PTAB

CBM2018-00025

Apple Inc v. Universal Secure Registry LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Universal Secure Registry
  • Brief Description: The ’813 patent discloses a system for verifying a user's identity before conducting a financial transaction at a point-of-sale (POS) device. The system, centered around a "Universal Secure Registry," uses an electronic ID device to authenticate a user via biometric data and/or secret information (e.g., a PIN), thereby enabling secure access to one of a plurality of associated user accounts.

3. Grounds for Unpatentability

Ground 1: Obviousness over Jakobsson and Maritzen - Claims 1-2, 4-11, 13, 16-20, and 24 are obvious over Jakobsson in view of Maritzen.

  • Prior Art Relied Upon: Jakobsson (International Publication No. WO 2004/051585) and Maritzen (Application # 2004/0236632).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Jakobsson taught the core elements of the claimed electronic ID device, including a user interface for receiving secret information (PIN) and biometric input, a processor, a communication interface, and a remote secure registry ("verifier") for authenticating a user to access financial services. However, Jakobsson did not explicitly disclose selecting from a plurality of accounts. Maritzen was argued to supply this missing element by teaching a personal transaction device that displays a list of multiple user accounts and allows a user to select one for a financial transaction. The combination of Jakobsson's security architecture with Maritzen's multi-account selection feature was asserted to render the claims of this ground obvious.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to improve the user-friendliness and functionality of Jakobsson's secure authentication system. Both references operate in the same field of handheld authentication devices for financial transactions. A POSITA seeking to enhance Jakobsson's device would have looked to solutions like Maritzen's to add the convenient and known feature of managing multiple accounts from a single device.
    • Expectation of Success: The combination would have been a predictable application of a known user interface technique (account selection from a list) to a known secure system. A POSITA would have reasonably expected success in integrating Maritzen’s software-based account management features into Jakobsson's hardware and security framework to yield the claimed invention.

Ground 2: Obviousness over Jakobsson, Maritzen, and Labrou - Claims 14, 15, 22, 23, 25, and 26 are obvious over Jakobsson, Maritzen, and Labrou.

  • Prior Art Relied Upon: Jakobsson (WO 2004/051585), Maritzen (Application # 2004/0236632), and Labrou (Application # 2004/0107170).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Jakobsson and Maritzen by adding Labrou to address dependent claims requiring a user interface configured to display "options for purchase" and accept the "selection of at least one product or service." Petitioner argued that while Jakobsson and Maritzen provided the secure, multi-account transaction framework, Labrou explicitly taught a mobile device with a user interface for browsing and purchasing goods and services. Labrou described a user selecting a service (e.g., purchasing movie tickets), browsing available options, and confirming the transaction, directly teaching the limitations of these claims.
    • Motivation to Combine: A POSITA, having already combined Jakobsson and Maritzen to create a secure multi-account payment system, would be motivated to incorporate Labrou's teachings to further enhance the system's commercial utility. Integrating an e-commerce interface for selecting products and services would be a logical next step to make the secure payment device more versatile and useful for consumers. All three references concern facilitating secure financial transactions with portable devices, providing a strong motivation to combine their respective features.
    • Expectation of Success: Adding a known user interface for purchasing goods (from Labrou) to the secure transaction system (from Jakobsson and Maritzen) was presented as a routine integration task for a POSITA. The combination was argued to be nothing more than the predictable implementation of well-understood e-commerce functionalities on a secure payment platform.

4. Key Claim Construction Positions

  • Secure Registry: Petitioner proposed that this term be construed as "a database with access restrictions." This broad construction was argued to be consistent with the specification and would allow prior art systems, such as Jakobsson’s "verifier," which functions as a secure database for authentication, to meet the claim limitation.
  • Biometric Input: Petitioner proposed this term means "information about a user's physical characteristics, such as fingerprint, voice print...or personal photograph." This construction was argued to be necessary to distinguish biometric information from "secret information" like a PIN, despite one inconsistent passage in the patent’s specification. This distinction was critical to Petitioner's mapping of separate claim elements to the prior art.
  • Point-of-Sale Device: Petitioner argued this term means "a device located at a point of sale capable of transmitting and/or receiving information related to a financial transaction." This construction supported identifying components like Jakobsson’s "communications terminal 140" (e.g., a card reader) as a POS device.

5. Relief Requested

  • Petitioner requested institution of a Covered Business Method review and cancellation of claims 1-2, 4-11, 13-20, and 22-26 of the ’813 patent as unpatentable for obviousness under 35 U.S.C. §103.