Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 1 of 151
`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 1 of 151
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`EXHIBIT 3
`EXHIBIT 3
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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 2 of 151
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`U.S. PATENT NO.: 9,467,838
`
`CONTROL
`NUMBER:
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`90/014,510
`
`FILING DATE:
`
`May 15, 2020
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`ART UNIT: 3992
`
`CONF. NO.: 7707
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`EXAMINER: Tarae, Catherine
`Michelle
`
`TITLE: METHOD TO PROVIDE AD HOC AND PASSWORD
`PROTECTED DIGITAL AND VOICE NETWORKS
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`FILED ELECTRONICALLY
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`Mail Stop Ex Parte Reexam
`ATM: Central Reexamination Unit
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`DECLARATION OF MALCOLM K. BEYER JR. IN SUPPORT OF
`REPLY TO OFFICE ACTION
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`I, Malcolm K. Beyer, Jr., being duly sworn, hereby state as follows:
`
`1.
`
`I am the Chief Executive Officer ("CEO") of Plaintiff A.GIS Software
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`Development LLC ("AGIS"). I am also the first-named inventor on U.S. Patent No. 9,467,838
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`(the "'838 patent"). I submit this declaration based on my personal knowledge and in support of
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`AGIS's response to the non-final office action issued by the Office in its reexamination of the
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`'838 patent (Control No. 90/014,51.0).
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`Background
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`2.
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`I graduated from the U.S. Naval Academy in 1962 and was commissioned as a
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`Second Lieutenant in the U.S. Marine Corps. I later attended the U.S. Navy's programming
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`school and was the lead programmer for the first automated Marine Corps Tactical Operations
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`Center Link-11 Navy Interface.
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`Document Subject to Protective Order in Case No. 2.19-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 3 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`3.
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`After leaving active service, I worked at a number of well-known technology
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`companies, including System Development Corporation (considered the world's first computer
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`software company) and Litton Industries. I then started several businesses which provided
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`technology and engineering solutions supporting defense and military customers.
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`4.
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`In 1987, I co-founded Advanced Programming Concepts, Inc. ("APC"), a Texas
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`corporation based in Austin, Texas. APC operated primarily out of its main business location in
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`Austin, Texas. APC specialized in designing, building, and supporting systems for enabling
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`integration and sharing time-critical information across dissimilar military and defense
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`applications. At APC, I was the majority shareholder and Chairman until we sold the business to
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`Ultra Electronics in July 1999.
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`5.
`
`On June 30, 2004, I founded Advanced Ground Information Systems, Inc.
`
`("A.GIS Inc."). AGIS Inc.'s main business location is located at 92 Lighthouse Drive, Jupiter,
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`Florida. AGIS Inc. also maintains business locations in Austin, TX and Kansas City, KS. AGIS
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`Inc. employs approximately 15 people. In 2017, the Board of AGIS, Inc. approved a
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`reorganization plan which organized AGIS and AGIS, Inc. under its current parent, AGIS
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`Holdings, Inc. AGIS, Inc. continues to sell the AGIS LifeRing solutions while AGIS maintains a
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`data center located at 1005 Stuart Lane, Marshall, Texas 75672. AGES's Texas data center hosts
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`servers, code, applications, and services necessary to run operations for AGIS Inc.'s LifeRing
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`products and solutions and is used for research and development projects.
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`6.
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`As the CEO of AGIS and AGIS Inc. and first-named inventor of the '838 patent, I
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`have knowledge of all facets of the businesses, including the conception and reduction to
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`practice of the '838 patent and the diligence involved in reducing to practice the claimed
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`inventions.
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`2
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 4 of 151
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`Attorney Docket No. 252.5.996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`Since 2004, AGIS c.'s primary business has revolved around offering the
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`"LifeRing" products and solutions which include client-based applications and a server-based
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`solutions for, generally, enabling smartphone, tablet, and PC users to easily and rapidly establish
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`secure ad hoc digital networks, LifeRing 5.0 and its predecessor versions have been offered and
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`sold to military, defense, and first-responder customers, as well as private industry customers.
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`8.
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`AGIS LifeRing software was developed by United States military veterans as a
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`response to the September llth, 2001 terrorist bombings. Since that time, th€: company has
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`continued its development efforts; leveraging the technological advances in modern PCs and
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`Smartphones as well as communications methods, AGIS's Lit7eRing software enables PC,
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`iPhone, and Android Tablet and Smartphone users to easily establish ad hoc COP networks
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`where many people need to coordinate and collaborate with many others.
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`9.
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`AGIS LifeRing provides users with the present location and status of others.
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`LifeRing soft /are uses GIBS to provide location data. Users can seamlessly enter geo-locations
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`of events or objects by selecting the desired map location and then the appropriate symbol.
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`Information about other networked users and symbols can be obtained by touching symbols on
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`the map.
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`10.
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`AGIS LifeRing provides an interactive map display. :Because accuracy is
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`necessary to ensure the success of life and death missions, AGIS's maps are geo-referenced so
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`that users and events are displayed at their correct locations in real-time. To interact and.
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`c:orrimunicate with other users in a one or more groups, users simply touch the display at the
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`desired map location and then select the appropriate or desired symbol, which appears at the
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`correct map location, to initiate an exchange. LifeRing supports 80 different map types.
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`3
`Document Subject to Protective Order in Case No. 2.19-cv-361 (E. D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 5 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`11.
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`Over the years, LifeRing has been successfully deployed and tested in operational
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`environments, including:
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`• New York Emergency Operations Center Test
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`• National Incident Management System (NIMS)Test
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`• Coalition Warrior Interoperability Demonstration (CWID)
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`• Army Network Integration Evaluation (NIE 12.1, 12.2 and13.1)
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`• Numerous US Joint Chiefs of Staff. Exercises
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`• The Defense Intelligence Agency (LifeRing won 4 Stars in the DIA's
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`PLUGFEST)
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`• SOCOM TNT Exercises (2012 &2013)
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`• US NATO Bold Quest (2012, 2013)
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`•
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`Joint-Interagency Field Experimentation (11FX) Exercises
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`• Army Expeditionary Warrior Experiment (AEWE 2013)
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`•
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`Jolted Tactics
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`• US Navy
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`•
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`International Partners (e.g., Australian, Dutch Defense Forces)
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`12.
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`I am the first-named inventor of the '838 patent and its claimed inventions. I am
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`very familiar with the claimed inventions of the '838 patent as I am the main point of contact for
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`patent prosecution matters at AGIS (and formerly at AGIS, Inc.) and I personally reviewed and
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`approved of the issued claims 1-84 of the '838 patent.
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`13.
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`In addition to me, Mr. Christopher R. Rice is identified as a co-inventor on the
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`'838 patent. With respect to the '838 patent, Mr. Rice's contributions included the client-server
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`4
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 6 of 151
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`Attorney Docket No. 252.5.996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
`
`communications. For example, Mr. Rice contributed to the portion of the claimed invention
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`related to the following recited limitations: "sending, to a second server, a request for second
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`georeferenced map data different from the first georeferenced map data" and "receiving, from
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`the second server, the second georeferertr 'd map data."
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`14.
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`In this reexamination proceeding, I understand that the Office has issued several
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`rejections based on I .S. Patent No. 7,353,034 ("Haney"). understand that Haney's application
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`filing date is April 4, 2005. However, I invented the claimed inventions prior to April 4, 2005.
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`15.
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`The claimed inventions of the '838 patent were conceived of by at least January
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`19, 2005 and were reduced to practice by October 22, 2005. The October 22, 2005 reduction to
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`practice was the product of diligent work on the part of a team of engineers and programmers
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`under my direction and supervision. Below, I identify and submit substantial evidence
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`regarding the conception and reduction to practice of the claimed inventions of the '838 patent.
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`16.
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`The claimed inventions recited in the '838 patent were conceived of by at least
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`January 19, 2005. In August 2004, AGIS and its customer Raytheon engaged in discussions to
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`develop a homeland security solution based on AGIS' s LifeRing solution. In Exhibit 1 to this
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`declaration, I provide a copy of an email summarizing an outline of the planned phases of
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`development. Exhibit I, After these August 2004 discussions, AGIS submitted a proposal for a
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`system of PDA/cell phone devices for use in a homeland defense system, and AGIS reduced its
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`proposal to a statement of work (SOW) on or around August 29, 2004. The August 29, 2004
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`SOW outlined the system using PDA. cell phone devices for transmitting and displaying tracked
`
`participants on maps,
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`"correctly geographically- superimposed on a map" and for interacting
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`with the map to exchange data. Exhibit 2.
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`5
`Document Subject to Protective Order in Case No. 2.19-cv-361 (E. D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 7 of 151
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`Attorney Docket No. 2525.996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
`
`17.
`
`On January 19, 2005 I prepared a presentation for Raytheon attached hereto as
`
`Exhibit 3, and this presentation was presented to Raytheon personnel, including Kurt Winckler,
`
`on January 21, 2005. The January 19, 2005 presentation attached as Exhibit 3 is evidence that I
`
`and Mr. Rice had conceived of the claimed inventions as early as January 19, 2005.
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`ADVANCED GROUND tNFORMATtON SYSTEM
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`ProOetaty
`
`Exhibit 3 at 1.
`
`18.
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`The January 21, 2005 presentation describes cell phone/PDA devices
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`programmed with software to permit users to display different maps and overlay maps, zoom and
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`offset maps, enter other entities (track symbols), assign information associated with entities,
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`obtain location and information of other AGIS units and tracking them, displaying tracking
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`histories, and selecting different maps (e.g., fixed versus moving).
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`6
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 8 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`AGIS OPERATION
`Display
`
`The AGIS operator can:
`Dispiay different maps and overlay maps
`- Zoom and Offset maps
`- Enter other entities (track symbols) such as accidents„ fires..
`trucks, military units, etc., and assign intbrmation associated with
`them
`- Obtain range and bearing readings to other locations
`- Obtain location and information of other ACTS units and the
`tracks that they have entered
`- Display the track histories
`- Select a ffxed map €his symbol moves across the map)
`Select a moving map this symbol stays at the center of the
`display a€
` the map moves underneath)
`- Specify that the map and the symbols occu€py most of the display
`
`Exhibit 3 at 3.
`
`19.
`
`The January 21, 2005 presentation describes that the AGIS software provides
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`each user with the following features: display user's phone's and other users' phones' location,
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`status, heading, speed, altitude, phone signal strength, and GPS status; displaying phones'
`
`locations, identities, and status information on different maps; establishing voice and data
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`communications with other participants by interacting with the symbols; and transmitting
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`messages and multimedia between participants.
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`7
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 9 of 151
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`Attorney Docket No. 2525.996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
`
`AGIS OPERATION
`Display
`
`The AGES operator can:
`Display different maps and overlay maps
`— Zoom and Offset maps
`Enter other entities (track symbols) such a5s, accidents, tires,
`trucks, military uni€s, etc., and assign information associated with
`them
`— Obtain range and bearing readings to other locations
`Obtain location and €€formation of other AGIS units and €he
`tracks that they have entered
`Display the track. histories
`— Select a fixed map (his symbol moves across the map)
`Select a moving map (his symbol stays at The center of the
`display and the map moves unde€neath)
`— Specify that the map and the symbols occupy most of the display
`
`Proprietary
`
`Exhibit 3 at 3.
`
`8
`Document Subject to Protective Order in Case No. 2•19-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 10 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`AGJS SOFTWARE
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`PROVIDES EACH USER:
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`• Display of his end other phones' location, status, heading, speed
`attitude, phone signal strength and GPS status (on, off, 2D or 3D).
`
`• His and other AGt$ panicipants' location, identity and status information
`superimposed on a variety of maps, aerial photographs, and satellite
`images.
`
`• Multipte, easily accessible, tayered SoftSwitches organized by category to
`triable €he ACIS operator to quickly operate the system.
`• The ability quickly. and 41OSity to establish voice and data communications
`(f..loint to talk) wAh any other AGIS net participant without losing the
`tactical picture by simply hooking other site's symbols.
`
`• The al tlFty quicidy to transmit free text, fixed formatted messages,
`photographs and video clips between each user
`
`.4etor4 W.*
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`ft :writ:Amy
`
`Exhibit 3 at 5.
`
`9
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 11 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`AG IS SOFTWARE
`Continued
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`AG /8 FURTHER PR.OVIDES EACH LI$E.R:
`
`• The ability to enter fdendly and hostile forces (or other information such as
`fires, ernergences, accidents, pilot boats. Fire boats, etc.1 locations on a
`soap and to associate data With their symboL
`intbrrnstion is then
`transmitted al'" g with the AGM participants location On the AG IS cellular
`net to ati other AGMequitved users:
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`• The abiiity to receive and transmit free text, fixed: formatted, photograph",
`and video clip" massages by f:lointing at the AGM user to whom they ate
`to be sent
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`• The ability to establish range and bearing data from the user to any point.
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`• The ability For each AGIS user to view h s oWf/ and other tracks' history bait
`and last he
` data.
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`• The ability to also operate from a PC and a Tablets:
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`•
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`ktat
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`Pmptiectaty
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`Exhibit 3 at 6.
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`20.
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`The January 21, 2005 presentation describes the formation and use of groups or
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`"nets" of participants.
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`10
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 12 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`AGIS OPERATION
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`The operator conticis €he AGM with either a St si or using Finge:€ On Glass
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`The operator interarJs with the AGIS through the use of layered SoftSvOtches
`which are located at the bottom of the display.
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`When initializing the system,. the AGIS operator specifies from a list those AGiS
`users with whom he desires to net location data and with whom he desires to
`be able to conduct rapid voice and data communications,
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`When the AGIS is prompted to respond with its location, it sends its location
`and 'status to all that are part of the net.
`
`MiiStd 282t5 symbols Or Homeland Defense defined symbols+) are associated
`with each user and appear at the correct location on each of the displays,
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`The AGM operator obtains information arnceming other symbols appearing on
`the display by touchng the screen at their location thereby •Ahooking" them,
`Data concerning the other symbol then appears on the low r part of the AGIS
`display.
`
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`Exhibit 3 at 8.
`
`Pmpirk:tary
`
`1l
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 13 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
`
`AGIS OPERATION
`Cellular phone calls
`
`When the AGIS op'erator decides to call another ACAS user; he simply
`hooks the other user's symbol and seleOs the Call SollSwillth, The phone
`of the AGlS receiving call then hears a ring and sees a box appear ammo:
`tie sender's syrnboi.,
`
`The AGIS operator can setup pre,fk,stablistied nets of up to six AGIS net
`participarits When he desires to talk to that group of users he selects the
`appropvriate net rumber and a conference call is e(ttornatically made,
`
`The AGIS operator can conference an almost unlimited number of AGIS
`participants by using the AGilS's 8th conferehoing capabiiity. AftgAi€s the
`AGIS operato€ assigns AGIS participants to a net number. When he desires
`to make the GertfereriCe call, he selects the net number. This action causes
`a message to be sent to alt of the AGM participants, causing their phones to
`a' utomatically cal en &)O number and automatically entering their participant
`code.
`
`Pmptiorarty
`
`4
`
`Exhibit 3 at 9.
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`21. AGIS's LifeRing solution was under development throughout 2004 and 2005.
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`During this period, I conceived and reduced to practice both non-server and server-based
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`implementations. As I discussed above, Mr. Rice's contributions included the client-server
`
`communications, including "sending, to a second server, a request for second georeferenced map
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`data different from the first georeferenced map data" and "receiving, from the second server, the
`
`second georeferenced map data." In the non-server implementations, AGIS's maps were
`
`uploaded to and called from databases and the transmissions occurred over SMS only. However,
`
`in the server-based implementations, which were conceived of by January 19, 2005, the devices
`
`communicated with intermediary servers and the maps requested and received from servers. The
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`12
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`

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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 14 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
`
`January 21, 2005 presentation describes an AGIS server implementation and the development
`
`and testing of preproduction server-based implementations were underway.
`
`AGIS SERVER
`
`• When AGiS is operating in a SMS (-slow speed) mode of operation,
`communications are from the AGIS phone to the telephone company and
`Inert from the phone company to all ether AGIS phones,
`
`• When the AGjS lid operating in a high speed GRPS COMA' 000 Ixf-NDO
`mode. communications are from the AGIS phone to the telephone phone
`tompenv, then to the. TCP/IP Server and from the TCPAP SONW to at the
`other AGIS phoۥes,
`
`• The TCP/1P Server pashe.s the received data to the ACAS phones so that
`information is ttiit*i:;:ed within approximately 5 Sec>0nd8,
`
`• The TCP/IP Se€ver provides into operability between £lie GRPS
`C0MP42000 IxEV-DO communications,
`
`• The AG /S accounts for when: the phones go into Voice mode and then
`transmits data in skis until high speed communications are available.
`
`• The TCP/IP Server is operating on a 24 hour basis, We are still in the
`process of resolving Server Trouble Reports.
`
`Proffic+Alty
`
`Exhibit 3 at 14.
`
`13
`Document Subject to Protective Order in Case No. 2719-cv-361 (E D.Tex.)
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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 15 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
`
`AGIS STATUS
`
`THE PROTOTYPE AGES HAS UNDERGONE A WEEK OF TESTING AT THE NAVAL.
`RESEARCH LABORATORY'S (WRY.} ANTITERRIORISM GROUP. DURING THE TEST
`PERIOD. ME: AWS OPERA no wrmour FAILURE. THE RESULTS OF THIS TESTIN.D
`WAS Postrive. 11. WAS REQUESTED THAT
`
`ASIS FUNCTION SWITCHES at MADE EASIER TO USE AND REMEMBER'
`
`MULTIPLE MAP SETS CAPABILITY SE PROVIDED'
`
`DIRECTION UP MAPS AND MOLTIPLE LOCATION MAPS SE PROVIDE:Ds*
`WE ARE UNDER CONTRACT TO ADD TNE OTHER FEATURES (OTHER IMAM SECUR4TY}
`DISCUSSED IN THIS PRESENTATKIN.
`
`THE PREPRODUCTION AGtS IS DUE TO SE TESTED AT NRI, IN FEB
`
`S.
`
`ALL THE FEATURES (EXCEPT' St:COMFY) WILE. SE INCORPORATED INTO THE SEATTLE
`DEL WEEaY
`
`f24 4:44424.4:,koewy trwerfialcub0
`
`Propriotary
`
`Exhibit 3 at 15.
`
`22.
`
`This is consistent with AGES's plans to provide "over the air" georeferenced maps
`
`via servers. Exhibit 4 at 8-9.
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`14
`Document Subject to Protective Order in Case No. 2.19-cv-361 (E D.Tex.)
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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 16 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`an:, Figure #€r depicts setection of co states arid geopolitical boundaries. As part of a
`
`Propnetary
`
`Advanced Grow rtd information Systems, ;r>-. TS pit titant,w14:15-tYS-9. Pmposai Nktmi>er
`0725
`Pmpriatary
`
`9
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`separate non government funded e€fort, AGIS otans to incorporate 'over the air
`downloading of georeferenced reaps.
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`Figure 17
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`Figure 18
`
`Figure 19
`
`Exhibit 4 at 8-9.
`
`23.
`
`Under my direction and supervision, AGIS was diligent in reducing to practice
`
`the claimed inventions of the '838 patent. Immediately after conception, I assembled a team to
`
`begin development and testing of various implementations. The AGIS project timeline consisted
`
`of multiple phases, and the project timeline was updated continuously over the course of
`
`development. Exhibits 5-8 describe multiple timeline updates based on changes to the server-
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`based implementation. From January 2005 to October 2005, AGIS dedicated hundreds of hours
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`to the development and testing of the server-based implementations of the AGIS LifeRi.ng
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`solution. The development team included myself, Christopher R. Rice, Sandel Blackwell,
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`Dennis Hoff, Scott Brown, and Jason Cardamone. Exhibits 9-14 include timesheets from the
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`individuals involved in the development and evaluation of the AGIS LifeRing solution during
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`the period of April 2005 through October 2005. These timesheets demonstrate that I was diligent
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`in reducing to practice the January 19, 2005 concepts for the server-based implementation of the
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`AGIS LifeRing solution. Please note that these timesheets indicate billable hours only, which
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`reflects a subset of the actual time dedicated to the research and development and testing of the
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`LifeRing solution.
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`24.
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`In April 2005, Mr. Rice dedicated at least 39 hours to fixing the SMS
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`transmission and 'FCP protocol portions of LifeRing. In April 2005, Mr. Blackwell billed 89
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`hours for work including, for example, updating the change rate of the displayed information,
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`grouping and selecting participant groups, and user location updates. Mr. Blackwell was also
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`involved in testing TCP and SMS communications issues and server issues including fixing
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`database scroll issues on the server-based implementation. Mr. Blackwell also worked on
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`addressing memory leakage issues. Mr. Blackwell also worked on integrating and developing
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`Global Mapper features and other different maps used in LifeRing. Mr. Blackwell
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`communicated with and worked closely with Mr. Rice to address these problems. Mr. Blackwell
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`also worked on finalizing several versions of code. In April 2005, Mr. Hoff billed 17 hours for
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`work on testing portions of LifeRing and developing code for the client side of LifeRing. Mr.
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`Hoff was involved in testing location tracking and the loading of the client side application.
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`Prior to April, Mx. Hoff was involved in development and testing for the location tracking,
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`mapping data, interaction with maps and symbols, displaying of locations, maps and symbols,
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`data and multimedia transfers, memory issues, and other issues related to both client and server
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`side issues and had billed over 190 hours for such work between January 2005's conception date
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`Attorney Docket No. 252.5.996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`and April 2005. In April 2005, Mr. Brown billed 160 hours for work on testing the LifeRing
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`system. Mr. Brown was responsible for testing all portions of the code and client side program
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`to find bugs and errors and to track reporting on such items. Mr. Brown also assisted Mr.
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`Blackwell, Mr, Rice and myself on documentation of the LifeRing reports, manuals, and
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`versions.
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`25.
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`In May 2005, Mr. Rice billed at least 60 hours for work related to fixing problems
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`related to SMS and voice transitions, photo transmissions, and SMS transmissions. Mr. Rice
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`also spent considerable time creating and testing UDP communications protocol for establishing
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`communications between applications and servers, including testing the new implementation of
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`the protocol with a device. Mr. Rice also worked on the development of the CSIF code. Du:
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`this time. Mr. Rice communicated frequently with Mr. Blackwell, who was also working on
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`updates to the code, in May 2005, Mr. Hoff billed 11 hours for work on testing portions of
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`LifeRing and working with Mr. Rice and Mr. Blackwell on testing features. In May 2005, Mr.
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`Cardamone billed 80 hours for work related to the code and configuration of an SVN code
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`repository. Mr. Cardamone also worked on the communications and display issues for LifeRing.
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`Mr, Brown was responsible for testing all portions of the code and client side program. to find
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`bugs and errors and to track reporting on such items. In May 2005, Mr. Brown billed 80 hours
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`for work on testing the LifeRing system. Mr. Brown also assisted Mr. Blackwell, Mr. Rice and
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`myself on documentation of the LifeRing reports, manuals, and versions.
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`26.
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`In June 2005, Mr. Rice billed at least 60 hours for t sork related to transmission
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`issues with SMS and phone/conference calls. He worked on enhancing the stability of our SMS
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`transmissions and supported our efforts on data reductions, UDP communications protocol, and
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`CSIF code. Mr. Rice also made changes to the code for location tracking and message handling.
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`Attorney Docket No. 252.5.996REX0
`Control No.: 90/014,510 (Re-exam of U.S. Patent No. 9,467,838)
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`Mr. Rice also worked on network configuration for our development server. During this time,
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`Mr. Rice communicated frequently with Mr. Blackwell, who was also working on updates to the
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`code. In June 2005, Mr. Hoff billed 10 hours for work on testing new versions of LifeRing. Mr.
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`Hoff was involved in testing SMS features of LifeRing. In June 2005, Mr. Cardamone billed
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`160 hours for work related to the LifeRing code repository and data reductions transmissions
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`related to LifeRing data. Mr. Brown was responsible for testing all portions of the code and
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`client side program to find bugs and errors and to track reporting on such items.
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`In June 2005,
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`Mr, Brown billed over 160 hours for work on testing the LifeRing system. Mr. Brown also
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`assisted Mr. Blackwell, Mr. Rice and myself on documentation of the LifeRing reports, manuals,
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`and versions.
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`27.
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`In July 2005, Mr. Rice billed over 40 billable hours on communications
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`infrastructure issues and network configuration and server migration issues. In July 2005, Mr.
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`Blackwell billed over 8() billable hours on various issues related to LifeRing including
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`communications issues, display issues, and location tracking issues. Mr. Blackwell performed
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`research to solve some issues that we were having with our server-based implementation and he
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`worked on developing the new maps that had been integrated and tested in April and May 2005.
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`Again, during this period, Mr. Blackwell remained in constant communication with Mr. Rice in
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`order to resolve issues with the development of LifeRing. In July 2005, Mr. Cardamone billed
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`120 hours for work on data processing and data reduction relating to the georeferenc€:d maps and
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`georeferenced map data for presentation and use in LifeRing. In April 2005, Mr, Brown billed
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`SO hours for work on testing the LifeRing system. Mr. Brown was responsible for testing all
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`portions of the code and client side program to find bugs and errors and to track reporting on
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`such items. Mr. Brown also assisted Mr. Blackwell, Mr. Rice and myself on documentation of
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`the LifeRing reports, manuals, and versions.
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`28.
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`In August 2005, Mr. Rice billed over 80 hours for work on the LifeRing database
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`systems, including databases used for location tracking data. Mr. Rice's August 2005 work also
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`included work on the processing output (maps) for LifeRing. During August 2005, we ran into
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`problems with the startup and shutdown of the LifeRing application. Mr. Rice worked on
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`researching ways to reduce delays in starting the program and obtaining new maps and location
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`data immediately upon startup. This included the retrieval of maps i.n both non-server and
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`server-based implementations. In August 2005, Mr. Blackwell billed over 150 hours for work on
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`the development of LifeRing. During this time, Mr. Blackwell was intimately involved in
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`researching and development of the server-based implementation. He also spent considerable
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`time on testing communications issues and updating the display of information on the client. In
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`August 2005, Mr. Cardamone billed 200 hours for work on data processing and data reduction
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`relating to the georeferenced maps and georeferenced map data for presentation and use in
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`LifeRing. During this time, Mr. Cardamone also worked on code processing output for display
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`(e.g., georeferenced maps) and various display filter issues i.n the LifeRing code. In August
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`2005, Mr. Brown billed 160 hours for work on testing the LifeRing system. Mr. Brown was
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`responsible for testing all portions of the code and client side program to find bugs and errors
`
`and to track reporting on such items. Mr. Brown also assisted Mr. Blackwell, Mr. Rice and
`
`myself on documentation of the LifeRing reports, manuals, and versions. Mr. Brown also
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`assisted on preparing the LifeRing product for presentation to customers in Seattle.
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`29.
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`In September 2005, Mr. Rice billed over 70 hours for work on the LifeRing
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`location tracking database and location history issues. Mr. Rice also began to develop code to
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`Case 5:21-cv-04653-BLF Document 75-4 Filed 03/28/22 Page 21 of 151
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`Attorney Docket No. 2525,996REX0
`Control No.: 90/014,510 (Re-exam of L.S. Patent No. 9,467,838)
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`more efficiently manage and distribute processing tasks in order to imp