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Monthly Archives: February 2017

PTAB Denies CBM Review For Alert System Patent

By Matthew Bultman[1]

Law360, New York (February 28, 2017, 6:38 PM EST) — The Patent Trial and Appeal Board refused Monday to institute America Invents Act covered business method review of a TeleSign Corp. patent covering an electronic alert system, the latest example of a patent the board decided was not eligible for review under the program.
The board found that Twilio Inc[2]., a communications software provider, had not shown that its California rival’s patent qualified for CBM review, which the AIA states was designed for patents that are related to financial products or services.

“[B]ased on the record presented and particular facts of this proceeding, petitioner has not established that [the patent] claims a method or apparatus for performing data processing or other operations used in the practice, administration or management of a financial product or service,” the board wrote. The decision came the same day the PTAB declined[3] to institute CBM review of two advertising patents that were challenged by Google Inc[4]. In both those cases, the board said Google hadn’t shown the patents were eligible for review based on the Federal Circuit’s recent ruling[5] in Unwired Planet.

The appeals court in Unwired Planet restricted the scope of the CBM program and said that the PTAB’s expansive view of which patents are eligible for review runs afoul of limits Congress set in the AIA. An attorney for Twilio declined to comment Tuesday. Representatives for TeleSign could not immediately be reached.

Based in Los Angeles, TeleSign provides security solutions aimed at preventing fraudsters from creating fake online registrations. The disputed patent relates to a notification system through which a registered user is sent a message that a specified event has occurred. The system then requires the user to acknowledge the event.

One example described in the patent is a bank customer who is notified each time there is a withdrawal of more than £1,000 from his or her checking account. In its August 2016 petition seeking CBM review, San Francisco-based Twilio argued the patent was invalid under the U.S. Supreme Court[6]‘s landmark Alice decision, which held that abstract ideas implemented using a computer are not eligible for a patent.

“[T]he abstract idea of verifying a registrant’s identity and then communicating with the registrant has been a ‘tool’ in the ‘storehouse of knowledge’ that is ‘free to all men and reserved exclusively to none’ at least since the introduction of the phone book,” Twilio wrote. Twilio also argued that several claims would have been obvious at the time of the invention. In its response, which was filed in December, TeleSign said it gave up legal rights to a handful of the patent’s claims.

It argued the remaining claims didn’t recite a service particular to a financial institution or include language that was financial in nature, meaning the patent wasn’t eligible for CBM review. Siding with TeleSign on Monday, the PTAB rejected Twilio’s argument that the patent’s description showed its primary purpose was financially related. The board said its focus was on what the patent claims, not just some examples of the invention that are described in the patent’s specification.

“Further, we do not agree with petitioner that the ‘primary purpose’ of [the patent] relates to finance,” it wrote, noting that the alert system could be used in nonfinancial ways, like notifying someone of sports scores or an airline flight change. Twilio had also argued that in the wake of Unwired Planet, the PTAB must “strike the proper balance” between “an invention of general usage that could also be used in the administration of a financial service” and “an invention that is used in administration of a financial service but that could also be used for nonfinancial purposes.” The board said this seemed to go against what the Federal Circuit said in its ruling.

“Petitioner … does not quote anything in Unwired Planet for this proposition, which appears to contradict the Federal Circuit’s direction that covered business method patents ‘are limited to those with claims that are directed to methods and apparatuses of particular types and with particular uses “in the practice, administration, or management of a financial product or service,”‘ and ‘[i]t is not enough that a sale … may occur, or even that the specification speculates such a potential sale might occur,'” the PTAB wrote. The patent-at-issue is U.S. Patent Number 9,300,792[7].

Twilio is represented by Wayne O. Stacy, Eliot D. Williams and Sarah J.

Guske of Baker Botts LLP[8]. TeleSign is represented by Jesse J. Camacho, Amy M.

Foust, Elena S. K. McFarland and Mary J.

Peal of Shook Hardy & Bacon LLP[9]. The case is Twilio Inc. v. TeleSign Corp., case number CBM2016-00099, before the Patent Trial and Appeal Board.

–Editing by Breda Lund.


  1. ^ Matthew Bultman (
  2. ^ Twilio Inc (
  3. ^ the PTAB declined (
  4. ^ Google Inc (
  5. ^ recent ruling (
  6. ^ U.S.

    Supreme Court (

  7. ^ 9,300,792 (
  8. ^ Baker Botts LLP (
  9. ^ Shook Hardy & Bacon LLP (

Mother Arrested for Murder of Her Infant in 2012

On Monday, December 31, 2012, at approximately 12:19 a.m., deputies from the Victorville Station and medical aid responded to a residence in the 16000 block of Sunhill Drive in the city of Victorville, following a 911 call for medical aid. Deputies and paramedics arrived at the home where they discovered a newborn infant unresponsive inside the residence. CPR and life-saving measures were done and the infant (Baby Boy Collins) was transported to Desert Valley Hospital.

Despite lifesaving measures, the infant was pronounced deceased at 12:48 a.m. Detectives from the San Bernardino County Sheriff’s Department, Specialized Investigations Division, Homicide Detail, were summoned and conducted the investigation. After an extensive investigation, Detectives determined the infant’s mother, Tanika Collins, 30, was responsible for the infant’s death.

The case was forwarded to the San Bernardino County District Attorney’s office for review. In January 2017, the District Attorney’s office finished the review of the case and issued an arrest warrant for Tanika Collins in the death of her son. Tanika was arrested by deputies from the Victorville Station on Thursday, February 23, 2017, and booked into High Desert Detention Center for Murder.

Anyone with information regarding this incident is urged to contact Detective Troy Mooradian or Sergeant Robert Warrick at (909)387-3589.

Callers wishing to remain anonymous are urged to call the We-tip Hotline at 1-800-78-CRIME (27463) or you may leave information on the We-Tip website at[1].


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ZOSI 700TVL 24 IR-LEDs Night Vision CCTV Surveillance Video Camera Home Security Indoor/Outdoor Use – Offer

ZOSI 700TVL 24 IR-LEDs Night Vision CCTV Surveillance Video Camera Home Security Indoor/Outdoor Use

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