Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 1 of 60
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` Exhibit 6
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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 2 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
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`Based on information presently available,1 Defendant AGIS Software Development LLC (“AGIS Software”) contends that
`
`Defendant Lyft Inc. (“Lyft” or “Plaintiff”) infringes claim 7 (the “Asserted Claim”) of U.S. Patent No. 7,031,728 (the “’728 Patent”)
`through the Accused Products, Services 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.
`
`D-1
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 3 of 60
`Attachment E for US Patent No. 7,031,728 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 Rider and Driver Apps are 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 does not concede that any claims of the ʼ728 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.
`
`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.
`
`
`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.
`
`D-2
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 4 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
`
`Claim – 7,031,728
`7[P]. A method of
`establishing a cellular
`phone communication
`network for designated
`participants, each having
`a similarly equipped
`cellular phone that
`includes voice
`communication, free and
`operator selected text
`messages, photograph and
`video, a CPU, a GPS
`navigation system and a
`touch screen display
`comprising the steps of:
`
`Exemplary Supporting Evidence Regarding Accused Products
`The Lyft Accused Products practice the method of establishing a cellular phone communication
`network for designated participants, each having a similarly equipped cellular phone that includes voice
`communication, free and operator selected text messages, photograph and video, a CPU, a GPS
`navigation system and a touch screen display.
`
`
`
`For example, Lyft provides Lyft app for passengers and 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. 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. The claimed methods are distributed by Lyft in the Lyft apps.
`The claimed methods are used/tested by Lyft using the Lyft apps. The claimed methods are downloaded
`and
`installed by Lyft’s customers
`(riders) and personnel
`(drivers, personnel) at
`the
`direction/encouragement of Lyft and used by Lyft’s customers and Lyft’s personnel.
`
`For example, when the passenger requests a ride from the Lyft app installed on their mobile phone, the
`ride request message is broadcasted to the nearby drivers who are online on the Lyft driver app. The
`message comprises the passenger’s name and profile photo.
`
`For example, when the driver accepts the ride request of the passenger, the passenger’s mobile phone
`receives the driver’s information such as name, location, and driver’s photo. After the passenger and
`the driver match, both of them get the option to text each other.
`
`
`E-3
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 5 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
` https://www.lyft.com/drive-with-lyft
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`E-4
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 6 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`Claim – 7,031,728
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`Exemplary Supporting Evidence Regarding Accused Products
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`
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` https://www.lyft.com/hub/posts/how-to-give-a-ride
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`E-5
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 7 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
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`E-6
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 8 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`
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`E-7
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 9 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`E-8
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 10 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`
`
`
`
`
`E-9
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 11 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://apps.apple.com/in/app/lyft/id529379082
`
`E-10
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`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 12 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
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`E-11
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 13 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`Claim – 7,031,728
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`Exemplary Supporting Evidence Regarding Accused Products
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`E-12
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 14 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
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`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.androidauthority.com/what-is-an-soc-smartphone-chipsets-explained-1051600/
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`E-13
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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 15 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`Claim – 7,031,728
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`Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.cashify.in/how-to-turn-off-gps-on-any-android-or-ios-device
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`E-14
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 16 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
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`
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`E-15
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 17 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`Claim – 7,031,728
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`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
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`
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`E-16
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 18 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`location when
`pickup
`location is set
`to current
`location
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`E-17
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 19 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`E-18
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`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 20 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`E-19
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 21 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`E-20
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`

`

`
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`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 22 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 11:21
`
`
`
`E-21
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`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 23 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
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`
`E-22
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 24 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`E-23
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`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 25 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`E-24
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 26 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`E-25
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`

`

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`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 27 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:32
`
`
`
`E-26
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`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 28 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
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`
`
`E-27
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`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 29 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
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`
`
`E-28
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`

`

`
`
`Claim – 7,031,728
`
`7[A] a) generating one or
`more symbols on the
`touch display screen, each
`representing a different
`participant that has a
`cellular phone that
`includes said voice
`communication, free and
`operator selected text
`messages, photograph and
`video, a CPU, said GPS
`system and a touch screen
`display;
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 30 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding 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.
`
`See Claim 7P above. The Lyft Accused Products practice generating one or more symbols on the touch
`display screen, each representing a different participant that has a cellular phone that includes said
`voice communication, free and operator selected text messages, photograph and video, a CPU, said
`GPS system and a touch screen display.
`
`This element is infringed literally, or in the alternative, under the doctrine of equivalents.
`
`For example, drivers’ and passengers’ mobile phones with the Lyft Driver and the Lyft app installed
`generates symbols including but not limited to blue dot denoting passenger’s location, blue navigate
`icon denoting driver’s location, and vehicle icons denoting nearby driver’s location on the display of
`the mobile phones.
`
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
`
`
`E-29
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`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 31 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.lyft.com/drive-with-lyft
`
`
`
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`
`E-30
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`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 32 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://apps.apple.com/in/app/lyft/id529379082
`
`E-31
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 33 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`
`E-32
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 34 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`E-33
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 35 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`E-34
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 36 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`
`
`E-35
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 37 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`location when
`pickup
`location is set
`to current
`location
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`E-36
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 38 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`E-37
`
`
`
`

`

`
`
`Claim – 7,031,728
`
`7[B]. b) providing and
`storing in each of the
`participant cellular
`phones one or more
`cellular phone telephone
`numbers, each cellular
`phone number of which
`relates to a different
`symbol of each of the
`participants in the
`communication network;
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 39 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding 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 practice providing and storing in each of the participant cellular phones one
`or more cellular phone telephone numbers, each cellular phone number of which relates to a different
`symbol of each of the participants in the communication network.
`
`This element is infringed literally, or in the alternative, under the doctrine of equivalents.
`
`For example, Lyft designates virtual numbers for each rider and driver when they join the Lyft
`network and initiate communications with each other. Lyft stores and provides the virtual phone
`numbers in the Lyft apps and/or the Lyft server(s). Respective phone numbers for each driver/rider is
`associated with the corresponding rider/driver and their symbols.
`
`
` https://help.lyft.com/hc/e/articles/115013081188
`
`
`E-38
`
`
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 40 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
` https://help.lyft.com/hc/e/articles/115012926947-How-to-create-a-Lyft-account
`
`
`
`
`E-39
`
`

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`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 41 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`E-40
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 42 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`E-41
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 43 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`
`
`E-42
`
`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 44 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`location when
`pickup
`location is set
`to current
`location
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`E-43
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 45 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`E-44
`
`
`
`

`

`
`
`Claim – 7,031,728
`
`7[C]. c) providing
`initiating cellular phone
`calling software in each
`cellular phone that is
`activated by touching a
`symbol on the touch
`display that automatically
`initiates a cellular phone
`call using the stored
`cellular phone number to
`the participant
`represented by the
`symbol; and
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 46 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding 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.
`
`With respect to the limitations reciting the cellular phone number(s) or telephone number(s), the claim
`is met either literally or under the doctrine of equivalents.
`The Lyft Accused Products practice providing initiating cellular phone calling software in each cellular
`phone that is activated by touching a symbol on the touch display that automatically initiates a cellular
`phone call using the stored cellular phone number to the participant represented by the symbol.
`
`This element is infringed literally, or in the alternative, under the doctrine of equivalents.
`
`For example, the Lyft app provides selectable interface elements within the Lyft app to call the
`rider/driver represented by a symbol. For example, when the driver is matched to the passenger, both
`the driver and the passenger receive the call icon on their respective Lyft apps through which both the
`driver and the passenger are given the functionality to call each other from within the apps. The call is
`placed using a virtual phone number.
`
`
`E-45
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 47 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`E-46
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 48 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`
`
`E-47
`
`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 49 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`E-48
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 50 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`
`
`E-49
`
`

`

`
`
`Claim – 7,031,728
`
`7[D]. d) generating a
`geographical location
`chart on said display
`screen to show the
`geographical location of
`each of the symbols
`representing the
`participants in the
`communication network
`by latitude and longitude.
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 51 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding 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
`With respect to the limitations reciting the cellular phone number(s) or telephone number(s), the claim
`is met either literally or under the doctrine of equivalents.
`The Lyft Accused Products practice generating a geographical location chart on said display screen to
`show the geographical location of each of the symbols representing the participants in the
`communication network by latitude and longitude.
`
`This element is infringed literally, or in the alternative, under the doctrine of equivalents.
`
`Lyft meets this limitation because it generates a display with a geographical map presenting symbols
`representing drivers/riders in the Lyft platform/network. A person of ordinary skill In the art would
`understand that a map is a type of chart. The symbols are presented in the geographical map based on
`their respective latitude and longitude. For example, drivers’ and passengers’ mobile phones with the
`Lyft Driver and the Lyft app installed generates symbols for riders/drivers. The maps in Lyft and Lyft
`Driver app also highlight the facility symbols such as a park, airport, and shops. The map in the Lyft
`app shows the location of the pickup address and the destination address when the passenger requests
`the ride.
`
`
`E-50
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 52 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`E-51
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 53 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`
`
`E-52
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 54 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`location when
`pickup
`location is set
`to current
`location
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`E-53
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 55 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`E-54
`
`
`
`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 56 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`E-55
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 57 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`
`
`
`
`E-56
`
`

`

`
`
`Claim – 7,031,728
`
`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 58 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`E-57
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 59 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`E-58
`
`
`
`

`

`Case 5:21-cv-04653-BLF Document 104-6 Filed 04/18/22 Page 60 of 60
`Attachment E for US Patent No. 7,031,728 Against Lyft Accused Products
`
`Claim – 7,031,728
`
`Exemplary Supporting Evidence Regarding 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.
`
`
`
`
`See Claim 7[A] above.
`
`
`
`
`
`
`E-59
`
`