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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
`Petitioners,
`v.
`UNIVERSAL SECURE REGISTRY, LLC,
`Patent Owner.
`_________________________________________
`Case IPR2018-00813
`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 IPR2019-00176, have
`
`been joined as a party to this proceeding.
`
`
`
`
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`TABLE OF CONTENTS
`
`B.
`
`C.
`
`D.
`
`I.
`INTRODUCTION .................................................................................................................. 1
`II. ARGUMENT .......................................................................................................................... 1
`Substitute Claim 56 Lacks Written Description Support Because
`A.
`The ’860 Application Does Not Disclose Public/Private Key Encryption
`And Decryption. ...................................................................................................... 1
`Schutzer And The ’585 Reference Render Obvious The Digital Signature In
`Substitute Claims 36, 42, And 45. .......................................................................... 3
`The ’585 Reference Discloses Financial Transactions As Required By Substitute
`Claims 36 And 45. .................................................................................................. 4
`The Prior Art Discloses All Three Of The “One-time Code,” “First
`Authentication Information,” And “Digital Signature” Required By Substitute
`Claims 36 And 45. .................................................................................................. 6
`The ’585 Reference’s Prepending/Appending Produces “Separable Fields” As
`Substitute Claims 42 And 45 Require. .................................................................... 7
`PO Does Not Overcome Petitioner’s Showing That The KEK Architecture In
`Substitute Claim 56 Is Obvious. ............................................................................. 9
`The CMTA Opposition Explicitly Showed The Unpatentability Of Substitute
`Claim 45. ............................................................................................................... 10
`PO Fails To Overcome Petitioner’s Showing That The Substitute Claims Are
`Patent Ineligible Under § 101. .............................................................................. 11
`Patent Owner Has Not Satisfied Its Duty Of Candor. .......................................... 12
`I.
`III. CONCLUSION .................................................................................................................. 12
`CERTIFICATE OF SERVICE ..................................................................................................... 17
`
`
`E.
`
`F.
`
`G.
`
`H.
`
`
`
`ii
`
`

`

`I.
`
`U.S. Patent No. 9,100,826
`Petitioner’s 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 substitute claims 36, 42, and 45 was an obvious addition to a
`
`combined authentication code, and that encryption with a key-encryption-key was
`
`a well-known way to encrypt data. Patent Owner’s (“PO”) Reply does not dispute
`
`these points. Instead, PO resorts to mischaracterizing the teachings of the
`
`references, the testimony of Petitioner’s experts, Petitioner’s methodical mapping
`
`of the “fields” required by claims 36 and 45, and the scope of claim 45.
`
`II. ARGUMENT
`A.
`Substitute Claim 56 Lacks Written Description Support Because
`The ’860 Application Does Not Disclose Public/Private Key
`Encryption And Decryption.
`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 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 ’860 application on which PO relies
`
`fail to support claim 56’s KEK architecture. CMTA Reply at 2-3. Confronted
`
`with this admitted flaw, PO and its expert attempt the new argument that the Board
`
`should overlook the application’s lack of disclosure because it reflects an “obvious
`
`error” and a POSITA would understand what was intended and would “also readily
`
`1
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`recognize two corrections.” CMTA Reply at 2-4; Ex-1117, Jakobsson Dep., 51:5-
`
`54:16. PO is wrong about this on all accounts.
`
`First, a POSITA would not conclude that the application should be
`
`understood to mean what PO and Dr. Jakobsson belatedly claim. Ex-1119, Shoup-
`
`Decl., ¶¶27-28. PO now argues that a POSITA would recognize that pages 49-50
`
`of the ’860 application should be corrected in two ways: first, decrypting with a
`
`user’s private, rather than public key, and second, changing both the encryption
`
`and decryption to be performed with a symmetric key. CMTA Reply at 3-4. But
`
`even Dr. Jakobsson, when deposed, did not suggest that a POSITA would identify
`
`both corrections. He identified only the first (Ex-1017, Jakobsson Dep., 51-54),
`
`which is the one that does not support the claimed KEK architecture. CMTA Opp.
`
`at 4. And PO does not explain why a POSITA would understand a passage that
`
`discloses a single encryption technique to be corrected to one that discloses two
`
`alternative techniques, or why a disclosure limited to asymmetric public keys
`
`should be understood to disclose symmetric keys. Ex-1119, Shoup-Decl., ¶¶25-28.
`
`Second, PO is incorrect that In re Oda, 443 F.2d 1200, 1205 (CCPA 1971),
`
`the sole case PO relies on, would allow the Board to find written description
`
`support where plain text of the ’860 application provides none. Nothing in Oda
`
`suggests that the specification may be “corrected” where, as here, it would not be
`
`clear to a POSITA what the correction would be. And PO presents no evidence as
`
`2
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`to why both asserted corrections are appropriate where the specification listed only
`
`one inoperable encryption technique. Furthermore, unlike in Oda, PO does not
`
`identify the source of the error, much less that it makes one correction clear. See
`
`443 F.2d at 1206 (“[I]t follows that when the nature of this error is known it is also
`
`known how to correct it”). Accordingly, PO fails to overcome Petitioner’s
`
`showing that claim 56 lacks support.
`
`B.
`
`Schutzer And The ’585 Reference Render Obvious The Digital
`Signature In Substitute Claims 36, 42, And 45.
`PO’s argument that Schutzer’s digital signature is different from the claimed
`
`digital signature (CMTA Reply at 10-12) overlooks Dr. Shoup’s detailed
`
`explanation of why it would have been obvious to include a digital signature that
`
`“securely authenticate a[n authentication device] user” to arrive at claims 36, 42,
`
`and 45. Ex-1119, Shoup-Decl., ¶¶45-50, 59; see also CMTA Opp. at 9-11. Dr.
`
`Shoup explained that a POSITA would have recognized that forming digital
`
`signatures, like those in Schutzer, could include generating a digital signature using
`
`a private key of the first device (e.g., decrypting data with a user’s private key like
`
`the first device’s combination function in the ’585 reference), and that the second
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`device could verify the digital signature (e.g., verifier reverses this process by
`
`encrypting the digital signature with a public key to authenticate the device that
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`created the digital signature). Ex-1119, Shoup-Decl., ¶¶49-50.
`
`PO offers no evidence to rebut Dr. Shoup, or to show that such a
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`3
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`modification would be beyond a POSITA’s skill. Nor can it—Dr. Jakobsson
`
`admitted that a POSITA would understand digital signatures are used “to
`
`authenticate the entity that generated the digital signature.” Ex-1117, 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 Discloses Financial Transactions As Required
`By Substitute Claims 36 And 45.
`The ’585 reference discloses the same financial transactions that substitute
`
`claims 36 and 45 would cover. PO’s argument to the contrary is meritless.
`
`PO is incorrect that the ’585 reference does not disclose financial systems
`
`“used for credit/debit card transactions.” CMTA Reply at 4-5. It expressly
`
`discloses that user authentication provides access to “financial services” using a
`
`“credit card.” CMTA Opp. at 5; Ex-1120, Juels-Decl., ¶¶37-38. PO’s piecemeal
`
`analysis of certain types of access in paragraphs 39 and 41 of the ’585 reference
`
`(CMTA Reply at 5-6) disregards the plain language stating “[a]ccess includes,
`
`without limitation … access to … financial services.” Ex-1104, ’585 Reference,
`
`¶39. PO also ignores that the ’585 references discusses tokens that can include
`
`bank cards (Ex-1104, ’585 Reference, ¶6) and that a POSITA would understand
`
`credit card-accessed “financial services” to include more than an online account
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`access. Ex-1120, Juels-Decl., ¶¶37-38. PO’s argument that the disclosed access
`
`only “describes action taken by the verifier” (CMTA Reply at 4-5) is wrong
`
`4
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`because paragraph 39 says nothing about financial access granted to the verifier.
`
`PO’s argument that the combination of Schutzer with the ’585 reference
`
`“would lead to [a] … nonsensical result” (CMTA Reply at 6-8) wrongly focuses on
`
`a single embodiment of Schutzer and mischaracterizes Petitioner’s combination.
`
`While PO cites only to description of Figures 1-2 of Schutzer (involving user pre-
`
`authorization to provide an anonymous card number, id. (citing Ex-1130, Schutzer,
`
`¶¶26, 28, 29)), the CMTA Opposition also cited an embodiment in which “a
`
`transaction card is used to authenticate a user and authorize a transaction.” CMTA
`
`Opp. at 5 (citing Ex-1130, Schutzer, Figs. 3-4). For example, a cardholder can use
`
`an “alternate card number ... generated at a point-of sale for a bankcard
`
`transaction,” which is forwarded to the card issuer for “authentication and
`
`approval.” Ex-1130, Schutzer, ¶¶34, 37; see also id. at ¶¶30-33, Figs. 3-4
`
`(describing similar online transaction, rather than at point of service).
`
`Furthermore, even if PO were correct that Schutzer only discloses pre-
`
`authorization, it would be obvious to use the code of the ’585 reference during
`
`such pre-authorization (CMTA Opp. at 6-7)—not after as PO suggests (CMTA
`
`Reply at 7-8). Authorizing a user before sending the user an anonymous card
`
`number and later using that number are part of enabling the same transaction.
`
`CMTA Opp. at 5. Thus, combining the ’585 reference and Schutzer would result
`
`in conducting and enabling financial transactions, as claims 36 and 45 require.
`
`5
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`D. The Prior Art Discloses All Three Of The “One-time Code,”
`“First Authentication Information,” And “Digital Signature”
`Required By Substitute Claims 36 And 45.
`Petitioner’s CMTA Opposition and Petition clearly identified each
`
`constituent of the first wireless signal in the prior art, rendering claims 36 and 45
`
`obvious. PO’s arguments to the contrary all fail.
`
`Petitioner showed that the claimed one-time code corresponds to values in
`
`the ’585 reference, such as the dynamic value (T). CMTA Opp. at 10 (citing, e.g.,
`
`paragraphs 63 and 66 describing dynamic value (T)), 14 (describing combination
`
`of K, T, and E). Petitioner further showed that these values are “combined with
`
`other information … to generate an authentication code”—not that the claimed
`
`one-time code corresponds to the entire authentication code itself, as PO
`
`mischaracterizes Petitioner’s argument. Compare CMTA Opp. at 10-11 with PO’s
`
`CMTA Reply at 14-15. PO does not dispute that the dynamic value (T), or a code
`
`including (T), satisfies the claimed “one-time code.”
`
`Petitioner does not “double-count” the authentication code of the ’585
`
`reference, as PO suggests (CMTA Reply at 9), because Petitioner pointed to
`
`separate constituents of an authentication code, including intermediate
`
`authentication codes. Petitioner has consistently shown that the portion of the
`
`authentication code based on the user data (P) satisfies the claimed “first
`
`authentication information.” See Pet. at 32 (“Jakobsson discloses that the user
`
`6
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`authentication device 120 derives the authentication code 290 [first authentication
`
`information] from User Data (P) [first biometric information].”); CMTA Opp. at
`
`11-12 (citing Petition), 13 (citing User Data (P) as part of authentication code); Ex-
`
`1119, Shoup-Decl., 34, 38, 44. The ’585 reference discloses combining user data
`
`(P) (e.g., biometric information) with other values (e.g., event state (E)) to form an
`
`authentication code, which can further be combined with other values to arrive at
`
`additional authentication codes. Ex-1104, ’585 Reference, ¶¶73-77, Fig. 2.
`
`PO is also incorrect that Petitioner only addressed combining a “one-time
`
`code” and “digital signature.” The CMTA Opposition showed that the three fields
`
`of the “first wireless signal” are met by the obvious combination of an
`
`authentication code (based on user data (P)) with a one-time code (dynamic value
`
`(T) of’585 reference) and Schutzer’s digital signature. CMTA Opp. at 11.
`
`Petitioner demonstrated an obvious “combination of prior art elements (one-time
`
`code, authentication code, and digital signature)” by “prepending or appending the
`
`one-time code and digital signature to the authentication code or including them
`
`therewith as other authentication information.” CMTA Opp. at 10-11.
`
`E.
`
`The ’585 Reference’s Prepending/Appending Produces
`“Separable Fields” As Substitute Claims 42 And 45 Require.
`The ’585 reference discloses different combination functions, including pre-
`
`pending or appending constituent codes and values to produce a signal with
`
`separable fields, and therefore renders obvious substitute claim 42 and 45. CMTA
`
`7
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Opp. at 10-14. PO does not dispute that prepended or appended values would
`
`result in separable fields, as claims 42 and 45 require. Instead, PO incorrectly
`
`argues that prepending/appending codes with the combination function of the ’585
`
`reference would not have been obvious. CMTA Reply at 15-18.
`
`Indeed, contrary to PO’s argument that Petitioner only addressed two fields,
`
`Petitioner showed it would be obvious to “append the one-time code and digital
`
`signature … as [an] addition[]” to the authentication code of the ’585 reference.
`
`CMTA Opp. at 14.
`
`PO is also mistaken that the ’585 reference requires a one-way function.
`
`CMTA Reply at 16-17. While a “one-way function” is one that cannot be reversed
`
`to reconstruct the inputs from the output, the ’585 reference expressly discloses
`
`embodiments in which “[t]he verifier 105 reverses the combination operation.”
`
`Ex-1104, ’585 Reference, ¶¶71, 58. Were the combination function always one-
`
`way as PO suggests, the verifier could never reverse it. PO cites nothing in the
`
`’585 reference that requires a one-way function in all embodiments, and instead
`
`relies only on the say-so of its expert. See CMTA Reply at 16-17; Ex-2113,
`
`Jakobsson-Decl., ¶53. Indeed, the ’585 reference lists one-way functions as one of
`
`many types of combination functions. Ex-1104, ’585 Reference, ¶72 (“using a
`
`block cipher or other one-way function, or other algorithm, or a combination of
`
`these and other techniques. . ..”); see also Ex-1120, Juels-Decl., ¶¶33, 35, 39-43.
`
`8
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`Furthermore, PO overlooks examples of reversible combination functions,
`
`and instead mischaracterizes Dr. Juels in suggesting he admitted prepending or
`
`appending values are “inadequate way[s] to generate or protect the authentication
`
`code.” CMTA Reply at 17. To the contrary, he explained that an eavesdropper
`
`can recover inputs only where the eavesdropper has enhanced knowledge and/or
`
`access. Ex-2114, Juels-Dep., 30:3-21, 34:12-36:12, 40:14-41:6.
`
`F.
`
`PO Does Not Overcome Petitioner’s Showing That The KEK
`Architecture In Substitute Claim 56 Is Obvious.
`Burnett teaches a well-known KEK architecture, and it would have been
`
`obvious to modify authentication information by encrypting it with a session key
`
`[first key], encrypting the session key with a KEK [second key], and transmitting
`
`the KEK-encrypted session key and the session key encrypted authentication
`
`information to the second device for decryption. CMTA Opp. at 16-18. PO’s only
`
`response is to suggest that the KEKs in Burnett are not shared. CMTA Reply at
`
`19-20. That is wrong. Burnett states that two parties (“Michelle” and “Pao-Chi”)
`
`share the same KEK. Ex-1121, Burnett, 85 (“Michelle ... encrypts the new session
`
`key using the KEK she shares with him...”). When Michelle wants to share a
`
`session key with Pao-Chi, she encrypts it with the shared KEK, just as the claimed
`
`first key encrypted by a second key that is sent to the second device. Id. Similarly,
`
`for password-based encryption (“PBE”), Burnett teaches passwords can be shared
`
`between parties so that each party can generate the same KEK [second key] using
`
`9
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`PBE to encrypt/decrypt a session key [first key]. Id. at 83. Burnett discloses other
`
`embodiments in which other symmetric keys, like a the claimed KEK, are shared
`
`between parties. Id. PO makes no reference to these embodiments that disclose
`
`sharing KEKs, either using PBE or otherwise. That is not surprising, because PO’s
`
`expert admitted he only reviewed limited parts of Burnett, and could not recall ever
`
`having reviewed the pages cited above. Ex-1132, Jakobsson Dep., 589:16-591:13.
`
`G. The CMTA Opposition Explicitly Showed The Unpatentability Of
`Substitute Claim 45.
`PO’s arguments that substitute claim 45, which requires decrypting a digital
`
`signature by the second device and a signal having separable fields, is not obvious
`
`over the cited references are incorrect for at least three reasons.
`
`First, PO’s argument that the CMTA Opposition failed to show the claimed
`
`decryption (CMTA Reply at 13) disregards the analysis that Petitioner presented
`
`with regard to claim 36 that Petitioner’s claim 45 analysis incorporates, which
`
`explicitly addressed encrypting with first device and decrypting with second
`
`device. See CMTA Opp. at 7-8 (discussing decrypting authentication
`
`information); Ex-1119, Shoup-Decl., ¶¶38-39. Furthermore, Dr. Shoup’s
`
`declaration showed that the combination function can be reversed by a verifier by
`
`decrypting with a user’s public key. Ex-1119, Shoup-Decl., ¶¶38-39.
`
`Second, PO’s argument that the CMTA Opposition failed to show the
`
`claimed separable fields (CMTA Reply at 13-14) overlooks the ’585 reference’s
`
`10
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`combination function Petitioner relied on for claim 36, which was incorporated
`
`into the analysis for claim 45. CMTA Opp. at 12. Petitioner identified the
`
`disclosed appending/prepending or inclusion as additions to an authentication
`
`code, which would result in “separable fields.” CMTA Opp. at 10-11, 14.
`
`Third, PO’s argument that Petitioner failed to address “the one-time code
`
`encrypted by the first … device” and associated decryption by the second device
`
`(CMTA Reply at 14) disregards that these limitations are expressly optional. See
`
`Limitation 45[e] (“at least one of the digital signature and/or the one-time code. .
`
`.”), 45[g] (same). Petitioner’s showing that the cited references render obvious
`
`encrypting/decrypting a digital signature for claim 36 is sufficient to show that
`
`claim 45 is unpatentable. See CMTA Opp. at 7-12, Ex-1119, Shoup-Decl., ¶52.
`
`H.
`
`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
`
`identity based on codes and/or information related to the account holder before
`
`enabling a transaction without adding an inventive concept. CMTA Opp. at 19-24;
`
`Ex-1119, Shoup-Decl. ¶¶70-75. PO’s asserted “technological improvements,”
`
`such as “local and remote authentication,” are all abstract concepts that could be
`
`implemented using a pen and paper or as a mental process. CMTA Reply, 23-24.
`
`That the claims implement these abstract concepts with a generic “first device” and
`
`11
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`“second device,” or in a particular order, does not render them less abstract. See,
`
`e.g., CMTA Opp. at 22-24. PO’s Reply fails to identify a single Supreme Court or
`
`Federal Circuit case in which analogous claims were found patent eligible.
`
`I.
`Patent Owner Has Not Satisfied Its Duty Of Candor.
`PO’s argument that it complied with its duty of candor because its CMTA
`
`preceded Lectrosonics is incorrect. Western Digital Corp. v. SPEX Techs., Inc.,
`
`IPR2018-00082, -00084, Paper 13 (PTAB April 25, 2018) and 37 C.F.R. § 42.11,
`
`which preceded Lectrosonics, imposed the same duty to disclose Schutzer with its
`
`CMTA. PO’s other argument that it “objectively believed that Schutzer was not
`
`materially relevant” (CMTA Reply at 25) disregards that PO’s duty of candor
`
`extends to information relevant to only a single added limitation, “even if it does
`
`not include the rest of the claim limitations.” Lectrosonics, at 9-10. PO’s
`
`argument that the Board would otherwise be inundated with references also lacks
`
`merit—if PO considers adding a digital signature to a system for authenticating
`
`users to confer patentability, then PO has a duty to disclose references material to
`
`digital signatures. Patent owners face similar disclosure requirements during
`
`examination, and the Board should find no exception here.
`
`III. CONCLUSION
`Based on the foregoing, PO fails to rebut Petitioner’s showing that the
`
`substitute claims are unpatentable.
`
`12
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`June 10, 2019
`
`
`
`Respectfully Submitted,
`
`/Monica Grewal/
`
`Monica Grewal
`Registration No. 40,056
`
`
`
`
`
`13
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`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`TABLE OF EXHIBITS
`
`Exhibit Number
`1101
`
`Description
`
`U.S. Patent No. 9,100,826
`
`1102
`
`1103
`
`1104
`
`1105
`
`1106
`
`1107
`
`1108
`
`1109
`
`1110
`
`1111
`
`1112
`
`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
`
`International Patent Application Publication No. WO
`2004/051585 (“Jakobsson”)
`
`U.S. Patent Application Publication No. 2004/0236632
`(“Maritzen”)
`
`U.S. Patent No. 5,280,527 (“Gullman”)
`
`International Patent Application Publication No. WO
`2005/001751 (“Verbauwhede”)
`
`’826 Patent File History, 03/18/2015 Notice of
`Allowance and Fees Due (“Notice of Allowance”)
`
`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 (“Opp.”)
`
`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
`
`14
`
`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`U.S. Provisional Application No. 60/812,279
`1113
`
`1114
`
`1115
`
`1116
`
`1117
`
`1118
`
`1119
`
`1120
`
`1121
`
`1122
`
`1123
`
`1124
`
`1125
`
`1126
`
`1127
`
`1128
`
`1129
`
`1130
`
`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
`
`Declaration of Dr. Ari Juels
`
`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)
`
`[Reserved]
`
`[Reserved]
`
`[Reserved]
`
`[Reserved]
`
`[Reserved]
`
`European Patent Application Publication No. EP
`
`15
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`

`

`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`1028401 (“Schutzer”)
`
`1131
`
`1132
`
`Merriam-Webster Definition of “Disable”
`
`Dr. Jakobsson Deposition Transcript
`
`
`
`
`
`
`
`16
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`

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`U.S. Patent No. 9,100,826
`Petitioner’s Sur-Reply To PO’s Reply To The Opposition To The CMTA
`CERTIFICATE OF SERVICE
`
`I hereby certify that on June 10, 2019, I caused a true and correct copy of
`
`
`
`the foregoing materials:
`
`• Petitioner’s Sur-Reply to Patent Owner’s Reply to the CMTA Opposition
`• Table of Exhibits
`• Exhibit 1132
`
`to be served via electronic mail on the following correspondents of record as listed
`
`in Patent Owners’ Mandatory Notices and Paper 33:
`
`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:
`(IPR2019-00176):
`Matthew Argenti (margenti@wsgr.com)
`Michael Rosato (mrosato@wsgr.com)
`WILSON SONSINI GOODRICH & ROSATI
`Respectfully Submitted,
`
`
`/Monica Grewal/
`Monica Grewal
`Registration No. 40,056
`
`Date: June 10, 2019
`
`17
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`