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This afternoon is number 18-1404 in Cora Technologies, Inc.

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versus HTC America.

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Mr. Lorelli.

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Thank you, Your Honor.

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Mr. Lorelli, if we agree within Cora that the district court erred in not addressing in step one the argument regarding the asserted claims improvement in

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computer functionality because it said it was better considered in step two.

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Is in court asserting that we have to remand to do it right or are you asking us to reverse based upon a finding the claims are abstract?

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With the step one analysis your honor it's de novo so you can make that decision right here.

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The court didn't consider

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whether it was a technological improvement in step one, which is what led us down this road.

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But that's where it began.

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There are basically three errors by the district court judge in its 101 decision on the pleadings.

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The first one was characterizing the claim too broadly.

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The second was holding that the claim was directed to an abstract idea when the specification and other decisions made clear that the 941 patent claims are directed to improvements

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to a technical problem of software piracy.

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And the third was its finding that modification and use of erasable non-volatile memory of the bios for license verification of software programs was somehow routine and conventional when that is in direct contradiction with the specification.

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Okay.

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You compare these asserted claims to visual memory.

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Yes.

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And there we found eligible a memory system with programmable operational characteristics that determine the type of data stored.

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And that was similar to the ENFISH specific referential table.

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It was very specifically done code data buffering by a bus master and so forth.

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I'm harder pressed to find similar support

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in the 941 patent's claims or written description for how to accomplish setting up the verification structure.

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Setting up the verification structure is disclosing the specification as using e-squared prom manipulation commands.

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Those are manipulation commands that don't exist on a generic computer.

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That's why the examiner, before allowing the claim, said that you need to claim an agent to set up that verification structure.

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So that's the

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support and specification for the specifics, the tool that's needed to do this, the tool that's needed to make the modification of the bios.

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But the problem is it doesn't tell you how to use the tool.

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And as I understand it, with the blue brief 27 footnote 4, you say that's within the knowledge of someone's skill in the art.

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The patent does not tell you how to do it, right?

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It does not tell you specifically how to do it.

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It tells you the tools to use to do it, those EPROM manipulation commands.

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And one of Skill in the Art would know how to use those commands by using some of the prior art that was, in fact, cited in the original examination.

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It is using those manipulation commands for a specific... Those manipulations.

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are standard in the art, am I correct, for manipulating ROM?

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Well, they don't manipulate ROM, Your Honor, and I think that's an issue.

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EPROM.

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EPROM.

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There are standards that teach people how to do it.

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I don't know that it's widespread, but there are standards that teach people how to do that.

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Your basic submission is essentially a Enfish type submission that this is for 101, never mind about 102 and 103, that the subject of this is improving computer functionality in the specific sense that you are using

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components of the computer to safeguard the computer in ways that had not been done before.

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I think that's very wrong.

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And you may be wrong about whether they hadn't been done or whether they're obvious.

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That's for a different day.

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But I think if you look at the concept of the specification that we have here, the specification is very clear.

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We talked about infish, and we talked about fails and visual memory.

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And all of those cases were very similar.

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When you look at the specification, you can often tell a lot about an invention.

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And in this case, the specification... One would hope.

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One would hope.

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But one wouldn't, often doesn't, when they're looking at some of the claims that are attacked under 101.

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In our specification, we talk about the technical problem.

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software piracy.

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It's a problem that didn't exist before computers.

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Before computers, there was no software that could be no software piracy.

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Just to be clear, what is happening here and what the invention is, is moving the licensed software from one place to another, right?

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In the second place, it's more difficult to hack.

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That is one notion of the improvement over one of the items of prior art solutions that was disclosed in the specification.

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There's another set of improvements over the other prior art that was disclosed in the specification.

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That was use of a dongle.

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Whenever I would want to run a software program, I'd have to plug a dongle into one of the ports in order for it to operate.

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And BIOS is very important, your honor, in understanding how it was back in 1998.

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It was October 1st, 1998, 20 years.

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BIOS boots up, yes?

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Yes.

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That's what it does.

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It boots the computer up.

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And folks that use computers don't have access to it.

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And it does checking for licenses at the time it boots up, right, with respect to the operating system?

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It does not, Your Honor.

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It does not check for licenses for software.

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It does not.

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Does it check for licenses for hardware?

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I believe it checks for the existence of hardware, but not for licenses of it, Your Honor.

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And BIOS, it's not something that a program could get to.

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That's one of the, again, I'm making 103 arguments, your honor, but that's for a different day, but it is for a different day.

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What we have here is a unique implementation.

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You're effectively modifying firmware, is that right?

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Yes, your honor.

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And in 1998, that's not something that computer programmers did.

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That's not something that computer programmers could do with a generic computer.

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And again, back to the specification.

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did a great job here, outlining the prior art solutions to the computer piracy problem and identifying the solution that was set forth in the specification and the solution that was claimed in claim one of the 941 patent.

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So then when we get a step one Alice analysis that says, wait a second, your claim is just directed to this abstract concept, which by the way, could read on all those prior art solutions too, we're taking a back.

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because the whole patent was written to focus on the use and modification of the E double, E squared prom, prom, to improve the security of licensing mechanisms.

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And that's what the invention was and did.

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And obviously we'll get to 103 a different day, but this is, this is what the.

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102.

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But this is what the patent is directed to, the claim is directed to.

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So when we get an opinion that doesn't go through the specification, the prosecution history, and just assumes that claim one is directed to an abstract idea, which is, if you notice on page nine of our blue brief, we highlighted the parts of the claims that the district court said were the abstract idea.

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It's a very, it's like 10 words out of, you know, a hundred word claim, but it misses the heart of it.

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It misses what the patent was all about.

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So that's where we struggle a lot with the determination of an abstract idea.

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But when we go back to the specification, the specification talks about how it's a technological improvement.

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And from Alice to Infish to visual memory, we have to investigate whether

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the claims embody a technical improvement.

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And if we do that by looking at the specification, the answer is clear.

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In this case, we have more help because HTC filed a petition for a CBM, a covered business method.

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And there the PTAB decided after looking at the filings that the 941 patent claims was a technical solution to a technical problem.

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We believe that's enough to bring us out of step one

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And I don't remember, but when the board rejected the CBM petition, did it do it on... The CBM definition of the statute is a two... Yeah, the statute is a two-part one, right?

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It has to be in a business method and not a technical solution.

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Which of those steps did the board find this pattern not to be?

[00:10:23] Speaker 04:
I can have that answer for you when I stand back up here, your honor, but the focus of the analysis was technical solution, technical problem.

[00:10:30] Speaker 01:
I see, not the, this just doesn't claim anything business, I'm using the short hand.

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I believe that's accurate, your honor, but I would like to check on that.

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So we are, we believe, like visual memory, because visual memory was deciding based on the processor that's involved in the computer what type of data to store on the cache.

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Cache still stored data, but they made a determination based on something else.

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We believe we're in lockstep with visual memory.

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And then if we take it to the second step, and we take it there and look at an inventive concept, we have a lot of support that the inventive concept is modifying and using this type of BIOS in a new and revolutionary manner, something that wasn't done before.

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the district court that we had a case against Apple in 2012 when she went through the intrinsic record tech tutorial and experts found in actually I believe said the inventive aspect of this claim is exactly what we're pointing to here today.

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But I believe that in this step two, we are locked up with Bascom if we get that far, Your Honor.

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319 is the relevant passage of the CBN decision, which says what you said it says.

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Thank you, Your Honor.

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Okay.

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I'm going to save your remodel.

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Mr. Lateef.

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May it please the court, Mr. Latif for HTC.

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Mr. Latif, and Cora says that before the 9-4-1 patent, OS-level programs did not traditionally interact with BIOS, and that one skilled in the art would not consider storing licensing information for programs in the computer's BIOS.

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That's in their blue brick at 34.

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And the Red Rape responds that that is demonstrably false.

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I'm looking at page 35 of the red brief.

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And they cite the patent examiner who said in the patent's prosecution record that, quote, that the prior art taught the use of underlined bios memory for storing license numbers.

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That's in your red brief at 35, Judge, from you.

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Am I correct?

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I couldn't hear the last part.

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Am I correct that that's it?

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at 35 in the red brief.

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Yes.

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So I go and look at the examiner's notice of allowability at 283.

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It appears to me that HDC omitted the rest of the examiner's explanation.

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The examiner goes on to say, quote, while it appears initially to render obvious the 9-4-1 pattern,

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quote, the prior art systems singly or collectively do not teach licensed programs running at the OS level interacting with a program verification structure stored in the bios to verify the program using the verification structure and having a user act on the program according to the verification.

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That's at 283 in the record.

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Why was that?

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remainder of the examiner's explanation omitted.

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And I'll tell you, my concern, one of them, in addition to it being omitted, is I start with your argument that the court has been lied to, that a demonstrably false statement has been made in the

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So why was that omitted?

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We were just summarizing what the examiner had stated.

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Isn't it reasonable for me to conclude that, in fact, the mischaracterization is in the red brief and not in the blue brief?

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No, I do not believe so.

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I mean, there is nothing in the claims that talk about this OS interaction with the bias.

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The language that I read here.

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seems to be not only pertinent to your statement in the red read, but contradictory.

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Is it not?

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Can you tell me why?

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I want to hear.

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We were just summarizing what the Notice of Allowance said, and I believe that the Notice of Allowance is talking about this interaction which is not in the claims.

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And the fact that the spec talks about including EPROM manipulation commands in no way limits whether the spec is talking about

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the manipulation commands from the OS or from any other device or programming.

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The examiner goes on to say, it is well known to those of ordinary skill of the art, he says, that a computer BIOS is not set up to manage a software license verification structure.

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Do you disagree with that?

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I agree he said that.

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I don't agree that that's pertinent to the claims at issue because the claims do not call for the bias to manage anything.

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The bias is just memory and it stores whatever you put in it.

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It is not required to manage or interact with anything and the claims here don't require it either.

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The prior art reference that the examiner referred to earlier on the top of that page clearly states that Ewerts teaches the use of bias memory for storing licensed numbers.

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So the examiner himself is contradicting an earlier statement that he made in that notice of balance.

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Does conventional bios include a quote, erasable non-volatile memory?

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I believe that the spec says that.

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The spec states that the invention includes a conventional computer.

[00:17:33] Speaker 01:
What are you reading from?

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Yeah, I'm sorry.

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It's column 1, 946.

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And it starts thus consider a conventional computer having a conventional bias module in which a key was embedded at the ROM section thereof.

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So the bias module has a ROM section.

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It goes on, and then I can read the whole thing, but the next part that is relevant is around line 65 of column 1, which states, the resulting encrypted license record is stored in another second non-volatile section of the bias.

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It's clearly still talking about the conventional bias module that has at least two sections.

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Do you agree?

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that generic computer components can sometimes operate in such an unconventional manner as to achieve improvement in functionality?

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Keep Amdocs in mind.

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I do not believe that is the case here.

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You agree it can be?

[00:18:52] Speaker 03:
I have to hear the question again, I'm sorry.

[00:18:53] Speaker 03:
Okay, that's right.

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Do you agree that generic computer components can sometimes operate

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in such an unconventional manner that they achieve an improvement in functionality?

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Yes.

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But I don't believe that is the case here.

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The functionality of the computer hasn't changed.

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It operates the same way.

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it still verifies a license.

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The licensing procedure that the claims are directed to has not been improved.

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What has been improved is the economic problem of license being attacked by a hacker.

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Whether a hacker could get into the bias, that functionality existed before this invention.

[00:19:40] Speaker 00:
In other words, what you're saying is the license verification technology is the same whether it's starred in BIOS or elsewhere.

[00:19:48] Speaker 03:
Correct.

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Just moving the verification structure from the hard drive to the BIOS is not an improvement in computer technology.

[00:20:00] Speaker 02:
Why isn't it?

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Instead of using a dongle or instead of having it accessible to a hacker,

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Isn't that different?

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It is different, but I don't believe it's invented and I don't believe it's unconventional to use memory as memory.

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The bias is just memory.

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Does it make it harder for a hacker?

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It could.

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Yes, bias is... Isn't that an improvement to functionality?

[00:20:25] Speaker 03:
That's not an improvement to the functionality of the computer.

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That is a property the computer had before this invention.

[00:20:32] Speaker 01:
In Enfish, the computer had the possibility of being programmed to have these cross-referencing tables.

[00:20:45] Speaker 03:
I agree that there are, if you look at computer technology, there's always an argument that could be made that new software is something that changes the computer, but I don't think it's enough just to have some new software to automatically make the argument that that's an improvement in the computer functionality or else all software cases

[00:21:08] Speaker 03:
could be argued to be an improvement in computer functionality.

[00:21:14] Speaker 01:
Right, but what Enfish does, and some of the later cases do, is pick up on the Alice parent lesson of the U.S.

[00:21:26] Speaker 01:
government's submission that computer improvements

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are on the eligibility side of the line and try to give it a real world definition so as not to be limited to new hardware but new ways of using the basic computer functionality of input output systems, displays to improve those things without regard to the particular

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use being made of the ultimate resulting computer operation.

[00:22:03] Speaker 01:
Once we start drawing that line, as indeed we have, and he said it's a necessary line to draw, then why exactly is this not on the Enfish virtual memory side of that line?

[00:22:19] Speaker 03:
Because this used conventional, ordinary technology in a conventional, ordinary way.

[00:22:25] Speaker 02:
Oh, let me ask you this.

[00:22:27] Speaker 02:
Is a hacked computer less functional?

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Would you agree with me on that?

[00:22:33] Speaker 03:
Yes.

[00:22:34] Speaker ?:
Okay.

[00:22:35] Speaker 02:
It's been hacked, so I guess it... So if you make it less hackable, it's more functional.

[00:22:41] Speaker 02:
Would you agree with that?

[00:22:43] Speaker 03:
It depends on what perspective you look at functionality.

[00:22:46] Speaker 03:
I believe that the test is whether the computer is able to function better as in efficiency, as in memory, as in database storage and processing.

[00:22:55] Speaker 03:
The processing of the computer has not been changed at all by the use of the bias as a memory.

[00:23:01] Speaker 02:
It's able to function less worse.

[00:23:03] Speaker 02:
Is that okay?

[00:23:06] Speaker 03:
No, it's not OK.

[00:23:07] Speaker 03:
It's not less worse if it could be hacked.

[00:23:10] Speaker 03:
Besides the fact that it could be hacked, it might be difficult to hack if it doesn't change the functionality of the computer.

[00:23:22] Speaker 03:
Thank you.

[00:23:31] Speaker 04:
Mr. Lorelli?

[00:23:33] Speaker 04:
Just a few comments, Your Honors.

[00:23:37] Speaker 00:
The statement that... Is it true that the functionality of the computer has not been changed?

[00:23:44] Speaker 04:
Absolutely not, your honor.

[00:23:47] Speaker 04:
They want to see the functionality of the computer, how it would work if people were licensed and using it properly.

[00:23:53] Speaker 04:
It has been changed for those hackers.

[00:23:58] Speaker 04:
Security has been improved.

[00:24:00] Speaker 04:
That is the functionality that we're talking about here.

[00:24:03] Speaker 04:
That's the technological investment.

[00:24:05] Speaker 00:
I mean, that is what we're talking about, is an improvement in computer security, not an improvement in the way the computer actually functions, right?

[00:24:16] Speaker 04:
That would be accurate, your honor.

[00:24:18] Speaker 04:
It's an improvement in computer security, license security, so that those companies that spend all that money designing software can protect those investments.

[00:24:31] Speaker 04:
The point is that

[00:24:35] Speaker 04:
We talk about improvements.

[00:24:37] Speaker 04:
Improvements, you've got to look at something that came before it.

[00:24:40] Speaker 04:
And the improvement is in the security of the process.

[00:24:43] Speaker 04:
That was different from if you just stored it on a hard drive.

[00:24:46] Speaker 04:
Or if you want to talk about the dongle, it's actually interesting standing here.

[00:24:50] Speaker 02:
Your opposing counsel agrees that a computer that's been hacked is less functional.

[00:24:56] Speaker 04:
Then maybe I should stop then, Your Honor.

[00:25:02] Speaker 04:
But the comment that really got to me was that we were just using conventional stuff in a conventional way, and that's just wrong.

[00:25:11] Speaker 00:
Oh, wait, wait.

[00:25:12] Speaker 00:
I mean, I thought you admitted earlier that you haven't changed the license verification process.

[00:25:19] Speaker 00:
It's just a question of where it's stored, which is more protective from hacking, right?

[00:25:26] Speaker 04:
Your Honor, and if I did say that, perhaps I misspoke.

[00:25:29] Speaker 04:
We moved it to it.

[00:25:31] Speaker 04:
not necessarily move to a different area because you can't do that on a normal computer.

[00:25:37] Speaker 04:
It was set up in a BIOS area, an area that people never considered using for licensing.

[00:25:45] Speaker 00:
I understand that argument, but the fact is it's just storing it in a different place.

[00:25:49] Speaker 00:
Maybe that's 101 eligible, maybe it's not, but that's what this is about, right?

[00:25:55] Speaker 04:
That is an issue as to what it's about.

[00:25:57] Speaker 04:
The benefits that you obtain

[00:26:00] Speaker 04:
from use of the BIOS for license security.

[00:26:05] Speaker 02:
But it's also a way of doing that, is it not?

[00:26:08] Speaker 04:
It's one way.

[00:26:10] Speaker 02:
But I say storing it in the booting system requires methodology, which you've also developed.

[00:26:23] Speaker 02:
That is, modification of the instructions.

[00:26:28] Speaker 04:
Correct, Your Honor.

[00:26:29] Speaker 04:
That's the prerequisite to the whole process.

[00:26:32] Speaker 00:
So the process is different.

[00:26:33] Speaker 00:
I thought there was no claim that you had invented a new instruction that was done using conventional approaches.

[00:26:44] Speaker 00:
What we're talking about here is making this 101 eligible is the fact, the very fact of moving it from one area to the other.

[00:26:53] Speaker 00:
You haven't invented

[00:26:56] Speaker 00:
a way of moving it from one place to the other?

[00:27:01] Speaker 04:
We did, Your Honor.

[00:27:02] Speaker 04:
We used those standard protocols that are not on a generic computer.

[00:27:06] Speaker 04:
We used them to create a structure that didn't exist before in the bios.

[00:27:11] Speaker 00:
Well, that's the point about moving it from one place to the other, but I didn't understand you in claiming that you invented a new method of moving it from one area to the other.

[00:27:26] Speaker 04:
I guess this will get us into the novelty in the 103 because no one ever did that before, Your Honor.

[00:27:33] Speaker 04:
I understand.

[00:27:34] Speaker 00:
I understand.

[00:27:35] Speaker 00:
But the question is whether you invented a way of doing it or the idea of doing it.

[00:27:42] Speaker 04:
We invented a way and the details of that way are represented in Claim 1.

[00:27:48] Speaker 04:
It's not just simply an abstract idea of license verification.

[00:27:51] Speaker 04:
The way we did it was by using

[00:27:55] Speaker 04:
the agent to set up the verification structure in the bios in an area that never saw licensing structures before.

[00:28:03] Speaker 00:
Okay.

[00:28:03] Speaker 00:
All right.

[00:28:03] Speaker 00:
Thank you.

[00:28:04] Speaker 00:
Thank you.

[00:28:06] Speaker 00:
I thank both counsel.

[00:28:07] Speaker 00:
The case is submitted.

[00:28:08] Speaker 00:
That concludes our session for this afternoon.