`Filed: October 11, 2019
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`
`
`
`
`Filed on behalf of: Visa Inc. and Visa USA Inc.
`By: Matthew A. Argenti
`
`Michael T. Rosato
`WILSON SONSINI GOODRICH & ROSATI
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`VISA INC. and VISA U.S.A. INC.,
`APPLE INC.,
`Petitioners,
`
`v.
`
`UNIVERSAL SECURE REGISTRY LLC,
`Patent Owner.
`_____________________________
`
`Case No. IPR2018-013501
`Patent No. 8,856,539
`_____________________________
`
`
`PETITIONERS’ SURREPLY TO PATENT OWNER’S
`CONDITIONAL MOTION TO AMEND
`
`
`
`1 Apple Inc., which filed a petition in IPR2019-00727, has been joined as a
`party to this proceeding.
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`USR EXHIBIT 2013
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`TABLE OF CONTENTS
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`Page
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`I.
`II.
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`III.
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`iii.
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`PO PROPOSES AN UNREASONABLE NUMBER OF CLAIMS ................ 1
`PO IMPROPERLY REINTRODUCES DISCLAIMED SUBJECT
`MATTER TO AMEND SUBSTITUTE CLAIM 52 ........................................ 1
`PO’S PROPOSED SUBSTITUTE CLAIMS LACK WRITTEN
`DESCRIPTION SUPPORT ............................................................................. 2
`A.
`Limitations 39[c], 48[a], 51[d], and 52[pre]: The specification
`both fails to disclose and is inconsistent with a lack of
`communication between the secure registry and the entity .................. 2
`i.
`PO’s citations do not disclose a lack of communications........... 2
`ii.
`Limitations 39[c], 48[a], and 52[pre] are not limited to
`“the transaction process” ............................................................. 3
`The specification’s biometric verification is a
`communication ............................................................................ 4
`Limitations 46[b] and 52[c] plainly require biometric
`verification prior to receipt of the transaction request, which is
`undisclosed ............................................................................................ 5
`PO’s citations do not support limitations 40[b] and 46[d] .................... 5
`Limitation 51[b] lacks written description support for multiple
`entities.................................................................................................... 6
`IV. THE SUBSTITUTE CLAIMS ARE OBVIOUS ............................................. 6
`A.
`PO’s arguments that Brener does not disclose limitations 39[c],
`48[a], 51[d], and 52[pre] are inconsistent with its written
`description arguments ........................................................................... 6
`Desai and Pare teach limitations 39[e] and 47[b] ................................. 8
`Brener and Schneier disclose limitations 40[b] and 46[c][d] ............... 9
`Brener discloses a “Public ID Code” (limitation 52[f][g]) ................. 11
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`B.
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`C.
`D.
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`B.
`C.
`D.
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`V.
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`THE SUBSTITUTE CLAIMS DO NOT RECITE PATENT-
`ELIGIBLE SUBJECT MATTER .................................................................. 12
`VI. THE PROPOSED SUBSTITUTE CLAIMS ARE INDEFINITE ................. 12
`VII. CONCLUSION .............................................................................................. 12
`VIII. APPENDIX – LIST OF EXHIBITS .............................................................. 14
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`I.
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`PO PROPOSES AN UNREASONABLE NUMBER OF CLAIMS
`PO does not dispute that for claims 1-3, 16, 21-24, and 38, PO has proposed
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`at least two substitute claims in proceedings before the Board. Yet the rule
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`presumes “that only one substitute claim would be needed to replace each
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`challenged claim.” 37 C.F.R. § 42.121(a)(3) (emphasis added). The plain
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`language of the presumption is not limited to a single motion or proceeding.
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`PO’s refusal to show whether its substitute claims are patentably distinct
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`from the substitute claims pending in IPR2018-00812 does nothing to address the
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`conundrum created by two competing motions to amend. If PO wanted to avoid
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`the dilemma of multiple amendments, it could have requested consolidation or
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`proposed the same amendments in both IPRs. It is not in the public interest to
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`grant amendments in one proceeding that potentially would not survive the other.
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`II.
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`PO IMPROPERLY REINTRODUCES DISCLAIMED SUBJECT
`MATTER TO AMEND SUBSTITUTE CLAIM 52
`PO’s argument that claim 52’s scope is “entirely different than disclaimed
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`claims” is conclusory and unexplained. Reply 2-3. Disclaimed claims 5 and 7
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`recite “credit card account information” and “bank account information,”
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`respectively. Thus, each has overlapping scope with the substitute claim’s “public
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`ID number that identifies a financial account number.”
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`PO also misses the point with respect to its disclaimer of a nearly identical
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`“public ID code” limitation in the ’137 patent. Both patents have the same
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`inventor and are directed to very similar subject matter. PO disclaimed a “public
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`ID code” limitation to avoid a CBM challenge yet now seeks an end-run around
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`the AIA’s challenges by introducing equivalent subject matter. The Board should
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`find PO is estopped from engaging in such gamesmanship and lack of candor.
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`III. PO’S PROPOSED SUBSTITUTE CLAIMS LACK WRITTEN
`DESCRIPTION SUPPORT
`A. Limitations 39[c], 48[a], 51[d], and 52[pre]: The specification both
`fails to disclose and is inconsistent with a lack of communication
`between the secure registry and the entity
`i. PO’s citations do not disclose a lack of communications
`PO cites to ’729 Application 17:27-18:1 and Figure 8 as describing an
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`embodiment with “no communications between the secure registry and the entity
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`during the transaction process.” Reply 4. First, PO recognizes that a user
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`“presents the resultant code to the merchant,” and the merchant sends that code to
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`the secure registry. Reply 4. PO provides no reason to narrowly construe
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`“communications” to exclude communications that pass through an intermediary.
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`Second, PO does not point to any positive disclosure of the claimed lack of
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`communications during the transaction process. Because the specification is silent,
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`it fails to allow a POSITA “to recognize the inventor invented what is claimed.”
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`Q.I. Press Controls, BV v. Lee, 752 F.3d 1371, 1380-81 (Fed. Cir. 2014) (negative
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`limitation not supported by specification that lacks a positive disclosure); Ex Parte
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`Nam Khong Then, Appeal 2018-006067, 2019 WL 2244822 at *2 (P.T.A.B. May
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`8, 2019) (“[T]he Specification lacks affirmative disclosure of the recited negative
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`limitation.”); c.f. Santarus, Inc. v. Par Pharmaceutical, Inc., 694 F.3d 1344, 1351
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`(Fed. Cir. 2012) (“Negative claim limitations are adequately supported when the
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`specification describes a reason to exclude the relevant limitation.”).
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`Third, with respect to claims 39 and 48 PO argues that “communicating
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`with” implies a one-way communication. Reply 4-5. But this contradicts the ’539
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`patent itself, which describes a communication from a USR database “providing an
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`appropriate code” as a “communication … with the database.” Ex-2008, 10:25-30.
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`The lack of supporting disclosure alone is enough to reject the amendments.
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`But the specification also provides multiple examples of communications between
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`the secure registry and entity. As discussed below, PO’s arguments that these
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`communications fall outside the claim exclusions are incorrect.
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`ii. Limitations 39[c], 48[a], and 52[pre] are not limited to “the
`transaction process”
`PO does not dispute that the “training process” is a communication between
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`the secure registry and the entity. Opp. 4. Instead, PO argues that such
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`communications are not within the scope of negative limitations 39[c], 48[c], and
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`52[pre] because they occur “before a transaction is initiated and a provider makes a
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`request to access secure data.” Reply 5; see also Reply 4 (“no communications …
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`during the transaction process.”). But the limitations simply refer to a lack of
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`communication prior to receiving a transaction request. It is irrelevant if the
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`training process occurs before PO’s artificial delineation of a “transaction process,”
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`a term only found in claim 51. The training process occurs before “the transaction
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`request is received,” and therefore supports a lack of written description.
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`PO’s citation to claim 51 undermines its argument. Claim 51 states the
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`request is received “during a transaction process initiated after completion of the
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`training process and termination of communications between the secure registry
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`and the entity.” CMTA A4. PO knew how to distinguish the training process from
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`the excluded communication. Claims 39, 48, and 52 make no such distinction.
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`iii. The specification’s biometric verification is a
`communication
`The specification describes additional communication between the entity
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`and the secure registry in the form of biometric verification. Opp. 5. In response,
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`PO argues the substitute claims are broad enough to encompass several
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`hypotheticals that appear nowhere in the specification. For example, PO concedes
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`the specification describes storing biometric information in the USR database but
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`argues the claims do not require such storage. Reply 6. PO also asserts biometric
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`verification could occur without communication or at another time. Reply 6-8.
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`Arguing the claims should be broadly interpreted to cover undisclosed
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`embodiments in no way solves PO’s written description dilemma.
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`Moreover, none of these arguments addresses the fact that the biometric
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`verification in the specification is communication between the secure registry and
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`entity. PO cites to verification done at the point of use, but PO does not address
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`how verification can take place without the user communicating the necessary
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`biometric information. See Reply 6-7 (citing Ex-2008, 5:16-17).
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`B.
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`Limitations 46[b] and 52[c] plainly require biometric verification
`prior to receipt of the transaction request, which is undisclosed
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`PO argues that the terms “having been” and “having had” do not
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`“necessarily … require that biometric verification of the user take place before the
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`transaction request is received.” Reply 8. PO’s argument is baseless. Claim 46
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`recites “receiving from the provider a transaction request … for an entity …, an
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`identity of the entity … having been verified using a biometric.” CMTA A3
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`(emphasis added); see also id., A5 (claim 52). The plain language facially requires
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`the verification to occur before receipt of the request or code. PO does not dispute
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`that this timing requirement lacks written description support.
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`C.
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`PO’s citations do not support limitations 40[b] and 46[d]
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`Limitations 40[b] and 46[d] require use of a “time value representative of
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`when the time-varying multicharacter code was generated.” CMTA A2, A3. But
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`PO’s citations to the ’729 Application refer to “the time the number was
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`received” and “the time of receipt of the code.” Reply 9 (emphasis added by PO).
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`Plainly, the time of generation and the time of receipt are different things.
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`Also, rather than identify relevant disclosure for the “mapping” requirement,
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`PO argues the time value is used to determine the validity of the code. Id. at 9-10.
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`But PO does not address Petitioner’s argument and evidence that determining
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`validity is not the same as the recited mapping to the identity of the entity. Opp. 7.
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`D. Limitation 51[b] lacks written description support for multiple
`entities
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`Limitation 51[b] requires “a training process by establishing
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`communications between the secure registry system and the entities.” CMTA A4.
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`PO cites support for a training process “for a single entity” but does not identify
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`support for a training process involving multiple entities. Reply 10.
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`IV. THE SUBSTITUTE CLAIMS ARE OBVIOUS
`A.
`PO’s arguments that Brener does not disclose limitations 39[c],
`48[a], 51[d], and 52[pre] are inconsistent with its written
`description arguments
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`PO argues Brener does not disclose limitations 39[c], 48[a], 51[d], and
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`52[pre] because “the customer computer 100 must first login and connect to the
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`secure provider 110 to … initiate purchase transactions.” Reply 11. Yet PO’s
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`argument cannot be reconciled with its written description position. In addition,
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`PO’s arguments mischaracterize Brener and are undermined by PO’s own expert.
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`If the priority applications support the claimed lack of communication
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`between the entity and secure registry, Brener does as well. Opp. 9-10. PO does
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`nothing to refute this, since PO takes inconsistent positions to both argue written
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`description support and overcome prior art disclosure. PO argues communications
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`before “a provider makes a request to access secure data” are irrelevant to written
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`description (Reply 5). By contrast, PO argues Brener’s description of a customer’s
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`pre-transaction login and connection process fails to disclose the claimed lack of
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`communication. Reply 12-13. PO cannot have it both ways. PO does not explain
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`why Brener’s login procedure is a communication excluded by the claims, but the
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`’729 Application training procedure is not.
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`Further, PO’s argument that Brener’s customer computer and secure
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`provider “maintain communications” prohibited by the claims fails for at least two
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`reasons. First, the only such communication PO identifies is the customer’s use of
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`the secure connection to “access the vendor computers 140 and carry out purchase
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`transactions.” Reply 13. But PO’s expert admitted this would be a communication
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`with the vendor, not the secure provider. Ex-1023, 22:20-23:23 (testifying that a
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`communication is “with” the “party you’re addressing it to when the message is
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`just being transmitted” and that “proxies along the line were not communicated
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`with because they are not the intended recipient”); 50:14-24 (admitting Brener’s
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`customer computer is “always using the secure computer as a proxy”).
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`Second, even if the customer’s initial purchase request was deemed a
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`communication with the secure provider, it is not excluded by the claims because it
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`occurs before the vendor sends a transaction request to the secure provider. That
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`is, the customer sends a purchase request through the secure provider to the
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`vendor, and the vendor subsequently transmits a transaction request to the secure
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`provider. PO identifies no communication from the user to the secure provider
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`taking place at the time the vendor sends the transaction request. Reply. 11-15.
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`The mere fact that the user and secure computer are connected to allow for
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`communication does not demonstrate that a communication is actually taking place
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`at the specific time PO argues the claim limitation is directed to. See Ex-1023,
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`44:2-23 (communication taking place before transaction request is received is “not
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`part of the process described in the claim”); 53:12-54:9 (Brener’s VPN “enables
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`communication” but that “doesn’t necessitate” sending messages). Like the ’539
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`patent, Brener is silent on the communications between customer and secure
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`provider once a transaction is initiated. If PO is correct that such silence provides
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`written support, then Brener’s silence likewise discloses the limitations.
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`PO also argues Petitioner’s reliance on Desai is flawed for failure to explain
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`how Brener would be modified to eliminate the VPN connection between the
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`customer computer and the secure provider. Reply 15. But Petitioner never
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`proposed modifying Brener to remove its VPN functionality, because the VPN
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`connection does not constitute an excluded communication.
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`B. Desai and Pare teach limitations 39[e] and 47[b]
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`PO does not dispute that Desai teaches validating users such as merchants.
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`Reply 16-18; see also Opp. 10. Instead, PO argues Desai does not need to validate
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`the merchant’s identity prior to executing a restriction mechanism because
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`“possession of the correct private key … confirms that the correct party is
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`accessing the data.” Reply 18. But limitations 39[e] and 47[b] are not limited to
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`validating a provider in order to cause execution of a restriction mechanism. Thus,
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`Desai’s disclosure of merchant validation teaches the limitations.
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`Nevertheless, PO is wrong that Desai’s merchant validation is unrelated to
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`its data access restrictions. Desai teaches treating registered and unregistered
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`members differently when determining access rights. See, e.g., Ex-1007, 27:36-
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`28:17, Figs. 41-42. This includes an embodiment where the system determines
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`(i.e., validates) whether a user like a merchant is registered before executing a
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`restriction mechanism. Id., 27:54-28:17, Fig. 42 (step 4304: “Is user a member?”).
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`If the user is not registered, the user may “be required to go through the sign-up
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`process.” Id., 27:64-65. This sign-up process involves “enter[ing] a universal
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`identification code, which may be called a ZKEY [which is] used as the universal
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`identification code to uniquely identify the new member.” Id., 21:15-18.
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`PO also argues Petitioner failed to provide a motivation to combine Pare
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`with other references. Reply 18. But no additional motivation is needed.
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`Petitioner cited Pare to show it is consistent with Desai, and Petitioner provided a
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`reason to incorporate validation into the combination. Opp. 10, 17 (explaining
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`merchant validation was optimal way of incorporating granular access controls).
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`C. Brener and Schneier disclose limitations 40[b] and 46[c][d]
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`PO fails to address Schneier’s teachings or Petitioner’s proffered motivation
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`to combine Brener and Schneier. Opp. 13-14. Instead, PO misrepresents the
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`teachings of Brener. First, PO argues Brener 13:6-10 only discloses a customer
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`object containing a digital signature sent to the bank, not the secure provider.
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`Reply 19-20. Yet Brener also discloses that the vendor can send the customer
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`object to the secure provider. Ex-1005, 2:19-3:11. PO does not explain why these
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`two teachings are “not directly attributable to one another.” Reply 19.
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`Second, PO’s reliance on 16:14-26 as supporting PO’s interpretation of 13:6-
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`10 is misplaced. See id. at 20. Whereas in 13:6-10 Brener states that the customer
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`object includes a digital signature, in 16:14-26 Brener describes the bank obtaining
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`a digital signature subsequent to receipt of the customer object.
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`Third, PO’s rebuttal argument focuses entirely on payment approval by a
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`bank and fails to address the anonymous shipping disclosure of Brener cited in the
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`Opposition. See, e.g., Opp. 13 (citing Ex-1005, 2:19-3:7, 10:14-17).
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`Fourth, PO argues sending the digital signature to the secure provider is
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`“unnecessary” because “the secure provider 110 already has authenticated the
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`identity of the customer using the certificate upon login.” Reply 20-21. PO’s
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`argument makes little sense. A customer being logged into the secure provider
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`does not authenticate a customer object received from a vendor, especially as there
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`may be multiple customers logged in. If the secure provider could ascertain the
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`identity of a customer from a transaction request merely because the customer is
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`logged-in, Brener’s entire customer object linking scheme would be unnecessary.
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`See, e.g., Ex-1005, 16:1-6 (describing confirming “the identity of the purchaser”);
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`see also id., 8:3-20 (“[T]he linking information can be stored in the database 170
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`of bank computer 150 so that only the bank, and not the secure provider, actually
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`knows the true identity and address of the customer.”) (emphasis added).
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`Thus, Brener discloses that a customer object, which can contain a digital
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`signature, is sent to the secure provider. PO does not dispute that a POSITA would
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`be motivated in view of Schneier to include a timestamp in such a signature, or that
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`this would satisfy the claim limitations.
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`D. Brener discloses a “Public ID Code” (limitation 52[f][g])
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`PO argues it is improper to use Brener’s linking information for both the
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`claimed “mapping … to an identity of the entity” and the claimed “public ID
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`code.” Reply 21-22. But PO does not explain why the linking information cannot
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`be used for both purposes. Brener makes clear that the linking information maps to
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`both customer information and financial information, and can be used by both the
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`secure provider and bank. See, e.g., Ex-1005, 8:9-14 (“The linking information is
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`stored … in … secure provider computer 110 [and] matches up each customer
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`object with the customer’s personal information [such as name and address].”);
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`9:24-26 (“[T]he linking information … link[s] the customer object with …
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`customer account information.”); 10:28-11:2; 14:16-22.
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`V. THE SUBSTITUTE CLAIMS DO NOT RECITE PATENT-ELIGIBLE
`SUBJECT MATTER
`Petitioner improperly incorporates by reference a magistrate judge’s report
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`and recommendation—not yet adopted by the district court—that analyzes
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`different claims on a different record. Reply 25; see 37 C.F.R. § 42.6(a)(3). PO’s
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`remaining arguments are conclusory and do not rebut Petitioner’s undisputed
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`evidence, analysis, or cited law. See Opp. 21-24. PO did not depose Dr. Tygar on
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`Ex-1021, nor does PO’s expert address subject matter eligibility in Ex-2011.
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`VI. THE PROPOSED SUBSTITUTE CLAIMS ARE INDEFINITE
`PO’s arguments do not reconcile the contradiction Petitioner identified for
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`claims 39, 46, 51, and 52. See Opp. 24-25. Instead, PO provides examples where
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`the provided information is “a transaction result.” Reply 25. Yet these claims
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`require this information “to enable transactions.” CMTA A1. PO does not explain
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`how a transaction result could be used to enable that transaction.
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`PO also does not dispute limitations 46[b] and 52[c] do not specify “what
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`location the biometrics are verified at” or who performs the verification. Reply 25.
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`PO’s expert’s claim that “such breadth does not render the claims indefinite” is
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`conclusory. Ex-2011, ¶54. Accordingly, the limitations are indefinite.
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`VII. CONCLUSION
`PO’s Contingent Motion to Amend should be denied.
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`Dated: October 11, 2019
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`Respectfully submitted,
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`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
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`VIII. APPENDIX – LIST OF EXHIBITS
`
`Description
`Exhibit No.
`1001
` U.S. Patent No. 8,856,539 to Weiss
`
`1002
`
` Declaration of Justin Douglas Tygar, PhD.
`
`1003
`
`
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`Curriculum Vitae of Justin Douglas Tygar
`
`1004
`
`1005
`
`1006
`
`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`1013
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`1014
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`1015
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`File History for U.S. Patent No. 8,856,539
`
`
` WO 00/14648 to Brener
` U.S. Patent No. 4,885,778 to Weiss
` U.S. Patent No. 6,820,204 to Desai et al.
` WO 01/13275 to Junda et al.
` U.S. Patent Publication No. 2001/0029485 to Brody et al.
` U.S. Provisional Patent Application No. 60/186,166
` Dynamic, Random House Webster’s Unabridged Dictionary,
`Second Edition, 2001
` Dynamic, The American Heritage Dictionary of the English
`Language, Third Edition, 1996
` Dynamic, Academic Press Dictionary of Science and Technology,
`1992
`
`
`
`
`
`Plaintiff’s Answering Brief in Opposition to Defendant’s Motion
`to Dismiss Plaintiff’s Complaint, Case 1:17-cv-00585-JFB,
`September 29, 2017
`
`Transcript of Deposition of Bjorn Markus Jakobsson, Ph.D.,
`August 1, 2019
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`Exhibit No.
`1016
`
`
`Description
`
`Bruce Schneier, Applied Cryptography, Second Edition:
`Protocols, Algorithms, and Source Code in C, John Wiley &
`Sons, Inc., 1996
`
`1017
`
`
`
`Stuart E. Weiner, “Electronic Payments in the U.S. Economy: An
`Overview,” Federal Reserve Bank of Kansas City, Economic
`Review Fourth Quarter, 1999 (available from www.kc.frb.org)
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
` Matthew Humphries, “Use Apple Pay, Get McDonald’s Fries for
`Free,” PCMag, April 19, 2018
`(https://www.pcmag.com/news/360532/use-apple-pay-get-
`mcdonalds-fries-for-free)
`
`
`
`
`
`
`
`Juli Clover, “Apple Launches New Summertime Savings Apple
`Pay Promotion,” MacRumors.com, July 19, 2018
`(https://www.macrumors.com/2018/07/19/apple-pay-
`summertime-savings-promotion/)
`
`“Payments Volume Growth Boosts Visa’s 2018 Earnings; Key
`Initiatives to Drive Future Value,” Frobes, October 29, 2018
`(https://www.forbes.com/sites/greatspeculations/2018/10/29/pa
`yments-volume-growth-boosts-visas-2018-earnings-key-
`initiatives-to-drive-future-value/#25fabaeb6585)
`
`Second Declaration of Justin Douglas Tygar, Ph.D.
`
` WO 98/04996 to Pare
`
`1023
`
`
`
`Transcript of Deposition of Bjorn Markus Jakobsson, Ph.D.,
`October 1, 2019
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`
`
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing Petitioners’ Surreply to Patent Owner’s
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`Conditional Motion to Amend and Exhibit 1023 were served on this 11th day of
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`October, 2019, on the Patent Owner at the correspondence address of the Patent
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`Owner as follows:
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`James M. Glass
`Tigran Guledjian
`Christopher A. Matthews
`Nima Hefazi
`Richard Lowry
`Razmig Messerian
`QUINN EMANUEL URQUHART & SULLIVAN LLP
`jimglass@quinnemanuel.com
`tigranguledjian@quinnemanuel.com
`chrismathews@quinnemanuel.com
`nimahefazi@quinnemanuel.com
`richardlowry@quinnemanuel.com
`razmesserian@quinnemanuel.com
`qe-usr-ipr@quinnemanueal.com
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`And on the remaining petitioners as follows:
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`Monica Grewal
`Benjamin Fernandez
`Mark Selwyn
`WILMER CUTLER PICKERING HALE AND DOOR LLP
`monica.grewal@wilmerhale.com
`ben.fernandez@wilmerhale.com
`mark.selwyn@wilmerhale.com
`wh-apple-usr-ipr@wilmerhale.com
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`Date: October 11, 2019
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`Respectfully submitted,
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`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
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`-17-
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