IPR2023-00425
`Unified Patents, LLC
`v.
`Dynapass IP Holdings LLC
`U.S. Patent 6,993,658
`
`Petitioner’s Demonstratives
`April 16, 2024
`
`Demonstrative Exhibit- Not Evidence
`
`Petitioner, Slide 1
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`Unified Patents, LLC
`v.
`Dynapass IP Holdings LLC
`U.S. Patent 6,993,658
`
`Petitioner’s Demonstratives
`April 16, 2024
`
`Demonstrative Exhibit- Not Evidence
`
`Petitioner, Slide 1
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Agenda
`
`• Introduction
`• Claim Overview
`• Level of Skill in the Art
`• Veneklase and Jonsson
`• Kew and Sormunen
`
`Demonstrative Exhibit- Not Evidence
`
`2
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Ex. 1001, FIG.1
`
`Demonstrative Exhibit- Not Evidence
`
`3
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Challenged Claims
`
`• Ground 1
`• Claim 5 would have been obvious over Veneklase (Ex. 1005)
`and Jonsson (Ex. 1006)
`• Ground 2
`• Claims 1 and 3-6 would have been obvious over Kew (Ex. 1007)
`and Sormunen (Ex. 1008)
`• PO made no separate arguments with respect to claims 3, 4, or 6.
`
`Demonstrative Exhibit- Not Evidence
`
`4
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`1. A method of authenticating a user on a first secure computer network, the user having a
`user account on said first secure computer network, the method comprising:
`[1.1] associating the user with a personal communication device possessed by the user,
`said personal communication device in communication over a second network, wherein
`said second network is a cell phone network different from the first secure computer
`network;
`[1.2] receiving a request from the user for a token via the personal communication device,
`over the second network;
`[1.3] generating a new password for said first secure computer network based at least upon
`the token and a passcode, wherein the token is not known to the user and wherein the
`passcode is known to the user;
`[1.4] setting a password associated with the user to be the new password;
`[1.5] activating access the user account on the first secure computer network;
`[1.6] transmitting the token to the personal communication device;
`[1.7] receiving the password from the user via the first secure computer network; and
`[1.8] deactivating access to the user account on the first secure computer network within a
`predetermined amount of time after said activating, such that said user account is not
`accessible through any password, via said first secure computer network.
`
`Demonstrative Exhibit- Not Evidence
`
`5
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`5. A user authentication system comprising:
`[5.1] a computer processor;
`[5.2] a user database configured to associate a user with a personal communication
`device possessed by the user, said personal communication device configured to
`communicate over a cell phone network with the user authentication system;
`[5.3] a control module executed on the computer processor configured to create a
`new password based at least upon a token and a passcode, wherein the token is not
`known to the user and wherein the passcode is known to the user, the control
`module further configured to set a password associated with the user to be the new
`password;
`[5.4] a communication module configured to transmit the token to the personal
`communication device through the cell phone network; and
`[5.5] an authentication module configured to receive the password from the user
`through a secure computer network, said secure computer network being different
`from the cell phone network, wherein the user has an account on the secure
`computer network,
`[5.6] wherein the authentication module activates access to the account in
`response to the password and deactivates the account within a predetermined
`amount of time after activating the account, such that said account is not
`accessible through any password via the secure computer network.
`
`Demonstrative Exhibit- Not Evidence
`
`6
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Claim Construction
`
`• Limitation [5.6]: “deactivates the account within a predetermined
`amount of time after activating the account”
`• Petitioner/Institution Decision-
`• does not require that the predetermined amount of time correspond
`to the entire time period between activation and deactivation of the
`account. Paper 9, 25.
`• predetermined amount of time begins at some point after
`activation. Reply, 9-10.
`• PO-
`• the claimed ‘predetermined amount of time’ is the timeframe between
`activation and deactivation of the account. Response at 36.
`
`Demonstrative Exhibit- Not Evidence
`
`7
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Claim Construction
`
`• Limitation [5.6]: “activates access to the account in response to
`the password”
`• PO: activates access to the account in response to the creation of the
`password. Response, 32.
`• Obvious under the plain meaning and PO’s construction. Petition, 41-46,
`66-70; Reply, 7-10; 16-17.
`
`Demonstrative Exhibit- Not Evidence
`
`8
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Level of Ordinary Skill in the Art
`
`Petition, p. 5
`
`Preliminary Response (Paper 8, p. 11)
`
`PO sur-reply, p.1
`
`Demonstrative Exhibit- Not Evidence
`
`9
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Ground 1 - Claim Limitations in Dispute
`
`5. A user authentication system comprising:
`[5.1] a computer processor;
`[5.2] a user database configured to associate a user with a personal communication device possessed by
`the user, said personal communication device configured to communicate over a cell phone network with
`the user authentication system;
`[5.3] a control module executed on the computer processor configured to create a new password based
`at least upon a token and a passcode, wherein the token is not known to the user and wherein the
`passcode is known to the user, the control module further configured to set a password associated with
`the user to be the new password;
`[5.4] a communication module configured to transmit the token to the personal communication device
`through the cell phone network; and
`[5.5] an authentication module configured to receive the password from the user through a secure
`computer network, said secure computer network being different from the cell phone network, wherein
`the user has an account on the secure computer network,
`[5.6] wherein the authentication module activates access to the account in response to the password and
`deactivates the account within a predetermined amount of time after activating the account, such that
`said account is not accessible through any password via the secure computer network.
`
`Demonstrative Exhibit- Not Evidence
`
`10
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.3] a control module executed on the computer processor configured to create a new password
`based at least upon a token and a passcode, wherein the token is not known to the user and
`wherein the passcode is known to the user, the control module further configured to set a password
`associated with the user to be the new password;
`• Veneklase
`• Random Code = token
`• Password = passcode
`• Jonsson
`• Challenge Code = token
`• Input security number =
`passcode
`• Response Code = New password
`
`Veneklase, Ex. 1005, 7:22-28.
`
`Petition, 25-34
`
`Demonstrative Exhibit- Not Evidence
`
`11
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Motivations to Combine
`
`• Transmit one “password” instead of two transmitted “passwords”
`• Prevent unauthorized access through SIM swapping
`• Explicit teaching, suggestion, and motivation to combine the
`algorithm of Jonsson because Veneklase also discloses the use of
`algorithms for additional security
`• Using a known technique to improve similar devices in the same
`way
`
`Petition, 31-34
`
`Demonstrative Exhibit- Not Evidence
`
`12
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`5.4- a communication module configured to transmit the token to the personal
`communication device through the cell phone network;
`
`EX1018 (corresponding to EX2005), 173.
`Demonstrative Exhibit- Not Evidence
`
`Reply, 3-5
`
`13
`
`EX1019, filed June 21, 2000.
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.5] an authentication module configured to receive the password from the user
`through a secure computer network, said secure computer network being different
`from the cell phone network,
`
`Veneklase-
`
`Jonsson
`
`Ex.1005, 7:23-24.
`
`Ex. 1006, 7:27–31.
`
`Demonstrative Exhibit- Not Evidence
`
`14
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.6] wherein the user has an account on the secure computer network, wherein the authentication
`module activates access to the account in response to the password and deactivates the account
`within a predetermined amount of time after activating the account, such that said account is not
`accessible through any password via the secure computer network
`• Petition
`• Activates Access = allow access if
`received response code matches
`expected response code. Pet. 41
`• PO’s interpretation:
`• Activates Access = activates access to
`the account in response to [the
`creation of] the password
`
`“The response code is compared to an
`expected response code, which, in
`exemplary embodiments, may be pre-stored
`or generated using the same algorithm and
`variables.” Jonsson, 10:2-5
`
`“the challenge code and the response is
`unique for each transaction.” Jonsson, 3:16-
`18
`
`Petition, 41-46; Reply, 7-10.
`
`Demonstrative Exhibit- Not Evidence
`
`15
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.6] wherein the user has an account on the secure computer network, wherein the authentication
`module activates access to the account in response to the password and deactivates the account
`within a predetermined amount of time after activating the account, such that said account is not
`accessible through any password via the secure computer network
`
`Veneklase-Jonsson
`• “predetermined ‘window’ of
`time”
`• Receive/send challenge code
`• Send response code for
`comparison to expected
`response code
`
`Demonstrative Exhibit- Not Evidence
`
`16
`
`Petition, 42-46; Reply, 7-10.
`
`Veneklase, 8:40-49
`
`Veneklase, 9:3-5.
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Ground 2 - Claim Limitations in Dispute
`
`5. A user authentication system comprising:
`[5.1] a computer processor;
`[5.2] a user database configured to associate a user with a personal communication device
`possessed by the user, said personal communication device configured to communicate over
`a cell phone network with the user authentication system;
`[5.3] a control module executed on the computer processor configured to create a new
`password based at least upon a token and a passcode, wherein the token is not known to the
`user and wherein the passcode is known to the user, the control module further configured to
`set a password associated with the user to be the new password;
`[5.4] a communication module configured to transmit the token to the personal
`communication device through the cell phone network; and
`[5.5] an authentication module configured to receive the password from the user through a
`secure computer network, said secure computer network being different from the cell phone
`network, wherein the user has an account on the secure computer network,
`[5.6] wherein the authentication module activates access to the account in response to the
`password and deactivates the account within a predetermined amount of time after activating
`the account, such that said account is not accessible through any password via the secure
`computer network.
`
`Demonstrative Exhibit- Not Evidence
`
`17
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Ground 2 - Claim Limitations in Dispute
`
`1. A method of authenticating a user on a first secure computer network, the user having a user
`account on said first secure computer network, the method comprising:
`[1.1] associating the user with a personal communication device possessed by the user, said
`personal communication device in communication over a second network, wherein said
`second network is a cell phone network different from the first secure computer network;
`[1.2] receiving a request from the user for a token via the personal communication device,
`over the second network;
`[1.3] generating a new password for said first secure computer network based at least upon the
`token and a passcode, wherein the token is not known to the user and wherein the passcode is
`known to the user;
`[1.4] setting a password associated with the user to be the new password;
`[1.5] activating access the user account on the first secure computer network;
`[1.6] transmitting the token to the personal communication device;
`[1.7] receiving the password from the user via the first secure computer network; and
`[1.8] deactivating access to the user account on the first secure computer network within a
`predetermined amount of time after said activating, such that said user account is not
`accessible through any password, via said first secure computer network.
`
`Demonstrative Exhibit- Not Evidence
`
`18
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.3] a control module executed on the computer processor configured to create a new password
`based at least upon a token and a passcode, wherein the token is not known to the user and
`wherein the passcode is known to the user, the control module further configured to set a
`password associated with the user to be the new password;
`
`• UserID/Identity Code = passcode
`• Code A = token
`• Code B = New Password
`
`Pet. At 60-62; Ex. 1007, FIG 2
`
`Demonstrative Exhibit- Not Evidence
`
`19
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.3] a control module executed on the computer processor configured to create a new password based at least
`upon a token and a passcode, wherein the token is not known to the user and wherein the passcode is known
`to the user, the control module further configured to set a password associated with the user to be the new
`password;
`Claim 1: A method of preventing unauthorised access to a host computer system (1) by a user at a remote terminal (2)
`comprising the steps of
`accepting a user identification code [passcode] input to the terminal by the user;
`generating a random code (Code A) [token] ;
`subjecting Code A to a transformation characteristic of a transformation algorithm identified by the input user
`identification code so as to generate a transformed code (Code B) [New Password]; transmitting Code A via a
`paging system (7) , to a receiver (6) held by the user, the receiver (6) comprising transformation means adapted to
`transform the received Code A to a second transformed Code C…
`
`When the user seeks access to the host system 1 via the terminal 2 , he enters his user identification code. This code may take any suitable
`
`form, for example his actual name or preferably a more secure code such as a PIN. The security server 5 includes a database of all authorised
`
`users and their authorised receiver units 6, and identifies the corresponding identity code for the appropriate receiver unit 6. The security
`
`server 5 then generates a random code (Code A) and subjects this number to an encryption using the same one-way algorithm as is stored
`
`in the user's receiver 6 together with the corresponding identity code. In this way a transformed code (Code B) is produced. EX1006, 7:34-
`
`8:10
`
`Demonstrative Exhibit- Not Evidence
`
`20
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.6] wherein the authentication module activates access to the account in response to the
`password and deactivates the account within a predetermined amount of time after activating the
`account, such that said account is not accessible through any password via the secure computer
`network.
`• Petition
`• Activates Access = allows access to the account by the user (Code B and Code C match)
`• PO’s interpretation:
`• Activates Access = activates access to the account in response to [the creation of] the
`password
`• Kew discloses creation of Code B (new password) when sending Code A
`(token) to the receiver to be transformed to Code C, which is then compared
`to Code B to allow access to the account
`• POSITA would have understood account access to be activated under PO’s
`interpretation when Code B was created and not after code C was received for
`comparison to Code B
`
`Demonstrative Exhibit- Not Evidence
`
`21
`
`Petition, 41-46; Reply, 7-10
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[5.6] wherein the authentication module activates access to the account in response to the password
`and deactivates the account within a predetermined amount of time after activating the account,
`such that said account is not accessible through any password via the secure computer network.
`
`• Kew discloses that the security server “prompts” entry of the “transformed Code C displayed by
`the receiver unit 6.” EX1007, 9:6-7.
`• v
`
`EX1018, 427; EX1024, ¶35
`
`Petition, 48, 62, 64, 66; Reply 17-22
`
`Demonstrative Exhibit- Not Evidence
`
`22
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Time-Bound Access was well-known in the art decades before
`the earliest priority date
`
`EX1003, ¶49; EX1024, ¶32; Reply, 17
`
`Demonstrative Exhibit- Not Evidence
`
`23
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Kew’s time-bound access
`
`The receiver unit 6 therefore uses the received random
`number and the identity code stored in its own EPROM to
`produce a transformed code (Code C) via its own
`characteristic algorithm. This transformed Code C is then
`displayed to the user on a display means 9, preferably a
`liquid crystal display, for a predetermined length of time
`such as five minutes. Kew, 8:33-9:3
`
`the receiver can only be enabled for a predetermined
`period to permit it to transform the received Code A to
`the transformed Code C by input of a second user
`identification code by the user. This second code may also
`be in the form of a PIN. In this way additional security is
`provided since an unauthorised user cannot gain access to
`the system even if he has possession of the receiver and
`knows the user identification code without knowledge of the
`second identification or activation code. Kew, 3:14-23
`
`Petition, 68-71; Reply, 18-22
`
`Demonstrative Exhibit- Not Evidence
`
`24
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Kew’s time-bound access as understood by a
`POSITA
`
`1) The user enters the user ID to generate Code A, which is used with the user ID/identity code to generate
`
`Code B, which begins the lifetime of Code B for a predetermined 5 minute period.
`
`2) Code A is sent to the receiver, which begins the lifetime of Code A for a predetermined period of 5 minutes.
`
`The user is alerted to enter his second identification code, which enables Code A to be transformed to Code
`
`C and displayed.
`
`3) The user must enter Code C while it is displayed during the 5 minute period that the receiver is enabled to
`
`generate code C.
`
`Reply, 22; EX1024, ¶39.
`
`Demonstrative Exhibit- Not Evidence
`
`25
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`PO: Kew’s “security sever” (Petitioner-identified “authentication module”) has no way
`of knowing when Kew’s “receiver unit” stops displaying “Code C,” and thus has no
`way of knowing when to deactivate the account. Sur-reply at 23.
`
`• Allows Code C to be valid
`indefinitely
`• Does not prevent a user from
`simply writing down Code C and
`entering it days later to access the
`account
`• Ignores the “prompt” from the
`security server
`
`Reply, 17-21
`
`Demonstrative Exhibit- Not Evidence
`
`26
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`[1.2] receiving a request from the user for a token via the personal
`communication device, over the second network;
`
`Kew, Fig.1
`
`Jonsson, Fig. 2
`
`Petition, 74-75; Reply, 23-24
`
`Demonstrative Exhibit- Not Evidence
`
`27
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
`
`Kew’s receiver is linked to the remote terminal for the exchange of
`information
`
`the receiver unit 6 would probably, but not
`necessarily, comprise a stand-alone piece of
`equipment, in this embodiment the receiver unit 6
`is intended to be linked to the remote terminal 2
`for the passage of information therebetween
`
`Kew, 9:27-31; EX1024, ¶40; Reply, 23
`
`Demonstrative Exhibit- Not Evidence
`
`28
`
`UNIFIED PATENTS EXHIBIT 1025
`UNIFIED PATENTS, LLC v. DYNAPASS IP HOLDINGS LLC
`IPR2023-00425
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
