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`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 1 of 12
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`
`
`BAKER BOTTS L.L.P.
`Jeremy J. Taylor (SBN 249075)
`jeremy.taylor@bakerbotts.com
`Arya Moshiri (SBN 324231)
`arya.moshiri@bakerbotts.com
`101 California St., Ste. 3600
`San Francisco, CA 94111
`Telephone: 415.291.6200
`Facsimile: 415.291.6300
`Bethany R. Salpietra (pro hac vice)
`bethany.salpietra@bakerbotts.com
`2001 Ross Ave., Ste. 900
`Dallas, TX 75201
`Telephone: 214.953.6500
`Facsimile: 214.953.6503
`
`Attorneys for Plaintiff Lyft, Inc.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`Case No. 5:21-cv-04653-BLF
`
`
`LYFT, INC.
`
`Plaintiff,
`
`v.
`AGIS SOFTWARE DEVELOPMENT LLC,
`Defendant.
`
`
`
`
`
`
`
`
`
`
`
`
`PLAINTIFF LYFT, INC.’S NOTICE OF
`MOTION AND OPPOSED MOTION TO
`COMPEL DISCOVERY AND
`COMPLIANCE WITH LOCAL PATENT
`RULES
`
`
`Date: July 28, 2022
`Time: 9:00 AM
`Judge: Hon. Beth Labson Freeman
`Trial Date: October 16, 2023
`Courtroom: 3, Fifth Floor
`
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 1
`
`Case No. 5:21-cv-04653-BLF
`
`

`

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`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 2 of 12
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`NOTICE OF MOTION AND MOTION
`Plaintiff Lyft, Inc. (“Lyft”) hereby gives notice that on July 28, 2022 at 9:00 A.M., in
`Courtroom 3, Fifth Floor, of the United States District Court for Northern District of California, San
`Jose Division, located at 280 South First Street, San Jose, California, or as soon thereafter as counsel
`may be heard, a hearing will be held by the Honorable Beth Labson Freeman, United States District
`Judge, on Lyft’s Motion to Compel Discovery and Compliance with Local Patent Rules in this
`action.
`
`Through this Motion, Lyft moves to compel AGIS Software Development LLC to: (1)
`comply with its obligations set forth under Patent Local Rule 3-2 and (2) provide full and accurate
`responses to Lyft’s discovery pursuant to this Court's Order (Dkt. 61).
`This Motion is based on the following Memorandum of Points and Authorities, the
`accompanying declaration of Arya Moshiri, the pleadings and records on file in this action, and such
`other written and/or oral arguments as may be presented at or before the time this Motion is taken
`under submission by the Court.
`
`
`
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 1
`
`Case No. 5:21-cv-04653-BLF
`
`

`

`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 3 of 12
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`MEMORANDUM OF POINTS AND AUTHORITIES
`Plaintiff Lyft, Inc. (“Lyft”) respectfully requests that the Court order Defendant AGIS
`Software Development LLC (“AGIS Software”) to comply with its obligations set forth under Patent
`Local Rule 3-2 (“Patent L.R. 3-2”) and to compel full and accurate responses to Lyft’s discovery
`served pursuant to this Court’s Order (Dkt. 61).
`On February 25, 2022, AGIS Software served its Patent Local Rule 3-2 production but failed
`to produce, and continues to refuse to produce, certain categories of documents required under the
`Local Rules, including patent licenses, conception and reduction to practice materials, and
`documents evidencing third-party disclosures of the alleged invention. AGIS has provided no
`reason for withholding these categories of materials.
`On January 28, 2022 the Court granted Lyft discovery into “AGIS Software’s patent
`enforcement communications with California companies.” Dkt. 61 at 9. Despite having license
`agreements with at least
` companies located or operating out of California and ongoing
`enforcement activities against three others, AGIS Software claims it never communicated or had
`any interaction with these companies. AGIS Software bases its refusal to produce these relevant
`materials on its belief that it need not produce non-privileged communications handled by AGIS
`Software’s attorneys hired to handle its enforcement and licensing efforts.
`On January 29, 2022, the Court also granted discovery “regarding the relationship between
`AGIS Software, AGIS, Inc., and AGIS Holdings and their contacts with California.” Id. Despite
`serving interrogatories to AGIS Software and subpoenas to AGIS Holdings and AGIS, Inc. seeking
`this information, the AGIS affiliates collectively refused to provide any information about AGIS
`Holdings or AGIS, Inc. because they were not named in the original complaint and because Lyft
`had not yet filed an amended complaint, even though this is precisely why the Court ordered
`discovery.
`This is not the first case between AGIS and Lyft. AGIS Software initially brought suit
`against Lyft in the Eastern District of Texas alleging infringement of the same five patents at issue
`here. See AGIS Software Development LLC v. Lyft, Inc., 2:21-cv-00024-JRG (E.D.T.X.) (later
`consolidated with 2:21-cv-00072-JRG (E.D.T.X.)) (hereinafter referred to as “the EDTX Action”).
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 2
`
`Case No. 5:21-cv-04653-BLF
`
`

`

`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 4 of 12
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`The EDTX Action proceeded to the expert report phase before Judge Payne issued an order
`recommending dismissal of the case for improper venue, which was subsequently adopted by Judge
`Gilstrap. Dkts. 212 & 235, Case No. 2:21-cv-00072-JRG. Despite the broad discovery already
`taken in the EDTX Action and AGIS Software’s assurances at the case management conference that
`“we can work through this issue very quickly,” AGIS Software still refuses to allow discovery taken
`in the EDTX Action to be used in this case without onerous and unacceptable conditions. See Jan.
`27, 2022 Case Management Conference Hearing Tr. (“CMC Hearing Tr.”) at 35:3-8.
`As a result of AGIS’s failure to fulfill its obligations under the Patent Local Rules and the
`Court’s order, Lyft has been forced to unnecessarily repeat discovery previously taken in the EDTX
`Action and file this motion to compel production of relevant information that is readily accessible
`to AGIS Software, much of which was likely produced in the EDTX Action, and information that
`AGIS Software is under independent obligation to produce in this case. AGIS Software’s refusal to
`comply with its discovery obligations and the requirements of the Patent Local Rules prejudices
`Lyft’s ability to prepare its amended complaint and prepare defenses.
`The Court granted an expedited case schedule with deadlines, shorter than those provided
`under the Patent Local Rules, based on AGIS Software’s assurances of a smooth discovery process
`that was “virtually complete” due to the advanced stages of the EDTX Action. CMC Hearing Tr.
`at 49:19-50:2. AGIS Software’s refusal to provide discovery from the EDTX Action, refusal to
`produce materials required under the Patent Local Rules, and refusal to produce the discovery
`specifically ordered by this Court, however, jeopardizes the current case schedule and calls into
`question AGIS Software’s assurance that the parties would be able to work through discovery
`disputes “very quickly.” CMC Hearing Tr. at 35:4-5.
`For the reasons explained herein, Lyft respectfully moves the Court to compel AGIS
`Software to comply with AGIS’s obligations under the Patent Local Rules and to provide complete
`responses to Lyft’s discovery requests specifically ordered by this Court.
`I.
`STATEMENT OF FACTS
`On January 28, 2022, the Court found that Lyft had “presented sufficient facts to justify
`jurisdictional discovery” regarding its claim that AGIS Software is an alter ego of its affiliates
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 3
`
`Case No. 5:21-cv-04653-BLF
`
`

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`Advanced Ground Information Systems, Inc. (“AGIS, Inc.”) and AGIS Holdings, Inc. (“AGIS
`Holdings”) and granted Lyft leave to pursue jurisdictional discovery “regarding the relationship
`between AGIS Software, AGIS, Inc., and AGIS Holdings and their contacts with California. Dkt.
`61 at 9. The Court also found that Lyft had established “a ‘colorable’ basis for personal jurisdiction”
`under Trimble v. PerDiemCo LLC, 997 F.3d 1147 (9th Cir. 2021)), and granted Lyft leave to pursue
`jurisdictional discovery to seek more facts regarding AGIS Software’s patent enforcement
`communications with California companies. Id. The Order specifically granted Lyft’s request for
`jurisdictional discovery in the form of five interrogatories and one four-hour Rule 30(b)(6)
`deposition. Id. at 10.
`Pursuant to the Court’s order, Lyft served a 30(b)(6) notice and five jurisdictional
`interrogatories on AGIS Software on February 4, 2022. See Exs. 11 & 12. Simultaneously, Lyft
`issued document and deposition subpoenas to AGIS, Inc. and AGIS Holdings, which included
`requests that are coextensive with the interrogatories and deposition topics directed at AGIS
`Software. See Exs. 13 & 14.
`On February 14, 2022, the Court issued a case schedule setting a February 25, 2022 deadline
`for AGIS Software to serve infringement contentions and its accompanying document production
`specified in Patent Local Rule 3-2.
`II.
`ARGUMENT
`A. AGIS Software’s Deficient Patent L.R. 3-2 Production
`Patent L.R. 3-2 requires the production of numerous categories of documents, including:
` “All agreements, including licenses, transferring an interest in any patent-in-suit”
`(Patent L.R. 3-2(f));
` documents “sufficient to evidence each discussion with, disclosure to, or other
`manner of providing to a third party, or sale of or offer to sell, or any public use of,
`the claimed invention prior to the date of application for the patent in suit” (Patent
`L.R. 3-2(a)); and
` “documents evidencing the conception, reduction to practice, design, and
`development of each claimed invention” (Patent L.R. 3-2(b)).
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 4
`
`Case No. 5:21-cv-04653-BLF
`
`

`

`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 6 of 12
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`Despite its obligations under the Patent Local Rules, AGIS Software has not produced any
`documents for at least these categories.
`Agreements of the kind contemplated by Patent L.R. 3-2(f) do exist, as confirmed by AGIS
`Software’s 30(b)(6) witness and public statement by AGIS Software or its affiliates. See, e.g., Ex.
`18 (March 22, 2022 Deposition Tr. of Thomas Meriam) at 44:14-45:4, 50:23-52:12 (
`
`
`); 2:21-cv-00024-JRG, Dkt. 1 (“AGIS Software licenses its patent portfolio,
`including the ’970, ’724, ’728, ’838, and ’100 Patents, to AGIS, Inc. AGIS, Inc. has marked its
`products accordingly.”); Ex. 2 (“LifeRing applications, solutions, and software products are covered
`by patents licensed from AGIS Software Development LLC.”); Ex. 1 (describing, in a press release,
`that “Facebook and WhatsApp have received a license to access AGIS’s patent portfolio”). Despite
`acknowledging the existence of license agreements, AGIS Software did not produce a single license
`agreement in its Patent Local Rule 3-2 production.
`AGIS Software also possesses documentation evidencing the “conception, reduction to
`practice, design and development of each claimed invention” (Patent L.R. 3-2(b)) as it has relied on
`such documentation to establish alleged priority dates in public proceedings. See, e.g., Ex. 3 at 5-
`150 (explaining AGIS Software’s conception and reduction to practice evidence for a related patent,
`which specifically identifies features recited in claims of the patents-in-suit such as “display user’s
`phone’s and other users’ phones’ location,” “establishing voice and data communications with other
`participants by interacting with the symbols,” and “transmitting messages and multimedia between
`participants”). No such documentation was provided in AGIS Software’s Patent Local Rule 3-2
`production.
`Likewise, AGIS Software also possesses—and did not produce—documentation evidencing
`disclosures of the claimed inventions that pre-date the filing date of applications of the patents-in-
`suit (Patent L.R. 3-2(a)). As recognized by AGIS Software in its infringement contentions, the
`LifeRing products, which both AGIS, Inc. and AGIS Software claim as their own product, practice
`claims of the patents-in-suit. See Ex. 4 at 4; Ex. 3, ¶¶ 5 & 7. Malcolm K. Beyer, AGIS Software’s
`CEO and inventor of the patents-in-suit, submitted a declaration to the United States Patent and
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 5
`
`Case No. 5:21-cv-04653-BLF
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`Trademark Office identifying and describing various third-party disclosures of the LifeRing
`products, which was accompanied by documentation evincing such disclosures. See Ex. 3; see also
`Exs. 5; 6; 7. Yet, AGIS Software produced no such documentation.
`The sufficiency of AGIS Software’s 3-2 production in this case is further belied by its 3-2
`production in the EDTX Action. Notably, the first three categories of documents in the Northern
`District of California’s (“NDCA”) Patent L.R. 3-2, 3-2(a) through 3-2(c), are coextensive with the
`entirety of the Eastern District of Texas (“EDTX”) Patent Local Rule 3-2. See Ex. 8 (E.D. Tex.
`Patent Local Rule 3-2); Ex. 9 (N.D. Cal. Patent Local Rule 3-2). NDCA Patent Local Rule 3-2
`includes an additional seven categories of documents, Patent L.R. 3-2(d) – (j), beyond those required
`in EDTX that must also be produced. See Ex. 9. Despite the fact that the NDCA Local Patent Rules
`require the production of substantially more documents than in EDTX, AGIS Software’s 3-2
`production in this case contained about 5,000 pages less than AGIS Software’s 3-2 production in
`the EDTX Action, which comprised nearly 8,000 pages. AGIS Software provided no explanation
`for why nearly 5,000 documents relevant to its Patent L.R. 3-2 production would not also be relevant
`to its NDCA Patent L.R. 3-2 production, and AGIS Software’s lack of response and omission of at
`least the specifically identified documents suggests that AGIS Software is intentionally withholding
`these documents in violation of the duties it owes this Court and Lyft.
`B. AGIS Software’s Deficient Response to Lyft’s Jurisdictional Interrogatory
`No. 1
`To demonstrate jurisdiction over AGIS Software and its alter egos AGIS Holding and AGIS,
`Inc., Lyft served Interrogatory No. 1, copied below, pursuant to the Court’s January 28, 2022 order
`granting discovery “regarding the relationship between AGIS Software, AGIS, Inc., and AGIS
`Holdings and their contacts with California”:
`
`JURISDICTIONAL INTERROGATORY NO. 1
`Identify all interactions, including Communications, between AGIS Software,
`AGIS Holdings, Inc., and/or AGIS, Inc. and any Person, company, or entity
`located, based, or incorporated in California from 2015 to the present, including but
`not limited to customers or potential customers of AGIS, Inc., licensees or potential
`licensees of AGIS Software and/or AGIS, Inc., law enforcement agencies, fire
`departments, first responders, state and local government agencies or departments,
`current and former members of the military, the State of California and any of its
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 6
`
`Case No. 5:21-cv-04653-BLF
`
`

`

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`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 8 of 12
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`departments or divisions, ADI Technologies, Inc., Maven Research, Inc. or “Maven
`Consulting”, CornerTurn LLC, Integrity Applications, Inc., American Reliance
`Inc., Green Hills Software LLC, Life360, Inc., Apple Inc., WhatsApp LLC,
`Facebook, Inc., Google LLC, Smith Micro Software LLC, T-Mobile U.S., Inc.,
`Waze LLC, HTC Corporation and Samsung Electronics America, Inc. and/or Uber
`Technologies, Inc. d/b/a UBER (“Uber”).
`
`
`In response to Interrogatory No. 1, AGIS Software
`. See Ex. 10 at 6-9. Based on publicly available information
`and AGIS Software’s 30(b)(6) witness, however, this is not accurate. AGIS Software has entered
`into license agreements
`
`
`. Ex. 18 at 44:14-45:4, 50:23-52:12. It is not possible that AGIS Software executed
`even one of these licenses without communications to and from the licensee.
`Through meet and confers and based on testimony from AGIS Software’s 30(b)(6) witness,
`it has become clear that AGIS Software is improperly withholding non-privileged communications
`made by AGIS Software’s agents, including its attorneys specifically hired to enforce and negotiate
`license agreements to its patents. AGIS Software’s position is untenable, as a company only acts
`through its employees, officers, and other agents, including its attorneys.
`
`
`
`
`
`, and AGIS Software continues to refuse to provide
`discovery into these communications. See generally Ex. 18 at 55:6-69:21.
`The Federal Circuit has confirmed that AGIS Software’s communications or other
`interactions with licensees located or operating in California are particularly relevant to the current
`jurisdictional inquiry. See Trimble Inc. v. PerDiemCo LLC, 997 F.3d 1147, 1156 (Fed. Cir. 2021).
`Trimble specifically identified nonexclusive license agreements and communications sent into the
`jurisdiction from outside as relevant to the jurisdictional inquiry in a patent infringement case. Id.
`(“just as sales of similar vehicles and the presence of dealerships in a forum can support personal
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 7
`
` Ex. 18 at 212:23-213:3.
`
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`jurisdiction in the tort context, so too can nonexclusive patent licenses”); id. at 1155 (“[t]he Supreme
`Court has held that communications sent into a state may create specific personal jurisdiction,
`depending on the nature and scope of such communications”).
`Interrogatory No. 1 also seeks information proportional to the needs of the case. As
`discussed previously, the information sought by this interrogatory is directly relevant to Lyft’s claim
`that this Court has personal jurisdiction over AGIS Software, and AGIS Software is best situated to
`provide this information. Furthermore, if AGIS Software lacks minimum contacts with California,
`as it asserts, the burden and expense associated with providing a full and accurate response to this
`interrogatory would be low. Accordingly, the benefit of Lyft’s proposed discovery outweighs any
`burden or expense to AGIS Software. In view of the foregoing, Lyft’s jurisdictional Interrogatory
`No. 1 seeks information that is both relevant and proportional to the needs of the case, and Lyft
`respectfully requests this Court compel AGIS Software to provide a full and accurate response to
`this interrogatory and additional time to depose AGIS Software on this topic. Specifically, Lyft
`requests an identification of all communications or other interactions between AGIS Software
`(including its employees, officers, and/or agents, such as attorneys) and any company or individual
`located in California (including a company’s employees, officers, and/or agents), specifically
`communications involved in negotiating and executing licenses to AGIS Software’s patents.
`C. AGIS Software’s Failure to Provide Discovery from Its Affiliates
`In addition to communications by AGIS Software, Lyft’s Interrogatory No. 1 also seeks
`communications and interactions by AGIS Software’s affiliates and alter egos AGIS, Inc. and AGIS
`Holdings. The Court specifically recognized Lyft’s alter ego theory and permitted discovery into
`“the relationship between AGIS Software, AGIS, Inc., and AGIS Holdings and their contacts with
`California.” Dkt. 61 at 9. Instead of identifying the communications and other interactions for all
`three affiliates, however,
`
`
`
`Ex. 10 at 2.
`Despite having the same CEO and officers and being represented by the same attorneys,
`
`
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 8
`
`Case No. 5:21-cv-04653-BLF
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` See id. at 8–9.
`
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`
`, AGIS Software’s gamesmanship is readily apparent.
`That Mr. Malcolm K. Beyer, Jr. is the CEO of both AGIS Software and AGIS, Inc. and has sworn
`that he has “knowledge of all facets of the businesses” of both AGIS Software and AGIS, Inc. further
`calls into question the motivation behind AGIS Software’s refusal to respond to this discovery. Ex.
`3, ¶ 6 (“As the CEO of AGIS and AGIS Inc. and first-named inventor of the ’838 patent, I have
`knowledge of all facets of the businesses”); see also Ex. 17, ¶ 5 (“As the CEO of AGIS and AGIS
`Inc. and first-named inventor of the Patents-in-Suit, I will be one of AGIS’s primary witnesses
`because I have knowledge of the businesses”). AGIS Software has no legitimate basis to refuse to
`provide discovery concerning LifeRing’s deployments and tests, including by first responders and
`military operational environments, which likely occurred in California, that AGIS, Inc. publicly
`touts and are well known to AGIS Software’s CEO, Malcom K. Beyer, Jr. Id., ¶ 11.
`In anticipation of AGIS Software’s tactics, Lyft served parallel subpoenas on both AGIS
`Holdings and AGIS, Inc., via document and testimony requests seeking the same information sought
`in Interrogatory No. 1 and related 30(b)(6) topics from AGIS Software. Compare Exs. 11 & 12 with
`Exs. 13 & 14. On March 16, 2022, AGIS Holdings and AGIS, Inc. served objections to Lyft’s
`subpoenas, taking the position that no documents or witnesses would be produced pursuant to the
`subpoena because the subpoena requests allegedly “exceed the scope of jurisdictional discovery
`ordered by the Court.” See generally, Exs. 15 & 16.
`AGIS’s position is directly contrary to this Court’s order which specifically granted “Lyft
`leave to pursue jurisdictional discovery regarding the relationship between AGIS Software, AGIS,
`Inc., and AGIS Holdings and their contacts with California.” Dkt. 61. As previously discussed, the
` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 9
`
`Case No. 5:21-cv-04653-BLF
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`requests enumerated in Lyft’s subpoenas to AGIS Holdings and AGIS, Inc. are relevant to the
`underlying personal jurisdiction inquiry under Lyft’s alter ego theory and do not exceed the
`discovery limits provided by the Court, because the requests are coextensive with and mirror the
`interrogatories and deposition topics directed at AGIS Software. Because Lyft’s alter ego theory
`concerns information about AGIS Holdings and AGIS, Inc., discovery from both these entities is
`warranted if the requested discovery is not provided by AGIS Software. The discovery is
`proportional to the needs of this case as the requests are narrowly tailored to address the alter ego
`factors. AGIS Software and its affiliates alone have the information Lyft seeks to establish each
`entities’ contacts with the State of California. Furthermore, the burden and expense of responding
`to the discovery propounded by Lyft will not outweigh its likely benefit. As discussed previously,
`if AGIS Software and its affiliates truly lacked the minimum contacts, there would be little
`responsive information.
`Lyft therefore respectfully requests this Court compel AGIS Holdings and AGIS, Inc. to
`respond to Lyft’s discovery requests—either through the issued subpoenas (see Exs. 13 & 14) or
`through Lyft’s jurisdictional interrogatories and deposition notice (see Exs. 11 and 12).
`CONCLUSION
`For the foregoing reasons, Lyft respectfully requests the Court grant Lyft’s motion.
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` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 10
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`Case No. 5:21-cv-04653-BLF
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`Case 5:21-cv-04653-BLF Document 75 Filed 03/28/22 Page 12 of 12
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`Dated: March 28, 2022
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`By:
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` Respectfully submitted,
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`/s/ Jeremy J. Taylor
`Jeremy J. Taylor
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`Jeremy J. Taylor (SBN 249075)
`Arya Moshiri (SBN 324231)
`jeremy.taylor@bakerbotts.com
`arya.moshiri@bakerbotts.com
`BAKER BOTTS L.L.P.
`101 California St., Ste. 3600
`San Francisco, CA 94111
`Telephone: 415.291.6200
`Facsimile: 415.291.6300
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`Bethany R. Salpietra (pro hac vice)
`bethany.salpietra@bakerbotts.com
`BAKER BOTTS L.L.P.
`2001 Ross Ave., Ste. 900
`Dallas, TX 75201
`Telephone: 214.953.6500
`Facsimile: 214.953.6503
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`Attorneys for Plaintiff Lyft, Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who have consented to electronic service are
`being served with a copy of this document via electronic mail on March 28, 2022.
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`/s/ Jeremy J. Taylor
`Jeremy J. Taylor
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` PLAINTIFF LYFT, INC.’S NOTICE OF MOTION AND
`OPPOSED MOTION TO COMPEL DISCOVERY
`AND COMPLIANCE WITH LOCAL PATENT RULES 11
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`Case No. 5:21-cv-04653-BLF
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