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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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`CSC SERVICEWORKS, INC.,
`Petitioner,
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`v.
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`PAYRANGE, INC.,
`Patent Owner.
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`
`
`IPR2023-01188
`U.S. Patent No. 10,891,608
`
`
`
`DECLARATION OF DR. B. CLIFFORD NEUMAN
` UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
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`CSC ServiceWorks - Ex. 1003
`Page 1 of 110
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`Neuman Declaration
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`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION ........................................................................................ 4
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE................ 5
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`III. LEVEL OF ORDINARY SKILL IN THE ART ....................................... 8
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`IV. RELEVANT LEGAL STANDARDS ......................................................... 9
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`V. OVERVIEW OF THE ‘608 PATENT ...................................................... 11
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`VI. CLAIM CONSTRUCTION ....................................................................... 14
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`VII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
` ...................................................................................................................... 14
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`A.
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`Summary of References ................................................................... 15
`
`a.
`
`b.
`
`c.
`
`d.
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`Summary of Laaroussi ..................................................................... 15
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`Summary of LeMay ......................................................................... 18
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`Summary of Sugimoto ..................................................................... 20
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`Summary of Okuniewicz ................................................................. 22
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`B. Reasons to Combine Secondary Prior Art References with
`Laaroussi ........................................................................................... 25
`
`a.
`
`b.
`
`c.
`
`Reasons to Combine Laaroussi and LeMay .................................. 25
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`Reasons to Combine Laaroussi and Sugimoto .............................. 30
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`Reasons to Combine Laaroussi and Okuniewicz .......................... 34
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`C. Ground 1: Claims 1-3, 5, 7-9, 11, 13-15, 17, and 19-20 are
`obvious under 35 U.S.C. § 103 over Laaroussi in view of LeMay
`and Sugimoto .................................................................................... 37
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`D. Ground 2: Claims 4, 6, 10, 12, 16, 18 are obvious over Laaroussi
`in view of LeMay, Sugimoto, and Okuniewicz ............................ 102
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`VIII. CONCLUSION ......................................................................................... 110
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`Neuman Declaration
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`I, Dr. B. Clifford Neuman, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I am making this declaration at the request of CSC Serviceworks, Inc.
`
`(“CSC”) in the matter of the Inter Partes Review of U.S. Patent No. 10,891,608
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`(“the ‘608 patent”) to Patel.
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`2.
`
`I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the specifics of my testimony, and I
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`have no other interest in this case or the parties thereto.
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`3.
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`I have been asked to provide my opinions regarding whether claims 1-2, 4-
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`8, 10-14, and 16-20 (“the Challenged Claims”) of the ‘608 patent are unpatentable,
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`as they would have been obvious to a person having ordinary skill in the art
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`(“POSITA”) at the time of the alleged invention in light of the prior art. It is my
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`opinion that all of the challenged claims would have been obvious to a POSITA.
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`4.
`
`In the preparation of this declaration, I have studied:
`
`a. The ‘608 patent, Ex.1001;
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`b. The prosecution history of the ‘608 patent (“‘608 file history”),
`
`Ex.1002;
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`c. U.S. Patent Publication No. 2010/0227671 to Laaroussi et al.
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`(“Laaroussi”), Ex.1004;
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`d. U.S. Patent No. 4,374,557 to Sugimoto et al. (“Sugimoto”), Ex.1005;
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`e. U.S. Patent No. 10,121,318 to LeMay et al. (“LeMay”), Ex.1006;
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`f. U.S. Patent No. 6,840,860 to Okuniewicz (“Okuniewicz”), Ex.1007;
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`g. Specification of the Bluetooth System, Version 1.2 (November 5,
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`2003), Ex.1011; and
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`h. Specification for RFID Air Interface, Version 1.2.0 (October 23,
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`2008), Ex. 1012.
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`5.
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`In forming the opinions expressed below, I have considered: the documents
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`listed above; the relevant legal standards, including the standard for obviousness;
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`any additional authoritative documents as cited in the body of this declaration; and
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`my own knowledge and experience based upon my work in the field of electronic
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`payments and distributed networks as described below.
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`6. Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`
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`7. My complete qualifications and professional experience are described in
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`my Curriculum Vitae, a copy of which can be found in Exhibit 1013. The following
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`is a brief summary of my relevant qualifications and professional experience.
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`8.
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`I received a Ph.D. in Computer Science in 1992 and an M.S. in Computer
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`Science in 1988 from the University of Washington, and an S.B. (Bachelor’s) in
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`Computer Science and Engineering in 1985 from the Massachusetts Institute of
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`Technology.
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`9.
`
`Since receiving my doctorate, I have devoted my career to the field of
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`distributed computer systems development and research, with a significant portion
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`of my experience in the area of electronic commerce and internet payments. I have
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`studied, taught, practiced, and researched in the field of computer science for over
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`forty years.
`
`10.
`
`I am currently an Associate Professor of Computer Science Practice in the
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`Department of Computer Science at the University of Southern California (USC),
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`where I have taught since 1992. I am also the Director of the Center for Computer
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`Systems Security, a Scientist at USC’s Information Sciences Institute, and I direct
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`the Computer Security Curricula within the Data Science Program at USC.
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`11.
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`I teach and have taught numerous courses at USC, including advanced
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`courses in computer science for upper-level undergraduates and graduate students,
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`on topics such as distributed systems and computer network security.
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`12. As part of my research at USC, I have worked in a number of areas,
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`including research in distributed computer systems with emphasis on scalability and
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`computer security, especially in the areas of authentication, authorization, policy,
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`electronic commerce, and protection of cyber-physical systems and critical
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`infrastructure such as the power grid. I have worked on the design and development
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`of scalable information, security, and computing infrastructure for the Internet. I am
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`also the principal designer of the Kerberos system, an encryption-based
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`authentication system used among other things as the primary authentication method
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`for most versions of Microsoft’s Windows, as well as many other systems. I
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`developed systems which used Kerberos as a base for more comprehensive computer
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`security services supporting authorization, accounting, and audit.
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`13.
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`In addition to my academic experience, I have many years of practical
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`experience designing computer security systems. For example, from 1985-1986, I
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`worked on Project Athena at MIT, to produce a campus-wide distributed computing
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`environment. I also served as Chief Scientist at CyberSafe Corporation from 1992-
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`2001. I have designed systems for network payment, which build upon security
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`infrastructure to provide a secure means to pay for services provided over the
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`Internet. For example, I designed the NetCheque and NetCash systems, which are
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`suitable for micropayments (payments on the order of pennies where the cost of
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`clearing a credit card payment would be prohibitive). In 2000 and 2001, I was on the
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`advisory board for NetResearch Inc, d/b/a BayBuilder, which was a company
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`developing online auction platforms.
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`14. As part of my research on computer security and electronic payment
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`systems, I was involved with the integration of portable electronic devices such as
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`smart cards and PCMCIA cryptographic processors with other computer devices
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`such as card readers and personal computers.
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`15.
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`I have authored or co-authored over 50 academic publications in the fields
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`of computer science and engineering. In addition, I have been a referee or editor for
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`the following academic journals: ACM Transaction on Information and Systems
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`Security and International Journal of Electronic Commerce. My curriculum vitae
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`includes a list of publications on which I am a named author.
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`16.
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`I am also a member of the IEEE, Association for Computer Machinery
`
`(ACM), and the Internet Society (ISOC), among others. I have also served as
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`program and/or general chair of the following conferences: The Internet Society
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`Symposium on Network and Distributed System Security and the ACM Conference
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`on Computer and Communications Security.
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`17. My complete qualifications and professional experience are described in
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`my Curriculum Vitae, a copy of which can be found in Exhibit 1013.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
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`18.
`
`I understand there are multiple factors relevant to determining the level of
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`ordinary skill in the pertinent art, including (1) the levels of education and experience
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`of persons working in the field at the time of the invention; (2) the sophistication of
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`the technology; (3) the types of problems encountered in the field; and (4) the prior
`
`art solutions to those problems.
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`19.
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`It is my understanding that the earliest possible priority date for the ‘608
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`patent is December 18, 2013. A person of ordinary skill in the art (“POSITA”) in the
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`field of the ‘608 patent, as of December 18, 2013, would have had a bachelor’s
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`degree in electrical engineering, computer engineering, computer science, or
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`equivalent training and approximately three years of experience with electronic
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`payment systems, vending machine technologies, or distributed network systems.
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`Lack of work experience can be remedied by additional education, and vice versa.
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`20. For purposes of this Declaration, in general, and unless otherwise noted,
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`my statements and opinions, such as those regarding my experience and the
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`understanding of a POSITA generally (and specifically related to the references I
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`consulted herein), reflect the knowledge that existed in the field as of the alleged
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`priority date of the ‘608 patent (i.e., December 18, 2013). Unless otherwise stated,
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`when I provide my understanding and analysis below, it is consistent with the level
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`of a POSITA as of the alleged priority date of the ‘608 patent.
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`IV. RELEVANT LEGAL STANDARDS
`21.
`I am not an attorney. In preparing and expressing my opinions and
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`considering the subject matter of the ‘608 patent, I am relying on certain basic legal
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`principles that counsel have explained to me. These principles are discussed below.
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`22.
`
`I understand that prior art to the ‘608 patent includes patents and printed
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`publications in the relevant art that predate the priority date of the alleged invention
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`recited in the ‘608 patent.
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`23.
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`I have been informed that a claimed invention is unpatentable under 35
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`U.S.C. § 103 if the differences between the invention and the prior art are such that
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`the subject matter as a whole would have been obvious at the time the invention was
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`made to a person having ordinary skill in the art to which the subject matter pertains.
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`I have also been informed by counsel that the obviousness analysis takes into
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`account factual inquiries including the level of ordinary skill in the art, the scope and
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`content of the prior art, and the differences between the prior art and the claimed
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`subject matter.
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`24.
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`I have been informed by counsel that the Supreme Court has recognized
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`several rationales for combining references or modifying a reference to show
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`obviousness of claimed subject matter. Some of these rationales include the
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`following: (a) combining prior art elements according to known methods to yield
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`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
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`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a reasonable
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`expectation of success; and (f) some teaching, suggestion, or motivation in the prior
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`art that would have led one of ordinary skill to modify the prior art reference or to
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`combine prior art reference teachings to arrive at the claimed invention.
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`V. OVERVIEW OF THE ‘608 PATENT
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`25. The ‘608 patent issued on January 12, 2021. ‘608 patent, codes (45), (10).
`
`The background of the ‘608 patent explains that the concept of payment on a
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`machine, or a “payment accepting unit,” has been around for “thousands of years.”
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`‘608 patent at 1:32-35. By the time the ‘608 patent application was filed, the concept
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`of payment on machines was well known and used in commercial applications such
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`as “vending machines,” “parking meters, toll booths, laundromat washers and
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`dryers, arcade games, kiosks, photo booths, toll booths, [and] transit ticket
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`dispensing machines.” ‘608 patent at 1:41-52.
`
`26. The ‘608 patent describes retrofitting an offline-payment operated
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`machine—such as the payment machines described above—with a payment module
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`to facilitate electronic transactions. ‘608 patent at Abstract; 9:16-27; 39:38-46:5;
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`Figs. 28A-B, 29A-B, 30. Figure 28A of the ‘608 patent is illustrative:
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`27. Figure 28A illustrates a block diagram of the offline-payment operated
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`machine 1500. ‘608 patent at 39:38-48. “[T]he offline-payment operated machine
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`1500 (e.g., a form of the machine 120) is an electro-mechanical machine capable of
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`accepting currency (e.g., coins), which is not connected to any networks (e.g.,
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`telephone, cellular, or Wi-Fi). ‘608 patent at 39:40-44. The offline-payment operated
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`machine includes, among other components, a coin microswitch 1502 and a control
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`unit 1506. ‘608 patent at 39:49-56. Microswitch 1502 includes a lever 1504 in the
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`coin slot of the offline-payment operated machine. ‘608 patent at 39:57-65. When a
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`coin enters the coin slot, lever 1504 is depressed, closing the microswitch 1502 and
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`sending a pulse to control unit 1506. ‘608 patent at 39:61-40:6. “[W]hen the control
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`unit 1506 receives a preset sequence of payment acceptance signals indicative of a
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`preset number of coins being received by the microswitch 1502, the control unit
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`1506 initiates the operation of the offline-payment operated machine 1500.” ‘608
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`patent at 40:7-11.
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`28. The offline-payment operated machine is retrofitted with a payment
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`module 1520 and functions to “accept electronic payments.” ‘608 patent at 40:22-
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`26. In certain embodiments, payment module 1520 has a first interface module 1522
`
`configured to output to control unit 1506 one or more electrical pulses emulating
`
`analog signals generated by a coin receiving microswitch 1502 when coins of a
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`predetermined value pass through. ‘608 patent at 40:35-49. When the control unit
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`1506 receives a certain number of pulses it may initiate operation of the offline-
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`payment operated machine. ‘608 patent at 40:35-49. The payment module 1520
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`further includes a short-range communication capability corresponding to a short-
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`range protocol, where the payment module is configured to communicate with one
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`or more mobile device that is also equipped with short-range communication
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`capability. ‘608 patent at 4:14-20.
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`29. However, as explained in further detail below, the purported benefits of the
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`‘608 patent and each of the features and functionalities described above was not
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`novel and, in fact, was previously known in the art before the priority date of the
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`‘608 patent. These features and functionalities were disclosed by the Laaroussi,
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`LeMay, Sugimoto, and Okuniewicz references.
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`VI. CLAIM CONSTRUCTION
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`30.
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`It is my understanding that in order to properly evaluate the ‘608 patent, the
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`terms of the claims must first be interpreted. It is my understanding that for the
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`purposes of this inter partes review, the claims are to be construed under the so-
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`called Phillips standard, under which claim terms are given their ordinary and
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`customary meaning as would be understood by one of ordinary skill in the art in light
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`of the specification and prosecution history, unless the inventor has set forth a special
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`meaning for a term. For the purposes of my analysis below, I do not believe any
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`claim terms require explicit construction.
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`VII.
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`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
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`31.
`
`I have been asked to provide my opinion as to whether the Challenged
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`Claims of the ‘608 patent would have been obvious in view of the prior art. The
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`discussion below provides a detailed analysis of how the prior art references
`
`identified below teach the limitations of the Challenged Claims of the ‘608 patent.
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`32. As part of my analysis, I have considered the scope and content of the prior
`
`art and any differences between the alleged invention and the prior art. I describe in
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`detail below the scope and content of the prior art, as well as any differences between
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`the alleged invention and the prior art, on an element-by-element basis for each
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`Challenged Claims of the ‘608 patent.
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`33. As described in detail below, the alleged invention of the Challenged
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`Claims would have been obvious in view of the teachings of the identified prior art
`
`references as well as the knowledge of a POSITA.
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`A. Summary of References
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`a. Summary of Laaroussi
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`34. U.S. Patent Publication No. 2010/0227671A1 to Laaroussi et al.
`
`(“Laaroussi”) relates to an offline payment-operated machine retrofitted with a
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`payment module configured for wireless communication and coin pulse emulation.
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`Laaroussi discloses “a currency media reader hub adapted to be retrofitted in a
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`gaming machine and to interconnect various existing components thereof.”
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`Laaroussi at [0002]. In certain embodiments, these gaming machines can be “vintage
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`gaming machines” that rely on “older automated systems” that are “built with a
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`primary controller” providing machine intelligence and an “input output controller”
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`adapted to communicate with exterior components. Laaroussi at [0055]. Laaroussi
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`teaches that the “currency media reader hub” is retrofitted to these gaming machines
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`and adapted to (1) connect the currency media reader hub to a “peripheral
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`component” such as a coins receiving module, (2) communicate with “virtual
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`currency holding media” such as RFID-enabled devices, and (3) communicate
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`wirelessly with a network. Laaroussi at Abstract. This arrangement is shown in an
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`annotated version of Figure 3 below:
`
`35.
`
`coins receiving module
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`currency media
`reader hub
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`gaming machine
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`36. The currency media reader hub “comprises a plurality of modules
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`interacting together” to allow numerous functionalities, such as cashless payments.
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`For instance, the currency media reader hub is adapted for cashless transactions with
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`“virtual currency holding media suitable to carry virtual money,” such as an “RFID
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`device” or a “chip-equipped card.” Laaroussi at [0061]. The currency media reader
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`hub has “both reading and writing capability” that allow it to modify data, the
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`amount of money, or other information stored on the virtual currency holding media.
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`Laaroussi at [0061].
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`37. The currency media reader hub is retrofitted between a peripheral
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`component of the gaming machine and the electrical components of the gaming
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`machine such that the currency media reader hub is “adapted to emulate a standard
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`payment acceptance module such as a bill acceptor module or coin acceptor module”
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`and communicate those signals to the gaming machine. Laaroussi at [0010], [0011],
`
`[0017]. Once connected, the currency media reader hub “act[s] as a gateway and a
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`translator between peripherals (bill acceptor, coin acceptor, etc.) and the gaming
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`machine.” Laaroussi at [0024]. When transferring data such as cashless transaction
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`information to the gaming machine, the currency media reader hub “emulates a
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`receiving module” such as a coins receiving module and, through a communication
`
`board module/port, uses “pulse string communication” to transmit that data to the
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`electrical components of the gaming machine. Laaroussi at [0058], [0060].
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`38. The currency media reader hub is further adapted “to store transactions
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`occurring on a gaming machine in a memory when there is no connection with a
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`network.” Laaroussi at [0026]. In particular, the currency media reader hub includes
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`a “memory module” where it can store “all transactions” between the virtual
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`currency media and the gaming machine. Laaroussi at [0026], [0063], [0067], Fig.
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`4.
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`b. Summary of LeMay
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`39. U.S. Patent No. 10,121,318 to LeMay et al. (“LeMay”) relates to a “gaming
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`system compatible with patron-controlled portable electronic devices, such as smart
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`phones or tablet computers.” LeMay at Abstract. The electronic gaming machine of
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`LeMay may include a “retrofit device” that communicates with a portable electronic
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`device (e.g. mobile device) using a wireless
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`interface and short-range
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`communication protocols such as Bluetooth and near-field communication (“NFC”).
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`LeMay at Abstract, 6:34-7:6, 22:64-23:11, Fig. 3A.
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`40. LeMay explains that the “wireless interface 18 can be configured to receive
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`information, such as information associated with a virtual ticket voucher, from a
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`portable electronic device” using short-range communication protocols such as the
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`NFC protocol. LeMay at 6:34-50. The “[w]ireless interface 18 can be also used to
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`accept information from a digital wallet application, such [as] an E-wallet
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`application,” which may be “linked to a bank account” and “used to transfer ‘cash’
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`electronically to an [electronic gaming machine] that can be used for wagers.”
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`LeMay at 6:51-62. The electronic gaming machine with the wireless interface
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`configured to communicate with a portable electronic device is illustrated in
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`annotated Figure 1 below:
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`41. With respect to the “retrofit device,” LeMay explains that it “can be coupled
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`to an existing [electronic gaming machine] 2 that doesn’t provide virtual ticket
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`voucher functionality to allow it to perform” these functions—i.e. to an offline
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`gaming machine to allow it to perform virtual ticketing functions. LeMay at 22:64-
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`23:11. The retrofit device can be configured to perform the virtual ticket voucher
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`and E-wallet processing and wireless interface control. LeMay at 23:43-52, 26:47-
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`65. Furthermore, the retrofit device can be configured to perform “device emulation”
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`to respond to the controller 50 of the electronic gaming machine “as if it were another
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`device on the [machine]” such as a bill validator. LeMay at 24:14-27.
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`42. LeMay also teaches that operation information (e.g., a voucher ticket,
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`validation number, and/or amount) is sent to the mobile device via the short-range
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`wireless transceiver in response to the initial wireless request. LeMay at 4:53-5:4,
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`9:33-45, 10:27-40, 11:20-24, 15:52-56, 38:58-39:11. The retrofit device
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`configuration in the electronic gaming machine (“EGM 2”) with a game controller
`
`50 is illustrated in annotated Figure 3A below:
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`
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`c. Summary of Sugimoto
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`43. U.S. Patent No. 4,374,557 to Sugimoto et al. (“Sugimoto”) relates to
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`vending machine circuitry and, in particular, the mechanical and electrical signals
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`transmitted between coin switches and machine controller circuitry. Sugimoto
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`discloses a coin changer for a vending machine comprising a coin changer main part
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`and an electronic type coin discrimination device. Sugimoto at Abstract. The coin
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`changer main part of Sugimoto “comprises coin switches for detecting coins of
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`respective denominations” with a receiving device for “receiving the coins which
`
`have passed through the coin switches.” Sugimoto at Abstract.
`
`44. Sugimoto explains that the coin changer first sorts out coins by
`
`denomination, and then transfers the coins to the main part of the coin changer
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`through passages 23A, 23B, and 23C. Sugimoto at 4:13-33. “Coin switches 24A,
`
`24B, and 24C are provided in these passages 23A, 23B and 23C.” Sugimoto at 4:13-
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`33. “Each of the coin switches 24A, 24B and 24C is actuated in response to passing
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`of each coin and produces a coin detection pulse corresponding to weight of the coin
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`of each denomination (i.e., amount of the coin).” Sugimoto at 7:30-51.
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`45. Once these analog detection pulses representing a single coin of a
`
`predetermined type are produced through actuation of the coin switches, the pulses
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`“are applied to an up-down counter 37 in which an amount of deposited coins is
`
`counted by cumulatively adding amounts of the deposited coins.” Sugimoto at 5:31-
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`66. A “vend control circuit 38 compares contents of the counter 37 (the amount of
`
`the deposited coins) [obtained by the analog coin pulses generated by the coin
`
`switches] with a preset vend price of the article to be [v]ended and thereupon
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`supplies a vend possible signal to a vender unit” which “dispenses the selected article
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`in response to this vend possible signal.” Sugimoto at 5:31-66. The vend control
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`circuit 38 “also subtracts the price of the vended article from the contents of the
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`counter 37.” Sugimoto at 5:31-66. “A coin return control circuit 39 controls payout
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`of change or returning of the amount of deposited coins upon completion of vending
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`of the selected article.” Sugimoto at 5:31-66. The communications between the coin
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`switches, vend control circuit, and vender unit are summarized in annotated Figures
`
`1 and 2 below:
`
`
`
`
`
`
`
`d. Summary of Okuniewicz
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`46. U.S. Patent No. 6,840,860 to Okuniewicz (“Okuniewicz”) provides “a
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`printing and dispensing bonusing system for electronic gaming devices, particularly
`
`a casino gaming device.” Okuniewicz at Abstract. The electronic gaming machine
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`of Okuniewicz includes an electronic activity detector and command generator that
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`is retrofit to the circuit board of an electronic device (such as a casino gaming
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`device.) Okuniewicz at Abstract, 7:11-28, Fig. 1.
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`47. Okuniewicz explains that “there is a need for an electronic activity detector
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`and command generator which is capable of detecting event occurrences on the
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`circuit board of a gaming device and then issue appropriate demands in response to
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`those event occurrences which will cause connected output devices to perform
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`designated tasks.” Id. at 3:48-53. The electronic activity detector and command
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`generator “will identify that an event is taking place within the machine” and
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`“recognize[] the event and dictate[] the proper response,” which in Okuniewicz
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`includes providing a printing and dispensing bonusing system for electronic gaming
`
`devices (e.g., casino gaming devices.). Okuniewicz at 3:54-59, 5:31-33. The
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`electronic activity detector and command generator (200) is illustrated in annotated
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`Figure 1 below:
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`
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`48. With respect to the retrofit electronic activity detector and command
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`generator, Okuniewicz explains that it “includes a machine interface 202 which
`
`consists of the connection of the programmable electronic activity detector and
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`command generator 200 to the circuit board 300 of an electronic device,” for
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`instance, a slot machine. Okuniewicz at 7:13-24. The machine input/output is either
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`sampled on the circuit board itself or the gaming machine may include a wiring
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`harness for simple connection. Okuniewicz at 7:13-24. In addition to the machine
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`interface 202, the electronic activity detector and command generator includes event
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`detector devices 204a-o (e.g., optical readers, electromagnetic pulse detectors, etc.)
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`that are configured to detect when an event occurs on the machine output lines 201a-
`
`o and signify the occurrence of the event by transferring an event occurrence
`
`notification signal to the data capture segment 206. Okuniewicz at 7:29-46, 11:14-
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`24. The data capture segment 206 receives the event occurrence notification signal
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`and interfaces the signal to the event occurrence information signal computing
`
`device (MCU 240.) Okuniewicz at 7:46-52. Okuniewicz teaches that obtaining the
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`notification from the offline payment-operated machine includes sampling the
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`control signals from the control unit. For instance, data capture device 206 permits
`
`the MCU 240 to sample the incoming data to determine event occurrences on circuit
`
`board 300 of the gaming machine, for instance, by clock pulse synchronization or
`
`multiplexing in which the MCU 240 is programmed to periodically poll each of the
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`input registers to determine if an event has occurred. Okuniewicz at 8:1-10. The
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`MCU “detects that a designated event has occurred in the slot machine by a match
`
`of a selected event occurrence information signal and an event held within the table”
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`and “generates a command signal which is sent to connected output devices.”
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`Okuniewicz at 9:11-15. The command signal is sent via a simple command pulse or
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`device trigger or via a serial interface. Okuniewicz at 8:60-66, 9:15-23.
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`49. Okuniewicz further teaches vending machine functionality for a casino
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`gaming machine, describing that “the system would include a dispensing device
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`which could be a vending device or the like which operative to output bonus items
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`including coin, cash, bonus
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`tickets,
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`lottery
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`tickets, scratch off
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`tickets,
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`complimentaries, promotional materials, and other such bonus awards” or other
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`bonusin
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