`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________
`
`AMAZON.COM, INC.,
`Petitioner,
`v.
`DYNAPASS IP HOLDINGS LLC,
`Patent Owner.
`
`______________________________
`Case No. IPR2024-00283
`
`U.S. Patent No. 6,993,658
`
`DECLARATION OF DR. JON B. WEISSMAN IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW OF
`CLAIMS 2 AND 7 OF U.S. PATENT NO. 6,993,658
`
`
`
`Amazon.com - Ex.1002
`Weissman Declaration ISO Petition
`Amazon v. Dynapass, IPR2024-00283
`
`

`

`TABLE OF CONTENTS
`
`
`I.
`
`Page
`INTRODUCTION & QUALIFICATIONS ................................................... 1
`A.
`Engagement .......................................................................................... 1
`B. Qualifications ....................................................................................... 2
`II. MATERIALS REVIEWED ........................................................................... 5
`III. DESCRIPTION OF THE RELEVANT TIMEFRAME, THE
`RELEVANT FIELD, AND A PERSON OF ORDINARY SKILL IN
`THE ART ........................................................................................................ 6
`MY UNDERSTANDING OF CERTAIN LEGAL STANDARDS ......................... 8
`IV. SUMMARY OF MY OPINIONS ................................................................ 11
`V.
`CLAIM CONSTRUCTION ......................................................................... 13
`VI. BACKGROUND .......................................................................................... 14
`A.
`The ’658 Patent .................................................................................. 14
`B.
`Cited References ................................................................................. 18
`1.
`Veneklase (Ex.1005) ................................................................ 19
`2.
`Jonsson (Ex.1006) .................................................................... 20
`3.
`Sormunen (Ex.1007) ................................................................ 22
`4.
`Kaufman (Ex.1008) .................................................................. 23
`5.
`Kew (Ex.1009) ......................................................................... 24
`VII. MY OPINIONS AS TO VENEKLASE, JONSSON, AND
`SORMUNEN AND THE OBVIOUSNESS OF CLAIM 7 ........................... 26
`A.
`Claim 5 ............................................................................................... 27
`1.
`Claim 5[pre]— “A user authentication system
`comprising:” ............................................................................. 27
`Claim 5[a]— “a computer processor;” .................................... 28
`Claim 5[b]— “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;” ............................................................ 30
`
`Amazon.com - Ex.1002
`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`2.
`3.
`
`
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`

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`TABLE OF CONTENTS
`(continued)
`
`Page
`
`4.
`
`5.
`
`6.
`
`Claim 5[c]— “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;” ............................................................. 35
`Claim 5[d]— “a communication module configured to
`transmit the token to the personal communication device
`through the cell phone network; and” ...................................... 40
`Claim 5[e]— “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,” ................................... 42
`Claim 5[f]— “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 a secure computer network.” ....................... 46
`B. A POSITA Would Have Been Motivated to Combine
`Veneklase and Jonsson ....................................................................... 51
`Claim 6 ............................................................................................... 56
`Claim 7 ............................................................................................... 58
`A POSITA Would Have Been Motivated to Combine
`Veneklase, Jonsson, and Sormunen .................................................... 61
`VIII. MY OPINIONS AS TO CLAIM 2 IN CONSIDERATION OF
`VENEKLASE IN VIEW OF JONSSON, SORMUNEN, AND
`KAUFMAN ................................................................................................... 66
`A.
`Claim 1 ............................................................................................... 66
`
`7.
`
`C.
`D.
`E.
`
`
`
`
`
`ii
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`TABLE OF CONTENTS
`(continued)
`
`Page
`
`1[b]— “receiving a request from the user for a token via the
`personal communication device, over the second
`network;” .................................................................................. 67
`Claim 2 ............................................................................................... 69
`B.
`C. A POSITA Would Have Been Motivated to Combine
`Veneklase, Jonsson, Sormunen, and Kaufman ................................... 72
`IX. MY OPINIONS AS TO CLAIM 7 IN CONSIDERATION OF KEW
`IN VIEW OF SORMUNEN .......................................................................... 76
`A. My Opinions as to Aspects of Claim 7 that are Inherited from
`Claim 5 ............................................................................................... 76
`1.
`5[pre] ........................................................................................ 76
`2.
`5[a] ........................................................................................... 77
`3.
`5[b] ........................................................................................... 79
`4.
`5[c] ........................................................................................... 83
`5.
`5[d] ........................................................................................... 86
`6.
`5[e] ........................................................................................... 88
`7.
`5[f] ............................................................................................ 90
`Claim 6 ............................................................................................... 94
`B.
`Claim 7 ............................................................................................... 95
`C.
`D. A POSITA Would Have Been Motivated to Combine Kew and
`Sormunen ............................................................................................ 97
`X. MY OPINIONS AS TO CLAIM 2 IN CONSIDERATION OF KEW
`IN VIEW OF SORMUNEN AND KAUFMAN .......................................... 102
`A.
`Claim 1 ............................................................................................. 102
`1.
`Claim 1[b]— “receiving a request from the user for a
`token via the personal communication device, over the
`second network;”.................................................................... 103
`Claim 2 ............................................................................................. 104
`
`B.
`
`
`
`
`
`iii
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`TABLE OF CONTENTS
`(continued)
`
`Page
`
`C. A POSITA Would Have Been Motivated to Combine Kew,
`Sormunen, and Kaufman .................................................................. 107
`XI. CONCLUSION ........................................................................................... 111
`
`
`
`
`
`iv
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`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`
`
`Exhibit
`1001
`1002
`1003
`1004
`1005
`
`1006
`
`1007
`
`1008
`1009
`1010
`1011
`
`1012
`
`1013
`
`PETITIONER’S EXHIBIT LIST
`
`Description
`U.S. Patent No. 6,993,658 to Engberg et al. (the “’658 Patent”)
`Declaration of Expert Dr. Jon Weissman
`Curriculum Vitae of Expert Dr. Jon Weissman
`File History of the ’658 Patent
`European Patent Application No. 0844551 to Veneklase
`(“Veneklase”)
`PCT Patent Publication No. WO 96/00485 to Jonsson
`(“Jonsson”)
`PCT Patent Publication No. WO 97/31306 to Sormunen
`(“Sormunen”)
`U.S. Patent No. 5,491,752 to Kaufman et al. (“Kaufman”)
`PCT Patent Publication No. WO 95/19593 to Kew (“Kew”)
`Amazon.com Sotera Stipulation
`Claim Construction Order, Dynapass IP Holdings LLC v.
`JPMorgan Chase & Co., No. 2:22-cv-00212-JRG-RSP (E.D.
`Tex. Oct. 31, 2023).
`Petition for Inter Partes Review in Unified Patents, LLC v.
`Dynapass IP Holdings LLC, IPR2023-00425, Paper 1 (PTAB
`Jan. 6, 2023) (“Unified Patents IPR”)
`Unified Patents Institution Decision, IPR2023-00425, Paper 9
`(July 18, 2023)
`
`
`
`v
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`
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`I, Jon B. Weissman, hereby declare as follows:
`
`I.
`
`INTRODUCTION & QUALIFICATIONS
`A. Engagement
`I have been retained on behalf of Amazon.com, Inc. (“Amazon” or
`1.
`
`“Petitioner”) in connection with the above-captioned petition for Inter Partes
`
`Review (“IPR”) of claims 2 and 7 of U.S. Patent No. 6,993,658 (the “’658 Patent”
`
`or “Ex. 1001”). I understand the ’658 Patent is currently assigned to Dynapass IP
`
`Holdings LLC (“Patent Owner”).
`
`2.
`
`Petitioner has asked me to offer opinions regarding the ’658 Patent,
`
`including whether claims 2 and 7 (which I may refer to subsequently as the
`
`“Challenged Claims”) are valid in view of certain prior art. This declaration sets
`
`forth the opinions I have reached to date regarding these matters.
`
`3.
`
`I am being compensated by Petitioner at my standard hourly
`
`consulting rate of $700 for my time spent on this matter. My compensation is not
`
`contingent on my findings or the outcome of this proceeding. I have no financial
`
`interest in the ’658 Patent, Petitioner, Patent Owner, or the outcome of this matter.
`
`4.
`
`This declaration briefly outlines my background and qualifications,
`
`describes the technology at issue and background of the art, identifies materials I
`
`reviewed to prepare this declaration, and sets forth my understanding of the patent
`
`claims and my analysis regarding unpatentability of the Challenged claims in view
`
`
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`
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`of the prior art discussed herein. I reserve the right to supplement my opinions in
`
`the future, to clarify responses where appropriate, and to take into account new
`
`information as it becomes available to me.
`
`B. Qualifications
`
`5. My academic and professional background is in computer science,
`
`specifically in the areas of data storage, file systems, backup/restore, distributed
`
`computing, cloud computing, and developing and testing large-scale software
`
`systems. I am a leading researcher and educator in these areas. My career includes
`
`over 25 years of experience in industry and academia in building, testing, and
`
`analyzing, such software systems. As a systems researcher, I have built practical
`
`systems that have applications in a wide variety of settings across diverse types of
`
`distributed and parallel systems. A list of my prior testimony and cases in which I
`
`supported various topics, including security methods and two-factor authentication,
`
`is included in my curriculum vitae (“CV”), which is provided as Ex.1003.
`
`6.
`
`I am a Full Professor of Computer Science at the University of
`
`Minnesota. I received my B.S. in Applied Mathematics and Computer Science
`
`from Carnegie-Mellon in 1984, and my M.S. and Ph.D. in Computer Science from
`
`the University of Virginia, with my M.S. earned in 1989 and my Ph.D. in 1995.
`
`7.
`
`In addition to my professorship, I lead the University of Minnesota’s
`
`Distributed Computing Systems Group. The Distributed Computing Systems
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`Group is focused on research into distributed and mobile systems, cloud
`
`computing, and high-performance computing. The Distributed Computing
`
`Systems Group also investigates cross-cutting topics including storage,
`
`networking, operating systems/middleware, security, and applications.
`
`8.
`
`As part of my work leading the Distributed Computing Systems
`
`Group, I designed a security system for our mobile Internet of Things (“IoT”)
`
`platform.
`
`9.
`
`I have extensive experience with developing technologies and
`
`techniques to improve security in backup/restore technologies. For example, as an
`
`investigator for the University of Minnesota Center for Intelligent Storage (CRIS)
`
`for over a decade, I was involved in Massive Array of Idle Disks (MAID) for
`
`archival storage. CRIS brought together both industry and academic partners to
`
`solve emerging storage problems in file and storage systems by exploring and
`
`developing new technologies and techniques to improve the usability, scalability,
`
`security, reliability, efficiency, and performance of storage systems for several use
`
`cases including backup.
`
`10.
`
`I have published over 100 peer-reviewed technical articles, including
`
`some awarded or nominated for Best Paper at highly competitive international
`
`conferences. Many of my published papers relate to security topics, including this
`
`small sample (and many more listed on my CV):
`
`
`
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`• “SQuBA: Social Quorum Based Access Control for Open IoT
`
`Environments,” Yixuan Wang, Abhishek Chandra, Jon Weissman,
`
`IEEE Edge 2023, best student paper awardee;
`
`• “A Security-enabled Grid System for MINDS Distributed Data
`
`Mining,” Jinoh Kim, Seonho Kim, Jon B. Weissman, Journal of
`
`Grid Computing, 2014;
`
`• “Adaptive middleware supporting scalable performance for high-
`
`end network services,” Byoung-Dai Lee, Jon B. Weissman,
`
`Young-Kwang Nam, Journal of Network and Computer
`
`Applications, 2009;
`
`• “DDDAS/ITR: A Data Mining and Exploration Middleware for
`
`Grid and Distributed Computing,” Jon B. Weissman, Vipin Kumar,
`
`Varun Chandola, Eric Eilertson, Levent Ertoz, Gyorgy Simon,
`
`Seonho Kim, Jinoh Kim, Workshop on Dynamic Data Driven
`
`Application Systems – DDDAS 2007, Beijing, China, 2007;
`
`• “Reputation-Based Scheduling on Unreliable Distributed
`
`Infrastructures,” Jason Sonnek, Mukesh Nathan, Abhishek
`
`Chandra, Jon Weissman, Proceedings of the 26th International
`
`Conference on Distributed Computing Systems (ICDCS ’06),
`
`Lisboa, Portugal, July 2006;
`
`
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`• “A Quantitative Comparison of Reputation Systems in the Grid,”
`
`Jason D. Sonnek, Jon B. Weissman, 6th IEEE/ACM International
`
`Workshop on Grid Computing, 2005.
`
`11.
`
`I routinely teach classes in operating systems at both the
`
`undergraduate and graduate level in which I teach students about security methods,
`
`including two-factor authentication. A list of courses that I teach as a Professor of
`
`Computer Science is included in my CV, which is included as Exhibit 1003.
`
`12.
`
`I have also served on the boards of several flagship journals, including
`
`IEEE Transactions on Parallel and Distributed Systems and IEEE Transactions on
`
`Computers. I am the steering committee chair of the ACM International
`
`Symposium on High Performance Parallel and Distributed Systems, the flagship
`
`conference in my area. And I serve as an investigator for both the Center for
`
`Research in Intelligent Storage (sponsored by the National Science Foundation)
`
`and the Digital Technology Center.
`
`II. MATERIALS REVIEWED
`
`13. My opinions are based on a review of the materials of record in this
`
`proceeding, including the ’658 Patent and its prosecution history, and each of the
`
`documents listed in the Exhibit List above and any other materials cited herein. I
`
`understand that other third parties, including Unified Patents, have filed inter
`
`partes review petitions on certain claims of the ’658 Patent. Ex.1012 (Unified
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`
`Petition); Ex.1013 (Unified Institution Decision). I understand that the Unified
`
`IPR did not challenge claims 2 or 7, which are the claims that are challenged here.
`
`I further understand that my opinions rely on some of the same references and
`
`arguments as asserted in the Unified IPR Petition.
`
`14.
`
`In reaching my opinions, I have also relied upon my general
`
`knowledge and experience in the field and also considered the viewpoint of a
`
`person having ordinary skill in the art (“POSITA”) at the time of the filing date of
`
`the ’658 Patent, i.e., March 6, 2000. As explained below, I am very familiar with
`
`the level of skill of a POSITA regarding the relevant technology at issue as of that
`
`time.
`
`III. DESCRIPTION OF THE RELEVANT TIMEFRAME, THE
`RELEVANT FIELD, AND A PERSON OF ORDINARY SKILL IN
`THE ART
`15. All of the opinions that I provide herein are provided through the lens
`
`of a POSITA during the relevant time period. I understand that the ’658 Patent
`
`was filed on March 6, 2000. For the purposes of my analysis, and in the absence
`
`of any information to the contrary, I have used the March 6, 2000 date as the
`
`relevant priority date (which I may refer to for simplicity as the “Priority Date’) for
`
`my analysis of the prior art.
`
`16.
`
`I considered several factors to determine the skill level of a POSITA
`
`of the ’658 Patent as of the Priority Date, including the types of problems
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`encountered in the art, solutions to those problems, the pace of innovation in the
`
`field, the sophistication of the technology, and the education level of active
`
`workers in the field.
`
`17. A POSITA of the ’658 Patent would have had at least (1) an
`
`undergraduate degree in electrical and computer engineering or a closely related
`
`field; and (2) two or more years of experience in security. Additional advanced
`
`educational degrees could substitute for some years of experience, and, likewise,
`
`additional industry experience could substitute for educational degrees as well.
`
`18.
`
`In addition, a POSITA would have been familiar with the principles
`
`that the ’658 Patent admits as being part of the general knowledge of the art,
`
`including, but not limited to, (A) operating systems controlling local area networks
`
`of workstations within a business or institution typically require submitting a user
`
`ID and password combination before allowing access to a workstation; and (B)
`
`two-factor authentication processes, such as that provided by the SecurID product,
`
`distributed by RSA Security Inc., where the first factor is a user passcode/personal
`
`identification number and the second factor is a SecurID card possessed by the
`
`user. The SecurID card generates and displays unpredictable, one-time-only
`
`access codes that automatically change every 60 seconds and the user supplies the
`
`displayed code upon logging into a system. The system has a corresponding “code
`
`generator” that verifies possession of the SecurID card. Ex.1001, 1:15-53.
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`19. Unless noted otherwise, when I state that something would be known
`
`or understood by one skilled in the art, or a skilled artisan, or a POSITA, I am
`
`referring to a person with the level of education and experience that I outlined
`
`above in the time period on or before the Priority Date.
`
`MY UNDERSTANDING OF CERTAIN LEGAL STANDARDS
`In formulating my opinions, I have been instructed to apply certain
`20.
`
`legal standards. I am not a lawyer and have not been asked to offer my opinion on
`
`the law. Counsel has informed me of the applicable legal standards, as set forth in
`
`the following sections. The following sections summarize the law as I have been
`
`instructed to apply it in formulating and rendering my opinions found later in this
`
`declaration. I understand that, in an Inter Partes Review proceeding, patent claims
`
`may be deemed unpatentable if it is shown that they are obvious in view of the
`
`prior art. I understand that prior art in an Inter Partes Review is limited to patents
`
`or printed publications that qualify as prior art.
`
`21.
`
`I understand that when considering the scope of the claims of a patent
`
`that the patent claim terms should generally be given the ordinary meaning that the
`
`terms would have to a POSITA.
`
`22.
`
`I understand that the person of ordinary skill in the art is deemed to
`
`read the claim term not only in the context of the particular claim in which the term
`
`appears, but in the context of the entire patent, including the specification. I
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`further understand that the principal considerations regarding the scope and
`
`meaning of the claims are the plain language of the claim (including the
`
`surrounding claim language and context), the patent specification, and the
`
`prosecution history. I understand that while a claim is to be read in light of the
`
`specification, one must generally avoid importing limitations into the claim from
`
`the specification. I am also informed that the prosecution history can often inform
`
`the meaning of the claim by demonstrating how the inventor understood the
`
`invention and whether the inventor limited the invention in the course of
`
`prosecution, making the claim scope narrower than it would otherwise be. I
`
`applied these understandings when considering the scope and meaning of the
`
`claims of the ’658 Patent.
`
`23.
`
`I understand that a claim is unpatentable if it would have been
`
`obvious. Obviousness of a claim requires that the claim would have been obvious
`
`from the perspective of a POSITA at the time the alleged invention was made. I
`
`understand that a claim could have been obvious from a single prior art reference
`
`or from a combination of two or more prior art references.
`
`24.
`
`I understand that an obviousness analysis requires an understanding of
`
`the scope and content of the prior art, any differences between the alleged
`
`invention and the prior art, and the level of ordinary skill in evaluating the
`
`pertinent art.
`
`
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`25.
`
`I further understand that a claim would have been obvious if it unites
`
`old elements with no change to their respective functions, or merely substitutes one
`
`element for another known in the field, and that combination yields predictable
`
`results. While it may be helpful to identify a reason for this combination, I
`
`understand that there is no strict requirement of finding an express teaching,
`
`suggestion, or motivation to combine within the references. When a product is
`
`available, design incentives and other market forces can prompt variations of it,
`
`either in the same field or different one. If a POSITA can implement a predictable
`
`variation, obviousness likely bars its patentability. For the same reason, if a
`
`technique has been used to improve one device and a POSITA would recognize
`
`that it would improve similar devices in the same way, using the technique would
`
`have been obvious. I understand that a claim would have been obvious if common
`
`sense directs one to combine multiple prior art references or add missing features
`
`to reproduce the alleged invention recited in the claims.
`
`26.
`
`I understand that in considering obviousness, it is important not to
`
`determine obviousness using the benefit of hindsight derived from the descriptions
`
`found in the patent being considered.
`
`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
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`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.
`
`28.
`
`I also understand that contemporaneous and independent invention by
`
`others is a secondary consideration tending to show obviousness. I am not aware
`
`of any allegations by the named inventors of the ’658 Patent or any assignee of the
`
`’658 Patent that any secondary considerations tend to rebut the obviousness of any
`
`challenged claim of the ’658 Patent.
`
`29.
`
`I understand that Petitioner has the burden of proving unpatentability
`
`by a preponderance of evidence, which means that the claims are more likely than
`
`not unpatentable.
`
`The analysis in this declaration is in accordance with the above-stated legal
`
`principles.
`
`IV. SUMMARY OF MY OPINIONS
`
`41. Having reviewed the ’658 Patent and the prior art references in the
`
`Exhibit List above, I have formed the following opinions:
`
`
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`• The combination of Veneklase in view of Jonsson and Sormunen
`
`discloses all limitations of claim 7 and the claim is rendered
`
`obvious by the combination;
`
`• The combination of Veneklase in view of Jonsson, Sormunen, and
`
`Kaufman disclose all limitations of claim 2 and the claim is
`
`rendered obvious by the combination;
`
`• The combination of Kew in view of Sormunen discloses all
`
`limitations of claim 7 and the claim is rendered obvious by the
`
`combination; and
`
`• The combination of Kew in view of Sormunen and Kaufman
`
`discloses all limitations of claim 2 and the claim is rendered
`
`obvious by the combination.
`
`42. A table displaying the grounds of invalidity is shown below:
`
`Ground
`1
`
`2
`3
`4
`
`Prior Art
`Veneklase in view of Jonsson and
`Sormunen
`Veneklase in view of Jonsson, Sormunen,
`and Kaufman
`Kew in view of Sormunen
`Kew in view of Sormunen and Kaufman
`
`Claim
`7
`
`2
`7
`2
`
`43. The reasons for my opinions are discussed in further detail below.
`
`12
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`Amazon.com – Ex.1002
`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`V. CLAIM CONSTRUCTION
`
`43.
`
`I understand that claim construction is a matter of law and that judges
`
`construe claims terms in patents. Here, I have been advised that Magistrate Judge
`
`Payne did just that in the JPMorgan case by recently construing the following
`
`terms:
`
`Disputed Term
`“concatenating”
`“receiving a request from the user for
`a token via the personal
`communication device, over the
`second network”
`“activates access to the account in
`response to the password”
`“activating access the user account on
`the first secure computer network”
`“password”
`
`The Court’s Construction
`“joining sequentially”
`“receiving, over the second network
`via the personal communication
`device, a request from the user for a
`token”
`“activates access to the account in
`response to the creation of the
`password”
`Plain and ordinary meaning
`Plain and ordinary meaning
`
`
`Ex. 1011, 16.
`
`44.
`
`I have been advised that Judge Payne’s construction of the “activates
`
`access…” limitation was based on Patent Owner’s disclaimer in the BofA and
`
`Unified IPRs (Ex.1011, 10-13), which was found to apply only to claim 5. I
`
`understand that Judge Payne found that there was no disclaimer for the “activating
`
`access…” limitation in claim 1 and afforded that phrase its plain-and-ordinary
`
`meaning.
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`
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`13
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`Amazon.com – Ex.1002
`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`45.
`
`I have been instructed to apply Judge Payne’s constructions in my
`
`analysis and was also instructed that all other terms should be given their plain
`
`meaning, which is how I have interpreted the other terms.
`
`
`
`VI. BACKGROUND
`
`A. The ’658 Patent
`
`46. A POSITA would recognize that the ’658 Patent is directed to two-
`
`factor authentication. Two-factor authentication uses two factors (e.g., known
`
`password and randomly generated code) to verify a user’s identity when logging
`
`into a secure system. It is my understanding that the ’658 Patent acknowledges
`
`that the named inventors did not invent two-factor authentication. For example,
`
`the ’658 Patent admits “[t]he SecurID product, which is distributed by RSA
`
`Security Inc.,” already “require[ed] a two-factor authentication process” before the
`
`’658 Patent. Ex.1001, 1:44-53. For the first factor, the SecurID used “a user
`
`passcode or personal identification number.” Id. For the second factor, the
`
`SecurID used a separate handheld card to “generate[] and display[] unpredictable,
`
`one-time-only access codes that automatically change every 60 seconds.” Id. The
`
`user would then use this “one-time-only access code” from the SecurID card to log
`
`into the system. Id.
`
`47.
`
`I understand the ’658 Patent is directed to “the authentication of users
`
`of secure systems” and “a system through which user tokens required for user
`Amazon.com – Ex.1002
`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`authentication are supplied through personal communication devices such as
`
`mobile telephones and pagers.” Ex.1001, 1:7-11. Specifically, the ’658 Patent
`
`describes an authentication system in which “access to the system is based upon:
`
`nonsecret information known to the user, such as the user ID; secret information
`
`known to the user, such as the passcode; and information provided to the user
`
`through an object possessed by the user, such as the token.” Id., 2:11-15. I
`
`understand the ’658 Patent purports to replace the SecurID card by using “a
`
`personal communication device such as a mobile phone or a pager” to obtain the
`
`benefits of the SecurID product in “a device that many users already carry.” Id.,
`
`1:58-59.
`
`48. As shown in Figure 1 of the ’658 Patent, two annotated versions of
`
`which I have reproduced below, in response to a user’s token request 160, user
`
`token server 116—which is within the user authentication server—generates a
`
`token 156 (e.g., randomly generated code) and creates a new password 158 based
`
`on the user’s passcode 154 (e.g., secret password known to user) and the token
`
`156. Ex.1001, 6:59-63, 2:11-15.1 The token 156 is transmitted to the user’s
`
`personal communication device 106 so the user can use it to log in. Id., 7:31-63,
`
`
`1 Emphasis in textual quotations and annotations/coloring in figures are added
`
`throughout, unless otherwise noted.
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`
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`15
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`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`9:60-64; see Ex.1012 (Unified IPR), Paper 1 at 2-4. This is demonstrated in the
`
`top annotated image below.
`
`Ex.1001, Fig. 1
`
`
`
`
`
`
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`16
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`Weissman Decl. ISO Petition
`Amazon v. Dynapass, IPR2024-00283
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`Ex.1001, Fig. 1
`
`
`
`
`
`49. As shown in the bottom annotated figure reproduced above, after
`
`
`
`receiving the token, I understand the ’658 Patent describes that “the user 108 logs
`
`into the secure system 110 using the user ID 152 and the password 158.” Ex.1001,
`
`7:40-45. Once this information is entered into the system by the user, “the
`
`authentication server 102 preferably compares the login data to the password 158
`
`(hashed or unhashed) or the passcode 154 and token 156 (hashed or unhashed)
`
`corresponding to the user ID 152 stored in the