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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`VISA INC., and VISA U.S.A. INC.,1
`Petitioner,
`v.
`UNIVERSAL SECURE REGISTRY, LLC,
`Patent Owner.
`_________________________________________
`Case IPR2018-00810
`U.S. Patent No. 9,100,826
`________________________________________
`
`PETITIONER APPLE INC.’S SUR-REPLY TO PATENT OWNER’S
`REPLY TO THE OPPOSITION TO THE CONDITIONAL MOTION TO
`AMEND
`
`
`
`
`
`1 Visa Inc. and Visa U.S.A. Inc., which filed a petition in IPR2019-00175, have
`
`been joined as a party to this proceeding.
`
`
`
`
`
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`
`Contents
`I.
`INTRODUCTION ............................................................................................... 1
`II. ARGUMENT ...................................................................................................... 1
`A. Substitute Claim 56 Lacks Written Description Support Because The ’860
`Application Does Not Disclose Public/Private Key Encryption And Decryption. 1
`Schutzer And The ’585 Reference Render Obvious The Digital Signature
`B.
`In Substitute Claims 36, 42, And 45. ..................................................................... 3
`C. The ’585 Reference Would Have Motivated A POSITA To Use A
`Combination Function That Includes Prepending/Appending, Which Renders
`Obvious Substitute Claims 36, 42, And 45. ........................................................... 4
`D. PO Does Not Overcome Petitioner’s Showing That The KEK Architecture
`In Substitute Claim 56 Is Obvious. ........................................................................ 8
`E. The CMTA Opposition Explicitly Showed The Unpatentability Of
`Substitute Claim 45. ............................................................................................... 9
`F. PO Fails To Overcome Petitioner’s Showing That The Substitute Claims Are
`Patent Ineligible Under § 101. .............................................................................. 10
`G. Patent Owner Has Not Satisfied Its Duty Of Candor. ................................. 11
`III. CONCLUSION .............................................................................................. 12
`CERTIFICATE OF SERVICE ............................................................................ 16
`
`
`
`
`
`
`ii
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`
`
`I.
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`INTRODUCTION
`In opposing the CMTA, Petitioner demonstrated that the plain text of the
`
`’860 application does not support substitute claim 56, that the incorporation of
`
`digital signatures in claim 36[f] was an obvious addition to a combined
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`authentication code, and that encryption with a key-encryption-key was a well-
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`known way to encrypt data. Patent Owner’s (“PO”) Reply does not dispute these
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`points. Instead, PO resorts to introducing a new theory for written description
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`support for claim 56 and mischaracterizing the teachings of the references cited by
`
`Petitioner, the testimony of Petitioner’s experts, and the scope of claim 45. The
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`Board should deny PO’s CMTA.
`
`II. ARGUMENT
`A.
`Substitute Claim 56 Lacks Written Description Support Because
`The ’860 Application Does Not Disclose Public/Private Key
`Encryption And Decryption.
`The CMTA Opposition showed that substitute claim 56 lacks written
`
`description support for the claimed key-encryption-key (“KEK”) architecture
`
`because the ’860 application discloses at most an inoperable form of public-key
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`encryption, which is unlike the use of symmetric keys in KEK encryption. CMTA
`
`Opp. at 3-4. PO and its expert now concede that – as written – the portions of the
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`’860 application on which PO relies fail to support claim 56’s KEK architecture.
`
`CMTA Reply at 4. Confronted with this admitted flaw, PO and its expert venture
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`
`
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`1
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`
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`the new argument that the Board should overlook the application’s lack of
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`disclosure because it reflects an “obvious error” and a POSITA would understand
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`what was intended and “also readily recognize two corrections.” CMTA Reply at
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`4-5; Ex-1017, Jakobsson Dep., 51:5-54:16. PO is wrong about this on all accounts.
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`First, a POSITA would not conclude that the application should be
`
`understood to mean what PO and Dr. Jakobsson belatedly claim. Ex-1019, Shoup-
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`Decl., ¶¶27-28. PO now argues that a POSITA would recognize that pages 49-50
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`of the ’860 application should be corrected in two ways: first, decrypting with a
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`user’s private, rather than public key, and second, changing both the encryption
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`and decryption to be performed with a symmetric key. CMTA Reply at 4-5. But
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`even Dr. Jakobsson, when deposed, did not suggest that a POSITA would identify
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`both corrections. He identified only the first – which is the one that does not
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`support the claimed KEK architecture. Ex-1017, Jakobsson-Dep., 51:5-55:16.
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`And PO does not explain why a POSITA would understand a passage that
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`discloses a single encryption technique to be corrected to one that discloses two
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`alternative techniques, or why a disclosure limited to asymmetric public keys
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`should be understood to disclose symmetric keys. Ex-1019, Shoup-Decl., ¶¶25-28.
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` Second, PO is incorrect that In re Oda, 443 F.2d 1200, 1205 (CCPA 1971),
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`the sole case on which PO relies, would allow the Board to find written description
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`support where the plain text of the ’860 application provides none. Nothing in Oda
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`
`
`
`2
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`
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`suggests that the specification may be “corrected” where, as here, it would not be
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`evident to a POSITA what the correction would be. And PO presents no evidence
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`as to why both asserted corrections are appropriate where the specification listed
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`only one inoperable encryption technique. Furthermore, unlike in Oda, PO makes
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`no argument as to the source of the error, much less that the source renders clear
`
`which correction is appropriate. See 443 F.2d at 1206 (“[I]t follows that when the
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`nature of this error is known it is also known how to correct it.”). Accordingly, PO
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`fails to overcome Petitioner’s showing that claim 56 lacks written description
`
`support.
`
`B.
`
`Schutzer And The ’585 Reference Render Obvious The Digital
`Signature In Substitute Claims 36, 42, And 45.
`The CMTA Opposition demonstrates that Schutzer discloses a digital
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`signature, and that it would have been obvious in view of the teachings of both
`
`Schutzer and the ’585 reference to prepend or append a digital signature to the
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`authentication code of the ’585 reference. See CMTA Opp. at 8-10. PO does not
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`dispute the obviousness of this combination, and instead tries to argue that
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`Schutzer’s digital signature is different from the claimed digital signature. CMTA
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`Reply at 6-8. But that argument overlooks the detailed testimony of Dr. Shoup,
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`who explained, citing Schutzer and the ’585 reference, that it would have been
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`obvious to include a digital signature that “securely authenticate authentication
`
`device user” to arrive at the limitations of claims 36, 42, and 45. See Ex-1019,
`3
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`
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`
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Shoup-Decl., ¶¶38-54; see also CMTA Opp. at 9-10. More specifically, Dr. Shoup
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`explained that a POSITA would have recognized that forming digital signatures,
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`like those in Schutzer, could include generating a digital signature using a private
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`key associated with the first device (e.g., decrypting data with a user’s private key
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`similar to the combination function on the first device of the ’585 reference), and
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`that the second device could verify the digital signature (e.g., the verifier reverses
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`this process by encrypting the digital signature with a public key to authenticate the
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`device that created the digital signature). Ex-1019, Shoup-Decl., ¶¶40, 44-45.
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`PO offers no evidence to rebut Dr. Shoup’s testimony, or to show that such a
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`modification would be beyond the skill of a POSITA. Nor can it—Dr. Jakobsson
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`admits that a POSITA would understand digital signatures are used “to
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`authenticate the entity that generated the digital signature.” Ex-1017, Jakobsson-
`
`Dep., 77:1-19. Accordingly, PO fails to rebut Petitioner’s showing that claims 36,
`
`42, and 45 would have been obvious.
`
`C. The ’585 Reference Would Have Motivated A POSITA To Use A
`Combination Function That Includes Prepending/Appending,
`Which Renders Obvious Substitute Claims 36, 42, And 45.
`The ’585 reference discloses different combination functions, including
`
`prepending or appending constituent codes and values, and therefore renders
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`obvious substitute claims 36, 42, and 45. CMTA Opp. at 10, 12-14. PO does not
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`dispute that prepended or appended values would result in separable fields, as
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`
`
`
`4
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`
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`claims 42 and 45 require, and instead argues that prepending/appending codes with
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`the combination function of the ’585 reference would not have been obvious.
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`CMTA Reply at 11-14. This is incorrect for at least four reasons.
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`First, PO’s argument that it would be “redundant” to combine Maritzen’s
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`keys, the “code” of the ’585 reference, and Schutzer’s digital signature because the
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`code of the ’585 “incorporates biometric data” (id. at 11-12) ignores that the ’585
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`reference discloses embodiments where the user data (P) is a PIN, rather than a
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`biometric. Ex-1005, ’585 Reference, ¶72 (“The user data (P) is a unit of
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`information such as … a personal identification number (PIN) or password.”). In
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`such an embodiment, two redundant biometrics would not be sent. Rather, a PIN
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`and a biometric would be sent. Furthermore, because not all the authentication
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`codes in the ’585 reference include the value (P), and instead can include only “the
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`secret (K), the dynamic value (T) and the event state (E),” including an
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`authentication code without the value (P) would not be redundant with Maritzen’s
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`keys. See id. at ¶71. Furthermore, under Petitioner’s alternative theory where the
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`biometric key of Maritzen is replaced with the User Data (P) (see, e.g., Pet. at 41;
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`CMTA Opp. at 8-10), Petitioner demonstrated that the ’585 reference explicitly
`
`teaches appending/prepending the User Data (P) with a code based on the dynamic
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`value (T). See CMTA Opp. at 13 (discussing paragraph 73 of the ’585 reference
`
`where (P) is appended to A (K, T, E)), 8-9 (citing same).
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`5
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Second, PO is incorrect that Maritzen “teaches away” from sending
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`information derived from biometric information (see CMTA Reply, 12; see also
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`POR at 30). As Petitioner explained, Maritzen does not discourage sending user
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`information or require maintaining user anonymity, and the broad teachings of the
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`’585 reference are compatible with Maritzen. Petitioner’s Reply to POR at 7-14.
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`Third, PO is mistaken that the ’585 reference requires an irreversible one-
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`way function. CMTA Reply at 12-14. As PO’s expert recognizes, one-way
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`functions are practically irreversible, Ex-1017, Jakobsson-Dep., 186:11-187:7, but
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`the ’585 reference expressly discloses embodiments in which “[t]he verifier 105
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`reverses the [allegedly one-way] combination operation.” Ex-1005, ’585
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`Reference, ¶582. Were the combination function in the ’585 reference always one-
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`way as PO suggests, the verifier could never reverse it.
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`PO cites nothing in the ’585 reference that requires a one-way function in all
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`embodiments (CMTA Reply at 13-14), and instead relies only on the say-so of its
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`expert. See CMTA Reply at 13-14; Ex-2015, Jakobsson-Decl., ¶44. Indeed, the
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`’585 reference makes clear that algorithms other than one-way functions may be
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`used for a combination function. Ex-1005, ’585 Reference, ¶72 (“[U]sing a block
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`cipher or other one-way function, or other algorithm, or a combination of these
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`and other techniques that combine two or more input values together.”).
`
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`2 Emphasis added unless otherwise noted.
`6
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Fourth, PO overlooks examples of reversible combination functions, and PO
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`mischaracterizes Dr. Juels in suggesting he admitted prepending or appending
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`values are “inadequate way[s] to generate or protect the authentication code.”3
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`CMTA Reply at 13-14. To the contrary, Dr. Juels explained that an eavesdropper
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`can recover inputs only under particular situations where the eavesdropper has
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`enhanced knowledge and/or access. Ex-2016, Juels-Dep., 30:3-21, 34:12-36:12,
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`40:14-41:6. Dr. Juels also did not suggest, as PO claims, that translation errors in
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`the biometric information in Maritzen’s key would “make it practically impossible
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`for the verifier to verify a received authentication code.” CMTA Reply at 14.
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`Rather, Dr. Juels testified that although errors would complicate making rigorous,
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`formal arguments regarding exact biometric matches, such a system “can be
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`applied practically.” See Ex-2016, Juels-Dep., 146:10-147:7, 150:11-18. And if
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`PO is correct that such an implementation is practically impossible, then PO admits
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`3 PO cites to a deposition of Dr. Juels, who submitted declarations in support of
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`Petitioner’s Oppositions to CMTAs in two different IPR proceedings (IPR2018-
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`00809 and -813), one for the same patent (-813). Since PO has opened the door to
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`such evidence in this proceeding, Petitioner requests that the Board consider Dr.
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`Juels’ testimony showing the ’585 reference does not require a one-way function
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`for the combination function. See IPR2018-00813, Ex-1120, ¶¶39-43.
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`
`
`7
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`
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`that the ’826 patent is not enabled, since the ’826 patent provides no solution to
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`this problem.
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`D.
`
`PO Does Not Overcome Petitioner’s Showing That The KEK
`Architecture In Substitute Claim 56 Is Obvious.
`Petitioner demonstrated in its CMTA Opposition that the claimed KEK
`
`architecture would have been obvious over Burnett and the other cited references.
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`In particular, Petitioner showed that Burnett teaches a well-known KEK
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`architecture, and that it would have been obvious to modify authentication
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`information by encrypting it with a session key [first key], encrypting the session
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`key with a KEK [second key], and transmitting the KEK-encrypted session key
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`and the session key encrypted authentication information to the second device for
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`decryption. CMTA Opp. at 15-17. PO’s only response is to suggest that the KEKs
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`in Burnett are not shared. CMTA Reply at 17. That is wrong. Burnett states that
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`two parties (“Michelle” and “Pao-Chi”) share the same KEK. See Ex-1021,
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`Burnett, 85 (“Michelle ... encrypts the new session key using the KEK she shares
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`with him...”). When Michelle wants to share a session key with Pao-Chi, she
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`encrypts it with the shared KEK, just like the claimed first key encrypted by a
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`second key that is sent to the second device. Id. Similarly, for password-based
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`encryption (“PBE”), Burnett teaches passwords can be shared between parties so
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`that each party can generate the same KEK [second key] using PBE to
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`encrypt/decrypt a session key [first key]. Id. at 83. Burnett discloses other
`8
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`embodiments in which other symmetric keys, like a the claimed KEK, are shared
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`between parties. Id. PO makes no reference to these embodiments that disclose
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`sharing KEKs, either using PBE or otherwise. That is not surprising, because PO’s
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`expert admitted he only reviewed limited parts of Burnett, and could not recall ever
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`having reviewed the pages cited above. Ex-1032, Jakobsson Dep., 589:16-591:13.
`
`E.
`
`The CMTA Opposition Explicitly Showed The Unpatentability Of
`Substitute Claim 45.
`The CMTA Opposition showed that substitute claim 45, which requires
`
`decrypting a digital signature by the second device and a signal having separable
`
`fields, is obvious over the cited references. CMTA Opp. at 5-11. PO’s arguments
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`to the contrary are incorrect for at least three reasons.
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`First, PO’s argument that the CMTA Opposition failed to show the claimed
`
`decryption (CMTA Reply at 8-9) disregards the analysis that Petitioner presented
`
`with regard to claim 36 that Petitioner’s claim 45 analysis incorporates, which
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`explicitly addressed encrypting with first device and decrypting with second
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`device. See CMTA Opp. at 7-8 (citing to the Clearing House that decrypts the
`
`transaction key). Furthermore, Dr. Shoup’s declaration explained that the
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`combination function can be reversed by a verifier by decrypting with a public key
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`associated with the user. Ex-1019, Shoup-Decl., ¶¶44-45.
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`Second, PO’s argument that the CMTA Opposition failed to show the
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`claimed separable fields (CMTA Reply at 9) overlooks Petitioner’s reliance on
`9
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`
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`appending/prepending, which would result in “separable fields,” in explaining that
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`claim 36 would have been obvious, which Petitioner incorporated by reference in
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`explaining the obviousness of claim 45. See CMTA Opp. at 10-11.
`
`Third, PO’s argument that Petitioner failed to address “the one-time code
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`encrypted by the first device” and associated decryption by the second device
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`(CMTA Reply at 9-10) overlooks that these limitations are expressly optional. See
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`Limitation 45[e] (“at least one of the digital signature and/or the one-time code
`
`encrypted by the first handheld device”), 45[g] (“decrypting, with the second
`
`device, at least one of the digital signature and/or the one-time code encrypted by
`
`the first handheld device”). Accordingly, Petitioner’s showing that the cited
`
`references render obvious encrypting and decrypting a digital signature in the
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`discussion of claim 36 is sufficient to show that claim 45 is unpatentable. See
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`CMTA Opp. at 8-10; Ex-1019, Shoup-Decl., ¶44.
`
`Accordingly, Petitioner’s CMTA Opposition shows that claim 45 is obvious
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`over Maritzen, the ’585 reference, Niwa, and Schutzer.
`
`F.
`
`PO Fails To Overcome Petitioner’s Showing That The Substitute
`Claims Are Patent Ineligible Under § 101.
`As the CMTA demonstrated, the substitute claims are ineligible under § 101
`
`because they are directed to the abstract idea of verifying an account holder’s
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`identity based on codes and/or information related to the account holder before
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`enabling a transaction without adding an inventive concept. CMTA Opp. at 18-24;
`10
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Ex-1019, Shoup-Decl., ¶¶63-68. PO’s asserted “technological improvements,”
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`such as “local and remote authentication,” “authentication information,” “first
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`biometric information,” “signal[s],” “first authentication information,” “a one-time
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`code,” and “second authentication information,” are all abstract concepts that could
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`be implemented using a pen and paper or as a mental process. CMTA Reply at 22-
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`23. That the claims implement these abstract concepts with a generic “first device”
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`and “second device,” or in a particular order, does not render them any less
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`abstract. See, e.g., CMTA Opp. at 22-24. PO’s Reply fails to identify a single
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`Supreme Court or Federal Circuit case in which analogous claims were found to be
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`patent eligible.
`
`G.
`Patent Owner Has Not Satisfied Its Duty Of Candor.
`PO’s argument that it complied with its duty of candor because no such duty
`
`existed before Lectrosonics is incorrect. Western Digital and 37 C.F.R. § 42.11,
`
`which preceded Lectrosonics, imposed a duty of candor that, in this instance,
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`required PO to disclose Schutzer with its CMTA. Western Digital Corp. v. SPEX
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`Techs., Inc., IPR2018-00082, -00084, Paper 13, (PTAB April 25, 2018); 37 C.F.R.
`
`§ 42.11. Furthermore, PO’s argument that it “objectively believed that Schutzer
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`was not materially relevant” (CMTA Reply at 24) disregards that PO’s duty of
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`candor extends to information that is relevant only to a single added limitation,
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`“even if it does not include the rest of the claim limitations.” Lectrosonics Inc. v.
`
`
`
`
`11
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`
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Zaxcom, Inc., IPR2018-01129, -01130, Paper 15, 9-10 (PTAB Feb. 25, 2019).
`
`PO’s argument that the Board would otherwise be inundated with references lacks
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`merit—if PO considers the mere addition of a digital signature to a system for
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`authenticating identities of users to confer patentability on its claims, then PO has a
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`duty to disclose those references that are material to digital signatures. Patent
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`owners face similar disclosure requirements during examination, and the Board
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`should find no exception here.
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`III. CONCLUSION
`Based on the foregoing, PO fails to rebut Petitioner’s showing that the
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`substitute claims are unpatentable. Accordingly, Petitioner requests that the Board
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`deny PO’s CMTA.
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`June 10th, 2019
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`
`
`Respectfully Submitted,
`
`/Monica Grewal/
`
`Monica Grewal
`Registration No. 40,056
`
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`12
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`TABLE OF EXHIBITS
`
`Exhibit Number
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`U.S. Patent No. 9,100,826
`
`Declaration of Dr. Victor Shoup (“Shoup-Decl.”)
`
`Universal Secure Registry, LLC v. Apple Inc. et al., No.
`17-585-VAC-MPT (D. Del.), ECF No. 1, Complaint
`
`U.S. Patent Application Publication No. 2004/0236632
`(“Maritzen”)
`
`International Patent Application Publication No. WO
`2004/051585 (“Jakobsson”)
`
`U.S. Patent Application No. 09/510,811 (“Niwa
`Application”)
`
`U.S. Patent No. 6,453,301 (“Niwa”)
`
`’826 Patent File History, 03/18/2015 Notice of
`Allowance and Fees Due
`
`Universal Secure Registry, LLC v. Apple Inc. et al., No.
`17-585-VAC-MPT (D. Del.), ECF No. 1 Plaintiff’s
`Answering Brief in Opposition to Defendants’ Motion to
`Dismiss
`
`Webster’s New World Dictionary of Computer Terms
`Eighth Edition Copyright 2000 (Date Stamped by
`Library of Congress March 28, 2000).
`
`Microsoft Computer Dictionary Fourth Edition
`Copyright 1999
`
`U.S. Provisional Application No. 60/775,046
`
`
`
`
`13
`
`
`
`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`1013
`U.S. Provisional Application No. 60/812,279
`
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`1024
`
`1025
`
`1026
`
`1027
`
`1028
`
`U.S. Provisional Application No. 60/859,235
`
`Declaration of Mark D. Selwyn in Support of Motion for
`Admission Pro Hac Vice
`
`Deposition of Victor Shoup Errata
`
`Dr. Jakobsson Deposition Transcript
`
`Declaration of Dr. Shoup in Support of Petitioner’s
`Reply to Patent Owner’s Response
`
`Declaration of Dr. Shoup in Support of Petitioner’s
`Opposition to Patent Owner’s Conditional Motion to
`Amend
`
`[Reserved]
`
`Burnett et al., RSA Security’s Official Guide to
`Cryptography
`
`Declaration of Dr. Mullins
`
`Digital Copy of Burnett et al., RSA Security’s Official
`Guide to Cryptography (Jakobson Deposition Exhibit 1)
`
`Introduction to Cryptography (Jakobsson Deposition
`Exhibit 2)
`
`U.S. Patent No 5,680,460 (“Tomko”)
`
`Soutar et. al – Biometric Encryption
`
`Juels and Wattenberg – A Fuzzy Commitment Scheme
`
`Davida, Frankel, and Matt – On Enabling Secure
`Applications Through Off-line Biometric Identification
`
`
`
`
`14
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`
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`1029
`Daugman – Biometric Decision Landscapes
`
`European Patent Application Publication No. EP
`1028401 (“Schutzer”)
`
`Merriam-Webster Definition of “Disable”
`
`Dr. Jakobsson Deposition Transcript
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`1032
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`U.S. Patent No. 9,100,826
`Petitioner’ Sur-Reply To PO’s Reply To The Opposition To The CMTA
`CERTIFICATE OF SERVICE
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`I hereby certify that on June 10, 2019, I caused a true and correct copy of
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`the foregoing materials:
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`• Petitioner’s Sur-Reply to Patent Owner’s Reply to the CMTA Opposition
`• Table of Exhibits
`• Exhibit 1032
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`to be served via electronic mail on the following correspondents of record as listed
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`in Patent Owners’ Mandatory Notices and Paper 32:
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`For PATENT OWNER:
`James M. Glass (jimglass@quinnemanuel.com)
`Tigran Guledjian (tigranguledjian@quinnemanuel.com)
`Christopher A. Mathews (chrismathews@quinnemanuel.com)
`Nima Hefazi (nimahefazi@quinnemanuel.com)
`Richard Lowry (richardlowry@quinnemanuel.com)
`Razmig Messerian (razmesserian@quinnemanuel.com)
`Jordan B. Kaericher (jordankaericher@quinnemanuel.com)
`Harold A. Barza (halbarza@quinnemanuel.com)
`Quinn Emanuel USR IPR (qe-usr-ipr@quinnemanuel.com)
`QUINN, EMANUEL, URQUHART & SULLIVAN, LLP
`For PETITIONER:
`(IPR2019-00175):
`Matthew Argenti (margenti@wsgr.com)
`Michael Rosato (mrosato@wsgr.com)
`WILSON SONSINI GOODRICH & ROSATI
`Respectfully Submitted,
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`/Monica Grewal/
`Monica Grewal
`Registration No. 40,056
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`Date: June 10, 2019
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