA
`
`Insurance Co.” and “BBB Insurance Co.,” which transfer information on insurance
`
`policies and prices to the system via telecommunication network service 5.
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`
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`-10-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`The information on insurance policies includes the types of policies offered by the
`
`insurance companies, including “automobile 35, homeowner 36, life 37 or health
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`38.” (Id. at col. 6, lines 52-53.) As discussed below, the information on insurance
`
`policies is output on a display screen of the system, allowing a user to view the
`
`types of policies available and to select one. (Id. at col. 6, lines 51-53.)
`
`A control signal is also received at the system for dispensing insurance
`
`quotations. The control signal is received at the system via an input device (i.e., a
`
`keyboard) operated by a customer and may be, for example, a signal generated
`
`upon completion of all necessary data entry by the customer. (See, e.g., id. at col.
`
`5, lines 44-48, disclosing that “[t]he processing unit 22 operates in response to
`
`program instructions to perform insurance quotation calculations in response to
`
`customer information received from any of the terminals.”)
`
`Lockwood further discloses “generating a benefit datum in response to said
`
`first control signal by processing subscriber specific data at said receiver station.”
`
`For example, Lockwood discloses that the control signal causes a personalized
`
`insurance quote (i.e., a benefit datum) to be generated at the receiver station (i.e., at
`
`the system for dispensing insurance quotations, including the central data
`
`processing center and one or more user terminals) by processing subscriber
`
`specific data, including the “age, gender, [and] marital status” of the customer. (Id.
`
`at col. 6, lines 55-56.) The personalized insurance quote explains the benefit of
`
`
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`-11-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`obtaining an insurance policy (e.g., the amount of money that will be received by
`
`the customer upon payment of a claim) and is specific to the particular customer.
`
`(Id.) The subscriber specific data is information solicited from the customer at the
`
`receiver station. (Id.)
`
`Lockwood also discloses “delivering said information content and said
`
`benefit datum at an output device at said receiver station, wherein said information
`
`content and said benefit datum explain a benefit of acquiring said product or
`
`service specific to said subscriber.” For instance, Lockwood discloses that the
`
`types of insurance policies to choose from (i.e., the information content) and the
`
`personalized insurance quote (i.e., the benefit datum) are delivered to a display
`
`device at the receiver station. (See, e.g., id. at col. 5, lines 16-19.)
`
`Lockwood further discloses “receiving a subscriber input at said receiver
`
`station after said step of delivering; and controlling said receiver station based on
`
`said subscriber input.” After the display of these items on the display device, a
`
`subscriber input is received at the receiver station. For example, the subscriber
`
`input may be an input of the customer’s credit card information that is used to
`
`purchase the insurance policy related to the generated insurance quote. (See, e.g.,
`
`col. 2, lines 15-18.) In response to the subscriber input, further processing is
`
`performed at the receiver station (e.g., a credit check is initiated, information on
`
`
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`-12-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`
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`the transaction is transferred to the relevant insurance company, etc.). (See, e.g.,
`
`id. at col. 1, line 67 to col. 2, line 7.)
`
`The claim chart below demonstrates in detail how Lockwood anticipates the
`
`method recited in claim 1.
`
`1. A method of processing video signals at a receiver station based on at least one
`information transmission, the method comprising the steps of:
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 61-63.)
`
` “A system for automatically dispensing information, goods and services to a
`customer on a self-service basis including a central data processing center in which
`information on services offered by various institutions in a particular industry is
`stored. One or more self-service information and sales terminals are remotely
`linked to the central data processing center and are programmed to gather
`information from prospective customers on goods and services desired, to transmit
`to customers information on the desired goods or services from the central data
`processing center, to take orders for goods or services from customers and transmit
`them for processing to the central data processing center, to accept payment, and to
`deliver goods or services in the form of documents to the customer when orders are
`completed. The central data processing center is also remotely linked to terminals
`of the various institutions serviced by the system, so that each institution can be
`kept up-dated on completed sales of services offered by that institution.” (See,
`e.g., Abstract.)
`receiving information content and a first control signal in said at least one
`information transmission at said receiver station, said information content
`describing at least one of a product and a service;
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 64-67.)
`
`“As seen in FIG. 4, the customer is asked (34) to select the type of insurance
`quotation desired (e.g. automobile 35, homeowner 36, life 37 or health 38).” (See,
`e.g., 6:51-53.)
`
` “The central data processing center 1 includes a central processing unit 22 and
`memory 23. The memory 23 stores program information and information on
`insurance policies and prices for various insurance companies, which are
`periodically up-dated from the terminals 4 of the various companies, and
`
`
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`-13-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
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`information on policy quotes and sales, which can be accessed periodically by the
`respective insurance company terminals. The processing unit 22 operates in
`response to program instructions to perform insurance quotation calculations in
`response to customer information received from any of the terminals, to send
`quotation data to the respective terminal, and to receive credit card information
`from a terminal and access the credit information terminal for credit approval or
`disapproval of a particular credit card. If a customer makes a purchase order at a
`particular terminal after credit is approved, the central data processing unit stores
`the policy information and sends instructions to the terminal to issue a policy.”
`(See, e.g., 5:37-55, emphasis added.)
`
`
`
`
` “The central data processing center is linked to data sources of various insurance
`companies containing information on premiums and policies. The terminal is
`programmed to audiovisually elicit from the customer the information necessary to
`provide an insurance quotation from the various companies.” (See, e.g., 2:10-15,
`emphasis added.)
`
` “Each sales and information terminal is programmed to gather a predetermined
`sequence of information from a customer on the services in which the customer is
`interested, and to transmit the information to the central data processing center. In
`response to the gathered information, the central data processing center extracts the
`desired information from its storage and transmits it back to the terminal where it
`is relayed to the customer.” (See, e.g., 2:48-55, emphasis added.)
`
`“Once all the necessary information has been gathered at the terminal (see 44), the
`processing unit 14 auto-dials the central data processing center 1 (see 45, FIG. 5),
`sends the gathered information to the center (46) and waits to receive an insurance
`quotation from each participating company.” (See, e.g., 7:5-10.)
`generating a benefit datum in response to said first control signal by processing
`subscriber specific data at said receiver station;
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 68-69.)
`
`“It is also an object of this invention to provide the general public information
`about comparable insurance coverages from several sources for comparison
`purposes and to automatically generate and issue insurance binder agreements
`according to customer’s choice and specifications.” (See, e.g., 1:31-36, emphasis
`added.)
`
`“Thus a customer will be asked pertinent questions on the type of insurance desired
`and the information necessary to process a quotation for that particular type of
`
`
`
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`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`insurance will be solicited. The gathered information is sent to the central data
`processing center, where the quotation is processed and transmitted back to the
`terminal.” (See, e.g., 3:17-23, emphasis added.)
`
`
`
`
`“The processing unit 22 operates in response to program instructions to perform
`insurance quotation calculations in response to customer information received from
`any of the terminals, to send quotation data to the respective terminal, and to
`receive credit card information from a terminal and access the credit information
`terminal for credit approval or disapproval of a particular credit card.” (See, e.g.,
`5:44-52.)
`
`“As seen in FIG. 4, the customer is asked (34) to select the type of insurance
`quotation desired (e.g. automobile 35, homeowner 36, life 37 or health 38). When
`the type of insurance is selected, a series of pertinent questions (39) for that type of
`insurance is asked, such as age, gender, marital status, and so on. The customer
`enters responses (40) on the touch pad, and the responses are shown on the monitor
`screen and repeated by the voice synthesizer for customer verification. Each valid
`answer is stored (41) until all necessary information has been gathered.” (See, e.g.,
`6:51-59, emphasis added.)
`delivering said information content and said benefit datum at an output device at
`said receiver station, wherein said information content and said benefit datum
`explain a benefit of acquiring said product or service specific to said subscriber;
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 70-71.)
`
`“As seen in FIG. 4, the customer is asked (34) to select the type of insurance
`quotation desired (e.g. automobile 35, homeowner 36, life 37 or health 38).” (See,
`e.g., 6:51-53.)
`
`“When a customer enters a terminal, the processing unit 14 is activated 25 by the
`photo sensor device 17, and sends a signal to the processing unit 10 of the video
`subsystem to begin playback of the sales presentation.” (See, e.g., 6:37-40.)
`
`“Information received back from the central data processing center 1, for example
`insurance quotations, will be displayed and may be printed out by the processing
`unit 14 over the printer unit 20.” (See, e.g., 5:16-19.)
`
`“The processing unit 22 operates in response to program instructions to perform
`insurance quotation calculations in response to customer information received from
`any of the terminals, to send quotation data to the respective terminal, and to
`receive credit card information from a terminal and access the credit information
`
`
`
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`
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`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`terminal for credit approval or disapproval of a particular credit card.” (See, e.g.,
`5:44-52.)
`receiving a subscriber input at said receiver station after said step of delivering;
`and
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 72-73.)
`
` “The customer is then given an opportunity to immediately select an insurance
`policy from one of the institutions.” (See, e.g., 3:23-25.)
`
`
`
`
`“The processing unit 22 operates in response to program instructions to perform
`insurance quotation calculations in response to customer information received from
`any of the terminals, to send quotation data to the respective terminal, and to
`receive credit card information from a terminal and access the credit information
`terminal for credit approval or disapproval of a particular credit card.” (See, e.g.,
`5:44-52.)
`
`“(9) If customer wishes to purchase insurance, credit card information is taken and
`relayed to the central data processing center;” (See, e.g., 6:14-16.)
`
`“If payment is accepted (61), the customer is asked to enter his or her name and
`address for billing purposes (62). The policy information collected at steps 53 and
`62 is transmitted to the central data processing center.” (See, e.g., 7:44-47.)
`controlling said receiver station based on said subscriber input.
`Lockwood discloses this claim element. (See Ex. 1012, ¶¶ 74-76.)
`“(5) If the customer elects to make a credit card or debit card purchase of goods or
`services in response to the data received, a credit check is requested from the credit
`information source;
`
`(6) On credit approval, the requested goods or services are dispensed in
`consideration for customer’s payment by credit card or other form of payment;
`
`(7) Information on the transaction is transmitted to the relevant company data
`source.” (See, e.g., 1:67-2:7.)
`
`“If the customer elects to purchase any of the quoted policies, the terminal accepts
`the customer’s credit card, initiates a credit check and, on approval, dispenses the
`policy.” (See, e.g., 2:15-18.)
`
`“If an insurance policy binder is desired, a credit check is initiated, and if payment
`is verified the order is processed and a policy is printed out at the terminal. If the
`
`
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`

`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,797,717
`
`customer decides, he may take the quotation home for study and decision and
`return later to purchase a policy since a record of the customer’s information is
`now on file.” (See, e.g., 3:25-31.)
`
` “(10) The central data processing center accesses the credit information terminal
`for credit approval or disapproval;
`
`(11) If credit is approved, the order is taken and a policy is issued to the customer
`at the terminal;
`
`(12) The central data processing center stores the information on the policy sold;
`
`
`
`
`(13) At the end of every day, the central data processing center transmits
`information on the daily quote and sales activity for each insurance company to the
`appropriate files of the Telenet ® comp