IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`MASTERCARD INTERNATIONAL INCORPORATED
`Petitioner
`
`v.
`
`JOHN D’AGOSTINO
`Patent Owner
`
`––––––––––
`
`Case IPR2014-00544
`(Patent 7,840,486)
`
`Title: System and Method for Performing Secure Credit Card Purchases
`
`
`
`––––––––––
`
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`
`
`
`
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`MASTERCARD INTERNATIONAL INCORPORATED
`Petitioner
`
`v.
`
`JOHN D’AGOSTINO
`Patent Owner
`
`––––––––––
`
`Case IPR2014-00544
`(Patent 7,840,486)
`
`Title: System and Method for Performing Secure Credit Card Purchases
`
`
`
`––––––––––
`
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`
`
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`Table of Contents
`
`Page
`
`Introduction .................................................................................................. 1
`
`Claim Construction ...................................................................................... 1
`
`Cohen Discloses a Payment Category Including at Least “Limiting
`Purchases to a Single Merchant...Prior to any Particular Merchant Being
`Identified” ..................................................................................................... 5
`
`Cohen Discloses Designating a Payment Category Before Generating the
`Transaction code .......................................................................................... 9
`
`Conclusion ..................................................................................................13
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`
`
`
`
`- i -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`PETITIONER’S UPDATED LIST OF EXHIBITS
`
`
`
`Exhibit No.
`
`Description
`
`Exhibit 1001 U.S. Patent No. 7,840,486
`
`Exhibit 1002 File History for U.S. Patent No. 7,840,486
`
`Exhibit 1003 File History for U.S. Reexamination No. 90/012,517
`
`Exhibit 1004 U.S. Patent No. 6,422,462 (“Cohen”)
`
`Exhibit 1005 U.S. Patent No. 6,636,833 (“Flitcroft”)
`
`Exhibit 1006 U.S. Patent No. 5,826,243 (“Musmanno”)
`
`Exhibit 1007 Complaint in D’Agostino v. MasterCard, Inc. et al. (13-cv-0738)
`
`Exhibit 1008 Declaration of Jack D. Grimes, Ph.D.
`
`Exhibit 1009 Excerpts from Random House Webster’s Unabridged Dictionary,
`Second Edition
`
`Exhibit 1010 U.S. Patent No. 6,064,987 (“Walker”)
`
`Exhibit 1011 U.S. Patent No. 5,283,829 (“Anderson”)
`
`Exhibit 1012
`
`ISO 8583 Financial Transaction Card Originated Messages –
`Interchange Message Specifications (1992) (“ISO 8583”)
`
`Exhibit 1013 File History for U.S. Patent No. 8,036,988
`
`Exhibit 1014 Patent Trial and Appeal Board’s (“PTAB”) 3/7/14 CBM Decision
`for U.S. Patent No. 8,036,988
`
`Exhibit 1015 Patent Trial and Appeal Board’s (“PTAB”) 3/7/14 CBM Decision
`for U.S. Patent No. 7,840,486
`
`
`
`
`- ii -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`Exhibit 1016 Patent Owner’s 12/24/13 Preliminary Response to Petitioner’s
`Request for CBM Patent Review of the ‘486 Patent
`
`Exhibit 1017 U.S. Provisional App. No. 60/079,884 (“’884 Provisional)
`
`Exhibit 1018 U.S. Provisional App. No. 60/099,614 (“’614 Provisional)
`
`Exhibit 1019 U.S. Provisional App. No. 60/098,175 (“’175 Provisional)
`
`Exhibit 1020 U.S. Provisional App. No. 60/092,500 (“’500 Provisional)
`
`- iii -
`
`
`
`
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`I.
`
`Introduction
`
`Patent Owner’s Response attempts to distinguish the claims of the ‘486
`
`patent from Cohen by presenting two principal arguments. Patent Owner contends
`
`that Cohen does not disclose: (1) a payment category that limits purchases to a
`
`single merchant prior
`
`to
`
`the merchant being
`
`identified;
`
`and
`
`(2)
`
`designating/selecting a payment category before generating the transaction code.
`
`Response at 1-2,18, 28. Patent Owner’s arguments, however, are premised on
`
`claim constructions already rejected by the Board in its Decision to Institute
`
`(“ID”). ID at 6-8. Because Cohen explicitly discloses each of the limitations at
`
`issue, as properly construed by the Board, all claims of the ’486 patent are
`
`unpatentable and should be canceled.
`
`II. Claim Construction
`
`Patent Owner and its declarant1 premise their arguments on flawed claim
`
`constructions that are divorced from the broadest reasonable interpretation standard
`
`applicable to this proceeding. 37 C.F.R. § 42.100(b).
`
`
`1 Edward L. Gussin’s testimony should be given no weight because his opinions
`
`are based on flawed claim constructions previously rejected by the Board, and
`
`because he lacks the minimum qualifications that he concedes are required of a
`
`person of ordinary skill in the art. Ex. 2007 ¶ 30; Ex. 1008 ¶ 18.
`
`
`
`- 1 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`Regarding “generating a transaction code,” Patent Owner argues that this
`
`term must be read to require that the “transaction code” be “indicative” of not just
`
`“a specific credit card account” but also “a payment category.” Response at 4-8.
`
`As the Board found, however, this may be a preferred embodiment, but it is
`
`certainly not required. ID at 6. Patent Owner’s argument that the Board’s
`
`construction
`
`is
`
`incorrect because
`
`it purportedly “excludes” a preferred
`
`embodiment” (pp. 4,8) is meritless. The Board’s construction properly includes
`
`within the scope of the claim the embodiment where the “transaction code” is
`
`indicative of a payment category. Thus, this embodiment is not “exclud[ed]” at all.
`
`Claim differentiation also counsels against Patent Owner’s construction requiring
`
`indication of a payment category. Claim 8, for example, would be superfluous if
`
`Patent Owner’s construction were adopted.
`
`Patent Owner’s additional argument that this term should be broadened to
`
`cover either a “credit card account or a debit card account” (pp. 5-6) is both
`
`irrelevant and meritless. First, Patent Owner does not explain how this revised
`
`construction would alter the outcome in this proceeding. Second, the argument is
`
`belied by the claims themselves, all of which are expressly limited to methods for
`
`“secure credit card purchases.” Ex. 1001 (emphasis supplied).
`
`Patent Owner’s proposed construction of “defining at least one payment
`
`category” is also flawed as it improperly avoids giving any meaning to the term
`
`
`
`- 2 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`“payment category,” instead merely repeating that disputed term in its proposed
`
`construction. Response at 9-11. Moreover, Patent Owner’s construction, which
`
`requires “specifying the limit of a payment category,” fails to apply the broadest
`
`reasonable interpretation standard. Nothing in the claim or specification requires
`
`that a payment category necessarily include “the limit” applicable to that category.
`
`Similarly, the Patent Owner’s argument regarding “particular merchant” is
`
`unfounded. Response at 11-13. The Board correctly found this term to mean “the
`
`merchant to whom the customer discloses the transaction code” and/or “the
`
`merchant with whom the customer is transacting.” ID at 8. The argument the
`
`Patent Owner now makes in support of its construction (i.e., that the “particular
`
`merchant” is merely one with whom a customer is able to engage in “a” purchase
`
`transaction and not necessarily “the” merchant with whom the customer is
`
`transacting, Response at 11-12) is unreasonable, at least because the Patent Owner
`
`argued the exact opposite to obtain allowance during the ex parte prosecution of
`
`the parent ‘486 Patent. See Ex. 1013 p. 187 (where the Patent Owner distinguished
`
`the prior art for failing to tie the transaction to the code, contending that the prior
`
`art is “not directed towards generating a temporary account number on a
`
`transactional basis,” but rather uses merchant type category codes and approved
`
`vendor lists having pre-identified merchants); Ex. 1008 p.14, n.3; Petition at 10.
`
`
`
`- 3 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`Additionally, the Patent Owner falsely states that “Petitioner’s expert
`
`agrees” with Patent Owner’s construction. Response at 11-12. To the contrary,
`
`Petitioner’s expert’s construction calls for “a specific merchant with whom a
`
`customer can engage in the purchase transaction” -- not “a” purchase transaction,
`
`as proposed by the Patent Owner. Ex. 1008 ¶ 23. Although only a word, the
`
`difference is immense. Under Patent Owner’s construction, the “particular
`
`merchant” could be any merchant potentially involved in any transaction --
`
`untethered to the “transactions” explicitly mentioned in the clause just preceding
`
`“particular merchant.” In context, the phrase “particular merchant” must reference
`
`“the” merchant with whom the customer is transacting -- not any merchant with
`
`whom the customer could transact.2 See Ex. 1008 ¶ 26.
`
`The Patent Owner further spends time attacking the Board’s construction of
`
`the “single merchant limitation.” Response at 13-16. These arguments lack
`
`substance. The Board interpreted this phrase as “any group, category, or type of
`
`
`2 Patent Owner’s reliance on claim differentiation is misplaced (Response at 13).
`
`None of the independent claims require the merchant ever be identified. Instead,
`
`they merely require a limitation to be included in a payment category “prior to any
`
`particular merchant being identified.” Moreover, the dependent claims include
`
`particular timing limitations related to when during transaction processing the
`
`merchant is identified. Thus, those claims are not superfluous.
`
`
`
`- 4 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`merchant is included in the payment category prior to the customer selecting a
`
`particular merchant for a transaction.” ID at 8. The Board, however, qualified this
`
`construction in its IPR2014-00543 Institution Decision (“Companion Institution”)
`
`regarding the ‘988 patent, p. 10, noting that the “single merchant” allows “for only
`
`one merchant.” Id. at 10. The Patent Owner ignores this clarifying construction,
`
`and interprets the Board’s construction of “said single merchant limitation” to be
`
`“any one group, type, or category of merchant.” Response at 13. But this is
`
`neither reasonable nor correct, as the Board has already explained in its
`
`Companion Institution, correctly construing this phrase as “for only one
`
`merchant.”
`
`In view of the foregoing, Patent Owner’s arguments regarding patentability
`
`also fail, as explained below.
`
`III. Cohen Discloses a Payment Category Including at Least “Limiting
`Purchases to a Single Merchant...Prior to any Particular Merchant
`Being Identified”
`
`In connection with claims 1-15 and 22-30, and limiting “purchases” or a
`
`“purchase” to a single merchant “prior to any particular merchant being
`
`identified,” Patent Owner argues (1) that Petitioner relies on Cohen’s disclosure of
`
`single-use cards (at 19); (2) that Cohen’s disclosure of single-use cards does “not
`
`meet the disputed claim limitation because a single-use card cannot be used to
`
`make multiple purchases as required by the claims” (at 19); and (3) that this claim
`
`limitation “includes making more than one purchase” (at 19). Patent Owner also
`
`
`
`- 5 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`generally argues that the “single merchant limitation” is not disclosed in Cohen.
`
`Response at 20-27.
`
`Patent Owner is wrong on all counts. First, Patent Owner assumes
`
`incorrectly that this limitation requires “multiple purchases” with a single
`
`merchant. But, the surrounding claim text is not restricted to multiple purchases or
`
`transactions. Instead, each of the independent claims at issue (1, 24, 25 and 29)
`
`specifies as follows, respectively: “limiting purchases to a single merchant for at
`
`least one transaction;” “limiting purchases to a single merchant;” “limits a nature,
`
`of a series of subsequent purchases to a single merchant;” and “limits a nature of a
`
`subsequent purchase to a single merchant.” Thus, under the broadest reasonable
`
`interpretation standard, the claims encompass conducting at least one purchase
`
`with a single merchant. They could also encompass multiple purchases at a single
`
`merchant, but that is not required. Had the Patent Owner desired to restrict its
`
`claims to only multiple purchases, it should have sought to do so by amendment.
`
`Second, even if, as Patent Owner contends, the claim requires multiple
`
`purchases with a single merchant, Cohen discloses this feature. Ex. 1004 at 2:35-
`
`43; 8:25-39 (“The card could be valid only for purchases on that particular day, to
`
`a certain designated purchase limit, and even, if desired only in a certain store, or
`
`group of stores or types of stores (e.g. clothing stores...); “any of [these] features...
`
`can also be combined.”) Id. 8:35-36 (emphasis supplied).
`
`
`
`- 6 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`The fact that Cohen also discloses a single-use card that can be used for a
`
`single purchase does not alter this conclusion. Cf. Response at 19. As disclosed in
`
`Cohen: “a card [could be used] in any computer store which is good for a total
`
`purchase of up to, for example, $2000 in value.” Id. at 8:38-40 (emphasis added).
`
`This portion of Cohen alone meets the Patent Owner’s narrow construction
`
`(Response at 20, 22-23) as it recites the use of a payment category comprising an
`
`unidentified “computer store” (singular, not plural) or, in other words, a “single
`
`merchant” allowing for one or multiple purchases or transactions, over any time
`
`period, up to a certain value. This is exactly what Patent Owner says is required by
`
`this limitation, and is exactly what is disclosed in Cohen -- as the Board previously
`
`found. ID at 12.
`
`Patent Owner further argues that Cohen’s disclosure does not satisfy the
`
`claims’ limits to a “single merchant” or designation of a payment category “prior
`
`to any particular merchant being identified.” Response at 21-26. Patent Owner
`
`also cites the Central Reexamination Unit’s (“CRU’s”) statement that “Cohen does
`
`not disclose a single merchant being included in a payment category prior to any
`
`particular merchant being identified.” Response at 27. Both the Patent Owner and
`
`the CRU misapply the teachings of Cohen.
`
`Applying this Board’s proper construction of the “single merchant
`
`limitation” (i.e., “only one merchant is included in the payment category prior to
`
`
`
`- 7 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`the customer selecting that particular merchant for a transaction”), or even using
`
`the Patent Owner’s construction (“including the limit in the payment category that
`
`limits transactions to a single merchant before any specific merchant is identified
`
`as the single merchant,” Response at 17), Cohen anticipates.
`
`More specifically, Cohen explicitly discloses a payment card system having
`
`“customized or limited use” credit cards. Ex. 1004, 2:55-57. These cards, in one
`
`example, “could be valid only for purchase...only in a certain store, or group of
`
`stores or type of stores (e.g., clothing stores)...” Id. 8:44-46. Or, the card could be
`
`used “in any computer store” (singular, not plural, and not an “identified” store).
`
`Id. 8:37-39. These instances alone demonstrate a payment category limited to one
`
`(i.e. a single) merchant (e.g., a certain store, type of store, clothing store or “any”
`
`unnamed computer store), in each case the name of the store being unidentified
`
`until the card is later used at the store itself. Accordingly, Cohen discloses the
`
`“single merchant limitation.”
`
`To support its flawed argument, Patent Owner resorts to selectively quoting
`
`Dr. Grimes in an effort to convince the Board that Dr. Grimes “concedes that a
`
`merchant type limit…does not satisfy the disputed claim limitation.” Response at
`
`22. In particular, Patent Owner quotes the following from Dr. Grimes: “pre-
`
`identifying a merchant by an MCC code is insufficient to satisfy the element ‘prior
`
`to any particular merchant being identified.’” Id. But, as the remainder of the
`
`
`
`- 8 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`sentence (left out by Patent Owner) makes clear, Dr. Grimes is not relying on “pre-
`
`identifying” a merchant to satisfy the claim element. Instead, as Dr. Grimes
`
`correctly states in the rest of that sentence: “the claimed identification must be
`
`related to the transactions in the payment category.” Ex. 1008, p. 14, n.3. Like Dr.
`
`Grimes, Petitioner relies on Cohen’s disclosure of identifying the merchant at the
`
`time of the transaction as satisfying the claim element, not any “pre-identification,”
`
`as the Board has recognized. (Companion Institution at 15) (“the user
`
`subsequently identifies a particular merchant”) (emphasis added).
`
`Accordingly, Patent Owner’s arguments that in Cohen, merchants must be
`
`pre-identified “in order to limit a credit card’s use to a group of stores, that group
`
`must already exist” (e.g. Response at 22-26) are irrelevant. These arguments
`
`confuse any pre-identification (which, as Dr. Grimes has noted, was disclaimed
`
`during ex parte prosecution) with the claimed identification that takes place in the
`
`course of carrying out the transaction that is subject to the limit. Whether
`
`merchants have been pre-identified as being within a particular class of merchants,
`
`such as clothing stores, is simply irrelevant to the claims. Accordingly, Cohen
`
`anticipates.
`
`IV. Cohen Discloses Designating a Payment Category Before Generating
`the Transaction code
`
`Patent Owner argues that the claims require “designating/selecting a
`
`payment category that places limitations on a transaction code before the
`
`
`
`- 9 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`transaction code is generated.”3 Response at 28-32 (emphasis added). Petitioner
`
`disagrees and respectfully submits that designating/selecting a payment category
`
`need not take place before the transaction code is generated. Indeed, nothing in the
`
`patent’s specification requires such a narrow reading, and the doctrine of claim
`
`differentiation supports a broader reading, not requiring the limitations at issue to
`
`proceed in sequence.
`
`For instance, claim 1 calls for “defining a payment category,” and separately
`
`“designating said payment category thereby designating at least that a transaction
`
`code … can be used by only one merchant,” and then separately “generating a
`
`transaction code” -- and claim 2 requires that “the step of designating said single
`
`merchant” take place “subsequent to generating the transaction code.” (Emphasis
`
`added). Claim 2’s “subsequent” requirement would not make sense if claim 1
`
`required just the opposite, as seemingly urged by the Patent Owner. Consequently,
`
`claim 1 does not require the designating/selecting step before the transaction code
`
`is generated. If the inventor had wanted to claim a particular sequence in Claim 1
`
`he would have explicitly done so, as he did in Claim 2.
`
`
`3 The Board construed “generating a transaction code” to mean “creating or
`
`producing a code that is usable as a substitute for a credit card number in a
`
`purchase transaction, the transaction code is pre-coded to be indicative of a specific
`
`credit card account.” ID at 6.
`
`
`
`- 10 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`Nonetheless, Patent Owner then argues that Cohen does not disclose these
`
`two steps in the order it says the claims require. Patent Owner’s argument is
`
`without merit, even if the claims were to be read to require that the limitations be
`
`placed on a transaction code before the code were generated.
`
`Patent Owner cites to one embodiment in Cohen where the payment
`
`category is defined after the transaction code is generated. (Response at 43; Ex.
`
`1004 (Cohen) at 9:13-23) This is the same embodiment cited by the CRU in
`
`issuing the Notice of Intent to Issue Ex Parte Reexamination Certification for the
`
`‘988 patent (‘988 NIIRC at 2-3). Both the Patent Owner and the CRU, however,
`
`misinterpret and/or misunderstand (or ignore) the explicit additional disclosures in
`
`Cohen defining a payment category before generating the transaction code. See,
`
`e.g., Cohen at 3:40-55, 56-67.
`
`More specifically, Patent Owner argues that Cohen’s single or multiple use
`
`cards do not satisfy the “defining/selecting a payment category that places a
`
`limitation on a transaction code” before “generating the transaction code.”
`
`Response at 28-32. Cohen, however, discloses that a single use card (i.e. a
`
`“disposable card”) is generated for the purpose of allowing a single transaction,
`
`after which it can be thrown away. Cohen at 2:14-15. Cohen also discloses that
`
`customized or limited use cards are generated for the purposes of allowing one or
`
`multiple transactions for only particular uses or groups of uses. Id. at 7:65-8:57.
`
`
`
`- 11 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`In all cases, a user can call a credit card company to request a single or
`
`customized use card. Cohen at 3:41-47 (“a user dials into her credit card company
`
`before making a transaction, and after providing the ordinary credit card number
`
`and verification data, is provided with a disposable or customized number and/or
`
`mailed, provided with, or allowed to activate a disposable or customized card for a
`
`single or limited range use.”) (ID at 13, emphasis added). The fact that the user
`
`requests the single or customized use card and then receives such a card in
`
`response - all before any transaction takes place - indicates that the payment
`
`category (i.e. restricting a card to a single or customized use, which effectively
`
`limits the card to a single merchant or multiple merchants, as the case may be) is
`
`defined before the transaction code is generated. The user receives a card that has
`
`already been designated for a single or customized use, so the single or customized
`
`use category must have been designated before the transaction code was generated.
`
`Cohen does not suggest otherwise.
`
`Indeed, Cohen is even more explicit, disclosing that “in advance of the
`
`purchase” a user can call the credit card company to “indicate” the exact use of the
`
`card, namely “what the single use or customized credit card number is to be used
`
`for.” Cohen 3:49-54. Cohen thus discloses that a user may first designate or select
`
`a payment category that places limitations on a transaction code (e.g., single use,
`
`customized use), saying what the card is to be used for (e.g., for purchases in
`
`
`
`- 12 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`computer stores). Then, “before making the transaction” and “in advance of
`
`purchase” -- and after saying what the card is to be used for (i.e., after
`
`defining/selecting a payment category) -- the user is “provided with a disposable or
`
`customized number” (i.e., transaction code) for making a purchase or purchases
`
`within the payment category. Id. This is the very sequence that Patent Owner says
`
`is missing from Cohen.
`
`But there is more. Cohen also discloses an additional embodiment, where “a
`
`user could be provided … with a set of disposable, one time only, or customized,
`
`limited use, numbers….” Ex. 1004, 3:56-60. Cohen further explains: “With
`
`respect to the customized card, the cards can either be preset for certain uses, or
`
`the cards can be ready and waiting in the user's office or home for setting to the
`
`desired use when the user is ready.” Id. 3:63-67 (emphasis added). Accordingly,
`
`Cohen discloses both designating a particular payment category before the number
`
`(or authorization code) is generated (i.e. the card is “preset” for a particular use)
`
`and designating a payment category after the code is generated (i.e. the card is
`
`“ready …for setting to the desired use when the user is ready”). As a result, Cohen
`
`anticipates, even if payment category designation is required before the code is
`
`generated.
`
`V. Conclusion
`
`The absence of comments in reply to a specific assertion made by the Patent
`
`Owner does not signify agreement with or concession of that assertion, but that the
`
`
`
`- 13 -
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
`assertion has already been addressed by MasterCard or is without any merit. For
`
`the foregoing reasons and based on the Petition, the expert declaration of Dr.
`
`Grimes, and all the supporting evidence of record, MasterCard respectfully
`
`requests that the Board issue a final decision cancelling each and every claim of
`
`
`
`
`
`Respectfully submitted,
`BAKER BOTTS LLP
`/Robert C. Scheinfeld/
`Robert C. Scheinfeld
`Reg. No. 31,300
`30 Rockefeller Plaza, 44th Floor
`New York, New York 10112-4498
`Phone: (212) 408-2512
`Facsimile: (212) 408-2501
`robert.scheinfeld@bakerbotts.com
`
`ATTORNEYS FOR PETITIONER
`MASTERCARD INTERNATIONAL
`INCORPORATED
`
`the ’486 patent.
`
`
`
`February 27, 2015
`
`
`
`Eliot D. Williams
`Reg. No. 50,822
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7511
`Facsimile: (650) 739-7611
`eliot.williams@bakerbotts.com
`
`
`
`
`- 14 -
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on the 27th day of February, 2015, a complete
`
`and entire copy of PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`was served via electronic mail and Federal Express to the Patent Owner’s attorneys
`
`of record at the following address:
`
`Stephen J. Lewellyn
`Brittany J. Maxey
`Maxey Law Offices, PLLC
`100 Second Avenue South
`Suite 401 North Tower
`St. Petersburg, Florida 33701
`s.lewellyn@maxeyiplaw.com
`b.maxey@maxeyiplaw.com
`
`
`
`
`
`
`
`Eliot D. Williams
`Reg. No. 50,822
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7511
`Facsimile: (650) 739-7611
`eliot.williams@bakerbotts.com
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`BAKER BOTTS LLP
`
`/Robert C. Scheinfeld/
`Robert C. Scheinfeld
`Reg. No. 31,300
`30 Rockefeller Plaza, 44th Floor
`New York, New York 10112-4498
`Phone: (212) 408-2512
`Facsimile: (212) 408-2501
`robert.scheinfeld@bakerbotts.com
`
`ATTORNEYS FOR PETITIONER
`MASTERCARD INTERNATIONAL
`INCORPORATED
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
