`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff,
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`FINTIV, INC.
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`
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`
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`v.
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`PAYPAL HOLDINGS, INC.,
`Defendant.
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`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`6:22-CV-00288-ADA
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`FINAL CLAIM CONSTRUCTIONS OF THE COURT
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`The Court provided preliminary claim constructions on December 19, 2022, for U.S. Patent
`
`Nos. 8,538,845 (“’845 patent”), 9,892,386 (“’386 patent”), 11,120,413 (“’413 patent”), 9,028,488
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`(“’488 patent”), and 10,438,196 (“’196 patent”). Fintiv asserted claims 1–3, 5–7 of the ’845 patent;
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`claims 1–3 of the ’386 patent; claims 1–2 of the ’413 patent, claims 1–4 of the ’488 patent, and 1–
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`2, 4–5 and 7 of the ’196 patent. The Court held a claim construction hearing on December 20,
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`2022, in which the Court heard argument on the following claim terms: (1) “mobile wallet,” (2)
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`“agent,” (3) “payment handler”/ “payment handler service,” and (4) “business process services.”
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`After careful consideration of the parties’ briefs, oral argument, and the applicable law, the Court
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`enters its final constructions for each term as shown below.
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`Claim Term
`
`Court’s Final Construction
`
`“mobile wallet”
`All Claims.
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`
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`“A stored value account or prepaid access
`account (PPA) that allows the owner (or
`‘subscriber’) to pay for goods and services of
`the mFS platform from his or her mobile
`wallet account.”
`
`1
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`IPR2022-00976
`Fintiv Ex. 2015 | Page 1 of 3
`
`
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`Case 6:22-cv-00288-ADA Document 60 Filed 01/09/23 Page 2 of 3
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`Claim Term
`
`Court’s Final Construction
`
`“agent”
`’386 Patent claims 1–3; ’196 Patent claim 1
`
`Plain and ordinary meaning.
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`Claim Term
`
`Court’s Final Construction
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`“agent branch”
`’845 Patent claim 1; ’386 Patent claims 1–2
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`Plain and ordinary meaning.
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`Claim Term
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`Court’s Final Construction
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`“unbanked subscriber”
`’845 Patent claims 1 and 5
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`Plain and ordinary meaning.
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`Claim Term
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`Court’s Final Construction
`
`“payment handler”/ “payment handler
`service”
`’386 Patent claims 1–3; ’413 Patent claims 1–
`2; ’196 Patent claim 1
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`This is a means-plus-function limitation.
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`Function: “use APIs of different payment
`processors including one or more APIs of
`banks, credit and Debit cards processors, bill
`payment processors” (’386, ’413) “expose a
`common API for interacting with different
`payment processors” (’196)
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`Structure: None, and therefore indefinite
`under 112(f)
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`
`
`
`Claim Term
`
`Court’s Final Construction
`
`“database services”/ “storage system”
`’386 Patent claims 1–3; ’413 Patent claims 1–
`2
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`Plain and ordinary meaning.
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`2
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`IPR2022-00976
`Fintiv Ex. 2015 | Page 2 of 3
`
`
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`Case 6:22-cv-00288-ADA Document 60 Filed 01/09/23 Page 3 of 3
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`Claim Term
`
`Court’s Final Construction
`
`“business process services”
`’386 Patent claims 1–3; ’413 Patent claims 1–
`2
`
`Means-plus-function.
`
`Function: implementing business workflows,
`including at least one of executing financial
`transactions, auditing financial transactions,
`invoking third-party services, handling errors,
`and logging platform objects.
`
`
`Structure: ’386 Patent claims 1-3 ’413 Patent
`claims 1-2 ’386 Patent Figure 1
`Corresponding ’386 Patent Figures ’386
`Patent Figure 20A-J (data flow) ’386 Patent
`Figure 21A-J (data flow) ’386 Patent Figure
`22A-J (data flow) ’386 Patent Figure 22A-J
`(data flow).
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`
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`Claim Term
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`Court’s Final Construction
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`Plain and ordinary meaning.
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`“presented to”
`’488 Patent claim 1; ’196 Patent claim 1
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`
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`SIGNED this 9th day of January, 2023.
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`3
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`IPR2022-00976
`Fintiv Ex. 2015 | Page 3 of 3
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