Square, Inc. v. 4361423 Canada Inc.
`Inter Partes Reviews
`January 27, 2021
`
`Petitioner’s
`Demonstratives
`
`IPR2019-01625 – U.S. Patent No. 8,286,875
`IPR2019-01627 – U.S. Patent No. 8,281,998
`IPR2019-01629 – U.S. Patent No. 9,269,084
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Square Exhibit 1045
`Square, Inc. v. 4361423 Canada Inc.
`IPR2019-01627
`Page 00001
`
`
`Inter Partes Reviews
`January 27, 2021
`
`Petitioner’s
`Demonstratives
`
`IPR2019-01625 – U.S. Patent No. 8,286,875
`IPR2019-01627 – U.S. Patent No. 8,281,998
`IPR2019-01629 – U.S. Patent No. 9,269,084
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Square Exhibit 1045
`Square, Inc. v. 4361423 Canada Inc.
`IPR2019-01627
`Page 00001
`
`
`
`The Tang Patents
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Comparison of Tang Patents
`
`Patent
`
`Independent Claim(s)
`
`Notable Features or Differences
`
`Apparatus: 1, 12, 18
`Method: 22, 24, 26
`System: 28
`
`• Capturing information from a magnetic
`stripe
`• Converting to an analog audio format
`suitable for transmission to an analog
`hands-free jack
`
`Apparatus: 1, 10, 12, 17
`Method: 14, 16
`System: 19
`
`• Capturing information from a magnetic
`stripe
`• Converting to an encrypted analog
`audio signal
`
`Apparatus: 1
`Method: 5
`
`• Capturing information from a smart card
`integrated circuit to produce an
`encrypted analog signal
`
`‘875
`
`‘998
`
`‘084
`
`2
`
`IPR2019-01627 Page 00002
`
`
`
`The Tang Patents
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`U.S. Patent No. 8,286,875
`
`1. An apparatus for effecting commercial
`transactions between an input device and a
`remote transaction server using a transaction
`card, said apparatus comprising:
`an input device for capturing information
`from the transaction card;
`a controller for converting the captured
`card information into a signal having an
`analog audio format suitable for transmission
`to an analog hands-free jack of a mobile
`communication device; and
`a communication link for coupling said
`input device to an analog hands-free jack of a
`mobile communication device for the
`transmission of said analog-audio-format
`signals therebetween;
`wherein when said input device captures
`the card information, said controller converts
`the card information into said analog-audio-
`format signal and transmits said converted
`signal via said communication link to said
`mobile communication device; and
`wherein said mobile communication
`device automatically transmits the captured
`card information to the remote transaction
`server and receives transaction validation
`information from said remote transaction
`server.
`
`3
`
`IPR2019-01627 Page 00003
`
`
`
`Technology Known in the Art
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Devices and Methods Admittedly Known
`
`U.S. Patent No. 8,286,875 at 1:24-2:11
`
`4
`
`IPR2019-01627 Page 00004
`
`
`
`Technology Known in the Art
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Mobile Audio Data Transmissions Exist
`
`Tang patents
`
`vs
`
`Bear
`
`Proctor
`
`Eisner
`
`5
`
`IPR2019-01627 Page 00005
`
`
`
`Summary of Grounds
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Instituted Grounds
`IPR2019-01625 — U.S. Patent No. 8,286,875
`Ground
`References
`1
`Proctor, Vrotsos
`2
`Proctor, Vrotsos, Hart
`3
`Eisner, Proctor
`4
`Eisner, Proctor, Hart
`
`Claims
`
`1-3, 6
`12, 14-16, 18-26, 28
`1-3, 6, 12, 18, 21-22, 24, 26, 28
`14-16, 19-20, 23, 25
`
`IPR2019-01627 — U.S. Patent No. 8,281,998
`Ground
`References
`1
`Proctor, Vrotsos
`2
`Proctor, Hart
`3
`Eisner, Proctor
`4
`Eisner, Proctor, Hart
`
`Claims 1, 12, 18, 22, 24, 26, and 28 are independent.
`
`Claims
`
`1-3, 6
`10, 12, 14-17, 19
`1-3, 6, 10, 12, 14, 16, 17, 19
`15
`
`Claims 1, 10, 12, 14, 16, 17, and 19 are independent.
`
`IPR2019-01629 — U.S. Patent No. 9,269,084
`Ground
`References
`1
`Proctor, Vrotsos, Hasumi
`2
`Bear, Landman, Colnot
`
`1-8
`1-8
`
`Claims
`
`Claims 1 and 5 are independent.
`
`6
`
`IPR2019-01627 Page 00006
`
`
`
`Summary of Grounds – Combinations of Proctor, Vrotsos, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Proctor, Vrotsos, and Hart
`IPR2019-01625 Grounds 1-2
`IPR2019-01627 Grounds 1-2
`
`Proctor (Ex. 1004)
`• Credit card 48
`– Magnetic stripe
`– Memory chip
`• Terminal 36
`– Converts to a modulated tonal pattern
`• Converter 30
`– Alone, incorporated into terminal 36, or
`incorporated into phone 22
`• Cellular telephone 22
`– Connector 26 used for hands-free headsets
`– Includes lines for analog microphone input
`and analog speaker out
`• Verification facility 20
`
`‘875 Pet. at 16-20, 23-34, 36-55, 58-59, 64-84, 87-90.
`‘998 Pet. at 16-20, 23-34, 39-57, 60-61, 66-85.
`
`7
`
`IPR2019-01627 Page 00007
`
`
`
`Summary of Grounds – Combinations of Proctor, Vrotsos, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Proctor, Vrotsos, and Hart
`IPR2019-01625 Grounds 1-2
`IPR2019-01627 Grounds 1-2
`
`Vrotsos (Ex. 1006)
`• Communications device
`• Attachment to communications device
`– Input device 308 (e.g., magnetic stripe reader
`or smartcard reader)
`– Processor 303
`•
`Receiving input
`•
`Encrypting
`•
`Processing for transmission to communications device
`• POSITA would have been motivated,
`for example, to incorporate a controller,
`such as Vrotsos’s processor, to process
`information and provide additional
`capabilities (e.g., encryption) in
`Proctor’s system.
`
`‘875 Pet. at 20-23, 25-29.
`‘998 Pet. at 20-23, 25-30.
`
`8
`
`IPR2019-01627 Page 00008
`
`
`
`Summary of Grounds – Combinations of Proctor, Vrotsos, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Proctor, Vrotsos, and Hart
`IPR2019-01625 Grounds 1-2
`IPR2019-01627 Grounds 1-2
`
`Hart (Ex. 1018)
`• Card reader
`– Magnetic read head
`– Swipe produces analog signals
`– Encrypts data
`– Components contained in tamper resistant
`housing
`• POSITA would have been motivated,
`for example, to include the magnetic
`stripe reader configurations of Hart for
`practical implementations of magnetic
`stripe readers to the extent Proctor is
`silent of such details.
`
`‘875 Pet. at 33-55, 85-90.
`‘998 Pet. at 34-57.
`
`9
`
`IPR2019-01627 Page 00009
`
`
`
`Summary of Grounds – Combinations of Eisner, Proctor, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Eisner, Proctor, and Hart
`IPR2019-01625 Grounds 3-4
`IPR2019-01627 Grounds 3-4
`
`Eisner (Ex. 1008)
`• Personal Reader Capture Transfer
`Technology Unit (PRCTT) 14
`– Magnetic stripe reader 30
`– Computer 34
`– Encryptor 48
`
`– DTMF generator 38
`•
`Converts to analog tones
`–
`Jack 44
`•
`E.g., RJ-11 or “any other suitable interface” (5:34-36)
`• Communications network 16
`– PSTN
`‘875 Pet. at 56-58, 61-85.
`– To merchant
`‘998 Pet. at 57-60, 63-85.
`
`10
`
`IPR2019-01627 Page 00010
`
`
`
`Summary of Grounds – Combinations of Eisner, Proctor, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Eisner, Proctor, and Hart
`IPR2019-01625 Grounds 3-4
`IPR2019-01627 Grounds 3-4
`
`Proctor (Ex. 1004)
`• As discussed, teaches processing card
`transactions over a mobile network
`using terminal 36—connected to
`cellular telephone 22 at connector 26
`typically used for analog hands-free
`headsets.
`• POSITA would have been motivated,
`for example, to modify Eisner’s card
`reader device, which connects to a
`communications network using “any ...
`suitable interface,” to connect to a
`mobile network through a cell phone via
`its hands-free jack, as taught by
`Proctor, to provide wireless functionality
`and compatibility with cellular networks.
`‘875 Pet. at 58-61.
`‘998 Pet. at 60-63.
`
`11
`
`IPR2019-01627 Page 00011
`
`
`
`Summary of Grounds – Combinations of Eisner, Proctor, and Hart
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combinations of Eisner, Proctor, and Hart
`IPR2019-01625 Grounds 3-4
`IPR2019-01627 Grounds 3-4
`
`Hart (Ex. 1018)
`• As discussed, teaches practical
`implementations of magnetic stripe
`readers, including magnetic read head
`functionality and tamper resistant
`housings.
`• POSITA would have been motivated,
`for example, to provide a housing to
`protect components and prevent
`tampering.
`
`‘875 Pet. at 85-90.
`‘998 Pet. at 85-87.
`
`12
`
`IPR2019-01627 Page 00012
`
`
`
`Summary of Grounds – Combination of Proctor, Vrotsos, and Hasumi
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Proctor, Vrotsos, and Hasumi
`IPR2019-01629 Ground 1
`
`Proctor (Ex. 1004)
`• Credit card 48
`– Magnetic stripe
`– Memory chip
`• Terminal 36
`– Converts to a modulated tonal pattern
`• Converter 30
`– Situated alone, incorporated into terminal 36,
`or incorporated into phone 22
`• Cellular telephone 22
`– Connector 26 used for hands-free headsets
`– Includes lines for analog microphone input
`and analog speaker out
`• Verification facility 20
`
`‘084 Pet. at 15-19, 24-39.
`
`13
`
`IPR2019-01627 Page 00013
`
`
`
`Summary of Grounds – Combination of Proctor, Vrotsos, and Hasumi
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Proctor, Vrotsos, and Hasumi
`IPR2019-01629 Ground 1
`
`Vrotsos (Ex. 1006)
`• Communications device
`• Attachment to communications device
`– Input device 308 (e.g., magnetic stripe reader
`or smartcard reader)
`– Processor 303 for receiving information,
`encrypting information, and processing
`information for transmission to the
`communications device over connector 27
`• POSITA would have been motivated,
`for example, to incorporate a controller,
`such as Vrotsos’s processor, to process
`information and provide additional
`capabilities (e.g., encryption) in
`Proctor’s system.
`
`‘084 Pet. at 19-22, 28-31.
`
`14
`
`IPR2019-01627 Page 00014
`
`
`
`Summary of Grounds – Combination of Proctor, Vrotsos, and Hasumi
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Proctor, Vrotsos, and Hasumi
`IPR2019-01629 Ground 1
`
`Hasumi (Ex. 1009)
`•
`Integrated circuit (IC) credit card 10
`– Contactless
`• Reading/writing device 4
`– Reads contactless IC card data as encrypted
`electromagnetic waves
`• Communication terminal 2
`• POSITA would have been motivated,
`for example, to configure Proctor’s
`system for use with a contactless IC
`cards, which are produced as
`encrypted analog signals, as taught by
`Hasumi.
`
`‘084 Pet. at 23-27, 32-39
`
`15
`
`IPR2019-01627 Page 00015
`
`
`
`Summary of Grounds – Combination of Bear, Landman, and Colnot
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Bear, Landman, and Colnot
`IPR2019-01629 Ground 2
`
`Bear (Ex. 1021)
`• Smart card 60
`• Smart card device 100
`– Reader 64
`– Controller 52
`– Communications interface 102
`•
`IR
`•
`Audio
`•
`RF
`• Cellular device 104
`• Remote server 106
`
`‘084 Pet. at 39-40.
`
`16
`
`IPR2019-01627 Page 00016
`
`
`
`Summary of Grounds – Combination of Bear, Landman, and Colnot
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Bear, Landman, and Colnot
`IPR2019-01629 Ground 2
`
`Landman (Ex. 1011)
`• Contactless smart card 385
`• Module 310
`– Reader/writer antenna 375
`– RF unit 345
`•
`Converts received radio frequency waveforms to
`intermediate frequency waveforms, intermediate
`frequency waveforms to digital samples
`– Encryption/decryption unit 335
`•
`Communications with smart card are encrypted
`– Process control unit (PCU) 315
`– Cellular modem 305
`– Cellular phone 320
`• POSITA would have been
`motivated, for example, to
`configure Bear’s system for use
`with contactless smart cards, as
`taught by Landman, to provide for
`secure wireless transactions.
`
`‘084 Pet. at 41-44, 50-54, 57-67.
`
`17
`
`IPR2019-01627 Page 00017
`
`
`
`Summary of Grounds – Combination of Bear, Landman, and Colnot
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Combination of Bear, Landman, and Colnot
`IPR2019-01629 Ground 2
`
`•
`
`Colnot (Ex. 1012)
`•
`Tip/Ring/Sleeve interface
`– Connects to mobile phone hands-free jack
`– Alternative to USB, telephone jack, audible
`tones
`– Modem generates modulated sound signal
`Transaction server
`– Process modulated sound signals
`– E.g., IVR server
`• POSITA would have been motivated,
`for example, to configure Bear’s
`system to transmit sound with a TRS
`interface, a known alternative to
`audibly playing tones, and to perform
`additional processing at the
`transaction servers, reducing
`unnecessary processing by the
`mobile device.
`‘084 Pet. at 44-48, 50-60.
`
`18
`
`IPR2019-01627 Page 00018
`
`
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