`
`
`
`
`
`
`EXHIBIT D
`EXHIBIT D
`
`
`
`
`
`
`

`

`
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Based on information presently available,1 Defendant AGIS Software Development LLC (“AGIS Software”) contends that
`Plaintiff Lyft Inc. (“Lyft” or “Plaintiff”) infringes claims 1-31 (the “Asserted Claims”) of U.S. Patent No. 10,299,100 (the “’100 Patent”)
`through the Accused Products which are manufactured, sold, offered for sale, and/or used by Lyft.
`
`The Accused Products comprise the Lyft and Lyft Driver applications, servers, and services manufactured, used, or sold by Lyft,
`Inc. during and after 2016. AGIS Software reserves the right to seek leave of court to amend this list of Accused Products after the
`filing of an amended complaint or as discovery progresses.
`
`Lyft directly infringes each of the Asserted Claims by making, using, importing, testing, distributing, selling, and/or offering for
`sale the Accused Products in violation of 35 U.S.C. § 271(a).
`
`Lyft indirectly infringes the Asserted Claims in violation of 35 U.S.C. § 271(b) by inducing third parties, including its users
`
`and/or customers, to directly infringe through their operation and use of the Accused Products. Lyft has knowingly and intentionally
`induced this direct infringement by, inter alia, (i) selling, importing, or otherwise providing the Accused Products to third parties with
`the intent that the Accused Products will be operated and used in a manner that practices the Asserted Claims; and (ii) marketing and
`advertising the Accused Products. Lyft’s marketing and promotional materials for the Accused Products are found, for example, on
`Lyft’s website, and in App stores of operating systems for which the Accused Products are made available. For example, Lyft’s website
`offers customers instructions and/or manuals for the Accused Products that instruct customers to, among other things, use the accused
`services in the Accused Products. Lyft’s website also offers support to customers, including instruction to, among other things, use the
`Accused Products share location information with a group of users. Lyft knows, or should have known, that its actions will result in
`infringement of the Asserted Claims, or subjectively believes that there is a high probability that its actions will result in infringement
`of the Asserted Claims but has taken deliberate actions to avoid learning these facts.
`
`Lyft also contributorily infringes each of the Asserted Claims in violation of 35 U.S.C. § 271(c) by selling, importing, offering
`
`for sale, and otherwise providing the Accused Products, which when used directly infringe the Asserted Claims. The Accused Products
`constitute a material part of the Asserted Claims.
`
`
`1 There is no operative complaint asserting non-infringement of any patent claim in this action at this time. AGIS Software reserves
`the right to update its contentions upon receipt of any future amended complaint.
`
`C-1
`
`

`

`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`The following chart identifies specifically where each limitation of each Asserted Claim is found within the Accused Products,
`
`and in particular, the corresponding elements that meet the limitations in the Lyft and Lyft Driver applications, services, and services.
`On information and belief, each charted version of the Lyft and Lyft 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 ʼ100 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.
`
`C-2
`
`

`

`
`
`-
`
`Claim
`10,299,100
`1[P]. A method
`performed by a
`mobile
`device
`having a display
`and one or more
`processors,
`the
`method
`comprising:
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`The Lyft Accused Products perform a computer implemented method as set forth below. Lyft further infringes
`directly and/or indirectly by performing, inducing others to perform, and/or contributing to the performance of: a
`method performed by a mobile device having a display and one or more processors.
`
`
`
`For example, Lyft provides Lyft Rider 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.
`
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
`
`
`C-3
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
` https://www.lyft.com/drive-with-lyft
`
`
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`C-4
`
`
`
`
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`
`C-5
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`
`C-6
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`
`
`C-7
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: executing operations on the one or more processors of the mobile device.
`
`
`
`
`
`1[A]. executing
`operations on the
`one
`or more
`processors of the
`
`C-8
`
`

`

`
`
`-
`
`Claim
`10,299,100
`mobile
`device,
`the
`operations
`comprising:
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`
`Lyft’s apps perform the limitations by executing operations on processors (either hardware or software). Lyft’s
`apps perform the operations in conjunction with Lyft’s servers, which receive passenger’s request for a ride and
`communicates the request to the nearby drivers. The nearby drivers receive the request for a ride from the
`passengers which they accept or decline. The servers further facilitate the communication between the passenger
`and the allocated driver during a ride.
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 3:27
`
`
`
`C-9
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`
`C-10
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`C-11
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`
`C-12
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`C-13
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`
`C-14
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Driver’s mobile
`phone screen
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46, Annotated
`
`
`
`C-15
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`
`C-16
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Passenger’s
`mobile phone
`screen
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07, Annotated
`
`
`
`C-17
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`
`C-18
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-19
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-20
`
`

`

`
`
`Claim
`10,299,100
`
`1[B]. associating
`the
`mobile
`device with an
`identifier,
`wherein
`identifier
`corresponds to a
`network
`participant
`
`the
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: associating the mobile device with an identifier, wherein the identifier
`corresponds to a network participant.
`
`
`
`The Lyft app, either alone or in conjunction with services provided Lyft’s server and/or services, performs this
`limitation when it receives the account creation data from the Lyft app for riders. The Lyft app also performs this
`limitation, after account creation, during the sign-in or log-in process from the Lyft app for riders. The Lyft app
`also performs this limitation when the Lyft server requests status or other data via the Lyft app for riders. In all
`cases, the identifier is information associated with the identity of the rider, account, device, phone number, or Lyft
`app for riders. For example, a Lyft passenger sets up their account by providing details including but not limited
`to name, email address, and phone number. After verifying the details of the passenger, Lyft adds them to the Lyft
`platform or network of drivers and passengers. Thereafter, the passenger starts booking rides.
`
`
`C-21
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Source: https://www.lyft.com/driver.
`
`
`
`
`C-22
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`
`Source: https://account.lyft.com/auth?next=https%3A%2F%2Fwww.lyft.com%2Flogin%2Fjump.
`
`C-23
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
` https://help.lyft.com/hc/e/articles/115012926947-How-to-create-a-Lyft-account
`
`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: determining a device location corresponding to a geographical location of the
`mobile device.
`
`
`
`
`1[C].
`a
`determining
`device
`location
`corresponding to
`
`C-24
`
`

`

`
`
`-
`
`Claim
`10,299,100
`a
`geographical
`location of
`the
`mobile device
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`
`
`The Lyft app performs this limitation by determining the location of the device associated with the account or
`identity data described above. For example, the passenger’s Lyft app installed determines the passenger’s location
`and displays it on the map in the Lyft app. Similarly, the driver’s mobile phone with the Lyft Driver app installed
`determines the driver’s location and displays it on the map in the Lyft Driver app. The rider’s location comprises
`geographical coordinates or geotagged/geocoded/georeferenced information related to a rider’s geographical
`location.
`
`
`C-25
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-26
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-27
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`C-28
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`
`C-29
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Provided certain conditions are met, users of the Rider and Driver Apps can share their location with other users
`of Driver and Rider Apps as well as additional contacts, friends, and family. Lyft encourages and instructs users
`of the Rider and Driver Apps to configure their phones to share their locations. The Driver and Rider Apps are
`pre-configured to show the location of riders and drivers and to update the locations continuously. For example,
`the Rider App provides rider locations to Lyft Servers in the forms of pickup locations and current locations and
`Lyft Servers transmit these locations to Driver Apps with ride requests and trip details. The Rider App can
`update the pickup locations and current locations and these location updates are similarly transmitted to Lyft
`Servers and Driver Apps. In another example, the Driver App provides driver locations to Lyft Servers
`immediately during sign up or log in to the Driver App and continuously provides updates to the Lyft Servers
`before, during, and after rides. The Rider App can show the location of drivers before requesting a ride, after
`requesting a ride, after being matched with a particular driver, during the approach of the driver, and during the
`ride until the completion of the ride. In other circumstances, Rider and Driver Apps are configured by Lyft to
`permit users to share their locations with others by specifying contacts, friends, family members. In some
`instances, Lyft Servers create a link for distribution to others for access to maps containing shared locations
`from Lyft Servers. These shared locations permit others to track the locations of riders and drivers during rides
`provided by Lyft. Location sharing in Lyft’s products also enables features to view and share trip progress and
`to track locations and computed routes. These features are built in to the Rider and Driver Apps and serviced by
`Lyft Servers.
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: receiving, from a server, mapping data including a map and coordinate
`translation data correlating coordinates of positions on the map with corresponding coordinates of geographical
`locations.
`
`C-30
`
`1[D]. receiving,
`from a server,
`mapping
`data
`including a map
`
`

`

`
`
`-
`
`Claim
`10,299,100
`and
`coordinate
`translation data
`correlating
`of
`coordinates
`positions on the
`map
`with
`corresponding
`coordinates
`geographical
`locations
`
`of
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`
`
`
`The Lyft app performs this limitation because it receives maps and/or map tiles from a server for displaying a map
`in the Lyft app display. The Lyft app also receives data for correlating map coordinates to geographical locations.
`For example, the Lyft server transmits the calculated location coordinates of the passenger and nearby drivers to
`the passenger’s device and loads them on the map. Further, the location coordinates of the driver and the passenger
`(pickup location) are transmitted to the driver’s device during the ride request from the passenger. Once the ride
`is accepted and the passenger is picked up by the driver, the destination address of the passenger is also loaded on
`the map in the Lyft Driver app on the driver’s device.
`
`
`C-31
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-32
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-33
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger
`pickup
`location
`
`Driver’s
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`C-34
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`
`C-35
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
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`
`
`Passenger’s
`location
`(blue dot)
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 3:49
`
`
`
`C-36
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`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s location
`(blue dot)
`
`Driver’s
`location
`
`
`C-37
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`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Passenger’s
`destination location
`loaded after the
`driver picks him/her
`up
`
`
`
`C-38
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
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` https://www.youtube.com/watch?v=b31WorLlcqE at 9:40
`
`C-39
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`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Passenger’s
`destination location
`loaded after the
`driver picks him/her
`up
`
`
`C-40
`
`

`

`
`
`Claim
`10,299,100
`
`receiving,
`1[E].
`from a server,
`location
`data
`indicating
`vehicle locations
`of one or more
`vehicles
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`See also 1[C].
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS reserves the
`right to supplement these contentions pursuant to production of such source code by Lyft and to the extent Lyft
`requires additional information in accordance with P.R. 3-1 and for any other reasons.
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform, and/or
`contributing to the performance of: receiving, from a server, location data indicating vehicle locations of one or
`more vehicles.
`
`
`
`The Lyft app performs this limitation because it receives vehicle location data from a server and that vehicle
`location data indicates the locations of drivers/vehicles. For example, the Lyft server transmits the calculated
`location coordinates of the passenger and nearby drivers (“location data indicating vehicle locations of one or
`more vehicles”) to the passenger’s device and loads them on the map in the Lyft app on the passenger’s device.
`
`
`C-41
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`

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`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-42
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-43
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`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`See also 1[C].
`
`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: marking the map with a plurality of symbols comprising: a participant symbol
`corresponding to the device location, one or more facility symbols corresponding to respective facility locations
`of one or more facilities, and one or more vehicle symbols corresponding to the respective vehicle locations of the
`one or more vehicles.
`
`
`
`The Lyft app performs this limitation because the Lyft app displays multiple symbols on its map, including a
`symbol for vehicles, facilities, businesses, landmarks, and other points of interest. For example, the map in the
`Lyft app on the passenger’s device comprises a blue dot (“participant symbol”) depicting the passenger’s current
`location. The map also identifies a pickup location which may correspond to the current location of the rider.
`Further, the map also highlights locations including but not limited to airports, road names, parks, shops and
`railway stations (“facility symbol”). The location of the nearby drivers is highlighted on the map in the passenger’s
`device using vehicle icons.
`
`
`C-44
`
`a
`
`1[F]. marking the
`map with
`a
`plurality
`of
`symbols
`comprising:
`participant
`symbol
`corresponding to
`the
`device
`location, one or
`more
`facility
`symbols
`corresponding to
`respective
`facility locations
`of one or more
`facilities,
`and
`one
`or more
`vehicle symbols
`corresponding to
`the
`respective
`vehicle locations
`of
`the one or
`
`

`

`
`
`-
`
`Claim
`10,299,100
`more
`vehicles,
`wherein marking
`the
`map
`comprises
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-45
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-46
`
`

`

`
`
`Claim
`10,299,100
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`
`
`See also 1[C].
`
`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: wherein marking the map comprises: determining, based at least in part on the
`vehicle locations and the coordinate translation data, positions on the map corresponding to the vehicle locations,
`displaying the map on the display of the mobile device, and placing the vehicle symbols on the map at the
`determined positions corresponding to the vehicle locations.
`
`
`
`The Lyft app performs this limitation because it determines where to place symbols on its map and places those
`symbols based on the data received from the server. For example, the Lyft server determines the location
`coordinates of the nearby drivers with respect to the passenger and transmits them to the Lyft app on the
`passenger’s device. The location coordinates of the nearby drivers are loaded on the map and is displayed on the
`passenger’s device. Each vehicle on the map indicates the position of a nearby driver.
`
`
`1[G]. wherein
`marking the map
`comprises:
`determining,
`based at least in
`part
`on
`the
`vehicle locations
`and
`the
`coordinate
`translation data,
`positions on the
`map
`corresponding to
`the
`vehicle
`locations,
`displaying
`map
`on
`display of
`
`the
`the
`the
`
`C-47
`
`

`

`
`
`-
`
`Claim
`10,299,100
`mobile
`device,
`and
`the
`placing
`vehicle symbols
`on the map at the
`determined
`positions
`corresponding to
`the
`vehicle
`locations.
`
`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`Lyft’s Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`C-48
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`current location
`(purple dot) and
`pickup location
`
`
`
`
`C-49
`
`

`

`RESTRICTED CONFIDENTIAL SOURCE CODE
`
`Attachment C for US Patent No. 10,299,100 Against Lyft Accused Products
`
`-
`
`Lyft’s Accused Products
`
`
`
`Claim
`10,299,100
`
`See also 1[C] and 1[F].
`
`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: responsive to user selection of a portion of the display corresponding to a
`position on the map, identifying a selected facility symbol based on the selected position, comprising: initiating a
`search of a set of symbols including the facility symbols for a symbol located nearest to the selected position and,
`based on a result of the search, identifying the selected facility symbol as the symbol located nearest to the selected
`position.
`
`
`
`The Lyft app performs this limitation because it receives user input data regarding pickups, stops or destinations
`entered by a user and those pickups, stops or destinations correspond to geographical locations on a map. For
`example, the Lyft passenger users the Lyft app for riders to select a pickup location and a destination location.
`The Lyft passenger can add entities of interest and select one or more entities of interest as a pickup or destination.
`The Lyft passenger can choose the pickup/stop/destination location by entering an address/location/shortcut or by
`choosing it on a map which will add/enter a symbol on the map and the passenger can change the location of the
`added/enter symbol to specify the location of the added/entered symbol as a pickup/stop/destination. Each of
`these methods will cause a symbol corresponding to the pickup/stop/destination to be added/entered on the map
`at the corresponding location. When the passenger completes this process, data associated with the added/entered
`symbol as a pickup/stop/destinat