Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 1 of 11
`
`Exhibit F - U.S. Patent No. 8,620,039 Claim Chart Against HID’s Biometric Products
`
`Claim Term(s)
`Claim 1
`(1.) A method of enrolling in a
`biometric card pointer system,1
`the method comprising the steps
`of:
`
`Accused HID System
`
`To the extent the preamble is found to be limiting, use of the Accused HID System—which
`includes one or more of HID’s biometric readers such as the Signo 25B Biometric Reader (“HID
`Reader”), in conjunction with HID Biometric Manager Software (“HBM”)—comprise a method
`of enrolling in a biometric card pointer system:
`
`“2.9.2 Enroll Cards
`
`1. On the People screen select a displayed person record.
`
`2. On the Cards screen click ADD CARD.
`
`3. At this point on the Details screen you can either scan a card to obtain the card details
`
`or, if no card is available,
`
`manually enter card details.
`Scan card for card details
`
`1. On the Details screen, click READ CARD. If more than one reader is installed, select a
`device from the displayed list.
`
`2. Within five seconds, present a card to the Signo Biometric Reader 25B device.
`
`Note: The card types supported by the device is configured in the device profile settings,
`
`see 2.21.2 Edit a device profile.”
`
`See HID® Biometric Manager Administration Guide at 46 (accessed at:
`https://www.hidglobal.com/sites/default/files/resource_files/plt-04029-b.2-hid-biometric-
`manager-administration-guide.pdf)
`
`“2.10.1 Enroll Biometrics
`
`One of the main features of HBM is enabling the enrollment of a fingerprint for
`
`authentication and access control when
`
`using the Signo Biometric Reader 25B.
`
`
`1 The term “biometric card pointer system” has been construed in CPC Patent Technologies Pty Ltd. v. Apple Inc. (“Apple Case”) to be a non-limiting preamble
`term with no patentable weight. With respect to any constructions of the ’039 patent terms from the Apple Case, although these constructions are not necessarily
`binding in this case, we are using them for the purposes of this analysis.
`
`
`
`1
`
`ASSA ABLOY Ex. 1030 - Page 1
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 2 of 11
`
`Claim Term(s)
`
`(1.a) receiving card
`information;
`
`(1.b) receiving the biometric
`signature;
`
`Accused HID System
`There are two ways to enroll the biometrics of a user:
`
`1. Signo Biometric Reader 25B reader.
`
`2. SIGNO-B-USB desktop enrollment reader.
`Note: HBM will use the SIGNO-B-USB reader by default. To use the Signo Biometric Reader
`25B for enrollment, you can select it at the start of enrollment.
`After enrollment, the user record containing the user information and biometrics are encrypted
`and stored in the HBM server database by default, for distribution to the connected Signo
`Biometric Reader 25B devices.”
`
`See HID® Biometric Manager Administration Guide at 52
`
`The HID Reader and the HBM software running on a computer are configured to receive
`information related to a biometric card:
`
`“2.9.2 Enroll Cards
`
`1. On the People screen select a displayed person record.
`
`2. On the Cards screen click ADD CARD.
`
`3. At this point on the Details screen you can either scan a card to obtain the card details
`
`or, if no card is available,
`
`manually enter card details.
`Scan card for card details
`
`1. On the Details screen, click READ CARD. If more than one reader is installed, select a
`device from the displayed list.
`
`2. Within five seconds, present a card to the Signo Biometric Reader 25B device.
`
`Note: The card types supported by the device is configured in the device profile settings,
`
`see 2.21.2 Edit a deviceprofile.”
`
`See HID® Biometric Manager Administration Guide at 46
`The HID Reader and the HBM software running on a computer are configured to receive a
`biometric signature:
`
`
`
`2
`
`ASSA ABLOY Ex. 1030 - Page 2
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 3 of 11
`
`Claim Term(s)
`
`Accused HID System
`
`
`
`
`
`
`
`3
`
`ASSA ABLOY Ex. 1030 - Page 3
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 4 of 11
`
`Claim Term(s)
`
`Accused HID System
`
`See HID® Biometric Manager Administration Guide at 53-54
`
`
`
`
`
`4
`
`ASSA ABLOY Ex. 1030 - Page 4
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
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`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 5 of 11
`
`Claim Term(s)
`(1.c) defining, dependent upon
`the received card information, a
`memory location in a local
`memory external to the card;
`
`Accused HID System
`The HBM software, which is external to the card, includes a memory location comprising a
`database of card credentials and biometric signatures (labeled “Credential Database” in the
`diagram below):
`
`
`
`
`
`See HID® Biometric Manager Administration Guide at 8 (accessed at:
`https://www.hidglobal.com/sites/default/files/resource_files/plt-04029-b.2-hid-biometric-
`manager-administration-guide.pdf)
`
`
`“The Credential Database is a SQL database that HBM services uses to store the
`credential data that has been gathered through manual registration or 1.5.4 Data Import. It
`also stores configuration data and transaction logs for all installed Signo Biometric
`Reader 25B devices.”
`
`
`See HID® Biometric Manager Administration Guide at 9.
`
`The HBM software identifies a memory location for the top credential associated with a person,
`and assigns the biometric data to that memory location:
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
`
`
`
`5
`
`ASSA ABLOY Ex. 1030 - Page 5
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 6 of 11
`
`Accused HID System
`The HBM software identifies a memory location for the top credential associated with a person,
`determines whether that memory location is unoccupied and, if it is unoccupied, assigns the
`biometric data to that memory location and stores it there:
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
` A
`
` maximum of “[t]hree templates with 10 fingers each can be enrolled” per person. Id. at 52.
`New biometrics cannot be registered without deleting old templates if the maximum has been
`reached. Id.
`The HBM software identifies a memory location for the top credential associated with a person,
`determines whether that memory location is unoccupied and, if it is unoccupied, assigns the
`biometric data to that memory location and stores it there:
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
` A
`
` maximum of “[t]hree templates with 10 fingers each can be enrolled” per person. Id. at 52.
`New biometrics cannot be registered without deleting old templates if the maximum has been
`reached. Id.
`
`
`To the extent the preamble is found to be limiting, the Accused HID System—which includes
`one or more of HID’s biometric readers such as the Sigmo 25B Biometric Reader (“HID
`
`Claim Term(s)
`(1.d) determining if the defined
`memory location is unoccupied;
`and
`
`(1.e) storing, if the memory
`location is unoccupied, the
`biometric signature at the
`defined memory location.
`
`Claim 13
`(13.) A biometric card pointer
`enrolment system comprising2:
`
`
`2 The term “biometric card pointer enrollment system” has been construed in the Apple Case to be a non-limiting preamble term with no patentable weight. With
`respect to any constructions of the ’039 patent terms from the Apple Case, although these constructions are not necessarily binding in this case, we are using
`them for the purposes of this analysis.
`
`
`
`6
`
`ASSA ABLOY Ex. 1030 - Page 6
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Claim Term(s)
`
`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 7 of 11
`
`Accused HID System
`Reader”), in conjunction with HID Biometric Manager Software (“HBM”)—comprises a
`biometric card enrollment pointer system:
`
`“2.9.2 Enroll Cards
`
`1. On the People screen select a displayed person record.
`
`2. On the Cards screen click ADD CARD.
`
`3. At this point on the Details screen you can either scan a card to obtain the card details
`
`or, if no card is available,
`
`manually enter card details.
`Scan card for card details
`
`1. On the Details screen, click READ CARD. If more than one reader is installed, select a
`device from the displayed list.
`
`2. Within five seconds, present a card to the Signo Biometric Reader 25B device.
`
`Note: The card types supported by the device is configured in the device profile settings,
`
`see 2.21.2 Edit a deviceprofile.”
`
`See HID® Biometric Manager Administration Guide at 46 (accessed at:
`https://www.hidglobal.com/sites/default/files/resource_files/plt-04029-b.2-hid-biometric-
`manager-administration-guide.pdf)
`
`“2.10.1 Enroll Biometrics
`
`One of the main features of HBM is enabling the enrollment of a fingerprint for
`
`authentication and access control when
`
`using the Signo Biometric Reader 25B.
`There are two ways to enroll the biometrics of a user:
`
`1. Signo Biometric Reader 25B reader.
`
`2. SIGNO-B-USB desktop enrollment reader.
`Note: HBM will use the SIGNO-B-USB reader by default. To use the Signo Biometric Reader
`25B for enrollment, you can select it at the start of enrollment.
`After enrollment, the user record containing the user information and biometrics are encrypted
`and stored in the HBM server database by default, for distribution to the connected Signo
`Biometric Reader 25B devices.”
`
`
`
`7
`
`ASSA ABLOY Ex. 1030 - Page 7
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 8 of 11
`
`Claim Term(s)
`
`(13.a.) a card device reader for
`receiving card information;
`
`(13.b) a biometric reader for
`receiving the biometric
`signature;
`
`Accused HID System
`
`See HID® Biometric Manager Administration Guide at 52
`
`The HID Reader is a card device reader for receiving card information:
`
`“2.9.2 Enroll Cards
`
`1. On the People screen select a displayed person record.
`
`2. On the Cards screen click ADD CARD.
`
`3. At this point on the Details screen you can either scan a card to obtain the card details
`
`or, if no card is available,
`
`manually enter card details.
`Scan card for card details
`
`1. On the Details screen, click READ CARD. If more than one reader is installed, select a
`device from the displayed list.
`
`2. Within five seconds, present a card to the Signo Biometric Reader 25B device.
`
`Note: The card types supported by the device is configured in the device profile settings,
`
`see 2.21.2 Edit a deviceprofile.”
`
`See HID® Biometric Manager Administration Guide at 46
`The HID Reader is a biometric reader that receives a biometric signature:
`
`“2.10.1 Enroll Biometrics
`
`One of the main features of HBM is enabling the enrollment of a fingerprint for
`
`authentication and access control when
`
`using the Signo Biometric Reader 25B.
`There are two ways to enroll the biometrics of a user:
`
`1. Signo Biometric Reader 25B reader.
`
`2. SIGNO-B-USB desktop enrollment reader.
`Note: HBM will use the SIGNO-B-USB reader by default. To use the Signo Biometric Reader
`25B for enrollment, you can select it at the start of enrollment.
`
`
`
`8
`
`ASSA ABLOY Ex. 1030 - Page 8
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 9 of 11
`
`Claim Term(s)
`
`(13.c) means for defining,
`dependent upon the received
`card information, a memory
`location in a local memory
`external to the card;3
`
`Accused HID System
`After enrollment, the user record containing the user information and biometrics are encrypted
`and stored in the HBM server database by default, for distribution to the connected Signo
`Biometric Reader 25B devices.”
`
`See HID® Biometric Manager Administration Guide at 52
`The HBM software, which is external to the card, includes a means for defining, dependent upon
`the received card information, a memory location comprising a database of card credentials and
`biometric signatures (labeled “Credential Database” in the diagram below). A user’s computer
`running the HBM software is a computer system with a processor executing an application that
`uses one or more segments of card information from a card as a memory reference or to
`determine a group of associated memory references. Specifically, the HBM software, upon
`receiving card information, can determine the user associated with the card information and
`whether the credential database has stored a biometric signal related to that card:
`
`
`
`
`
`See HID® Biometric Manager Administration Guide at 8 (accessed at:
`https://www.hidglobal.com/sites/default/files/resource_files/plt-04029-b.2-hid-biometric-
`manager-administration-guide.pdf)
`
`
`
`3 The term “means for defining, dependent upon the received card information, a memory location in a local memory external to the card” has been construed in
`Apple Case to be means plus function language. The function was further defined in the Apple Case to mean “defining, dependent upon the received card
`information, a memory location in a local memory external to the card.” The structure was defined in the Apple Case to be “a computer system with a processor
`executing an application that uses any segment of card information 605 from a card 601 (1) as a memory reference as shown in Fig. 4 or (2) to determine a group
`of associated memory references or (3) all equivalents of (1) and (2).” With respect to any constructions of the ’039 patent terms from the Apple Case, although
`these constructions are not necessarily binding in this case, we are using them for the purposes of this analysis.
`
`
`
`9
`
`ASSA ABLOY Ex. 1030 - Page 9
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 10 of 11
`
`Accused HID System
`“The Credential Database is a SQL database that HBM services uses to store the
`credential data that has been gathered through manual registration or 1.5.4 Data Import. It
`also stores configuration data and transaction logs for all installed Signo Biometric
`Reader 25B devices.”
`
`
`See HID® Biometric Manager Administration Guide at 9.
`
`The HBM software identifies a memory location for the top credential associated with a person,
`and assigns the biometric data to that memory location:
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
`The HBM software includes a means for identifying a memory location for the top credential
`associated with a person, determines whether that memory location is unoccupied and, if it is
`unoccupied assigns the biometric data to that memory location:
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
` A
`
` maximum of “[t]hree templates with 10 fingers each can be enrolled” per person. Id. at 52.
`New biometrics cannot be registered without deleting old templates if the maximum has been
`reached. Id.
`The HBM software includes a means for storing, if the memory location is unoccupied, the
`biometric signature at the defined memory location. Specifically, a computer running the HBM
`software comprises a computer system with a processor unit running a software process(es) to
`store the biometric signature and at least one of a storage device or memory. The HBM software
`
`Claim Term(s)
`
`(13.d) means for determining if
`the defined memory location is
`unoccupied; and
`
`(13.e) means for storing, if the
`memory location is unoccupied,
`
`
`
`10
`
`ASSA ABLOY Ex. 1030 - Page 10
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`

`

`Case 6:22-cv-01170 Document 1-6 Filed 11/15/22 Page 11 of 11
`
`Accused HID System
`identifies a memory location for the top credential associated with a person, and assigns the
`biometric data to that memory location and stores it there.
`
`
`“When all of the selected fingers have been successfully scanned, click DONE. The
`enrolled fingerprints are associated with the top credential in the credential list.”
`
`
`See HID® Biometric Manager Administration Guide at 55.
`
` A
`
` maximum of “[t]hree templates with 10 fingers each can be enrolled” per person. Id. at 52.
`New biometrics cannot be registered without deleting old templates if the maximum has been
`reached. Id.
`
`
`Claim Term(s)
`the biometric signature at the
`defined memory location.4
`
`
`
`
`4 The term “means for defining, dependent upon the received card information, a memory location in a local memory external to the card” has been construed in
`Apple Case to be means plus function language. The function was further defined in the Apple Case to mean “storing, if the memory location is unoccupied, the
`biometric signature at the defined memory location.” The structure was defined in the Apple Case to be “a computer system with a processor unit 105 running
`software process(es) 401 and at least one of: a storage device 109 or memory 106.” With respect to any constructions of the ’039 patent terms from the Apple
`Case, although these constructions are not necessarily binding in this case, we are using them for the purposes of this analysis.
`
`
`
`11
`
`ASSA ABLOY Ex. 1030 - Page 11
`ASSA ABLOY AB v. CPC Patent Technologies Pty. Ltd.
`IPR2022-01093 - U.S. Patent No. 8,620,039
`
`