Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 1 of 130
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` Exhibit 2
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`

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`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 2 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`
`Based on information presently available,1 Defendant AGIS Software Development LLC (“AGIS Software”) contends that
`
`Plaintiff Lyft Inc. ( “Lyft” or “Plaintiff”) infringes claims 1-26 (the “Asserted Claims”) of U.S. Patent No. 10,341,838 (the “’838 Patent”)
`through the Accused Products which are manufactured, sold, offered for sale, and/or used by Lyft.
`
`The Accused Products comprise the Lyft and Lyft Driver applications, servers, and services manufactured, used, or sold by Lyft,
`Inc. during and after 2016. AGIS Software reserves the right to seek leave of court to amend this list of Accused Products after the
`filing of an amended complaint or as discovery progresses.
`
`Lyft directly infringes each of the Asserted Claims by making, using, importing, testing, distributing, selling, and/or offering for
`sale the Accused Products in violation of 35 U.S.C. § 271(a).
`
`Lyft indirectly infringes the Asserted Claims in violation of 35 U.S.C. § 271(b) by inducing third parties, including its users
`
`and/or customers, to directly infringe through their operation and use of the Accused Products. Lyft has knowingly and intentionally
`induced this direct infringement by, inter alia, (i) selling, importing, or otherwise providing the Accused Products to third parties with
`the intent that the Accused Products will be operated and used in a manner that practices the Asserted Claims; and (ii) marketing and
`advertising the Accused Products. Lyft’s marketing and promotional materials for the Accused Products are found, for example, on
`Lyft’s website, and in App stores of operating systems for which the Accused Products are made available. For example, Lyft’s website
`offers customers instructions and/or manuals for the Accused Products that instruct customers to, among other things, use the accused
`services in the Accused Products. Lyft’s website also offers support to customers, including instruction to, among other things, use the
`Accused Products share location information with a group of users. Lyft knows, or should have known, that its actions will result in
`infringement of the Asserted Claims, or subjectively believes that there is a high probability that its actions will result in infringement
`of the Asserted Claims but has taken deliberate actions to avoid learning these facts.
`
`
`1 ThereThese infringement contentions are provided on a provisional basis to comply with the deadline for P.L.R. 3-1. However, at
`this time, there is no operative complaint asserting non-infringement of any patent claim in this action at this time., and these
`contentions are not responsive to any claim or cause of action. AGIS Software reserves the right to update itsthese contentions upon
`receipt of any futurean amended complaint. These March 18, 2022 amended contentions do not add or modify any theories of
`infringement and are provided solely for the purpose of making clear that AGIS Software does not allege infringement of any Lyft
`iOS-based applications and that AGIS Software does not rely on any Apple products.
`
`A-1
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 3 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
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`Lyft also contributorily infringes each of the Asserted Claims in violation of 35 U.S.C. § 271(c) by selling, importing, offering
`
`for sale, and otherwise providing the Accused Products, which when used directly infringe the Asserted Claims. The Accused Products
`constitute a material part of the Asserted Claims.
`
`The following chart identifies specifically where each limitation of each Asserted Claim is found within the Accused Products,
`
`and in particular, the corresponding elements that meet the limitations in the Lyft and Lyft Driver applications, services, and services.
`On information and belief, each charted version of the Lyft servers related to the Lyft and Lyft Driver Apps is representative of all
`versions of the Accused Products, including all variants of the Accused Products made, sold, offered for sale, or used on any version of
`the Android and iOS operating systems. On information and belief, Lyft also has applications through other distribution platforms.
`AGIS Software relies on circumstantial evidence of the servers’ features by relying on the end features or services provided by the Lyft
`and Lyft Driver Apps.
`
`AGIS Software does not concede that any claims of the ʼ838 Patent that are not listed below are not infringed by the identified
`
`Accused Products. Moreover, the citations to certain documents and other information below are intended to be exemplary only and in
`no way foreclose AGIS from citing or relying on additional documents, information, source code, and/or testimony at a later time. These
`contentions are preliminary in nature and an analysis of Lyft’s products, internal documentation, source code, and/or testimony from
`relevant witnesses may more fully and accurately describe the infringing features of its accused products. Accordingly, AGIS Software
`reserves the right to seek leave of court to supplement, correct, modify, and/or amend these contentions once such additional information
`is made available to AGIS Software. Furthermore, AGIS Software reserves the right to seek leave of court to supplement, correct,
`modify, and/or amend these contentions as discovery in this case progresses; in view of the Court’s claim construction order(s);2 in view
`of any positions taken by Lyft, including but not limited to positions on claim construction, invalidity, and/or non-infringement; and in
`connection with the preparation and exchange of expert reports.
`
`
`2 The construction of claim terms herein is consistent with the constructions in AGIS Software Dev. LLC v. Huawei Device USA, Inc.,
`No. 2:17-cv-00513-JRG, Dkt. 205 (E.D. Tex. Oct. 10, 2018); AGIS Software Dev. LLC v. Google LLC, No. 2:19-cv-00361-JRG, Dkt.
`147 (E.D. Tex. Dec. 8, 2020); AGIS Software Dev. LLC v. T-Mobile USA, Inc., et al., No. 2:21-cv-00072-JRG, Dkt. 213 (E.D. Tex.
`Nov. 10, 2021). AGIS Software reserves the right to update its constructions and contentions in view of this Court’s claim
`construction order.
`
`A-2
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 4 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`
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`The contents of each claim cell below on which another claim cell depends are expressly incorporated by reference in that
`dependent cell, as if set forth in their entirety therein.
`
`A-3
`
`

`

`
`
`-
`
`Claim
`10,341,838
`1[P]. A method
`performed by
`one or more
`servers
`each
`having one or
`more
`processors, the
`method
`comprising:
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 5 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
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`The Lyft Servers perform the computer implemented method as set forth below. Lyft further infringes directly and/or
`indirectly by performing, inducing others to perform, and/or contributing to the performance of: a method performed
`by one or more servers each having one or more processors
`
`For example, Lyft provides the Lyft app for passengers and the Lyft Driver app for drivers. The Lyft apps for riders
`and drivers, in conjunction with Lyft’s servers and services, provide users with interactive methods to request, view,
`and track locations of passengers/riders using real-time maps and communications. Lyft provides one or more
`servers with processors (either hardware or software). The Lyft server(s) and their services communicate with the
`Lyft apps for riders and drivers. The Lyft server(s) and their services host information related to and instructions
`for processing user/device/vehicle accounts, location data, and map data.
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
` https://www.lyft.com/drive-with-lyft
`
`
`A-4
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`
`
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 6 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`A-5
`
`

`

`
`
`Claim
`10,341,838
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 7 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`A-6
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 8 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`
`
`Claim
`10,341,838
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`A-7
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 9 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`
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`Claim
`10,341,838
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`A-8
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`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 10 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`Claim
`10,341,838
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`A-9
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`

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`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 11 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`
`
`Claim
`10,341,838
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`
`
`A-10
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`

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`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 12 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: executing operations on the one or more processors, the operations.
`
`For example, Lyft servers comprise processors which receive passenger’s request for a ride and communicate the
`request to the nearby drivers. The nearby drivers receive the request for a ride from the passengers which they accept
`
`
`
`1[A]. executing
`operations on
`the one or more
`processors, the
`
`A-11
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 13 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`or decline. The servers further facilitate the communication between the passenger and the allocated driver during
`a ride.
`
`
`
`
`Claim
`10,341,838
`operations
`comprising:
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`A-12
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 14 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`
`
`Claim
`10,341,838
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`A-13
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 15 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`
`
`Claim
`10,341,838
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`
`
`A-14
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`

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`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 16 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
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`
`
`Claim
`10,341,838
`
`
`
`
`
`A-15
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`

`

`
`
`Claim
`10,341,838
`
`1[B]. obtaining
`first
`data
`provided by a
`first
`mobile
`device
`corresponding
`to a vehicle, the
`first
`data
`including a first
`identifier
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 17 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
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`Accused Products
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: obtaining first data provided by a first mobile device corresponding to a vehicle,
`the first data including a first identifier.
`
`
`For example, the Lyft driver sets up his/her account by providing information including but not limited to name,
`email address, phone number, driver’s license and vehicle information. Lyft assigns one or more indentifications
`associated with the account.
`
`For example, the Lyft Driver app installed in a driver’s mobile device allows a driver to set up his/her account by
`providing information including but not limited to name, email address, phone number, driver’s license and vehicle
`information. The Lyft server(s) perform this limitation when they obtain the account creation data from the Lyft app
`for drivers. The Lyft server(s) also perform this limitation, after account creation, when they obtain the data during
`the sign-in or log-in process from the Lyft app for drivers. The Lyft server(s) also perform this limitation when they
`obtain the data by requesting status or other data via the Lyft app for drivers. In all cases, the first identifier is
`information associated with the identity of the driver, account, vehicle, or Lyft app for drivers.
`
`A-16
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 18 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Source: https://www.lyft.com/driver.
`
`
`
`A-17
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 19 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-18
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`

`

`
`
`Claim
`10,341,838
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 20 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`Source: https://account.lyft.com/auth?next=https%3A%2F%2Fwww.lyft.com%2Flogin%2Fjump.
`
`
` https://help.lyft.com/hc/e/articles/115012925687-Driver-requirements
`
`
`
`
`A-19
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 21 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
` https://help.lyft.com/hc/e/articles/115013081188
`
`
`
`
` https://help.lyft.com/hc/e/articles/115013081188
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`
`
`
`A-20
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`

`

`
`
`Claim
`10,341,838
`
`1[C].
`the
`permitting
`first
`mobile
`device
`corresponding
`to the vehicle
`to
`join
`a
`communication
`network,
`the
`permitting
`a
`based
`on
`determination
`regarding
`the
`first data
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 22 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: permitting the first mobile device corresponding to the vehicle to join a
`communication network, the permitting based on a determination regarding the first data.
`
`
`The Lyft server(s) perform this limitation when the server uses the account or identity information described above
`to add the account/driver/vehicle to the Lyft platform or network of drivers and passengers. The Lyft server(s) also
`perform this limitation when the server uses the account or identity information to create or activate or update an
`account using the account or identity information described above. The Lyft server(s) also perform this limitation
`when a driver completes the sign-in or log-in process. The Lyft server(s) also perform this step using a verification
`or validation process within sign-up, sign-in, or status request process.The account or identity information is
`associated with the Lyft platform or network of drivers and passengers or a subset of the platform or network.
`
`A-21
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 23 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Source: https://www.lyft.com/driver.
`
`
`
`
`A-22
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 24 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-23
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 25 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`Source: https://account.lyft.com/auth?next=https%3A%2F%2Fwww.lyft.com%2Flogin%2Fjump.
`
`
`
`Claim
`10,341,838
`
` https://help.lyft.com/hc/e/articles/115012925687-Driver-requirements
`
`
`
`
`A-24
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 26 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
` https://help.lyft.com/hc/e/articles/115013081188
`
`
`
`
` https://help.lyft.com/hc/e/articles/115013081188
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`
`
`A-25
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 27 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: obtaining second data provided by a second mobile device corresponding to a
`participant, the second data including a second identifier associated with the participant.
`
`
`For example, the Lyft app installed on a passenger’s mobile device allows a passenger to set up his/her account by
`providing information including but not limited to name, email address and phone number. The Lyft server(s)
`perform this limitation when they obtain the account creation data from the Lyft app for riders. The Lyft server(s)
`also perform this limitation, after account creation, when they obtain the data during the sign-in or log-in process
`from the Lyft app for riders. The Lyft server(s) also perform this limitation when they obtain the data by requesting
`status or other data via the Lyft app for riders. In all cases, the second identifier is information associated with the
`identity of the rider, account, device, phone number, or Lyft app for riders.
`
`
`
`
`-
`
`Claim
`10,341,838
`1[D]. obtaining
`second
`data
`provided by a
`second mobile
`device
`corresponding
`to a participant,
`the second data
`including
`a
`second
`identifier
`associated with
`the participant
`
`A-26
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 28 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Source: https://help.lyft.com/hc/e/articles/115012926947-How-to-create-a-Lyft-account.
`
`
`
`
`A-27
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 29 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-28
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 30 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`1[E]. allowing
`the
`second
`mobile device
`corresponding
`to
`the
`participant
`to
`join
`the
`communication
`network,
`the
`allowing based
`on
`a
`determination
`regarding
`the
`second data
`
`Source: https://account.lyft.com/auth?next=https%3A%2F%2Fwww.lyft.com%2Flogin%2Fjump.
`
`The Lyft rider app allows a user to register and join the network with their phone number.
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: allowing the second mobile device corresponding to the participant to join the
`communication network, the allowing based on a determination regarding the second data.
`
`The Lyft server(s) perform this limitation when the server uses the account or identity information described above
`to add the account/rider/phone number/Lyft app for riders to the Lyft platform or network of drivers and passengers.
`The Lyft server(s) also perform this limitation when the server uses the account or identity information to create or
`activate or update an account using the account or identity information described above. The Lyft server(s) also
`perform this limitation when a rider completes the sign-in or log-in process. The Lyft server(s) also perform this
`step using a verification or validation process within sign-up, sign-in, or status request process. The account or
`identity information is associated with the Lyft platform or network of drivers and passengers or a subset of the
`platform or network.
`
`
`
`A-29
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 31 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Source: https://help.lyft.com/hc/e/articles/115012926947-How-to-create-a-Lyft-account
`
`
`
`
`A-30
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`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 32 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-31
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 33 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`1[F]. receiving
`vehicle
`data
`location
`provided by the
`first
`mobile
`device
`corresponding
`to the vehicle,
`wherein
`the
`vehicle
`data
`location
`are associated
`with the first
`identifier and
`indicate
`coordinates of
`a geographical
`location of the
`first
`mobile
`device
`
`Source: https://account.lyft.com/auth?next=https%3A%2F%2Fwww.lyft.com%2Flogin%2Fjump.
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: receiving vehicle location data provided by the first mobile device corresponding
`to the vehicle, wherein the vehicle location data are associated with the first identifier and indicate coordinates of a
`geographical location of the first mobile device.
`
`The Lyft server(s) perform this limitation when they receive driver location data associated with the account or
`identity information described above. This information is received at the Lyft server(s) via the Lyft app for drivers.
`For example, when a driver is online and ready to take request for rides, the driver’s app sends its location
`coordinates to the Lyft servers enabling the servers to match the driver with the nearby passengers. The location
`data of the driver is associated with his/her account or identity data described above, including but not limited to
`name, phone number and vehicle information. The driver’s location data comprises geographical coordinates or
`geotagged/geocoded/georeferenced information related to a driver’s geographical location.
`
`
`A-32
`
`

`

`
`
`Claim
`10,341,838
`
`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 34 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`A-33
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 35 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Driver’s location
`
`
`
`A-34
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 36 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`
`
`Driver’s location
`
`
`
`
`Provided certain conditions are met, users of the Rider and Driver Apps can share their location with other users
`of Driver and Rider Apps as well as additional contacts, friends, and family. Lyft encourages and instructs users
`of the Rider and Driver Apps to configure their phones to share their locations. The Driver and Rider Apps are
`pre-configured to show the location of riders and drivers and to update the locations continuously. For example,
`the Rider App provides rider locations to Lyft Servers in the forms of pickup locations and current locations and
`Lyft Servers transmit these locations to Driver Apps with ride requests and trip details. The Rider App can update
`the pickup locations and current locations and these location updates are similarly transmitted to Lyft Servers and
`
`A-35
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 37 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Driver Apps. In another example, the Driver App provides driver locations to Lyft Servers immediately during
`sign up or log in to the Driver App and continuously provides updates to the Lyft Servers before, during, and after
`rides. The Rider App can show the location of drivers before requesting a ride, after requesting a ride, after being
`matched with a particular driver, during the approach of the driver, and during the ride until the completion of the
`ride. In other circumstances, Rider and Driver Apps are configured by Lyft to permit users to share their locations
`with others by specifying contacts, friends, family members. In some instances, Lyft Servers create a link for
`distribution to others for access to maps containing shared locations from Lyft Servers. These shared locations
`permit others to track the locations of riders and drivers during rides provided by Lyft. Location sharing in Lyft’s
`products also enables features to view and share trip progress and to track locations and computed routes. These
`features are built in to the Rider and Driver Apps and serviced by Lyft Servers.
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: receiving participant location data provided by the second mobile device
`corresponding to the participant, wherein the participant location data are associated with the second identifier and
`indicate coordinates of a geographical location of the second mobile device.
`
`The Lyft server(s) perform this limitation when they receive rider location data associated with the account or
`identity information described above. This information is received at the Lyft server(s) via the Lyft app for riders.
`For example, when a passenger books a ride, the passenger’s Lyft app for riders sends its current location coordinates
`to the Lyft servers enabling the servers to match the passenger with the nearby drivers. The location data of the
`passenger is associated with his/her account or identity data described above including but not limited to username,
`email address and phone number.
` The rider’s location data comprises geographical coordinates or
`geotagged/geocoded/georeferenced information related to a rider’s geographical location.
`
`
`
`A-36
`
`1[G]. receiving
`participant
`data
`location
`provided by the
`second mobile
`device
`corresponding
`to
`the
`participant,
`wherein
`participant
`data
`location
`are associated
`with the second
`identifier and
`
`the
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 38 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
`
`
`
`-
`
`Claim
`10,341,838
`indicate
`coordinates of
`a geographical
`location of the
`second mobile
`device
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 3:27
`
`
`
`
`A-37
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 39 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 3:49
`
`
`
`A-38
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 40 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-39
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 41 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`A-40
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 42 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`See also 1[F].
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: sending participant data to the second mobile device corresponding to the
`
`1[H]. sending
`participant data
`
`A-41
`
`

`

`Case 5:21-cv-04653-BLF Document 104-2 Filed 04/18/22 Page 43 of 130
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
`
`participant, wherein the participant data comprise the vehicle location data, wherein the second mobile device
`corresponding to the participant is configured to (1) determine coordinates of a position on the participant map
`corresponding to the coordinates of the geographical location of the second mobile device, (2) display the participant
`map, and (3) place a first symbol on the participant map at the determined coordinates of the position on the
`participant map corresponding to the coordinates of the geographical location of the second mobile device.
`
`The Lyft server(s) communicates driver geographical location to the rider’s Lyft app. The rider’s lyft app is
`programmed to receive the driver location data and process it to display a map with a symbol indicating the driver’s
`location on the ma