Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 1 of 9
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`WILLIAM GRECIA,
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`Plaintiff,
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`v.
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`CITIBANK, N.A.,
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`Formatted Table
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`Case No. 19-cv-2811 (VEC)
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`AMENDED COMPLAINT
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`JURY TRIAL DEMANDED
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`Defendant.
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`William Grecia brings this patent-infringement action against Citibank, N.A. (hereinafter,
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`“Citibank”).
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`Parties
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`1.
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`William Grecia is an individual. He maintains a residence in Downingtown,
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`Pennsylvania.
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`2.
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`Citibank is a national banking association, having a principal place of business in
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`New York, New York.
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`Jurisdiction and Venue
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`This action arises under the patent laws of the United States, 35 U.S.C. §§ 101 et
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. §§
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`seq.
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`3.
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`4.
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`1331 and 1338(a).
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`5.
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`This Court may exercise personal jurisdiction over Citibank. Citibank conducts
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`-1-
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`EWS-001258
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`Early Warning Services 1023
`IPR of U.S. Pat. No. 8,887,308
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 2 of 9
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`continuous and systematic business in New York and in this District. Citibank maintains
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`corporate offices in this District. This patent-infringement case arises directly from Citibank’s
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`continuous and systematic activity in this District. In short, this Court’s exercise of jurisdiction
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`over Citibank would be consistent with traditional notions of fair play and substantial justice.
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`6.
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`7.
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`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b)(1) and 1400(b).
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`Claim Construction
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`On September 8, 2018, the Court (Sullivan, J.) entered an order construing claim
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`terms set forth in the patent-in-suit. Grecia v. Mastercard Int’l Inc., Case No. 15-cv-9059 (RJS)
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`(S.D.N.Y. Sept. 8, 2018) (Doc. 89). “Cloud digital content” means “data capable of being
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`processed by a computer.” (Id. at 11.) “Verified web service” means “a web service that is used
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`to authenticate the identity of a user or device.” (Id. at 12.) “Verification token” means “data that
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`represents permission to access digital media or cloud digital content.” (Id. at 15.)
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`Infringement of U.S. Patent No. 8,887,308
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`8.
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`William Grecia hereby realleges and incorporates by reference, as if fully set forth
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`herein, the allegations of paragraphs 1-7 above.
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`9.
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`William Grecia is the exclusive owner of the ‘308 patent, which is attached hereto
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`as “Exhibit A.”
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`Deleted: 1
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`10.
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`11.
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`The ‘308 patent is valid and enforceable.
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`The ‘308 patent claims patentable subject matter under § 101. Indeed, the United
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`States Patent and Trademark Office examined the elements of the ‘308 patent and found an
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`“inventive concept”: “[N]either Baiya nor Wimmer either singly or in combination implicitly or
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`explicitly suggests a process for transforming a user access request for cloud digital content into
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`EWS-001259
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 3 of 9
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`a computer readable authorization object with the steps of . . . .” (File History Excerpt attached
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`hereto as “Exhibit B.” (emphasis in original).)
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`12.
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`The U.S. Patent and Trademark Office then quoted the following elements of the
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`‘308 patent as providing this “inventive concept”: “establishing an API communication between
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`the apparatus of (a) and a database apparatus, the database apparatus being a different
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`database from the verification token database of (b) wherein the API is related to a verified web
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`service, wherein the verified web service is a part of the database apparatus, wherein
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`establishing the API communication requires a credential assigned to the apparatus of (a),
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`wherein the apparatus assigned credential is recognized as a permission to conduct a data
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`exchange session between the apparatus of (a) and the database apparatus to complete the
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`verification process, wherein the data exchange session is also capable of an exchange of query
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`data, wherein the query data comprises at least one verified web service account identifier; then
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`d) requesting the query data, from the apparatus of (a), from the API communication data
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`exchange session of (c), wherein the query data request is a request for the at least one verified
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`web service identifier. (Ex. B (File History) (emphasis in original).)
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`13.
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`“Since no prior art teaches or suggests any process with the above allowable
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`limitations, claim [1] is allowed. (Ex. B (File History).)
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`14.
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`The U.S. Patent and Trademark Office has denied three petitions for inter partes
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`review filed against the ‘308 patent. Each of these decisions affirms the U.S. Patent and
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`Trademark Office’s initial determination that the elements of the ‘308 patent disclose an
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`“inventive concept.” On August 30, 2016, the U.S. Patent and Trademark Office held the ‘308
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`patent valid over prior art that failed to teach or suggest “a credential assigned to the apparatus of
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`EWS-001260
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 4 of 9
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`(a)” or “requesting the query data, from the apparatus of (a) . . . .” (Decision in Unified Patents
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`Inc. v. Grecia attached as “Exhibit C.”)
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`15.
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`On January 19, 2017, the U.S. Patent and Trademark Office held the ‘308 patent
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`valid over prior art that failed to teach “establishing an API communication between the
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`apparatus of (a) and a database apparatus,” “wherein establishing the API communication
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`requires a credential assigned to the apparatus of (a),” or “the apparatus of (a) using a cross-
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`referencing action during subsequent user access requests to determine one or more of a user
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`access permission for the cloud digital content.” (Decision in DISH Network, L.L.C. v. Grecia
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`attached hereto as “Exhibit D.”)
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`16.
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`On July 3, 2017, the U.S. Patent and Trademark Office held the ‘308 patent valid
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`over prior art that failed to disclose “a computer readable authorization object.” (Decision in
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`Mastercard Int’l Inc. v. Grecia attached hereto as “Exhibit E.”)
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`17.
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`Claim 1 covers, “A process for transforming a user access request for cloud
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`digital content into a computer readable authorization object . . . .” Citibank’s service, Citi with
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`Zelle (hereinafter, “CZelle”), infringes claim 1, transforming a user’s email address, for example,
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`into a payment token that may be used to send and receive money safely. The ‘308 patent
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`teaches, “the invention is a process of an apparatus . . . another apparatus, tangible computer
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`medium, or associated methods (hereinafter referred to as The App) . . . .” (Ex. A (‘308 patent),
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`col. 3:15-19).) In this case, Citibank’s service, CZelle, is The App taught and claimed in the ‘308
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`patent
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`18.
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`Claim 1 involves, “receiving an access request for cloud digital content through
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`an apparatus in process with at least one CPU, the access request being a write request to a data
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`EWS-001261
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 5 of 9
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`store, wherein the data store is at least one of: a memory connected to the at least one CPU; a
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`storage connected to the at least one CPU; and a database connected to the at least one CPU
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`through the Internet; wherein the access request further comprises verification data provided by
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`at least one user, wherein the verification data is recognized by the apparatus as a verification
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`token . . . .” CZelle, which includes software, hardware, and firmware owned and controlled by
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`Deleted: CZelle
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`Citibank (hereinafter, the “Citi App”), receives a write request for access to Zelle cloud digital
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`financial account data through a CPU to write a Zelle “token” (i.e., a “computer readable
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`authorization object”) to storage. This write request is the Citibank customer registering his
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`email address and mobile telephone number with the CZelle service, the Citi App. The
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`customer’s email address and mobile telephone number is the “verification token.” The Citi App
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`practices the step of “receiving” covered by claim 1 of the ‘308 patent.
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`19.
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`Zelle is offered directly within the Citi App. (See Claim Chart attached hereto as
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`“Exhibit F.”) Citibank, Zelle, or both deleted from public view the document styled IBM Zelle
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`RESTful API #27050366, which demonstrates how the Citi App practices steps of claim 1 of the
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`‘308 patent. A copy of this deleted document has been preserved by Mr. Grecia and is excerpted
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`in the attached claim chart.
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`Deleted: or
`Deleted: .
`Deleted: or
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`20.
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`Next, claim 1 involves “authenticating the verification token of (a) using a
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`database recognized by the apparatus of (a) as a verification token database . . . .” Citibank’s
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`CZelle has a database that Citibank uses to authenticate a CZelle user’s email address and mobile
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`Deleted: or
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`telephone number. The Citi App practices the “authenticating” step covered by claim 1 of the
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`‘308 patent.
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`21.
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`Claim 1 involves “establishing an API communication between the apparatus of
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`EWS-001262
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 6 of 9
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`(a) and a database apparatus, the database apparatus being a different database from the
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`verification token database of (b) wherein the API is related to a verified web service, wherein
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`the verified web service is a part of the database apparatus, wherein establishing the API
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`communication requires a credential assigned to the apparatus of (a), wherein the apparatus
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`assigned credential is recognized as a permission to conduct a data exchange session between the
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`apparatus of (a) and the database apparatus to complete the verification process, wherein the data
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`exchange session is also capable of an exchange of query data, wherein the query data comprises
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`at least one verified web service account identifier . . . .” CZelle establishes a connection to the
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`Zelle service database that is related to the Zelle services API. This connection is established
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`with a credential assigned to Citibank’s CZelle service (e.g., Participant ID, Partner ID). The Citi
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`App is the “apparatus of (a),” and the Participant ID or Partner ID is assigned to the Citi App.
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`The Zelle service database is a different database than the database Citibank CZelle uses to
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`authenticate the user’s registered email address and mobile telephone number. The Citi App
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`Deleted: or mobile telephone number.
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`practices the “establishing an API communication” step covered by claim 1 of the ‘308 patent.
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`Zelle is offered directly within the Citi App. (See Claim Chart attached hereto as “Exhibit F.”)
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`22.
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` Claim 1 next involves “requesting the query data, from the apparatus of (a), from
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`the API communication data exchange session of (c), wherein the query data request is a request
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`for the at least one verified web service identifier; then e) receiving the query data requested in
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`(d) from the API communication data exchange session of (c) . . . .” CZelle infringes claim steps
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`d) and e) when the Zelle service database returns the CXCTokens requested. The claimed
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`credential
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`required
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`RESTful
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`API
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`operation
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`call
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`is
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`https://<servername:serverport>/fxh/svc/cxctokens/{key}. After Citibank authenticates the user’s
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`EWS-001263
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 7 of 9
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`email address or telephone number (i.e., verification token), Citibank infringes by establishing a
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`connection to the Zelle service database related to the Zelle services API with an assigned
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`credential (e.g., Participant ID, Partner ID). The Zelle web service is a “part” of the FTM
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`database, and the FTM database infringes because the FTM database is a different database than
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`the Citibank CZelle verification token database. The Zelle database is a different database than
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`the verification token database that Citibank uses to authenticate the user’s telephone number or
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`email address. The Citi App practices the “requesting and receiving query data” steps covered by
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`claim 1 of the ‘308 patent. Zelle is offered directly within the Citi App. (See Claim Chart
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`attached hereto as “Exhibit F.”) Defendant Citibank is the party that practices the steps of
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`“establishing an API communication,” “requesting query data,” and “receiving query data,” all
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`within the meaning of claim 1 of the ‘308 patent.
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`23.
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`Lastly, claim 1 involves “creating a computer readable authorization object by
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`writing into the data store of (a) at least one of: the received verification data of (a); and the
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`received query data of (e); wherein the created computer readable authorization object is
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`recognized by the apparatus of (a) as user access rights associated to the cloud digital content,
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`wherein the computer readable authorization object is processed by the apparatus of (a) using a
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`cross-referencing action during subsequent user access requests to determine one or more of a
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`user access permission for the cloud digital content.” CZelle infringes claim step f) by creating a
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`computer readable authorization object by writing the “enrolled” Citibank CZelle verification
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`data of a) and the “enrolled” Zelle query data received in e) into the CZelle data storage. The
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`CZelle authorization object is used in subsequent requests for access to Zelle privileged financial
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`data to “send money” using a cross reference action between the CZelle data store and the Zelle
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`EWS-001264
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 8 of 9
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`web service to determine (e.g., the tokenStatus String) an access permission to the Zelle privy
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`financial data. The Citi App practices the “creating a computer readable authorization object”
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`step covered by claim 1 of the ‘308 patent. Zelle is offered directly within the Citi App. (See
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`Claim Chart attached hereto as “Exhibit F.”) Defendant Citibank performs the act of creating a
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`computer readable authorization object, as claimed in the ‘308 patent. What is more, this
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`“computer readable authorization object” is then processed by the Citi App as claimed in the
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`‘308 patent and as described in this Amended Complaint.
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`Prayer for Relief
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`WHEREFORE, William Grecia prays for the following relief against Citibank:
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`(a)
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`(b)
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`(c)
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`(d)
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`(e)
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`Judgment that Citibank has directly infringed claim 1 of the ‘308 patent;
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`A reasonable royalty;
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`Pre-judgment interest and post-judgment interest at the maximum rate allowed by
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`law;
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`Post-judgment injunction; and
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`Such other and further relief as the Court may deem just and proper.
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`Demand for Jury Trial
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`William Grecia demands a trial by jury on all matters and issues so triable.
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`Deleted: ¶
`Date: March 29, 2019
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`... [1]
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`-8-
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`EWS-001265
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`Case 1:19-cv-02811-VEC Document 28 Filed 07/05/19 Page 9 of 9
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`Date: July 5, 2019
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`Respectfully Submitted,
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`/s/ Matthew M. Wawrzyn
`Matthew M. Wawrzyn (pro hac vice)
`matt@wawrzynlaw.com
`WAWRZYN & JARVIS LLC
`2700 Patriot Blvd., Suite 250
`Glenview, IL 60026
`847.656.5864
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`Counsel for William Grecia
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`-9-
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`EWS-001266
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`Case 1:19-cv-02811-VEC Document 28-1 Filed 07/05/19 Page 1 of 17
`Case 1:19—cv-02811-VEC Document 28-1 Filed 07/05/19 Page 1 of 17
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`EXHIBIT A
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`EXHIBIT A
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`EWS-001267
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`EWS-001267
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`Case 1:19-cv-02811-VEC Document 28-1 Filed 07/05/19 Page 8 of 17
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`U.S. Patent
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`Nov. 11, 2014
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`Sheet 6 of7
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`US 8,887,308 B2
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`02
`~6
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`604
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`If'
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`606
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`If'
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`608
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`610
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`If'
`If'
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`612
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`If
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`( Start )
`~
`Receive a branding request from at least
`one communications console of the
`plurality of data processing devices
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`Authenticate the membership verification
`token
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`'
`'
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`Establish connection with the at least
`one communications console
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`~
`Request at least one electronic
`identification reference from the at least
`one communications console
`~
`Receive the at least one electronic
`identification reference from the at least
`one communications console
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`Brand metadata of the encrypted digital
`media
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`'
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`( End )
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`FIG.6
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`EWS-001274
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`Case 1:19-cv-02811-VEC Document 28-1 Filed 07/05/19 Page 10 of 17
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`US 8,887,308 B2
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`1
`DIGITAL CLOUD ACCESS (PDMAS PART III)
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`CROSS-REFERENCE TO RELATED
`APPLICATIONS
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`This application is a continuation of and claims the priority
`benefit of U.S. patent application Ser. No. 13/740,086 filed
`Jan. 11, 2013 which is a continuation of and claims the pri(cid:173)
`ority benefit of Ser. No. 13/397,517 filed Feb. 15, 2012 now
`issued as U.S. Pat. No. 8,402,555 on Mar. 19, 2013 which is
`a continuation of and claimed the priority benefit of Ser. No.
`12/985,351 filed Jan. 6, 2011 which was a continuation of and
`claimed the priority benefit ofU.S. patent application Ser. No.
`12/728,218 filed Mar. 21, 2010, which are incorporated
`herein by reference in their entirety.
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`BACKGROUND OF THE INVENTION
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`1. Field of the Invention
`The present invention relates to the field of digital rights
`management schemes used by creators of electronic products
`to protect commercial intellectual property copyrights privy
`to illegal copying using computerized devices. More specifi(cid:173)
`cally, the present invention teaches a more personal system of
`digital rights management which employs electronic ID, as
`part of a web service membership, to manage access rights
`across a plurality of devices.
`2. Description of the Prior Art
`Digital rights management (DRM) is a generic term for
`access control technologies used by hardware manufacturers,
`publishers, copyright holders and individuals to impose limi(cid:173)
`tations on the usage of digital content across devices. DRM
`refers to any technology that inhibits undesirable or illegal
`uses of the digital content. The term generally doesn't refer to
`forms of copy protection that can be circumvented without
`modifYing the file or device, such as serial numbers or key
`files. It can also refer to restrictions associated with specific
`instances of digital works or devices.
`Traditional DRM schemes are defined as authentication
`components added to digital files that have been encrypted
`from public access. Encryption schemes are not DRM meth(cid:173)
`ods but DRM systems are implemented to use an additional
`layer of authentication in which permission is granted for
`access to the cipher key required to decrypt files for access. A
`computer server is established to host decryption keys and to
`accept authentication keys from Internet connected client
`computers running client software in which handles the
`encrypted files. The server can administer different authori(cid:173)
`zation keys back to the client computer that can grant different
`sets of rules and a time frame granted before the client is
`required to connect with the server to reauthorize access
`permissions. In some cases content can terminate access after
`a set amount of time, or the process can break if the provider
`of the DRM server ever ceases to offer services.
`In the present scenario, consumer entertainment industries 55
`are in the transition of delivering products on physical media
`such as CD and DVD to Internet delivered systems. The
`Compact Disc, introduced to the public in 1982, was initially
`designed as a proprietary system offering strict media to
`player compatibility. As the popularity of home computers
`and CD-ROM drives rose, so did the availability of CD rip(cid:173)
`ping applications to make local copies of music to be enjoyed
`without the use of the disc.After a while, users found ways to
`share digital versions of music in the form of MP3 files that
`could be easily shared with family and friends over the Inter(cid:173)
`net. The DVD format introduced in 1997 included a new
`apparatus for optical discs technology with embedded copy
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`2
`protection schemes also recognized as an early form ofDRM.
`With internet delivered music and video files, DRM schemes
`has been developed to lock acquired media to specific
`machines and most times limiting playback rights to a single
`machine or among a limited number of multiple machines
`regardless of the model number. This was achieved by writing
`the machine device ID to the meta data of the media file, then
`cross referencing with a trusted clearinghouse according to
`pre-set rules. DRM systems employed by DVD and CD tech-
`10 nologies consisted of scrambling (also known as encryption)
`disc sectors in a pattern to which hardware developed to
`unscramble (also known as decryption) the disc sectors are
`required for playback. DRM systems built into operating
`systems such as Microsoft Windows Vista block viewing of
`15 media when an unsigned software application is running to
`prevent unauthorized copying of a media asset during play(cid:173)
`back. DRM used in computer games such as SecuROM and
`Steam are used to limit the amount of times a user can install
`a game on a machine. DRM schemes fore-books include
`20 embedding credit card information and other personal infor(cid:173)
`mation inside the metadata area of a delivered file format and
`restricting the compatibility of the file with a limited number
`of reader devices and computer applications.
`In a typical DRM system, a product is encrypted using
`25 Symmetric block ciphers such as DES and AES to provide
`high levels of security. Ciphers known as asymmetric or pub(cid:173)
`lic key/private key systems are used to manage access to
`encrypted products. In asymmetric systems the key used to
`encrypt a product is not the same as that used to decrypt it. If
`30 a product has been encrypted using one key of a pair it cannot
`be decrypted even by someone else who has that key. Only the
`matching key of the pair can be used for decryption. After
`receiving an authorization token from a first-use action are
`usually triggers to decrypt block ciphers in most DRM sys-
`35 terns. User rights and restrictions are established during this
`first-use action with the corresponding hosting device of a
`DRM protected product.
`Examples of such prior DRM art include Hurtado (U.S.
`Pat. No. 6,611,812) who described a digital rights manage-
`40 ment system, where upon request to access digital content,
`encryption and decryption keys are exchanged and managed
`via an authenticity clearing house. Other examples include
`Alve (U.S. Pat. No. 7,568,111) who teaches a DRM and
`Tuoriniemi (U.S. Pat. No. 20090164776) who described a
`45 management scheme to control access to electronic content
`by recording use across a plurality of trustworthy devices that
`has been granted permission to work within the scheme.
`Recently, DRM schemes have proven unpopular with con(cid:173)
`sumers and rights organizations that oppose the complica-
`50 tions with compatibility across machines manufactured by
`different companies. Reasons given to DRM opposition
`range from limited device playback restrictions to the loss of
`fair-use which defines the freedom to share media products
`will family members.
`Prior art DRM methods rely on content providers to main-
`tain computer servers to receive and send session authoriza(cid:173)
`tion keys to client computers with an Internet connection.
`Usually rights are given from the server for an amount of time
`or amount of access actions before a requirement to reconnect
`60 with the server is required for reauthorization. At times, con(cid:173)
`tent providers will discontinue servers or even go out of
`business some years after DRM encrypted content was sold to
`consumers causing the ability to access files to terminate.
`In the light of the foregoing discussion, the current states of
`65 DRM measures are not satisfactory because unavoidable
`issues can arise such as hardware failure or property theft that
`could lead to a paying customer loosing the right to recover
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`EWS-001276
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`Case 1:19-cv-02811-VEC Document 28-1 Filed 07/05/19 Page 11 of 17
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`US 8,887,308 B2
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`3
`purchased products. The current metadata writable DRM
`measures do not offer a way to provide unlimited interoper(cid:173)
`ability between different machines. Therefore, a solution is
`needed to give consumers the unlimited interoperability
`between devices and "fair use" sharing partners for an infinite
`time frame while protecting commercial digital media from
`unlicensed distribution to sustain long-term return of invest(cid:173)
`ments.
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`SUMMARY OF THE INVENTION
`
`4
`least one communications console. Further, the at least one
`electronic identification reference is received from the at least
`one communications console. Finally, branding metadata of
`the encrypted digital media is performed by writing the mem(cid:173)
`bership verification token and the electronic identification
`reference into the metadata.
`The present invention is particularly useful for giving users
`the freedom to use products outside of the device in which the
`product was acquired and extend unlimited interoperability
`10 with other compatible devices.
`
`An object of the present invention is to provide unlimited
`interoperability of digital media between unlimited machines
`with management of end-user access to the digital media.
`In accordance with an embodiment of the present inven- 15
`tion, the invention is a process of an apparatus which in
`accordance with an embodiment, another apparatus, tangible
`computer medium, or associated methods (herein referred to
`as The App) is used to: handle at least one branding action
`which could include post read and write requests of at least 20
`one writable metadata as part of at least one digital media
`asset to identifY and manage requests from at least one excel(cid:173)
`sior enabler, and can further identify and manage requests
`from a plurality of connected second enablers; with at least
`one token and at least one electronic identification reference 25
`received from the at least one excelsior enabler utilizing at
`least one membership. Here, controlled by the at least one
`excelsior enabler, The App will proceed to receive the at least
`one token to verify the authenticity of the branding action and
`further requests; then establish at least one connection with at 30
`least one programmable communications console of the at
`least one membership to request and receive the at least one
`electronic identification reference; and could request and
`receive other data information from the at least one member(cid:173)
`ship. The method then involves sending and receiving vari- 35
`able data information from The App to the at least one mem(cid:173)
`bership to verifY a preexisting the at least one branding action
`of the at least one writable metadata as part of the at least one
`digital media asset; or to establish permission or denial to
`execute the at least one branding action or the post read and 40
`write requests of the at least one writable metadata. To do this,
`controlled by the at least one excelsior enabler. The App may
`establish at least one connection, which is usually through the
`Internet, with a programmable communications console,
`which is usually a combination of an API protocol and 45
`graphic user interface (GUI) as part of a web service. In
`addition, the at least one excelsior enabler provides reestab(cid:173)
`lished credentials to the programmable communications con(cid:173)
`sole as part of the at least one membership, in which The App
`is facilitating and monitoring, to authenticate the data com- 50
`munications session used to send and receive data requests
`between the at least one membership and TheApp.
`In accordance with another embodiment of the present
`invention, the present invention teaches a method for moni(cid:173)
`taring access to an encrypted digital media and facilitating 55
`unlimited interoperability between a plurality of data pro(cid:173)
`cessing devices. The method comprises receiving a branding
`request from at least one communications console of the
`plurality of data processing devices, the branding request
`being a read and write request of metadata of the encrypted 60
`digital media, the request comprising a membership verifica(cid:173)
`tion token corresponding to the encrypted digital media. Sub(cid:173)
`sequently, the membership verification token is authenti(cid:173)
`cated, the authentication being performed in connection with
`a token database. Thereafter, connection with the at least one 65
`communications console is established. Afterwards, at least
`one electronic identification reference is requested from the at
`
`BRIEF DESCRIPTION OF THE DRAWINGS
`
`For a more complete understanding of the present inven(cid:173)
`tion, the needs satisfied thereby, and the objects, features, and
`advantages thereof, reference now is made to the following
`description taken in connection with the accompanying draw(cid:173)
`ings.
`FIG. 1 shows a system for monitoring access to an
`encrypted digital media according to an embodiment of the
`present invention.
`FIG. 2 shows a system for authoring an encrypted digital
`media according to an embodiment of the present invention.
`FIG. 3 shows a flow chart giving an overview of the process
`of digital media personalization according to an embodiment
`of the present invention.
`FIG. 4 shows a flow chart giving an overview of the process
`of an access request made by an enabler according to an
`embodiment of the present invention.
`FIG. 5 shows personalized digital rights management com(cid:173)
`ponent as part of a compatible machine with writable static
`memory.
`FIG. 6 shows a flowchart for monitoring access to an
`encrypted digital media according to an embodiment of the
`present invention
`FIG. 7 shows a flowchart showing authoring an encrypted
`digital media according to an embodiment of the present
`invention.
`Skilled artisans will appreciate that elements in the figures
`are illustrated for simplicity and clarity and have not neces(cid:173)
`sarily been drawn to scale. For example, the dimensions of
`some of the elements in the figures may be exaggerated rela(cid:173)
`tive to other elements to help to improve understanding of
`embodiments of the present invention
`
`DETAILED DESCRIPTION OF THE DRAWINGS
`
`Before describing in detail the particular system and
`method for personalised digital media access system in accor(cid:173)
`dance with an embodiment of the present invention, it should
`be observed that the present invention resides primarily in
`combinations of system components related to the device of
`the present invention.
`Accordingly, the system components have been repre(cid:173)
`sented where appropriate by conventional symbols in the
`drawings, showing only those specific details that are perti(cid:173)
`nent to understanding the present invention so as not to
`obscure the disclosure with details that will be readily appar(cid:173)
`ent to those of ordinary skill in the art having the benefit of the
`description herein.
`In this document, relational terms such as 'first' and 'sec(cid:173)
`ond', and the like may be used solely to distinguish one entity
`or action from another entity or action without necessarily
`requiring or implying any actual such relationship or order
`between such entities or actions. The terms 'comprises',
`'comprising', or any other variation thereof, are intended to
`cover a non-exclusive inclusion, such that a process, method,
`
`EWS-001277
`
`

`

`Case 1:19-cv-02811-VEC Document 28-1 Filed 07/05/19 Page 12 of 17
`
`US 8,887,308 B2
`
`5
`article, or apparatus that comprises a list of elements does not
`include only those elements but may include other elements
`not expressly listed or inherent to such process, method,
`article, or apparatus. An element proceeded by 'comprises ..
`. a' does not, without more constraints, preclude the existence
`of additional identical elements in the process, method,
`article, or apparatus that comprises the element.
`The present invention is directed at providing infinite access
`rights oflegally acquired at least one encrypted digital media
`asset to the content acquirer, explained in this document as the
`excelsior enabler, and optionally to their recognized friends
`and family, explained in this document as a plurality of sec(cid:173)
`ondary enablers. To explain further, the excelsior enabler and
`secondary enablers defined comprises human beings or com(cid:173)
`puterized mechanisms programmed to process steps of the
`invention as would normally be done manually by a human
`being. Additionally, an apparatus used alone or in accordance
`with an embodiment, an