PTAB

IPR2025-01552

Samsung Electronics America Inc v. Paygeo LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Transaction Platform
  • Brief Description: The ’296 patent discloses a system and method for a mobile transaction platform that enables registered members to conduct financial transactions. The platform facilitates the transfer and exchange of funds from various sources, such as credit card accounts, bank accounts, and third-party accounts, within a mobile telecommunications environment.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lin and Rackley - Claims 1-14 are obvious over Lin in view of Rackley.

  • Prior Art Relied Upon: Lin (Application # 2010/0078472) and Rackley (Application # 2008/0010192).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lin discloses the core features of the challenged claims. Lin teaches a system for peer-to-peer financial transactions on a mobile device (e.g., an iPhone using an iTunes account), which serves as the claimed third-party service. Lin’s system includes a transaction application with interfaces for selecting a payee, specifying a payment amount, and choosing from various payment sources like credit cards and bank accounts. Petitioner asserted that Lin’s disclosure of communicating with credit card verification servers, bank servers, and the iTunes server meets the limitations of having separate communication interfaces for a credit card company, a financial institution, and a third-party entity, respectively. For dependent claims, Petitioner contended that Lin's system operates on a mobile device (claim 2) and that modifying it to add features like an address book for payee selection would have been obvious.
    • Motivation to Combine: Petitioner contended that while Lin discloses transactions between different users, Rackley explicitly teaches a "balance transfer" function, allowing a single user to move funds between their own different accounts (e.g., from a bank account to a stored-value account). A POSITA would combine Rackley’s balance transfer functionality with Lin's platform to provide users with more comprehensive financial management tools. This combination would allow a user to, for example, fund their third-party account (like Lin's iTunes account) directly from their bank account, a desirable and commercially valuable feature. This combination directly addresses claim 5, where the paying member and receiving member are the same person.
    • Expectation of Success: Petitioner asserted a high expectation of success. Implementing a balance transfer for a single user in a system like Lin's, which already manages more complex transactions between two different users, would be a straightforward and predictable modification.

Ground 2: Obviousness over Lin, Rackley, and Tumminaro - Claims 1-14 are obvious over Lin and Rackley in further view of Tumminaro.

  • Prior Art Relied Upon: Lin (Application # 2010/0078472), Rackley (Application # 2008/0010192), and Tumminaro (Application # 2007/0255652).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, specifically addressing the communication interface limitations. Petitioner argued that to the extent the Board might find the Lin/Rackley combination does not explicitly teach using distinct, individualized communication interfaces for each type of financial partner, Tumminaro remedies this deficiency. The core functionality of the claimed system is still provided by the combination of Lin and Rackley as argued in Ground 1.
    • Motivation to Combine: Tumminaro explicitly teaches that in a mobile payment system, each financial partner (e.g., banking partners, card partners) may have a different electronic interfacing scheme. Tumminaro discloses using a distinct Application Program Interface (API) for each partner to allow for "easy integration" and enhanced security. Petitioner argued a POSITA would be motivated to incorporate Tumminaro's teaching of individualized APIs into the Lin/Rackley system. This would ensure a robust, secure, and flexible platform capable of accommodating the unique technical and security protocols of various financial partners, which was a known challenge and design consideration in the art.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because implementing partner-specific APIs was a common and well-understood practice for integrating disparate financial systems. It was a predictable solution to a known problem, and both Lin and Rackley already contemplated communicating with multiple external financial entities.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’296 patent as unpatentable.