Patent Owner Demonstratives
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`1
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`Dr. Houh is Not A POSITA
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`POR, 9
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`POR, 10
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`“[t]he Board [has] within its discretion
`to weigh the credibility of expert testimony” Shoes by Firebug
`LLC v. Stride Rite Children’s Grp., LLC, 962 F.3d 1362, 1372
`(Fed. Cir. 2020)
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`POR, 9
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`2
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`Claim Terms
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`3
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`Integration Tier Including Web Services
`Communication Mechanisms
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`Reply , 2
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`Reply , 2
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`4
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`Sur-Reply , 1
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`Integration Tier Including Web Services
`Communication Mechanisms
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`Reply , 2
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`Sur-Reply , 5
`“The mere fact that there is an alternative embodiment disclosed in the [asserted patent] that is not encompassed by
`[our] claim construction does not outweigh the language of the claim, especially when the court’s construction is supported by the
`intrinsic evidence.” August Tech. Corp. v. Camtek, Ltd., 655 F. 3d 1278, 1285
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`5
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`…including web services communication mechanisms
`for interfacing with a mobile wallet application
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`Reply , 3-4
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`Reply , 4
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`Sur-reply , 21
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`6
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`…including web services communication mechanisms
`for interfacing with a mobile wallet application
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`Sur-Reply , 22
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`Sur-Reply , 21
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`Web Services are different that Web Sites and Web Pages
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`“Hardware SIM Card”
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`‘399 POR , 16
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`’399 Sur-Reply , 22
`8
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`THE PETITION FAILS TO DEMONSTRATE THE
`THE PETITION FAILS TO DEMONSTRATE THE
`UNPATENTABILITY OF CHALLENGED CLAIMS
`UNPATENTABILITY OF CHALLENGED CLAIMS
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`9
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`Petitioner Has Failed To Show That Dill Teaches An
`Integration Tier, Including A Web Services Communication Mechanisms
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`Sur-Reply , 14
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`Sur-Reply , 14
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`10
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`Dill Fails To Teach An Integration Tier That Includes A Web
`Services Mechanism For Interfacing With A Mobile Wallet Application
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`Dill’s Mobile Wallet Application (121) Doe NOT Communicate
`with the Web Interface (137)
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`Petition , 24
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`11
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`POR , 42-43
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`Dill Fails To Teach An Integration Tier That Includes Web Services Mechanisms For Interfacing With A
`Plurality Of Different Device Types Over A Plurality Of Different Channels
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`Petition , 24
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`The “Different Channels” identified by Petitioner do not
`interface with the web Interface
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`Reply , 15
`12
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`Dill Fails To Teach A Notification Services Engine Configured To
`Interface With The Integration Tier
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`Institution, 26
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`Houh Supplement Dec, 2
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`Reply, 12
`Petitioner educed no additional evidence of how the Dill’s
`Transfer Module Interfaces with itself
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`13
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`Dill Fails To Teach Receipt Of A Communication From The Agent
`Terminal Over At Least One Of The Plurality Of Channels
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`Dill is wholly silent with regard to any communication that is
`received from the agent (135) via the web interface (137)
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`POR , 37-38
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`Reply , 14
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`14
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`Dill Fails To Teach Receipt Of A Communication From The Agent
`Terminal Over At Least One Of The Plurality Of Channels
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`Petition , 45
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`Petitioner Changed their Mapping of “channels” from the
`Petition (left) to the reply (right)
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`Reply , 13
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`15
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`Petitioner Has Failed To Establish That Dill Teaches Web Services
`For Interfacing With A Mobile Wallet Application
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`Sur-Reply , 19
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`Petitioner has offered no evidence that Dill’s webpage is
`accessed with the mobile wallet application (120)
`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`16
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`POR , 45-46
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`Petitioner Has Failed To Establish That Dill Teaches Web Services
`For Interfacing With A Mobile Wallet Application
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`POR , 42
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`Sur-Reply , 20
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`An internet browser is not a “Mobile Wallet Application”
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`17
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`The Petition Erroneously Maps Dill’s Mobile Wallet Application
`(121) In Mobile Network Operator (120) To The Claimed “Mobile
`WalletApplication” Installed On A Mobile Device
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`Dill , [0094]
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`Institution , 29
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`Dill’s Mobile Wallet Application runs is run by the MNO
`and/or the transfer facilitator
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`POR , 49
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`18
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`Dill And Bykov Fail To Teach A Mobile Wallet Installed On A
`Hardware SIM Card
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`‘399 Petition , 23-24
`Bykov’s personal exchange
`module is not a “SIM Card”
`instead, it is a card used for
`NFC transactions
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`Independent claims
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`20
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`US 9,208,488
`US 9,208,488
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`[1.0] A computing system for facilitating managementof a
`mobile wallet, including: «0.0.0.0... ccccesseeneeeceseeseeeeneeeeeeeseeeenes
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`[1.1] ome Of MOre PLOCESSOMS) 0.0... eeeeceeeeseeneceeeeseceeeeseneeeeseeeeeaees
`
`[1.2] system MeMOLYs......... eee ceccecceeceeeeeeeeeceeeeeceeceseecaeesseeeeeseseeeeeeees
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`[1.3A] an integration tier configured to manage mobile wallet
`sessions with a mobile device and oo... ccc eeceeeseeseeeeueeueene
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`[1.3B] [an integration tier configured to manage mobile wallet
`sessions with a mobile device and] including webservices
`communication mechanisms for interfacing with a mobile
`wallet application installed on a hardware SIM card.............
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`[1.3C] [an integration tier configured to manage mobile wallet
`sessions and] ... as well as with a plurality of different
`device types over a plurality of different communication
`Chammel s, .........ccceccccessessacescessseceecesesueseeeessnscecessesenseeceeesseeeeeees
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`[1.3D] [an integration tier configured to manage mobile wallet
`sessions with a mobile device]... the integration tier being
`configured to receive binary and text messages from the
`MODE GEVICES cece esc cceccesssseseaesessussuseeeeeceeeeeeeueeveusausuueuaaueens
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`[1.4A] a notification services engine configured to interface
`with the integration tier amd 00.0.0... eee cece ceeeeeeeeeeeteeeeeeerens
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`[1.4B] [a notification services engine configured to interface
`with the integration tier and] to send Short Message Peer-
`to-Peer (SSMP) messages, Short Messaging Service
`(SMS) messages and Simple Mail Transfer Protocol
`(SMTP) messages over the different communication
`channels to different devices,............cccccccssesessessceenseeeeseeeeeeens
`
`[1.4C] [a notification services engine configured to interface
`with the integration tier and to send Short Message Peer-
`to-Peer (SSMP) messages, Short Messaging Service
`(SMS) messages and Simple Mail Transfer Protocol
`(SMTP) messages overthe different communication
`channels to different devices] including the mobile device,
`to interface with the mobile wallet application installed on
`the hardware SIM cardy........cccccsccssccssessesccsssseesceeeecsseneesseens
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`[1.5A] service connectors that are each configured to connect
`the computing system to a different third party system;.......
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`[1.5B] each of the service connectors being configured as a
`separate module for integrating a corresponding external
`service to the computing system) ...............:eceeeeeeeeeeeeeeereeees
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`[1.6] a payment handler that exposes a common API for
`interacting with different payment processors}..........2...000
`
`[1.7] a security services engine that performs subscriber
`authentication utilizing a database-based Access Control
`List (ACL)s.ccsccccsccsssssesssecsssetessseessseesrssessesssserssseessssesesueersveeees
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`[1.8] a rules engine configured to enforce constraints on
`financial transactions performed with the mobile wallet
`application, the mobile wallet application being associated
`with a mobile wallet account; amd 0... eeccececceeseneeeeeeseees
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`[1.9] one or more computer-readable storage media having
`stored thereon computer-executable instructions that are
`executable by the one or more processors to cause the
`computing system to perform a transaction for a customer
`using the mobile wallet which is owned by anotherentity
`than the customer, comprising the following: ................00+
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`[1.10A] the computing system receiving communication from
`an agent terminal over one of a plurality of communication
`channels connected to the cloud-based transaction
`PlARHOIIN, «os. eee eee eeteeee cece cee eeeee test eeeenaeseaeeneeseeceseaaeesaneaesneseneees
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`[1.10B]...the agent communication indicating that a customer
`desires to perform a transaction comprising a mobile
`wallet transaction using a third party mobile wallet..............
`
`[1.10C]...the mobile wallet transaction comprising at least one
`of a mobile wallet transfer in which funds are transferred
`from the mobile wallet of the customerto a third party
`mobile wallet, a mobile wallet withdrawal in which funds
`are withdrawn from the third party mobile wallet and
`provided to the customer, or a mobile wallet deposit in
`which funds are deposited into the third party mobile
`Wallets .........cccccccescscescesceccsseeeessessesessessescescesescessnneenecsans
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`[1.11] the computing system sending the agent communication
`to the third party mobile wallet platforms ..........ccsssceereneenes
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`[1.12A] the computing system determining whether the mobile
`wallet transaction comprises the mobile wallet withdrawal
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`[1.12B] ... when the mobile wallet transaction is determined to
`comprise the mobile wallet withdrawal, generating and
`providing a perishable withdrawal code to the consumer,
`which is presented to the agent terminalto facilitate
`processing of the mobile wallet withdrawal...
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`[1.13] the computing system receiving communication fromthe
`third party mobile wallet platform confirming processing
`of the transaction, the transaction comprising at least one
`of the mobile wallet transfer, the mobile wallet withdrawal
`or the mobile wallet deposit; and... cee ceeeesteeeeeneeeneenes
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`[1.14] the computing system sending communication to the
`agent terminal over one of a plurality of communication
`channels connected to the cloud-based transaction
`platform, the communication indicating confirmation of
`the processing of the tramsactiOn. .........0..cecccceeeeeseeeeeeneeeneenes
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`US 10,438,196
`US 10,438,196
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`[1.0] A computing systemfor facilitating management of a
`mobile wallet, COMPpPLiSiING: .............ccccscseecssesseseesereenseseneceseees
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`[1.1] OME OF MOLE PLOCESSOLS)........ccsecccsseserseeseeceesseseeseneenseseenensetes
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`[1.2] SYSTEM MMEMOLY)..........c cc ececcesseeceneeeceeeeeeseeeceeeensesseneessunesseneeess
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`[1.4C] [a notification services engine configured to interface
`with the integration tier and to send a plurality of
`corresponding different types of messages...to different
`devices] including a customer's mobile device, to interface
`with a mobile wallet application installed on the
`customer's Mobile MEVICE? occ ceececcceceeeeceseeseusenseesesseneeeeeneess
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`[1.3.A] an integration tier configured to manage mobile wallet
`sessions with a mobile device and oo... ccs ceseeseeeeneeees
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`[1.5] service connectors that are each configured to connect the
`computing system to a different third party system:..............
`
`[1.6] a payment handler that exposes a common APIfor
`interacting with different payment processors}.................+0
`
`[1.3B] [an integration tier configured to manage mobile wallet
`sessions with a mobile device and] including web services
`communication mechanisms for interfacing with a mobile
`wallet application and... cesceeeeseeeseeeeeeeeeeteaeeeeetneeetaeenaeeees
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`[1.3C] [an integration tier configured to manage mobile wallet
`sessions and] ... a plurality of different device types over a
`plurality of different communication channels,...............0068
`
`[1.3D] [an integration tier configured to manage mobile wallet
`sessions with a mobile device]...the integration tier being
`configured to receive binary and text messages from a
`MObIie MEVICES oo. cece cs eeseessneceessceveseeesensseseeseensencsueuseavenee
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`[1.4A] a notification services engine configured to interface
`with the integration tier and ..............::cscssssecsseessesersensssereenneess
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`[1.10B]...the customer communication indicating that the
`customer desires to purchase an itemat an agent terminal
`for a specified amount of funds using a specified payment
`method from a mobile wallets 0.0... ccc ce cecceeeeseseneeeeeeeessees
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`[1.11] return a secure, perishable purchase code to the customer
`overat least one of the plurality of channels connected to
`the computing SYStCM);..............ccecceeeseeeceeeseeeeeeeeeeeeeeseteeseeeeees
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`[1.12A] receive communication from the agent terminal overat
`least one of the plurality of channels connected to the
`COMPuUting SYSTEM, 2... ee eee eee eeeeeeneeteeceteeteeeeeareneeeeeaeenee
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`[1.7] a security services engine that performs subscriber
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`authentication utilizing a database-based Access Control
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`[1.12B]...the agent terminal communication indicating that the
`purchase code has been presented to an agenty...........0...006
`
`[1.8] a rules engine configured to enforce constraints on
`financial transactions performed with the mobile wallet
`application, the mobile wallet application being associated
`with a mobile wallet account; and .0...0...... ccc. cccceceeeseeeeeneeeenes
`
`[1.9] one or more computer-readable storage media having
`stored thereon computer-executable instructions which are
`executable by the one or more processors, to facilitate a
`transaction for a customer using the mobile wallet by
`causing the computing system to performat least the
`FOUOWING! «eee eee eeceeneeeee cence seeeeeeeaeesaeeeseeeaeeeseeeeeseaeeneeeenteeaeees
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`[1.10A] receive communication from the customer over one of
`the plurality of channels connected to the computing
`SYSUCIN, oo. eeceeeeceecceeeeeeeeeeceeeecesceeeeeeeseneaaeaese ee geeaeeeetensensaeeeeeesenes
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`"DEMONSTRATIVE EXHIBIT - NOT EVIDENCE"
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`[1.13] debit the mobile wallet by the specified amountof funds; ..
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`[1.14] credit an agent account by the specified amount of funds;
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`[1.15] after selecting a particular channel included in the
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`plurality of channels, send a notification communication
`from the computing system to the agent terminal using the
`particular channel, which is connected to the computing
`system, the notification communication providing a
`notification indicating confirmation of the processing of
`the transaction. ........0..e.cceccececeeececeeceeeeeeceeeeeeeceeeeeneeeeeteeeeeneeeees
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