PTAB

IPR2017-01449

Masabi Ltd. v. Bytemark, Inc.

Title: Method and System for Distributing Electronic Tickets with Visual Display
Brief Description: The ’967 patent describes a method and server system for visually validating an electronic ticket on a user's device. The system provides a "visual validation display object" for inspection by a ticket taker, which is intended to be more efficient and reliable for human verification than machine-scanning barcodes or QR codes.

Prior Art Relied Upon: Terrell (WO 2009/141614).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Terrell discloses every element of the challenged claims. Terrell described an electronic ticketing method where an "eye-readable" image is displayed on a mobile device for inspection. Petitioner asserted that Terrell's system meets the limitations of independent claims 1, 17, and 18 by teaching a server that receives a validation request from a mobile device (via a "validation button"), processes a token (a "specified unique ticket number"), and transmits back a data file containing a visual object. This object, which can include animated graphics, was argued to be the claimed "visual validation display object." Petitioner further contended that Terrell anticipates the dependent claims by disclosing a "valid to" time (meeting time-lock limitations) and the use of encryption keys for securing ticket data. The animation of graphics in response to user interaction (touching the validation button) was argued to anticipate claim 34.

Prior Art Relied Upon: Cruz (Application # 2004/0030658).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Cruz discloses a complete electronic ticketing system that anticipates the challenged claims. Cruz taught using "optically or visually recognizable patterns," such as a picture, to enhance security, which Petitioner equated with the "visual validation display object." The system operated on a "pull-type" model where a user's device sends a request to a server, which validates it and returns a modular ticket object, allegedly mapping to the process in the independent claims. Petitioner argued that Cruz’s teaching of delaying the transport of ticket data objects for security purposes until closer to the time of use directly anticipates the time-lock limitations of dependent claims 3 and 20. Furthermore, Cruz's disclosure of using Public Key Infrastructure (PKI) for copy protection and authentication was argued to meet the limitations of the encryption-related dependent claims (4-6 and 21-23).

Prior Art Relied Upon: Dutta (Patent 7,315,944).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Dutta anticipates all challenged claims by disclosing a ticket redemption system using a "human-verifiable" Rapid Verification Token (RVT) displayed on a portable device. This RVT, which could be a rotating wineglass image with patterns that change over time, was presented as a clear example of the "visual validation display object." Petitioner argued Dutta's process—where a user's device sends a redemption request to a server that validates the ticket and issues the RVT—directly maps to the limitations of independent claims 1, 17, and 18. Dutta's disclosure that the RVT is valid only for a defined period was argued to anticipate the time-lock limitations. The use of PKI to encrypt the electronic ticket with a public key corresponding to the user's device was argued to anticipate all limitations of the encryption-focused dependent claims. Finally, Dutta's description of the system operating on PDAs with input/output functions, which were known to include touchscreens, was argued to anticipate the animation-on-touch feature of claim 34.

"visual validation display object": Petitioner argued this term, not explicitly defined in the ’967 patent, should be given its broadest reasonable construction. The specification refers to a "validating visual object" and provides examples like "Patterns of color change, Animations and Geometric patterns... video or image data." Petitioner contended that the core criterion provided by the patent owner is that the object is "readily recognizable from human observation." Therefore, Petitioner proposed the construction "any object that is readily recognizable from human observation." This broad construction was central to Petitioner's arguments that the visual patterns and images disclosed in Terrell, Cruz, and Dutta meet this claim limitation.

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 17-23, and 34 of Patent 8,494,967 as unpatentable.