Google LLC v. Telcom Ventures LLC

1. Case Identification

• Case #: IPR2025-01349
• Patent #: 11,924,743
• Filed: July 25, 2025
• Petitioner(s): Google LLC
• Patent Owner(s): Telcom Ventures LLC
• Challenged Claims: 1-14

2. Patent Overview

• Title: Systems and Methods for Smartphone-Based Financial Transactions
• Brief Description: The ’743 patent discloses systems for establishing and using a capability at a smartphone to conduct financial transactions. The technology involves a smartphone enabling a transaction function responsive to sensing a parameter and determining that its value satisfies a criterion, and subsequently requesting and receiving authorization to complete the transaction.

3. Grounds for Unpatentability

Ground 1: Obviousness over Barnett, Waters, and White - Claims 1-14 are obvious over Barnett, Waters, and White.

• Prior Art Relied Upon: Barnett (Application # 2009/0170483), Waters (WO 2006/087503), and White (Patent 7,434,723).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Barnett taught a foundational system where an NFC-enabled smartphone conducts in-store financial transactions at a point-of-sale (POS) terminal. However, Barnett allegedly lacked specific teachings on conditional capability enablement and remote authorization. To remedy this, Petitioner argued that Waters taught selectively enabling a smartphone’s NFC tag only when a sensor (e.g., fingerprint, pressure, heat) detects a value that satisfies a security criterion. This corresponds to claim limitations requiring enablement "responsive to sensing a value of a parameter." Further, Petitioner contended that White taught a mobile payment approval process where a first "slave" device (the consumer's phone) requests transaction authorization from a second "master" device (e.g., a parent's or employer's phone) over a network, such as Wi-Fi. This maps to limitations requiring the establishment of a master-slave relationship and the request/receipt of authorization.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Barnett with Waters to improve the security of mobile payments. In Barnett’s retail environment with multiple, potentially unmonitored NFC readers, selectively enabling the NFC function via a sensor input as taught by Waters would be a known and desirable method to prevent unauthorized access or accidental transactions. A POSITA would further incorporate White’s teachings to add a flexible and robust authorization layer. The ability for a card owner to remotely approve transactions on a purchase-by-purchase basis was a known method for implementing parental or corporate spending controls, directly addressing the need for secure transaction approval in the Barnett-Waters system.
  • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success because all three references operate in the same field of mobile payments and employ compatible, well-understood technologies like NFC and Wi-Fi. Combining a sensor-based security check (Waters) and a remote authorization protocol (White) with a basic NFC payment system (Barnett) would be a predictable integration of known solutions to known problems.

Ground 2: Obviousness over Barnett, Waters, White, and Smith - Claims 5 and 12 are obvious over Barnett, Waters, White, and Smith.

• Prior Art Relied Upon: Barnett (Application # 2009/0170483), Waters (WO 2006/087503), White (Patent 7,434,723), and Smith (WO 02/09005).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon the Barnett-Waters-White combination from Ground 1 and introduces Smith to address limitations in claims 5 and 12 related to receiving information after a transaction is completed. Petitioner argued that the primary combination established the full transaction process up to payment authorization. Smith was introduced to teach the subsequent step of generating and transmitting an electronic receipt from the vendor's POS device to the purchaser’s smartphone. Smith explicitly discloses that this receipt can contain authorization information from the financial institution that approved the payment, thereby satisfying the claim limitation of receiving information from both the access point and another predetermined device (the financial institution) after payment.
  • Motivation to Combine: A POSITA, having constructed the transaction system of Barnett, Waters, and White, would be motivated to add Smith's teachings to complete the commercial transaction loop. Providing a digital receipt is a logical, expected, and highly beneficial feature for consumers, offering proof of purchase and facilitating record-keeping. Smith’s disclosure of sending a receipt post-authorization directly addresses what a POSITA would recognize as a natural final step in the payment workflow.
  • Expectation of Success: Integrating a digital receipt feature as taught by Smith into the primary combination would be straightforward and predictable. Smith’s system uses short-range wireless technologies compatible with those in Barnett, and the concept of generating a receipt after payment authorization is a conventional business practice. A POSITA would have easily recognized that the authorization response from the financial entity in the White system could serve as the trigger for the POS terminal to generate and send the receipt as taught by Smith.

4. Arguments Regarding Discretionary Denial

• Petitioner noted its intent to substantively address any potential arguments for discretionary denial, including those under 35 U.S.C. §314(a), during the discretionary denial briefing phase in accordance with the Patent Office's interim procedures.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-14 of the ’743 patent as unpatentable.