PTAB

IPR2025-01361

Google LLC v. CardWare Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Generating and Using Limited-Use Payment Information
  • Brief Description: The ’634 patent describes a method and system for an electronic payment device, such as a smart card, that can generate a "limited-duration payment number" for use in a single transaction to enhance security. The device receives a priming operation from a user, generates the temporary number, and transmits it for transaction processing.

3. Grounds for Unpatentability

Ground 1A: Claims 1-2, 7-16, 27-34, and 36-38 are obvious over Gomez, Amacker, and Casey.

  • Prior Art Relied Upon: Gomez (Patent 9,600,808), Amacker (Patent 8,423,462), and Casey (Patent 8,255,323).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the prior art combination discloses all limitations of the challenged claims. Gomez taught a mobile payment system using a secure, time-limited authentication cryptogram for each transaction, transmitted via Near Field Communication (NFC). This cryptogram is generated after a user presents a credential (e.g., PIN or fingerprint). Amacker and Casey taught integrating such payment systems into a mobile device (e.g., a smartphone) with a touchscreen. They disclosed receiving a payment request on the device, displaying transaction details and payment options to the user, and requiring user confirmation (e.g., tapping an "accept" button) before transmitting payment information. Casey further taught receiving and displaying a digital receipt on the device after the transaction is complete.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine these references to improve Gomez's system. Integrating Gomez’s payment card into a smartphone as taught by Amacker and Casey was a predictable step to reduce the number of devices a user must carry. Adding a touchscreen UI from Amacker and Casey to display transaction details before approval would enhance security by allowing the user to verify the merchant and amount. Providing a digital receipt as taught by Casey was a known and beneficial feature to confirm transaction completion.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success as the combination involved applying known UIs and device integration techniques to a known secure payment system to achieve predictable improvements in usability and security.

Ground 1B: Claims 3-6, 17-26, 35, and 39-72 are obvious over Gomez, Amacker, Casey, and Law.

  • Prior Art Relied Upon: Gomez (Patent 9,600,808), Amacker (Patent 8,423,462), Casey (Patent 8,255,323), and Law (Application # 2015/0134540).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Gomez-Amacker-Casey combination by adding the teachings of Law. Law disclosed a system for facilitating payments using a virtual card on a mobile device where multiple funding cards can be registered. For each funding card, Law generated a static "funding card identifier" that is different from the actual Primary Account Number (PAN). This identifier is stored on the device and transmitted during a transaction to indicate which underlying card to use, thereby protecting the actual card details. Petitioner argued that this addresses claim limitations related to generating and using static, unique account information that is associated with a selected issued payment account but is transmitted in place of the actual account number. Law also taught generating dynamic, limited-use data based in part on secret information associated with the selected funding card.
    • Motivation to Combine: Petitioner asserted that Gomez did not explicitly detail how information about the selected underlying credit card is communicated to the payment processor. A POSITA would have been motivated to incorporate Law’s method of using a funding card identifier to solve this problem. Law’s approach provided a secure and well-defined method for selecting one of multiple linked accounts for a transaction without exposing the actual card number, a clear benefit for the combined system.
    • Expectation of Success: The integration was presented as a straightforward application of Law's tokenization-like technique to the known multi-account payment system of Gomez, yielding the predictable result of enhanced security and functionality.

Ground 1C: Claim 13 is obvious over Gomez, Amacker, Casey, and Chin.

  • Prior Art Relied Upon: Gomez (Patent 9,600,808), Amacker (Patent 8,423,462), Casey (Patent 8,255,323), and Chin (Patent 7,593,000).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was asserted as an alternative for rendering claim 13 obvious. Claim 13 requires that user validation involves a "known user touch gesture." While Petitioner argued that a fingerprint swipe in the primary combination met this limitation, it offered Chin as an alternative. Chin taught a method for authenticating a user on a mobile device by recognizing a pre-stored tactile pattern or gesture entered on a touchscreen without visual aids.
    • Motivation to Combine: Petitioner argued that a POSITA would have been motivated to implement Chin's tactile gesture authentication as an alternative to a PIN or fingerprint scan. Chin explicitly described its method as an improvement over virtual keypads, which can be cumbersome, slow, or difficult for users with certain impairments. Adding this known authentication method would predictably enhance the usability and accessibility of the combined payment device.
    • Expectation of Success: A POSITA would have reasonably expected success in adding Chin's gesture recognition as another user authentication module, as it was a known technique for unlocking mobile devices and applying it to authorize a payment transaction was a simple extension of its purpose.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-72 of the ’634 patent as unpatentable.