Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`Apple, Inc. (“Apple”) hereby contends that the asserted claims (claims 1-17) of U.S. Patent No. 9,240,009 (“the ’009 patent”) are invalid as
`anticipated and/or rendered obvious by U.S. Publication No. 2006/0165060 (“Dua”) under 35 U.S.C. §§ 102 and/or 103, alone or in view of the
`knowledge and skill of one in the art at the time and/or any other prior art reference identified herein or within the related pleading, including, but not
`limited to, GlobalPlatform Card Specification Version 2.1.1 (“GlobalPlatform”), Smart Card Handbook Third Edition, by Wolfgang Rankl and
`Wolfgang Effing (2003) (“Smart Card Handbook”), and U.S. Patent Application Publication No. 2006/0174352 (“Thibadeau”). Dua was filed on
`January 21, 2005, and published on July 27, 2006. GlobalPlatform was published on March 2003. Smart Card Handbook was available at the Linda
`Hall Library and was cataloged by subject matter at the Library of Congress in 2003. Thibadeau was filed on January 31, 2006, and published on
`August 3, 2006.
`The chart below discloses how the aforementioned prior art reference discloses, either expressly or inherently, and/or renders obvious each of
`the asserted claims. The citations provided are exemplary and do not necessarily include each and every disclosure of the limitation in the references.
`Apple has endeavored to cite to the most relevant portions of the identified prior art, but other portions of the identified prior art may additionally
`disclose, either expressly or inherently, and/or render obvious one or more limitations of the asserted claims. Thus, Apple reserves the right to rely on:
`(1) uncited portions of the identified prior art; (2) other prior art not identified herein; (3) references that show the state of the art (irrespective of
`whether such references themselves qualify as prior art to the asserted patents); (4) factual testimony from the inventors or authors of the prior art
`references, or purveyors of prior art devices; and/or (5) expert testimony, to provide context to or aid in understanding the prior art and the state of the
`art at the time of the alleged inventions.
`The lack of a citation for an element should not be deemed an admission that the element is not disclosed or is not inherent in the reference.
`When the chart indicates a particular reference discloses or embodies a limitation, the terms “discloses,” “disclosed,” “embodies,” and “embodied”
`refer to explicit and/or inherent disclosure and/or obvious variations of the actual disclosure. Further, for each claim limitation that Apple contends is
`indefinite, Apple has used its best efforts to reasonably interpret the claims to fulfill their duties in charting the prior art references.
`Where Apple cites to a particular drawing or figure in the accompanying charts, the citation encompasses the description of the drawing or
`figure, as well as any text associated with the drawing or figure. Similarly, where Apple cites to particular text concerning a drawing or figure, the
`citation encompasses that drawing or figure as well. Certain identified prior art inherently discloses features of the asserted claims. Apple reserves the
`right to rely on inherency to demonstrate the invalidity of the asserted claims. Moreover, certain prior art references may inherently disclose certain
`features of the asserted claims as construed by RFCyber. Apple may rely on cited or uncited portions of the prior art, other documents, factual testimony,
`and expert testimony to establish the inherency of certain features of the prior art to invalidate the asserted claims.
`The exemplary disclosures identified below disclose and/or render obvious the asserted claims as Defendant currently understands them,
`including based on Plaintiff’s infringement contentions. No disclosure or statement below is intended to assert or agree with any particular claim
`
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
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`construction position and Defendant reserves the right to advance and rely on positions regarding claim construction and noninfringement regardless
`of the disclosures asserted herein.
`
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`Claim
`No.
`1[pre]
`
`’009 Patent Claim Limitation
`
`A mobile device for conducting a
`secured transaction over a network, the
`mobile device comprising:
`
`WEST\297652083.1
`
`U.S. Patent 9,240,009 (the ’009 Patent)
`Exemplary disclosure
`
`To the extent the preamble is limiting, Dua discloses the mobile device for conducting a
`secured transaction over a network, the mobile device comprising:
`For Example:
`See Claim 1.
`“The present invention relates generally to systems and methodologies for conducting
`electronic commerce and more particularly to systems and methodologies for issuing,
`managing, storing and using credentials authorizing the legitimate holder of Such a credential
`to accomplish a desired result.”
`“Another important trend in consumer-related electronics is the increased speed and the reduced
`size of available electronic components which has contributed to the proliferation of powerful
`wireless devices. Mobile devices including personal digital assistants (PDAs) and cellular
`phones now number over one billion worldwide. The capability of wireless devices has been
`augmented by their ability to connect to the Internet and also to exchange data over short ranges
`with other wireless devices or readers.”
`“As stated above, the present invention preferably involves the distribution of credentials to a
`“wireless device”. As used herein, wireless device 200 is preferably a device that is capable of
`wirelessly connecting to the Internet using network protocols such as GSM/GPRS,
`CDMA2000, W-CDMA, EDGE, HDR, 1xRTT, UMTS, IMT-2000, 802.11a, 802.11b,
`802.11g, or BLUETOOTH or other relevant protocols developed hereinafter. Preferably,
`wireless device 200 has a display screen and a key pad for alphanumeric and special character
`data input. It is further preferred that wireless device 200 has processing and secure storage
`capabilities allowing it to host and operate a wallet application capable of receiving, storing,
`managing and transmitting multiple payment, identification, and other confidential information
`electronically. Wireless device 200 also preferably has an
`integrated short-range
`communication capability for transmitting confidential information and exchanging other data
`between the wallet application and an external reader that is in proximity to the wireless
`device.”
`
`3
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`“FIG. 3 illustrates some of the SIP components, their relationship to one another and the
`protocols that are employed. A user agent acting as a client (in this case the issuer WCM 410
`which is in communication with issuer card management system 420) uses SIP to set up a
`session with a user agent that acts as a server (in this case a wallet application operating on
`user's wireless device 400). The session initiation dialogue uses SIP and involves one or more
`proxy servers to forward requests and responses between the two user agents. The user agents
`also make use of the SDP, which is used to describe the media session.”
`“Mobile transactions can be performed in three environments: local, remote, and personal. Each
`environment has its own mobile commerce services and characteristics that may require
`specific technologies. A wallet application on a wireless device that enables transactions in all
`three environments will provide the greatest utility to users. Electronic credentials issued to a
`user and stored in the wallet application can be used in all three environments.”
`“As can be seen in FIG. 8, a first transmission path of an electronic credit card authorization
`request 870 includes, for example, a merchant store controller and merchant host system, an
`acquirer/processor network, a private network Such as VisaNet, and a issuer gateway. Using
`these components, point of sale terminal 860, via RF reader 820 can be used to capture and
`transmit an electronic credential from a wireless device for online authorization. The second
`transmission path as shown in FIG. 8 is via WCM 810 using the Internet and wireless link 880
`and issuer DNS server 890 and is used to deliver a PIN request to wireless device 800 and to
`receive a user-input response from wireless device 800.”
`Dua ¶¶ [0002], [0015], [0041], [0107], [0313], [0405].
`
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`Exhibit D-2 – Invalidity Chart Regarding
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`WEST\297652083.1
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`Dua at FIGs. 1, 3, and 8.
`
`7
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`
`Dua discloses a network interface.
`For Example:
`See 1[pre], which is incorporated by reference.
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`
`8
`
`1[a]
`
`a network interface;
`
`WEST\297652083.1
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`
`Dua discloses an interface to receive a secure element.
`For Example:
`See 1[pre]-1[a], which are incorporated by reference.
`“There are three general categories of smart cards: contact, contactless, and hybrid Smart
`cards. A contact Smart card requires that the user insert the Smart card into a Smart card
`reader with a direct connection to a conductive micro-module on the surface of the card. It is
`via these physical contact points, that transmission of commands, data, and card status takes
`place.”
`“A wireless device loaded with the wallet application may come with some pre-loaded
`extensions. Extensions may reside on the device memory, in an embedded Smart card, in a
`removable storage media, or on a remote server, securely accessible through the wallet
`application protocols. An extension may communicate with the user, may exchange
`information with remote servers or it may use other elements of the device hardware or
`software.”
`
`9
`
`1[b]
`
`an interface to receive a secure
`element;
`
`WEST\297652083.1
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`“The wallet shell is the core of the wallet platform. The wallet application handles processing
`of incoming credentials and extensions, the execution of extensions within the wallet
`framework, controlling access to secure storage, enabling communication with an embedded
`RF interface or Smart card, and facilitating the use of operating system and hardware features
`such as display and sound.”
`Dua ¶¶ [0008], [0295], [0309]
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`
`1[c]
`
`a memory space for storing at least a
`module and an application downloaded
`from the network;
`
`Dua discloses a memory space for storing at least a module and an application downloaded
`from the network.
`For Example:
`
`WEST\297652083.1
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`

`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`See 1[pre]-1[b], which are incorporated by reference.
`“Smart cards provide a distinct advantage in that they offer the ability to provide
`authentication in connection with a transaction. Card authentication can be performed by the
`reader terminal and/or the issuer's systems using dynamic techniques that distinguish genuine
`cards from clones. A Smart card generally includes an embedded semiconductor device which
`is programmed before issue with the account holders information. This data is protected
`through secure encryption methods, making it difficult to fraudulently replicate a Smart card.
`The integrated circuits within Smart cards in general have continued to improve with
`miniaturization, low power requirements, the addition of strong encryption capability, and
`tamper-proof standards for crypto-processor chips”
`“As a result of the increased move towards standardization, improving technology and more
`demanding security and authorization requirements, Smart cards are slowly replacing the
`magnetic stripe card as the dominant technology for conducting financial transactions. The
`enhanced ability of smart cards to secure confidential information and the ability of POS
`systems to authenticate the chip cards makes them an attractive alternative to magnetic stripe
`cards. Also, the reduction of fraudulent transactions achieved by smart cards results in lower
`risk, and lower fees for the consumer and the merchant.”
`“Depending on the situation, SIP messages between the WCM and the wallet application on
`the wireless device can carry any supported content types in its payload (e.g. WML, HTML,
`XHTML, gif, text and others). SIP payload content could include encryption keys, encryption
`algorithms, forms, user authentication information (e.g. user names, passwords, PINs, and
`answers to secret questions), Software extensions the issuer wants to register with the wallet
`application, Software updates, electronic credentials, updates to existing credentials, graphics
`that are part of the credentials, and other Such information.”
`“These are just a few examples of the types of credentials that can be issued to and stored
`within the wallet application. Implementing electronic versions of these credentials in the
`wallet application creates different operating and processing requirements for each credential.
`Consider the requirements associated with implementing the Subway stored value credential
`through the wallet platform. The logic required to operate the Subway stored value credential,
`the unique message format for communication between the wireless device and a RF reader at
`the turnstile, unique display messages, an over-the-air reload tool, and other features
`11
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`

`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`associated with the stored value credential that a user might see on the wireless device—all
`need to be programmed into the wallet application. These types of requirements are embodied
`in mini-programs that operate within the wallet application called “extensions' since they
`“extend the capability of the wallet application in order to handle new features and
`capabilities that are specific to an issuer's credential. These extensions allow credentials to be
`used in a controlled way through specific issuer-defined functions.”
`Dua ¶¶ [0007], [0014], [0215], [0293].
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`For example:
`GlobalPlatform pp.19, 29, 31(§3.5), 39(§5.1.1.), pp.62(§6.4.1), 63(§6.4.1.1), 65(§6.4.1.2)
`Dua discloses “a novel system and methodology for conducting financial and other transactions
`requiring authorization” that involves the secure distribution, and personalization, of
`12
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`

`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`applications to a “handheld device such as a mobile telephone via a wireless network.” Dua,
`¶[0026]. Dua’s systems/methods may use a wireless device that “has processing and secure
`storage capabilities allowing it to host and operate a wallet application capable of receiving,
`storing, managing and transmitting multiple payment, identification, and other confidential
`information electronically”
`through a wireless
`interface or
`through a short-range
`communication capability. Id., ¶¶[0041], [0309]. The wireless device includes a smart card that
`can be programmed with an account holder’s information, keys and authentication information
`that provides for authentication in connection with a transaction and protects data through
`secure encryption methods. Id., ¶¶[0007], [0215], [0295].
`Dua refers to credit card organizations “working jointly over the last few years to develop
`specifications that define a set of requirements for security and interoperability between chip
`cards and terminals on a global basis, regardless of the manufacturer, financial institution, or
`where the card was used,” which a POSITA would recognize as including GlobalPlatform. Id.,
`¶[0014]; GlobalPlatform, p.16(§1); Ex1003, ¶¶99-100, Smart Card Handbook, p.290, 950.
`Indeed, GlobalPlatform discloses “a hardware-neutral, vendor-neutral, Application-
`independent [smart] card management specification” that provides a security architecture that
`protects the “structure and function of cards within the GlobalPlatform system” for the life of
`the card—thus providing a “secure element” as claimed. GlobalPlatform, pp.16, 32. Dua’s
`“wallet application should meet standards defined by card organizations,” and GlobalPlatform
`was specifically developed by such card organizations. Dua, ¶[0525]; GlobalPlatform, p.16.
`For these reasons alone, a POSITA would be motivated to and would find it obvious to employ
`the well-known GlobalPlatform system with Dua’s smart cards. Id.
`Moreover, Dua discloses the use of a Java platform and Java applets with its wireless devices,
`which a POSITA would recognize as being a reference to Java Card. Dua, ¶¶[0195], [0500].
`GlobalPlatform is designed to be compatible with Java Card. GlobalPlatform, p.24(§1.5.2.10);
`see also id. p.29(§3.1) (“GlobalPlatform is intended to run on top of any secure, multi-
`application card runtime environment.”). And, GlobalPlatform “has primarily become the de
`facto standard for loading and managing Java-based applications with the Java Card operating
`system. Smart Card Handbook, p.290. This further confirms a POSITA would be motivated to
`and would find it obvious to use GlobalPlatform with Dua’s smart cards.
`
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`

`1[d]
`
`a processor coupled to the memory
`space and configured to execute the
`module to perform operations
`including:
`
`1[e]
`
`sending to a server via the network
`interface an identifier identifying the
`application together with device
`information of a secure element,
`
`WEST\297652083.1
`
`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`Dua discloses a processor coupled to the memory space and configured to execute the module
`to perform operations.
`For Example:
`See 1[pre]-1[c], which are incorporated by reference.
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`For example:
`GlobalPlatform pp..62(§6.4.1), 63(§6.4.1.1), 65(§6.4.1.2)
`Dua discloses sending to a server via the network interface an identifier identifying the
`application together with device information of a secure element, wherein the application is
`downloaded from the network in the mobile device.
`For Example:
`
`14
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`

`wherein the application is downloaded
`from the network in the mobile device;
`
`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`See 1[pre]-1[d], which are incorporated by reference.
`“The present invention, in a preferred embodiment provides for using some of the SIP-
`network infrastructure that mobile operators will have in place to deliver credentials from
`SIP-based Wireless Credential Manager (WCM) 110 at an issuer site to a SIP-based wallet
`application on a wireless device 200. The system disclosed herein is designed to interoperate
`with mobile 2.5G, 3G, and Wi-Fi networks among others.”
`“In the next example, the 180 (Ringing) response is routed to the Sample Bank WCM 510. In
`this example, Bob decides to allow connectivity with the Sample Bank server 510 by pressing
`a key on his phone (as prompted for by the wallet application). After he presses the
`appropriate key to accept connectivity with Sample Bank’s server 510, his SIP phone 500
`sends a 200 (OK) response to indicate that the call has been answered by the wallet
`application. The 200 (OK) contains a message body with the SDP media description of the
`type of session that the wallet application running on Bob's SIP phone 500 is willing to
`establish with the Sample Bank WCM 510. As a result, there is a two-phase exchange of SDP
`messages: the WCM 510 sent one to Bob's wallet application, and the wallet application sent
`one back to the WCM 510. This two-phase exchange provides basic negotiation capabilities
`and is based on a simple offer/answer model of SDP exchange. If Bob did not wish to answer
`the communication from Sample Bank or was busy on a phone call, an error response would
`have been sent instead of the 200 (OK), which would have resulted in no media session being
`established between the wallet application on Bob's phone 500 and the Sample Bank WCM
`510. The complete list of SIP response codes is in Section 21 of RFC 3261. The 200 (OK)
`(message F9 in FIG. 4) might look like this as Bob's wallet application sends it out:”
`“The open-architecture of the wallet platform allows credential issuers to deploy their own
`commerce-specific applications called “extensions’. Extensions literally “extend the
`capability of the wallet platform by enabling a new set of features defined by the credential
`issuer. Different credentials serve many unique purposes and are not all used in the same
`way.”
`Dua ¶¶ [0104], [0160], [0289].
`To the extent that this element is not explicitly disclosed, a POSITA would have found this
`element obvious in light of this reference in combination with the knowledge and skill of a
`POSITA and/or one or more of the other prior art references identified by Defendants. For
`15
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`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)
`
`example, a POSITA would have recognized and understood that the teachings of this
`reference could be modified, combined, or replaced with the teachings from the other
`identified prior art references, including, but not limited to, the disclosures identified in the
`following documents and charts related to this limitation:
`
`See, e.g, APL-RFC0916-PA-00000001 - APL-RFC0916-PA-00021141
`See, e.g., “D” Charts regarding the ’009 patent
`
`A POSITA would have been motivated to combine the teachings of these references to
`practice this limitation. For example, one of skill in the art would find these combinations
`obvious to try, due at least to the similarity of the technical teachings of the art. As another
`example, one of skill in the art would find that the teachings could be predictably
`interchanged by, for example, simple substitution, at least because of the predictability of the
`art and the known interchangeability of the various elements. As another example, one of skill
`in the art would be motivated to combine the references, and would have a reasonable
`expectation of success in doing so, at least because the references use known variations of
`existing technology to solve routine and well understood problems in predictable ways.
`For example:
`GlobalPlatform pp. 18(§1.3); 19, 20(§1.4), 81(§7.6.2), 92(§7.6.2), 93(§7.6.2); 98(§7.7.4).
`Dua discloses establishing a secured channel between the secure element and the server using
`a key set installed on the secure element, wherein the server is configured to prepare data
`necessary for the application to function as designed on the mobile device.
`For Example:
`See 1[pre]-1[e], which are incorporated by reference.
`“These and other objects of the present invention are obtained through the use of a novel
`system and methodology for conducting financial and other transactions requiring
`authorization. According to the methodology of the present invention, credentials may be
`selectively issued by issuers Such as credit card companies, banks, and merchants to
`consumers permitting the specific consumer to conduct a transaction according to the
`authorization given as reflected by the credential or set of credentials. The preferred
`
`16
`
`1[f]
`
`establishing a secured channel between
`the secure element and the server using
`a key set installed on the secure
`element, wherein the server is
`configured to prepare data necessary
`for the application to function as
`designed on the mobile device; and
`
`WEST\297652083.1
`
`RFCyber's Exhibit No. 2006, IPR2022-00413
`Page 016
`
`

`

`Exhibit D-2 – Invalidity Chart Regarding
`U.S. Publication No. 2006/0165060 (“Dua”)