Exhibit 24
`
`
`
`U.S. Patent No. 5,892,906 to Wayne W. Chou et al. (“Chou”)
`
`U.S. Patent No. 5,892,906 to Wayne W. Chou et al. (“Chou”) anticipates and/or renders obvious, at least under Ancora’s apparent
`infringement theories, the claims as detailed below of U.S. Patent No. 6,411,941 (the “’941 Patent”) under at least 35 U.S.C. § 102(a)(2)
`and 103. Chou was filed on July 19, 1996, and issued on April 6, 1999, and is therefore prior art to the ’941 Patent.
`
`Nothing stated in this chart shall be treated as an admission or suggestion that Defendants agree with Ancora regarding either the scope
`of any of the asserted claims or the claim constructions advanced by Ancora in its infringement contentions, or that Defendants’ accused
`products meet any limitations of the claims.
`
`The chart below provides representative examples of where each element of each claim is found within Chou, at least under Ancora’s
`apparent construction of the claims as applied in Ancora’s infringement contentions. The cited evidence is merely illustrative, and
`Defendants reserve the right to cite alternative or additional evidence.
`
`To the extent that Ancora contends that Chou does not disclose one or more limitations of the claims, it would have been obvious to
`combine the teachings of Chou with: (1) the knowledge of one of ordinary skill in the art to show all the limitations of the claims; (2) the
`teachings of the prior art references set forth in Defendants’ other invalidity charts with respect to the one or more limitations; and/or
`(3) the teachings of any of the prior art references cited and discussed in the cover document of Defendants’ invalidity contentions, as
`cited below for the one or more limitations.
`
`Because Ancora has yet to identify any limitation of the asserted claims that it contends is not fully disclosed by Chou, either alone or
`in combination with other prior art cited by Defendants, Defendants expressly reserve the right to rebut any such contention, including
`by identifying additional obviousness combinations, if any such contention is made by Ancora.
`
`Where the chart below states that Chou “discloses” a limitation, such disclosure may be express, inherent or obvious to one of ordinary
`skill in the art based on Chou.
`
`
`
`
`
`
`
`
`
`
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 1 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`1[preamble]: A method of restricting
`software operation within a license for
`use with a computer including an
`erasable, non-volatile memory area of
`a BIOS of the computer, and a volatile
`memory area; the method comprising
`the steps of:
`
`Chou discloses and/or renders obvious this limitation. See, e.g.,
`
`“In accordance with one embodiment of the invention, when the computer is in the locked
`state, the external memory must be operatively connected to the computer each time the
`computer is booted up. If the user removes the external memory, or inadvertently forgets to
`attach it to the computer, the security function will halt complete execution of the BIOS
`routines.
`
`In another embodiment of the invention, the locked state requires the user to manually enter
`the password through the keyboard in response to a prompt during execution of the BIOS
`routine. The security function compares a unique, user defined password stored in the BIOS
`memory to the user supplied password. If the two passwords agree, the computer completes
`execution of the BIOS routine.” 2:33-47
`
`“During the execution of the normal BIOS routines within the BIOS memory 15 of FIG. 3,
`the contents of memory location 30 are checked and if the contents of memory location 30
`of the CMOS RAM 17 indicate a locked condition, the POST routine 23 will stop execution
`before the BOOT routine 22 can be executed, and enter the security routine 25. Once in the
`security 25 routine, the security routine attempts to read the contents of the security key
`ROM 19 connected to the serial port 16. If security key 19 is connected to serial port 16, the
`unique key serial number and encrypted product M are read. The security function forms a
`product of the read serial number and the computer I.D. 28 stored in BIOS EEPROM 15.
`The security function 25 decrypts the second encrypted value M read from security key 19,
`and compares it with the computed product. If a match is produced by the comparison, the
`computer goes on to execute the BOOT codes 22 and peripheral routines 21.” 4:42-58.
`
`“FIG. 5 illustrates the step-by-step process for executing the security function 25 as well as
`locking and unlocking the computer in accordance with the preferred embodiment. In step
`40 the user attaches the key containing the ROM 19 to the serial port 16 of the computer.
`The computer is rebooted in step 41 through a software reboot command.
`
`2
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 2 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`Any subsequent operation of the computer requiring the computer to be rebooted can only
`occur after the user attaches the key having ROM 19 to serial port 16 as shown in step 40
`unless the user enters the unlocked state. After completing the POST routine 42, the BIOS
`routine examines the contents of CMOS RAM 17 in step 43, and enters the security routine
`25 if the computer 10 was not previously set in the unlocked state as is determined in decision
`block 44.
`
`The computer will be in the lock state if it has not previously been specifically set in the
`unlocked state. If the external ROM 19 is not connected as determined in decision 45, a
`message is posted to the user "CONNECT KEY". The security routines are executed in step
`46, by first reading the contents of the ROM of the key 19 attached to serial port 16. The
`ROM contains two values, an unencrypted serial number unique to the key, and an encrypted
`value M which represents the product of the serial number of the key and the computer I.D.
`number. A decryption subroutine is entered in step 48, which using the public key 29 stored
`within the BIOS memory 15, decrypts the value of the product M. The security routines then
`reads, in step 49, the computer I.D. from location 28 of the BIOS memory 15. A product is
`calculated in step 50, between the read serial number from the attached key 19, and the
`computer I.D. 28 obtained from the BIOS memory 15.
`
`The two products are compared in decision block 51 and if a match occurs, then the user has
`been verified as possessing the connect key and is authorized to use the computer. The
`remaining boot code is executed in steps 53 and the peripheral routines are executed in step
`54. This represents the completion of the BIOS routine execution, permitting the user to
`operate the computer in the normal way. In the event the comparison is not obtained in
`decision block 51, the boot up process is stopped in step 52 inhibiting any further use of the
`computer.” 5:21-62.
`
`“FIG. 10 illustrates, in flow chart form, execution of the BIOS routines including the security
`function. At the user site, the user first executes a boot up command in step 101 for entering
`one or two passwords which he will use. The POST Routine is executed in step 102. As no
`passwords exists within the BIOS EEPROM memory 15(a) as determined in 103, the boot
`up process completes by executing the remaining BIOS routines in step 104. Following
`
`3
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 3 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`completion of the boot up process the user may enter a SETUP mode 105 common to
`operating system configurations. The security administration mode 106 is selected by the
`user from the SETUP mode menu, which includes several submenu items. If the setup mode
`is not selected, the boot up ends in step 106. The new PASSWORD menu item is selected
`by the user in step 107 from the administration function 106. The user may enter one or two
`passwords in step 108 and the security function routine will store the password in step 109
`in the BIOS EEPROM memory 15(a). This feature also permits new passwords to be entered
`in place of any two previously entered passwords.
`
`If a single password has been entered into the BIOS EEPROM 15A, a subsequent boot up
`and selection of the security administration mode will require use of the single password.
`An additional password may be entered into the system by the first user, from the same menu
`selection from the security administration mode.
`
`If the user wishes to lock or unlock the computer and enter the SETUP mode in step 105, he
`enters the security administration mode in step 106 again. One of the menu items provided
`in the security administration mode is a lock state 112, as well as an unlock state 113. By
`selecting the lock state 112 each subsequent boot up of the computer 10 will request a
`password verification from the user. The selection of the lock state clears the memory
`location 30(a) of the CMOS RAM 17(a). The BIOS routine will therefore encounter the
`default value in location 30(a) during each subsequent execution in step 115 and decision
`block 116 will require that the BIOS function execute the security function.
`
`Execution of the security function in step 118 will generate a prompt to enter the password
`in step 119. The user enters a password which is verified in decision block 120 by the
`security function and the boot up process completes execution in step 104.
`
`The computer 10 may be unlocked by returning to the security administration mode and
`selecting the appropriate unlock submenu item 113. Selecting the unlocked state will write
`a unlock code at location 30(a) of the CMOS RAM 17(a) in step 123. Subsequent boot up
`
`4
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 4 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`processes will check the contents of location 30(a) of CMOS RAM 17(a) in decision block
`116 and skip the security function.
`
`The embodiment provides an emergency mode such that the user can enter the
`administration mode without entering either one of the user selected passwords, if he had
`access to the digital signature supplied with the computer. The user, instead of entering a
`password, enters the encrypted signature supplied to him in step 119. The public key stored
`within the BIOS memory 15A decrypts the entered digital signature, to a value equal to the
`computer serial number. This signature is verified by the BIOS security function in decision
`block 124, by comparing it to the computer serial number stored within the BIOS EEPROM
`15A. The administration mode may then be entered in step 106 which provides for a menu
`selection of either selecting a new password. Entry and storage of the new password are
`effected as in the original password registration.
`
`If the decrypted signature and stored computer serial number do not match, execution steps
`in step 125, and a message is displayed in step 126 "INCORRECT PASSWORD".” 8:42-
`9:44.
`
`“Referring now to FIG. 1, a general organization of a personal computer 10 is shown which
`includes a security function stored as a programming routine within the BIOS EEPROM 15.
`As will be evident with respect to the description of this embodiment, the BIOS routines
`which provide for the basic input/output system cannot be completely executed unless the
`security function is successfully executed.
`
`As will be understood by those familiar with the architecture of a personal computer, a CPU
`14, a CMOS RAM 17, and the BIOS memory is supported on a mother board which permits
`upgrades to be made to the system. A serial port 16 permits the computer 10 to communicate
`with externally connected devices. A monitor 11 and keyboard 13 provide a user interface
`with the personal computer 10.
`
`In accordance with the preferred embodiment of the present invention, a memory device
`such as a detachable read only memory (ROM), 19 shown in FIG. 2 having nine pin
`
`5
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 5 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`connector 20 may be detachably connected to the serial port 16. The detachable ROM 19 of
`FIG. 2 serves as a key which contains information necessary to permit the BIOS routine
`stored within BIOS memory 15 to complete execution. The BIOS routines perform various
`functions, such as power-on self tests (POST), peripheral routines, boot codes, etc., for
`initially loading the computer operating system software from a hard disk memory, or from
`floppy disk associated with the computer 10. The key has a small form factor permitting it
`to be carried separately by the user on a key chain. Thus, if the computer 10 is stolen, the
`key is not stolen with it.
`
`FIG. 3 illustrates the organization of the BIOS memory 15 which may be a flash EEPROM
`containing the various executable BIOS routines as well as routines for implementing a
`security function. Inclusion of routines for executing a security function 25 with the BIOS
`routines is particularly useful in preventing a thief from bypassing security measures which
`might have been implemented on the hard drive, or in an application program, or which
`previously made use of the CMOS RAM 17. Unless the BIOS routine has completely
`executed, the computer operating system can never be accessed rendering the computer
`inoperative.
`
`The contents of the BIOS memory 15 are illustrated in FIG. 3, including the POST (power-
`on self test) routine 23, the boot code 22 for loading the computer operating system in RAM,
`and routine 21 for configuring peripheral devices connected to computer 10.
`
`The security routines 25 within the BIOS memory require a user to follow a specific
`procedure which identify the user as an authorized user. If the user is not verified as
`authorized, the BIOS routines will not be completely executed, rendering the computer
`inoperative.
`
`The EEPROM of FIG. 3 which serves as the BIOS memory 15 includes a first unique, one
`of a kind, computer ID 28 established by the computer manufacturers, and a public
`decryption key 29. As will be evident during the description of the installation stage, the
`security key of FIG. 2 stores a unique serial number in ROM 19 as well as an encrypted
`value of the product of the key serial number and the computer's I.D. During execution of
`
`6
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 6 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`the security function, the contents of key ROM 19 are read. The encrypted quantity is
`decrypted, and compared with a product formed from the serial number read from ROM 19
`and the stored computer I.D. 28 stored in the BIOS memory 15. If these quantities match,
`the BIOS routine continues execution.
`
`Two keys may be provided, and in the event one key is mislaid, the other key permits access
`to the administrative function which can unlock the computer permitting operation of the
`computer. The stored public key 29 is provided at the time the BIOS EEPROM is configured,
`which permit decoding of encrypted values stored within the keys. Either of these keys may
`be used to gain access to the administration function should one key be lost or unavailable.”
`3:21-4:28.
`
`This limitation also would have been obvious to a person of ordinary skill in the art based
`on (1) Chou; (2) the knowledge of a person of ordinary skill in the art; and/or (3) the
`teachings with respect to this claim element as detailed in the cover document of Defendants’
`invalidity contentions and Defendants’ other invalidity charts.
`
`1[a]: selecting a program residing in
`the volatile memory;
`
`Chou discloses and/or renders obvious this limitation. See, e.g.,
`
`“The two products are compared in decision block 51 and if a match occurs, then the user
`has been verified as possessing the connect key and is authorized to use the computer. The
`remaining boot code is executed in steps 53 and the peripheral routines are executed in step
`54. This represents the completion of the BIOS routine execution, permitting the user to
`operate the computer in the normal way. In the event the comparison is not obtained in
`decision block 51, the boot up process is stopped in step 52 inhibiting any further use of the
`computer.” 5:52-62.
`
`“If the user wishes to lock or unlock the computer and enter the SETUP mode in step 105,
`he enters the security administration mode in step 106 again. One of the menu items provided
`in the security administration mode is a lock state 112, as well as an unlock state 113. By
`selecting the lock state 112 each subsequent boot up of the computer 10 will request a
`password verification from the user. The selection of the lock state clears the memory
`
`7
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 7 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`location 30(a) of the CMOS RAM 17(a). The BIOS routine will therefore encounter the
`default value in location 30(a) during each subsequent execution in step 115 and decision
`block 116 will require that the BIOS function execute the security function.
`
`Execution of the security function in step 118 will generate a prompt to enter the password
`in step 119. The user enters a password which is verified in decision block 120 by the
`security function and the boot up process completes execution in step 104.
`
`The computer 10 may be unlocked by returning to the security administration mode and
`selecting the appropriate unlock submenu item 113. Selecting the unlocked state will write
`a unlock code at location 30(a) of the CMOS RAM 17(a) in step 123. Subsequent boot up
`processes will check the contents of location 30(a) of CMOS RAM 17(a) in decision block
`116 and skip the security function.
`
`The embodiment provides an emergency mode such that the user can enter the
`administration mode without entering either one of the user selected passwords, if he had
`access to the digital signature supplied with the computer. The user, instead of entering a
`password, enters the encrypted signature supplied to him in step 119. The public key stored
`within the BIOS memory 15A decrypts the entered digital signature, to a value equal to the
`computer serial number. This signature is verified by the BIOS security function in decision
`block 124, by comparing it to the computer serial number stored within the BIOS EEPROM
`15A. The administration mode may then be entered in step 106 which provides for a menu
`selection of either selecting a new password. Entry and storage of the new password are
`effected as in the original password registration.” 9:1-40.
`
`This limitation also would have been obvious to a person of ordinary skill in the art based
`on (1) Chou; (2) the knowledge of a person of ordinary skill in the art; and/or (3) the
`teachings with respect to this claim element as detailed in the cover document of Defendants’
`invalidity contentions and Defendants’ other invalidity charts.
`
`1[b]: using an agent to set up a
`verification structure in the erasable,
`
`Chou discloses and/or renders obvious this limitation. See, e.g.,
`
`8
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 8 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`non-volatile memory of the BIOS, the
`verification structure accommodating
`data that includes at least one license
`record;
`
`
`
`“The process of creating the security function as part of the contents of the BIOS memory is
`illustrated in FIG. 6. The process begins with a selection of a private/public key combination
`in step 65. The private/public keys will be used to encrypt a quantity which represents the
`product of a serial number for the key as well as the computer I.D. for the particular computer
`for which the key operates. The BIOS memory is prepared by storing within it, the routines
`illustrated in FIG. 3 including the POST Routine, security function routines, boot codes, and
`the peripheral routines. Further, the BIOS memory is loaded with the computer I.D. number
`for which it is to be installed, as well as the public key derived in step 65.
`
`Once the routines are loaded for effecting the functions of FIG. 4, the BIOS memory is
`installed in the mother board of the computer 10 in step 67.
`
`A key is selected in step 68 for programming with the information which is related
`specifically to the computer 10. The key includes the ROM 19 which is written in step 69
`with a serial number unique to that key, if the serial number was not included at the time of
`the ROM manufacture, as well as an encrypted value M which is equal to the product of the
`computer's I.D. and the serial number assigned to the key.
`
`A central log is maintained in step 70 of each key serial number and the respective computer
`I.D. which has been part of the encrypted value stored within the key.
`
`In this way, in the event the user looses his key, he can obtain another one from the
`manufacturer by reporting his computer I.D. to the manufacturer. The manufacturer using
`the master list can identify the serial number of the key and create, using the private key, a
`new key for shipment to the user.” 6:20-53.
`
`“FIG. 9 illustrates the process for storing a password as well as exercising the locking option
`for locking or unlocking the computer. The computer in the locked state requires the user to
`enter his password each time a boot up sequence is started. The security function is
`implemented in the BIOS routines, such that if a password has been previously entered in
`
`9
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 9 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`memory, and the user has placed the computer in the locked state, a prompt will come up
`during the execution of the BIOS routines requesting the user to enter his password. If the
`password is correctly entered, and the BIOS security function verifies that the entered
`password is equal to the stored password, execution of the BIOS routines continues and the
`computer is rendered in an operative condition.
`
`A security administration mode associated with the security function permits the user to
`register two valid passwords, and then to place the computer in either a locked state or
`unlocked state. In placing the computer in the unlocked state, the user must return to the
`security administration mode and select either the locked or unlocked state. Once one
`password has been registered and stored within the BIOS EEPROM 15(a), the user cannot
`return to the security administration mode unless he enters the appropriate password . The
`computer therefore cannot be unlocked without entering the password.
`
`Along with the first and second user entered passwords stored in the BIOS EEPROM 15A,
`an encrypted computer serial number is provided by the manufacturer of the computer. The
`computer serial number will act as an emergency password, which in the event of the lost of
`the first and second passwords, permits the user to enter the administrative function. The
`actual computer serial number is not disclosed to the user, instead a public key encrypted
`value of the computer serial number is supplied to the user. The public key with the BIOS
`EEPROM 15(a) decrypts the encrypted value provided to the user, permitting its comparison
`with the actual serial number stored in a memory location of the BIOS EEPROM 15(a).
`
`FIG. 9 illustrates the process for preparing the security function for storage in the BIOS
`EEPROM 15(a). A secure encryption system such as PKCS or DSS is selected in step 91
`from which a private and public key pair is created in step 92. The BIOS routine is compiled
`in step 93, with the security function. The BIOS routines are configured to operate, and
`invoke the security function if the CMOS RAM 17(a) stores in location 30(a) a locked state
`code. Additionally, an administration function which will be evident from the succeeding
`figures is incorporated within the BIOS EEPROM for permitting password registration
`and/or changes, as well as selecting a locked or unlocked mode of operation. The computer
`serial number is stored within the BIOS EEPROM memory 15A in its unencrypted state.
`
`10
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 10 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`The BIOS code and public key is loaded in the BIOS EEPROM in step 94. The BIOS
`EEPROM 15(a) is then installed in the computer 10 mother board.
`
`The computer serial number is also read from the computer, and a digital signature of the
`serial number is created in step 97. The digital signature is printed and sent along to the user
`permitting in the case of the loss of either password, entry to the administrative mode in lieu
`of use of the password.” 7:48-8:41.
`
`This limitation also would have been obvious to a person of ordinary skill in the art based
`on (1) Chou; (2) the knowledge of a person of ordinary skill in the art; and/or (3) the
`teachings with respect to this claim element as detailed in the cover document of Defendants’
`invalidity contentions and Defendants’ other invalidity charts.
`
`
`
`1[c]: verifying the program using at
`least the verification structure from the
`
`Chou discloses and/or renders obvious this limitation. See, e.g.,
`
`11
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 11 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`erasable non-volatile memory of the
`BIOS; and
`
`“The EEPROM of FIG. 3 which serves as the BIOS memory 15 includes a first unique, one
`of a kind, computer ID 28 established by the computer manufacturers, and a public
`decryption key 29. As will be evident during the description of the installation stage, the
`security key of FIG. 2 stores a unique serial number in ROM 19 as well as an encrypted
`value of the product of the key serial number and the computer's I.D. During execution of
`the security function, the contents of key ROM 19 are read. The encrypted quantity is
`decrypted, and compared with a product formed from the serial number read from ROM 19
`and the stored computer I.D. 28 stored in the BIOS memory 15. If these quantities match,
`the BIOS routine continues execution.” 4:6-19.
`
`“During the execution of the normal BIOS routines within the BIOS memory 15 of FIG. 3,
`the contents of memory location 30 are checked and if the contents of memory location 30
`of the CMOS RAM 17 indicate a locked condition, the POST routine 23 will stop execution
`before the BOOT routine 22 can be executed, and enter the security routine 25. Once in the
`security 25 routine, the security routine attempts to read the contents of the security key
`ROM 19 connected to the serial port 16. If security key 19 is connected to serial port 16, the
`unique key serial number and encrypted product M are read. The security function forms a
`product of the read serial number and the computer I.D. 28 stored in BIOS EEPROM 15.
`The security function 25 decrypts the second encrypted value M read from security key 19,
`and compares it with the computed product. If a match is produced by the comparison, the
`computer goes on to execute the BOOT codes 22 and peripheral routines 21.” 4:42-58.
`
`“FIG. 5 illustrates the step-by-step process for executing the security function 25 as well as
`locking and unlocking the computer in accordance with the preferred embodiment. In step
`40 the user attaches the key containing the ROM 19 to the serial port 16 of the computer.
`The computer is rebooted in step 41 through a software reboot command.
`
`Any subsequent operation of the computer requiring the computer to be rebooted can only
`occur after the user attaches the key having ROM 19 to serial port 16 as shown in step 40
`unless the user enters the unlocked state. After completing the POST routine 42, the BIOS
`routine examines the contents of CMOS RAM 17 in step 43, and enters the security routine
`
`12
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 12 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`25 if the computer 10 was not previously set in the unlocked state as is determined in decision
`block 44.
`
`The computer will be in the lock state if it has not previously been specifically set in the
`unlocked state. If the external ROM 19 is not connected as determined in decision 45, a
`message is posted to the user "CONNECT KEY". The security routines are executed in step
`46, by first reading the contents of the ROM of the key 19 attached to serial port 16. The
`ROM contains two values, an unencrypted serial number unique to the key, and an encrypted
`value M which represents the product of the serial number of the key and the computer I.D.
`number. A decryption subroutine is entered in step 48, which using the public key 29 stored
`within the BIOS memory 15, decrypts the value of the product M. The security routines then
`reads, in step 49, the computer I.D. from location 28 of the BIOS memory 15. A product is
`calculated in step 50, between the read serial number from the attached key 19, and the
`computer I.D. 28 obtained from the BIOS memory 15.
`
`The two products are compared in decision block 51 and if a match occurs, then the user has
`been verified as possessing the connect key and is authorized to use the computer. The
`remaining boot code is executed in steps 53 and the peripheral routines are executed in step
`54. This represents the completion of the BIOS routine execution, permitting the user to
`operate the computer in the normal way. In the event the comparison is not obtained in
`decision block 51, the boot up process is stopped in step 52 inhibiting any further use of the
`computer.” 5:21-62.
`
`“FIG. 10 illustrates, in flow chart form, execution of the BIOS routines including the security
`function. At the user site, the user first executes a boot up command in step 101 for entering
`one or two passwords which he will use. The POST Routine is executed in step 102. As no
`passwords exists within the BIOS EEPROM memory 15(a) as determined in 103, the boot
`up process completes by executing the remaining BIOS routines in step 104. Following
`completion of the boot up process the user may enter a SETUP mode 105 common to
`operating system configurations. The security administration mode 106 is selected by the
`user from the SETUP mode menu, which includes several submenu items. If the setup mode
`is not selected, the boot up ends in step 106. The new PASSWORD menu item is selected
`
`13
`
`Ancora's Exhibit 2011
`Samsung v. Ancora IPR2021-00583
`Page 13 of 140
`
`

`

`
`
`’941 Patent Claim Limitation
`
`U.S. Patent No. 5,892,906 to Paul C. Chou et al. (“Chou”)
`
`Exhibit 24
`
`by the user in step 107 from the administration function 106. The user may enter one or two
`passwords in step 108 and the security function routine will store the password in step 109
`in the BIOS EEPROM memory 15(a). This feature also permits new passwords to be entered
`in place of any two previously entered passwords.
`
`If a single password has been entered into the BIOS EEPROM 15A, a subsequent boot up
`and selection of the security administration mode will require use of the single password.
`An additional password may be entered into the system by the first user, from the same menu
`selection from the security administration mode.
`
`If the user wishes to lock or unlock the computer and enter the SETUP mode in step 105, he
`enters the security administration mode in step 106 again. One of the menu items provided
`in the security administration mode is a lock state 112, as well as an unlock state 113. By
`selecting the lock state 112 each subsequent boot up of the computer 10 will request a
`password verification from the user. The selection of the lock state clears the memory
`location 30(a) of the CMOS RAM 17(a). The BIOS routine will therefore encounter the
`default value in location 30(a)