PTAB

IPR2025-01554

Samsung Electronics America Inc v. Paygeo LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Financial Transaction Platform
  • Brief Description: The ’307 patent discloses a system and method for conducting financial transactions in a mobile environment. The platform enables registered members to transfer funds using various payment sources, such as bank accounts, credit cards, and third-party accounts, by interfacing with financial institutions and other users.

3. Grounds for Unpatentability

Ground 1: 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, the primary reference, discloses a system for peer-to-peer financial transactions on an electronic device (e.g., an iPhone) using a transaction application. Lin’s system is associated with a third-party service provider (Apple), allows users to add various payment sources (credit cards, bank accounts, iTunes accounts), select a payee, specify a payment amount, and receive transaction notifications. Petitioner contended that to the extent Lin does not explicitly teach user registration or pre-access login credentials, Rackley remedies this. Rackley discloses a "Mobile Wallet" system where users must register for the service and log in with a username and password or PIN before accessing the application, a common feature for improving security.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Rackley’s teachings with Lin’s system to enhance functionality and security. Specifically, a POSITA would be motivated to incorporate Rackley’s "balance transfer" feature, which allows a user to move funds between their own different accounts. This would provide users of Lin’s system with more comprehensive tools for managing their funds. A POSITA would also integrate Rackley's user registration and login features to ensure that sensitive financial information is exchanged only between authenticated, registered users, thereby improving system security.
    • Expectation of Success: A POSITA would have had a high expectation of success. Lin already discloses transactions between different users, so implementing a balance transfer involving a single user would be a straightforward, if not simpler, task. Likewise, adding user registration and login screens was a well-known and routine practice for securing financial applications at the time.

Ground 2: 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, arguing that if the Board finds the Lin/Rackley combination does not sufficiently teach the claimed "communication interface" limitations, the addition of Tumminaro renders them obvious. The challenged claims require distinct communication interfaces for a first financial institution, a second financial institution, and a third-party entity. Petitioner asserted that Tumminaro explicitly teaches a mobile payment platform where each financial partner (e.g., banking partners, card partners) may have a different electronic interfacing scheme, and the system communicates using an appropriate Application Program Interface (API) for each partner.
    • Motivation to Combine: A POSITA would be motivated to incorporate Tumminaro's teaching of using distinct APIs into the combined Lin/Rackley system. This approach allows for the "easy integration of financial partners" while improving security by tailoring connection requirements to each specific partner. Given that different financial entities use unique security protocols, using individualized interfaces as taught by Tumminaro would be a logical and necessary step to create a robust, secure, and versatile payment platform.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing this feature. It was common for financial partners to have their own unique security protocols and requirements. Integrating distinct APIs for each partner into the Lin/Rackley system would have been a straightforward application of known software integration techniques to achieve the predictable result of secure, interoperable communications.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’307 patent as unpatentable.