IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`
`CARDWARE INC.,
`Patent Owner
`
`U.S. Patent No. 11,328,286
`Issued: May 10, 2022
`
`Declaration of William C. Easttom II Ph.D., D.Sc.
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`I.
`
`1.
`
`INTRODUCTION
`
`I, William C. Easttom II Ph.D., D.Sc. (Chuck Easttom), have been retained by
`
`Cardware INC., (“Cardware”), to provide independent expert analysis and my
`
`opinion on certain issues relating to U.S. Patent 11,328,286 (hereafter
`
`referred to as the ‘286 patent). The scope of my assignment is set out below.
`
`2. My analysis of that evidence, my background, and qualifications, as well as
`
`my conclusions on this matter are provided in this declaration.
`
`II. BACKGROUND AND QUALIFICATIONS
`
`3.
`
`I have 30 years of experience in the computer science industry including
`
`extensive experience with computer programming, databases, and computer
`
`networking. That experience includes extensive programming experience
`
`including software engineering for medical software, Department of Defense
`
`software, financial software, and other applications. I have authored 41
`
`computer science books, including textbooks used at over 60 universities
`
`around the world.
`
`4.
`
`I hold a Doctor of Science degree in Cyber Security from Capitol Technology
`
`University. I also hold a Doctor of Philosophy (Ph.D.) in Technology (focused
`
`on nanotechnology) from Capitol Technology University. I also have a Doctor
`
`of Philosophy (Ph.D.) in Computer Science from the University of
`
`Portsmouth. I also hold three master’s degrees (one in Applied Computer
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`Science, one in Education, and one in Systems Engineering). I am an inventor
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`with 25 computer science patents.
`
`5.
`
`I am a Senior member and Distinguished Speaker for the Association of
`
`Computing Machinery (ACM) and a Senior Member and Distinguished
`
`Visitor of the Institute for Electrical and Electronics Engineering (IEEE). The
`
`IEEE is the world’s largest and most preeminent engineering organization.
`
`Among other activities, the IEEE creates industry standards for a wide range
`
`of engineering disciplines, including software development standards. I am
`
`also a Distinguished Visitor of the IEEE. I have been a member of the IEEE
`
`Software & Systems Engineering Standards Committee for several years. I
`
`worked on the DevOps 2675 standards group from 2017 to 2019. I am also
`
`currently the Vice Chair of the IEEE p23026 Standards Group "Systems and
`
`Software Engineering -- Engineering and Management of Websites for
`
`Systems, Software, and Services Information." Furthermore, I am the Chair
`
`of IEEE P3123 Standard for Artificial Intelligence and Machine Learning
`
`(AI/ML) Terminology and Data Formats. I am also a member of the IEEE
`
`Engineering in Medicine and Biology Standards Committee. Standard for a
`
`Unified Terminology for Brain-Computer Interfaces P2731 from 2020 to
`
`present.
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`6.
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`In addition to the summary, I have provided here, I describe my qualifications,
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`issued patents, publications, and experience as an expert witness in greater
`
`detail in my CV, attached as Exhibit A.
`
`III. MATERIALS CONSIDERED
`
`7.
`
`In forming my opinions, I have reviewed the following:
`
`a.
`
`For Case No. PGR2023-00012
`
`i. The Petition for post grant review of U.S. Patent No. 11,328,286
`
`ii. Exhibit 1001, U.S. Patent No. 11,328,286;
`
`iii. Exhibit 1003, the January 11, 2023, declaration of Dr. Shamos;
`
`iv. Exhibit 1012, U.S. Prov. Patent App. No. 61/794,891;
`
`b.
`
`For Case No. PGR2023-00013
`
`i. The Petition for post grant review of U.S. Patent No. 11,328,286
`
`ii. Exhibit 1001, U.S. Patent No. 11,328,286;
`
`iii. Exhibit 1003, the January 11, 2023, declaration of Dr. Shamos;
`
`iv. Exhibit 1012, U.S. Prov. Patent App. No. 61/794,891; and
`
`c. All references cited in this declaration.
`
`IV. LEGAL PRINCIPLES AND ASSIGMENT
`
`8.
`
`I have been asked to analyze and consider Dr. Shamos’ opinion that the
`
`provisional application to which the ’286 patent claims priority (61/794,891)
`
`does not disclose or otherwise reasonably convey to a person of ordinary skill
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`in the art (“POSITA”) that the inventor was in possession of the subject matter
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`claimed in the ’286 patent.
`
`9.
`
`For the purposes of this analysis, I considered the disclosure of the provisional
`
`itself, as well as the knowledge of a POSITA, as explained below.
`
`10.
`
`I reserve the right to consider and analyze other portions of Dr. Shamos’
`
`V.
`
`11.
`
`opinion if and when requested.
`
`PERSON OF ORDINARY SKILL IN THE ART
`
`I understand that Dr. Shamos has posited that a POSITA would be “someone
`
`with (1) a bachelor’s degree in computer science, computer engineering,
`
`electrical engineering, or a related field, and; (2) in addition, one to two years
`
`of experience working with payment processing and/or digital authentication
`
`systems, including familiarity with short-range wireless technologies such as
`
`RFID technology. Graduate education could substitute for professional
`
`experience, or significant experience in the field could substitute for
`
`education.”
`
`12. For the purposes of this declaration, I will use Dr. Shamos’ definition of a
`
`POSITA.
`
`
`
`VI.
`
`’286 PATENT CLAIM LIMITATIONS AT ISSUE
`
`A. Claim 3: “Touch Screen . . .”
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`13. Dr. Shamos asserts that there is “no support in the ’891 Provisional for the
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`recitation of claim 3 that ‘the touch-screen user interface is operable to control
`
`an access of the card device for payment transactions at an NFC Card Reader
`
`facility, and is operable to enable and disable NFC payment transactions by
`
`the card device.”
`
`14. A POSITA would recognize that the provisional application discusses touch
`
`screen user interfaces from the figure included in the provisional application,
`
`which shows a “Touch Sensor Array” and a “Display,” each connected to a
`
`“Microprocessor & Memory.” Ex. 1012, 19 (Figure).
`
`15.
`
`It is also informative to consider common uses of the terms touch sensor and
`
`
`
`touch screen:
`
`16. The Electronics Hub states that: “A touch sensor detects touch or near
`
`proximity without relying on physical contact. Touch sensors are making their
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`way into many applications like mobile phones, remote controls, control
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`panels, etc. Present day touch sensors can replace mechanical buttons and
`
`switches.”1
`
`17. TeachEngineering.Org states “Touch sensors—called tactile sensors by
`
`engineers—are part of many devices that we use every day. Tactile sensors
`
`are sensitive to touch, force or pressure, and are made using light (optical),
`
`electricity or magnetism.”2
`
`18. According to lecture notes in the Electrical Engineering Department of UC
`
`Berkley, a touch screen functions by “an arrayed sensor detects some
`
`electrical interaction’ when a ‘finger touches the touch screen.”3
`
`19. The 2007 paper “An Overview of Optical-Touch Technologies”4 describes
`
`touch screen and touch sensor being used interchangeably, specifically stating
`
`"These new LCDs
`
`integrate a light-sensing element (photodiode or
`
`phototransistor) into each LCD pixel, which allows the display to act as a
`
`
`1 https://www.electronicshub.org/touch-sensors/
`2 https://www.teachengineering.org/lessons/view/umo_sensorswork_lesson03
`3 https://inst.eecs.berkeley.edu//~ee16a/sp15/Lecture/Lecture_9.pdf
`4 Maxwell, I. (2007). An overview of optical-touch technologies. Information
`Display, 23(12), 26.
`https://walkermobile.com/December_2007_ID_Overview_of_Optical_Touch_Tech
`nologies.pdf
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`large- array photosensor; with appropriate image-analysis techniques, it can
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`act as a touch sensor or even a card scanner."
`
`20. Samsung’s own website shows how tightly coupled touch screen and touch
`
`sensor are: “If the screen is wet, the touch sensor may not work properly.
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`Even for waterproof models, some touch functions may not work if the
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`product is used in water.”5 (emphasis added)
`
`21. A POSITA would understand that when the provisional patent application
`
`discusses touch sensors, that a touch screen is a specific implementation of a
`
`touch sensor, and thus touch screens are disclosed in the provisional patent
`
`application.
`
`22. Provisional claim 4 of the provisional application further discusses that the
`
`“device may incorporate a plurality of touch sensors which may allow user
`
`input of information . . . to confirm/deny transaction information . . . or with
`
`a gesture across said sensor for the purpose of lock/unlock or control access
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`for transactions.” Ex. 1012, 16. A POSITA would understand from this
`
`discussion that the provisional application supports the limitation, “touch-
`
`screen user interface operable to control an access of the card for payment
`
`transactions.”
`
`
`5 https://www.samsung.com/us/support/troubleshooting/TSG01213974/
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`B. Claim 3: “payment transactions at a NFC Card Reader
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`Facility”
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`23. Dr. Shamos asserts that the disclosure of “near field radio frequency” in the
`
`provisional patent is not sufficient to support the near field communications
`
`(NFC) limitation of claim 3.
`
`24. A POSITA would first look at what the provisional patent application states:
`
`25.
`
`In paragraph 4, the provisional patent application states “One type of credit
`
`card in circulation employs radio frequency (‘RF’) identification where there
`
`is a near field radio frequency. These cards essentially have a low power RF
`
`antenna built into the card and when the cardholder passes the antenna in front
`
`of a reader comprising an RF field, there is enough power generated and
`
`reduced for the processor to interact wirelessly with the receiving device.”
`
`Ex. 1012, 9.
`
`26.
`
`In paragraph 17 the provisional patent application states “In this embodiment,
`
`the card could use RFID or near field technology so that it can connect to a
`
`personal computer and be used to uniquely generate a credit card number for
`
`online purchases.” Ex. 1012, 13-14.
`
`27. This alone would be enough for a POSITA to conclude that the provisional
`
`patent application does indeed disclose, and the inventor was in possession of,
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`NFC payment transactions. However, there is also much more evidence of
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`this, when considered from the perspective of a POSITA.
`
`28. The Oxford Dictionary of Electronics and Electrical Engineering devices near
`
`field communication as “Wireless technology that enables two devices to
`
`communicate when within 4 cm of each other. The devices require *loop
`
`antennae and use electromagnetic induction to connect. They operate at a
`
`frequency of 13.56 MHz and can transfer data at rates from 106k to 424k
`
`bits/second. The main applications are in contactless payments systems and
`
`access control.”6
`
`29. That is a low powered antenna using a radio signal, precisely as described in
`
`the provisional patent application.
`
`30. Stanford University describes NFC as follows: “Near Field Communication,
`
`more commonly known as NFC, is a subset of RFID that limits the range of
`
`communication to within 10 centimeters or 4 inches.”7
`
`
`6 Butterfield, Andrew; Szymanski, John. A Dictionary of Electronics and Electrical
`Engineering (Oxford Quick Reference) (Kindle Locations 22202-22205). OUP
`Oxford.
`7 https://cs.stanford.edu/people/eroberts/cs181/projects/2010-
`11/NFCChips/difference.html
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`31. Carnegie Mellon University states “NFC is an offshoot of RFID with the
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`exception that NFC is designed for use by devices within close proximity to
`
`each other.”8
`
`32. Therefore, a POSITA would understand that NFC is a type of RFID. A
`
`POSITA would then readily understand that the disclosure of “near field radio
`
`frequency” and of RFID credit card interactions with a “reader” in the
`
`provisional patent application, do indeed disclose Near Field Communications
`
`(NFC) payment transactions.
`
`33. Dr. Shamos also asserts that, notwithstanding the above disclosures, “there is
`
`no disclosure in the ’891 Provisional of using touch-screen input to control
`
`enabling or disabling of any payment transaction functionality.” I disagree.
`
`34. As noted above, the Figure in the provisional discloses a touch screen array.
`
`As described in the provisional (and above), the payment card could employ
`
`near field technology to communicate with other devices and/or a payment
`
`reader. Ex. 1012, 9 & 13-14 (paragraphs 4 and 17). The provisional further
`
`discloses that the touch screen can be used to “confirm/deny transaction
`
`information.” Ex. 1012, 16 (provisional claim 4). This conveys to a POSITA
`
`that the touch screen can be used to control a transaction, including enabling
`
`or disabling. Further, given the other disclosures about near field technology,
`
`
`8 https://www.andrew.cmu.edu/course/14-760-s20/applications/ln/14760-l19.pdf
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`a POSITA would have understood that NFC could be used as a
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`communication medium for achieving this functionality.
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`C. Claim 5
`
`35. Dr. Shamos states that there is no disclosure in the provisional for ’286 patent
`
`claim 5, reciting: “The system of claim 1, wherein the payment card device is
`
`absent a payment number information necessary for completing an online
`
`transaction, and wherein the information presented on an interface of said card
`
`device, are limited to an in-store merchant card reader facility use only.” I
`
`disagree.
`
`36.
`
`It is clear that the provisional disclosure is focused on a substitute payment
`
`card that protects against theft, including theft by onlookers who can see
`
`payment information on a traditional payment card (e.g., by a merchant). The
`
`provisional discloses a payment card that lacks
`
`traditional payment
`
`information printed on it. For example, “in one embodiment, the number on
`
`the front of the card can be a full or partial number . . . Effectively, a credit
`
`card can be created that has no fixed number and therefore cannot be stolen.
`
`Only the number generated at the instant the card is being used matters.
`
`Accordingly, unauthorized use of the card is nearly impossible because no
`
`transaction can be conducted with only the partial static part of the credit card
`
`number.”). Ex. 1012, 12-13 (paragraph 14). A POSITA would have
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`understood that in order to perform online transactions, a user would need to
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`have complete issued account information as well as potentially other issuer-
`
`provided information. Given that the payment card disclosed in the
`
`provisional does not have visible account information, there is no way for a
`
`user to simply use the information that might be presented on an interface of
`
`the card (such as a partial number) to perform an online transaction.
`
`37. Despite the lack of printed/visible payment information on the card, the
`
`provisional discloses that the card lacking payment information can still be
`
`used at an in-store merchant facility because it is capable of generating
`
`payment information at the time of the transaction. Ex. 1012, 12 (paragraph
`
`14) (“As the credit card is being read by the machine, part or all of the number
`
`may be dynamically produced at the time the card is read.”); id. at 18
`
`(Abstract) (“A system is described to allow said device to emulate behavior
`
`of a credit card when used in electronic credit card readers . . . Methods are
`
`also described . . . to generate a one-time credit card number when read by
`
`said card readers . . .”).
`
`38.
`
`I disagree with Dr. Shamos’s interpretation of paragraph 17 of the provisional,
`
`which he relies on for the proposition that the information presented on an
`
`interface of the card is suitable for both online and in-store transactions. This
`
`paragraph discusses online transactions, but it involves a personal computer.
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`It states that the card “could use RFID or near field technology so that it can
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`connect to a personal computer and be used to uniquely generate a credit
`
`card number for online purchases.” Ex. 1012, 13-14 (emphasis added).
`
`Accordingly, the information used for online transactions (via the personal
`
`computer) is unique from those used for other transactions (in-store).
`
`39. For example, paragraph 14 explains that “As the credit card is read by the
`
`machine, part or all of the number may be dynamically produced at the time
`
`the card is read.” Ex. 1012, 12-13. This may be based on “the user’s private
`
`information, the user’s bank information, the time of day or the facility that is
`
`reading the card.” Id. An online transaction cannot use “the facility that is
`
`reading the card.” Id. With this disclosure, a POSITA would understand that
`
`in certain embodiments, information presented on an interface is limited to an
`
`in-store merchant card reader facility reading the card.
`
`D. Claim 6
`
`40. Dr. Shamos states that “there is no disclosure of using ‘a transaction
`
`information, a merchant, a facility information, a sequence counter, a payment
`
`card account information, secrets, and an information limited to said card
`
`device and to said card device’ and to said computing device to generate a
`
`limited-use payment information at a card issuer authority as recited by
`
`challenged claim 6.” I do not agree.
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`41. For example, as I noted above, paragraph 14 explains that a dynamic part of a
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`number (i.e., limited-use payment information) can be based on “the facility
`
`that is reading the card.” Ex. 1012, 12. A POSITA would understand that
`
`this could be a facility involved in the transaction generally and/or a merchant
`
`conducting the transaction. Definitions of the word facility are informative in
`
`this case:
`
`42. Merriam Webster defines facility as “something (such as a hospital) that is
`
`built, installed, or established to serve a particular purpose”9
`
`43. The Oxford Learners Dictionary defines facilities as “buildings, services,
`
`equipment, etc. that are provided for a particular purpose.”10
`
`44. Certainly, a merchant’s place of business qualifies as a facility.
`
`45.
`
` Claim 5 of the provisional application further provides that “transaction
`
`identifiers” (e.g., “a merchant” or “facility information”) can be used “to
`
`generate a limited-use number.” Ex. 1012, 16. Dr. Shamos does not discuss
`
`this disclosure.
`
`46.
`
`It is also my opinion that the provisional discloses the limitation of ’286
`
`patent, claim 6: “information limited to said card device and said computing
`
`device.” For example, provisional claim 5 provides that a “counter unit”
`
`
`9 https://www.merriam-webster.com/dictionary/facility
`10 https://www.oxfordlearnersdictionaries.com/definition/english/facility
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`“generates a sequential parameter when the card is read by said credit card
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`reader” and is combined with other information to generate a limited-use
`
`credit card number. Ex. 1012, 16 (provisional claim 5). While provisional
`
`claim 5 is directed to card-present (in facility) transactions, paragraph 17 of
`
`the provisional specification provides an embodiment where the card can also
`
`communicate a limited-use number to a separate electronic device, such as a
`
`personal computer. Specifically, the “card could use RFID or near field
`
`technology so that it can connect to a personal computer and be used to
`
`uniquely generate a credit card number for online purchases.” Ex. 1012, 13-
`
`14 (paragraph 17). Accordingly, in the embodiment where the card is used in
`
`conjunction with the personal computer, the “counter unit” is “information
`
`limited to said card device and said computing device.” I note that this is true
`
`even though the system “uniquely” generates numbers for online purchases.
`
`E. Claim 12
`
`47. Dr. Shamos (again with no explanation) states that there is no support in the
`
`provisional for claim 12. I think this is wrong.
`
`48. Paragraph 16 of the ’891 provisional application describes asking a security
`
`question. Ex. 1012, 13. Claim 12 of the ’286 patent describes a security
`
`challenge. A security question is, as described in the provisional application,
`
`is used to “verify the customer’s identity.” Ex. 1012, 13 (paragraph 16).
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`Nothing in the provisional application limits the form of answering that
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`question. Entering a pin number, supplying a biometric signal, entering a
`
`pattern, are all possible methods for answering a security question.
`
`49. First, the provisional discloses “a card user personal information question.”
`
`See Ex. 1012, 12 (paragraph 13, 13 (paragraph 16).
`
`50. Second, the provisional discloses “a card issuer authority security question.”
`
`See Ex. 1012, 12 (paragraph 13, 13 (paragraph 16).
`
`51. Third, the provisional discloses “a user touch-screen entry.” Ex. 1012, 12
`
`(paragraph 13), 16, (provisional claim 4), 19 (Figure) (disclosing a touch
`
`sensor array and display coupled to a microprocessor and memory).
`
`52. Fourth, the same provisions of the provisional disclose a “user touch-screen
`
`swipe” and “a user gesture of a device” as required by claim 12. This is
`
`explicit in provisional claim 4 of the provisional. Ex. 1012, 16.
`
`53. Finally, the provisional discloses the limitations, ““a biometric sensing of a
`
`user touch”; “a biometric sensing of a recognized user proximity”; and “a
`
`biometric sensing of a recognized user.” Ex. 1012, 12 (paragraph 13) (“[T]he
`
`card can comprise additional human inputs, e.g., touch sensors which can be
`
`formed by contacts that a user can press . . . There can also be additional inputs
`
`to key in customer specific information. For example, there can be inputs to
`
`key in a password or any other kind of unique identifier”); id., 16 (provisional
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`claim 4) (“user input of information”). Claim 12 of the ’286 patent requires
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`that the computer is “operable to present at least one challenge, of a set of
`
`security challenges, comprising” the above biometric sensing limitations. In
`
`other words, the limitation is about presenting the security challenge. One of
`
`ordinary skill in the art would have understood disclosure of plurality of touch
`
`sensors, as well as the remaining disclosure in paragraph 13 and provisional
`
`claim 4, conveys these limitations.
`
`54. For example, the online article Biometric Sensor Chips Information states
`
`“Biometric sensors consist of an array of tiny electrodes and an analog-to-
`
`digital converter (ADC) that digitizes information from the sensor array.”11
`
`55. The 2001 article “Innovations in fingerprint capture devices”12 repeatedly
`
`discusses sensor arrays for biometrics.
`
`56. The book Introduction to Biometrics states “A suitable user interface
`
`incorporating the biometric sensor or reader is needed to measure or record
`
`the raw biometric data of the user. For example, an optical fingerprint sensor
`
`may be used to image the friction ridge pattern at the tip of the finger.”13 A
`
`
`
`11
`https://www.globalspec.com/learnmore/semiconductors/sensor_ic/biometric_senso
`rs
`12
`http://www.cse.msu.edu/~rossarun/BiometricsTextBook/Papers/Fingerprint/XiaFp
`CaptureDevices_PR03.pdf
`13
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`POSITA would recognize that this particular description matches what is
`
`disclosed in the provisional patent application.
`
`57. A POSITA would readily understand that touch sensor arrays are how
`
`fingerprint biometrics are accomplished14,15,16. Therefore, a POSITA would
`
`also understand that the “plurality of touch sensors” disclosed in the
`
`provisional patent application does support the limitations “a biometric
`
`sensing of a user touch,” “a biometric sensing of a recognized user proximity,”
`
`and “a biometric sensing of a recognized user” from claim 12 of the ‘286
`
`patent.
`
`58.
`
`It is unclear what else Dr. Shamos thinks is missing from the provisional to
`
`support claim 12. However, I note that Paragraph 13 of the provisional further
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`discloses that the security responses can be used to reject or accept a user
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`authorization.
`
`F.
`
`Claim 15
`
`
`Jain, Anil K.; Ross, Arun A.; Nandakumar, Karthik. Introduction to Biometrics (p.
`4). Springer US. Kindle Edition
`14 Wettels, N., Santos, V. J., Johansson, R. S., & Loeb, G. E. (2008). Biomimetic
`tactile sensor array. Advanced robotics, 22(8), 829-849.
`15 Liu, J. C., Hsiung, Y. S., & Lu, M. S. C. (2011). A CMOS micromachined
`capacitive sensor array for fingerprint detection. IEEE Sensors Journal, 12(5),
`1004-1010.
`16 Fritsche, G. O., & Miyatake, M. N. (1999, July). A simple fingerprint sensor
`based on ridge conductivity. In Proceedings of the Third International Workshop on
`Design of Mixed-Mode Integrated Circuits and Applications (Cat. No. 99EX303)
`(pp. 207-209). IEEE.
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`59. Dr. Shamos asserts that the provisional “briefly mentions that a credit card
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`processing facility can ‘authenticate’ the transaction but does not describe the
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`‘credit card processing facility’ as being a card issuing authority or as
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`performing the precise functions recited by limitations 15.11 and 15.12.” Dr.
`
`Shamos does not address this from the perspective of a POSITA. There is no
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`doubt that a POSITA would have understood that a credit card processing
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`facility includes a card issuing authority. Indeed, the provisional discusses
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`emulating a traditional credit card and using the existing payment
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`infrastructure. Ex. 1012, 8-9 (paragraphs 2, 5), 18 (Abstract).
`
`60. As one example, the 2006 paper Service Interaction through Role based
`
`Identity17, states “Lufthansa.de checks this receipt of payment with credit card
`
`authority, for example, VISA for validation.”
`
`61. As another example, the U.S. Department of Justice refers to those who issue
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`cards as “card issuing authorities.”18
`
`62. This would also be clear to a POSITA from the context of how the term credit
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`card authority is used in the provisional patent application. For example, in
`
`claim 7 “transaction information to be displayed for user, merchant, bank or
`
`
`17 Chowdhury, M. M., & Noll, J. (2006). Service interaction through role based
`identity. In Proceedings of Wireless World Research Forum Meeting (Vol. 17).
`18 https://www.justice.gov/d9/opcl/docs/pia-pivcard-hspd12.pdf
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`credit card authority.” The three parties to a transaction are the user, merchant,
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`and whomever issued the credit card.
`
`63. A POSITA would readily have understood that the provisional patent
`
`application does indeed clearly disclose this claim limitation of the ‘286
`
`patent.
`
`G. Claim 20
`
`64. Dr. Shamos asserts that the provisional application does not support the
`
`limitation of claim 20, “wherein the computing device is operable to receive,
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`store, display and transmit issuer-provided payment information, associated
`
`with, but not depicted on, the payment device.” Dr. Shamos appears to focus
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`exclusively on the “display” aspect of this limitation.
`
`65.
`
`I next note that paragraph 16 of the ’891 provisional patent application
`
`actually describes a display screen. Ex. 1012, 13. Paragraph 17 of the ’891
`
`provisional patent application describes the credit card number being
`
`displayed on an LCD screen. Id., 13-14. Provisional claim 7 of the ‘891
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`provisional patent application also discloses displaying information. Id., 16.
`
`CONCLUSIONS
`
`66. Based on the analysis presented in this declaration, it is my opinion that the
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`identified limitations of the ’286 patent discussed by Dr. Shamos are
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`supported by the provisional patent application.
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`67.
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`I hereby declare that all statements made in this Declaration of my own
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`knowledge are true, that all statements made on information and believe are
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`believed to be true, and further, that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable
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`by fine or imprisonment, or both, under 35 U.S.C. 1001.
`
`Executed on May 15, 2023.
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` ________________________
`
`William C. Easttom II Ph.D., D.Sc.
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`Exhibit A
`Exhibit A
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`Curriculum Vitae William C. Easttom II (Chuck Easttom)
`chuckeasttom@gmail.com
`
`Education
`
`University Degrees
`• B.A. Southeastern Oklahoma State University. Major Communications with
`Minors in Chemistry and Psychology. Extensive coursework in science
`(chemistry, physics, and biology) as well as specific courses in neuroscience
`(neurobiology of memory, cognitive science, etc.). Also, additional coursework in
`computer science including programming and database courses. While attending I
`was named to the National Dean’s List.
`• M.Ed. Southeastern Oklahoma State University. Coursework included technology
`related courses such as digital video editing, multimedia presentations, and
`computer graphics. A statistics course was also part of the coursework. While
`attending I was named to Who’s Who in Colleges and Universities.
`• M.B.A. Northcentral University major in Applied Computer Science. Extensive
`course work in graduate computer science including graduate courses in C++
`programming, C# programming, Computer Graphics, Web Programming,
`Network communication, Complex Database Management Systems, and Artificial
`Intelligence. Approximately 30 graduate hours of graduate computer science
`courses. Additionally, a doctoral level statistics course was included. A semester
`research project in electronic medical software was also part of the curriculum. I
`also took several research courses beyond the requirements for the degree.
`• MSSE Master of Science in Systems Engineering. University of Texas at El
`Paso. The coursework includes studies in software & system requirements;
`system integration, verification, and validation; system architecture and design;
`and systems modeling & simulation. 4.0 GPA member of Phi Kappa Phi honor
`society. Also, I am a member of the Gold Key Honor society.
`• D.Sc. Doctor of Science in Cyber Security from Capitol Technology University.
`The curriculum included a broad coverage of cybersecurity issues. My
`dissertation topic was “A Comparative Study of Lattice Based Algorithms for
`Post Quantum Computing”. 4.0 GPA.
`• Ph.D. Doctor of Philosophy in Technology from Capitol Technology University.
`The focus of this program was on nanotechnology used in bioengineering. More
`specifically my studies focused on carbon nanotubes used in bioengineering.
`Dissertation topic “The Effects of Complexity on Carbon Nanotube Failures”. 4.0
`GPA.
`• Ph.D. Doctor of Philosophy in Computer Science from University of Portsmouth
`in England. The emphasis was on computer networking and the application of
`applied mathematics. Dissertation topic “A Systematic Framework for Network
`Forensics Using Graph Theory”.
`
`Industry Certifications
`The following is a list of engineering and computer industry certifications I have earned.
`
`1
`
`
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`Engineering Certifications
`Note: some of