UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`MOZIDO CORFIRE – KOREA, LTD.
`Patent Owner.
`———————
`
`IPR2022-01149
`U.S. Patent No. 10,223,692
`_____________________
`
`DECLARATION OF DR. HENRY HOUH,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`1
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`Inter Partes Review of U.S. 10,223,692
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 4
`I.
`Qualifications and Professional Experience .................................................... 6
`II.
`III. Level of Ordinary Skill in the Art ................................................................. 13
`IV. Relevant Legal Standards .............................................................................. 14
`V.
`Background .................................................................................................... 16
`VI. Overview of the ’692 Patent .......................................................................... 17
`VII. Claim Construction ........................................................................................ 24
`A.
`“from the first portion of the screen” .................................................. 24
`VIII. Identification of how the Claims are Unpatentable ....................................... 27
`A. Ground 1: Claims 1-4 and 11-13 would have been obvious
`under 35 U.S.C. § 103(a) over Hertel in view of Chitti, Spodak,
`and Tedesco. ........................................................................................ 28
`1.
`Summary of Hertel (APPL-1005) .................................. 28
`2.
`Summary of Chitti (APPL-1006) .................................. 35
`3.
`Summary of Spodak (APPL-1008) ................................ 39
`4.
`Summary of Tedesco (APPL-1007) .............................. 40
`5.
`Overview of Analysis .................................................... 42
`6.
`Claim 1 ........................................................................... 44
`7.
`Claim 2 ......................................................................... 117
`8.
`Claim 3 ......................................................................... 123
`9.
`Claim 4 ......................................................................... 125
`10.
`Claim 11 ....................................................................... 127
`11.
`Claim 12 ....................................................................... 133
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`2
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`B.
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`C.
`
`E.
`
`Claim 13 ....................................................................... 135
`12.
`Ground 2: Claims 5-6 and 10 would have been obvious under
`35 U.S.C. § 103(a) over Hertel in view of Chitti, Spodak,
`Tedesco, and Bierbaum. .................................................................... 140
`1.
`Summary of Bierbaum (APPL-1010) .......................... 140
`2.
`Claim 5 ......................................................................... 143
`3.
`Claim 6 ......................................................................... 148
`4.
`Claim 10 ....................................................................... 148
`Ground #3: Claim 7 would have been obvious under 35 U.S.C.
`§ 103(a) over Hertel in view of Chitti, Spodak, Tedesco,
`Bierbaum and Grigg. ......................................................................... 150
`1.
`Summary of Grigg (APPL-1012) ................................ 150
`2.
`Claim 7 ......................................................................... 154
`D. Ground #4: Claim 8 would have been obvious under 35 U.S.C.
`§ 103(a) over Hertel in view of Chitti, Spodak, Tedesco, and
`Ording. ............................................................................................... 158
`1.
`Summary of Ording (APPL-1016) .............................. 158
`2.
`Claim 8 ......................................................................... 159
`Ground #5: Claim 9 would have been obvious under 35 U.S.C.
`§ 103(a) over Hertel in view of Chitti, Spodak, Tedesco, and
`Roman................................................................................................ 164
`1.
`Summary of Roman (APPL-1017) .............................. 164
`2.
`Claim 9 ......................................................................... 165
`Conclusion ................................................................................................... 169
`
`
`X.
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`3
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`Houh Declaration
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`I, Henry Houh, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
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`Inter Partes Review of U.S. 10,223,692
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`
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`1.
`
`I am making this declaration at the request of Apple, Inc. in the matter
`
`of the Inter Partes Review of U.S. Patent No. 10,223,692 (“the ’692 Patent”) to
`
`Min Hwan Jeon.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the outcome of this matter or the specifics of my testimony.
`
`3.
`
`I have been asked to provide my opinions regarding whether claims 1-
`
`13 (“the Challenged Claims”) of the ’692 Patent are unpatentable as they would
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`have been obvious to a person having ordinary skill in the art (“POSITA”) at the
`
`time of the alleged invention, in light of the prior art. It is my opinion that all of the
`
`limitations of the challenged claims would have been obvious to a POSITA.
`
`4.
`
`In the preparation of this declaration, I have studied:
`
`a.
`
`b.
`
`the ’692 Patent, APPL-1001;
`
`the prosecution history of the ’692 Patent (“’692 File History”),
`
`APPL-1002;
`
`c. U.S. Patent Publication No. 2009/0288012 to Hertel et al. (“Hertel”),
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`APPL-1005;
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`4
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`d. U.S. Patent Publication No. 2009/0037326 to Chitti et al. (“Chitti”),
`
`APPL-1006;
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`e. U.S. Patent 8,296,686 to Tedesco et al. (“Tedesco”), APPL-1007;
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`f. U.S. Patent Publication No. 2012/0123937 to Spodak (“Spodak”),
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`APPL-1008;
`
`g. U.S. Patent 7,967,196 to Bierbaum et al. (“Bierbaum”), APPL-1010;
`
`h. U.S. Patent Publication No. U.S. Patent Publication No.
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`2012/0197743 to Grigg et al. (“Grigg”), APPL-1012;
`
`i. U.S. Patent Publication No. 2009/0183120 (“Ording”), APPL-1016;
`
`and
`
`j. U.S. Patent 9,116,596 (“Roman”), APPL-1017.
`
`k. In forming the opinions expressed below, I have considered:
`
`the documents listed above;
`
`the relevant legal standards, including the standard for obviousness,
`
`and any additional authoritative documents as cited in the body of this
`
`declaration; and
`
`my own knowledge and experience based upon my work in the field
`
`of software and telecommunications as described below, as well as the
`
`following materials:
`
`a. U.S. Patent 7,090,577 to Serizawa et al., APPL-1009;
`
`
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`5
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`b. U.S. Patent 8,140,418 to Casey et al., APPL-1011;
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`c. U.S. Patent Publication No. 2013/0339166 to Baer et al., APPL-1013;
`
`d. U.S. Patent 5,732,230 to Cullen et al., APPL-1014;
`
`e. U.S. Patent 9,323,442 to Ledet et al., APPL-1015;
`
`f. U.S. Patent 6,590,568 to Astala et al., APPL-1018;
`
`g. U.S. Patent 9,436,376 to Shinozaki et al., APPL-1019; and
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`h. any other document cited in this analysis.
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`The materials I have reviewed and studied, including those listed in this paragraph,
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`are the type of evidence an expert in the field of software and mobile application
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`development would consider in reaching conclusions.
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`5.
`
`Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`6. My complete qualifications and professional experience are described
`
`in my Curriculum Vitae, a copy of which can be found in APPL-1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
`
`7.
`
`I received a Ph.D. in Electrical Engineering and Computer Science
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`from the Massachusetts Institute of Technology (“MIT”) in 1998. I also received a
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`Master of Science degree in Electrical Engineering and Computer Science in 1991,
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`
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`6
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`a Bachelor of Science degree in Electrical Engineering and Computer Science in
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`1989, and a Bachelor of Science degree in Physics in 1990, all from MIT.
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`8.
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`I am currently self-employed as an independent technical consultant. I
`
`am also president of a company, Einstein’s Workshop, that provides supplemental
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`science, technology, engineering, and mathematics (“STEM”) education to
`
`children of all ages.
`
`9.
`
`I first entered telecommunications in 1987 when I worked as a
`
`summer intern at AT&T Bell Laboratories as part of a five-year dual degree
`
`program at MIT. I continued to work at AT&T Bell Laboratories as part of this
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`MIT program. While at MIT, I was a teaching assistant (“TA”) in the Electrical
`
`Engineering and Computer Science Department’s core Computer Architectures
`
`course. I first was a TA as a senior for a role typically reserved for graduate
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`students. I later became head TA. The course covered various topics in computer
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`architectures, as well as programming. As a TA, I helped write homework
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`assignments, lab assignments (including those that involved programming), and
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`exams. I also taught in the recitation sections.
`
`10. Later, as part of my doctoral research at MIT from 1991-1998, I was a
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`research assistant in the Telemedia Network Systems (“TNS”) group at the
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`Laboratory for Computer Science. The TNS group built a high-speed gigabit
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`network and created applications that ran over the network. Example applications
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`included ones for remote video capture, processing, and display of video on
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`computer terminals. In addition to working on the design of core network
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`components (which was based on FPGAs), designing and building the high-speed
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`links (which included programmable logic devices), and designing and writing the
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`device drivers for the interface cards (which included programmable logic
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`devices), I also set up the group’s web server. Also, I helped to maintain, install,
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`and upgrade the networking devices used within the group, along with other
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`graduate students.
`
`11.
`
`I also helped to build the web pages that initiated the above-
`
`mentioned video sessions via a web interface. Vice President Al Gore visited our
`
`group in 1996 and received a demonstration of—and remotely drove—a radio-
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`controlled toy car with a wireless video camera mounted on it that was built by our
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`group. This toy car device received commands transmitted over a network from a
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`remote computer, and video data from the toy car was transmitted wirelessly then
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`over a computer network back to the user controller. On occasion, we allowed
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`users visiting our web site to drive the toy car from their remote computer while
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`they watched the video on their computer. The video stream was encoded by TNS-
`
`designed hardware, streamed over the TNS-designed network, and displayed using
`
`TNS-designed software.
`
`12.
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`I defended and submitted my Ph.D. thesis, titled “Designing Networks
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`for Tomorrow’s Traffic,” in January 1998. As part of my thesis research, I
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`analyzed local area and wide area flows to show a more efficient method for
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`routing packets in a network, based on traffic patterns at the time. The traffic flow
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`data included Ethernet, IP, TCP or UDP, and RTP header information, which I
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`analyzed to come to the conclusions in my thesis.
`
`13. From 1997 to 1999, I was a Senior Scientist and Engineer at NBX
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`Corporation, a start-up that made business telephone systems for streaming
`
`packetized audio over data networks instead of using traditional telephone lines.
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`NBX was later acquired by 3Com Corporation.
`
`14. As part of my work at NBX, I designed the core audio reconstruction
`
`software algorithms for the telephones, as well as the packet transmission
`
`algorithms. I also designed and validated the core packet transport protocol used by
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`the phone system. The protocol was used for all signaling in the phone system,
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`including for the setup of conference calls. The NBX system also featured a
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`computer interface for initiating phone calls, which could also initiate conference
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`calls. The NBX system also supported the Telephony Application Programming
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`Interface (“TAPI”) that allowed other computer programs to integrate with our
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`system telephony features. We obtained U.S. Patent No. 6,697,963, entitled
`
`“Telecommunication method for ensuring on-time delivery of packets containing
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`time-sensitive data,” as part of this work. I also programmed the first prototype of
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`our phone which communicated using IP, and I demonstrated our IP phones
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`working over the Internet when we attended a trade show in California. The phone
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`connected over the Internet to our headquarters in Andover, MA. I also
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`programmed a data capture and analysis system that provided data on the operation
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`of the system.
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`15. From 1999-2004, I was employed by Empirix or its predecessor
`
`company, Teradyne. Empirix was a leader in test tools for telecommunications
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`protocols and systems, providing functional testing tools as well as load testing
`
`tools. From 2000-2001, I conceived and built a test platform for testing Voice-
`
`over-IP (VoIP). The first application on this new test platform was a cloud
`
`emulator for simulating the effects of transmitting VoIP over a busy network. The
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`test platform was based on a network processor chip, which could be programmed
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`to cut-through packets while processing packet data such as various protocol later
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`headers including addresses included therein and even packet data contents. I also
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`designed a protocol analyzer built on the same platform. The application captured
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`and performed protocol decoding at various layers in the protocol stacks of
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`captured packets, including detailed Ethernet header decoding, IP header decoding,
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`TCP header decoding, UDP header decoding, RTP header decoding, and many
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`other specified protocols. The application was also designed to reconstruct entire
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`conversations that spanned multiple packets.
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`16. At Empirix, I also rearchitected the design of the Web Test division’s
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`core product, e-Test Suite. E-Test Suite was a software program designed to
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`perform functional and load testing of web applications. I was technical lead on
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`the project, and also worked on programming a Javascript interpreter for the
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`product. Javascript is the flexible programming layer that allows users to interact
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`with web pages through actions such as clicking and dragging that allows web
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`page programmers to extend the functionality of a web page beyond clicking on
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`links.
`
`17.
`
`In 2006, as part of my role at BBN Technologies, I helped found
`
`PodZinger Inc., now known as RAMP Inc. PodZinger utilized BBN’s speech
`
`recognition algorithms to search through the spoken words in audio and video
`
`segments. While I was Vice President of Operations and Technology, PodZinger
`
`followed its initial prototype with a full streaming audio and video search solution.
`
`I also created a social networking web site, which BBN sold to a venture-funded
`
`startup company. In the process of creating the web site, I designed and specified
`
`the authentication and authorization protocols.
`
`18. At my educational company, Einstein’s Workshop, I created the initial
`
`web site and integrated it with online payment solutions. I also evaluated, sourced,
`
`and configured the point-of-sale system for the company, which also involved
`
`integration with and setup of mobile shopping terminals. We also teach
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`programming to children of all ages, starting with Scratch programming for young
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`elementary students and advancing through programming in Python and for game
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`development for high school students. I conceived many of the programming
`
`classes and have taught programming to novice and more advanced students. We
`
`also created an educational computer-aided design tool, called BlocksCAD. We
`
`received a grant, on which I was the principal investigator, to further develop
`
`BlocksCAD and successfully met our grant objectives. BlocksCAD was spun-off
`
`from Einstein’s Workshop and has been part of various incubator/accelerator
`
`programs in education as well as at the MIT Media Lab. Today, BlocksCAD is
`
`used worldwide in makerspaces as well as in schools throughout the U.S.
`
`19.
`
`I have been awarded several United States patents, including the
`
`following examples:
`
`• U.S. Patent No. 7,975,296, “Automated security threat testing of
`
`web pages”;
`
`• U.S. Patent No. 7,877,736, “Computer language interpretation and
`
`optimization for server testing”;
`
`• U.S. Patent No. 7,801,910, “Method and apparatus for timed tagging
`
`of media content”;
`
`• U.S. Patent 7,590,542, “Method of Generating Test Scripts Using a
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`Voice-Capable Markup Language”; and
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`12
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`• U.S. Patent No. 6,967,963, “Telecommunication method for
`
`ensuring on-time delivery of packets containing time-sensitive
`
`data.”
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`20.
`
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
`
`experience of persons working in the field at the time of the invention; (2) the
`
`sophistication of the technology; (3) the types of problems encountered in the field;
`
`and (4) the prior art solutions to those problems.
`
`21. A person of ordinary skill in the art (“POSITA”) in November 2012
`
`would have had a working knowledge of network-based payment techniques
`
`pertinent to the ’692 Patent, including software development in the field of mobile
`
`payment techniques. Such POSITA would have had a bachelor’s degree in
`
`electrical engineering, computer science, or equivalent training, and approximately
`
`two years of work experience in software development. Lack of work experience
`
`can be remedied by additional education, and vice versa.
`
`22. For purposes of this declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the priority
`
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`date of the ’692 Patent (i.e., November 28, 2012 (“priority date”)). Unless
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`otherwise stated, when I provide my understanding and analysis below, it is
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`consistent with the level of a POSITA prior to the priority date of the ’692 Patent.
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`IV. RELEVANT LEGAL STANDARDS
`23.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’692 Patent, I am relying on certain basic
`
`legal principles that counsel have explained to me. These principles are discussed
`
`below.
`
`24.
`
`I understand that prior art to the ’692 Patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
`
`invention recited in the ’692 Patent. For purposes of this declaration, I am applying
`
`November 28, 2012, as the priority date of the ’692 Patent (“priority date”).
`
`25.
`
`It is my understanding that, to anticipate a claim under 35 U.S.C.
`
`§ 102, a reference must disclose each and every element of the claim. I have been
`
`informed that a reference may disclose an element expressly or inherently. I
`
`understand that, for a limitation to be inherently disclosed by a reference, the
`
`limitation necessarily must be present, or the natural result of the combination of
`
`elements explicitly disclosed by the prior art.
`
`26.
`
`I have been informed that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
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`that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
`
`takes into account factual inquiries including the level of ordinary skill in the art,
`
`the scope and content of the prior art, and the differences between the prior art and
`
`the claimed subject matter.
`
`27.
`
`I further understand that certain factors may support or rebut the
`
`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
`
`the invention, any long-felt but unsolved need in the art that was satisfied by the
`
`alleged invention, the failure of others to make the alleged invention, praise of the
`
`alleged invention by those having ordinary skill in the art, and copying of the
`
`alleged invention by others in the field. I understand that there must be a nexus—a
`
`connection—between any such secondary considerations and the alleged invention
`
`recited in the claims. I also understand that contemporaneous and independent
`
`invention by others is a secondary consideration tending to show obviousness.
`
`28.
`
`I am not aware of any allegations by the named inventor of the ’692
`
`Patent or any assignee of the ’692 Patent that any secondary considerations are
`
`relevant to the obviousness analysis of any Challenged Claim of the ’692 Patent.
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`29.
`
`I have been informed by counsel that the Supreme Court has
`
`
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
`
`obtain predictable results; (c) use of a known technique to improve a similar device
`
`(method, or product) in the same way; (d) applying a known technique to a known
`
`device (method, or product) ready for improvement to yield predictable results; (e)
`
`choosing from a finite number of identified, predictable solutions, with a
`
`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
`
`in the prior art that would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`V. BACKGROUND
`30. Mobile wallet applications, sometimes referred to as electronic wallets
`
`or “e-wallets,” are virtual wallets that allow users to store several debit card, credit
`
`card, membership card, coupons, or other account-type information in an
`
`application on their mobile phones. The mobile wallet application on the mobile
`
`phone can then be used to pay for goods or services either online or at point-of-sale
`
`terminals at merchant locations. E-wallets with this functionality were well-known
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`by the time of the ʼ692 Patent. See, e.g., APPL-1005 (Hertel), ¶ 58; APPL-1006
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`(Chitti), ¶¶ 23-25; APPL-1013 (Baer), ¶¶ 1-2. In some cases, the mobile wallet
`
`application may permit a user to enter several different payment instruments (e.g.,
`
`credit cards) in the application as available payment cards that the user may select
`
`to conduct a particular transaction. See, e.g., APPL-1005 (Hertel), ¶ 58; APPL-
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`1006 (Chitti), ¶¶ 23-25; APPL-1013 (Baer), ¶¶ 1-2, 51. The user can then designate
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`a particular payment card as the “main” or default payment card, but can also
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`switch to a “temporary” payment card as the payment instrument for a particular
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`transaction instead of the default payment card. See, e.g., APPL-1006 (Chitti),
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`¶¶ 26-27, 31; APPL-1008, ¶90; APPL-1013 (Baer), ¶ 51.
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`VI. OVERVIEW OF THE ’692 PATENT
`31. The ’692 Patent was originally filed as an international (PCT)
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`application on August 29, 2013,1 and claims priority to a Korean patent application
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`filed on November 28, 2012 (“priority date”). The ’692 Patent relates to “a method
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`for setting a payment card, and more particularly, to a method for setting a mobile
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`payment card to be used for payment and a mobile device applying the same.”
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`1 I have been informed that Application No. 14/647,859 (“the ’859 Application”)
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`was filed on May 28, 2015, as the U.S. national phase application of the PCT
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`application.
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`Houh Declaration
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`APPL-1001, 1:16-20.
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`Inter Partes Review of U.S. 10,223,692
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`32. The ’692 Patent explains that “[t]o prevent double payment, a mobile
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`wallet application sets one of the issued mobile payment cards as a main payment
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`card and makes a payment.” APPL-1001, 1:24-26. However, “[i]t is possible to
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`make a payment using a mobile payment card other than the main payment card.”
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`APPL-1001, 1:27-28. The ’692 Patent explains that:
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`When the user temporarily uses another mobile payment card to make
`a payment (for example, for one-time payment), the user should recover
`the original main payment card after finishing the payment. In this case,
`the operation of recovering the original main payment card may be a
`cumbersome procedure and may cause inconvenience to the user. In
`addition, the operation of changing the main payment card to another
`payment card may also cause inconvenience or difficulty to the user,
`and the user may not be accustomed to that operation, considering that
`mobile commerce is still at an early stage.
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`APPL-1001, 1:32-43.
`33.
`In view of this background, the objective of the ’692 Patent is to:
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`provide a method for setting a temporary payment card, which sets, as
`a temporary payment card, a mobile payment card which is moved by
`a user from among mobile payment cards listed in a list, and resets the
`setting of the temporary payment card when a payable time passes, so
`that a user can change the temporary payment card more easily, swiftly,
`naturally, amusingly, and intuitively, and a mobile device applying the
`same.
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`Houh Declaration
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`APPL-1001, 1:49-57.
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`Inter Partes Review of U.S. 10,223,692
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`
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`34. With reference to annotated Figures 10 and 11 below, the method of
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`the ’692 Patent displays a list of mobile payment cards (Fig. 10) at a first portion of
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`a touch screen interface of a mobile phone. APPL-1001, 4:36-40. The first portion
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`of the touch screen interface is shown toward the lower end of the touch screen
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`interface of the mobile phone in Figure 10. As shown in Figure 11, the method also
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`includes receiving, through the touch screen interface, a user input selecting a
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`mobile payment card (“ABC Premier”) from the list of mobile payment cards, and
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`detecting the user input sliding the mobile payment card from the first portion of
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`the touch screen interface to a second portion of the touch screen interface. APPL-
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`1001, 4:41-48. The second portion of the touch screen interface is shown toward
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`the upper end of the touch screen interface of the mobile phone in Figure 11. As
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`shown in Figure 11, the user has selected the “ABC Premier” card as the temporary
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`payment card. APPL-1001, 4:41-48.
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`Houh Declaration
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`Inter Partes Review of U.S. 10,223,692
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`second
`portion of
`touch
`screen
`interface
`
`card
`sliding
`up
`
`
`list of
`cards
`
`first portion
`of touch
`screen
`interface
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`APPL-1001 (’692 Patent), Figs. 10 and 11 (annotated)
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`
`
`
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`35. The ’692 Patent explains that based upon the user input of sliding the
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`mobile payment card (“ABC Premier”), the method includes setting, as a
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`temporary card, the mobile payment card, where, while the mobile payment card is
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`set as the temporary card, payments will be made by the mobile payment card.
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`APPL-1001, 4:56-61.
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`36. Payments will be made with the temporary payment card while it is
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`set as the temporary card for a limited period of time (e.g., 30 seconds). APPL-
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`1001, 4:62-65. As shown in annotated Figure 15 below, a numerical indicator of a
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`20
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`Houh Declaration
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`payable time (e.g., 30 seconds) is displayed while the temporary payment card is in
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`Inter Partes Review of U.S. 10,223,692
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`use. APPL-1001, 4:66-5:2, 5:42-43. Simultaneously, as shown in annotated Figure
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`16 below, the temporary mobile payment card is moved a first distance from a first
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`portion of the touch screen towards a second portion of the touch screen. As shown
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`in FIG. 16, the “ABC PREMIER” card is slid down by one-third (1/3) of the total
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`distance by which the card has been slid up, and “20 seconds” is identified as a
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`remaining payable time. APPL-1001, 5:43-47, 5:53-58, 5:63-6:2.
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`card
`moved
`down
`
`payable
`time
`
`remaining
`payable
`time
`
`APPL-1001 (’692 Patent), Figs. 15 and 16 (annotated)
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`37. When the payable time (e.g., 30 seconds) has passed, the temporary
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`Houh Declaration
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`payment card is reset such that the previously selected mobile payment card
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`Inter Partes Review of U.S. 10,223,692
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`(“ABC Premier”) is no longer set as the temporary card and payments are made
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`through a main/default card. APPL-1001, 4:62-65, 2:44-45, 2:51-52.
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`38. To obtain allowance, claim 1 was amended as follows (amendments
`
`shown with underlining).
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`1. A method for setting a temporary payment card, comprising:
`displaying a list of mobile payment cards at a first portion of a touch
`screen interface;
`receiving, through the touch screen interface, a user input selecting a
`mobile payment card from the list of mobile payment card;
`detecting the user input sliding the mobile payment card from the first
`portion of the touch screen interface to a second portion of the touch screen
`interface;
`based upon the user input sliding the mobile payment card, setting, as
`a temporary card, the mobile payment card, wherein while the mobile
`payment card is set as the temporary card, payments will be made by the
`mobile payment card;
`displaying a numerical indicator of a payable time, wherein the
`numerical indicator initially indicates a first remaining time amount;
`simultaneously:
`moving the mobile payment card a first distance from the first portion
`of the screen towards a second portion of the touch screen, and
`decrementing the numerical indicator a first difference to display a
`remaining payable time,
`wherein:
`the first distance is proportional to an amount of payable time
`that has passed, and
`the first difference is proportional to the amount of payable time
`that has passed: and
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`
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`Houh Declaration
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`Inter Partes Review of U.S. 10,223,692
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`resetting the setting of the temporary payment card when the payable
`time passes such that the mobile payment card is no longer set as the
`temporary card and payments are made through a main car