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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________________
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`APPLE INC.,
`Petitioner
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`v.
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`BILLJCO LLC,
`Patent Owner
`
`
`CASE: IPR2022-00131
`U.S. PATENT NO. 9,088,868
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`_______________________
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`
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`DECLARATION OF ISTVAN JONYER, PH.D. REGARDING CLAIMS 1, 2,
`5, 20, 24, 25, 28, AND 43 OF U.S. PATENT 9,088,868
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`TABLE OF CONTENTS
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`INTRODUCTION ...................................................................................... 1
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`SUMMARY OF OPINIONS ...................................................................... 1
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`Education and Experience ................................................................ 3
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`Compensation .................................................................................. 6
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`I.
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`II.
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`III. QUALIFICATIONS AND EXPERIENCE ................................................ 3
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`A.
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`B.
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`C. Documents and Other Materials Considered .................................... 7
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`D.
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`Prior Testimony and Publications ..................................................... 7
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`IV. STATEMENT OF LEGAL PRINCIPLES ................................................. 8
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`A.
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`B. Obviousness ...................................................................................... 9
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`Claim Construction ........................................................................... 8
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`SCOPE OF OPINIONS ........................................................................... 11
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`V.
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`VI. OVERVIEW OF THE '868 PATENT ...................................................... 11
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`A.
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`B.
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`C.
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`D.
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`E.
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`The Specification and Drawings ..................................................... 12
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`The Claim Language ...................................................................... 14
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`Prosecution History......................................................................... 20
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`Persons of Ordinary Skill in the Art ............................................... 21
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`Claim Construction ......................................................................... 21
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`VII. HABERMAN DOES NOT RENDER ANY CHALLENGED CLAIM
`OBVIOUS ................................................................................................. 31
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`A. Haberman Fails to Disclose Or Make Obvious The Limitation:
`"Accepting User Input, From A User Of A Mobile Application
`User Interface Of A User Carried Mobile Data Processing
`System, For Configuring A User Specified Location Based
`Event Configuration To Be Monitored And Triggered By The
`Mobile Data Processing System Wherein The Mobile Data
`Processing System Uses The User Specified Location Based
`Event Configuration To Perform Mobile Data Processing
`System Operations" ........................................................................ 31
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`B. Haberman Fails To Disclose Or Make Obvious The Claim
`Limitation: "Determining The At Least One Location Based
`Condition Of The User Specified Location Based Event
`Configuration Including Whether The Identifier Data For The
`Wireless Data Record Received For Processing By The Mobile
`Data Processing System Matches The Third Identifier And The
`At Least One Of The First Identifier And The Second
`Identifier" ........................................................................................ 36
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`C. Haberman Fails To Disclose Or Make Obvious
`The Claimed "First Identifier," "Second Identifier"
`Or "Third Identifier" ........................................................................ 36
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`VIII. HABERMAN IN COMBINATION WITH BOGER
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`DO NOT RENDER ANY CHALLENGED CLAIM OBVIOUS ............ 40
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`IX. HABERMAN IN COMBINATION WITH EVANS
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`FAILS TO RENDER THE CHALLENGED CLAIMS
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`UNPATENTABLE AS OBVIOUS .......................................................... 43
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`X. HABERMAN IN COMBINATION WITH EVANS AND BOGER
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`FAILS TO RENDER THE CHALLENGED CLAIMS
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`UNPATENTABLE AS OBVIOUS .......................................................... 44
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`XI. OBJECTIVE INDICIA OF NON-OBVIOUSNESS ................................ 44
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`I, Istvan Jonyer, Ph.D., hereby declare as follows:
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`I.
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`
`INTRODUCTION
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`1.
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`I am a computer scientist, former academic, Google manager, and
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`technology entrepreneur with experience developing mobile device applications.
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`2.
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`I have been engaged by Patent Owner BillJCo LLC as a consultant in
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`connection with the present inter partes review by Petitioner Apple Inc.
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`3.
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`This Declaration sets forth the opinions I have formed and the bases for
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`them concerning patentability of claims 1, 2, 5, 20, 24, 25, 28, and 43 ("the
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`Challenged Claims") of U.S. Patent No. 9,088,868 ('868 Patent) (EX1001).
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`4.
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`I have relied on my knowledge, experience, and expertise in the
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`technologies involved, which I have acquired over my career, in providing the
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`analysis and opinions contained in this report. All of my conclusions and opinions
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`are provided within a reasonable degree of professional certainty.
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`SUMMARY OF OPINIONS
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`II.
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`5.
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`It is my opinion that, based on the evidence presented in the Petition,
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`none of the Challenged Claims are obvious under 35 U.S.C. § 103 in view of U.S.
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`Patent Application Publication No. 2005/0096044 ("Haberman") (EX1004). It is my
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`further opinion that a person of ordinary skill in the art would not have had any
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`reason to have modified Haberman as claimed in the Challenged Claims.
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`6.
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`It is my further opinion that, based on the evidence presented in the
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`Petition, none of the Challenged Claims are obvious under 35 U.S.C. § 103 in view
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`of Haberman in combination with U.S. Patent Application Publication No.
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`2002/0159401 ("Boger") (EX1005). It is my further opinion that a person of ordinary
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`skill in the art would not have had any reason to have combined Haberman with
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`Boger in the manner as claimed in the Challenged Claims.
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`7.
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`It is my further opinion that, based on the evidence presented in the
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`Petition, none of the Challenged Claims are obvious under 35 U.S.C. § 103 in view
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`of Haberman in combination with U.S. U.S. Patent 6,327,535 ("Evans") (EX1006).
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`It is my further opinion that a person of ordinary skill in the art would not have had
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`any reason to have combined Haberman with Evans in the manner as claimed in the
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`Challenged Claims.
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`8.
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`It is my further opinion that, based on the evidence presented in the
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`Petition, none of the Challenged Claims are obvious under 35 U.S.C. § 103 in view
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`of Haberman in combination with Evans and Boger. It is my further opinion that a
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`person of ordinary skill in the art would not have had any reason to have combined
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`Haberman with Evans and Boger in the manner as claimed in the Challenged Claims.
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`9.
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`It is further my opinion that Apple's devices accused of infringement in
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`a pending litigation between Apple and BillJCo (BillJCo, LLC v. Apple, Inc., 4:22-
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`cv-03201-YGR (N.D.Ca.)), meet the limitations of at least one claim of the '868
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`Patent.
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`10. The subsequent sections of this Declaration provide my qualifications
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`and experience and then my analysis and the bases for my opinions.
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`III. QUALIFICATIONS AND EXPERIENCE
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`A. Education and Experience
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`
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`11.
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`I earned a B.S. in Computer Science and Engineering, with high honors,
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`from the University of Texas at Arlington in May 1999, followed by an M.S. in
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`Computer Science and Engineering from the University of Texas at Arlington in
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`May 2000. I earned a Ph.D. in Computer Science and Engineering from the
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`University of Texas at Arlington in August 2003 focusing on machine learning and
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`artificial intelligence. I also earned an MBA, focusing on venture capital and
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`entrepreneurship, from Carnegie Mellon University's Tepper School of Business, in
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`May 2010.
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`12.
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`I started my career at Nortel Networks in June of 2000 as a software
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`design engineer and implemented software features for the first generation of 3G
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`mobile data communications back-end infrastructure devices such as the Shasta
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`Networks packet data switching node (PDSN). My work
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`included
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`the
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`implementation of the OpenRP protocol, tower handoff, logging and analytics, time
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`synchronization of the PDSN cards over an ATM network, performance
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`improvement of multimedia content serving and routing through the PDSN, as well
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`as the implementation of a traffic generator and simulator for capacity testing of the
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`PDSN. I was also the engineer in charge of developing and executing acceptance
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`testing for the Kyocera handset to be approved for Nortel Networks packet data
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`equipment.
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`13. Upon receiving my Ph.D., I accepted an assistant professor position
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`with Oklahoma State University and started my academic career in August of 2003.
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`In this capacity I performed scientific research in the areas of machine learning,
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`artificial intelligence, and computer networks, and taught undergraduate and
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`graduate courses in the fields of artificial intelligence, algorithms and data structures,
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`programming languages, programming language design, and social issues in
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`computing. I also advised Masters and Doctoral students on their thesis and
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`dissertation work, collaborated with faculty at Oklahoma State University and at
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`other research institutions, organized conference special tracks in the areas of
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`machine learning and data mining, and served as an expert reviewer to numerous
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`scientific publications, journals and conference proceedings. I have also served as a
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`grant reviewer to the National Science Foundation. I also designed and built, from
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`components, the largest supercomputing laboratory at the university with high-speed
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`networking and dedicated internal and external DNS servers.
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`14.
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`In 2007, I started a company, KDResearch, in the field of stock option
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`screening based on data science. I developed and configured a hybrid cloud/on-
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`premise web application with real-time streaming data.
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`15.
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`In 2008, I enrolled in the MBA program at the Tepper School of
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`Business at Carnegie Mellon University, where I specialized in entrepreneurship and
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`venture capital. In the fall of 2008, I was recruited by a venture capital firm in
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`Pittsburgh, PA, called Pittsburgh Equity Partners, where I generated deal flow and
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`performed technical and business due diligence. In the summer of 2009, I completed
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`an internship at a venture capital firm, New Venture Partners, with $1.2 billion in
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`assets under management.
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`16.
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`In August of 2010, I accepted a position with Google to become the
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`head of global device partnerships of the Google TV product line. In this capacity I
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`headed up a team in Mountain View, CA, and Seoul, Korea, to interface with our
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`launch partners Intel, Marvel, MediaTek, Samsung, Sony, Logitech, LG, Sharp,
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`Vizio, and others.
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`17.
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`In February of 2012, I left Google to start a company, called
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`FantasyBrain, in the area of fantasy sports. We used a data science approach to build
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`large fantasy sports communities. I personally designed and implemented over 90%
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`of the codebase, including the front-end, the back-end, and our novel algorithms.
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`18. Starting in the fall of 2013, I worked for a number of Silicon Valley-
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`based startups including, Rescale, Near-Me, and 3Gear Systems (later NimbleVR)
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`in various capacities. In August of 2014, I designed and implemented a photo and
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`video sharing mobile app on the Android platform that facilitated person to person
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`visual communications using minimal user interaction.
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`19.
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`In March of 2015, I joined the newly formed venture capital firm
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`NexStar Partners with $100 million in assets under management as Principal, where
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`I drove deal flow and due diligence activities in the areas of content delivery, mobile
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`and streaming media, virtual reality and augmented reality, artificial intelligence and
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`machine learning, Internet of Things, and mobile telecommunications.
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`20.
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`In the fall of 2018, I started my consulting practice in the areas of
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`litigation consulting, technical and business due diligence, and investment advisory.
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`The list of my previous and current consulting engagements is included in my CV,
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`attached as Exhibit A to this Declaration.
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`B. Compensation
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`21.
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`I am being compensated for my time at the rate of $500 per hour. The
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`compensation is not contingent upon my performance, the outcome of this or any
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`other proceeding, or any issues involved in or related to this matter.
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`C. Documents and Other Materials Considered
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`22.
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`In addition to my education, training, and knowledge, my opinions are
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`based on review of the documents and other materials identified in this Declaration,
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`including the '868 Patent and its prosecution histories, the prior art references cited
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`by Petitioner, the prior art references discussed during prosecution of the '868 Patent,
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`certain technical dictionaries, and background materials discussed in this
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`Declaration, and any other references specifically identified in this Declaration. A
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`list of documents and materials that I reviewed in the course of preparing this
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`Declaration is attached as Exhibit B.
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`D.
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`Prior Testimony and Publications
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`23.
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`I have not authored any publications within the last ten years.
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`24.
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`In addition to this case, I have submitted declarations, reports, and
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`testimony in the last four years in the following cases:
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`• Declaration: IPR2022-00131, Apple Inc. v. BillJCo LLC, United States
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`Patent and Trademark Office.
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`• Declaration: IPR2022-00129, Apple Inc. v. BillJCo LLC, United States
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`Patent and Trademark Office.
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`• Expert Report and Deposition: Mon Cheri Bridals, LLC and Maggie
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`Sottero Designs, LLC v. Cloudflare, Inc. Case No.: 19-cv-01356-VC,
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`United States District Court, Northern District of California, San Francisco
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`Division.
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`• Declaration: Unified Patents, LLC v. Investel Capital Corporation.
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`IPR2020-00781, United States Patent and Trademark Office, Patent Trial
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`and Appeal Board.
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`• Declaration: Uzair, et al v. Google. Case No. 18-CV-328915, Superior
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`Court of the State of California, County of Santa Clara.
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`• Declaration and Deposition: Sleep Number Corporation v. Steven Jay
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`Young; Carl Hewitt; UDP Labs, Inc. United States District Court for The
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`District of Minnesota. Court File No. 20-cv-01507-NEB-ECW.
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`IV. STATEMENT OF LEGAL PRINCIPLES
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`25.
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`I have been advised of certain legal principles applicable to this inter
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`partes review. I have incorporated and applied these legal principles within the
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`opinions set forth below in this Declaration.
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`A. Claim Construction
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`26.
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`I understand that patent claims are to be interpreted in view of the claim
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`language itself, a patent's specification, and the prosecution history. I understand that
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`claim construction starts with the plain language of the claims as understood by a
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`person having ordinary skill in the art at the time the patent was filed. I am further
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`informed that a patent's specification is always highly relevant to the claim
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`construction analysis and usually dispositive of the meaning. I also understand that
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`the prosecution history may also provide evidence of how the PTO and the inventor
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`understood the patent. I also understand that extrinsic evidence, such as technical
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`dictionaries, may provide insight as to the meaning of technical terms.
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`27.
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`I understand that a patentee may be its own lexicographer, so long as
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`the definition of a specific term is clearly set forth in the specification and it is clear
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`the inventor intended to define the term.
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`28.
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`I further understand that Petitioner does not contend that any claim term
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`should be given a special meaning, and instead, has taken the position that the claim
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`terms should be given their plain and ordinary meanings. See Petition at 6.
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`B. Obviousness
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`29.
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`I understand that a patent claim may be found invalid as obvious if the
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`differences between the claimed invention and the prior art are such that the claimed
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`invention as a whole would have been obvious before the effective filing date of the
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`claimed invention to a person having ordinary skill in the art to which the claimed
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`invention pertains. I further understand that obviousness of a patent claim is
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`determined based on (1) the scope and content of the prior art; (2) the differences
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`between the claims and the prior art; (3) the level of ordinary skill in the art; and (4)
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`objective indicia of non-obviousness.
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`30.
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`I understand that in assessing the prior art, one must consider whether
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`a POSITA would have been motivated to combine the prior art or modify the
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`references to achieve the claimed invention, and whether there would have been a
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`reasonable expectation of success in doing so. I understand that this motivation may
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`come from a teaching, suggestion, or motivation to combine. I also understand that
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`a specific teaching, suggestion, or motivation is not required.
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`31.
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`I also understand that objective indicators of non-obviousness
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`(sometimes referred to as "secondary considerations") must be considered in
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`evaluating obviousness, including commercial success of the claimed invention,
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`whether others copied the invention, whether others in the field praised the
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`invention, and licensing of the invention. I understand that secondary considerations
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`of non-obviousness support a finding of non-obviousness if the evidence of
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`secondary considerations is sufficiently tied to the patented features. Where a patent
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`claims a combination of features, I understand that the evidence of secondary
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`considerations may be tied to the claimed combination as a whole.
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`32.
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`I understand that, after consideration of all of these factors, a patent is
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`not obvious unless the difference between the subject matter sought to be patented
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`and the prior art are such that the subject matter as a whole would have been obvious
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`at the time the invention was made to a person having ordinary skill in the art to
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`which said subject matter pertains.
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`V.
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`SCOPE OF OPINIONS
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`33.
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`I have been asked only to provide my independent opinions and
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`analysis of the issues I specifically discuss in this declaration. I note that the Petition
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`(and the evidence it cites) may raise other issues, but I have not been asked to provide
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`my opinions as to any of those other issues.
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`VI. OVERVIEW OF THE '868 PATENT
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`34. On July 21, 2015, the '868 Patent was issued by the United States Patent
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`and Trademark Office. The title of the '868 Patent is "Location Based Exchange
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`Permissions."
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`35.
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`In furtherance of its title, the '868 patent describes, in part, "location
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`based exchanges of data between distributed mobile data processing systems for
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`locational applications." Ex. 1001, 1:20-24. The '868 patent states that the
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`"[a]dvantages of having a service as the intermediary point between clients, users,
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`and systems, and their associated services, include[] centralized processing,
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`centralized maintaining of data,. . . [and] having a supervisory point of control." Id.
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`at 1:39—46. The '868 Patent also explains that "[w]hile a centralized service has its
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`advantages, there are also disadvantages." Id. at 1:66-67. For example, according to
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`the '868 patent, a centralized service may "suffer from performance and maintenance
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`overhead" and presents concerns about the "privacy" of users' "personal
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`information." Id. at 2:6-7, 2:43-53.
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`36. To that end, the '868 Patent Abstract states that the "Information which
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`is transmitted inbound to, transmitted outbound from, or is in process at, a mobile
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`data processing system, is used to trigger processing of actions in accordance with
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`user configured permissions, charters, and other configurations. Id. at p. 1, Abstract.
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`A. The Specification and Drawings
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`37. The '868 Patent describes a modification of earlier architectures, which
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`it calls Location Based Services (LBS), to leverage the computing capabilities of
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`mobile devices in Location Based Exchanges (LBX). According to the '868 Patent,
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`"LBS (Location Based Services) is a term which has gained in popularity over the
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`years as MSs incorporate various location capability. … This disclosure introduces
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`a new terminology, system, and method referred to as Location Based eXchanges
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`(LBX). … LBX describes leveraging the distributed nature of connectivity between
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`MSs in lieu of leveraging a common centralized service nature of connectivity
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`between MSs. … The underlying architectural shift differentiates LBX from LBS
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`for depending less on centralized services, and more on distributed interactions
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`between MSs. LBX provides server-free and server-less location dependent features
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`and functionality.” EX1001; Col. 3:53 – Col. 4:8.
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`38.
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`In order to address user privacy concerns, the '868 Patent describes the
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`use of "permissions" and "privileges."
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`39.
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`It should be noted that the '868 Patent states that "[t]he terminology
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`'permissions' and 'privileges' are used interchangeably in this disclosure." EX1001,
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`123:59-61.
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`40. The '868 Patent explains it is preferred that "permissions are maintained
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`in a peer to peer manner prior to lookup for proper service sharing. In another
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`embodiment, permissions are specified and used at the time of granting access to the
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`shared services." EX1001, 10:30-33.
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`41. The '868 Patent states as an objective that a "method and system is
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`needed for making users comfortable with knowing that their personal information
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`is at less risk of being compromised." Id. at 2:56-58. To that end, the '868 Patent
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`teaches "[i]t is another advantage herein for providing peer to peer permissions,
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`authentication, and access control." Id. at 10:45-46. Also, "[w]hile wireless
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`proximity is used for governing automatic location determination, whereabouts
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`information may be communicated between MSs great distances from each other
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`provided there are privileges and/or charters in place making such whereabouts
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`information relevant for the MS. Whereabouts information of others will not be
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`maintained unless there are privileges in place to maintain it. Whereabouts
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`information may not be shared with others if there have been no privileges granted
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`to a potential receiving MS. Privileges can provide relevance to what whereabouts
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`(WDR) information is of use, or should be processed, maintained, or acted upon."
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`Id. at 12:53-64.
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`42. The '868 Patent also discloses that "[i]t is another advantage to support
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`a countless number of privileges that can be configured, managed, and processed in
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`peer to peer manner between MSs. Any peer to peer feature or set of functionality
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`can have a privilege associated to it for being granted from one use to another. It is
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`also an advantage for providing a variety of embodiments for how to manage and
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`maintain privileges in a network of MSs." EX1001, 12:28-34.
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`B.
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`The Claim Language
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`43.
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`Independent claim 1 of the '868 Patent recites in pertinent part:
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`A method, comprising:
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`accepting user input, from a user of a mobile application user interface of a
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`user carried mobile data processing system, for configuring a user specified
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`location based event configuration to be monitored and triggered by the
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`mobile data processing system wherein the mobile data processing system
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`uses the user specified location based event configuration to perform mobile
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`data processing system operations comprising:
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`accessing at least one memory storing a first identifier and a second
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`identifier and a third identifier wherein each identifier is determined by the
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`mobile data processing system for at least one location based condition
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`monitored by the mobile data processing system for the mobile data
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`processing system triggering a location based action, the location based
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`action performed by the mobile data processing system upon the mobile data
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`processing system determining the at least one location based condition
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`including whether identifier data determined by the mobile data processing
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`system for a wireless data record received for processing by the mobile data
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`processing system matches the third identifier and at least one of the first
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`identifier and the second identifier, the wireless data record corresponding to
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`a beaconed broadcast wireless data transmission that is beaconed outbound
`
`from an originating data processing system to a destination data processing
`
`system, the first identifier indicative of the mobile data processing system of
`
`the mobile application user interface for use by the mobile data processing
`
`system in comparing the first identifier to the identifier data determined by
`
`the mobile data processing system for the wireless data record received for
`
`processing by the mobile data processing system, the second identifier
`
`indicative of originating data processing system identity data of the wireless
`
`data record received for processing for use by the mobile data processing
`
`system in comparing the second identifier to the identifier data determined
`
`by the mobile data processing system for the wireless data record received
`
`for processing by the mobile data processing system, the third identifier
`
`40550969.1
`
`15
`
`BILLJCO
`EXHIBIT 2008 - Page 18 of 55
`
`
`
`
`
`indicative of the originating data processing system of the wireless data
`
`record received for processing wherein the third identifier is monitored by
`
`the mobile data processing system for use by the mobile data processing
`
`system in comparing the third identifier to the wireless data record received
`
`for processing by the mobile data processing system;
`
`receiving for processing the wireless data record corresponding to the
`
`beaconed broadcast wireless data transmission that is beaconed outbound
`
`from the originating data processing system to the destination data
`
`processing system;
`
`determining the identifier data for the wireless data record received
`
`for processing by the mobile data processing system; comparing the
`
`identifier data for the wireless data record received for processing by the
`
`mobile data processing system with the third identifier and the at least one of
`
`the first identifier and the second identifier;
`
`determining the at least one location based condition of the user
`
`specified location based event configuration including whether the identifier
`
`data for the wireless data record received for processing by the mobile data
`
`processing system matches the third identifier and the at least one of the first
`
`identifier and the second identifier; and
`
`40550969.1
`
`16
`
`BILLJCO
`EXHIBIT 2008 - Page 19 of 55
`
`
`
`
`
`performing, upon the determining the at least one location based
`
`condition, the location based action in accordance with the determining the
`
`at least one location based condition of the user specified location based
`
`event configuration including whether the identifier data for the wireless
`
`data record received for processing by the mobile data processing system
`
`matches the third identifier and the at least one of the first identifier and the
`
`second identifier.
`
`EX1001, 283:55-284:65.
`
`44.
`
`Independent claim 24 is similar to claim 1, but claims a system. Claim
`
`24 recites:
`
`A user carried mobile data processing system, comprising:
`
`one or more processors; and
`
`memory coupled to the one or more processors, wherein the memory
`
`includes executable instructions which, when executed by the one or more
`
`processors, results in the mobile data processing system accepting user
`
`input, from a user of a mobile application user interface of the mobile data
`
`processing system, for configuring a user specified location based event
`
`configuration to be monitored and triggered by the mobile data processing
`
`system wherein the mobile data processing system uses the user specified
`
`location based event configuration to perform mobile data processing system
`
`40550969.1
`
`17
`
`BILLJCO
`EXHIBIT 2008 - Page 20 of 55
`
`
`
`
`
`operations comprising: accessing at least one memory storing a first
`
`identifier and a second identifier and a third identifier wherein each
`
`identifier is determined by the mobile data processing system for at least one
`
`location based condition monitored by the mobile data processing system for
`
`the mobile data processing system triggering a location based action, the
`
`location based action performed by the mobile data processing system upon
`
`the mobile data processing system determining the at least one location
`
`based condition including whether identifier data determined by the mobile
`
`data processing system for a wireless data record received for processing by
`
`the mobile data processing system matches the third identifier and at least
`
`one of the first identifier and the second identifier, the wireless data record
`
`corresponding to a beaconed broadcast wireless data transmission that is
`
`beaconed outbound from an originating data processing system to a
`
`destination data processing system, the first identifier indicative of the
`
`mobile data processing system of the mobile application user interface for
`
`use by the mobile data processing system in comparing the first identifier to
`
`the identifier data determined by the mobile data processing system for the
`
`wireless data record received for processing by the mobile data processing
`
`system, the second identifier indicative of originating data processing system
`
`identity data of the wireless data record received for processing for use by
`
`40550969.1
`
`18
`
`BILLJCO
`EXHIBIT 2008 - Page 21 of 55
`
`
`
`
`
`the mobile data processing system in comparing the second identifier to the
`
`identifier data determined by the mobile data processing system for the
`
`wireless data record received for processing by the mobile data processing
`
`system, the third identifier indicative of the originating data processing
`
`system of the wireless data record received for processing wherein the third
`
`identifier is monitored by the mobile data processing system for use by the
`
`mobile data processing system in comparing the third identifier to the
`
`wireless data record received for processing by the mobile data processing
`
`system;
`
`receiving for processing the wireless data record corresponding to the
`
`beaconed broadcast wireless data transmission that is beaconed outbound
`
`from the originating data processing system to the destination data
`
`processing system; determining the identifier data for the wireless data
`
`record received for processing by the mobile data processing system;
`
`comparing the identifier data for the wireless data record received for
`
`processing by the mobile data processing system with the third identifier and
`
`the at least one of the first identifier and the second identifier;
`
`determining the at least one location based condition of the user
`
`specified location based event configuration including whether the identifier
`
`data for the wireless data record received for processing by the mobile data
`
`40550969.1
`
`19
`
`BILLJCO
`EXHIBIT 2008 - Page 22 of 55
`
`
`
`
`
`
`
`processing system matches the third identifier and the at least one of the first
`
`identifier and the second identifier; and
`
`performing, upon the determining the at least one location based
`
`condition, the location based action in accordance with the determining the
`
`at least one location based condition of the user specified location based
`
`event configuration including whether the identifier data for the wireless
`
`data record received for pr
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