Challenged claims of Proxense LLC’s patent that describes a hybrid device having a personal digital key and receiver-decoder circuit and methods of use are unpatentable as obvious over prior art, the Patent Trial and Appeal Board said, in an inter partes review by the Microsoft Corporation. The board determined that the challenged claims are obvious over prior art that discloses two-level authentication for secure transaction, a digital content security system, and a method, system, and apparatus having near field communication chip with configurable memory that is updatable via a host processor.
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