PATENT OWNER’S DEMONSTRATIVE
`EXHIBITS FOR ORAL ARGUMENT
`
`IPR2022-00976
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`APPLE INC.,
`
`Petitioner,
`
`
`v.
`
`
`FINTIV, INC.,
`
`Patent Owner.
`
`
`
`
`
`Case No. IPR2022-00976
`U.S. Patent N o 9,892,386
`
`
`
`
`

`

`Overview
`
`• Business process services limitations (Claims 1-3)
`• Deposit/Withdrawal Limitations (Claim 1-2)
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`2
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`Business Process Services Limitations
`
`Claim 1- Deposit Funds Transaction
`
`Claim 2- Withdraw Funds Transaction
`
`Claim 3- Transfer Funds Transaction
`
`1. A monetary transaction system for conducting
`monetary transactions between subscribers and other
`entities, the system comprising one or more of:
`
`2. A monetary transaction system for conducting
`monetary transactions between subscribers and other
`entities, the system comprising one or more of:
`
`3. 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;
`
`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;
`
`….
`
`an integration tier operable to manage mobile wallet
`sessions and maintain the integrity of financial
`transactions, the integration tier also including a
`communication application programming interface
`(API) and other communication mechanisms to accept
`messages from channels;
`
`an integration tier operable to manage mobile wallet
`sessions and maintain the integrity of financial
`transactions, the integration tier also including a
`communication application programming interface
`(API) and other communication mechanisms to accept
`messages from channels;
`
`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;
`
`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;
`
`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;
`
`…
`
`….
`
`APPL-1001, 30:1-31:3
`
`APPL-1001, 32:3-32:20
`
`APPL-1001, 33:33-33:50
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`3
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`DILL FAILS TO TEACH THE CLAIMED BUSINESS
`PROCESS SERVICES (CLAIMS 1-3)
`• Petitioner does not dispute that, under SuperGuide Corp. v. DirectTV
`Enters, 358 F.3d 870, 885-886 (Fed. Cir. 2004), the phrase “at least
`one of A and B” requires at least one A and at least one B *
`• Accordingly, the claims require that the business process services be
`operable to implement, inter alia, (i) auditing at least one financial
`transaction, (ii) handling at least one error, and (iii) logging at least
`one platform object.
`• Dill does not teach systems that’s performs any
`• auditing at least one financial transaction
`• handling at least one error
`• logging at least one platform object
`
`*Sur-Reply at 17
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`Dill Does Not Teach “Auditing a Financial Transaction”
`
`Petition at 28-29
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`Dill uses the “transaction identifier” to determine whether
`or not to perform the transaction
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`5
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`APPL-1005
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`Auditing As Explained by Dr. Shamos
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`Ex. 2009 at 18-19
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`6
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`Dill Does Not Teach “Auditing a Financial Transaction” as
`Understood by a POSITA
`
`POR at 39
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`Parties agree that Dill teaches a prospective test
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`7
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`Reply at 14
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`Sur-Reply at 13
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`Dill Does Not Teach “Handling Errors/ Error Handling*”
`
`Petition at 29
`
`*Parties Agree Handling
`Errors and Error Handling are
`synonymous
`
`Ex 2018 at 117:10-118:5
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`APPL-1005
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`Dill teaches that the data in transaction is “verified” prior
`to performing the transaction
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`Handling Errors/Error Handling
`As Explained by Dr. Shamos
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`Ex. 2009 at 19-20
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`9
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`Handling Errors/Error Handling As Explained by Dr. Houh
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`Ex 2018 at 125:13-125:16
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`Parties agree that “Try-Catch-Finally” block in
`Java script is an example Error Handler
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`Ex 2018 at 126:2-126:6
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`Dill Does Not Teach “Handling Errors/ Error Handling”
`as Understood by a POSITA
`
`POR at 40
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`Dill does not teach that anything
`is done in response to the error
`being detected
`
`Reply at 15
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`Sur-Reply at 14
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`Dill Does Not Teach “Logging Platform Objects”
`
`Petition at 30-31
`
`Dill teaches looking up subscriber information in a
`database
`
`APPL-1005
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`Logging As Explained by Dr. Shamos
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`Ex. 2009 at 21-23
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`13
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`Dill Does Not Teach “Logging Platform Objects”
`as Understood by a POSITA
`
`POR at 42
`
`Reply at 18
`
`Sur-Reply at 21
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`Dill does not teach storing any information about any of objects in in Dill’s system in a log
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`Petitioner has failed to meet it’s burden of identifying
`“[h]ow the challenged claim is to be construed” under
`35 CFR 42.104(b)
`
`Reply at 12
`
`Reply at 14
`
`Reply at 17
`
`Reply at 19
`
`Petition at 5
`
`Where the meanings of terms are
`potentially subject to dispute, it is
`incumbent that the Petition set
`forth its construction of the
`metes and bounds of each such
`term.
`POR at 16
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`15
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`Petitioner has attempted to shift the burden to the Patent
`Owner
`
`Auditing
`
`Handling Errors/ Error Handling
`
`Reply at 13
`
`Reply at 15
`
`a “determination that a claim term “needs no construction” or has the “plain and ordinary
`meaning” may be inadequate when a term has more than one “ordinary” meaning or when
`reliance on a term’s “ordinary” meaning does not resolve the parties’ dispute.”
`O2 Micro Int'l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1361 (Fed. Cir. 2008).
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`Sur-Reply at 11
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`16
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`Petitioner has attempted to shift the burden to the Patent
`Owner
`
`Logging
`
`Reply at 18
`
`Reply at 19
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`Petitioner Never Offered What the Plain and Ordinary Meaning
`of Any Terms Is
`• During his deposition, Dr. Houh was asked numerous times to articulate his
`definitions of the “ordinary and customary meanings” of disputed claim terms.
`• With respect to “auditing” see: 99:2-10; 99:11-19; 100:2- 11; 100:12- 101:5; 101:25- 102:20;
`104:11-21; 104:22- 105 Ll.13; 105:15- 106:6; 106:16-25; 107:1-9; 108:8-22;
`• With respect to “error handling” see: 117:16- 118:5; 118:11- 120:7; 120:8-19; 122:23- 124:6;
`124:7- 125:2; 126:5-11; 126:12- 127:1.
`Sur-Reply at 11
`• In every case, he failed to provide any specific meaning for the term, often
`dodging the questions by criticizing Dr. Shamos’ construction while refusing to
`offer one of his own.
`
`Petitioner has failed to meets is burden of identifying
`“[h]ow the challenged claim is to be construed”
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`Only evidence of the “plain and ordinary meaning” of
`the terms is provided by Dr. Shamos
`
`• “Plain and ordinary meaning” is that the ordinary meaning that would be
`attributed to those words by persons of ordinary in the relevant art.
`• Petitioner does not dispute that Dr. Shamos is a POSITA.
`• Dr. Shamos offered is understanding of the terms “auditing,” “handling
`errors/ error handling,” and “logging” as a POSITA based on reviewing the
`patent its entirety.
`• Dr. Shamos’ understanding of the terms is consistent with extrinsic
`evidence that would have been available to a POSITA as of the effective
`filing date.
`• Petitioner offered no alternative meaning that their POSITA (Dr. Houh)
`would have ascribed to the terms.
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`The Plain and Ordinary Meaning as
`understood by a POSITA is:
`
`Ex. 2009 at 17
`
`Ex. 2009 at 19
`
`Ex. 2009 at 21
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`Petitioner has failed to meet it’s burden of identifying
`“[h]ow the construed claim is unpatentable,” under 35
`CFR 42.104(c)
`• Petitioner alleges that claim terms should be construed under “plain
`and ordinary meaning”
`• Petitioner offers no evidence of how a POSITA would understand the
`claim terms under “plain and ordinary meaning”
`• Patent Owner does offer evidence of how of how a POSITA would
`understand the claim terms “plain and ordinary meaning”
`• Accordingly Patent Owner’s “plain and ordinary meaning” of the
`terms is the only evidence in the record
`• Cited References do not meet “plain and ordinary meaning” as
`defined by the evidence in the record
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`DILL FAILS TO SHOW OR SUGGEST A TRANSACTION
`DILL FAILS TO SHOW OR SUGGEST A TRANSACTION
`WHERE THE SENDER AND THE RECIPIENT ARE ONE
`WHERE THE SENDER AND THE RECIPIENT ARE ONE
`AND THE SAME (CLAIMS 1 AND 2)
`AND THE SAME (CLAIMS 1 AND 2)
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`Patent Owner Response, at 4.
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`Deposit Transaction Disclosed in ‘386 Patent (e.g., a “Cash-in”)
`
`Patent Owner Response, 3-5.
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`Undisputed Limitation of Claim 1
`
`Petitioner does not dispute that Claim 1 recites a transaction
`where a subscriber deposits funds into the subscriber’s own account …
`
`(Patent Owner response, at 1; Patent Owner’s Sur-Reply, at 1).
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`The Petition’s Mapping of ¶101 of Dill to the Deposition Transaction of Claim 1
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`Patent Owner Response, at 26-27 (quoting Petition at 48).
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`The Petition’s Mapping of ¶ 101 of Dill to the Deposition Transaction of Claim 1
`
`This passage teaches that, in the
`context of a transaction
`between a sender 105 and a
`recipient, the transferred funds
`can be delivered to a funds
`withholding system. The
`passage does not state or even
`imply that the sender and
`receiver are the same party.
`
`Patent Owner’s Sur-Reply, at 7, quoting Dill at ¶ 101.
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`The Petition’s Mapping of Fig. 5 of Dill to the Deposition Transaction of Claim 1
`
`Sender and
`recipient are
`not the same
`party.
`
`Patent Owner Response at 27
`(quoting Petition at 50-51).
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`In Dill, The Sender And Receiver Are Unrelated Parties
`
`Dill is explicit: the
`sender’s mobile wallet is
`unrelated to the receiving
`mobile wallet.
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`29
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`Dill (Ex. 1005), at ¶57; see Patent Owner Response, at 28-29.
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`

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`Dr. Houh Relies On Dill’s Statement That The Sender And Receiver
`Are Unrelated Parties For Numerous Aspects of Claim 1
`Element [1.1] - Ex. 1003, ¶78: “Further, Dill discloses that the money transfer facilitator 140 “provide[s] a structured
`settlement between unrelated entities such as the sending mobile wallet 125 and receiving mobile wallet 130.”
`
`Element [1.4] – Ex. 1003, ¶ 104: “Dill teaches that the system 100 in Figure 9 “allows a money transfer facilitator 140, using
`a unique customer identifier and internal and/or external mapping databases 150, to provide a structured settlement between
`unrelated entities such as the sending mobile wallet 125 and receiving mobile wallet 130, or between the sending cash retail
`location and receiving mobile wallet 130.” APPL-1005, ¶57. Thus, Dill discloses that the database 150 is operable to store
`financial transaction details (e.g., unique identifiers for a structured settlement).”
`
`Element [1.10.9] – Ex. 1003, ¶¶159-160: Further, Dill teaches that the “money transfer facilitator 140, using a unique
`customer identifier and internal and/or external mapping databases 150, [] provide[s] a structured settlement between
`unrelated entities such as the sending mobile wallet 125 and receiving mobile wallet 130.”
`
`Element 1.11.5 – Ex. 1003, ¶180: Dill discloses that its system “allows a money transfer facilitator 140, using unique
`customer identifier and internal and/or external mapping databases 150, to provide a structured settlement between unrelated
`entities such as the sending mobile wallet 125 and receiving mobile wallet 130.”
`
`Element [1.11.8] – Ex. 1003, ¶188: Dill discloses that its system “allows a money transfer facilitator 140, using unique
`customer identifier and internal and/or external mapping databases 150, to provide a structured settlement between unrelated
`entities such as the sending mobile wallet 125 and receiving mobile wallet 130.”
`Patent Owner Response, at 29, note 4;
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`Sur-Reply at 8.
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`Dill Does Not Imply That The Sender And Recipient Are The Same In The Same Transaction
`
`This means that a party that acts as
`a sender in one transaction can
`alternatively act as a recipient in
`another (different) transaction.
`This language does not imply or
`suggest that the same party can act
`as both sender and receiver in the
`same transaction.
`
`… It should be noted that the names
`sender and recipient are used only to
`illustrate a particular entity's and/or
`device’s function at a given time and are
`not intended to imply any limitations on
`the functions that can be performed by a
`given entity and/or device. That is, any
`given entity and/or device associated with
`that entity can alternately act as sender or
`recipient. (Dill, ¶52)(emphasis added)
`
`Patent Owner Response, at 28.
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`Dill Does Not Imply That The Sender And Recipient Are The Same In The Same Transaction
`
`The Petition attempts
`to re-write Dill
`
`… That is, any given entity and/or
`device associated with that entity can
`alternately act as sender or recipient. ..
`(Dill, ¶52) (emphasis added)
`
`… That is, any given entity and/or
`device associated with that entity can
`alternately act as sender or and
`recipient.
`
`Patent Owner Response, at 28.
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`Patent Owner’s Expert Dr. Shamos Has Testified Unequivocally That Dill Restricts
`Its Transactions As Taking Place Between Unrelated Entities
`
`75. Quite simply, Dill restricts its transactions and taking place between unrelated
`entities. This precludes the sender and the receiver in Dill from being the same
`party. By contrast, in the deposit transaction of claim 1, the sender, who brings
`cash to the agent branch, is the same as the recipient, who wants the cash
`deposited in his account. No such transaction is disclosed in Dill.
`
`Declaration of Michael Shamos, Ex. 2009, ¶75 (emphasis in original).
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`The Reply Is Limited To Attorney Argument That Dill Discloses That The Sender and Receiver
`Can Be The Same Party In The Same Transaction
`
`… “While Petitioner’s Expert, Dr. Houh, submitted a Reply Declaration (Ex. 2018) in
`this matter, Dr. Houh’s Reply Declaration is silent on whether Dill discloses or
`suggests that the “sender” and “receiver” or “recipient” can be the same party in the
`same transaction. Accordingly, with respect to this issue, the Reply is based on
`attorney argument rather than expert testimony.” (Patent Owner’s Sur-Reply, at 2.)
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`The Underlined Arguments in the Reply Are Devoid Of Any Citations To
`Either Of Petitioner’s Expert Declarations (Exs. 1003 and 1017)
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`Patent Owner’s Sur-Reply, at 3.
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`

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`Dr. Houh’s Original Declaration Never Said That The “Sender” And
`“Receiver” Or “Recipient” Can Be The Same Party In The Same Transaction
`
`Dr. Houh stops short of
`stating that Dill discloses a
`“sender” and “receiver” or
`“recipient” being the same
`party in the same transaction.
`
`Patent Owner’s Sur-Reply, at 4-5 (quoting Houh Decl., Ex. 1003)
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`Dr. Houh’s Original Declaration Never Said That The “Sender” And
`“Receiver” Or “Recipient” Can Be The Same Party In The Same Transaction
`
`Dr. Houh refers back to his analysis
`of limitation [1.9.1] as allegedly
`supporting the notion that “Dill
`teaches that a sender deposits funds
`in her account;” however, his
`analysis of limitation [1.9.1] (at
`¶¶130-133 of his Declaration) makes
`no such statement.
`
`Patent Owner’s Sur-Reply, at 6 (quoting Houh Decl., Ex. 1003)
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`Petitioner Has Failed To Show By A Preponderance Of The Evidence
`That Dill Teaches That The “Sender” And “Receiver” Or “Recipient”
`Are The Same Party In The Same Transaction
`
`• Dill, ¶57 is explicit that the sender’s mobile wallet is unrelated to the receiving mobile wallet.
`
`• The Petition cannot rely on Dill, ¶57 for numerous elements of Claim 1 while simultaneously arguing that it is
`inapplicable to the claim limitation requiring that the subscriber deposit funds in the subscriber’s own account.
`
`• Dill, ¶101 teaches that, in the context of a transaction between a sender 105 and a recipient, the transferred
`funds can be delivered to a funds withholding system. The passage does not state or even imply that the sender
`and receiver are the same party.
`
`• Dill, ¶52 teaches that a party that acts as a sender in one transaction can alternatively act as a recipient in
`another (different) transaction. This language does not imply or suggest that the same party can act as both
`sender and receiver in the same transaction.
`
`• Petitioner uses only attorney argument in the Reply to counter the unequivocal testimony of Patent Owner’s
`Expert (Dr. Shamos) supporting the points set forth above.
`
`• Dr. Houh never testified that, in Dill, the “sender” and “receiver” or “recipient” can be the same party in the
`same transaction
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`Withdrawal Transaction Disclosed in ‘386 Patent (e.g., a “Cash-out”)
`
`Patent Owner Response, at 6.
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`Withdrawal Transaction Disclosed in ‘386 Patent (e.g., a “Cash-out”)
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`Undisputed Limitation of Claim 2
`
`Petitioner does not dispute that Claim 2 recites a transaction
`where… a subscriber withdraws funds from the subscriber’s own account.
`
`(Patent Owner’s Sur-Reply, at 1).
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`The Purported Motivation For Combining Dill And Liao Set
`Forth In The Petition Was Premised On The Assertion That
`Dill “Contemplates A Withdrawal Transaction”
`
`[2.12.1] wherein the monetary transaction system is implemented to withdraw funds at an agent branch using the mobile device
`configured to run a monetary transaction system application, including performing the following steps:
`
`Limitation [2.12.1] is rendered obvious by Dill and Liao. First, Dill discloses that the monetary transaction system is implemented at
`an agent branch. …
`
`Second, Dill contemplates a withdrawal transaction. Dill discloses that two types of transactions that may be performed in its money
`transfer facilitation system include “delivering funds to a bank account of a recipient such as destination account 175 of the recipient’s
`financial institution 170,” and “making funds available for pick up at an agent location.” APPL-1005, ¶101. A POSITA would have
`understood that these types of transactions involve withdrawing funds. APPL-1003, ¶239. …
`
`A POSITA would have been motivated to modify Dill so that the sender 105 (or recipient 110) may withdraw funds into the sender’s
`(or recipient’s) account. Dill teaches that two types of transactions that may be performed in its money transfer facilitation system
`include “delivering funds to a bank account of a recipient,” and “making funds available for pick up at an agent location.” APPL-1005,
`¶101. Thus, Dill contemplates a withdrawal transaction. APPL-1003, ¶244.
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`Petition, at 96-98.
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`

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`The Petition Relied On Liao For Its Use Of A
`“Mobile Device” For Performing The Transaction
`
`…This modification of Dill would have been desirable to a POSITA for several reasons. First, Dill’s objective is to
`take advantage of the capability of mobile devices to conduct “money transfer services.” APPL-1005, ¶4. As shown
`by Liao, making withdrawals with a mobile phone is one type of “money transfer service[]” that would have been
`desirable to a POSITA in view of Dill’s emphasis on providing “improved methods and systems for performing
`money transfers to facilitate flexible payment options for the transactions.” APPL-1005, ¶4; APPL-1003, ¶245.
`
`Second, this modification would have involved the combination of prior art elements (Dill’s money
`transfer facilitation system with Liao’s withdrawal using a mobile phone) according to known methods
`(withdrawing funds with a mobile phone, as taught by Liao) to yield the predictable and desirable result of
`permitting Dill’s sender (or receiver) to withdraw funds from her account.
`
`Petition, at 98-99.
`
`IPR2022-00976
`
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
`
`43
`
`

`

`Conclusion
`
`• Dill does not teach each of
`• Auditing
`• Logging
`• Error Handling
`• Petitioner has not met their burden of showing “[h]ow the challenged
`claim is to be construed.”
`• Dill fails to show or suggest a transaction where the sender and the
`recipient are one and the same.
`• Dill fails to show or suggest a deposit transaction or a withdrawal
`transaction.
`
`IPR2022-00976
`
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
`
`44
`
`