UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`FINTIV, INC.,
`Patent Owner.
`———————
`
`IPR2022-00976
`U.S. Patent No. 9,892,386
`_____________________
`
`DECLARATION OF DR. HENRY HOUH,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
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`TABLE OF CONTENTS
`Introduction .................................................................................................. 4
`I.
`Qualifications and Professional Experience .................................................. 6
`II.
`III. Level of Ordinary Skill in the Art ............................................................... 13
`IV. Relevant Legal Standards ............................................................................ 14
`V. Overview of the ’386 Patent ....................................................................... 17
`VI. Claim Construction ..................................................................................... 31
`VII.
`Identification of How the Claims are Unpatentable ..................................... 32
`A. Ground 1: Claims 1 and 3 would have been obvious under 35
`U.S.C. § 103(a) over Dill in view of Vadhri, Akashika, and
`Hansen. ............................................................................................. 34
`1.
`Summary of Dill (APPL-1005) .................................... 34
`
`B.
`
`Summary of Vadhri (APPL-1006) ............................... 42
`2.
`Summary of Akashika (APPL-1007) ........................... 46
`3.
`Summary of Hansen (APPL-1008) .............................. 53
`4.
`Overview of Analysis .................................................. 57
`5.
`Claim 1 ........................................................................ 59
`6.
`Grounds 1 and 2: claim 3 would have been obvious over Dill in
`view of Vadhri, Akashika, and Hansen (Ground 1); claim 2
`would have been obvious over Dill in view of Vadhri,
`Akashika, Hansen, and Liao (Ground 3). ........................................ 143
`1.
`Limitations in Claims 2 and 3 That are Identical or
`Similar to Claim 1 ..................................................... 144
`Limitations Unique to Both Claims 2 and 3 ............... 150
`Limitations Unique to Claim 3 (Ground 1) ................ 153
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`2.
`3.
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`2
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`Limitations Unique to Claim 2 (Ground 2) ................ 158
`4.
`VIII. Conclusion ................................................................................................ 176
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`3
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`I, Henry Houh, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
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`Inter Partes Review of U.S. 9,892,386
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`
`
`1.
`
`I am making this declaration at the request of Apple, Inc. in the matter
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`of the Inter Partes Review of U.S. Patent No. 9,892,386 (“the ’386 patent”) to
`
`Michael A. Liberty.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the specifics of my testimony.
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`3.
`
`I have been asked to provide my opinions regarding whether claims 1-
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`3 (“the Challenged Claims”) of the ’386 patent are unpatentable as they would
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`have been obvious to a person having ordinary skill in the art (“POSITA”) at the
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`time of the alleged invention, in light of the prior art. It is my opinion that all of the
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`limitations of the challenged claims would have been obvious to a POSITA.
`
`4.
`
`In the preparation of this declaration, I have studied:
`
`a.
`
`b.
`
`the ’386 patent, APPL-1001;
`
`the prosecution history of the ’386 Patent (“’386 File History”),
`
`APPL-1002;
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`c. U.S. Patent Publication No. 2009/0265272 to Dill et al. (“Dill,”
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`APPL-1005);
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`4
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`d. U.S. Patent Publication No. 2010/013334 to Vadhri (“Vadhri,” APPL-
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`1006);
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`e. U.S. Patent Publication No. 2009/0217047 to Akashika et al.
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`(“Akashika,” APPL-1007);
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`f. U.S. Patent Publication 2004/0230527 (“Hansen,”APPL-1008);
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`g. U.S. Patent No. 7,865,141 to Liao et al. (“Liao,” APPL-1009);
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`h. In forming the opinions expressed below, I have considered:
`
`the documents listed above;
`
`the relevant legal standards, including the standard for obviousness,
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`and any additional authoritative documents as cited in the body of this
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`declaration; and
`
`my own knowledge and experience based upon my work in the field
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`of software and telecommunications as described below, as well as the
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`following materials:
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`a. G. Winfield Treese et al., “Designing Systems for Internet
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`Commerce,” Second Edition, Addison-Wesley, 2003 (“Treese”) (excerpt), APPL-
`
`1012;
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`b. H. Newton, “Newton’s Telecom Dictionary,” 17th Edition, CMP
`
`Books, 2001 (excerpt, p. 52), APPL-1014; and
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`c.
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` T. Thai et al., “.Net Framework Essentials,” Third Edition, O’Reilly
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`& Associates, Inc., 2003 (excerpt, pp. 1-10), APPL-1015.
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`d. any other document cited in this analysis.
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`The materials I have reviewed and studied, including those listed in this
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`paragraph, are the type of evidence an expert in the field of software and mobile
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`application development would consider in reaching conclusions.
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`5.
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`Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`6. My complete qualifications and professional experience are described
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`in my Curriculum Vitae, a copy of which can be found in APPL-1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
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`7.
`
`I received a Ph.D. in Electrical Engineering and Computer Science
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`from the Massachusetts Institute of Technology (“MIT”) in 1998. I also received a
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`Master of Science degree in Electrical Engineering and Computer Science in 1991,
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`a Bachelor of Science degree in Electrical Engineering and Computer Science in
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`1989, and a Bachelor of Science degree in Physics in 1990, all from MIT.
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`8.
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`I am currently self-employed as an independent technical consultant. I
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`am also president of a company, Einstein’s Workshop, that provides supplemental
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`6
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`science, technology, engineering, and mathematics (“STEM”) education to
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`children of all ages.
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`9.
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`I first entered telecommunications in 1987 when I worked as a
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`summer intern at AT&T Bell Laboratories as part of a five-year dual degree
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`program at MIT. I continued to work at AT&T Bell Laboratories as part of this
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`MIT program. While at MIT, I was a teaching assistant (“TA”) in the Electrical
`
`Engineering and Computer Science Department’s core Computer Architectures
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`course. I first was a TA as a senior for a role typically reserved for graduate
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`students. I later became head TA. The course covered various topics in computer
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`architectures, as well as programming. As a TA, I helped write homework
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`assignments, lab assignments (including those that involved programming), and
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`exams. I also taught in the recitation sections.
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`10. Later, as part of my doctoral research at MIT from 1991-1998, I was a
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`research assistant in the Telemedia Network Systems (“TNS”) group at the
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`Laboratory for Computer Science. The TNS group built a high-speed gigabit
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`network and created applications that ran over the network. Example applications
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`included ones for remote video capture, processing, and display of video on
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`computer terminals. In addition to working on the design of core network
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`components (which was based on FPGAs), designing and building the high-speed
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`links (which included programmable logic devices), and designing and writing the
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`device drivers for the interface cards (which included programmable logic
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`devices), I also set up the group’s web server. Also, along with the other graduate
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`students, I helped to maintain, install, and upgrade the networking devices used
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`within the group, including setting up and configuring access control lists
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`(“ACLs”) for accounts and file systems. Such ACLs are standard methods of
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`controlling permissions associated with system resources and I have utilized and
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`managed them with in many other contexts, including in web-based systems,
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`networked systems, and operating systems.
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`11.
`
`I also helped to build the web pages that initiated the above-
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`mentioned video sessions via a web interface. Vice President Al Gore visited our
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`group in 1996 and received a demonstration of—and remotely drove—a radio-
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`controlled toy car with a wireless video camera mounted on it that was built by our
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`group. This toy car device received commands transmitted over a network from a
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`remote computer, and video data from the toy car was transmitted wirelessly then
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`over a computer network back to the user controller. On occasion, we allowed
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`users visiting our web site to drive the toy car from their remote computer while
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`they watched the video on their computer. The video stream was encoded by TNS-
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`designed hardware, streamed over the TNS-designed network, and displayed using
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`TNS-designed software.
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`12.
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`I defended and submitted my Ph.D. thesis, titled “Designing Networks
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`for Tomorrow’s Traffic,” in January 1998. As part of my thesis research, I
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`analyzed local area and wide area flows to show a more efficient method for
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`routing packets in a network, based on traffic patterns at the time. The traffic flow
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`data included Ethernet, IP, TCP or UDP, and RTP header information, which I
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`analyzed to come to the conclusions in my thesis.
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`13. From 1997 to 1999, I was a Senior Scientist and Engineer at NBX
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`Corporation, a start-up that made business telephone systems for streaming
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`packetized audio over data networks instead of using traditional telephone lines.
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`NBX was later acquired by 3Com Corporation.
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`14. As part of my work at NBX, I designed the core audio reconstruction
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`software algorithms for the telephones, as well as the packet transmission
`
`algorithms. I also designed and validated the core packet transport protocol used by
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`the phone system. The protocol was used for all signaling in the phone system,
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`including for the setup of conference calls. The NBX system also featured a
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`computer interface for initiating phone calls, which could also initiate conference
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`calls. The NBX system also supported the Telephony Application Programming
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`Interface (“TAPI”) that allowed other computer programs to integrate with our
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`system telephony features. We obtained U.S. Patent No. 6,697,963, entitled
`
`“Telecommunication method for ensuring on-time delivery of packets containing
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`time-sensitive data,” as part of this work. I also programmed the first prototype of
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`our phone which communicated using IP, and I demonstrated our IP phones
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`working over the Internet when we attended a trade show in California. The phone
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`connected over the Internet to our headquarters in Andover, MA. I also
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`programmed a data capture and analysis system that provided data on the operation
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`of the system.
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`15. From 1999-2004, I was employed by Empirix or its predecessor
`
`company, Teradyne. Empirix was a leader in test tools for telecommunications
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`protocols and systems, providing functional testing tools as well as load testing
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`tools. From 2000-2001, I conceived and built a test platform for testing Voice-
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`over-IP (VoIP). The first application on this new test platform was a cloud
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`emulator for simulating the effects of transmitting VoIP over a busy network. The
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`test platform was based on a network processor chip, which could be programmed
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`to cut-through packets while processing packet data such as various protocol later
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`headers including addresses included therein and even packet data contents. I also
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`designed a protocol analyzer built on the same platform. The application captured
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`and performed protocol decoding at various layers in the protocol stacks of
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`captured packets, including detailed Ethernet header decoding, IP header decoding,
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`TCP header decoding, UDP header decoding, RTP header decoding, and many
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`other specified protocols. The application was also designed to reconstruct entire
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`conversations that spanned multiple packets. At Empirix, I also rearchitected the
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`design of the Web Test division’s core product, e-Test Suite. E-Test Suite was a
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`software program designed to perform functional and load testing of web
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`applications. I was technical lead on the project, and also worked on programming
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`a Javascript interpreter for the product. Javascript, standardized as ECMAScript, is
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`the flexible programming layer that allows users to interact with web pages
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`through actions such as clicking and dragging that allows web page programmers
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`to extend the functionality of a web page beyond clicking on links.
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`16.
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`In 2006, as part of my role at BBN Technologies, I helped found
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`PodZinger Inc., now known as RAMP Inc. PodZinger utilized BBN’s speech
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`recognition algorithms to search through the spoken words in audio and video
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`segments. While I was Vice President of Operations and Technology, PodZinger
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`followed its initial prototype with a full streaming audio and video search solution.
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`I also created a social networking web site, which BBN sold to a venture-funded
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`startup company. In the process of creating the web site, I designed and specified
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`the authentication and authorization protocols.
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`17.
`
`I also worked with setting up accounting systems and integrating on-
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`line payment systems on numerous occasions. In 1994, I started a company, Agora
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`Technology Group, that set up web sites for targeted advertising, and later
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`provided consulting services to companies and organizations to set up their web
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`sites. I managed all the finances and bookkeeping for the company, including
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`keeping all the books and ledgers. Starting in the early 2000’s, I integrated web
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`payment systems with various web sites, writing the necessary code for the
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`systems integration.
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`18. At my educational company, Einstein’s Workshop, I created the initial
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`web site and integrated it with online payment solutions. I also evaluated, sourced,
`
`and configured the point-of-sale system for the company, which also involved
`
`integration with and setup of mobile shopping terminals. Furthermore, I set up the
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`accounting system, built the web site, integrated various web payment mechanisms
`
`with the web site, set up mobile payment systems, and also set up a mobile point of
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`sale system. At Einstein’s Workshop, we teach programming to children of all
`
`ages, starting with Scratch programming for young elementary students and
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`advancing through programming in Python and for game development for high
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`school students. I conceived many of the programming classes and have taught
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`programming to novice and more advanced students. We also created an
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`educational computer-aided design tool, called BlocksCAD. We received a grant,
`
`on which I was the principal investigator, to further develop BlocksCAD and
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`successfully met our grant objectives. BlocksCAD was spun-off from Einstein’s
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`Workshop and has been part of various incubator/accelerator programs in
`
`education as well as at the MIT Media Lab. Today, BlocksCAD is used worldwide
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`in makerspaces as well as in schools throughout the U.S.
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`19.
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`I have been awarded several United States patents, including the
`
`following examples:
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`• U.S. Patent No. 7,975,296, “Automated security threat testing of
`
`web pages”;
`
`• U.S. Patent No. 7,877,736, “Computer language interpretation and
`
`optimization for server testing”;
`
`• U.S. Patent No. 7,801,910, “Method and apparatus for timed tagging
`
`of media content”;
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`• U.S. Patent No. 7,590,542, “Method of Generating Test Scripts
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`Using a Voice-Capable Markup Language”; and
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`• U.S. Patent No. 6,967,963, “Telecommunication method for
`
`ensuring on-time delivery of packets containing time-sensitive
`
`data.”
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`
`20.
`
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
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`experience of persons working in the field at the time of the invention; (2) the
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`sophistication of the technology; (3) the types of problems encountered in the field;
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`and (4) the prior art solutions to those problems.
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`21. A person of ordinary skill in the art (“POSITA”) in June 2011 would
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`have had a working knowledge of monetary transaction systems pertinent to the
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`’386 patent, including software development in the field of mobile payment
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`techniques. Such POSITA would have had a bachelor’s degree in electrical
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`engineering, computer science, or equivalent training, and approximately two years
`
`of work experience in software development. Lack of work experience can be
`
`remedied by additional education, and vice versa.
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`22. For purposes of this declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the priority
`
`date of the ’386 patent (i.e., June 3, 2011 (“priority date”)). Unless otherwise
`
`stated, when I provide my understanding and analysis below, it is consistent with
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`the level of a POSITA prior to the priority date of the ’386 patent.
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`IV. RELEVANT LEGAL STANDARDS
`
`23.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’386 patent, I am relying on certain basic
`
`legal principles that counsel have explained to me. These principles are discussed
`
`below.
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`24.
`
`I understand that prior art to the ’386 patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
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`invention recited in the ’386 patent. For purposes of this declaration, I am applying
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`June 3, 2011, as the priority date of the ’386 patent (“priority date”).
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`25.
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`It is my understanding that, to anticipate a claim under 35 U.S.C.
`
`§ 102, a reference must disclose each and every element of the claim. I have been
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`informed that a reference may disclose an element expressly or inherently. I
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`understand that, for a limitation to be inherently disclosed by a reference, the
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`limitation necessarily must be present, or the natural result of the combination of
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`elements explicitly disclosed by the prior art.
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`26.
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`I have been informed that a claimed invention is unpatentable under
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`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
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`the scope and content of the prior art, and the differences between the prior art and
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`the claimed subject matter.
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`27.
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`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
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`the invention, any long-felt but unsolved need in the art that was satisfied by the
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`alleged invention, the failure of others to make the alleged invention, praise of the
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`alleged invention by those having ordinary skill in the art, and copying of the
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`alleged invention by others in the field. I understand that there must be a nexus—a
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`connection—between any such secondary considerations and the alleged invention
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`recited in the claims. I also understand that contemporaneous and independent
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`invention by others is a secondary consideration tending to show obviousness.
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`28.
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`I am not aware of any allegations by the named inventor of the ’386
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`patent or any assignee of the ’396 patent that any secondary considerations are
`
`relevant to the obviousness analysis of any Challenged Claim of the ’386 patent.
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`29.
`
`I have been informed by counsel that the Supreme Court has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
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`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
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`in the prior art that would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at the claimed
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`invention.
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`V. OVERVIEW OF THE ’386 PATENT
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`30. The ’386 patent was originally filed as U.S. Application No.
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`15/201,152 (“the ’152 application”) on July 1, 2016. I have been informed that the
`
`’152 application is related to several earlier non-provisional applications, the
`
`earliest of which was U.S. Application No. 13/484,199, which was filed on May
`
`30, 2012, and which is now U.S. Patent No. 8,538,845. I have also been informed
`
`that the ’152 application claims priority to two provisional applications, the earliest
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`of which was U.S. Provisional Application No. 61/493,064, which was filed on
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`June 3, 2011.
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`31. The ’386 patent relates to a “monetary transaction system for
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`conducting monetary transactions between transaction system subscribers and
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`other entities.” APPL-1001, 1:39-37, 3:43:45. The ’386 patent explains that “the
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`monetary transaction system includes a mobile device configured to run a
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`monetary transaction system application,” and “a monetary transaction system
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`subscriber that has a profile with the system.” APPL-1001, 1:39-44, 3:46-50.
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`According to the ’386 patent, “[t]he subscriber indicates, via the monetary
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`transaction system application, one or more specified transactions that are to be
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`performed using the monetary transaction system.” APPL-1001, 1:44-47, 3:50-53.
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`The ’386 patent explains that “[p]erforming these transactions includes
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`communicating with a monetary transaction database to determine whether the
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`transaction is permissible based on data indicated in the subscriber's profile.”
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`APPL-1001, 1:49-52, 3:55-58.
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`32.
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`In addition, the ’386 patent explains that “[t]he monetary transaction
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`system also includes at least one entity that is to be involved in the specified
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`transaction, where the entity has a profile with the monetary transaction system.
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`This entity may be a person, a retail store, an agent or other entity.” APPL-1001,
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`1:53-57, 3:59-63.
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`33. Figure 1 of the ’386 patent below illustrates “an example system
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`architecture of a mobile wallet platform.” APPL-1001, 13:3-4. The “mobile wallet
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`platform” shown in Figure 1 includes various functional components such as an
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`“integration tier 101,” “notification services 102,” “business process services 104,”
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`“payment handler 105,” “security services 106,” “database 108,” and “rules engine
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`109.” APPL-1001, 13:4-51. The ’386 patent explains that the “[c]omponents of a
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`mobile wallet platform can be connected to one another over (or be part of) a
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`system bus and/or a network. Networks can include a Local Area Network
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`(“LAN”), a Wide Area Network (“WAN”), and even the Internet. Accordingly,
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`components of the mobile wallet platform can be ‘in the cloud.’” APPL-1001, 13:-
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`65-14:3. Thus, the ’386 patent envisions that the “components” of the “mobile
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`wallet platform” may be embodied in a distributed computing environment.
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`APPL-1001, Fig. 1
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`34. The ’386 patent explains that “FIG. 2 depicts a monetary transaction
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`system 200 similar to that described in FIG. 1. The monetary transaction
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`system 200 may provide a more simplified system structure in which each of the
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`above services may be provided.” APPL-1001, 14:27-30. Figure 2 of the ’386
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`patent is reproduced below. Thus, the ’386 patent discloses that the monetary
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`transaction system 200 shown in Figure 2 includes the functional components (e.g.,
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`“services”) shown in Figure 1. APPL-1001, 14:27-28 (“FIG. 2 depicts a monetary
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`transaction system 200 similar to that described in FIG. 1.”).
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`Subscriber
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`Subscriber
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`APPL-1001, Fig. 2 (annotated)
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`Agent
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`35. Figure 2 above shows an embodiment of a monetary transaction
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`system 200 in which a first subscriber 205 utilizes a mobile device 206 having a
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`mobile wallet application 207 to conduct a transaction with another entity (e.g.,
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`another subscriber 222, or a retail store or agent 223) through a monetary
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`transaction system 210. APPL-1001, 14:27-39.
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`36. The monetary transaction system 210 performs certain services in
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`support of the requested transaction by accessing the profile information 211 about
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`the subscriber and using a rules engine 200 to determine whether the transaction is
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`permissible based on factors such as whether the requesting subscriber (i) has
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`sufficient money in her account, or (ii) has exceeded a specified number of allowed
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`transactions. APPL-1001, 14:40-64.
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`The subscriber can indicate, using the mobile application 207 which
`transaction or other action he or she would like to perform. The
`indicated transaction 208 is sent to the mobile wallet platform 210 to be
`carried out by the platform. The transaction processor 216 (which may
`be similar to or the same as transaction processor 121 of FIG. 1)
`performs the transaction(s) specified by the (unbanked) subscriber 205.
`The transaction processor may implement various other components to
`perform
`the
`transaction
`including memory 217,
`(wireless)
`communication module 215, rules engine 210 and/or
`transaction
`database 225.
`Performing the specified transactions may include communicating with
`the monetary transaction database 225 to determine whether the
`transaction is permissible based on data indicated in the unbanked
`subscriber's profile (for instance, whether the subscriber has enough
`eMoney in his or her stored value account, or has enough money in his
`or her bank account). Rules engine 220 may also be consulted to
`determine whether the subscriber has exceeded a specified number of
`allowed transactions. Then, if funds are available, and the transaction
`is otherwise permissible, the monetary transaction system can transfer
`money or eMoney 221 to or from an entity such as a user or agent (e.g.
`entity 222) to or from an establishment such as a retail store or agent
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`company (e.g. entity 223).
`APPL-1001, 14:40-64.
`37.
`I understand that the Examiner issued two Office Actions during
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`prosecution of the ’386 patent. APPL-1002, 1606-1612 (first Office Action), 1368-
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`1371 (second Office Action). I understand that the Examiner rejected the
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`prosecution claims only on patent-eligibility grounds under 35 U.S.C. § 101. I
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`understand that the Examiner did not reject the prosecution claims on the basis of
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`any prior art.
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`38.
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`I have been informed that claim 1 of the ’386 patent corresponds to
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`prosecution claim 1, claim 2 of the ’386 patent corresponds to prosecution claim 4,
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`and claim 3 of the ’386 patent corresponds to prosecution claim 5.
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`39. To obtain allowance, claim 1 of the ’386 patent (prosecution claim 1),
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`claim 2 (prosecution claim 4), and claim 3 (prosecution claim 5) were amended as
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`follows (amendments shown with underlining).
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`Claim 1 (prosecution claim 1). A monetary transaction system for
`conducting monetary transactions between subscribers and other entities, the
`system comprising one or more of:
`an integration tier operable to manage mobile wallet sessions, the
`integration tier also including a communication application programming
`interface (API) and other communication mechanisms to accept messages
`from channels;
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`notification services operable to send notifications through different
`notification channels including one or more of short message peer-to-peer,
`short-message services and simple mail transfer protocol emails;
`business process services operable to implement business workflows,
`including at least one of executing financial transactions, auditing financial
`transactions, invoking third-party services, handling errors, and logging
`platform objects;
`database services operable to store financial transaction details, store
`customer profiles, and manage money containers;
`a payment handler service operable to use APIs of different payment
`processors including one or more APIs of banks, credit and debit cards
`processors, bill payment processors;
`a rules engine operable to gather financial transaction statistics and
`use the gathered financial transaction statistics to enforce constraints
`including transaction constraints;
`a security service operable to perform subscriber authentication;
`at least one entity that is to be involved in the specified transaction, the at
`least one entity having a profile with the monetary transaction system:
`wherein the at least one entity is the agent; and
`wherein the monetary transaction system is implemented to deposit
`funds at an agent branch, the funds being deposited by a subscriber at the
`agent branch using a mobile device configured to run a monetary transaction
`system application, the monetary transaction system performing the
`following steps:
`receiving a communication message from the mobile device over one
`of a plurality of channels connected to the monetary transaction system, the
`communication message being received by an API associated with the
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`APPL-1003
`APP