Trials@uspto.gov
`571-272-7822
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`Paper 36
`Entered: February 1, 2024
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`ASSA ABLOY AB, ASSA ABLOY INC.,
`ASSA ABLOY RESIDENTIAL GROUP, INC., AUGUST HOME, INC.,
`HID GLOBAL CORPORATION, and
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioners,
`
`v.
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`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
`____________
`
`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`____________
`
`Record of Oral Hearing
`Held: November 9, 2023
`____________
`
`Before SCOTT A. DANIELS, AMBER L. HAGY, and FREDERICK C.
`LANEY, Administrative Patent Judges.
`
`
`
`

`

`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`ON BEHALF OF THE PETITIONER:
`
`DION BREGMAN, ESQUIRE
`ANDREW DEVKAR, ESQUIRE
`Morgan, Lewis & Bockius LLP
`Silicon Valley
`1400 Page Mill Road
`Palo Alto, California 94304-1124
`
`ON BEHALF OF THE PATENT OWNER:
`
`ANDREW RYAN, ESQUIRE
`STEVEN M. COYLE, ESQUIRE
`Cantor Colburn LLP
`20 Church Street, 22nd Floor
`Hartford, Connecticut 06103
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` The above-entitled matter came on for hearing on Thursday, November
`9, 2023, commencing at 1:00 p.m. EDT, at the U.S. Patent and Trademark
`Office, 600 Dulany Street, Alexandria, Virginia.
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`

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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`
`P R O C E E D I N G S
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`- - - - -
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`JUDGE DANIELS: Good afternoon, everyone. Welcome. It's
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`Thursday, November 9th. And we have the next two cases here in this
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`series. We have this afternoon the oral hearings for IPR2022-01093 and
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`01094, ASSA ABLOY versus CPC Technologies. I'm Judge Daniels. Also,
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`here with me are Judge Hagy and Judge Laney.
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`Can I get the party's appearances please? We have first from
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`Petitioner.
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`MR. BREGMAN: Good afternoon, Your Honors. I'm lead
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`Counsel, Dion Bregman. With me is my colleague, Andrew Devkar,
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`who will be handling the arguments on behalf of the Petitioner today.
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`Believe client representatives Chris Kroby and Yon Sohn are also on the
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`public line.
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`JUDGE DANIELS: Thank you. So, Mr. Devkar is doing all the
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`arguments today?
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`MR. BREGMAN: Yes, sir.
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`JUDGE DANIELS: Great. And from Patent Owner?
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`MR. COYLE: Good afternoon, Your Honor. Steve Coyle from
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`Cantor Colburn, for the Patent Owner CPC. With me today are my
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`colleagues, Andrew Ryan and Nicholas Geiger. With the Board's
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`permission, I will be handling the bulk of the substantive argument related to
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`the various prior art issues. My colleague Andrew Ryan will -- to the extent
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`that there's a discussion of the real party in interest issue, he will handle that.
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`JUDGE DANIELS: Great. Thank you, Mr. Coyle. All right. You
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`all have heard this before, but I'll run through the housekeeping issues pretty
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`

`

`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`quickly. Each party has 60 minutes of total time to present your arguments.
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`Each party can allocate the time however you choose. When it's your turn,
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`please just let me know how much time you'd like to reserve for rebuttal.
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`As always, if you are referring to exhibit on the screen -- and you can
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`share your screen with us, if you if you'd like -- please share for the record
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`the exhibit and page number or for demonstrative, the slide numbers to
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`which you're referring. We have this -- we have your demonstratives up as
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`well as the case file, so we can look at it as well as, again, if you want to
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`share something through the screen.
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`Petitioner has the burden on the original claims and will go first in
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`each case. And -- well, you can present both of your cases. Unless you
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`want to, you can present them both in your first -- in your time. And then
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`Patent Owner will go second. And as I said, you can each reserve time for
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`rebuttal.
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`I'll keep the hearing right here with me on my phone. And I already
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`told the court reporter that we will pause at the end once we've concluded
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`the hearing in order for her to ask for any clarifications or questions she
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`might have.
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`All right. And unless there's any questions, we can get going. And
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`Mr. Devkar, you -- you're up first. Just let me know how much time you
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`want to reserve.
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`MR. DEVKAR: Thank you, Your Honor. I'd like to reserve 30
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`minutes, please.
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`JUDGE DANIELS: Okay.
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`MR. DEVKAR: Okay. Good afternoon, Your Honors. May it
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`please the Board. As you know, we're here to discuss two IPRs which
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`

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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`challenged the claims of the 039 patent. Now, because these IPRs have been
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`consolidated and have the same disputed issues, I intend for all the points I
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`make today to apply to all the claims in both IPRs, unless otherwise stated.
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`Further yonder because the same disputed issues apply to all claims in these
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`IPRs. We believe that all challenged claims rise or fall together on a narrow
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`set of issues.
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`I'll share Petitioners' demonstratives here as I get going. So, I'm
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`going to refer to Petitioners' slide 4 to begin with a little background on the
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`039 patent to set the context for everyone. Now, the 039 patent was directed
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`to a style of authentication that use both a user's card, such as a credit card,
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`smart card or key fob or the like, as well as the user's biometric signature.
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`For example, a process could be used for authentication at an ATM machine.
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`According to the 039 patent where you would have a typical card, such as a
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`credit card, for accessing the ATM machine.
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`But in addition to that card, which would typically have a pin number
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`or the like, you would also scan your biometric fingerprint -- biometric data,
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`such as using the fingerprint for a user. And this allowed for improved
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`security according to the 039 patent because instead of using only a card,
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`which could be stolen or forged, you're pairing that card with a check against
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`the user's biometric data. And by adding this verification against a user's
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`biometric data, such as a fingerprint, the security of the system was
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`purportedly improved.
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`Now, referring to Petitioners' slide 6, let's look at representative
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`Claim 1 and figure 4 of the patent, which is the most critical figure in the
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`039 patent for the disputes at issue in these proceedings. Looking at figure
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`4, what's shown here is a card or -- that a user would hold. And in that card,
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`in field 604, is card information or a segment of card information that's
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`labeled as 605. The card information at element 604 in the patent was a
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`pointer. And throughout the 039 patent, it refers to a biometric card pointer
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`arrangement. And this element 604 was a pointer. It was an actual memory
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`address.
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`And that memory address pointed to a specific memory location in a
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`local database 124, which was external to the card. Now, in Claim 1, you'll
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`see a recitation of the system. In step 1[A], receiving card information. In
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`step 1[B], receiving biometric -- the biometric signature. And in steps 1[C],
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`"defining, dependent upon the received card information, a memory location
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`in a local memory external to the card." Now, what this is saying is the
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`system is now determining what the relevant memory location is that -- that's
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`pointed to by that card. And as shown in figure 4, that card has a field, the
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`card information 604, that points to a specific memory location in the
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`database.
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`Now, usually --
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`JUDGE LANEY: Counsel, can I just ask you a quick question?
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`MR. DEVKAR: Sure.
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`JUDGE LANEY: The context of figure 4 in the specification, to a
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`person of skill in the art, what is the breadth of a pointer? So -- I mean, is
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`the pointer saying memory address -- I don't know how it would refer to that
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`specific physical address. Or is a pointer sufficient so that the system is a
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`piece of information that will then be used to go to a specific -- another
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`specific location? I'm just trying to understand your -- what do you -- what's
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`your position on -- in the context of the specification in the figure 4, how a
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`person skilled in the art, the breadth, they would understand pointer?
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`MR. DEVKAR: Yeah. Great question, Your Honor. So, in our
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`petition, we presented two alternatives for what that could mean. And one
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`of the alternatives was that it was an actual pointer, it was an actual memory
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`address that pointed to a specific memory address in the memory. But
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`alternatively, this could be interpreted as a -- that the card information
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`determines the memory address or allows the system to determine in a one-
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`to-one fashion what memory address is at issue.
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`And I think, Your Honor, it would be helpful to understand that the
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`context of what this was all about and the purported point of novelty in the
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`039 patent because I think that illuminates your question. I'm now going to
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`refer to Petitioners' slide 8. And this was the whole point of the biometric
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`pointer system in the 039 patent.
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`And I'm going to refer to an excerpt in the 039 patent, which is
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`Exhibit 1001, at column 8, lines 34 through 41. And it reads, "It is noted
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`that the step 204 reads the contents stored at a single memory address
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`defined by the card data and checks these contents against the biometric
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`signature received in the step 203. There is no need to search the entire
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`database to see if there is a match. Thus, the disclosed biometric card
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`pointer arrangement provides a particularly simple and fast biometric
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`verification check."
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`So, what the patent is saying, Your Honor, is that the purported point
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`of novelty is that the -- by pointing to a specific memory location, the system
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`is now able to check and perform verification against a particular biometric
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`signature stored and corresponding to a specific user. This is in contrast to
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`checking sequentially all of the signatures in the database until one finds a
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`match or doesn't find the match. Now, that's a very computationally
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`intensive process comparing fig -- signatures. The idea here -- this was
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`access control or performing authentication. So, you want to be able to do it
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`very quickly and efficiently.
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`So, what the 039 patent is saying is, let's have the card information
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`point to or determine a specific memory address so that we can perform a
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`very fast biometric verification check by comparing in a one-to-one fashion,
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`the biometric signature that's input by the user at the station against a
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`particular biometric signature stored in the database. You only have to
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`compare against one signature, as opposed to comparing against many of
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`So, looping back to your question, Your Honor, what the pointer --
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`what the memory location does is serve to determine a specific memory
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`location. And that's why we believe it was -- also an interpretation that you
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`could use, for example, a database lookup. And we understand that in the
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`recent final written decision that you reached in a another IPR recently on
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`the same patent, you essentially came to that conclusion in determining a set
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`of claims unpatentable that given a card information, you could correlate or
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`store in association that card information with a particular biometric
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`signature in a database. And that would in effect, satisfy the defining
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`limitation because you are identifying in one-to-one fashion a particular
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`biometric signature. And --
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`JUDGE LANEY: And is there any -- I'm sorry. Are there any facts
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`or any arguments or facts presented in this case that would re -- not just
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`require, but that we should be made particularly aware of in light of the
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`earlier ruling? In other words, is there something else we need to address, or
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`

`

`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
`
`is the -- are all the relevant facts that were addressed in that ruling equally
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`applicable in this case? Do you understand my question?
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`MR. DEVKAR: I do understand your question, Your Honor. And
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`thank you for raising it. The answer is we think the Board's construction got
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`it largely correct. And we were happy to see that because it results in
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`unpatentability of the challenged claims in this proceeding for much the
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`same reason as it did in the Apple IPR.
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`But there was one thing that -- because in that related proceeding, the
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`panel was not asked to consider Claim 3. And I think that sheds a little light
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`on the Board's construction because Claim 3 was not -- unlike the claims
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`that were considered in the other proceeding, which were recited as methods
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`for enrollment, Claim 3 is recited -- and I'm referring to Petitioners' slide 7
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`right now on the screen. Claim 3 was recited as a method for securing a
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`process at a verification station in which both an enrollment and a
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`verification step are recited.
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`So, if we look at elements D of Claim 3, element D recites, "If the
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`provided card information has not been previously provided to the
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`verification station, storing the inputted biometric signature in a memory at a
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`memory location defined by the provided card information."
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`And in contrast, in element E, "If the provided card information has
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`been previously provided to the verification station, comparing the inputted
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`biometric signature to the biometric signature stored in the memory at the
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`memory location defined by the provided card information."
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`So, in Claim 3, what we're seeing is there is a memory location
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`defined by the provided card information. We see it right there in figure 4 to
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`the right. In the patent -- in the sole embodiment in the patent, there was a
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`memory pointer stored on the card, and it pointed to a specific memory
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`location.
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`What Claim 3 is saying is you're going to do one of two things with
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`that defined memory location. You're either going to store to it, in the event
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`that you're doing enrollment, or you're going to read from it, in the event that
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`you're doing verification. The purported invention was that simple Your
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`Honors you have a memory location defined by card information. In other
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`words, the card information determines a specific memory location and
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`you're either going to store to it or you're going to read from it, depending on
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`whether you're doing enrollment or verification.
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`JUDGE LANEY: And I understand from what you just said, or I'd
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`like you to correct me if my understanding is incorrect, you're saying
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`defined by in this context similar to our earlier discussion about pointer is
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`that the information will drive where the computer goes in the memory for
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`the information, either to store it or retrieve it. It doesn't -- and I want to
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`clarify, you're not suggesting defined by means that that card is going to
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`have a specific matrix or -- however it is computers know at the smallest
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`granular level of where that data is stored.
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`It's not going to have that information, or it's not required to have that
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`information. It may but it -- all that's required by the claim is that it has a
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`data piece, that that data piece is necessarily going to identify where in
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`memory, either to store or to retrieve this information.
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`MR. DEVKAR: Yes, Your Honor. I believe your description was
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`correct. That's what we believe. And that's what the Board's construction in
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`the related proceeding, we think, got entirely correct is that the card
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`information determines the specific memory location at issue, a -- in a one-
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`to-one fashion, not a one-to-many fashion, a one-to-one fashion. And that
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`aspect of the Board's construction was correct. And I think it resolves the
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`disputes in this IPR, just as it did in the related IPR because in the
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`Petitioners' Hsu ground, we indeed have a database record that correlates a --
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`the user's card information or account number that stored on the card with a
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`particular biometric signature stored in memory.
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`And when that's later retrieved, the system compares against that
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`specific signature stored at that specific memory location, not anyone else's,
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`not everyone else's in sequence. It allows a comparison against a particular
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`So, does that answer your question, Your Honor?
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`JUDGE LANEY: Yes, thank you. And I definitely want you to get
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`back to you. I think you were going to address something that you didn't
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`like about our construction. And I want to make sure I hear --
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`MR. DEVKAR: Oh, yeah. So, the one thing I was going to point out
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`was that the construction you reached was focused on the enrollment
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`procedure. And that's understandable because the claims at issue in that
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`proceeding were recited as methods of enrollment. And so, I believe, Your
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`Honors noted that in the enrollment procedure, the memory location allows,
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`determines the specific memory location at issue.
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`But what -- all I wanted to point out is that as we read the patent, it's
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`not restricted to an enrollment. In fact, Patent Owner's expert admitted
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`repeatedly in his deposition in this proceeding, the card information defines
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`the memory location already even before you get to the system and scan the
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`card.
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`And we see that right in figure 4. The card information determines a
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`memory location already. It's just that when you go to the system, the
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`system is now going to do -- the system now needs to identify what the
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`memory location of interest is. So, in that sense, once the system scans the
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`card, it now knows or is able to determine the specific memory location at
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`issue.
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`But all we wanted to point out is that there's nothing specific to
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`enrollment that is required here. The -- this happens the same way for both
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`enrollment and verification. It's just what you're going to do with that
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`memory location that differs. You're either going to store to it, or you're
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`going to read from it. That --
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`JUDGE LANEY: But presumably -- I mean, presumably -- so --
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`maybe I'm misunderstanding. Presumably, the card is generic when it's
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`created. And then at some point, the card becomes someone's card based on
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`the data that is put onto the card. What I hear you saying is that my -- what I
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`just said may not be right because you're saying that the card itself, even
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`before it becomes someone's card, will have data that can -- that will
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`determine the location and memory or the biometrics. And I guess I'm
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`MR. DEVKAR: Yeah. So, Your Honor, in the only example in the
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`patent, the card information had a -- an actual memory address in it. The
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`card pointed -- points to a specific memory address in memory. Now, as
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`you know, and I think the Board's final written decision in the related IPR
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`found is that the patent is not limited to that, as long as the card information
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`determines the specific memory address, allows the system to determine a
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`specific memory address at issue, then that that's sufficient.
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`IPR2022-01094 (Patent 8,620,039)
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`But there's no evidence in the patent of anything other than what's
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`shown in figure 4, where you have a pointer pointing to something. So, in
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`that instance, the card information -- someone would have already
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`predefined this card with a specific memory address that points to a specific
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`memory location. Now, if instead of database was used, there are other
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`ways that one could do this, so long as the information in the card
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`determines a specific memory address in a database.
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`And I think that was indeed the example that was used in the recent
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`final written decision is there would be a record in a database, the card
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`information would allow the system to quickly retrieve that record and know
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`which memory location at which to store the biometric signature. But
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`there's no evidence in that -- of that in the patent, Your Honor. The only
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`embodiment in the patent was a card that had the card information
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`predefined on it. And it, of course, corresponded to a specific memory
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`location and memory.
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`JUDGE LANEY: And why is it relevant to this case, you
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`highlighting that enrollment aspect? In other words, if we were to disagree
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`with you and stand by the enrollment part that you're highlighting, how does
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`that impact your case here?
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`MR. DEVKAR: It will not impact it, Your Honor. That's why I say
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`in that sense, we're completely happy with the Board's construction because
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`it leads to unpatentability the claim's in just the same way. Our art, you
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`know, satisfies the defining limitation for both enrollment and verification.
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`So, the fact that you've set it for verification doesn't change the outcome in
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`our proceedings.
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`I was just pointing out that if we were to write the construction
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`ourselves, it would be very similar, but it would not be limited to the
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`enrollment procedure. That is a distinction that's -- that ultimately is not
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`going to matter here, Your honor. It -- for much the same reasons that Your
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`Honors reached in the related IPR proceeding are grounded based on the
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`Hsu reference -- and that's H-S-U -- involves a very similar database storage
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`where user -- card information for a user is stored in one-to-one
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`correspondence with the biometric signature, and not satisfied for both
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`enrollment and verification.
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`And then we -- of course, we have a separate ground, which I won't
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`belabor right now that -- that's much like the 039 patent. But in both cases,
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`the memory location determines -- sorry -- the card information determines
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`the memory location in both enrollment and verification. So, it ultimately
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`doesn't make a difference, Your Honor.
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`JUDGE DANIELS: I just have a quick follow up. And also, let me
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`say that this was one of the more difficult claim constructions we've done in
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`a while. And I think some of it has to do with, you know, there's not a
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`whole lot other than the pointing to, which isn't very helpful in the patent
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`itself. So, we really had to look hard at what both parties, you know,
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`proposed for claim construction, and how it was argued, as you saw.
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`That aside, as far as -- you make a good distinction between the
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`enrollment and the verification. So, it's still your position after Judge
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`Laney's questions that set or established, still can apply to both enrollment
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`and the later verification stages as we essentially did in the prior cases.
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`MR. DEVKAR: I want to make sure I'm understanding the question
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`properly, Your Honor. I -- we do believe that the memory location is
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`defined by the card information in all instances, you know, for both
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`enrollment and verification. But we're not -- it -- the Board's construction
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`that was reached in the related proceeding is perfectly sufficient for the
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`purposes of these IPR just as it was there because our art satisfies both the
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`enrollment -- it satisfies the defining limitation for both enrollment and for
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`verification. So, it doesn't change the outcome, Your Honor.
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`And -- does that answer your question, or were you asking
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`something slightly different?
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`JUDGE DANIELS: No. I think that's a good answer. If I was
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`asking something different, it's probably just my own -- our own thought
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`process in the panel. And we had a lot of discussions about this claim
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`construction. So, if I can articulate it better later on in the hearing, I'll try it
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`again.
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`MR. DEVKAR: Yeah. Thank you, Your Honor. And just to be
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`clear, we're not challenging the Board's construction because it's perfectly
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`adequate for this proceeding. I was just pointing out that that is why you
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`saw some discussion in our brief before the Board had reached its recent
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`construction about the enrollment procedure versus verification. We were
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`trying to point out the same points I was just making here.
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`But let me point out what I think is the critical finding that the Board
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`made that resolves the disputes in this proceeding. And I'm going to put a
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`Petitioners demonstrative slide 10 on the screen here. And these are some
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`excerpts from the written decision in the related proceeding, which for the
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`record is IPR2022-00600 at paper number 22. And in this first excerpt, you
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`have, Your Honors, saying that the card data is provided for setting or
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`establishing what memory location address or address in the local database
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`the fingerprint is to be stored.
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`But then you -- Your Honors make the critical finding that even with
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`this understanding, however, the card data does not actually create a memory
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`location. The memory location already exists. It just has not been set or
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`established by the card data as the memory location at which the fingerprint
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`data is stored.
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`And then below that multiple iterations of, you know, what defining
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`means. And Your Honor said, defining means to identify a memory location
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`into which the biometric data is going to be stored. And that's the critical
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`piece, Your Honor, is that Patent Owner had presented somewhat of a
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`moving target on what they meant and what their construction was. And
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`they use the word set or established.
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`But what they really meant to say was that set or established means
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`that the system needs to create the memory location in the enrollment
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`procedure. And Your Honors correctly disagreed with that by saying that
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`the memory location already exists. It just hasn't been set by the system yet
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`as the location of interest. And in that sense, we totally agree, Your Honor.
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`This resolves the disputes in this proceeding because the Hsu reference -- H-
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`S-U -- the Hsu reference has a database entry -- a database record that
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`correlates the card information in a one-to-one fashion with a user's
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`biometric signature or fingerprint data.
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`And show -- referring now to Petitioners' slide 11, these are some of
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`the findings when applying the Board's defining construction to the database
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`entry at issue in the related proceeding. And you'll see down in the bottom
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`excerpt, at page -- which occurs at page 45 of the final written decision,
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`IPR2022-01094 (Patent 8,620,039)
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`"The creation of a player account in Bradford or Foss, prior to receiving the
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`card information, does not preclude subsequently identifying a memory
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`location, among pre-existing memory locations or addresses within the pre-
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`existing player ID database, and establishing that memory location as the
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`location where the new biometric data, e.g., a player's fingerprint, is going to
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`be stored."
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`And that, Your Honor, is the same analysis that would be done for
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`the Hsu reference in these proceedings, which has a database in which there
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`is a storage of card information in association with one's fingerprint data.
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`And that record is easily retrievable. And for the verification by the same
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`card information, it is a one-to-one correspondence. So, it -- that same
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`analysis applies here in these proceedings and leads to unpatentability for the
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`same reasons, Your Honor.
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`Ultimately, Patent Owner originally tried to say that the memory
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`location needs to be created. And Your Honor, I'll read from Patent Owner's
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`response at pages 11 and 12. In the 1093 Proceeding. Patent Owner states
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`there, defining, as used in the challenged claims, does not and cannot mean
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`merely looking up or identifying something that has already been defined.
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`And that was Patent Owner's position. In other words, you can't have
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`an already existing memory location. You need to recreate it based on the
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`card information. As we pointed out, Your Honors, incidentally, regardless
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`of what -- even under Patent Owner's meaning, Hsu would still satisfy that
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`construction. But what you -- what your final written decision points out is
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`that it is not necessary to create the memory location. The memory location
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`can already exist in the database, so long as it's -- it can be determined from
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`the card information what the memory location of interest is.
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`JUDGE LANEY: Do you think the preferred embodiment shows one
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`that it creates a memory location? I guess I'm having a hard time with
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`understanding how the card could create -- I mean, memories of physical
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`thing, right? A memory location, at some levels, that's physical thing?
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`MR. DEVKAR: That's right.
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`JUDGE LANEY: Physically separate from the card?
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`MR. DEVKAR: That's -- oh, sorry.
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`JUDGE LANEY: Do you agree with that?
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`MR. DEVKAR: A memory location is indeed a physical address.
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`Now, whether that's a specific memory location pointed to by a pointer or
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`simply a physical address that -- that's retrievable from a database record
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`based on card information, Your Honors' construction allowed for either of
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`those.
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`I think what would illuminate your question, Your Honor, about
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`whether it is created or not, I've shown Petitioners' slide 17 on the screen.
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`And I think figure 5 is very helpful for illuminating what's going on here. If
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`you look down the flowchart shown in figure 5 here, you have in step 202,
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`process the card information. So, now the card information has been
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`received by the reader. In step 203, you receive the user's biometric
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`signature.
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`Critical here, Your Honor, is step 204. If you see step 204, it says
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`memory at card data. This is computer science shorthand for pointer
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`notation. So, the memory at the memory location of card data equals
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`signature question mark. And what this means is, is the memory location at
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`IPR2022-01093 (Patent 8,620,039)
`IPR2022-01094 (Patent 8,620,039)
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`So, the system is actually checking, hey, we know what the memory
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`location is. Is there a signature there