Samsung Electronics America Inc v. Paygeo LLC

1. Case Identification

• Case #: IPR2025-01553
• Patent #: 10,937,018
• Filed: October 1, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Paygeo, LLC
• Challenged Claims: 1-14

2. Patent Overview

• Title: Mobile Financial Transaction Platform
• Brief Description: The ’018 patent discloses a system and method enabling registered members to conduct financial transactions, such as peer-to-peer payments and fund transfers, in a mobile telecommunications environment. The platform is designed to interface with various entities, including credit card companies, financial institutions, and other users.

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 functionalities of the claimed system. Lin teaches a peer-to-peer mobile payment system operating within an ecosystem like Apple's iTunes, where users can manage various payment sources (credit cards, bank accounts, non-cash accounts like iTunes) on a mobile device to initiate and receive payments. Lin discloses the necessary hardware, user interfaces for selecting a payee and payment source, and communication with financial servers. Petitioner asserted that Rackley, which discloses a "Mobile Wallet" application, remedies any alleged deficiencies in Lin by explicitly teaching user registration for service access and the functionality of "balance transfers," where a user moves funds between their own different accounts (e.g., from a bank account to a third-party account). The combination of Lin's comprehensive mobile payment framework with Rackley's teachings on user registration and balance transfers allegedly renders all limitations of independent claims 1 and 8 obvious.
  • Motivation to Combine: A POSITA would combine Rackley's teachings with Lin's system to provide users with enhanced functionality and better tools for managing funds. Specifically, adding the "balance transfer" capability taught by Rackley would be a desirable feature for users of Lin's platform. Furthermore, incorporating Rackley's more explicit user registration process would improve the security of Lin's system by ensuring that financial information is exchanged only between registered users, a known and desirable goal in the art.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. Both Lin and Rackley operate in the same field of mobile financial transactions and address similar problems. Integrating known features like user registration and balance transfers into a mobile payment application would have been a straightforward application of conventional techniques to yield predictable results.

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 in the event the Board determines that the combination of Lin and Rackley fails to render the communication interface limitations of the challenged claims obvious. Petitioner contended that Tumminaro explicitly teaches a mobile payment platform that uses distinct Application Program Interfaces (APIs) to connect with different financial partners (e.g., banking partners, card partners). Tumminaro explains that each partner may have a different electronic interfacing scheme, and using specific APIs for each allows for "easy integration" and enhanced security. Adding this teaching to the Lin and Rackley combination explicitly supplies the claimed limitations requiring distinct communication interfaces for communicating with a credit card company, a financial institution, and a third-party entity.
  • Motivation to Combine: A POSITA would be motivated to incorporate Tumminaro's use of distinct APIs into the Lin/Rackley system to improve interoperability and security. It was well-known that different financial institutions used proprietary and unique communication protocols. Tumminaro’s approach of using individualized APIs provides a direct solution to this problem, enabling a single mobile platform to securely and reliably connect with a diverse range of financial partners. This modification would improve the robustness and marketability of the combined Lin/Rackley system.
  • Expectation of Success: A POSITA would have had a high expectation of success. Implementing partner-specific APIs was a known technique for integrating disparate systems in the financial technology space. Tumminaro’s teachings provide a clear roadmap for this integration, and applying it to the system of Lin and Rackley would involve the use of conventional programming techniques to achieve the predictable result of seamless communication with multiple, varied financial partners.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 10,937,018 as unpatentable.