Inter Partes Review
`U.S. Patent No. 9,189,785
`
`Apple Inc. v. Mozido, Inc., Case IPR2022-01150
`
`Eugene Goryunov,
`Haynes Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Ex.1011 / IPR2022-01150 / Page 1 of 23
`Apple Inc. v. Mozido, Inc.
`
`
`U.S. Patent No. 9,189,785
`
`Apple Inc. v. Mozido, Inc., Case IPR2022-01150
`
`Eugene Goryunov,
`Haynes Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Ex.1011 / IPR2022-01150 / Page 1 of 23
`Apple Inc. v. Mozido, Inc.
`
`
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`Background on ’785 Patent
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`Ex.1001 (’785 Patent), Abstract, Fig. 5; Pet. 7-8, 10.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`2
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`2
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`Instituted Claims and Grounds
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. 14; Institution Decision, 5.
`3
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`3
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`Easterly-Luz renders obvious claim 1
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`• Easterly renders obvious limitation [1.4.4]
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`• Easterly renders obvious limitation [1.4.6]
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`Easterly-Luz renders obvious claim 4
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`Easterly-Luz renders obvious claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`4
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`4
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`
`• Easterly teaches a customer profile that indicates a
`desired route to settle the transaction
`
`Easterly
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`Ex.1003, ¶94; Ex.1005, ¶124; Pet. 37; Reply 4-5.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`5
`5
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`
`• Easterly provides that a debit (EFT) network is an
`example mechanism for settling a transaction
`
`Easterly
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`Ex.1003, ¶95; Ex.1005, ¶13; Pet. 37; Reply 4-5.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`6
`6
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`Easterly
`
`• Easterly’s teaching of a specific route to settle the transaction is not
`limited to a payment type
`• Limiting Easterly to a payment type would exclude Easterly’s disclosure
`of routing preferences that include external debit networks
`Ex.1005, ¶¶14, 96; Reply 5; Ex.1003, ¶94.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`7
`7
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`
`Patent Owner’s Expert
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex.2004, ¶73; Reply 6.
`8
`8
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`
`Patent Owner’s Expert
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex.1010, 25:1-17; Reply 7.
`9
`9
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`Easterly Renders Obvious [1.4.4]
`Embedded Payment Information Including “an Indication of Which Debit Network is to be Used to
`Process the Payment”
`
`Patent Owner’s Expert
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex.1010, 10:23-11:1; Reply 7.
`10
`10
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`Easterly-Luz renders obvious claim 1
`
`• Easterly renders obvious limitation [1.4.4]
`
`• Easterly renders obvious limitation [1.4.6]
`
`Easterly-Luz renders obvious claim 4
`
`Easterly-Luz renders obvious claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`11
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`
`Limitation [1.4.6]
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex.1001, claim 1.
`12
`12
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`
`• Easterly teaches that the barcode includes a user
`preferred network
`
`Easterly
`
`000
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`Ex.1003, ¶101; Ex.1005, ¶¶124, 95, 14; Pet. 35-36, 39-40; Reply 8.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`13
`13
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`
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`
`• Easterly teaches that the barcode includes a
`merchant’s preferred network
`
`Easterly
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`Ex.1003, ¶101; Ex.1005, ¶¶96, 124; Pet. 40-41, 39-40; Reply 8-9.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`14
`14
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`
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`
`• Easterly teaches that the barcode includes a specific
`route to settle the transaction (“selected network”)
`
`Easterly
`
`0
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`0
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`Ex.1003, ¶107; Ex.1005, ¶¶28, 124; Pet. 41; Reply 12.
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`15
`15
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`Petitioner’s Expert
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`Easterly
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`Ex.1003, ¶¶111, 109; Ex.1005, ¶20; Pet. 41-43; Reply 10-11.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`16
`16
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`Easterly Renders Obvious [1.4.6]
`Indication of Which Debit Network is to be Used Includes “(1) a User Preferred Network, (2) a
`Provider Preferred Network and (3) a Selected Network”
`
`Easterly
`
`000
`
`0
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`Ex.1005, ¶¶124, 95; Pet. 39, 41; Reply 10-11, 13-14.
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`17
`17
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`Easterly-Luz renders obvious claim 1
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`• Easterly renders obvious limitation [1.4.4]
`
`• Easterly renders obvious limitation [1.4.6]
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`Easterly-Luz renders obvious claim 4
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`Easterly-Luz renders obvious claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`18
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`Easterly Renders Obvious Claim 4
`Debit Network is Selected “Based on the Location at Which the Payment is Initiated”
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`Petitioner’s Expert
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`Easterly
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`• Petition equates the claimed “location” to one of different merchants,
`e.g., T.J.Maxx or CVS
`
`Ex.1003, ¶144; Ex.1005, ¶96; Pet. 52-53; Reply 14.
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`19
`19
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`Easterly Renders Obvious Claim 4
`Debit Network is Selected “Based on the Location at Which the Payment is Initiated”
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`Easterly
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`• Easterly renders obvious claim 4 even under Patent Owner’s
`suggestion that the claimed “location” means a geographic location
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex.1005, ¶21; Reply 15-16.
`20
`20
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`Easterly-Luz renders obvious claim 1
`
`• Easterly renders obvious limitation [1.4.4]
`
`• Easterly renders obvious limitation [1.4.6]
`
`Easterly-Luz renders obvious claim 4
`
`Easterly-Luz renders obvious claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`21
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`Easterly Renders Obvious Claim 5
`Debit Network is Selected “Based on Time of Day at Which the Payment is Initiated”
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`• Easterly teaches that the merchant has preferences for
`routing the transaction, including taking into account time
`Easterly
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`Ex.1003, ¶148; Ex.1005, ¶14; Pet. 53-54; Reply 16.
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`22
`22
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`Inter Partes Review
`U.S. Patent No. 9,189,785
`
`Apple Inc. v. Mozido, Inc., Case IPR2022-01150
`
`Eugene Goryunov,
`Haynes Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
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`23
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