Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 1 of 19
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`Exhibit 1
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`Exhibit 1
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 2 of 19
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`U.S. Patent No. 8,205,249 (“’249 Patent”)
`
`Accused Products
`Apple products, including without limitation the Apple iPhone XS, XS Max, 11, 11 Pro, 11 Pro Max, 12, 12 mini, 12 Pro, 12
`Pro Max, 13, 13 mini, 13 Pro, and 13 Pro Max (“Accused Products”), infringe at least Claim 13 of the ’249 Patent.
`
`
`Claim 13
`
`Claim 13
`[13pre] A terminal for use in
`connection with a portable
`data carrier, said terminal
`including
`
`Exemplary Evidence of Infringement
`To the extent the preamble is limiting, each Accused Product includes a terminal for use in
`connection with a portable data carrier.
`For example, the exemplary Apple iPhone 13 supports Tap to Pay. When utilizing Tap to Pay, the
`exemplary Apple iPhone 13 operates as a terminal for use in connection with a portable data carrier
`(e.g., another iPhone).
`See, e.g.:
`
`
`
`1
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 3 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://developer.apple.com/tap-to-pay/.
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`2
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 4 of 19
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`Claim 13
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`Exemplary Evidence of Infringement
`
`See https://developer.apple.com/tap-to-pay/.
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`3
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 5 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
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`[13a] a device arranged to
`cause a user to select one of at
`least two possible different
`quality authentication
`methods, wherein the portable
`data carrier is arranged to
`perform a user authentication
`using one of the at least two
`possible different quality
`authentication methods and
`
`
`
`https://developer.apple.com/design/human-interface-guidelines/technologies/tap-to-pay-on-
`See
`iphone.
`
`
`In each Accused Product, the terminal includes a device arranged to cause a user to select one of at
`least two possible different quality authentication methods, wherein the portable data carrier is
`arranged to perform a user authentication using one of the at least two possible different quality
`authentication methods.
`For example, the exemplary Apple iPhone 13 supports Tap to Pay, which is arranged to cause a user
`to select one of at least two different authentication methods that vary in quality from a security
`perspective. The exemplary iPhone 13 also supports payment applications, such as Apple Pay,
`which utilize different authentication methods that vary in quality from a security perspective. For
`example, authentication using Face ID or Touch ID provides an inherently relatively higher quality
`from a security perspective. In contrast, a passcode provides an inherently relatively lower quality
`from a security perspective.
`See, e.g.:
`
`
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`4
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 6 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://developer.apple.com/tap-to-pay/.
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`5
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 7 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://developer.apple.com/tap-to-pay/.
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`6
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 8 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`https://developer.apple.com/design/human-interface-guidelines/technologies/tap-to-pay-on-
`See
`iphone.
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`7
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 9 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`[13b] to confirm the
`authentication to the terminal,
`and
`
`
`
`See https://support.apple.com/en-us/HT203027.
`
`
`In each Accused Product, the portable data carrier is arranged to confirm the authentication to the
`terminal.
`For example, the exemplary Apple iPhone 13 (portable data carrier) supports mobile payment
`applications, such as Apple Pay, which confirm the authentication to a terminal (the Accused
`Product).
`See, e.g.:
`
`
`
`8
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`
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 10 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://support.apple.com/guide/security/secure-element-and-nfc-controller-
`seccb53a35f0/web.
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`
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`9
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 11 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://support.apple.com/en-us/HT201239.
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`10
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 12 of 19
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`Claim 13
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`Exemplary Evidence of Infringement
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`
`
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`See https://support.apple.com/guide/security/paying-with-cards-using-apple-pay-
`secfbd5c0e54/1/web/1.
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`In each Accused Product, the data carrier is arranged to create quality information about the
`authentication method used and to attach such quality information to the result of a security
`establishing operation, the difference in quality of said authentication methods varies between an
`inherently relatively lower quality and an inherently relatively higher quality from a security
`perspective.
`
`11
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`[13c] the data carrier is
`arranged to create quality
`information about the
`authentication method used
`and to attach such quality
`information to the result of a
`security establishing operation,
`
`
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`
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 13 of 19
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`Claim 13
`the difference in quality of said
`authentication methods varies
`between an inherently
`relatively lower quality and an
`inherently relatively higher
`quality from a security
`perspective.
`
`Exemplary Evidence of Infringement
`For example, the exemplary Apple iPhone 13 (portable data carrier) supports mobile payment
`applications, such as Apple Pay, which create quality information about the authentication method
`used and attach that information to the result of a security establishing operation.
`See, e.g.:
`
`
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`
`
`12
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 14 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`See https://support.apple.com/guide/security/payment-authorization-with-apple-pay-
`secc1f57e189/1/web/1.
`
`
`See https://support.apple.com/guide/security/paying-with-cards-using-apple-pay-
`secfbd5c0e54/1/web/1.
`
`
`For example, the exemplary Apple iPhone 13 (portable data carrier) supports mobile payment
`applications, such as Apple Pay, which support CDCVM and attach CDCVM information to the
`result of the security establishing operation.
`See, e.g.:
`
`
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`13
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 15 of 19
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`Claim 13
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`Exemplary Evidence of Infringement
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`See https://web.archive.org/web/20201108133245/https:/support.apple.com/en-us/HT202527.
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`14
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 16 of 19
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`Claim 13
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`Exemplary Evidence of Infringement
`
`See https://practical_emv.gitlab.io/assets/practical_emv_rp.pdf.
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`15
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 17 of 19
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`Claim 13
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`
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`Exemplary Evidence of Infringement
`
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`
`
`See https://practical_emv.gitlab.io/assets/practical_emv_rp.pdf.
`For example, the exemplary Apple iPhone 13 (portable data carrier) supports mobile payment
`applications, such as Apple Pay, which utilize different authentication methods that vary in quality
`from a security perspective. For example, authentication using Face ID or Touch ID provides an
`inherently relatively higher quality from a security perspective. In contrast, a passcode provides an
`inherently relatively lower quality from a security perspective.
`See, e.g.:
`
`
`
`16
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`
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 18 of 19
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`Claim 13
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`Exemplary Evidence of Infringement
`
`See https://support.apple.com/en-us/HT203027.
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`17
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`Case 6:21-cv-01101-ADA Document 63-2 Filed 09/30/22 Page 19 of 19
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`Claim 13
`
`Exemplary Evidence of Infringement
`
`See https://technologypartner.visa.com/Download.aspx?id=573.
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`18
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