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JP Morgan Chase & Co. v. Maxim Integrated Products, Inc. (CBM2014-00179)

Representative Claim

  1. A system for communicating data securely, comprising:
    a first portable module comprising:
    a nonvolatile memory for storing a first data;
    a first real time clock circuit for time stamping data transactions;
    a counter for counting a transaction count;
    an input/output circuit;
    a substantially unique electronically readable identification number readable by said input/output circuit; and
    a memory control circuit in electrical communication with said nonvolatile memory, said real time clock, said counter, and said input/output circuit;
    a portable module reader that can be placed in communication with said first portable module, said portable module reader can be connected to a plurality of other devices;
    a secure microcontroller based module in electronic communication with said portable module reader, said secure microcontroller comprising:
    a microcontroller core;
    a math coprocessor, in communication with said microcontroller core, for processing encryption calculations;
    an energy circuit for storing energy;
    a memory circuit connected to said microcontroller core;
    a memory circuit in communication with said microcontroller core; and
    a second real time clock circuit in communication with said microcontroller,
    said combination of said portable module reader and said secure microcontroller performing secure data transfers with said first portable module.

Posture:

Petition for CBM review.

Abstract Idea: No

“In sum, Petitioner’s generalized arguments are insufficient to show that the claims are directed to an abstract idea. Based on our review of each claim, as a whole, we are not persuaded they are directed to an abstract idea. Thus, we need not turn to the second step of the relevant framework.”

Additional Information:

“Petitioner’s analogies to alleged historical examples of secure transfer of data are no substitute for a specific analysis regarding how or why the specific claim language supports Petitioner’s assertion that the claims are directed to the abstract idea of secure data transfer. See Pet. 72. Nor does the Petition adequately tie these examples to the specific claim language, or otherwise sufficiently explain how they relate to the challenged claims. See Prelim Resp. 65-66. It is not clear how these examples, including placing a wax seal on a document, encasing cuneiform tablets in clay envelopes, and signing a document before a notary, could be tied to the claim language. The claims include components lacking any counterpart in the examples, such as a “counter for counting a transaction count” and a “math coprocessor, in communication with said microcontroller core, for processing encryption calculations.”

“The Petition does not address sufficiently how or why the particular claims are directed to an abstract idea. See Prelim Resp. 65-66. In particular, Petitioner’s arguments do not even reference the specific limitations of the challenged claims, with the exception of the preamble (“[a] system for communicating data securely”) and the phrase “performing secure data transfers” in claim 1. Pet. 72-73. For example, the recited “first portable module” and “secure microcontroller based module” contain a handful of tangible physical components, some with specific connections (e.g., “memory circuit connected to said microcontroller core”; “math coprocessor, in communication with said microcontroller core”) and functions (e.g., “nonvolatile memory for storing a first data”; “first real time clock circuit for time stamping data transactions”; “math coprocessor . . . for processing encryption calculations ”). Ex. 1001, 24:1-36 (emphases added).”