Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`Fintiv, Inc. v. Apple Inc., Case No. 1:19-CV-1238-ADA (W.D. Tex.)
`
`Invalidity of U.S. Patent No. 8,843,125
`by
`U.S. Patent Publication No. 2010/0138518 A1 (“Aiglstorfer”)
`
`
`REFERENCE: U.S. Patent Publication No. 2010/0138518 A1 (“Aiglstorfer”) was filed on November 18, 2009 and published on June 3, 2010.
`Aiglstorfer is prior art to the ’125 patent under at least 35 U.S.C. § 102(a). All emphasis is added unless otherwise indicated. 1
`
`
`
`
`’125 Patent Claim 11
`
`Disclosure
`
`11. A method for provisioning a
`contactless card applet in a mobile
`device comprising a mobile wallet
`application, the method comprising:
`
`To the extent the preamble is limiting, Aiglstorfer, as evidenced by the example citations below, discloses a method for provisioning a
`contactless card applet in a mobile device comprising a mobile wallet application, at least as this language appears to be interpreted by
`Fintiv, and as the term “provisioning” has been construed by the Court to have its plain and ordinary meaning, where the plain and
`ordinary meaning is “making available for use.”
`
`See e.g.:
`
`• Aiglstorfer at Abstract (“A method for downloading information from a remote server. The method includes receiving, at a
`portable device, banking card information for an account and storing the banking card information into a secure memory
`within the portable device. Responsive to the receiving, a first moblet software module automatically sends a wireless
`message to the remote server to inform the remote server of the banking card information being received at the portable
`device. The portable device may receive a second moblet software module associated with the banking card information. The
`portable device may subsequently execute the second moblet software module which utilizes the banking card information,
`
`
`1 To the extent that these Invalidity Contentions rely on or otherwise embody particular constructions of terms or phrases in the Asserted Claims, including the constructions
`ordered by the Court in this action, Defendant is not proposing any such constructions as proper constructions of those terms or phrases and reserves the right to adopt different
`claim construction positions in this and other proceedings. Various positions put forth in this document are predicated on Plaintiff’s incorrect and overly broad interpretation of its
`claims as evidenced by its Preliminary Infringement Contentions, dated May 20, 2019 and proposed Amended Infringement Conventions, dated December 6, 2019 (collectively,
`the “Infringement Contentions” or “Preliminary Infringement Contentions”). Those positions are not intended to and do not necessarily reflect Defendant’s interpretation of the
`true and proper scope of Plaintiff’s claims, and Defendant reserves the right to adopt claim construction positions that differ from or even conflict with various positions put forth
`in this document.
`
`-1-
`
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`
`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`wherein the first and second moblet software modules comprise device independent commands of a generic syntax and
`wherein further the commands are executed by a device dependent software module also resident on the portable device.”).
`• Aiglstorfer at paragraph [0008] (“It is advantageous to combine the functionality of a conventional card with an electronic
`device to create an electronic wallet to enable a user to interact with an account associated with the conventional card. In one
`embodiment, the electronic wallet can be used as a credit card in an easy-to-use fashion while maintaining its functionalities
`as an electronic device. It is advantageous and important that the financial information be installed on the electronic wallet in
`a secure manner that may be transparent to the user. It will become apparent to those skilled in the art in view of the detailed
`description of the present invention that the embodiments of the present invention provide the above referenced
`advantages.”).
`• Aiglstorfer at paragraph [0009] (“According to one embodiment, the electronic wallet implements a method for automatically
`downloading information from a remote server. The electronic wallet may be implemented on a cellular phone or other
`portable electronic device.”).
`• Aiglstorfer at paragraph [0027] (“Referring now to FIG. 1, an exemplary system 100 for downloading information to an
`electronic wallet comprising a removable security element in accordance with one embodiment of the present invention is
`shown. The system 100 includes an electronic device 110 which may be any portable electronic device, e.g., an electronic
`wallet, a cellular phone, a personal digital assistant (PDA), etc., a trusted service manager (TSM) 120 and a remote server
`130.”).
`• Aiglstorfer at Fig. 1:
`
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`
`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0034] (“The TSM 120 may transmit a first banking card information 105 to a trusted secure agent
`(TSA) 102 that resides on the electronic device 110. The first banking card information 105 may be transmitted when the
`identity of the user corresponding to the first banking card information is verified and authenticated. For example, if a user
`has a Bank of America account and the identity of the user is verified and authenticated, then the banking card information
`associated with the Bank of America account of the user may be transmitted to the electronic device 110.”).
`• Aiglstorfer at paragraph [0036] (“The TSA 102 stores the first banking card information 105 in the removable security
`element 104 in response to receiving the first banking card information 105. The TSA 102 may also notify 107 the first
`moblet software module 106 that the first banking card information has been received and is stored in the removable security
`element 104. The first moblet software module 106 may in turn notify 109 the remote server 130.”).
`• Aiglstorfer at paragraphs [0030] - [0031] (“The remote server 130 may provide various applications to the electronic device
`110. For example, the remote server 130 may provide a first moblet software module 106 operable on the electronic device
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`110 that may in turn manage additional moblet software modules. It is appreciated that moblet software modules are operable
`in a MOJAX environment operating on a device. According to one embodiment, MOJAX is device specific while moblet
`software modules operating within the MOJAX environment are device generic.
`It is appreciated that the first moblet software module 106 may be installed during manufacturing of the electronic device 110.
`Alternatively, the first moblet software module 106 may be requested 101 from the remote server 130 and subsequently
`downloaded. The request 101 may indicate a device type of the electronic device 110. In response to the request 101, the
`remote server 130 may transmit 103 the first moblet software module 106 to the electronic device 110. Furthermore,
`responsive to the request 101, the remote server 130 may also transmit 103 a device dependent software, e.g., MOJAX
`environment, to the electronic wallet. It is appreciated that in one embodiment the device dependent software may be installed
`during manufacturing of the electronic device 110.”).
`• Aiglstorfer at paragraph [0044] (“Referring now to FIG. 2, an exemplary system 200 for downloading information to an
`electronic wallet comprising a non-removable security element in accordance with one embodiment of the present invention
`is shown. The system 200 includes an electronic device 210, e.g., an electronic wallet, a cellular phone, a PDA, etc., a trusted
`service manager (TSM) 220 and a remote server 230. It is appreciated that the TSM 220 and the remote server 230 operate
`similar to the TSM 120 and the remote server 130 already described above with respect to FIG. 1.”).
`• Aiglstorfer at Fig. 2:
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0060] (“FIG. 4 illustrates an exemplary component architecture for an electronic wallet in
`accordance with embodiments of the present invention. As shown, a mobile wallet 410 controls the operations and user
`selection of a plurality of other moblet software modules, e.g., moblets 420 a-420 h. Moblets 420 a-420 h provide the user
`with a wide range and variety of financial services and applications such as banking applications, shopping applications,
`coupon applications, credit card applications, etc. A wallet moblet is a moblet that runs within the mobile wallet 410. It is
`appreciated that the first moblet 410 and all other moblets 420 a-420 h operate within a MOJAX framework according to the
`installed MOJAX core 430. The MOJAX core may be device specific, but since it operates as a platform for operation of the
`moblets, the moblets themselves may be written in a device-independent syntax that is only MOJAX-specific. It is
`appreciated that the component architecture shown in FIG. 4 represents a software hierarchy of software components installed
`on a portable computer system as described herein.”).
`• Aiglstorfer at Fig. 4:
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0063] (“FIGS. 5A-5D show an exemplary embedded card personalization in accordance with one
`embodiment of the present invention. The embedded card personalization comprises a secure element that is embedded within
`the device. The TSA agent and a wallet moblet operate within the MRE. The TSA agent performs all the interactions with the
`secure element. For example, referring to FIG. 5B, TSM pushes a new card applet into the TSA agent. In one embodiment,
`the new card applet may be banking information. As a result, the TSA agent communicates and pushes the received
`information into the secure element. Referring now to FIG. 5C, the TSA agent notifies the wallet moblet operating within the
`MOJAX environment that the information from the TSM has been received. Referring now to FIG. 5D, the wallet moblet in
`response to the notification from the TSA agent request a card moblet from the wallet registry. In response to the request, the
`wallet registry transmits the card moblet to the wallet MRE where the card moblet is installed within the MOJAX
`environment.”).
`• Aiglstorfer at Fig. 5B:
`
`-6-
`
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`
`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0064] (“FIGS. 6A-6D show externalized card personalization in accordance with one embodiment
`of the present invention. Externalized card personalization may comprise a removable secure element. Removable secure
`elements do not require a TSA agent to interact with the secure element. The wallet MRE comprises a wallet moblet.
`Referring now to FIG. 6B, the TSM pushes the new card applet into the removable secure element. Referring now to FIG. 6C,
`the TSM notifies the wallet moblet operating within the wallet MRE, e.g., MOJAX environment, that the new card applet is
`installed. Referring now to FIG. 6D, the wallet moblet in response to receiving the notification from the TSM may send a
`request for a card moblet to the wallet registry. In response to the request, the wallet registry may transmit the card moblet to
`the wallet MRE where the card moblet is installed.”).
`• Aiglstorfer at Fig. 6B:
`
`-7-
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`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`See also the disclosures for claim elements [1a] and [1g] below.
`
`
`
`
`[a] activating the mobile wallet
`application;
`
`Aiglstorfer, as evidenced by the example citations below, discloses activating the mobile wallet application, at least as this claim
`limitation appears to be interpreted by Fintiv.
`
`See e.g.:
`
`• Aiglstorfer at paragraph [0012] (“It is appreciated that responsive to a user request, the electronic wallet may send a message
`to the remote server to download the first moblet software module. The sent message may indicate a device type of the
`electronic wallet. Accordingly, the electronic wallet receives from the remote server the device dependent software module
`via a wireless network. Moreover, the electronic wallet receives from the remote server the first moblet software module via a
`wireless network. Accordingly, the electronic wallet executes the first moblet software module using the device dependent
`software module. According to one embodiment, the first and the second moblet software modules are written using MOJAX
`commands.”).
`
`-8-
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`• Aiglstorfer at paragraphs [0030] - [0031] (“The remote server 130 may provide various applications to the electronic device
`110. For example, the remote server 130 may provide a first moblet software module 106 operable on the electronic device
`110 that may in turn manage additional moblet software modules. It is appreciated that moblet software modules are operable
`in a MOJAX environment operating on a device. According to one embodiment, MOJAX is device specific while moblet
`software modules operating within the MOJAX environment are device generic.
`It is appreciated that the first moblet software module 106 may be installed during manufacturing of the electronic device 110.
`Alternatively, the first moblet software module 106 may be requested 101 from the remote server 130 and subsequently
`downloaded. The request 101 may indicate a device type of the electronic device 110. In response to the request 101, the
`remote server 130 may transmit 103 the first moblet software module 106 to the electronic device 110. Furthermore,
`responsive to the request 101, the remote server 130 may also transmit 103 a device dependent software, e.g., MOJAX
`environment, to the electronic wallet. It is appreciated that in one embodiment the device dependent software may be installed
`during manufacturing of the electronic device 110.”).
`• Aiglstorfer at Fig. 1:
`
`-9-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0032] (“The first moblet software module 106 is installed on the electronic device 110 and becomes
`operable on the electronic device 110. The first moblet software module 106 may manage additional moblet software
`modules. It is appreciated that the first moblet software module 106 may be operating within the electronic wallet
`environment. For example, the electronic wallet environment may have a corresponding graphical element icon. Upon a user
`selection of the electronic wallet environment, additional graphical element icons associated with moblet software modules
`may be displayed. The displayed moblet software modules may be executed upon selection thereof.”).
`• Aiglstorfer at paragraphs [0034] - [0035] (“The TSM 120 may transmit a first banking card information 105 to a trusted
`secure agent (TSA) 102 that resides on the electronic device 110. The first banking card information 105 may be transmitted
`when the identity of the user corresponding to the first banking card information is verified and authenticated. For example, if
`a user has a Bank of America account and the identity of the user is verified and authenticated, then the banking card
`information associated with the Bank of America account of the user may be transmitted to the electronic device 110.
`
`-10-
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`In the electronic device 110 with a removable security element 104, the TSA 102 acts as a communication gateway between
`the TSM 120 and the electronic device 110. The removable security element 104 may be a subscriber identity module (SIM)
`card. The removable security element 104 may be equipped with near field communication (NFC) technology. It is
`appreciated that the TSA 102 may be a plug-in software module.”).
`• Aiglstorfer at paragraph [0045] (“It is appreciated that a first moblet software module 204 may be installed during
`manufacturing of the electronic device 210. Alternatively, the first moblet software module 204 may be requested 201 from
`the remote server 230. The request 201 may indicate a device type of the electronic device 210. In response to the request
`201, the remote server 230 may transmit 203 the first moblet software module 204 to the electronic device 210. Furthermore,
`responsive to the request 201, the remote server 130 may transmit 203 a device dependent software, e.g., MOJAX
`environment. It is appreciated that in one embodiment the device dependent software may be installed during manufacturing
`of the electronic device 110.”).
`• Aiglstorfer at Fig. 2:
`
`
`
`-11-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`• Aiglstorfer at paragraph [0046] (“The first moblet software module 204 is installed and becomes operable on the electronic
`device 210. In this embodiment, since the electronic device 210 does not have a removable security element 104, the TSM
`220 communicates to a non-removable security element 202 without using the TSA 102. Moreover, the TSM 220
`communicates with the first moblet software module 204 without using the TSA 102. It is appreciated that according to one
`embodiment of the present invention, the non-removable security element 202 is near field communication (NFC) enabled.”).
`• Aiglstorfer at paragraph [0047] (“It is appreciated that the first moblet software module 204 becomes operable on the
`electronic device 210 when it is installed on the electronic device 210. The first moblet software module 204 may manage
`additional moblet software modules. It is appreciated that the first moblet software module 204 may operate within the
`electronic wallet environment. For example, moblet software modules are operable in a MOJAX environment operating on a
`device. According to one embodiment, MOJAX is device specific while moblet software modules operating within the
`MOJAX environment are device generic. According to one embodiment, the electronic wallet environment may have a
`corresponding graphical element icon. Upon selection of the electronic wallet environment, additional graphical element
`icons associated with moblet software modules may be displayed. The displayed moblet software modules may be executed
`upon selection thereof.”).
`• Aiglstorfer at paragraph [0065] (“Referring now to FIGS. 7A and 7B, an exemplary flow diagram 700 for downloading
`information into a secure element in accordance with one embodiment of the present invention is shown. At step 710,
`responsive to a user request, the portable device, e.g., cellular phone, sends a message to a remote server to download a first
`moblet software module. It is appreciated that the message sent to the remote server may indicate a device type of the potable
`device.”).
`• Aiglstorfer at Fig. 7A:
`
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`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0066] (“At step 712, the portable device receives a device dependent software module. The device
`dependent software module is transmitted by the remote server via a wireless network. At step 714, the portable device
`receives the first moblet software module from the remote server via a wireless network.”).
`
`[b] connecting to a Trusted Service
`Manager (TSM) system;
`
`Aiglstorfer, as evidenced by the example citations below, discloses connecting to a Trusted Service Manager (TSM) system, at least as
`this claim limitation appears to be interpreted by Fintiv.
`
`-13-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`See e.g.:
`
`• Aiglstorfer at paragraph [0027] (“Referring now to FIG. 1, an exemplary system 100 for downloading information to an
`electronic wallet comprising a removable security element in accordance with one embodiment of the present invention is
`shown. The system 100 includes an electronic device 110 which may be any portable electronic device, e.g., an electronic
`wallet, a cellular phone, a personal digital assistant (PDA), etc., a trusted service manager (TSM) 120 and a remote server
`130.”).
`• Aiglstorfer at Fig. 1:
`
`
`• Aiglstorfer at paragraph [0029] (“The TSM 120 is a trusted entity in charge of sending secure information, e.g., financial
`information, regarding a specific user to the electronic device 110. The TSM 120 may verify and authenticate the user with
`regard to a particular bank or financial institution. For example, the identity of a user with a Bank of America account may be
`
`-14-
`
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`verified and authenticated. It is appreciated that although embodiments herein are described with respect to banking
`information and bank accounts, the information may be related to any card, e.g., a reward card, a movie rental card, a gas
`card, a coffee shop card, a stored value card, a loyalty card, etc. As such, the use of banking information is exemplary and not
`intended to limit the scope of the present invention. After verification of the user identity and authentication of the user, the
`TSM 120 may transmit the banking information regarding the Bank of America account (for instance) to the electronic device
`110.”).
`• Aiglstorfer at paragraph [0034] (“The TSM 120 may transmit a first banking card information 105 to a trusted secure agent
`(TSA) 102 that resides on the electronic device 110. The first banking card information 105 may be transmitted when the
`identity of the user corresponding to the first banking card information is verified and authenticated. For example, if a user
`has a Bank of America account and the identity of the user is verified and authenticated, then the banking card information
`associated with the Bank of America account of the user may be transmitted to the electronic device 110.”).
`• Aiglstorfer at paragraph [0035] (“In the electronic device 110 with a removable security element 104, the TSA 102 acts as a
`communication gateway between the TSM 120 and the electronic device 110. The removable security element 104 may be a
`subscriber identity module (SIM) card. The removable security element 104 may be equipped with near field communication
`(NFC) technology. It is appreciated that the TSA 102 may be a plug-in software module.”).
`• Aiglstorfer at paragraph [0039] (“It is appreciated that additional banking card information and moblet software modules
`associated therewith may be similarly received and installed and messaged by the first moblet 106. For example, a second
`banking card information 113 may be transmitted from the TSM 120 to the TSA 102. The TSA 102 may store the second
`banking card information 113 in the removable security element 104. The TSA 102 may subsequently automatically notify
`115 the first moblet software module 106 of the transmission of the second banking card information. According to one
`embodiment, the first moblet software module 106 notifies 117 the remote server 130 that the second banking card
`information 113 has been received.”).
`• Aiglstorfer at paragraph [0044] (“Referring now to FIG. 2, an exemplary system 200 for downloading information to an
`electronic wallet comprising a non-removable security element in accordance with one embodiment of the present invention
`is shown. The system 200 includes an electronic device 210, e.g., an electronic wallet, a cellular phone, a PDA, etc., a trusted
`service manager (TSM) 220 and a remote server 230. It is appreciated that the TSM 220 and the remote server 230 operate
`similar to the TSM 120 and the remote server 130 already described above with respect to FIG. 1.”).
`• Aiglstorfer at Fig. 2:
`
`-15-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0046] (“The first moblet software module 204 is installed and becomes operable on the electronic
`device 210. In this embodiment, since the electronic device 210 does not have a removable security element 104, the TSM
`220 communicates to a non-removable security element 202 without using the TSA 102. Moreover, the TSM 220
`communicates with the first moblet software module 204 without using the TSA 102. It is appreciated that according to one
`embodiment of the present invention, the non-removable security element 202 is near field communication (NFC) enabled.”).
`• Aiglstorfer at paragraph [0063] (“FIGS. 5A-5D show an exemplary embedded card personalization in accordance with one
`embodiment of the present invention. The embedded card personalization comprises a secure element that is embedded within
`the device. The TSA agent and a wallet moblet operate within the MRE. The TSA agent performs all the interactions with the
`secure element. For example, referring to FIG. 5B, TSM pushes a new card applet into the TSA agent. In one embodiment,
`the new card applet may be banking information. As a result, the TSA agent communicates and pushes the received
`information into the secure element. Referring now to FIG. 5C, the TSA agent notifies the wallet moblet operating within the
`MOJAX environment that the information from the TSM has been received. Referring now to FIG. 5D, the wallet moblet in
`response to the notification from the TSA agent request a card moblet from the wallet registry. In response to the request, the
`
`-16-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`wallet registry transmits the card moblet to the wallet MRE where the card moblet is installed within the MOJAX
`environment.”).
`• Aiglstorfer at Fig. 5B:
`
`
`• Aiglstorfer at paragraph [0064] (“FIGS. 6A-6D show externalized card personalization in accordance with one embodiment
`of the present invention. Externalized card personalization may comprise a removable secure element. Removable secure
`elements do not require a TSA agent to interact with the secure element. The wallet MRE comprises a wallet moblet.
`Referring now to FIG. 6B, the TSM pushes the new card applet into the removable secure element. Referring now to FIG. 6C,
`the TSM notifies the wallet moblet operating within the wallet MRE, e.g., MOJAX environment, that the new card applet is
`installed. Referring now to FIG. 6D, the wallet moblet in response to receiving the notification from the TSM may send a
`request for a card moblet to the wallet registry. In response to the request, the wallet registry may transmit the card moblet to
`the wallet MRE where the card moblet is installed.”).
`• Aiglstorfer at Fig. 6B:
`
`-17-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`• Aiglstorfer at Fig. 6C:
`
`
`
`-18-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`[c] synchronizing the mobile wallet
`application with the TSM system;
`
`Aiglstorfer, as evidenced by the example citations below, discloses synchronizing the mobile wallet application with the TSM system,
`at least as this claim limitation appears to be interpreted by Fintiv.
`
`
`
`
`
`See e.g.:
`
`• Aiglstorfer at paragraph [0027] (“Referring now to FIG. 1, an exemplary system 100 for downloading information to an
`electronic wallet comprising a removable security element in accordance with one embodiment of the present invention is
`shown. The system 100 includes an electronic device 110 which may be any portable electronic device, e.g., an electronic
`wallet, a cellular phone, a personal digital assistant (PDA), etc., a trusted service manager (TSM) 120 and a remote server
`130.”).
`• Aiglstorfer at Fig. 1:
`
`-19-
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`

`

`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Aiglstorfer at paragraph [0029] (“The TSM 120 is a trusted entity in charge of sending secure information, e.g., financial
`information, regarding a specific user to the electronic device 110. The TSM 120 may verify and authenticate the user with
`regard to a particular bank or financial institution. For example, the identity of a user with a Bank of America account may be
`verified and authenticated. It is appreciated that although embodiments herein are described with respect to banking
`information and bank accounts, the information may be related to any card, e.g., a reward card, a movie rental card, a gas
`card, a coffee shop card, a stored value card, a loyalty card, etc. As such, the use of banking information is exemplary and not
`intended to limit the scope of the present invention. After verification of the user identity and authentication of the user, the
`TSM 120 may transmit the banking information regarding the Bank of America account (for instance) to the electronic device
`110.”).
`• Aiglstorfer at paragraph [0034] (“The TSM 120 may transmit a first banking card information 105 to a trusted secure agent
`(TSA) 102 that resides on the electronic device 110. The first banking card information 105 may be transmitted when the
`identity of the user corresponding to the first banking card information is verified and authenticated. For example, if a user
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`IPR2020-00019
`Fintiv EX2010 Page 20
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`Chart A-3
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`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`has a Bank of America account and the identity of the user is verified and authenticated, then the banking card information
`associated with the Bank of America account of the user may be transmitted to the electronic device 110.”).
`• Aiglstorfer at paragraph [0035] (“In the electronic device 110 with a removable security element 104, the TSA 102 acts as a
`communication gateway between the TSM 120 and the electronic device 110. The removable security element 104 may be a
`subscriber identity module (SIM) card. The removable security element 104 may be equipped with near field communication
`(NFC) technology. It is appreciated that the TSA 102 may be a plug-in software module.”).
`• Aiglstorfer at paragraph [0039] (“It is appreciated that additional banking card information and moblet software modules
`associated therewith may be similarly received and installed and messaged by the first moblet 106. For example, a second
`banking card information 113 may be transmitted from the TSM 120 to the TSA 102. The TSA 102 may store the second
`banking card information 113 in the removable security element 104. The TSA 102 may subsequently automatically notify
`115 the first moblet software module 106 of the transmission of the second banking card information. According to one
`embodiment, the first moblet software module 106 notifies 117 the remote server 130 that the second banking card
`information 113 has been received.”).
`• Aiglstorfer at paragraph [0044] (“Referring now to FIG. 2, an exemplary system 200 for downloading information to an
`electronic wallet comprising a non-removable security element in accordance with one embodiment of the present invention
`is shown. The system 200 includes an electronic device 210, e.g., an electronic wallet, a cellular phone, a PDA, etc., a trusted
`service manager (TSM) 220 and a remote server 230. It is appreciated that the TSM 220 and the remote server 230 operate
`similar to the TSM 120 and the remote server 130 already described above with respect to FIG. 1.”).
`• Aiglstorfer at Fig. 2:
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`IPR2020-00019
`Fintiv EX2010 Page 21
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`Chart A-3
`
`Invalidity Contentions: Patent No. 8,843,125
`
`’125 Patent Claim 11
`
`Disclosure
`
`
`• Ai