PTAB

IPR2025-01551

Samsung Electronics America Inc v. Paygeo LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cashless Financial Transaction System and Method
  • Brief Description: The ’671 patent discloses a method for conducting cashless financial transactions between two mobile devices. The system involves a first user generating a code with financial information and transferring it to a second user's proximate device via a directional movement (e.g., a swipe), after which the second user can accept or decline the transaction.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 22 are obvious over Look and Stallings.

  • Prior Art Relied Upon: Look (Application # 2007/0260558) and Stallings (Application # 2010/0156812).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Look teaches the foundational elements of the challenged claims, including a mobile financial service method where a payor's device generates a secure two-dimensional code containing transaction data and transmits it to a proximate payee's device for authorization. Look also discloses the payee's device sending a reverse code back as a receipt. Petitioner asserted that Stallings supplies the missing element of claim 1[1d]: transferring information between two proximate mobile devices using a directional swipe gesture on the first device in the direction of the second. This mapping directly addresses dependent claim 3, which specifies a "directional swipe movement."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Stallings’s intuitive and secure directional gesture interface with Look’s mobile payment framework. The motivation would be to improve user experience by providing a more interactive transfer method and to enhance security by avoiding the public display of a QR code, which could be intercepted by an unintended recipient.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination. It would involve implementing a known UI technique (directional swipe) into a known data transfer process (mobile payment), which would require only routine hardware and software modifications to existing mobile devices with touchscreens, a technology well-established at the time.

Ground 2: Claims 1-3 and 22 are obvious over Look, Stallings, and Tumminaro.

  • Prior Art Relied Upon: Look (Application # 2007/0260558), Stallings (Application # 2010/0156812), and Tumminaro (Application # 2007/0255620).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented to the extent the combination of Look and Stallings does not render all claim limitations obvious. Petitioner argued that Tumminaro provides explicit teachings for several limitations. Tumminaro discloses a dedicated "mobile payment platform and service" (claim 1[1e]) that confirms transaction executability. Crucially, it teaches a system where the payee is explicitly presented with a screen to "accept payment," "decline payment," or "request a change" (claim 1[1g]), and where the platform executes or prevents the transaction based on this choice (claims 1[1h] and 1[1i]). Tumminaro also discloses sending a confirmation message back to the payor indicating acceptance or denial (claim 1[1j]) and a system where users are registered with the service (claim 22).
    • Motivation to Combine: A POSITA would combine Tumminaro's features into the Look/Stallings system to improve transaction accuracy, reliability, and security. Incorporating Tumminaro's explicit accept/decline functionality would give the payee clear control over the transaction, preventing erroneous or fraudulent payments. Adding Tumminaro's dedicated platform and user registration would streamline transactions for authenticated users and centralize control, improving speed and security.
    • Expectation of Success: A POSITA would expect success in integrating Tumminaro's software-based features into the system proposed by Look and Stallings. Because Look’s system already involves the payee in authorizing and validating transactions, modifying the software to include an explicit accept/decline input, as taught by Tumminaro, would be a straightforward and predictable enhancement.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 22 of the ’671 patent as unpatentable.