UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`KIOSOFT TECHNOLOGIES LLC
`
`and
`
`TECHTREX, INC.
`
`Petitioners
`
`v.
`
`PAYRANGE, INC.
`Patent Owner
`
`Patent 11,074,580
`
`DECLARATION OF GERALD SMITH IN SUPPORT OF PETITION FOR
`POST-GRANT REVIEW OF U.S. PATENT NO. 11,074,580
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Kiosoft LLC EX1003
`U.S. Patent No. 11,074,580
`
`Petitioners Kiosoft Technologies, LLC, et al.
`Exhibit 1003
`Page 1
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`

`

`TABLE OF CONTENTS
`Introduction ....................................................................................................... 3
`I.
`II. Summary of My Opinions ................................................................................ 3
`III. Qualifications and Experience ........................................................................ 4
`IV. Materials Considered .................................................................................... 8
`V. Relevant Legal Standards................................................................................. 9
`Level of Ordinary Skill ........................................................................................... 9
`Claim Construction ............................................................................................... 10
`Written Description and Enablement ................................................................ 11
`Indefiniteness .................................................................................................... 11
`Anticipation ....................................................................................................... 12
`Obviousness ...................................................................................................... 12
`VI. Technology Background ............................................................................. 14
`VII. Overview of the ’580 Patent ........................................................................ 22
`VIII. Overview of the Prior Art ........................................................................... 28
`A. WIPO Publication No. WO2014093857 to Anderson (EX1005) .............. 28
`B. U.S. Publication No. 2017/0193508 to Patel (EX1007) ............................ 34
`C. U.S. Patent No. 8,596,529 to Kolls (EX1016) ............................................. 36
`IX. Application of the Prior Art to the Claims ................................................ 44
`A. Claims 1 to 17 Are Anticipated By Anderson (EX1005) in view of the MDB
`Protocol (EX1006) (Ground 1) ............................................................................. 44
`1. Where Each Element is Found in the Prior Art ......................................... 49
`B. Claims 1 to 17 Are Obvious Based on Anderson (EX1005) in view of Kolls
`(EX1016) and The ’508 Publication (EX1007) )(Ground 2) .............................105
`1. Reason to Combine Anderson in view of Kolls .......................................105
`2. Reason to Combine Anderson and Kolls in view of The ’508 publication
`
`107
`3. Where Each Element is Found in the Prior Art .......................................109
`
`
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`Exhibit 1003
`Page 2
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`Post-Grant Review of U.S. Patent No. 11,074,580
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`X. Ground (4): Claims of the ’580 Are Indefinite ...........................................167
`A. The Limitation “Validating The Request, Wherein Validation Of The Request
`Indicates That The Mobile Device Is Authorized, By A Remote Server, To
`Access The Signals Generated By The First Peripheral Device” Is Indefinite
`(Claims 1-17) ......................................................................................................167
`B. The Limitations “Registering The Electronic Device As A Slave To The
`Machine Controller” And “Registering The First Peripheral Device As A Slave
`To The Electronic Device” Are Indefinite (Claims 1-17) ..................................173
`XII. Other Evidence Relevant to Obviousness ..................................................174
`
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`ii
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`Petitioners Kiosoft Technologies, LLC, et al.
`Exhibit 1003
`Page 3
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`Post-Grant Review of U.S. Patent No. 11,074,580
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`
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`I, GERALD SMITH, declare as follows:
`
`I.
`
`
`Introduction
`I have been asked by KioSoft Technologies LLC and TechTrex, Inc.
`
`(“Petitioners” and, collectively, “KioSoft”) to provide my opinions in the above-
`
`captioned post-grant review proceeding involving U.S. Patent No. 11,074,580
`
`(“the ’580 patent,” EX1001), which is titled “Device And Method For Providing
`
`External Access To Multi-Drop Bus Peripheral Devices.”
`
`
`
`I am being compensated at the rate of $450 per hour for the time I spend in
`
`connection with the proceeding. My compensation is not dependent in any way on
`
`the substance of my opinions or on the outcome of this proceeding.
`
`II.
`
`
`Summary of My Opinions
`To assist and orient the reader in reviewing this declaration, I have
`
`provided a summary of my main opinion below. Claims 1 to 17 (the “challenged
`
`claims”) are anticipated by the prior art. Also, a person of ordinary skill in the art
`
`(“POSITA”) at the time of the alleged invention would have found the subject
`
`matter of claims 1 to 17 obvious in view of the prior art. Additionally, a POSITA
`
`would not have found certain elements of the claims to be enabled by the written
`
`description of the ’580 patent as of its filing date. A POSITA would have found
`
`other elements of the claims to have been indefinite as of the ’580 patent’s filing
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`date.
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`3
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`Petitioners Kiosoft Technologies, LLC, et al.
`Exhibit 1003
`Page 4
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`Post-Grant Review of U.S. Patent No. 11,074,580
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`The specific grounds of unpatentability that I refer to are identified below:
`
`
`
`Challenge
`Ground Statute(s)
`§102(a)(1) Anticipation by WO 2014093857
`1
`(“Anderson,” EX1005)
`Obviousness by Anderson in view of U.S.
`8,596,529 (“Kolls,” EX1016) and U.S.
`2017/0193508 (“’508 publication,”
`EX1007)
`Non-statutory subject matter
`
`§103
`
`§101
`
`2
`
`3
`
`4
`
`§112(b)
`
`Indefiniteness
`
`Challenged
`Claim(s)
`1-17
`
`1-17
`
`1-17
`
`1-17
`
`
`III. Qualifications and Experience
`
`A copy of my curriculum vitae is provided as Exhibit 1004.
`
`
`
`I obtained a Bachelor of Science in Electrical Engineering from Rose-
`
`Hulman Institute of Technology in 1978 and continued post graduate studies at
`
`Rutgers University from 1978 to 1983 in Electronics Engineering and Computer
`
`Science.
`
`
`
`I am the founder of Generic Smart Cards LLC. I founded this company in
`
`2012. I have worked extensively with smart cards, terminals, and transaction
`
`solutions since 1983. I have worked in a wide range of technologies relating to
`
`smart cards, including, but not limited to, silicon, operating systems, card
`
`applications, packaging, printing technologies, edge interfaces, terminals, and host
`
`system applications.
`
`4
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`Page 5
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`For the past 20 years, I have focused on security and identity attributes of
`
`
`
`smart cards and smart card enabled solutions. I have served as an International
`
`Standards Organization (ISO) project editor and as a contributor to a number of
`
`major smart card standards, including, and not limited to, ISO/IEC 7816, ISO/IEC
`
`14443, ISO/IEC 24727, FIPS 201, and FIPS 140. I have actively participated in
`
`the Java Card Forum, PC/SC implementations, MULTOS smart card O/S
`
`application development, and Microsoft Windows Smart Card O/S evaluations. In
`
`addition, I have in-depth knowledge and experience with proprietary O/S smart
`
`card implementations, including but not limited to ORGA Micardo, Siemens
`
`CardOS, Schlumberger MultiFlex, Gemplus MPCOS, and G&D StarCOS.
`
`
`
`From 1978 to 1983, I was an Officer in the United States Army Signal
`
`Corps attached to the Communications Electronics Command at Fort Monmouth,
`
`New Jersey. The Signal Corps is a division of the U.S. Army that develops, tests,
`
`provides, and manages communications and information systems support for the
`
`command and control of combined armed forces. In the Signal Corps, I actively
`
`participated in the research and development of software intensive terminals and
`
`peripherals encompassing device mechanisms, microprocessor technologies
`
`(HW/SW) and system integration. I was part of a high level research team
`
`exploring distributed processing configurations. I achieved the rank of Captain
`
`prior to leaving the U.S. Army for private industry.
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`5
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`Exhibit 1003
`Page 6
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`In 1983, I began work as a technologist at Mars Electronics International, a
`
`
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`company directed to unattended payment systems. I was promoted to product line
`
`manager for all of the company’s North American coin mechanisms, the core
`
`product for the business at that time.
`
`
`
`From 1989-1993, I was employed at VeriFone where I served as the
`
`Director of Engineering in a unit that developed food service and vending industry
`
`applications implemented through computer software and hardware. During this
`
`time at VeriFone, I worked on development of the Valu-CardTM Stored Value card
`
`system to complement the company’s Point-of-sales (POS) business.
`
`
`
`From 1993-1995, I was employed at Schlumberger where I competed for,
`
`obtained, and developed technology business relating to smart card pilot projects
`
`for VISA and smart card applications for MasterCard.
`
`
`
`From 1995-1996, I worked at Zenith Data Systems / Groupe BULL as a
`
`technical manager for Smart Card Technology and Internet Commerce.
`
`
`
`From 1996-1999, I served as Director of New Business Development for
`
`ORGA Card Systems Inc., where I was responsible for managing the company’s
`
`Americas region and coordinating with international business units in Germany,
`
`Latin America, and the Far East. In this position, I worked as Project Leader on
`
`the MasterCard Smart Card Access project using the MULTOS platform for secure
`
`card transactions. In 1999, I joined American Express as a Development Leader
`
`6
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`Exhibit 1003
`Page 7
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`for the “Blue from American Express” Smart Card product development initiative.
`
`In that position, I served as Advanced Card Technology leader on IP Management,
`
`chip card specifications, security models using smart cards, and external standards.
`
`I was promoted to Vice President in 2001. Among other duties at American
`
`Express, I served as Product Manager, Business and Technical Architect of the
`
`“Summer Concerts in Blue” product launch (summer of 2000), served as a Board
`
`Member of the Global Platform governance body from 2000-2002, was a
`
`contributing member to GlobalPlatform Card and Card Management System
`
`specification, was a JavaCard Forum representative, and a technical representative
`
`to ISO/IEC JTC1 SC17 International Standard body including contact card,
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`contactless card, and test methods.
`
`
`
`From 2003-2007, I worked at SHARP Microelectronics of the Americas, a
`
`world leader in LCD, Integrated Circuits, RF, Imaging, and Optoelectronics
`
`technology, where I served as the Senior Smart Card Business Development
`
`Manager / Senior Field Technical Manager. Among other duties, I served as a
`
`subject matter expert in the area of Smart Card technologies working as a
`
`development leader for integration of smart card technology into identity, payment,
`
`and telecommunication solutions.
`
`
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`Since 2007, I have been employed with ID Technology Partners as a
`
`subject matter expert for a diverse range of engagements related to smart cards,
`
`7
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`Page 8
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`biometrics and other high assurance identification verification initiatives and
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`technologies. My projects have included government and non-government
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`credentialing programs as well as one-off enterprise solutions.
`
`IV. Materials Considered
`
`In formulating my opinions, I have relied upon my training, knowledge,
`
`and experience that are relevant to the ’580 patent. I have specifically considered
`
`the following documents, in addition to all other documents cited in this
`
`declaration:
`
`
`
`Exhibit Description
`
`1001 U.S. Patent No. 11,074,580 to Patel et al. (“the ’580 patent”)
`
`1002 Prosecution History of the ’580 patent
`
`1005 PCT International Publication No. WO 2014/093857 (“Anderson”)
`1006 Multi-Drop Bus / Internal Communication Protocol, version 4.2,
`National Automatic Merchandising Association, February, 2011
`(“MDB/ICP”)
`1007 U.S. Publication No. 2017/0193508 (“’508 publication”)
`
`1008 U.S. Publication No. 2007/0083287 (“Defosse”)
`
`1009 U.S. Publication No. 2007/0095901 (“Illingworth”)
`
`1010 U.S. Publication No. 2009/0303982 (“Blachman”)
`
`1011 U.S. Publication No. 2007/0119680 (“Saltsov”)
`
`1013 U.S. Patent No. 9,092,768 (“Breitenbach”)
`
`8
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`Exhibit 1003
`Page 9
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`Post-Grant Review of U.S. Patent No. 11,074,580
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`1014 U.S. Patent No. 8,157,167 (“Cost”)
`
`1015 U.S. Patent No. 6,390,269 (“Billington”)
`
`1016 U.S. Patent No. 8,596,529 (“Kolls”)
`
`
`V. Relevant Legal Standards
`
`I am not a lawyer. In forming my opinions, I have relied upon various
`
`legal principles, as explained to me by Petitioners’ counsel. My understanding of
`
`these principles is summarized below.
`
`
`
`I understand that a patent claim defines the scope of an alleged invention. I
`
`further understand that a claimed invention must be new, useful, and non-obvious
`
`over the prior art as of its earliest filing date for it to be patentable. I understand
`
`that in this proceeding, Petitioners have the burden of proving that it is more likely
`
`than not that at least one of the challenged claims would have been unpatentable
`
`over the prior art.
`
`
`
`In determining the patentability of a claim, I understand that the first step is
`
`to understand the claim from the perspective of a POSITA to determine its
`
`meaning and scope. With that understanding, I have considered the claims at issue
`
`against the prior art from the perspective of a POSITA, as further summarized
`
`below.
`
`Level of Ordinary Skill
`
`9
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`Petitioners Kiosoft Technologies, LLC, et al.
`Exhibit 1003
`Page 10
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`Post-Grant Review of U.S. Patent No. 11,074,580
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`A POSITA at the time of the earliest claimed filing date of the ’580 patent
`
`
`
`would have a Bachelor of Science in Electrical Engineering, Computer Science, or
`
`another degree related to electromechanical systems, as well as at least 3 years of
`
`academic or industry experience in electronic payment systems.
`
`Claim Construction
`
`I have been informed by Petitioners’ counsel that in this proceeding, the
`
`United States Patent and Trademark Office (“PTO”) interprets the claims of an
`
`unexpired patent, such as the ’580 patent, under the same standards used in a
`
`United States District Court. This includes interpreting the claims through the lens
`
`of a POSITA in view of the entire patent. Accordingly, in formulating my
`
`opinions, I reviewed the claims of the ’580 patent as I perceive a POSITA would
`
`have understood them at the time of the earliest claimed priority date of the ’580
`
`patent, after reading the entire ’580 patent specification. As described below, I
`
`believe that the earliest possible effective filing date for the challenged claims is
`
`July 21, 2020 —the date that the claims and embodiments depicted in FIGS. 26 to
`
`35 were added.
`
`
`
`Finally, I have been informed that claim construction is ultimately a
`
`question of law. Accordingly, I understand that a tribunal may choose to construe
`
`certain terms to provide clarity to the proceeding should any dispute arise between
`
`the parties over how a term should be construed. If the tribunal chooses to
`
`10
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`Exhibit 1003
`Page 11
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`construe any term, then I reserve my right to review and potentially modify any
`
`opinions below in view of such constructions.
`
`Written Description and Enablement
`
`I understand that each claim must be analyzed to determine its effective
`
`priority date by comparing each of its elements to the application from which the
`
`patent issued and/or any alleged priority applications.
`
`
`
`I understand that in order for a claim to claim priority to a previously filed
`
`application, the claim must have written description support in that priority
`
`document, and the written description needs to have been carried over into the
`
`application in which the claim appears.
`
`
`
`I understand that claims are required to be supported by a written
`
`description in the specification that must reasonably convey to a person of ordinary
`
`skill in the art that the inventor had possession of the claimed subject matter as of
`
`the filing date.
`
`
`
`I also understand that the supporting disclosure of an application must be
`
`sufficient to inform a person of ordinary skill in the art that the inventor how to
`
`both make and use the claimed invention, without undue or unreasonable
`
`experimentation.
`
`Indefiniteness
`
`11
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`Petitioners Kiosoft Technologies, LLC, et al.
`Exhibit 1003
`Page 12
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`I understand that a claim is indefinite if it fails to inform, with reasonable
`
`
`
`certainty, a POSITA about the scope of the invention. Moreover, I also understand
`
`that claims must particularly and distinctly set out what is claimed so that the
`
`public has fair notice of the claimed invention. For example, if the language of a
`
`claim may be read and understood in more than one way by a POSITA, then that
`
`claim is indefinite. I understand that the claim must be read in light of the
`
`disclosure of the application, the teachings of the prior art, and the knowledge of a
`
`POSITA at the time of the invention of the claim. Further, I understand that each
`
`term in a claim must find clear support or antecedent basis in the specification.
`
`Anticipation
`
`I have been informed by Petitioners’ counsel that a patent claim is
`
`unpatentable if every element is actually disclosed in a prior art reference as recited
`
`in the claims. The disclosure may be explicit, implicit, or inherent. I understand
`
`that a reference is read from the perspective of a POSITA at the time of the
`
`invention.
`
`Obviousness
`
`I understand that an obviousness analysis involves properly construing a
`
`patent claim and then comparing that claim to the prior art to determine whether
`
`the claimed invention would have been obvious to a POSITA in view of the prior
`
`art and in light of the general knowledge in the art.
`
`12
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`Page 13
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`I also understand that obviousness can be established by combining or
`
`
`
`modifying the teachings of the prior art to achieve the claimed invention. I
`
`understand that the reason to combine prior art references must be shown. This
`
`reason to combine can come from a variety of sources, not just the prior art itself or
`
`the specific problem the patentee was trying to solve. And I understand that the
`
`references themselves need not provide a specific hint or suggestion of the alteration
`
`needed to arrive at the claimed invention; the analysis may include recourse to logic,
`
`judgment, and common sense available to a POSITA that does not necessarily
`
`require explanation in any reference. It is also my understanding that where there is
`
`a reason to modify or combine the prior art to achieve the claimed invention, there
`
`must also be a reasonable expectation of success in so doing.
`
`
`
`I understand that a combination of familiar elements according to known
`
`methods is likely to be obvious when it does no more than yield predictable results. I
`
`understand that when there is a design need or market pressure to solve a problem
`
`and there are a finite number of identified, predictable solutions, a skilled person has
`
`good reason to pursue the known options within his or her technical grasp. If this
`
`leads to the anticipated outcome, then that outcome is likely a product not of
`
`innovation, but of ordinary skill and common sense, and therefore is considered
`
`obvious according to patent laws.
`
`13
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`Page 14
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`I understand that when a skilled person would have reached the claimed
`
`
`
`invention through routine optimization, the invention may be deemed obvious. I
`
`also understand that such routine optimization involves testing an element or
`
`parameter that is termed a “results-effective” variable (that is, a variable that
`
`achieves a recognized result). And I understand that routine optimization involves
`
`using only routine techniques and ordinary skill of one in the relevant art.
`
`
`
`I understand that courts have held that when there is a “design need” or
`
`“market demand” and there are a “finite number” of solutions, it would have been
`
`obvious for a person of ordinary skill in the art to try such solutions. When the
`
`general conditions of a claim are disclosed in the prior art, it is not inventive to
`
`discover the optimum or workable ranges by routine experimentation.
`
`
`
`I understand that when considering the obviousness of an invention, one
`
`should also consider whether there are any objective indicia (also known as
`
`secondary considerations) that support the non-obviousness of the invention. I
`
`understand that objective indicia of non-obviousness include commercial success,
`
`long-felt but unmet need, failure of others, praise in the industry, and unexpected
`
`superior results. I am not aware of any objective indicia that would change my
`
`opinion regarding the claims of the ’580 patent.
`
`VI. Technology Background
`
`14
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`Exhibit 1003
`Page 15
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`Conventional, electronic vending machines typically contain a
`
`
`
`microprocessor-based control system called a “vending machine controller” (or
`
`“VMC”). Such systems are used to control, monitor and record detailed
`
`information about the state of an associated vending machine including, for
`
`example, sales, cash received and paid out, errors, events, temperatures, inventory
`
`change, lock and unlock. EX1010, ¶2. The VMC may also control, monitor and
`
`record information from peripheral devices associated with functions such as coin
`
`acceptance, change giving, displays, credit cards and wireless transactions. Id.
`
`The Multi-Drop Bus/Internal Communication Protocol (the “MDB protocol”),
`
`maintained by the National Automatic Marketing Association (NAMA), is an
`
`interface standard used for collecting, recording, transmitting and auditing data
`
`associated with vending machines. Id. The MDB protocol determines the way in
`
`which the VMC learns what coins were accepted by a coin mechanism peripheral,
`
`what bills were accepted by a bill validator peripheral, and how much credit is
`
`available through a card reader peripheral. It is a way for the VMC to “tell” the
`
`coin mechanism how much change to pay out or to “tell” the card reader how
`
`much credit to return to the card.
`
`
`
`Unlike many shared bus protocols, the MDB protocol defines the VMC as
`
`the one and only master of the MDB and all other electronic peripheral devices as
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`slaves. EX1006, §1.2. The VMC is able to communication with up to 32
`
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`peripheral devices, with each peripheral device assigned a unique address and
`
`command set. Id. The VMC “polls” the MDB bus, asking each peripheral for
`
`activity, to which the peripherals respond with an acknowledgement (ACK),
`
`negative acknowledgement (NAK), or specific data, depending on its current
`
`activity. If a peripheral does not respond in a predetermined time, the VMC
`
`assumes the device is not on the bus. A purpose for the polling configuration is
`
`that it prevents bus interference, or “crashes,” because each peripheral only
`
`responds upon being polled. Id. The VMC resets all peripherals by pulling the
`
`transmit line “active” for a minimum of 100 mS. The protocol recommends that
`
`the VMC re-initialize each peripheral after this type of reset. Id. However,
`
`because any of the peripherals might go offline or otherwise not respond to polling
`
`on the MDB bus, it is necessary for the VMC to initialize and register each
`
`peripheral after a reset.
`
`
`
`The VMC and each peripheral device has a unique address. Id., §§2.2, 2.3.
`
`The VMC can address packets to any of the peripheral devices, but the peripheral
`
`devices cannot communicate with each other. Instead, the peripheral devices can
`
`only address packets to the VMC in response to receiving a packet from the VMC.
`
`A packet is 36 bytes, including an address byte, optional data bytes, and a
`
`checksum (CHK) byte. Id., §2.2. The packet can carry up to eight instructions in
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`the first byte. The VMC will respond to data from a peripheral with an ACK,
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`NAK, or Retransmit (RET). Similarly, the packet transmitted by the peripherals to
`
`the VMC consist of up to 36 bytes, including an address, data (ACK or NAK), and
`
`a CHK byte. Id.
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`
`
`The MDB protocol also provides for a File Transport Layer (FTL) that
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`allows the VMC to function as a network manager for all FTL data transfers, and
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`to drive the MDB/ICP interface to exchange high-level information between the
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`VMC and peripherals. Id., §2.6.
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`Since the MDB protocol establishes the manner by which each
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`component device communicates with the VMC, the connection to each device is
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`identical. Every device has basically two MDB connectors to allow it to both
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`connect to the MDB bus in the machine and provide a connection for another
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`device. EX1009, ¶67. The MDB protocol was written to allow for extensions of
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`the protocol to accommodate additional features of peripheral devices which were
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`not known at the time of drafting of the protocol. EX1011, ¶16. With the
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`intentional adaptability built into the MDB protocol, it was commonplace to add
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`electronic devices as intermediate controllers in a broad range of retrofits of
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`conventional MDB-based vending machines, by connecting the device between the
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`VMC and peripheral devices, as shown, for example, in EX1011, FIG. 2
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`(reproduced below), wherein the electronic device is denoted as 32.
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`FIG. 3 (reproduced below) in EX1011 demonstrates the common
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`approach that was implemented with vending machines to add new functionalities
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`or new, previously unsupported (by the VMC) peripheral devices 30. As seen
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`below, the slave interface of the electronic device 32 was connected to the MDB
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`bus and set to communicate with the VMC 4, and the master (or host) interface
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`was connected to the peripheral devices 10, 30, which are decoupled from the
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`MDB of the machine.
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`The retrofit device was typically connected between the VMC and
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`peripheral devices to expand audit functionalities, such as, for example, in Defosse,
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`which discloses a vending machine 12 configured with an audit device 18, cashless
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`reader peripheral 30, and a transceiver to interact with a mobile device 14 over a
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`direct wireless connection 40 to exchange data. EX1008, ¶¶18, 22, FIG. 1
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`(reproduced below). The audit device 18 is connected between the VMC 24 and
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`peripheral devices 30, 32 via an MDB interface (id., ¶37), and configured to
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`operate as a “slave” with respect to the VMC 24 and the mobile device 14 (id.,
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`¶35), and as a “master” with respect to the peripheral devices, as depicted in FIG.
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`1.
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`Page 20
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`Breitenbach (EX1013) is yet another example of a conventional electronic
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`device that can be “added to a standard machine (e.g., as a post-production and/or
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`after-market addon) to add to and/or alter functionality thereof—e.g., an ‘after-
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`market’ retrofit device.” EX1013, 2:58-63. Like many of the VMC retrofit
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`devices that were well-known, Breitenbach discloses a plug-and-play retrofit
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`device (120/320/420/520/720) that can be readily installed into standard MDB
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`protocol-based vending machines. See, e.g., id., FIGS. 1, 3-5, 7. The expansion of
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`functionalities includes providing for direct communication between a customer’s
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`Page 21
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`smartphone and the machine’s components/functionalities via the retrofit device.
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`Id., 4:58-64, 6:65-7:14, 18:16-22.
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`As shown in the embodiment depicted in FIG. 1 (reproduced below), the
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`retrofit device 120 can be installed and connected between the VMC 110 and the
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`peripheral devices 112 (input device) and 116 (communication device) to alter or
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`expand functionalities of the VMC 110. The retrofit device can be connected as a
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`slave to the VMC in the machine 108 by means of MDB connectors to, for
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`example, emulate a payment peripheral device. Id., 11:6-10, 14:41-45. The
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`retrofit device also operates as a master to the connected peripheral devices,
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`communicating with the peripherals according to the MDB protocol. Id., 14:20-23,
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`14:60-15:2. As depicted by the broken lines in FIG. 1 below, the input device 112
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`and communication device 116 peripherals can be decoupled from the MDB of the
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`machine.
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`Page 22
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`Breitenbach’s retrofit device (120/320/420/520/720) can include a
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`wireless transceiver (460/760) that communicates with customer mobile devices
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`(104/704) using NFC, infrared (IR), Bluetooth and/or WiFi. Id., 18:15-23. The
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`retrofit device (120/320/420/520/720) includes an electronic processing device
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`(374/474/574/910), an MDB connector 350, a USB connector 370, and non-
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`transitory memory containing instructions to operate the retrofit device according
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`to the MDB protocol, among others. Id., 15:31-40, 11:6-10, 11:52-54, 12:1-14.
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`VII. Overview of the ’580 Patent
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`The ’580 Patent is titled “Device And Method For Providing External
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`Access To Multi-Drop Bus Peripheral Devices” and relates to “mobile-device-to-
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`machine payment processing systems over a non-persistent network.” EX1001,
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`1:30-21.
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`The ’580 patent describes that a device with processor(s), memory, a slave
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`interface, and host interface(s) performs as a virtual peripheral by registering itself
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`as a slave to the machine controller coupled with the slave interface and performs
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`as a virtual machine controller by registering peripheral(s) coupled with the host
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`interface(s) as slaves to the device. The device receives a command from the
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`machine controller via the slave interface and, in response to receiving the
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`command: sends an acknowledgement to the machine controller via the slave
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`interface; and relays the command to a respective peripheral via a respective one of
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`the host interface(s), where the device sends signals to and from the machine
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`controller asynchronous of sending signals to and from the peripheral(s). EX1001,
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`Abstract.
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`The ’580 Patent acknowledges that “[v]ending machines (or ‘automatic
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`retailing’ machines), i