Exhibit G
`Exhibit G
`
`

`

`
`
`Alfred R. Fabricant
`afabricant@fabricantllp.com
`Peter Lambrianakos
`plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue, Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Benjamin T. Wang
`bwang@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-9226
`
`Attorneys for Defendant
`AGIS Software Development LLC
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`LYFT, INC.,
`
`
`
`
`v.
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Defendant.
`
`
`
`Plaintiffs,
`
` Case No. 5:21-cv-04653-BLF
`
`DEFENDANT AGIS SOFTWARE
`DEVELOPMENT LLC’S DISCLOSURE
`OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS
`
`Hon. Judge Beth Labson Freeman
`
`
`
`
`
`
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`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`5:21-cv-04653-BLF
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`Defendant AGIS Software Development LLC (“AGIS Software”) hereby makes the
`following infringement disclosure under the Patent Local Rules with respect to United States Patent
`Nos. 7,031,728; 7,630,724; 8,213,970; 10,299,100; and 10,341,838 (collectively, the “Patents-in-
`Suit”). AGIS Software’s investigation is ongoing, and discovery has not yet commenced. 1
`Accordingly, these disclosures are based on information available to AGIS Software at this time.
`AGIS Software reserves the right to supplement this disclosure after further discovery regarding the
`Lyft Accused Products set forth below. AGIS Software also reserves the right to assert additional
`claims of the Patents-in-Suit, accuse different products, or find literal and/or equivalent infringing
`elements in the Lyft Accused Products.
`I. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`PURSUANT TO PATENT LOCAL RULE 3-1
`A. ASSERTED CLAIMS
`Plaintiff Lyft Inc. (“Plaintiff” or “Lyft”) has infringed and continues to infringe at least the
`following claims of the Patents-in-Suit in connection with the Lyft Accused Products set forth
`below:
`
`• Claim 7 of U.S. Patent No. 7,031,728 (the “’728 Patent”);
`• Claims 9, 12-16 of U.S. Patent No. 7,630,724 (the “’724 Patent”);
`• Claims 2, 10, 12-13 of U.S. Patent No. 8,213,970 (the “’970 Patent”);
`• Claims 1-31 of U.S. Patent No. 10,299,100 (the “’100 Patent”); and
`• Claims 1-26 of U.S. Patent No. 10,341,838 (the “’838 Patent”).
`AGIS Software reserves the right to seek leave of court to add, delete, substitute, or
`otherwise amend this list of asserted claims should further discovery, the Court’s claim construction,
`or other circumstances so merit.
`B. ACCUSED INSTRUMENTALITIES
`AGIS Software is currently aware that the following Lyft Products infringe each of the
`Patents-in-Suit, either alone or in concert with one or more other Lyft Accused Products:
`• Lyft applications, services, and servers;
`
`2
`
`1 There is no operative complaint in this action, and AGIS has not filed an answer.
`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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`• Lyft Driver applications, services, and servers; and
`• Lyft servers related to Lyft applications and Lyft Driver applications.
`AGIS Software reserves the right to amend this list of accused instrumentalities, as well as
`other information contained in this document and the exhibits hereto, to incorporate new information
`learned during the course of discovery including, but not limited to, the inclusion of newly-released
`products or any other equivalent devices ascertained through discovery.
`C. CLAIM CHARTS
`Claim charts identifying a location of every element of every asserted claim of the Patents-
`in-Suit within Lyft Accused Products are attached hereto as Exhibits A-E. AGIS Software believes
`that the citations in the claim charts are representative of all Lyft Accused Products. For example,
`where AGIS Software cites reference material or images representing an application, service, or
`server that citation is representative for all other such applications, services, or servers including all
`prior and future versions unless otherwise noted. AGIS Software reserves the right to amend these
`claim charts as well as other information contained in this document and the exhibits hereto, to
`incorporate new information learned during the course of discovery including, but not limited to,
`information that is not publicly available or readily discernible without discovery. AGIS Software
`further reserves the right to amend these claim charts, as well as other information contained in this
`document and the exhibits attached hereto, pursuant to Patent Local Rules 3-1(g) and 3-6.
`D. LITERAL INFRINGEMENT AND DOCTRINE OF EQUIVALENTS
`AGIS Software asserts that, under the proper construction of the asserted claims and their
`claim terms, the limitations of the asserted claims of the Patents-in-Suit are literally present in the
`Lyft Accused Products as set forth in the claim charts attached hereto as Exhibits A-E. AGIS
`Software contends that any and all elements found not to be literally infringed are infringed under
`the doctrine of equivalents because the differences between the claimed inventions and the accused
`instrumentalities, if any, are insubstantial.
`AGIS Software contends that Lyft directly infringes the asserted claims by making, using,
`offering for sale, selling, and importing into the United States the accused instrumentalities as well
`
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`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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`as indirectly infringe by contributing to and/or inducing others (e.g., Lyft customers or its Lyft
`customers’ customers) to directly infringe those claims by making, using, offering for sale, or selling
`the Lyft Accused Products. AGIS Software contends that Lyft directly infringes the asserted claims
`by testing the Lyft Accused Products in the United States.
`Pursuant to Patent Local Rule 3-6(a), AGIS Software reserves the right to amend its
`Infringement Contentions as to literal infringement or infringement under the doctrine of
`equivalents, e.g., in light of the Court’s claim construction.
`E. PRIORITY DATES
`Under Patent Local Rule 3-1(f), each of the asserted claims of the Patents-in-Suit are entitled
`to a priority date of at least as early as September 21, 2004. 2 For the purposes of this case only,
`AGIS Software intends to assert the following priority dates to earlier applications:
`• April 17, 2006 for Claims 1-31 of U.S. Patent No. 10,299,100 (the “’100 Patent”);
`and
`• April 17, 2006 for Claims 1-26 of U.S. Patent No. 10,341,838 (the “’838 Patent”)
`With the identification of these priority dates, AGIS does not waive the right to assert earlier
`priority dates to earlier applications. AGIS Software reserves the right to establish an earlier date
`of invention based upon actions related to conception and reduction to practice of the claimed
`inventions.
`F. PRACTICING PRODUCTS
`Pursuant to Patent Local Rule 3-1(g), AGIS Software contends that licensee AGIS, Inc.’s
`LifeRing products are covered by at least one of claim 7 of the ’728 Patent; claims 9, 12-16 of the
`’724 Patent; claims 2, 10-13 of the ’970 Patent; claims 1-31 of the ’100 Patent; and claims 1-26 of
`the ’838 Patent. AGIS is not aware of any other licensee that practice any claim of the Patents-in-
`Suit. AGIS Software’s investigation is ongoing and AGIS Software reserves the right to
`supplement, amend, or amend these contentions in view of facts learned during discovery, the
`
`2 AGIS continues to rely on interim priority dates identified in each of the Patents-in-Suit to establish
`priority prior to the actual filing date of the Patents-in-Suit.
`
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`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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`release of new products, or the modification of current products, and/or the Court’s claim
`construction.
`Pursuant to Patent Local Rule 3-1(h), while there is no operative complaint and AGIS has
`not filed an answer, the first date of infringement appears to be at or around May 2012 and AGIS
`reserves the right to seek past damages up to six years before the filing of any counterclaim in this
`action. AGIS Software’s investigation is ongoing and AGIS Software reserves the right to
`supplement, amend, or amend these contentions in view of facts learned during discovery and after
`the filing of the amended complaint.
`Pursuant to Patent Local Rule 3-1(i), while there is no operative complaint and AGIS has
`not filed an answer, Lyft’s infringement of the Asserted Patents has been willful since January 29,
`2021, when it received a complaint in AGIS Software Development LLC v. Lyft Inc. 2:21-cv-
`00024 (E.D. Tex., Jan. 29, 2021), and continues to be willful. AGIS Software’s investigation is
`ongoing and AGIS Software reserves the right to supplement, amend, or amend these contentions
`in view of facts learned during discovery and after the filing of the complaint.
`G. PRODUCTION OF DOCUMENTS PURSUANT TO PATENT LOCAL RULE
`3-2
`
`AGIS Software is producing or making available for inspection documents that are in AGIS
`Software’s possession, custody, or control as set forth in Patent Local Rule 3-2. An AGIS Software
`3-2 Production Index identifying these documents is attached hereto.
`This preliminary identification of documents is for convenience and is not an admission that
`each document falls within any exemplary categories in the Patent Local Rules, or that any
`document qualifies as prior art. AGIS Software is continuing with its investigation, particularly
`with respect to ESI. Thus, AGIS Software reserves its right to add to, delete from, or otherwise
`modify its disclosures in this section as its investigation proceeds.
`Production of these documents is governed by Patent Local Rule 2-2, and, with the exception
`of documents produced pursuant to P.R. 3.2(c) and public documents listed in the infringement
`charts, are considered “Highly Confidential –Attorneys Eyes Only” and disclosure of the
`
`
`
`
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`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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`

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`confidential document or information shall be limited to each party’s outside attorney(s) of record
`and the employees of such outside attorney(s).
`
`DATED: February 25, 2022
`
`
`
`
`
`Respectfully submitted,
`
`RUSS AUGUST & KABAT
`By: /s/ Benjamin T. Wang
`
`
` Benjamin T. Wang
`
`FABRICANT LLP
`Alfred R. Fabricant
`ffabricant@fabricantllp.com
`Peter Lambrianakos
`plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`vrubino@fabricantllp.com
`411 Theodore Fremd Avenue, Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
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`Attorneys for Defendant
`AGIS Software Development LLC
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`CERTIFICATE OF SERVICE
`The undersigned hereby certified that a true and correct copy of the above and foregoing
`
`document has been served via electronic mail on February 25, 2022, to all counsel of record.
`I declare under the penalty of perjury that the foregoing is true and correct.
`
`DATED: February 25, 2022
`
`
`
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`/s/ Benjamin T. Wang
` Benjamin T. Wang
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`6
`DEFENDANT AGIS SOFTWARE’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`

`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.
`
`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.
`
`
`1 There is no operative complaint asserting non-infringement of any patent claim in this action at this time. AGIS Software reserves
`the right to update its contentions upon receipt of any future amended complaint.
`
`A-1
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`
`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. 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.
`
`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.
`
`A-2
`
`

`

`
`
`-
`
`Claim
`10,341,838
`1[P]. A method
`performed by
`one or more
`servers
`each
`having one or
`more
`processors, the
`method
`comprising:
`
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
`
`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-3
`
`
`
`
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`
`A-4
`
`

`

`
`
`Claim
`10,341,838
`
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`A-5
`
`

`

`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 4:01
`
`
`
`A-6
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`
`
`Claim
`10,341,838
`
`
`
`A-7
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`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
`operations
`comprising:
`
`A-8
`
`

`

`
`
`Claim
`10,341,838
`
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`Accused Products
`
`or decline. The servers further facilitate the communication between the passenger and the allocated driver during
`a ride.
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`A-9
`
`

`

`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 4:01
`
`
`
`A-10
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`-
`
`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: obtaining first data provided by a first mobile device corresponding to a vehicle,
`the first data including a first identifier.
`
`
`
`1[B]. obtaining
`first
`data
`provided by a
`first
`mobile
`device
`corresponding
`
`A-11
`
`

`

`
`
`-
`
`Claim
`10,341,838
`to a vehicle, the
`first
`data
`including a first
`identifier
`
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
`
`Accused Products
`
`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.
`
`Source: https://www.lyft.com/driver.
`
`
`
`A-12
`
`

`

`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`Claim
`10,341,838
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`
`A-13
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`

`

`
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`Claim
`10,341,838
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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`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
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`A-14
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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`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.
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`
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`A-15
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`

`
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`Claim
`10,341,838
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`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
`
`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`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-16
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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`Claim
`10,341,838
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`Source: https://www.lyft.com/driver.
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`A-17
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`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-18
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`

`
`
`Claim
`10,341,838
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`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
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`

`

`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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`
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`-
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`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
`
`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.
`
`
`A-21
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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`Claim
`10,341,838
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`Source: https://help.lyft.com/hc/e/articles/115012926947-How-to-create-a-Lyft-account.
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`A-22
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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`Claim
`10,341,838
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`
`
`A-23
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`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-24
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`

`

`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-25
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`

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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`Accused Products
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`
`
`Claim
`10,341,838
`
`
`
`A-26
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`

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`Attachment A for US Patent No. 10,341,838 Against Lyft Accused Products
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`-
`
`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 correspo