COMPLAINT for Patent Infringement filed with Jury Demand against PayPal
`Holdings, Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 400, receipt
`number 0311-2347547.) - filed by IOENGINE LLC. (Attachments: # 1 Exhibit A, #
`2 Exhibit B, # 3 Exhibit C, # 4 Civil Cover Sheet)(fms) (Entered: 03/26/2018)
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`Printed By:
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`RMCALLEN2 on Monday, August 27, 2018 - 6:57 PM
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 1 of 206
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`COMPLAINT for Patent Infringement filed with Jury Demand against PayPal Holdings,
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`Part
`1
`2
`3
`4
`5
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`Multiple Documents
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`Description
`100 pages
`Exhibit A
`Exhibit B
`Exhibit C
`Civil Cover Sheet
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`© 2018 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service
` // PAGE 1
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 2 of 206
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`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 1 of 100 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`IOENGINE, LLC,
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`Plaintiff,
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`v.
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`PAYPAL HOLDINGS, INC.,
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`Defendant.
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`C.A. No. _________
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`Jury Trial Demanded
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff IOENGINE, LLC (“Plaintiff” or “IOENGINE”), by and through its
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`undersigned counsel, alleges as follows:
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`THE PARTIES
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`IOENGINE is a limited liability company organized and existing under the laws
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`of the State of Delaware, with its principal place of business at 22 Ensign Road, Norwalk,
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`Connecticut 06853.
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`Defendant PayPal Holdings, Inc. (“Defendant” or “PayPal”) is a corporation
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`organized and existing under the laws of the State of Delaware, having a place of business at
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`2211 North First Street, San Jose, California, 95131.
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`Defendant’s registered agent in the State of Delaware is The Corporation Trust
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`Company, 1209 Orange Street, City of Wilmington, County of New Castle, 19801.
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 3 of 206
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`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 2 of 100 PageID #: 2
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`JURISDICTION AND VENUE
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`This is an action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. § 100 et seq., including, but not limited to, 35 U.S.C. § 271.
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`This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
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`§§ 1331 and 1338(a).
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`This Court has personal jurisdiction over PayPal. On information and belief,
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`Defendant is subject to this Court’s specific and general personal jurisdiction pursuant to due
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`process and the Delaware Long-Arm Statute, due to its (i) substantial business in this forum,
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`including at least a portion of the infringing acts alleged herein; (ii) incorporation in the forum;
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`and (iii) regularly doing or soliciting business, engaging in other persistent courses of conduct,
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`and deriving substantial revenue from infringing goods and services provided to individuals in
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`Delaware.
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`On information and belief, within this state, PayPal has offered for sale and sold,
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`and continues to offer for sale and sell, products and services embodying the patented
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`inventions, thereby committing, contributing to, and inducing, and continuing to commit,
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`contribute to, and induce, acts of patent infringement alleged herein. On information and belief,
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`PayPal maintains a regular and established place of business in this District, including through a
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`facility at 3505 Silverside Road, Wilmington, Delaware 19810. PayPal has committed such
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`purposeful acts and/or transactions in Delaware such that it reasonably should know and expect
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`that it could be haled into this Court as a consequence of such activity.
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`Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c), and 1400(b)
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`because, among other reasons, Defendant is incorporated in and resides in the State of Delaware
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`and because Defendant regularly transacts or solicits business in this District and has committed
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`at least a portion of the infringing acts at issue in this case from and within this District. On
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`2
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`PayPal Inc. v. IOENGINE, LLC
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`information and belief, Defendant has a regular and established place of business in this District
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`at 3505 Silverside Road, Wilmington, Delaware 19810. In addition, on information and belief,
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`Defendant employs a number of persons in this District and derives and has derived substantial
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`revenue from goods and services provided to persons or entities in this District and from
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`infringing acts occurring within this District.
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`Venue is additionally proper in this District because IOENGINE is incorporated
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`in the State of Delaware and because one of the patents-in-suit has twice been litigated and tried
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`to a jury verdict in this District.1
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`BACKGROUND
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`This dispute involves fundamental technology that allows portable electronic
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`devices, used in conjunction with terminals, to support enhanced functionality. For example,
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`the technology at issue allows users to interact with portable devices through a terminal’s
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`interactive user interface, using the terminal’s input and output components, while maintaining
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`a secure processing environment on the portable device to enable secure communications
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`between the portable device, the terminal, and a communications network. Further, the
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`technology at issue describes terminals and portable devices that execute program code in a
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`coordinated fashion, allowing for a convenient, secure way to conduct electronic transactions,
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`such as processing mobile credit card payments and refunds.
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`The technology at issue was invented by Mr. Scott McNulty, who also founded
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`IOENGINE.
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`
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`See IOENGINE, LLC v. Imation, Corp., no. 14-cv-1572 (D. Del.); IOENGINE, LLC v.
`1
`Interactive Media Corp. d/b/a Kanguru Solutions, no. 14-cv-1571 (D. Del.).
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`3
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 5 of 206
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`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 4 of 100 PageID #: 4
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`THE IOENGINE PATENTS-IN-SUIT
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`On September 17, 2013, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 8,539,047 (the “’047 Patent”), entitled “Apparatus,
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`Method and System for a Tunneling Client Access Point,” after full and fair examination. The
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`application that led to the ’047 Patent, U.S. Patent Application Ser. No. 12/950,321, was a
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`continuation of U.S. Patent Application Ser. No. 10/807,731, filed on March 23, 2004. A true
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`and correct copy of the ’047 Patent is attached hereto as Exhibit A.
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`On June 16, 2015, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 9,059,969 (the “’969 Patent”), entitled “Apparatus,
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`Method and System for a Tunneling Client Access Point” after full and fair examination. The
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`application that led to the ’969 Patent, U.S. Patent Application Ser. No. 13/960,514, was a
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`continuation of U.S. Patent Application Ser. No. 12/950,321, which was a continuation of U.S.
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`Patent Application Ser. No. 10/807,731, filed on March 23, 2004. A true and correct copy of
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`the ’969 Patent is attached hereto as Exhibit B.
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`On September 26, 2017, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 9,774,703 (the “’703 Patent”), entitled “Apparatus,
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`Method and System for a Tunneling Client Access Point” after full and fair examination. The
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`application that led to the ’703 Patent, U.S. Patent Application Ser. No. 14/721,540, was a
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`continuation of U.S. Patent Application Ser. No. 13/960,514, which was a continuation of U.S.
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`Patent Application Ser. No. 12/950,321, which was a continuation of U.S. Patent Application
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`Ser. No. 10/807,731, filed on March 23, 2004. A true and correct copy of the ’703 Patent is
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`attached hereto as Exhibit C.
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`IOENGINE is the assignee of all right, title, and interest in and to the ’047
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`Patent, the ’969 Patent, and the ’703 Patent (collectively, the “Patents-in Suit”) and possesses
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`4
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 6 of 206
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`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 5 of 100 PageID #: 5
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`all rights of recovery under the Patents-in-Suit, including the right to recover damages for past
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`infringement.
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`All of the Patents-in-Suit are valid, enforceable, and unexpired.
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`PAYPAL’S INFRINGEMENT
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`IOENGINE repeats, re-alleges, and incorporates by reference the preceding
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`paragraphs as if fully set forth herein.
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`As described below, PayPal infringes claims of each of the Patents-in-Suit
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`directly (alone or jointly), by making, using, selling, offering for sale, and importing into the
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`United States certain products or services, and indirectly by contributing to and inducing direct
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`infringement by others, by encouraging and instructing others to make and use such products or
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`services in an infringing manner.
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` More specifically, the infringing products (the “PayPal Infringing Products”)
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`include, but are not limited to, PayPal’s card reader products for mobile payments (for example,
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`the PayPal Chip Card Reader, PayPal Mobile Card Reader, PayPal Chip and Swipe Reader, and
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`PayPal Chip and Tap Reader)2 alone or in combination with a credit card, debit card, smart card,
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`or contactless payment device; PayPal or third party mobile applications used in connection with
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`PayPal’s card reader products (e.g., the PayPal Here App); PayPal’s secure financial transaction
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`servers used in connection with PayPal’s card reader products to process credit, debit, and smart
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`card transactions and contactless payment transactions; products and systems incorporating the
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`foregoing; and reasonably similar PayPal products with on-board storage and processing
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`capabilities that embody the apparatuses or practice the methods claimed by each of the Patents-
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`2
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`See, e.g., https://www.paypal.com/us/webapps/mpp/credit-card-reader.
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`5
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
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`in-Suit. The PayPal Infringing Products meet the limitations of at least one claim of each of the
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`Patents-in-Suit literally and/or under the doctrine of equivalents.
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`The PayPal Infringing Products include portable card and contactless payment
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`readers that are designed to provide a “a mobile payment solution” to allow users to “accept
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`multiple forms of payment simply and securely, wherever your business takes you,” both “on-
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`the-go or in your store.”3
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`PayPal instructs and encourages its customers to use the PayPal Infringing
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`Products in a manner that infringes at least one claim of each of the Patents-in-Suit, including
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`by providing software development kits for the PayPal Infringing Products,4 by providing
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`information on its website (available at www.paypal.com) and on third-party platforms (e.g.,
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`https://www.youtube.com/user/PayPal), including videos, demonstrations, and other
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`information, and by providing technical support for the PayPal Infringing Products. In each
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`case, the information and materials provided by PayPal contain detailed descriptions and
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`instructions for using and implementing functionality claimed in each of the Patents-in-Suit
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`including, at least, card reader device setup, processing chip card (“EMV”) card payments,
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`processing magnetic stripe card payments, processing contactless payments, processing refunds,
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`and processing firmware updates. PayPal additionally instructs and encourages its customers
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`and third parties to use the PayPal Infringing Products in a manner that infringes at least one
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`claim of each of the Patents-in-Suit by instructing and encouraging its customers and third
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`parties to use the PayPal Infringing Products with PayPal’s Point of Sale Partners (e.g., the Lavu
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`3
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`4
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`https://www.paypal.com/webapps/mpp/credit-card-reader.
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`See, e.g., https://developer.paypal.com/docs/integration/paypal-here/.
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`6
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
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`Point of Sale App,5 TouchBistro App,6 Vend Register App,7 ERPLY cloud-based POS
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`software8, Brightpearl POS system,9 and TouchPoint POS system,10each a “POS Partner App”).
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`FIRST COUNT FOR RELIEF
`(DIRECT INFRINGEMENT OF THE ’047 PATENT)
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`IOENGINE repeats, re-alleges, and incorporates by reference the preceding
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`paragraphs as if fully set forth herein.
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`The ‘047 Patent is presumed valid and PayPal has had actual knowledge of the
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`’047 Patent at least as early as the filing of this Complaint.
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`PayPal is not licensed under the ’047 Patent and has no other right or permission
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`to practice the invention embodied therein.
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`On information and belief, PayPal has infringed and continues to infringe, directly
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`(alone or jointly), literally, and/or under the doctrine of equivalents, in violation of 35 U.S.C. §
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`271, one or more claims of the ’047 Patent by performing, without authority, one or more of the
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`following acts: making, having made, using, importing, selling, and offering for sale in the
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`United States one or more products or services that embody the invention claimed in the ’047
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`Patent, including but not limited to the PayPal Infringing Products. Since at least after receiving
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`notice of this Complaint, Defendant has knowingly infringed, and continues to infringe, one or
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`5
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`6
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`7
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`8
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`See, e.g., https://www.paypal.com/us/webapps/mpp/partner/lavu-pos.
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`See, e.g., https://www.paypal.com/us/webapps/mpp/partner/touchbistro-pos.
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`See, e.g., https://www.paypal.com/us/webapps/mpp/partner/vend-pos.
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`See, e.g., https://www.paypal.com/us/webapps/mpp/partner/erply-pos.
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`See, e.g., https://www.paypal.com/us/webapps/mpp/point-of-sale-systems/retail-
`9
`pos/brightpearl.
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`See, e.g., https://www.paypal.com/us/webapps/mpp/point-of-sale-systems/restaurant-
`10
`pos/touchpoint.
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`7
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
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`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 8 of 100 PageID #: 8
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`more claims of the ’047 Patent by making, having made, using, importing, selling, and offering
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`for sale in the United States the PayPal Infringing Products, which products constitute a material
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`part of the invention and are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`For example, the PayPal Infringing Products embody the patented invention of the
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`’047 Patent and infringe at least Claim 1 of the ’047 patent because each of PayPal’s card reader
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`products for mobile payments is:
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`“[a] portable device, comprising:
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`(a) an external communications interface configured to enable the
`transmission of a plurality of communications between the portable
`device and a terminal comprising a terminal processor, a first input
`component, a first output component, and a network interface;
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`(b) a processor; and
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`(c) a memory having executable program code stored thereon,
`including:
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`(1) first program code which, when executed, causes an interactive
`user interface to be presented on the first output component, wherein
`the interactive user interface is configured to enable the user to cause
`the portable device processor to execute program code stored on the
`portable device memory;
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`(2) second program code which, when executed, enables the
`portable device to (i) receive a communication resulting from user
`interaction with the interactive user interface and (ii) cause a
`communication to be sent through the terminal network interface to
`a communications network node; and
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`(3) third program code which, when executed by the portable device
`processor in response to a communication resulting from user
`interaction with
`the
`interactive user
`interface, causes a
`communication to be transmitted to a communications network
`node;
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`wherein the portable device is configured to effect the display on the
`first output component of processing activity of program code stored
`on the portable device memory; and
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`8
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`wherein the portable device is configured to communicate with the
`terminal and to communicate through the terminal network interface
`with the communications network node.”11
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`Direct Infringement: PayPal Chip Card Reader.
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`The PayPal Chip Card Reader is a portable device that offers a “secure way to process chip card,
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`contactless, and swipe payments on-the-go or in your store”:
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`The PayPal Chip Card Reader contains a Freescale MCIMX258CJM4A M09P
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`12
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`ARM core processor or its equivalent:
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`13
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`11
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`’047 Patent, Claim 1.
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`See PayPal Chip Card Reader Guide, available at
`12
`https://www.paypal.com/us/webapps/mpp/credit-card-reader-how-to/chip-card-reader (the
`“PayPal Chip Card Reader Guide Website”).
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`13 Unless otherwise noted, all pictures of the internal components of the PayPal Chip Card
`Reader were taken of a PayPal Chip Card Reader with the plastic covering removed.
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`9
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`IPR2019-00906 (US 9,059,969)
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`The Freescale MCIMX258CJM4A M09P ARM core processor contains 128 KB
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`SRAM, 32 KB ROM, and/or 16 KB data cache memory, or its equivalent.
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`The PayPal Chip Card Reader contains a 2GB Micron Flash memory module with
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`FBGA code NQ282, corresponding to part number MT29F2G08ABBEAHC-IT:E and/or a
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`512MB SDRAM memory module with FPGA Code D9LQQ, corresponding to part number
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`MT46H32M16LFBF-5 IT:C, or its equivalent:
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`
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`The PayPal Chip Card Reader contains a Bluetooth communications interface
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`configured to enable the transmission of communications between the PayPal Chip Card Reader
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`and a terminal (for example, an Apple iOS or Android device having a processor, an input
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`component such as a touchscreen sensor, an output component such as a display, and a network
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`interface and that contains the PayPal Here App or a POS Partner App). The PayPal Chip Card
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`Reader uses Bluetooth to “pair” with the terminal:
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`14
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`See PayPal Chip Card Reader Guide Website.
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`10
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`14
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`On information and belief, the PayPal Chip Card Reader’s memory stores
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`program code that is configured to cause an interactive user interface to be presented on the
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`terminal’s display (for example, to indicate that the PayPal Chip Card Reader has been paired
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`with the terminal, or to display a message that the PayPal Chip Card Reader requires an update),
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`which the user can interact with (for example, to initiate a credit card transaction, or to initiate a
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`firmware update).
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`For example, the PayPal Here App presents a message when a PayPal Chip Card
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`Reader has been connected and is available for transactions:
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`Also, if a card reader software (“firmware”) update is necessary, the PayPal Here
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`App presents a message that a firmware update is required:
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`15
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`15 Unless otherwise noted, all screen captures of PayPal’s instructional videos for the PayPal
`Chip Card Reader were captured from https://youtu.be/nY5tsHB-S70, last visited Mar. 23, 2018,
`also available from https://www.youtube.com/user/PayPal (PayPal’s “verified” YouTube
`channel).
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`11
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`16
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`Further, on information and belief, the PayPal Chip Card Reader’s memory stores
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`program code that is configured to enable the PayPal Chip Card Reader to receive
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`communications resulting from user interaction with the PayPal Here App or a POS Partner
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`App’s user interface displayed on the terminal and to cause a communication to be sent to a
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`network server through the terminal’s network interface (for example, program code to enable
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`the PayPal Chip Card Reader to receive communications and to cause communications to be sent
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`via Bluetooth, in connection with the processing of payments or firmware updates).
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`On information and belief, the PayPal Chip Card Reader’s memory also stores
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`program code to be executed by the PayPal Chip Card Reader’s processor in response to a
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`communication resulting from user interaction with a user interface on the terminal that is
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`configured to cause a communication to be sent to a network server through the terminal’s
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`network interface (for example, to cause a communication to be sent to PayPal’s secure financial
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`transaction servers to process payments using the PayPal Here App or a POS Partner App, or to
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`request firmware updates).
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`
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`16 Unless otherwise noted, all screen captures of the PayPal Here App in use with the PayPal
`Chip Card Reader were taken on an iPhone 5s running the PayPal Here App.
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`12
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`For example, the PayPal Here App’s user interface allows the user to enter the
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`charge amount and to initiate the transaction by pressing the “charge” button:
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`The PayPal Here App’s user interface also allows the user to initiate a firmware
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`
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`update by pressing the “update” button:
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`
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`On information and belief, the PayPal Chip Card Reader’s memory stores
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`program code to be executed by the PayPal Chip Card Reader’s processor in response to a
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`communication resulting from user interaction with the PayPal Here App’s user interface that is
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`configured to cause a communication to be transmitted to a communications network to process
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`the transaction:
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`13
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
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`On information and belief, the PayPal Chip Card Reader’s memory also stores
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`program code to be executed by the PayPal Chip Card Reader’s processor in response to a
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`communication resulting from user interaction with the PayPal Here App’s user interface that is
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`configured to cause a communication to be transmitted to a communications network to
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`download a firmware update:
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`
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`On information and belief, the PayPal Chip Card Reader is configured to effect
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`the terminal’s display of processing activity of program code stored on the PayPal Chip Card
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`Reader’s memory (for example, to indicate successful pairing of the PayPal Chip Card Reader to
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`the terminal, to display payment processing progress details, to provide payment processing
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`confirmation, or to display firmware update details).
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`14
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`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
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`For example, the PayPal Chip Card Reader is configured to effect the display of
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`the terminal running the PayPal Here App to indicate that a chip card has been inserted and that
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`the transaction is processing:
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`The PayPal Chip Card Reader is also configured to effect the display of the
`
`terminal running the PayPal Here App to indicate that the firmware has been updated
`
`
`
`successfully:
`
`
`
`The PayPal Chip Card Reader is configured to communicate with the terminal
`
`running the PayPal Here App or a POS Partner App, and to communicate through the terminal’s
`
`network interface to a network server (for example, for securely processing credit card or
`
`contactless payment transactions, or firmware updates).
`
`15
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 17 of 206
`
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 16 of 100 PageID #: 16
`
`
`
`Direct Infringement: PayPal Mobile Card Reader.
`
`The PayPal Mobile Card Reader is a portable device that “fits in your pocket and works
`
`with compatible mobile devices to help get you paid on-the-go”:
`
`The PayPal Mobile Card Reader contains a EFM32 TG110F32 ARM Cortex-M3
`
`17
`
`processor or its equivalent:
`
`18
`
`The PayPal Mobile Card Reader contains memory, including at least up to 32 KB
`
`Flash memory and up to 4KB RAM memory integrated into an EFM32 TG110F32 ARM Cortex-
`
`M3 processor, or its equivalent.
`
`The PayPal Mobile Card Reader includes an audio jack communications interface
`
`(e.g., an AHJ connector) configured to enable the transmission of communications between the
`
`
`
`See PayPal Mobile Card Reader Guide, available at
`17
`https://www.paypal.com/us/webapps/mpp/credit-card-reader-how-to/mobile-card-reader (the
`“PayPal Mobile Card Reader Guide Website”).
`
`18 Unless otherwise noted, all pictures of the internal components of the PayPal Mobile Card
`Reader were taken of a PayPal Mobile Card Reader with the plastic covering removed.
`
`16
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 18 of 206
`
`
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 17 of 100 PageID #: 17
`
`
`
`PayPal Mobile Card Reader and a terminal (for example, an Apple iOS or Android device having
`
`a processor, an input component such as a touchscreen sensor, an output component such as a
`
`display, and a network interface and that contains the PayPal Here App or a POS Partner App).
`
`On information and belief, the PayPal Mobile Card Reader’s memory stores
`
`program code that is configured to cause an interactive user interface to be presented on the
`
`terminal’s display (for example, to indicate that the PayPal Mobile Card Reader has been
`
`connected to the terminal and detected), which the user can interact with (for example, to initiate
`
`a credit card transaction).
`
`For example, the PayPal Here App presents a message when the PayPal Mobile
`
`Card Reader has been detected:
`
`19
`
`Further, on information and belief, the PayPal Mobile Card Reader’s memory
`
`stores program code that is configured to enable the PayPal Mobile Card Reader to receive
`
`communications (for example, an audio-data communication sent to the PayPal Mobile Card
`
`
`
`19 Unless otherwise noted, all screen captures of the PayPal Here App in use with the PayPal
`Mobile Card Reader were taken on an iPhone 5s running the PayPal Here App.
`
`17
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 19 of 206
`
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 18 of 100 PageID #: 18
`
`
`
`Reader device over audio pins (pins 3 and 4) of the AHJ interface) resulting from user interaction
`
`with the PayPal Here App or a POS Partner App’s user interface displayed on the terminal and to
`
`cause a communication to be sent to a network server through the terminal’s network interface
`
`(for example, program code to enable the PayPal Mobile Card Reader to receive communications
`
`and to cause communications to be sent via audio-data communication, in connection with the
`
`processing of payments).
`
`On information and belief, the PayPal Mobile Card Reader’s memory also stores
`
`program code to be executed by the PayPal Mobile Card Reader’s processor in response to a
`
`communication resulting from user interaction with a user interface on the terminal that is
`
`configured to cause a communication to be sent to a network server through the terminal’s
`
`network interface (for example, to cause a communication to be sent to PayPal’s secure financial
`
`transaction servers to process payments using the PayPal Here App or a POS Partner App).
`
`For example, the PayPal Here App’s user interface allows the user to enter the
`
`charge amount and to initiate the transaction by pressing the “charge” button:
`
`
`
`
`
`On information and belief, the PayPal Mobile Card Reader’s memory stores
`
`program code to be executed by the PayPal Mobile Card Reader’s processor in response to a
`
`18
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 20 of 206
`
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 19 of 100 PageID #: 19
`
`
`
`communication resulting from user interaction with the PayPal Here App’s user interface that is
`
`configured to cause a communication to be transmitted to a communications network to process
`
`the transaction:
`
`
`
`On information and belief, the PayPal Mobile Card Reader is configured to effect
`
`the terminal’s display of processing activity of program code stored on the PayPal Mobile Card
`
`Reader’s memory (for example, to indicate successful connection to the terminal and detection of
`
`the PayPal Mobile Card Reader, or to display payment processing progress details and to provide
`
`payment processing confirmation).
`
`For example, the PayPal Mobile Card Reader is configured to effect the display of
`
`the terminal running the PayPal Here App to indicate that the PayPal Mobile Card Reader has
`
`been detected:
`
`19
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 21 of 206
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 20 of 100 PageID #: 20
`
`
`
`The PayPal Mobile Card Reader is also configured to effect the display of the
`
`terminal running the PayPal Here App to indicate that a credit card swipe was successful:
`
`
`
`
`
`The PayPal Mobile Card Reader is configured to communicate with the terminal
`
`running the PayPal Here App or a POS Partner App, and to communicate through the terminal’s
`
`network interface to a network server (for example, for securely processing credit card
`
`transactions).
`
`
`
`
`
`20
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 22 of 206
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 21 of 100 PageID #: 21
`
`
`
`Direct Infringement: PayPal Chip and Swipe Reader.
`
`The PayPal Chip and Swipe Reader is a portable device that allows users to “[g]et paid where
`
`your business takes you”:
`
`The PayPal Chip and Swipe Reader contains an ARM STM 32F103 Series
`
`20
`
`microprocessor or its equivalent:
`
`The PayPal Chip and Swipe Reader contains memory, including 16 Kbytes to 1
`
`Mbyte of Flash and 6K to 96K SRAM memory integrated into an ARM STM 32F103 Series
`
`
`
`21
`
`microprocessor, or its equivalent.
`
`
`
`See PayPal Chip and Swipe Reader Guide, available at
`20
`https://www.paypal.com/us/webapps/mpp/credit-card-reader-how-to/chip-and-swipe-reader (the
`“PayPal Chip and Swipe Reader Guide Website”).
`
`21 Unless otherwise noted, all pictures of the internal components of the PayPal Chip and
`Swipe Reader were taken of a PayPal Chip and Swipe Reader with the plastic covering removed.
`
`21
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00906 (US 9,059,969)
`Exhibit 2029
`Page 23 of 206
`
`
`
`
`

`

`Case 1:18-cv-00452-UNA Document 1 Filed 03/23/18 Page 22 of 100 PageID #: 22
`
`
`
`The PayPal Chip and Swipe Reader contains a Bluetooth communications
`
`interface configured to enable the transmission of communications between the PayPal Chip and
`
`Swipe Reader and a terminal (for example, an Apple iOS or Android device having a processor,
`
`an input component such as a touchscreen sensor, an output component such as a display, and a
`
`network interface and that contains the PayPal Here App or a POS Partner App). The PayPal
`
`Chip and Swipe Reader uses Bluetooth to “pair” with the terminal:
`
`22
`
`On information and belief, the PayPal Chip and Swipe Reader’s memory stores
`
`program code that is configured to cause an interactive us