EXHIBIT 5
`
`Infringement of U.S. Patent 8,463,030 (the “’030 Patent”)
`by the Bank of America Accused Products
`
`This chart describes infringement by the Bank of America Mobile Banking App (the
`“BoA App”), its mobile check deposit feature, and the mobile devices, computers, servers,
`software, and other infrastructure related to and/or associated with the BoA App and its mobile
`check deposit feature (collectively, the “BoA Accused Products”). The BoA Accused Products
`directly and/or indirectly infringe at least claims 1-4, 6-7, 13, 16-19, 21-22, 25-27, 29-32, and
`35-37 of the ’030 Patent literally and under the doctrine of equivalents. As described below,
`every accused limitation is directly performed and controlled by the BoA App in combination
`with Bank of America’s computer, servers, software, and other infrastructure, such that Bank of
`America makes and uses each asserted claim, and thereby directly infringing each asserted claim.
`Additionally, and in the alternative, a user of the BoA app to perform mobile check deposit uses
`each asserted claim by putting the system as a whole into service and thereby directly infringes
`each asserted claim.
`
`The claim charts below provide examples of how the BoA Accused Products infringe the
`asserted claims. NantWorks does not have access to BoA’s confidential technical documents
`and source code that fully describe how the BoA Accused Products operate and all of the
`different ways in which they infringe the claims. NantWorks anticipates that it may learn of
`additional ways in which the BoA Accused Products infringe the asserted claims and reserves the
`right to supplement its infringement contentions to include all additional ways in which the BoA
`Accused Products infringe the asserted claims.
`
`Claims
`
`Claim 1. [1.pre] A
`transaction system
`comprising:
`
`Infringement by the BoA Accused Products
`
`To the extent the preamble is limiting, the BoA Accused
`Products meet this limitation. See for example:
`
`The BoA Accused Products include a transaction system as
`detailed in the claim limitations below.
`
`For example, the system includes a mobile device such as an
`iPhone, Android mobile device, or tablet computer. See, e.g.:
`
`1
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`Patent Owner’s Ex. 2009, Page 1 of 77
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`

`

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`
`
`
`
`
`https://apps.apple.com/us/app/bank-of-america-mobile-
`banking/id284847138#?platform=iphone
`
`
`2
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`Patent Owner’s Ex. 2009, Page 2 of 77
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`

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`
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`
`
`https://play.google.com/store/apps/details?id=com.infonow.bof
`a
`
`For example, additionally and/or in the alternative, the system
`includes the BoA App operating on a customer’s mobile
`device and BoA’s computers and servers computers. The BoA
`App communicates with these computers and servers. On
`information and belief, the BoA App operating on a
`customer’s mobile device and/or BoA’s computers and
`servers perform image and data processing functions
`associated with the BoA App. The computers and servers also
`communicate with the BoA App to perform functions
`including verification, authentication, encryption, and data
`integrity. See, e.g.:
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`3
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`Patent Owner’s Ex. 2009, Page 3 of 77
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`

`

`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/security-center/faq/online-
`banking/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this limitation.
`
`For example. the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer. See,
`e.g.:
`
`
`
`[1.A] a mobile device
`configured to acquire data
`related to an object;
`
`4
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`Patent Owner’s Ex. 2009, Page 4 of 77
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`

`

`
`
`
`
`
`
`https://apps.apple.com/us/app/bank-of-america-mobile-
`banking/id284847138#?platform=iphone
`
`
`5
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`Patent Owner’s Ex. 2009, Page 5 of 77
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`

`

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`
`
`
`
`https://play.google.com/store/apps/details?id=com.infonow.bof
`a
`
`For example, the mobile device, via its integrated camera,
`obtains data in the form of an image of a front and back of a
`check to be deposited by a Bank of America customer and
`provides that image data to the BoA App. See, e.g.:
`
`
`
`
`6
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`Patent Owner’s Ex. 2009, Page 6 of 77
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`

`

`
`
`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`For example, additionally, and/or in the alternative, on
`information and belief, the BoA App operating on a
`customer’s mobile device and/or BoA’s computers and
`servers performs a data processing operation on at least a
`
`7
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`Patent Owner’s Ex. 2009, Page 7 of 77
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`portion of the captured image to produce data, the data
`including at least recognized symbolic content within the
`image of the check. On information and belief this data
`includes MICR symbols, alphanumeric characters
`corresponding to the check payer and payee names, the dollar
`amount to be transferred to the payee, and routing and account
`numbers associated with the payer displayed on the check
`image. On information and belief, this data also includes the
`payer’s signature and the payee’s endorsement of the check.
`See, e.g.:
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`
`8
`
`
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`Patent Owner’s Ex. 2009, Page 8 of 77
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`

`

`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this limitation.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer. See,
`e.g.:
`
`
`
`[1.B] an object
`identification platform
`configured to obtain the
`acquired data, recognize the
`object as a target object
`based on the acquired data,
`
`
`
`https://apps.apple.com/us/app/bank-of-america-mobile-
`banking/id284847138#?platform=iphone
`
`
`9
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`Patent Owner’s Ex. 2009, Page 9 of 77
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`

`

`
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`
`
`
`
`https://play.google.com/store/apps/details?id=com.infonow.bof
`a
`
`For example, the BoA App receives, via the mobile device on
`which it operates and an associated camera, a digital image of
`a front and back of a check to be deposited by a Bank of
`America customer and user of the BoA App. See, e.g.:
`
`
`
`
`10
`
`
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`Patent Owner’s Ex. 2009, Page 10 of 77
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`

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`
`
`For example, on information and belief, the BoA App
`operating on a customer’s mobile device and/or BoA’s
`computers and servers receive the captured digital image from
`the mobile device via the BoA App and perform image
`processing and verification functions on the received image.
`On information and belief, the BoA Accused Products utilize
`the received check image and determined symbol content to
`identify that a valid check document is present in the image
`and to distinguish the check from non-accepted documents
`using a database that stores data characteristics of an accepted
`check document. On information and belief, the BoA Accused
`Products includes at least a database storing object image
`information associated with the check types that may be
`processed by the BoA Accused Products (e.g., personal
`checks, business checks, government/treasury checks,
`cashier’s checks) and the BoA accused products perform a
`query of such database to determine whether the received
`check constitutes such a check type.
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`Additionally and in the alternative, on information and belief,
`the BoA Accused Products include at least a database storing
`recognizable MICR symbols parameters for recognizing such
`MICR symbols. On information and belief, the BoA App
`operating on a customer’s mobile device and/or BoA’s
`computers and servers receive the captured digital image and
`MICR symbols contained therein from the mobile device via
`the BoA App and perform image processing and verification
`functions on the received image and MICR symbols. On
`information and belief, the BoA Accused Products perform a
`
`11
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`Patent Owner’s Ex. 2009, Page 11 of 77
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`

`

`
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`query of such database to determine whether the received
`check image contains recognizable MICR symbols.
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`
`12
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`Patent Owner’s Ex. 2009, Page 12 of 77
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`

`

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`
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`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`
`For example, to the extent that Defendants contend that the
`BoA Accused Products do have an identification platform to
`recognize a target object , e.g, the BoA Accused Products do
`not store all possible known check formats in a database as
`targets, the Accused Products would infringe under the
`doctrine of equivalents because the BoA Accused Products
`store enough information and recognition parameters to
`determine the type of check being cashed and if it is a type of
`check that can be cashed. Whether the BoA Accused Products
`have a database of all known check types and recognition
`parameters instead of database with only important check
`types and parameters, the manner in which they are used and
`operate is an insubstantial difference: both scenarios
`accomplish substantially the same function of storing enough
`information to allow check cashing, in substantially the same
`way, i.e., by storing information regarding checks so such
`information can be compared to the check being cashed, and
`accomplish substantially the same result of having an ability to
`store enough information to compare the check to be cashed to
`known check types so that it can be recognized for cashing.
`
`The BoA Accused Products meet this limitation.
`
`For example, when a user performs a mobile check deposit
`using the BoA Accused Products, the BoA App operating on a
`customer’s mobile device and/or BoA’s computers and
`servers associate the deposit and associated check with
`information including a transaction/confirmation number, the
`captured image of the check, and deposited amount. See, e.g.:
`
`
`13
`
`[1.C] and determine object
`information associated with
`the target object; and
`
`
`Patent Owner’s Ex. 2009, Page 13 of 77
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`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`14
`14
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`Patent Owner’s Ex. 2009, Page 14 of 77
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`Patent Owner’s Ex. 2009, Page 14 of 77
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`

`
`
`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`15
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`Patent Owner’s Ex. 2009, Page 15 of 77
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`

`

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`[1.D] associate the target
`with target information
`pertinent to the target; and
`
`
`
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this limitation.
`
`For example, when a user performs a mobile check deposit
`using the BoA Accused Products, the BoA Accused Products
`associate the deposited check with information pertaining to
`the check including a transaction/confirmation number, the
`captured image of the check, and deposited amount, and the
`information is sent to the customer’s mobile device following
`a mobile deposit transaction. See, e.g.:
`
`
`16
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`Patent Owner’s Ex. 2009, Page 16 of 77
`
`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`17
`17
`
`Patent Owner’s Ex. 2009, Page 17 of 77
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`Patent Owner’s Ex. 2009, Page 17 of 77
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`

`

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`
`
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`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`18
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`Patent Owner’s Ex. 2009, Page 18 of 77
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`[1.E] a content platform
`configured to obtain the
`object information, and
`initiate a transaction
`associated with the target
`object with a selected
`account over a network
`based on the object
`information.
`
`
`
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this limitation.
`
`For example, the BoA App operating on a customer’s mobile
`device and/or BoA’s computers and servers use the
`information associated with the deposited check (including, for
`example, a transaction/confirmation number, the captured
`image of the check, and deposited amount) to enable a check
`deposit transaction with the BoA customer’s banking account,
`allowing appropriate funds to be deposited into the customer’s
`account upon completion of processing of the deposited check.
`See, e.g.,
`
`
`19
`
`Patent Owner’s Ex. 2009, Page 19 of 77
`
`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`20
`20
`
`Patent Owner’s Ex. 2009, Page 20 of 77
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`Patent Owner’s Ex. 2009, Page 20 of 77
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`

`

`
`
`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`21
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`Patent Owner’s Ex. 2009, Page 21 of 77
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`Claim 2. The system of
`claim 1, wherein the mobile
`device is configured to
`operate, at least in part, as
`the object identification
`platform.
`
`
`
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, on information and belief, the BoA App
`operating on a customer’s mobile device performs a data
`processing operation on at least a portion of the captured
`image to identify features relating to the displayed check, the
`features within the image of the check. On information and
`belief, the BoA App utilizes the check image and determines
`features to identify that a valid check document is present in
`the image and to distinguish the check from non-accepted
`documents using characteristics of an accepted check
`document. On information and belief, such features that are
`identified include MICR symbols, alphanumeric characters
`corresponding to the check payer and payee names, the dollar
`amount to be transferred to the payee, and routing and account
`numbers associated with the payer displayed on the check
`image. On information and belief, these features also include
`the payer’s signature and the payee’s endorsement of the
`check.
`
`
`22
`
`Patent Owner’s Ex. 2009, Page 22 of 77
`
`

`

`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`
`
`
`
`
`23
`
`Patent Owner’s Ex. 2009, Page 23 of 77
`
`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`24
`24
`
`Patent Owner’s Ex. 2009, Page 24 of 77
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`Patent Owner’s Ex. 2009, Page 24 of 77
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`Claim 3. The system of
`claim 2, wherein the object
`identification platform is
`distributed between the
`mobile device and at least
`one remote server coupled
`with the mobile device via a
`network.
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`Additionally and/or in the alternative to Claim 2, the BoA
`Accused Products meet this claim.
`
`For example, the BoA App operating on a customer’s mobile
`device performs a data processing operation on at least a
`portion of the captured image to identify features relating to
`the displayed check, the features within the image of the
`check. Additionally, on information and belief, remote
`computers and servers owned, controlled, and/or operated by
`BoA with which the BoA App communicates perform image
`and data processing functions associated with the BoA App.
`
`25
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`Patent Owner’s Ex. 2009, Page 25 of 77
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`

`

`
`
`
`
`
`The computers and servers also communicate with the BoA
`App to perform functions including verification,
`authentication, encryption, and data integrity, and check
`transaction processing. On information and belief, the remote
`computers and servers utilize the received check image and
`determine certain features to identify that a valid check
`document is present in the image and to distinguish the check
`from non-accepted documents using a database that stores data
`characteristics of an accepted check document, as well as
`process and determine features including MICR symbols,
`alphanumeric characters corresponding to the check payer and
`payee names, the dollar amount to be transferred to the payee,
`and routing and account numbers associated with the payer
`displayed on the check image. On information and belief,
`these features also include the payer’s signature and the
`payee’s endorsement of the check.
`
`See, e.g.:
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`https://www.bankofamerica.com/security-center/faq/online-
`banking/
`
`
`26
`
`
`
`
`
`Patent Owner’s Ex. 2009, Page 26 of 77
`
`

`

`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`
`
`
`27
`
`Patent Owner’s Ex. 2009, Page 27 of 77
`
`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`28
`28
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`Patent Owner’s Ex. 2009, Page 28 of 77
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`Patent Owner’s Ex. 2009, Page 28 of 77
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`
`Claim 4. The system of
`claim 1, wherein a remote
`server coupled with the
`mobile device over a
`network is configured to
`operate as the object
`identification platform.
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`Additionally and/or in the alternative to Claims 1 and 2, the
`BoA Accused Products meet this claim.
`
`For example, the BoA App operating on a customer’s mobile
`device, on information and belief, sends information of the
`check image to remote computers and servers owned,
`controlled, and/or operated by BoA to perform a data
`processing operations on at least a portion of the captured
`image to identify features relating to the displayed check, the
`features within the image of the check. Additionally, on
`information and belief, the remote computers and servers
`
`29
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`Patent Owner’s Ex. 2009, Page 29 of 77
`
`

`

`
`
`
`
`
`perform image and data processing functions associated with
`the BoA App, including verification, authentication,
`encryption, and data integrity, and check transaction
`processing. On information and belief, the remote computers
`and servers utilize the received check image and determine
`certain features to identify that a valid check document is
`present in the image and to distinguish the check from non-
`accepted documents using a database that stores data
`characteristics of an accepted check document, as well as
`process and determine features including MICR symbols,
`alphanumeric characters corresponding to the check payer and
`payee names, the dollar amount to be transferred to the payee,
`and routing and account numbers associated with the payer
`displayed on the check image. On information and belief,
`these features also include the payer’s signature and the
`payee’s endorsement of the check.
`
`See, e.g.:
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`https://www.bankofamerica.com/security-center/faq/online-
`banking/
`
`
`30
`
`
`
`
`
`Patent Owner’s Ex. 2009, Page 30 of 77
`
`

`

`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-
`check-deposit-faqs/
`
`
`
`
`
`
`31
`
`Patent Owner’s Ex. 2009, Page 31 of 77
`
`

`

`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`Deposit Receipt
`
`Bw @
`
`—e—e—e
`
`Your deposit is processing.
`
`Please write “Deposited” on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day
`
`—_
`mre.
`1a
`po Pip stews,
`=or ameneee > pe ee
`DODOOONORE
`LTHRLTET O10)
`x
`Churn fo Mam |
`
`Deposited To
`
`Total Deposit
`
`Checking
`
`$575.00
`
`
`
`
`Tap images to save, print or email
`
`Credit Pending,
`Posts On
`
`
`
`
`4/25/2020
`
`
`
`
`32
`32
`
`Patent Owner’s Ex. 2009, Page 32 of 77
`
`Patent Owner’s Ex. 2009, Page 32 of 77
`
`

`

`
`
`
`
`
`Claim 6. The system of
`claim 1, wherein at least
`one remote server coupled
`with the mobile device over
`a network operates as the
`content platform.
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer
`having a display. The BoA App operates to display an image
`of a check document to be deposited by a Bank of America
`customer on the screen of a the customer’s mobile device
`using the device’s integrated camera. The user then follows
`the prompts to send the check image deposit the check in their
`account. On information and belief, remote computers and
`servers owned, controlled, and/or operated by BoA receive
`
`33
`
`Patent Owner’s Ex. 2009, Page 33 of 77
`
`

`

`
`
`
`
`
`processed information from the check and the user’s request
`for deposit and process the check deposit in the user’s account.
`Once the deposit is completed, the BoA’s servers respond to
`the BoA App to confirm deposit to the user.
`
`See, e.g.:
`
`
`
`
`
`
`
`
`34
`
`Patent Owner’s Ex. 2009, Page 34 of 77
`
`

`

`
`
`—_@@ @
`
`Your deposit is processing.
`
`Deposit Receipt
`
`Bw @
`
`
`
`
`
`Please write "Deposited" on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day.
`
`
`=
`rr
`Pon
`aor Pulp
`Satobaipettae
`:
`Che fe Mastin
`Tap images to save, print or email
`
`!
`
`iil.
`é
`| F
`i
`Bias
`:
`i i
`
`Deposited To
`
`Total Deposit
`
`Credit Pending,
`Posts On
`
`Checking
`
`$575.00
`
`4/25/2020
`
`
`
`
`
`BOFA
`
`Your Mobile Check Deposit has been received.
`
`Your deposit is processing.
`
`|
`
`|
`
`Please write “Deposited” on your check and keepit for one
`week.
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day.
`
`:
`ry
`i
`_—
`Fes
`Fert Fe S5VOO ee
`saree Php Meerwey
`1S)
`dameofamanca
`E
`Chia F Martens
`
`.
`i
`'
`|
`|
`
`Tap images to save, print or email
`
`Deposited To
`
`Total Deposit
`
`ier
`a
`if iP
`1
`we
`aa
`A
`if iz
`B
`i a
`
`Checking
`
`$575.00
`
`Credit Pending,
`Posts On
`
`4/25/2020
`
`
`
`
`
`
`
`
`35
`35
`
`Patent Owner’s Ex. 2009, Page 35 of 77
`
`Patent Owner’s Ex. 2009, Page 35 of 77
`
`

`

`
`
`
`
`
`Claim 7. The system of
`claim 1, wherein the content
`platform is further
`configured to provide
`content information
`pertinent to the target object
`to the mobile device based
`on the object information.
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer
`having a display. The BoA App operates to display an image
`of a check document to be deposited by a Bank of America
`customer on the screen of a the customer’s mobile device
`using the device’s integrated camera. The user then follows
`the prompts to send the check image deposit the check in their
`account. On information and belief, the BoA App operating
`on a customer’s mobile device and/or BoA’s computers and
`servers process information and then receive the processed
`information from the check and the user’s request for deposit,
`and then process the check deposit in the user’s account. Once
`the deposit is completed, the BoA’s computer and servers
`respond to the BoA App to confirm deposit to the user based
`on the information from the check.
`
`See, e.g.:
`
`36
`
`Patent Owner’s Ex. 2009, Page 36 of 77
`
`

`

`
`
`
`
`
`
`Five thendlired Severty Five-CO/10O
`BANK OF AMERICA
`:
`=
`Cie F Martone 5
`BOOCCCOCONS
`«bis=N5R7" O1ON
`
`Ne
`Feee ogi
`
`
`
`aus
`
`
`
`
`
`Deposit To
`Available Balance
`
`Checking
`Available Balance: $686.96
`
`Amount
`
`Enter Amount
`
`>
`
`CANCEL
`
`CONTINUE
`
`
`
`
`
`
`
`
`37
`37
`
`Patent Owner’s Ex. 2009, Page 37 of 77
`
`Patent Owner’s Ex. 2009, Page 37 of 77
`
`

`

`
`
`—_@@ @
`
`Your deposit is processing.
`
`Deposit Receipt
`
`Bw @
`
`
`
`
`
`Please write "Deposited" on your check and keep it for one
`week,
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day.
`
`
`=
`rr
`Pon
`aor Pulp
`Satobaipettae
`:
`Che fe Mastin
`Tap images to save, print or email
`
`!
`
`iil.
`é
`| F
`i
`Bias
`:
`i i
`
`Deposited To
`
`Total Deposit
`
`Credit Pending,
`Posts On
`
`Checking
`
`$575.00
`
`4/25/2020
`
`
`
`
`
`BOFA
`
`Your Mobile Check Deposit has been received.
`
`Your deposit is processing.
`
`|
`
`|
`
`Please write “Deposited” on your check and keepit for one
`week.
`
`Funds deposited before 9 p.m. ET are generally available for
`withdrawal by the next business day.
`
`:
`ry
`i
`_—
`Fes
`Fert Fe S5VOO ee
`saree Php Meerwey
`1S)
`dameofamanca
`E
`Chia F Martens
`
`.
`i
`'
`|
`|
`
`Tap images to save, print or email
`
`Deposited To
`
`Total Deposit
`
`ier
`a
`if iP
`1
`we
`aa
`A
`if iz
`B
`i a
`
`Checking
`
`$575.00
`
`Credit Pending,
`Posts On
`
`4/25/2020
`
`
`
`
`
`
`
`
`38
`38
`
`Patent Owner’s Ex. 2009, Page 38 of 77
`
`Patent Owner’s Ex. 2009, Page 38 of 77
`
`

`

`
`
`
`
`
`Claim 13. The system of
`claim 1, wherein the
`transaction comprises a
`commercial transaction.
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer. The
`BoA App operating on a customer’s mobile device and/or
`BoA’s computers and servers process an image of a check
`document to be deposited by a Bank of America customer in
`the customer’s bank account, which is then deposited in the
`customer’s bank account, which is a commercial transaction.
`See, e.g.:
`
`
`39
`
`Patent Owner’s Ex. 2009, Page 39 of 77
`
`

`

`
`
`
`
`
`
`https://apps.apple.com/us/app/bank-of-america-mobile-
`banking/id284847138#?platform=iphone
`
`
`40
`
`Patent Owner’s Ex. 2009, Page 40 of 77
`
`

`

`
`
`
`
`
`
`https://play.google.com/store/apps/details?id=com.infonow.bof
`a
`
`
`
`
`
`
`41
`
`Patent Owner’s Ex. 2009, Page 41 of 77
`
`

`

`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`
`42
`
`Patent Owner’s Ex. 2009, Page 42 of 77
`
`

`

`
`
`
`
`
`Claim 16. The system of
`claim 1, wherein the
`selected account comprises
`an on-line account.
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer. The
`BoA App operating on a customer’s mobile device and/or
`BoA’s computers and servers process an image of a check
`document to be deposited by a Bank of America customer in
`the customer’s bank account, which is then deposited in the
`customer’s bank account, which is an on-line account for this
`process to work. See, e.g.:
`
`
`
`https://apps.apple.com/us/app/bank-of-america-mobile-
`banking/id284847138#?platform=iphone
`
`
`43
`
`Patent Owner’s Ex. 2009, Page 43 of 77
`
`

`

`
`
`
`
`
`
`https://play.google.com/store/apps/details?id=com.infonow.bof
`a
`
`
`
`
`
`
`44
`
`Patent Owner’s Ex. 2009, Page 44 of 77
`
`

`

`
`
`
`
`
`
`
`
`
`https://www.bankofamerica.com/online-banking/mobile-and-
`online-banking-features/mobile-check-deposit/
`
`
`
`
`45
`
`Patent Owner’s Ex. 2009, Page 45 of 77
`
`

`

`
`
`
`
`
`Claim 17. The system of
`claim 1, wherein the
`selected account comprises
`an account linked with the
`mobile device.
`
`To the extent that Defendants contend that the BoA Accused
`Products do not literally infringe the limitations of this claim,
`such differences are insubstantial and thus the claim
`limitations are satisfied under the doctrine of equivalents.
`The BoA Accused Products meet this claim.
`
`For example, the BoA App operates on a mobile device such
`as an iPhone, Android mobile device, or tablet computer. The
`BoA App operates within the mobile device, and is linked to
`the account of the user of the mobile device. The BoA App
`operating on a customer’s mobile device and/or BoA’s
`computers and servers process an image of a