PTAB

IPR2019-00317

William Hill U.S. Holdco, Inc. v. CG Technology Development, LLC

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1. Case Identification

2. Patent Overview

  • Title: Devices for Gaming
  • Brief Description: The ’224 patent describes a gaming computing device that uses a two-tiered verification system to authenticate a patron. The system employs an identification scanner for a government-issued document and a biological sensor for biometric data; upon successful verification, the device offers gaming activities to the patron.

3. Grounds for Unpatentability

Ground 1: Anticipation over Bradford - Claims 2, 5-7, 9-11, and 13-15 are anticipated by Bradford under 35 U.S.C. §102.

  • Prior Art Relied Upon: Bradford (Patent 6,612,928).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bradford, which was not considered during prosecution, discloses every element of the challenged claims. Independent claim 2 recites a gaming device with a processor, memory, an identification acceptor for government IDs, a biological sensor, and a network connector, programmed to perform a two-step verification before offering gaming. Petitioner asserted Bradford teaches a gaming device with a "first authenticator reader" (the claimed identification acceptor) for items like driver's licenses and a "second authenticator reader" (the claimed biological sensor), such as a fingerprint or facial geometry reader. Bradford’s system is disclosed as being networked, instructing the user, obtaining data from both authenticators, verifying the patron against a database, and enabling gameplay upon verification, thus teaching all limitations of claim 2. Petitioner further contended that Bradford explicitly discloses the additional limitations of dependent claims 5-7 and 9-15, such as using a camera for facial recognition (claims 5-6), off-site verification (claims 7 and 11), verification against financial account data (claim 9), on-device processing (claim 10), and use of a remote wagering account (claim 15).
    • Key Aspects: Petitioner's central argument was that the ’224 patent merely reclaims old technology fully disclosed over a decade earlier in Bradford's two-factor authentication system for gaming environments.

Ground 2: Obviousness over Bradford and Parrott - Claims 2, 4-7, and 9-15 are obvious over Bradford in view of Parrott.

  • Prior Art Relied Upon: Bradford (Patent 6,612,928) and Parrott (Application # 2005/0054417).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that to the extent Bradford does not explicitly teach every detail, combining it with Parrott renders the claims obvious. While Bradford discloses a system for reading identification cards, Parrott provides a more specific disclosure of a gaming machine with an integrated scanner for driver's licenses that uses optical character recognition. Parrott also explicitly teaches other common gaming machine peripherals, such as currency acceptors/dispensers and credit/debit card readers, which correspond to limitations in dependent claims.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings because both Bradford and Parrott address the same field of casino gaming systems and solve the same problems of patron identification and funding. A POSITA would have been motivated to integrate Parrott’s well-known and specific hardware implementations (e.g., scanner, card reader) into Bradford's two-factor authentication framework to create a more integrated and functional device, which Petitioner described as a predictable combination of known elements.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining known hardware components like scanners and card readers with a software-based authentication system was a routine and predictable design choice at the time.

Ground 3: Obviousness of Claim 4 over Bradford, Parrott, and Slater

  • Prior Art Relied Upon: Bradford (Patent 6,612,928), Parrott (Application # 2005/0054417), and Slater (Patent 7,792,753).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground specifically addressed the limitations of dependent claim 4, which adds the requirement that the device is programmed to accept funds for a wagering account hosted on off-site computers belonging to "two or more different gaming operators" that are "distinct legal entities." Petitioner argued the combination of Bradford and Parrott teaches accepting funds for a remote wagering account. The Slater patent, which relates to ATM technology, was introduced to supply the missing element. Slater teaches an ATM accepting funds (cash or checks) at one location for deposit into accounts held at multiple, different, and legally distinct banks.
    • Motivation to Combine: A POSITA seeking to improve the electronic funds account (EFA) system taught in Bradford, which itself has noted similarities to ATMs, would have naturally looked to established ATM technology like that in Slater. The motivation would be to achieve significant cost savings and operational efficiency by allowing a single gaming kiosk to accept funds for multiple, distinct casino operators, analogous to how a modern ATM services customers from many different banks.
    • Expectation of Success: A POSITA would have expected success in applying Slater's established principles of networked financial transactions across different entities to the gaming kiosk environment described in Bradford and Parrott.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 2, 4-7, and 9-15 based on Bradford in view of the general knowledge of a POSITA. This ground argued that if Bradford’s features were considered to be in separate embodiments, a POSITA would have found it obvious to combine them to create a single, more efficient device.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 2, 4-7, and 9-15 of the ’224 patent as unpatentable.