UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`EVERI PAYMENTS INC.
`Petitioner,
`
`v.
`
`SIGHTLINE PAYMENTS LLC
`Patent Owner.
`
`______________
`
`Case IPR2022-00707
`U.S. Patent No. 9,785,926
`
`
`
`
`
`DECLARATION OF DWIGHT CREVELT
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 9,785,926
`
`
`
`EVERI EX. 1001
`Everi v. Sightline IPR2022-00707
`
`

`

`TABLE OF CONTENTS
`I.
`INTRODUCTION ........................................................................................... 8
`BACKGROUND AND QUALIFICATIONS ................................................. 8
`II.
`INFORMATION RELIED UPON ................................................................ 15
`III.
`IV. SCOPE OF ASSIGNMENT AND MATERIALS REVIEWED .................. 15
`V.
`LEGAL STANDARDS AND UNDERSTANDINGS APPLIED ................ 17
`VI. LEVEL OF ORDINARY SKILL IN THE ART ........................................... 20
`VII. CLAIM CONSTRUCTION .......................................................................... 21
`VIII. BACKGROUND OF THE TECHNOLOGY ................................................ 22
`A.
`Player Tracking, Loyalty, and Slot Accounting Systems ................... 22
`B.
`Bonusing, Promotions, and Cashless Gaming .................................... 31
`C.
`Transferring Funds Between the Player’s Financial Account, the
`Player’s Gaming Account, and the Gaming Devices .................................... 43
`IX. OVERVIEW OF THE ’926 PATENT .......................................................... 49
`X. GROUND 1: CLAIMS 1-2, 4-5, 7-10, 12-17, AND 19-20 ARE OBVIOUS
`IN VIEW OF SMITH .............................................................................................. 57
`A. Overview of Smith .............................................................................. 57
`B.
`Independent Claim 1 ........................................................................... 63
`1.
`[1.0] A computer-based method of electronic fund transfer
`between a stored value account and a gaming account, the method
`performed by one or more computing devices comprising instructions
`stored in a memory, which when executed by one or more processors
`of the one or more computing devices, cause the one or more computing
`devices to perform the method comprising: ........................................ 63
`2.
`[1.1] associating in computer memory of the one or more
`computing devices, a stored value account of a player with player
`credentials for a gaming environment, ................................................ 65
`3.
`[1.2] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, ...................................................................... 69
`4.
`[1.3] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; ................................................................ 74
`5.
`[1.4] based at least partially on the player credentials for the
`player entered into a remote computing device, identifying the stored
`value account associated with the player credentials; and .................. 75
`6.
`[1.5] responsive to receiving a funding instruction entered into
`the remote computing device and via closed-loop transactions, causing
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`by the one or more computing devices a decrease of the balance of
`funds of the stored value account and an increase of the balance of a
`gaming account. ................................................................................... 79
`C.
`Claim 2: The computer-based method of claim 1, wherein the gaming
`account is any of a wagering account, a casino level player account, and a
`metered gaming credit account. ..................................................................... 85
`D.
`Claim 4: The computer-based method of claim 1, wherein the causing
`of the decrease of the balance of the stored value account and the increase of
`the balance of the gaming account occurs in substantially real-time. ........... 86
`E.
`Claim 5: The computer-based method of claim 1, wherein the remote
`computing device is any of a mobile computing device, a smart phone, a tablet
`computer, a desktop computer, a laptop computer, a gaming device, a
`wearable computing device, a kiosk, and an automated transaction machine
`(ATM). ........................................................................................................... 89
`F.
`Claim 7: The computer-based method of claim 1, wherein the player
`credentials comprises a unique identifier associated with a player loyalty
`program. ......................................................................................................... 90
`G.
`Claim 8 ................................................................................................ 93
`1.
`[8.0] A computer-based method of funding a gaming account
`associated with a player, the method performed by a transaction
`facilitator computing system comprising instructions stored in a
`memory, which when executed by a processor of the transaction
`facilitator computing system, cause
`the
`transaction facilitator
`computing system to: .......................................................................... 93
`2.
`[8.1] associate in a computer memory of the transaction
`facilitator computing system, a stored value account of a player with a
`player credentials for a gaming environment, ..................................... 94
`3.
`[8.2] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, ...................................................................... 94
`4.
`[8.3] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; ................................................................ 95
`5.
`[8.4] receive a load request, wherein the load request is initiated
`at a remote computing device and comprises a request to increase a
`balance of a gaming account of a player with funds held by the stored
`value account of the player, ................................................................. 95
`6.
`[8.5] wherein
`the
`load
`request comprises
`the player
`credentials; ........................................................................................... 95
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`7.
`[8.6] cause an increase of the balance amount of the gaming
`account based on an amount of funds requested in the load request; and
`cause a decrease of the funds of the stored value account based on the
`amount of funds requested in the load request. ................................... 96
`H.
`Claim 9: The computer-based method of claim 8, wherein the remote
`computing device is any of a mobile computing device, a smart phone, a tablet
`computer, a desktop computer, a laptop computer, a gaming device, a
`wearable computing device, a kiosk, and an automated transaction machine
`(ATM). ........................................................................................................... 97
`I.
`Claim 10: The computer-based method of claim 8, wherein the gaming
`account is any of a wagering account, a casino level player account, and a
`metered gaming credit account. ..................................................................... 97
`J.
`Claim 12: The computer-based method of claim 8, wherein the increase
`of the balance amount of the gaming account is caused to occur substantially
`in real-time. .................................................................................................... 97
`K.
`Claim 13: The computer-based method of claim 8, wherein the funds
`held by the stored value account are accessible through use of a stored value
`payment vehicle issued to the player. ............................................................ 97
`L.
`Claim 14 .............................................................................................. 98
`1.
`[14.0] A gaming system, comprising: ....................................... 98
`2.
`[14.1] a gaming account to hold funds for a player; ................. 98
`3.
`[14.2] a loyalty account assigned to the player, ........................ 99
`4.
`[14.3] wherein the loyalty account is maintained by a customer
`management computing system; and ................................................ 102
`5.
`[14.4] at least one computing device comprising a processor and
`non-transitory computer readable medium having instructions stored
`thereon which when executed by the processor cause the processor
`to:
`105
`6.
`[14.5] associate a stored value account of a player with the
`loyalty account of the player, ............................................................ 106
`7.
`[14.6] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, .................................................................... 108
`8.
`[14.7] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; .............................................................. 108
`9.
`[14.8] based on a received funding command, selectively
`increase funds held by the stored value account and decrease funds held
`by the gaming account through a closed-loop payment network, .... 109
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`10.
`[14.9] wherein the funding command is provided by the player
`from a remote computing device. ...................................................... 111
`M. Claim 15: The gaming account funding system of claim 14, wherein the
`gaming account is any of a casino level player account, a brick-and-mortar
`wagering account, a race-and-sports wagering account, and an internet
`gaming wagering account. ........................................................................... 112
`N.
`Claim 16: The gaming account funding system of claim 14, further
`comprising the remote computing device. ................................................... 113
`O.
`Claim 17: The gaming account funding system of claim 14, wherein the
`remote computing device is any of a mobile computing device, a smart phone,
`a tablet computer, a desktop computer, a laptop computer, a gaming device, a
`wearable computing device, a kiosk, and an automated transaction machine
`(ATM). ......................................................................................................... 113
`P.
`Claim 19: The gaming account funding system of claim 14, wherein the
`selective increase of funds held by the stored value account occurs
`substantially in real-time. ............................................................................ 113
`Q.
`Claim 20: The gaming account funding system of claim 14, wherein the
`funding command comprises information identifying player credentials and
`an amount of funds to be transferred. .......................................................... 116
`XI. GROUND 2: CLAIMS 1-2, 4-10, 12-17, AND 19-20 ARE OBVIOUS IN
`VIEW OF SOMMER ............................................................................................. 119
`A. Overview of Sommer ........................................................................ 119
`B.
`Independent Claim 1 ......................................................................... 123
`1.
`[1.0] A computer-based method of electronic fund transfer
`between a stored value account and a gaming account, the method
`performed by one or more computing devices comprising instructions
`stored in a memory, which when executed by one or more processors
`of the one or more computing devices, cause the one or more computing
`devices to perform the method comprising: ...................................... 123
`2.
`[1.1] associating in computer memory of the one or more
`computing devices, a stored value account of a player with player
`credentials for a gaming environment, .............................................. 124
`3.
`[1.2] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, .................................................................... 130
`4.
`[1.3] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; .............................................................. 133
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`5.
`[1.4] based at least partially on the player credentials for the
`player entered into a remote computing device, identifying the stored
`value account associated with the player credentials; and ................ 133
`6.
`[1.5] responsive to receiving a funding instruction entered into
`the remote computing device and via closed-loop transactions, causing
`by the one or more computing devices a decrease of the balance of
`funds of the stored value account and an increase of the balance of a
`gaming account. ................................................................................. 138
`C.
`Claim 2: The computer-based method of claim 1, wherein the gaming
`account is any of a wagering account, a casino level player account, and a
`metered gaming credit account. ................................................................... 143
`D.
`Claim 4: The computer-based method of claim 1, wherein the causing
`of the decrease of the balance of the stored value account and the increase of
`the balance of the gaming account occurs in substantially real-time. ......... 144
`E.
`Claim 5: The computer-based method of claim 1, wherein the remote
`computing device is any of a mobile computing device, a smart phone, a tablet
`computer, a desktop computer, a laptop computer, a gaming device, a
`wearable computing device, a kiosk, and an automated transaction machine
`(ATM). ......................................................................................................... 147
`F.
`Claim 6: The computer-based method of claim 1, further comprising:
`subsequent to identifying the stored value account, sending by the one or more
`computing devices an indication of the balance of funds available to the player
`for display on the remote computing device. .............................................. 148
`G.
`Claim 7: The computer-based method of claim 1, wherein the player
`credentials comprises a unique identifier associated with a player loyalty
`program. ....................................................................................................... 150
`H.
`Claim 8 .............................................................................................. 152
`1.
`[8.0] A computer-based method of funding a gaming account
`associated with a player, the method performed by a transaction
`facilitator computing system comprising instructions stored in a
`memory, which when executed by a processor of the transaction
`facilitator computing system, cause
`the
`transaction facilitator
`computing system to: ........................................................................ 152
`2.
`[8.1] associate in a computer memory of the transaction
`facilitator computing system, a stored value account of a player with a
`player credentials for a gaming environment, ................................... 153
`3.
`[8.2] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, .................................................................... 153
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`4.
`[8.3] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; .............................................................. 154
`5.
`[8.4] receive a load request, wherein the load request is initiated
`at a remote computing device and comprises a request to increase a
`balance of a gaming account of a player with funds held by the stored
`value account of the player, ............................................................... 154
`6.
`[8.5] wherein
`the
`load
`request comprises
`the player
`credentials; ......................................................................................... 154
`7.
`[8.6] cause an increase of the balance amount of the gaming
`account based on an amount of funds requested in the load request; and
`cause a decrease of the funds of the stored value account based on the
`amount of funds requested in the load request. ................................. 155
`I.
`Claim 9: The computer-based method of claim 8, wherein the
`computing device remote from the by the transaction facilitator computing
`system is any of a mobile computing device, a smart phone, a tablet computer,
`a desktop computer, a laptop computer, a gaming device, a wearable
`computing device, a kiosk, and an automated
`transaction machine
`(ATM). ......................................................................................................... 156
`J.
`Claim 10: The computer-based method of claim 8, wherein the gaming
`account is any of a wagering account, a casino level player account, and a
`metered gaming credit account. ................................................................... 157
`K.
`Claim 12: The computer-based method of claim 8, wherein the increase
`of the balance amount of the gaming account is caused to occur substantially
`in real-time. .................................................................................................. 157
`L.
`Claim 13: The computer-based method of claim 8, wherein the player
`funds held by the stored value account are accessible through use of a stored
`value payment vehicle issued to the player. ................................................ 157
`M. Claim 14 ............................................................................................ 157
`1.
`[14.0] A gaming system, comprising: ..................................... 157
`2.
`[14.1] a gaming account to hold funds for a player; ............... 158
`3.
`[14.2] a loyalty account assigned to the player, ...................... 159
`4.
`[14.3] wherein the loyalty account is maintained by a customer
`management computing system; and ................................................ 161
`5.
`[14.4] at least one computing device comprising a processor and
`non-transitory computer readable medium having instructions stored
`thereon which when executed by the processor cause the processor
`to:
`163
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`6.
`[14.5] associate a stored value account of a player with the
`loyalty account of the player, ............................................................ 164
`7.
`[14.6] wherein the stored value account is an open-loop account
`that holds a balance of funds maintained by a host computing system
`on a bank card network, .................................................................... 165
`8.
`[14.7] wherein funds held in the stored value account are usable
`for payment transactions at any of a plurality of merchants associated
`with the bank card network; .............................................................. 166
`9.
`[14.8] based on a received funding command, selectively
`increase funds held by the stored value account and decrease funds held
`by the gaming account through a closed-loop payment network, .... 166
`10.
`[14.9] wherein the funding command is provided by the player
`from a remote computing device. ...................................................... 168
`N.
`Claim 15: The gaming account funding system of claim 14, wherein the
`gaming account is any of a casino level player account, a brick-and-mortar
`wagering account, a race-and-sports wagering account, and an internet
`gaming wagering account. ........................................................................... 169
`O.
`Claim 16: The gaming account funding system of claim 14, further
`comprising the remote computing device. ................................................... 169
`P.
`Claim 17: The gaming account funding system of claim 14, wherein the
`remote computing device is any of a mobile computing device, a smart phone,
`a tablet computer, a desktop computer, a laptop computer, a gaming device, a
`wearable computing device, a kiosk, and an automated transaction machine
`(ATM). ......................................................................................................... 170
`Q.
`Claim 19: The gaming account funding system of claim 14, wherein the
`selective increase of funds held by the stored value account occurs
`substantially in real-time. ............................................................................ 170
`R.
`Claim 20: The gaming account funding system of claim 14, wherein the
`funding command comprises information identifying player credentials and
`an amount of funds to be transferred. .......................................................... 173
`
`
`
`EVERI EX. 1001
`Everi v. Sightline IPR2022-00707
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`I, Dwight Crevelt, hereby declare as follows:
`INTRODUCTION
`I.
`I am over the age of 18 and am competent to submit this declaration.
`1.
`
`The statements and opinions herein are based on my personal knowledge and upon
`
`my background, education, research, training, and experience relating to the subject
`
`matter discussed.
`
`2.
`
`I have been retained by Dickinson Wright PLLC on behalf Petitioner
`
`Everi Payments Inc. (“Everi”) in this matter to offer technical opinions relating to
`
`U.S. Patent No. 9,785,926 (“the ’926 Patent”) and to submit this declaration in
`
`connection with the Inter Partes Review of Claims 1-2, 4-10, 12-17, and 19-20 of
`
`the ’926 Patent. If called upon to do so, I am prepared to testify as an expert witness
`
`in this regard.
`
`II. BACKGROUND AND QUALIFICATIONS
`I am an expert in the field of design and operation of gaming machines
`3.
`
`and systems for the casino industry, including cashless wagering systems.
`
`4.
`
`I am the founder and presently president of Crevelt Computer System,
`
`Inc., a gaming business consulting and engineering development company that is
`
`located and incorporated in Las Vegas, Nevada. I founded Crevelt Computer in
`
`1977. Although I discuss my expert qualifications in more detail below, I also attach
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`as Appendix A a recent and complete curriculum vitae, which details my
`
`educational and professional background.
`
`5. My formal, post-high school education started at the University of Las
`
`Vegas in 1973. I continued my education at the U.S. Naval Academy from 1975 to
`
`1977. While at the Navy, I was a systems engineering major. I then attended Iowa
`
`State University, where I received my Bachelor of Science degree in Computer
`
`Engineering in 1979.
`
`6.
`
`In 1977, I started developing my own slot machine system. This
`
`involved disassembling existing systems, re-engineering components, creating new
`
`software, and creating new code for new games. It also involved creating drives for
`
`stepper motors, lights, controls and switches on the gaming. When I left the Navy
`
`and joined Iowa State University, I brought this slot machine system with me. As I
`
`was continued developing it, my slot machine system was displayed at VEISHEA at
`
`Iowa State, which is an annual week-long celebration showcasing the university, its
`
`collages, student accomplishments and the engineering college, that puts new
`
`inventions and designs out for display.
`
`7. My professional experience in the casino gaming industry started in
`
`1974, when I joined Gamex Industries as a software engineer. As a software
`
`engineer, I designed and developed casino game management systems, including an
`
`on-line slot accounting and monitoring system, and I also maintained Gamex’s on-
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`line casino table game accounting system. I was also responsible for maintaining
`
`the system that monitored the play of table games and slot machines as installed in
`
`Caesar’s Palace, Las Vegas.
`
`8.
`
`In 1977, I started my own consulting company, Crevelt Computer
`
`System, Inc., and near the end of 1977 I worked at United Audio Visual as a software
`
`engineer developing audio/video controllers for multimedia shows.
`
`9.
`
`From 1979 to 1980, I continued to work in the gaming industry as a
`
`computer engineer for Sircoma (later becoming International Game Technologies,
`
`or IGT). At Sircoma, I developed various gaming machines, including video Poker,
`
`video Blackjack, video Red Dog and Whirlwin. I also had responsibility for
`
`developing and maintaining the software for these video slot machines. I also acted
`
`as a technical gaming control liaison, which involved providing the Nevada Gaming
`
`Control Board staff with technical information regarding the company’s gaming
`
`devices. The Nevada Gaming Control Board regulates the gaming industry in
`
`Nevada, overseeing the licensing and compliance of casinos as well as
`
`manufacturers and the equipment used in gaming.
`
`10.
`
`In 1981, I worked for Mills-Jennings as a Director of Corporate
`
`Research. In this role, I assembled and supervised a research and development team
`
`that designed a complete line of video casino gaming machines, such as video poker
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`machines, video slot machines, and the like. My research and development team
`
`also designed an on-line casino accounting system suited for the casino floor.
`
`11. From 1984 to 1986, as a consultant with Crevelt Computer System Inc.,
`
`I worked with Electronic Data Technologies, where I designed and developed the
`
`first complete on-line player tracking/loyalty system, known as the Action System.
`
`I designed hardware, software, and performed the first systems analysis of player
`
`tracking/loyalty system. This included the necessary hardware and software to
`
`monitor the gaming machines and communicate this data to the slot monitoring
`
`system. The slot monitoring system included a network of PC computers and
`
`software applications utilizing the client/server architecture
`
`12. From 1988 to 1996, I worked for Electronic Data Technologies (EDT)
`
`and International Game Technologies (IGT). I was responsible for design,
`
`development and implementation of player tracking/loyalty and accounting systems
`
`for casino games, which included providing communications with the casino’s other
`
`computer systems including the casino management systems. Specifically, I
`
`managed the department and oversaw the design and development of the hardware,
`
`software, and systems integration. I also managed the deployment and support for
`
`over 150 installations of the SMART system (also referred to by the customers as
`
`the EDT System, or the Action System) and a “smart card”-based system for cashless
`
`gaming and player tracking/loyalty.
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`13. During that time, I was also responsible for the development and
`
`deployment of the first cashless system utilized by Caesar’s Palace, Las Vegas. I
`
`worked directly with the Director of IT at Caesar’s to integrate our system into their
`
`existing casino systems. Caesar’s system was already configured to communicate
`
`with financial institutions through its ATM systems within the casino. We worked
`
`to integrate our cashless system into Caesar’s ATM system to allow the electronic
`
`transfer of funds from a patron’s financial accounts to the casino’s systems. We also
`
`integrated a PIN pad that supported the DES-encryption standard as required by the
`
`financial institutions at the time.
`
`14.
`
`In 1995, I was promoted to Product Manager for Cashless Applications.
`
`In this role, I prepared business plans and strategies for implementing cashless
`
`gaming products, including IGT’s first smart-card based cashless gaming system
`
`installed at the Monte Carlo Casino in Monaco. I also spent time evaluating casino-
`
`related intellectual property, particularly patents, especially those pertaining to
`
`cashless gaming and progressive systems.
`
`15. At the end of 1996, I left IGT and continued as a consultant with Crevelt
`
`Computer Systems, where I have since worked with many gaming equipment
`
`manufacturers on the design and development of casino gaming devices, including
`
`slots, video games, Keno and Bingo systems. I also have provided independent
`
`laboratory analysis of games for regulators in New South Wales, Australia and the
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`state of Mississippi. Additionally, I have conducted mathematical analyses for
`
`casino gaming devices.
`
`16. From 1998-2013, Crevelt Computer System was a Partner in
`
`FootTraffic Promotional Gaming LLC. As a Partner with FootTraffic Promotional
`
`Gaming LLC, I designed, developed, managed and marketed a series of promotional
`
`games for casinos, retailers and trade shows. These are free-play games that are
`
`designed to bring or attract patrons to the casino with an opportunity to win cash and
`
`prizes, including integration with player tracking/loyalty systems. These games
`
`have been very successful and several have been incorporated into permanent
`
`promotions at several casinos, including Peppermill Casino (Reno), Casino
`
`Fandango (Carson City), and Silver Legacy (Reno).
`
`17.
`
`I am the co-author of two books that relate to the casino gaming
`
`industry – Slot Machine Mania (1988) and Video Poker Mania!! (1991). Both of
`
`these books were still in publication more than 20 years after they were first
`
`published.
`
`18.
`
`I have been interviewed for numerous magazines, radio programs and
`
`television shows regarding gaming machines and the casino industry, including
`
`appearances on Secrets Revealed (a documentary on The Learning Channel, TLC)
`
`and High Rollers (a documentary on the Discovery Channel).
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`19. Throughout my career, I have kept up to date with the latest
`
`developments in the casino industry by subscribing to casino-related trade
`
`publications, attending casino gaming shows to review competitors’ products, and
`
`reviewing competitors’ and industry patents.
`
`20.
`
`I am an inventor on six United States Patents, all of which are related
`
`to the casino industry, namely wagering systems, player tracking, and electronic
`
`fund transfers (EFT) systems within the gaming environment. One of these patents
`
`(U.S. Patent No. 5,902,983, Exhibit E1023) – which I refer to in more detail below
`
`– is specifically directed to a gaming system which allows a player to transfer funds
`
`from a remote funds repository (e.g., a bank) via an electronic funds transfer system
`
`and convert transferred funds to plays on said gaming machine.
`
`21.
`
`I have been retained as an expert in various litigation and Inter Partes
`
`Review (“IPR”) matters regarding the hardware and software design and
`
`development of gaming machines and gaming systems, including player tracking
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`systems, cashless systems, progressive systems and promotional systems. A list of
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`cases I have been retained as an expert for is provided as Appendix B.
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`22.
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`I have also served as a consultant in various legal matters, as
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`summarized in the same Appendix.
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`EVERI EX. 1001
`Everi v. Sightline IPR2022-00707
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`

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`III.
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`INFORMATION RELIED UPON
`In addition to my general knowledge from education and experience in
`23.
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`this field, I have reviewed and considered, among other things: the ’926 Patent, the
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`prosecution history of the ’926 Patent, the prior art of record, and the prior art
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`described in this Declaration. I have also researched and reviewed other prior art
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`references that are relevant to the ’926 Patent.
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`IV. SCOPE OF ASSIGNMENT AND MATERIALS REVIEWED
`I have been retained as an expert on behalf of Everi to provide
`24.
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`information and opinions to the Patent Trial and Appeal Board (“the Board”) to
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`assist in its analysis of the patentability of the ’926 Patent in the above-captioned
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`Inter Partes Review.
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`25.
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`I am being compensated at the rate of $400 an hour. My compensation
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`does not d