Filed on behalf of Dr. Lakshmi Arunachalam
`By: Dr. Lakshmi Arunachalam, Pro Se
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`222 Stanford Avenue
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`Menlo Park, CA 94025
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`Tel: (650) 690-0995
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`Fax: (650) 854-3393
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
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`PATENT OWNER’S REQUEST FOR RE-HEARING
`
`In
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`Covered Business Method Review of U.S. Patent No. 8,037,158
`_____________________
`SAP America, Inc.
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`Petitioner
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`v.
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`Dr. Lakshmi Arunachalam
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`Patent Owner
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`__________________
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`CASE CBM2013-00013
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`Patent 8,037,158
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`_____________________
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`1
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`Patent Owner (“PO”) and inventor, Dr. Arunachalam files this Request for Re-
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`Hearing in a timely manner from PTAB’s Final Written Decision (“FWD”). PTAB
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`overlooked many key points in its incorrect arguments against: the ‘158 as a
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`technological invention in its Institution Decision (“ID”) pp. 18-19 and FWD pp.
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`13-15; Lawlor, ComputerWorld, SFCU, Electronic Banking in ID pp. 24-32 and
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`FWD pp. 20-27; 101, 112 2nd paragraph issues in FWD pp. 15-20; its incorrect
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`claim constructions in FWD pp. 9-13. PO incorporates by reference all papers
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`submitted in this case previously, the file history and the record. PTAB was
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`fraudulently misled by SAP’s counsel and their expert witness’s false statements
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`on basic technical issues. Neither Lawlor nor Computerworld, not SFCU nor
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`Electronic Banking by Lipis disclose nor teach any of the claim elements of the
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`challenged claims in the subject patent. PTAB overlooked key disclosures in the
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`patent specification in its severely flawed claim construction not including what
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`the specification has disclosed. For example, (1) In its Institution Decision (“ID”)
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`and FWD pp.10-11, PTAB misapprehended the enormity of the problem that the
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`invention solved: applications were local to the back office and did not exist at the
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`front-end on a Web page or Web browser in 1995 prior to PO’s invention. Web
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`browsing/hyperlinking/Web forms were the norm of the day (‘158: Cols 1, 2, 5).
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`“If user 100 is a Web user, however, there is no current mechanism for performing
`a robust, real-time transaction with the bank, as illustrated in FIG. 4A. CGI scripts
`provide only limited two-way capabilities, as described above. Thus, due to this
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`2
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`lack of a robust mechanism by which real-time Web transactions can be
`performed, the bank is unable to be a true "Web merchant," namely a merchant
`capable of providing complete transactional services on the Web.” (‘158: Col 5)
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`There were no POSvc applications displayed on a Web page or Web browser.
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` “Each Web merchant may choose the types of services that it would like to offer
`its clients. In this example, if Bank decided to include in their POSvc application
`access to checking and savings accounts, user 100 will be able to perform real-time
`transactions against his checking and savings accounts. Thus, if user 100 moves
`$500 from his checking account into his savings account, the transaction will be
`performed in real-time, in the same manner the transaction would have been
`performed by a live teller at the bank or an ATM machine. Therefore, unlike his
`prior access to his account, user 100 now has the capability to do more than browse
`his bank account. The ability to perform these types of robust, real-time
`transactions from a Web client is a significant aspect of the present invention.”
`(‘158: Col 7)
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`The POSvc application displayed on a Web page or Web browser, also called a
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`VAN service or value-added network service or VAN service 704.
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`(2) In ID pp.13-14, FWD p. 9, PTAB missed the disclosure in ‘158:Col 6 that a
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`POSvc application is a transactional application, from which a Web user 100
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`transacts and that this POSvc application is a transactional application that must be
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`displayed on a Web page or Web browser.
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`“POSvc applications 510 are transactional applications, namely applications that
`are designed to incorporate and take advantage of the capabilities provided by the
`present invention…A POSvc application is an application that can execute the type
`of transaction that the user may be interested in performing. The POSvc list is
`displayed via the graphical user interface component.” (‘158: Col 6)
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`3
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`PTAB construed POSvc application in FWD p. 9 as “a software program that
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`facilitates execution of transactions requested by a user.” While ‘158: Col. 6
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`describes the term “POSvc application” as “an application that can execute the
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`type of transaction that the user may be interested in performing,” PTAB’s
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`construction fails to reflect even this aspect of the Patent. For example, there is no
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`discussion of ‘facilitation.’ PTAB also fails to give credence to the very next
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`sentence in the Patent, which characterizes the application as “displayed via the
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`graphical user interface component.” Nor does PTAB address the fact that such an
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`application is a “transactional application[] . . . designed to incorporate and take
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`advantage of the capabilities provided by the present invention,” including
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`“switching, object routing, application and service management functions.” (‘158:
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`Col 6). PTAB’s construction also disregards the fact that the ability of a POSvc
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`application to “perform . . . robust, real-time transactions from a Web client is a
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`significant aspect of the present invention. (‘158: Col 7). Such functionality is
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`better captured in the PO’s proposed construction. PTAB does not offer the
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`broadest reasonable construction in light of the specification as would be read by a
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`person of ordinary skill in the relevant art. Figs 4B, 5B, 5C, 5D, and 6A all
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`illustrate a POSvc application being displayed on a Web page. Col. 9 of the
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`specification, too, clearly states that “[a]pplication service 704 includes POSvc
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`applications such as Bank POSvc described above, and illustrated in Fig. 6A,”
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`4
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`which corresponds to VAN service 704. Fig.5D shows the POSvc application
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`displayed on a Web page including the object identity with information entries and
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`attributes (“NAME,” “PASSWORD”) displayed on the Web page. ‘158: Col 7 also
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`details information entries as user 100, checking account #, savings account #,
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`$500 for attributes, name of user, checking and savings accounts, amount
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`transferred, in checking account object identity, which is an individual networked
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`object that uniquely identifies a specific instantiation of the object. (‘158: Col 8)
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`(3) In FWD p.9, PTAB construed “Web application” as “a computer program to
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`perform a certain type of work using the Web,” not in accord with any intrinsic or
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`extrinsic record. Illustrative are these excerpts from the ‘158: Col 7:
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`“Thus, unlike his prior access to his account, user 100 now has the capability to do
`more than browse his bank account. The ability to perform these types of robust,
`real-time transactions from a Web client is a significant aspect of the present
`invention… the transactions are not merely two-way, between the user and Bank,
`but three-way, amongst the consumer, Bank and Car dealership. According to one
`aspect of the present invention, this three-way transaction can be expanded to n-
`way transactions, where n represents a predetermined number of merchants or
`other service providers who have agreed to cooperate to provide services to users.
`(‘158:Col 7)
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`“The present invention is independent of the Web browser being utilized and the
`user can use any Web browser, without modifications to the Web
`browser.”(‘158:Col 3)
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`“Web browsers are software interfaces that run on Web clients to allow access to
`Web servers via a simple user interface. A Web user's capabilities today from a
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`5
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`Web browser are, however, extremely limited. The user can perform one-way,
`browse-only interactions.” (‘158: Col 1)
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`PO construes Web application as “a transactional Web client application displayed
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`on a Web page or Web browser from which a user transacts and that displays an
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`object identity with information entries and attributes on the Web page and with
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`which the user interacts to transact” (‘158:Fig. 5D; see discussion on POSvc
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`application in 2 above for support for including the object identity with
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`information entries and attributes displayed in the application on a Web page or
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`Web browser; ‘158: Col 7, 8, 9 and Figs.5C, 5D) and the claim language requires
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`the method of performing a real time Web transaction from a Web application to
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`comprise providing a POSvc application as a selection in a Web page. PO’s
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`construction that a Web application is the same as a POSvc application displayed
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`on a Web page or Web browser is in accord with the specification and the claim
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`language. In order for the POSvc application or Web application to be displayed
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`on a Web page or Web browser, a Web server is involved. A Web application is a
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`client-server application, just as a Web browser-Web server combo is a client-
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`server application (where the Web browser is a Web client and the Web server is
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`the server) and a database application is a client-server application. The Web client
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`application displayed on a Web browser is distinct from the Web browser, even
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`though the Web browser is itself a Web client. The invention in this patent
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`6
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`involves n-dimensional client- server client-server applications. (‘158: Col 7).
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`Claim 1 recites that the POSvc application is displayed on a Web page, and so does
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`the specification at Col 6. Cols 1, 5, 7 clearly distinguish the present invention
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`from hyperlinking.
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`“POSvc applications 510 are transactional applications … displayed via the
`graphical user interface component. One embodiment of the present invention
`supports HyperText Markup Language as the graphical user interface component.
`(‘158: Col 6)
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`(4) PO’s construction of “service network” is an “OSI application layer network
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`that delivers VAN services 704 or provides POSvc application on a Web page or
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`Web browser.” PTAB states at ID p. 21 in IPR2013-00194 : “the numerous uses
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`of “services” in the ´492 Patent refer to services provided by banks, merchants, and
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`other service providers, … do not provide underlying network connectivity or
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`communications. The ´492 Patent describes merchants providing services via the
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`Web through a service network running on top of a facilities network, namely the
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`Internet or E-mail.” In ID p.15 and FWD p. 9, PTAB construction for “service
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`network” is not in accord with the specification. Provisional application with S/N
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`60/006,634 from which the ‘158 derives priority and ‘158: Cols 4, 5, 6 distinguish
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`a service network from a facilities network. The facilities network is a TCP/IP-
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`based (‘158: Col 6) network with physical hardware components. An Ethernet cord
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`and OSI network layer router or switch (‘158: Col 4) are examples of a facilities
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`7
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`network. The service network delivers VAN services or POSvc applications on a
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`Web page or Web browser (‘158: Col 5, 9, Figs. 5D, 6A). The service network,
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`which by definition (‘158: Col. 5) must include a GUI and a POSvc application
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`displayed on a Web page or Web browser. (5) At ID p. 16, PTAB’s construction
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`for “utilizing a routed data structure that is both complete and non-deferred” as
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`“using a data structure that facilitates switching a user who selects a transactional
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`application to a service provider program that provides immediate processing” and
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`at FWD p. 12, as “using a data structure that facilitates switching the processing of
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`information associated with a user selected transactional application that provides
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`immediate processing” is not in accord with the specification or the claim
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`language. At ID p. 16, PTAB extrapolates erroneously: “A “complete” routed
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`transactional data structure provides the information to accomplish the routing to
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`perform switching.” PTAB overlooked and misapprehended the technical problem
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`solved and the complexity of the technological solution provided by PO. PTAB
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`brashly states:
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`“…35 U.S.C. § 112 , second paragraph analysis, the Specification does not
`describe clearly how a data structure is transactional, as opposed to non-
`transactional, or routed, as opposed to non-routed. …“utilizing a routed
`transactional data structure that is both complete and non-deferred,” … mean using
`a data structure that facilitates switching the processing of information associated
`with a user– selected transactional application that provides immediate processing.
`Switching the processing of information from one resource to another, such as
`from one program or data base to another, is a well-known abstract concept that is
`not limited to any particular technical approach…” (FWD p. 17)
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`Such jumping to obscenely technically incorrect conclusions is pathetic for
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`innovation in the USA, unduly killing valid patents of good inventions that have
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`benefited the industry at large monumentally. With PTAB’s erroneous claim
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`constructions not in accord with the disclosures in the patent specification and
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`misled by SAP on fundamental Web technologies, PTAB fails to distinguish
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`between prior art and PO’s claimed inventions. PTAB’s analysis of the cited art
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`misses the whole point of the invention: real-time Web transactions by a Web user
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`from a POSvc application displayed in a Web browser or Web page. If the problem
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`had been that simple, the world would have solved it long ago. Yet in 1995, there
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`was only one-way browsing, hyperlinking, CGI and Web forms and disjointed
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`islands of information in the Back Office of enterprises. Applications were local to
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`the Back end. There were no POSvc applications at the front-end displayed on a
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`Web page or a Web browser. PTAB wonders how a data structure would be
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`transactional. This is why PO has persistently required that the POSvc application
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`be construed to be “a transactional application displayed on a Web page or Web
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`browser with the object identity with information entries and attributes displayed
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`on the Web page, with which the user interacts and transacts from.” It is this object
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`identity or object data structure that has the attributes (which are the characteristics
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`of the object) and information entries (which are the values of the characteristics
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`of the objects) , where the user inputs the values of the characteristics of the object
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`9
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`in the live POSvc Web application displayed on a Web page or Web browser in
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`order to perform a real-time Web transaction, such as in ‘158: Col 7.
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`“Each Web merchant may choose the types of services … in their POSvc
`application access to checking and savings accounts, user 100 will be able to
`perform real-time transactions against his checking and savings accounts. Thus, if
`user 100 moves $500 from his checking account into his savings account, the
`transaction will be performed in real-time, … same … by a live teller … ATM
`machine. …unlike his prior access to his account, user 100 now has the capability
`to do more than browse his bank account. The ability to perform these types of
`robust, real-time transactions from a Web client is a significant aspect of the
`present invention.” (‘158: Col 7)
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`Fig.5D shows the POSvc application displayed on a Web page including the object
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`identity with information entries and attributes (“NAME,” “PASSWORD”)
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`displayed on the Web page. ‘158: Col 7 also details information entries as user
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`100, checking account #, savings account #, $500 for attributes, name of user,
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`checking and savings accounts, amount transferred, in checking account object
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`identity, which is an individual networked object that uniquely identifies a specific
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`instantiation of the object. (‘158: Col 8) It is this data structure, called object
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`identity with information entries and attributes, that is interactive and that
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`interactive object data structure is what makes the data structure transactional
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`versus non-transactional. These information entries and attributes are routed in the
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`OSI application layer as a structured whole over the service network on the Web
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`from the POSvc application displayed on a Web page. It is this structure or
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`instantiated object with its information entries and attributes that gets routed and
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`becomes a networked object between the POSvc application on a Web page or
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`Web browser and the services of a Web merchant. This is not a CORBA object,
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`which is a program object or lines of code. This is the crux of the invention where
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`this structured whole, the object identity with information entries and attributes,
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`that makes it “complete” and it is routed non-deferred in real-time from the POSvc
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`application on a Web page or Web browser to the services of a Web merchant.
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`Therefore, PTAB, having misapprehended and overlooked this significant
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`invention, must allow Claim 1 as 101 patentable, term construable with ample
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`support in the specification and hence also patentable under 112, 2nd paragraph.
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`PTAB’s conclusion in FWD p. 17 is erroneous, “we conclude that claim 1 does not
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`recite patent–eligible subject matter.” PO has just evidenced why claim 1 does
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`recite patent-eligible subject matter. This also shows why this should not be a
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`CBM because it solves a technological problem and is a technological invention.
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`This explanation was overlooked by the PTAB and solves all the 101; 112, 2nd
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`paragraph issues. PO has shown above why the claim term “routed transactional
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`data structure” is not indefinite. (6) In FWD p. 12, PTAB erroneously construed
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`“object routing” as “the use of individual network objects to route a user from a
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`selected transactional application to the processing provided by the service
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`provider.” In FWD p. 12, PTAB has missed even that the very term “object
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`11
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`routing” means routing of objects, not routing of users. (7) The PTAB erroneously
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`concludes:
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` “Claim 1 does not recite a particular technology. Because claim 1 recites only
`using a data structure that facilitates switching so that a financial transaction can
`occur, we are not persuaded that claim 1 recites a technical solution to a technical
`problem” (ID p. 18)
` “The discussion of such shortcomings in the prior art does not change the nature
`of claim 1 as being drawn to a method of performing a transaction by carrying out
`certain non-technical steps.” (FWD p. 14)
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`PTAB does not provide any reasonable justification and overlooks the complexity
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`of the problem solved by the inventor in 1995, a universal unmet need for a
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`solution, as seen from the cited art Computerworld and SFCU, who exemplify all
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`enterprises seeking a technical solution to a complex technological problem. In
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`FWD p. 23, PTAB has overlooked the point that SFCU and Computerworld did
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`not conduct real-time transactions, they conducted deferred transactions via email,
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`one-way browsing, Web forms and hyperlinking, all of the technologies that PO
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`has already disclaimed in ‘158: Cols 1,2 and 5. ‘158: Cols 1, 5, 7 detail the
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`problems of prior art in 1995, namely, hyperlinking, one-way browsing, Web page,
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`Web form, CGI. In 1995, applications were local to the Back Office of enterprises
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`and did not connect to the front-end to a Web page or Web server or to a non-
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`existent POSvc application displayed on a Web page. Neither EB nor SFCU meet
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`the claim limitations in Claim 1, namely, “a real time Web transaction,” “a real
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`time Web transaction form a Web application,” “a point-of-service application as a
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`12
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`selection within the Web page,” “point-of-service application operating in a service
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`network atop the World Wide Web,” “transferring funds from the checking
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`account to the savings account in real-time utilizing a routed transactional data
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`structure that is both complete and non-deferred.” PTAB erroneously concluded:
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`“we conclude that the preponderance of the evidence shows that claim 1 is
`unpatentable under 35 U.S.C. § 103 over the combination of EB and SFCU.”
`(FWD p. 23)
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`Examples of SAP’s counsel and expert witness knowingly and fraudulently
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`misleading PTAB and licensed lawyers violating professional rules abound. For
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`example, in FWD pp. 24-25, PTAB evidences that they were led by SAP to come
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`to the conclusion that combining Lawlor with Computerworld would have resulted
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`in claim 1 of the subject patent claim. It is also clear that PTAB lacks knowledge
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`of early Web technologies. In FWD pp. 20-27, PTAB, with no valid reason,
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`unreasonably concludes that claims 1-3 and 11 are rendered obvious by Lawlor in
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`combination with Computerworld or SFCU with Electronic Banking by Lipis, even
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`though PO has evidenced repeatedly that neither Computerworld, nor Electronic
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`Banking nor Lawlor nor SFCU disclose or teach any of the claim limitations of the
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`challenged claims. PTAB states:
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`“Petitioner notes that the combination of Lawlor and Computerworld is nothing
`more than combining the remote banking services of Lawlor with the World Wide
`Web banking Web sites described in Computerworld without any significant
`modification. Pet. 41. Petitioner points out that both references discuss home
`banking systems, i.e., the disclosed Computerworld systems operate on the World
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`13
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`Wide Web, while Lawlor operates over standard phone networks. Id. Citing the
`Declaration of Dr. Sirbu Ex. 1003 (“Sirbu Decl.”), Petitioner persuasively argues
`that one of ordinary skill in the art would have found it obvious to adapt the
`Lawlor system to the World Wide Web, as Computerworld discusses banks that
`were performing money transfers over the World Wide Web. In consideration of
`the above, we conclude Petitioner has shown by a preponderance of the evidence
`that, under 35 U.S.C. § 103, claim 1 is unpatentable over the combination of
`Lawlor and Computerworld.” (FWD pp. 24-25)
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` (8) PTAB brashly extrapolates and jumps to inaccurate conclusions providing no
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`valid reason, stating:
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`“The Specification notes that object routing can be accomplished using an
`undisclosed, proprietary protocol, TransWeb™ Management Protocol (TMP) that
`can incorporate…(DOLSIBs… to perform the object routing. Id. at col. 7, l. 54–65.
`The term “routed transactional data structure” is indefinite because it fails to
`inform a person skilled in the art of the scope of “data structure,” and also because
`the “rout[ing]” uses an undisclosed proprietary protocol.” (FWD p. 20)
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`“… “utilizing a routed transactional data structure that is both complete and non-
`deferred,”…to mean…Switching the processing of information from one resource
`to another, such as from one program or data base to another, is a well-known
`abstract concept that is not limited to any particular technical approach, such as
`object routing, as recited in claim 4. … The service network … is an abstract
`concept … the service provider can service the customer…transfer funds …. This
`does not impose a meaningful limitation on the scope of the claim. See SiRF Tech,
`601 F.3d at 1333. … Thus, we conclude that Petitioner has demonstrated that
`claims 1–3 and 11 do not recite patentable subject matter under 35 U.S.C. § 101.”
`(FWD pp. 15-17)
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`“The steps … in claim 1 … providing a webpage for display, … application the
`user can select to access checking and savings accounts, accepting signals from an
`input device, and transferring funds. There is no technological invention in these
`steps… performing a transaction by carrying out certain non-technical steps. As we
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`have construed … POSvc application … service network … A user’s selection of a
`transactional application transfers processing to a service provider program which,
`… provides immediate processing. None of these features changes the non-
`technological nature of claim 1. Thus, the subject matter of claim 1 is directed to a
`non-technical invention, i.e., simply transferring funds.” (FWD pp. 13-15)
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`Such brash, obscenely unreasonable, baseless and incorrect conclusions are what
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`make the AIA and IPR process unconstitutional. PTAB has failed to acknowledge
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`that the CBM process is unconstitutional, as stated by Federal Circuit Judge
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`Newman that no administrative body of the Fed Govt can rule a property right
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`invalid and only a Court has that right. These current PTAB and AIA procedures
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`render the PTO’s existence meaningless. PTAB may as well stop wasting the
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`valuable creative time of inventors and just issue a memo up front that PO
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`objections are pointless and invalidation is a foregone conclusion. PTAB does not
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`think it even has to give valid reasons. In short, the AIA and PTAB are legalizing
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`piracy. A patent is a property right. The USPTO is an administrative body that
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`does not have the constitutional right to snatch a patent away from the PO simply
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`because deep-pocketed cronies want them to. The USPTO may grant a property
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`right, but cannot take it away. Congress grants patent property rights, and only
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`Congress can take those rights away. PO spent valuable health, time, money, costs,
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`attorneys’ fees to file and procure a patent and defend the patent against frivolous
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`petitions by deep-pocketed Defendant infringers. To date, the USPTO has assigned
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`examiners and judges without the experience to assess the PO’s inventions
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`competently. A person of reasonable skill in the art can readily see this from the
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`Record. In addition, PTAB Judges have undisclosed financial conflicts of interest
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`as do their bosses. PTAB Judges displayed bias in this case by authorizing SAP to
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`file an opposition to PO’s motion to stay the case until underlying matters
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`involving judicial conflicts of interest, fraud and substitution of parties in the lower
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`court were resolved. Rules are being made arbitrarily. PO is due from PTAB a
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`refund of all monies spent thus far by PO from the time of filing of the patent
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`application until the present time, of the order of several million dollars, including
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`USPTO fees, attorneys’ fees
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`to procure and defend
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`the patent
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`in
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`this
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`unconstitutional CBM. For at least the reasons set forth herein, PO requests PTAB
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`to allow all claims.
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`Date: October 17, 2014
`222 Stanford Avenue,
`Menlo Park, CA 94025
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`650.690.0995
`Laks22002@yahoo.com
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`Respectfully submitted,
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`DR. LAKSHMI ARUNACHALAM
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`_/Lakshmi Arunachalam/_________
` Lakshmi Arunachalam
`Pro Se Patent Owner
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`16
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`CERTIFICATION OF SERVICE (37 CFR 42.6(e), 42.105(a))
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`The undersigned hereby certifies that the above-captioned “PATENT OWNER’S
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`
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`REQUEST FOR RE-HEARING” in Case CBM2013-00013 was served in its
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`entirety on October 17, 2014, upon the following parties via e-mail:
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`
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`SAP, America, Inc
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`Attn: Samir N. Pandya
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`Sr. IP Counsel
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`SAP Global Litigation Group
`3999 West Chester Pike
`Newtown Square, PA 19073
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`Lori A. Gordon and Michael Q. Lee
`STERNE, KESSLER, GOLDSTEIN
`& FOX P.L.L.C.
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`1100 New York Avenue, NW
`Washington, DC 20005
`lgordon-PTAB@skgf.com
`mlee-PTAB@skgf.com
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`Attorneys for Petitioner
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`610.661.9767
`Samir.pandya@sap.com
`Petitioner’s correspondence address Of record at the USPTO PTAB
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`Dr. Lakshmi Arunachalam
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`_/Lakshmi Arunachalam/_________
`Lakshmi Arunachalam
`Pro Se Patent Owner
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`Date: October 17, 2014
`222 Stanford Avenue
`Menlo Park, CA 94025
`650.690.0995
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