Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 1 of 96
`
`
`
`Exhibit K
`
`
`
`
`

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`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 2 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Based on information presently available,1 Defendant AGIS Software Development LLC (“AGIS Software”) contends that
`Defendant Lyft Technologies Inc. (“Lyft” or “Plaintiff”) infringes claims 2, 10, 12, and 13 (the “Asserted Claims”) of U.S. Patent No.
`8,213,970 (the “’970 Patent”) through the Accused Products which are manufactured, sold, offered for sale, and/or used by Lyft
`
`The Accused Products comprise the Lyft and Lyft Driver applications, servers, and services manufactured, used, or sold by Lyft,
`Inc. during and after 2016. AGIS Software reserves the right to seek leave of court to amend this list of Accused Products after the
`filing of an amended complaint or as discovery progresses.
`
`Lyft directly infringes each of the Asserted Claims by making, using, importing, testing, distributing, selling, and/or offering for
`sale the Accused Products in violation of 35 U.S.C. § 271(a).
`
`Lyft indirectly infringes the Asserted Claims in violation of 35 U.S.C. § 271(b) by inducing third parties, including its users
`
`and/or customers, to directly infringe through their operation and use of the Accused Products. Lyft has knowingly and intentionally
`induced this direct infringement by, inter alia, (i) selling, importing, or otherwise providing the Accused Products to third parties with
`the intent that the Accused Products will be operated and used in a manner that practices the Asserted Claims; and (ii) marketing and
`advertising the Accused Products. Lyft’s marketing and promotional materials for the Accused Products are found, for example, on
`Lyft’s website, and in App stores of operating systems for which the Accused Products are made available. For example, Lyft’s website
`offers customers instructions and/or manuals for the Accused Products that instruct customers to, among other things, use the accused
`services in the Accused Products. Lyft’s website also offers support to customers, including instruction to, among other things, use the
`Accused Products share location information with a group of users. Lyft knows, or should have known, that its actions will result in
`infringement of the Asserted Claims, or subjectively believes that there is a high probability that its actions will result in infringement
`of the Asserted Claims but has taken deliberate actions to avoid learning these facts.
`
`
`1 These infringement contentions are provided on a provisional basis to comply with the deadline for P.L.R. 3-1. However, at this
`time, there is no operative complaint asserting non-infringement of any patent claim in this action, and these contentions are not
`responsive to any claim or cause of action. AGIS Software reserves the right to update these contentions upon receipt of an amended
`complaint. These March 18, 2022 amended contentions do not add or modify any theories of infringement and are provided solely for
`the purpose of making clear that AGIS Software does not allege infringement of any Lyft iOS-based applications and that AGIS
`Software does not rely on any Apple products.
`
`D-1
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 3 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`Lyft also contributorily infringes each of the Asserted Claims in violation of 35 U.S.C. § 271(c) by selling, importing, offering
`
`for sale, and otherwise providing the Accused Products, which when used directly infringe the Asserted Claims. The Accused Products
`constitute a material part of the Asserted Claims.
`
`The following chart identifies specifically where each limitation of each Asserted Claim is found within the Accused Products,
`
`and in particular, the corresponding elements that meet the limitations in the Lyft and Lyft Driver applications, services, and services.
`On information and belief, each charted version of the Lyft Rider and Driver Apps are representative of all versions of the Accused
`Products, including all variants of the Accused Products made, sold, offered for sale, or used on any version of the Android and iOS
`operating systems.
`
`AGIS Software does not concede that any claims of the ʼ970 Patent that are not listed below are not infringed by the identified
`
`Accused Products. Moreover, the citations to certain documents and other information below are intended to be exemplary only and in
`no way foreclose AGIS from citing or relying on additional documents, information, source code, and/or testimony at a later time. These
`contentions are preliminary in nature and an analysis of Lyft’s products, internal documentation, source code, and/or testimony from
`relevant witnesses may more fully and accurately describe the infringing features of its accused products. Accordingly, AGIS Software
`reserves the right to seek leave of court to supplement, correct, modify, and/or amend these contentions once such additional information
`is made available to AGIS Software. Furthermore, AGIS Software reserves the right to seek leave of court to supplement, correct,
`modify, and/or amend these contentions as discovery in this case progresses; in view of the Court’s claim construction order(s);2 in view
`of any positions taken by Lyft, including but not limited to positions on claim construction, invalidity, and/or non-infringement; and in
`connection with the preparation and exchange of expert reports.
`
`The contents of each claim cell below on which another claim cell depends are expressly incorporated by reference in that
`dependent cell, as if set forth in their entirety therein.
`
`
`2 The construction of claim terms herein is consistent with the constructions in AGIS Software Dev. LLC v. Huawei Device USA, Inc.,
`No. 2:17-cv-00513-JRG, Dkt. 205 (E.D. Tex. Oct. 10, 2018); AGIS Software Dev. LLC v. Google LLC, No. 2:19-cv-00361-JRG, Dkt.
`147 (E.D. Tex. Dec. 8, 2020); AGIS Software Dev. LLC v. T-Mobile USA, Inc., et al., No. 2:21-cv-00072-JRG, Dkt. 213 (E.D. Tex.
`Nov. 10, 2021). AGIS Software reserves the right to update its constructions and contentions in view of this Court’s claim
`construction order.
`
`D-2
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 4 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
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`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`(Unasserted) 1[P].
`The Lyft Accused Products comprise a communication system for transmitting, receiving, confirming receipt,
`A communication
`and responding to an electronic message. Lyft infringe directly and/or indirectly by providing a
`system for
`communication system for transmitting, receiving, confirming receipt, and responding to an electronic
`transmitting,
`message.
`
`receiving,
`
`confirming receipt,
`For example, Lyft provides Lyft Rider app for passengers and Lyft Driver app for drivers. The Lyft apps for
`and responding to
`riders and drivers, in conjunction with Lyft’s servers and services, provide users with interactive methods to
`an electronic
`request, view, and track locations of passengers/riders using real-time maps and communications. The Lyft
`message,
`server(s) and their services communicate with the Lyft apps for riders and drivers. The Lyft server(s) and their
`comprising:
`services host information related to and instructions for processing user/device/vehicle accounts, location data,
`and map data. The claimed methods are distributed by Lyft in the Lyft apps. The claimed methods are
`used/tested by Lyft using the Lyft apps. The claimed methods are downloaded and installed by Lyft’s
`customers (riders) and personnel (drivers, personnel) at the direction/encouragement of Lyft and used by
`Lyft’s customers and Lyft’s personnel.
`
`The Lyft Driver application receives an electronically transmitted request for a ride message and
`acknowledges the receipt of the message which triggers a forced message alert that locks the device for a
`period of time until the driver sends a response message (decline or accept) to clear the locked display
`(“transmitting, receiving, confirming receipt, and responding to an electronic message”).
`
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
`
`
`D-3
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 5 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
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`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.lyft.com/drive-with-lyft
`
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`
`
`
`D-4
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 6 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`
`D-5
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 7 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
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`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`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.
`
`
`
`D-6
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 8 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`D-7
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 9 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`1[A]. a
`The Lyft Accused Products comprise: a predetermined network of participants, wherein each participant has a
`predetermined
`similarly equipped PDA/cell phone that includes a CPU and a touch screen display a CPU and memory.
`
`network of
`
`participants,
`
`wherein each
`For example, Lyft is a network of drivers and passengers where drivers connect with individuals requesting a
`participant has a
`ride. Drivers access the platform using the Lyft Driver app and passengers access the platform using the Lyft
`similarly equipped
`app on their respective smart devices including but not limited to smartphones and tablets comprising a
`PDA/cell phone
`display, a processor and a storage media.
`that includes a
`
`CPU and a touch
`screen display a
`CPU and memory
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
` https://www.lyft.com/drive-with-lyft
`
`
`D-8
`
`
`
`
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 10 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`
`D-9
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 11 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`
`D-10
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 12 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`D-11
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 13 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
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`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`
` http://www.mobilecellphonerepairing.com/mobile-phone-parts.html
`
`
`
`
`
`
` http://www.mobilecellphonerepairing.com/mobile-phone-parts.html
`
`
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: a data transmission means that facilitates the transmission of
`electronic files between said PDA/cell phones in different locations
`
`
`
`For example, Lyft’s servers connect passengers to nearby drivers when a request for a ride is placed. The
`servers receive a passenger’s request for a ride and communicate the request to nearby drivers. The nearby
`drivers receive the request for a ride from the passengers to which they either accept or decline the request.
`The locations of the passenger and the nearby drivers are different from each other.
`
`1[B]. a data
`transmission
`means that
`facilitates the
`transmission of
`electronic files
`between said
`PDA/cell phones
`in different
`locations
`
`D-12
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 14 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`
`D-13
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 15 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`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: a sender PDA/cell phone and at least one recipient PDA/cell phone
`for each electronic message
`
`
`
`
`1[C]. a sender
`PDA/cell phone
`and at least one
`recipient PDA/cell
`
`D-14
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 16 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`phone for each
`For example, Lyft’s servers connects the passengers (“sender”) to the nearby drivers (“recipient”) when a
`electronic message
`request for a ride is placed. The servers receive a passenger’s request for a ride and communicates the request
`to nearby drivers. The nearby drivers receive the request for a ride from the passengers to which they either
`accept or decline the request.
`
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`D-15
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 17 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`D-16
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 18 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`D-17
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 19 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`D-18
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 20 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`
`D-19
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 21 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`1[D]. a forced
`message alert
`software
`application
`program including
`a list of required
`possible responses
`to be selected by a
`participant
`recipient of a
`forced message
`response loaded on
`each participating
`PDA/cell phone
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves
`the right to supplement these contentions pursuant to production of such source code by Lyft and to the extent
`Lyft requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: a forced message alert software application program including a list
`of required possible responses to be selected by a participant recipient of a forced message response loaded on
`each participating PDA/cell phone
`
`
`
`For example, Lyft provides Lyft app for passengers and Lyft Driver app for drivers. The Lyft apps for riders
`and drivers, in conjunction with Lyft’s servers and services, provide users with interactive methods to request,
`view, and track locations of passengers/riders using real-time maps and communications. The Lyft server(s)
`and their services communicate with the Lyft apps for riders and drivers. The Lyft server(s) and their services
`host information related to and instructions for processing user/device/vehicle accounts, location data, and map
`data. The claimed methods are distributed by Lyft in the Lyft apps. The claimed methods are used/tested by
`Lyft using the Lyft apps. The claimed methods are downloaded and installed by Lyft’s customers (riders) and
`personnel (drivers, personnel) at the direction/encouragement of Lyft and used by Lyft’s customers and Lyft’s
`personnel.
`
`The Lyft Driver application receives an electronically transmitted request for a ride which triggers a forced
`message alert that locks the device for a period of time until the driver (“recipient”) sends a response message
`(decline or accept) to clear the locked display.
`
`
`D-20
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 22 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Driver’s device
`screen locked
`displaying
`passenger’s ride
`request message
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`
`D-21
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 23 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`D-22
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 24 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`
`
`D-23
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`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 25 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`
`D-24
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 26 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves
`the right to supplement these contentions pursuant to production of such source code by Lyft and to the extent
`Lyft requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: means for attaching a forced message alert software packet to a
`voice or text message creating a forced message alert that is transmitted by said sender PDA/cell phone to the
`recipient PDA/cell phone, said forced message alert software packet containing a list of possible required
`responses and requiring the forced message alert software on said recipient PDA/cell phone to transmit an
`automatic acknowledgment to the sender PDA/cell phone as soon as said forced message alert is received by
`the recipient PDA/cell phone.
`
`
`
`For example, the Lyft Driver app receives an electronically transmitted request for a ride from a passenger
`which triggers a forced message alert that locks the driver’s device for a period of time until the driver
`(“recipient”) sends a response message (decline or accept) to clear the locked display.
`
`For example, at the backend, each nearby driver’s Lyft app that receives the ride request sends an
`acknowledgement of receipt to the Lyft server(s). The acknowledgement is communicated to the rider’s Lyft
`app via the Lyft server(s).
`
`
`1[E]. means for
`attaching a forced
`message alert
`software packet to
`a voice or text
`message creating a
`forced message
`alert that is
`transmitted by said
`sender PDA/cell
`phone to the
`recipient PDA/cell
`phone, said forced
`message alert
`software packet
`containing a list of
`possible required
`responses and
`requiring the
`forced message
`alert software on
`said recipient
`PDA/cell phone to
`transmit an
`automatic
`acknowledgment
`to the sender
`
`D-25
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 27 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`PDA/cell phone as
`Driver’s device
`soon as said forced
`screen locked
`message alert is
`displaying
`received by the
`passenger’s ride
`recipient PDA/cell
`request message
`phone;
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`D-26
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 28 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`D-27
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 29 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
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`
`
`
`
`D-28
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`

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`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 30 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`D-29
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 31 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves
`the right to supplement these contentions pursuant to production of such source code by Lyft and to the extent
`Lyft requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: means for requiring a required manual response from the response
`list by the recipient in order to clear recipient's response list from recipient's cell phone display.
`
`
`
`For example, the Lyft Driver app receives an electronically transmitted request for a ride from a passenger
`which triggers a forced message alert that locks the driver’s device for a period of time until the driver
`(“recipient”) sends a response message (decline (cross button) or accept) to clear the locked display.
`
`
`
`1[F]. means for
`requiring a
`required manual
`response from the
`response list by
`the recipient in
`order to clear
`recipient's
`response list from
`recipient's cell
`phone display;
`
`D-30
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 32 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`D-31
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 33 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`
`
`D-32
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 34 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`D-33
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 35 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Driver’s device
`screen locked
`displaying
`passenger’s ride
`request message
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`
`D-34
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 36 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`Driver’s device screen
`locked displaying
`passenger’s ride request
`message is removed after
`driver chooses the
`response (here, accept
`response)
`
`
`
`
` https://www.youtube.com/watch?v=b31WorLlcqE at 9:40, Annotated
`
`D-35
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 37 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves
`the right to supplement these contentions pursuant to production of such source code by Lyft and to the extent
`Lyft requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: means for receiving and displaying a listing of which recipient
`PDA/cell phones have automatically acknowledged the forced message alert and which recipient PDA/cell
`phones have not automatically acknowledged the forced message alert.
`
`
`
`For example, at the backend, each nearby driver’s Lyft App (“recipient PDA/cell phone”) that received ride
`request sends an acknowledgement of receipt to Lyft server(s).
`
`
`1[G]. means for
`receiving and
`displaying a listing
`of which recipient
`PDA/cell phones
`have automatically
`acknowledged the
`forced message
`alert and which
`recipient PDA/cell
`phones have not
`automatically
`acknowledged the
`forced message
`alert;
`
`D-36
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 38 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`D-37
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 39 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`
`
`D-38
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 40 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`D-39
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 41 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Driver’s device
`screen locked
`displaying
`passenger’s ride
`request message
`
`
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`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: means for periodically resending said forced message alert to said
`recipient PDA/cell phones that have not automatically acknowledged the forced message alert.
`
`
`
`
`
`
`1[H]. means for
`periodically
`resending said
`forced message
`alert to said
`recipient PDA/cell
`phones that have
`
`D-40
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 42 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`not automatically
`For example, at the backend, each nearby driver’s Lyft app that received ride request sends an
`acknowledged the
`acknowledgement of receipt to Lyft server(s). Therefore, the second communication of the ride request is sent
`forced message
`to those drivers’ Lyft app who did not acknowledge the ride request message. This communication of ride
`alert; and
`request is periodically sent until the ride is accepted by any driver.
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`D-41
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 43 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`
`
`D-42
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 44 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`D-43
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 45 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`Driver’s device
`screen locked
`displaying
`passenger’s ride
`request message
`
`
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`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: means for receiving and displaying a listing of which recipient
`PDA/cell phones have transmitted a manual response to said forced message alert and details the response
`from each recipient PDA/cell phone that responded.
`
`For example, at the backend, a list of all the drivers’ Lyft app that transmitted the response to a ride request
`message of a passenger are maintained at Lyft’s server(s). This ensures that drivers who declined the ride do
`
`1[I]. means for
`receiving and
`displaying a listing
`of which recipient
`PDA/cell phones
`have transmitted a
`manual response
`
`D-44
`
`

`

`Case 5:21-cv-04653-BLF Document 84-12 Filed 04/01/22 Page 46 of 96
`Attachment D for US Patent No. 8,213,970 Against Lyft Accused Products
`
`
`
`Claim - 8,213,970 Exemplary Supporting Evidence Regarding Accused Products
`to said forced
`not further receive the ride request of the same p