Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`In these Infringement Contentions, AGIS Software Development LLC (“AGIS”) contends that at least the following claims of
`
`U.S. Patent No. 9,445,251 (the “’251 Patent”) identified below are infringed by the Accused Products (i.e., phones, tablets, media
`players, and servers, as well as, operating systems and software thereon) which are manufactured, sold, offered for sale, and/or used
`by Apple Inc. (“Apple”).
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`
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`The Accused Products comprise Apple products running the iOS mobile operating system, including iPhone, iPad, and iPod
`
`Touch models sold during and after 2011. For example, the Accused Products comprise the following iOS-based devices: iPhone 4s
`(A1431, A1387), iPhone 5, (A1428, A1429, A1442), iPhone 5C (A1456, A1507, A1516, A1529, A1532), iPhone 5S (A1453, A1457,
`A1518, A1528, A1530, A1533), iPhone SE (A1723, A1662, A1724), iPhone 6 (A1549, A1586, A1589), iPhone 6 Plus (A1522,
`A1524, A1593), iPhone 6S (A1633, A1688, A1700), iPhone 6S Plus (A1634, A1687, A1699), iPhone 7 (A1660, A1778, A1779),
`iPhone 7 Plus (A1661, A1784, A1785), iPhone 8, iPhone 8 Plus, iPhone X, iPad (A1219, A1337), iPad 2 (A1395, A1396. A1397),
`iPad 3rd generation (A1416, A1430, A1403), iPad 4th generation (A1458, A1459, A1460), iPad 5th generation (A1822, A1823), iPad
`mini (A1432, A1454, A1455), iPad mini 2 (A1489, A1490, A1491), iPad mini 3 (A1599, A1600), iPad mini 4 (A1538, A1550), iPad
`Air (A1474, A1475), iPad Air 2 (A1566, A1567), iPad Pro 12.9-inch (A1584, A1652), iPad Pro 9.7-inch (A1673, A1674, A1675),
`iPad Pro 10.5-inch (A1701, A1709), iPad Pro 12.9-inch 2nd generation (A1670, A1671). The Accused Products comprise iPod touch
`4th generation (A1367), iPod touch 5th generation 16GB Mid 2013 (A1509), iPod touch 5th generation (A1509, A1421), iPod touch
`6th generation (A1574). The Accused Products comprise Apple Watch Series 1(A1801, A1802), Apple Watch Series 2 (A1757,
`A1758), Apple Watch Edition (A1816, A1817), Apple Watch Hermes (A1757, A1758), Apple Watch Nike+ (A1757, A1758), Apple
`Watch 1st generation (A1553, A1554), Apple Watch Sport (A1553, A1554), Apple Watch Edition (A1553, A1554), Apple Watch
`Hermes (A1553, A1554), Apple Watch Series 3 (GPS+Cellular) (various upcoming models), and Apple Watch Series 3 (GPS)
`(various upcoming models). The Accused Products comprise the iOS mobile operating systems, including the following versions (and
`all intervening updates and sub-versions): iOS 4, iOS 5, iOS 6, iOS 7, iOS 8, iOS 9, iOS 10, and iOS 11. The Accused Products
`comprise the watchOS mobile operating systems, including the following versions (and all intervening updates and sub-versions):
`watchOS, watchOS 2, watchOS 3, and watchOS 4 (upcoming release on September 19, 2017). The Accused Products comprise apps,
`networks, servers, and/or services provided by Apple and related to: Find My iPhone, Find My Friends, iCloud, iTunes, Apple ID,
`Maps, iMessage, Messages, FaceTime, iOS Device Activation network, and SMS Text Forwarding. The Accused Products further
`comprise Apple’s iCloud (formerly MobileMe) services and Apple’s servers hosting iCloud (formerly MobileMe) data and services.
`The Accused Products comprise Apple Maps services and Apple’s internal servers hosting Apple Maps data and services, as well as,
`third-party servers providing Apple with data and services for use with Apple Maps. The Accused Products comprise Apple Messages
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`C-1
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`and iMessage services and Apple’s internal servers hosting Apple Messages and iMessage data and services, as well as, third-party
`servers providing Apple with data and services for use with Apple Messages and iMessage data and services.
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`
` AGIS does not concede that any claims of the ’251 Patent that are not listed below are not infringed by the identified 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 Apple’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 reserves the
`right to supplement, correct, modify, and/or amend these contentions once such additional information is made available to AGIS.
`Furthermore, AGIS reserves the right 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); in view of any positions taken by Apple, 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.
`
`US9445251B2
`1[P]. A computer-
`implemented method
`comprising:
`
`Apple
`The Accused Products include Apple’s iOS-based devices, e.g. iPhones, iPads, and iPods; and watchOS-
`based devices, e.g. Apple Watches. These devices implement the method as follows.
`
`Each of the Accused Products is a first device programmed to perform operations as set forth below. Each of
`the Accused Devices is programmed to perform these operations by Apple via Apple’s iOS software and
`associated apps provided by Apple.
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`For example, the Accused Products are programmed with application frameworks such as Location Services,
`which provide device-location features to iOS and/or applications running on iOS.1 (e.g. Find My iPhone,
`Family Sharing, and Find My Friends). iOS is integrated with centralized features and/or applications (e.g.
`iCloud and Maps). Alternatively, any device with a browser or device-location application can access device-
`location features through iCloud.com.
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`1 See, e.g., https://support.apple.com/en-us/HT203033 , https://support.apple.com/en-us/HT207056
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`C-2
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`See https://support.apple.com/explore/find-my-iphone-ipad-mac-watch
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`C-3
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
`See https://support.apple.com/kb/PH2698?locale=en_US
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`See https://support.apple.com/en-us/HT201493
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`C-4
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`See http://www.apple.com/icloud/family-sharing/
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`See https://support.apple.com/en-us/HT201060
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`C-5
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`[1A] with a first
`device, receiving a
`message from a
`second device,
`wherein the message
`relates to joining a
`group;
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`
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`Apple
`
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`The Accused Products practice receiving a message from a second device, wherein the message relates to
`joining a group. Each Accused Product (“first device”) is programmed to receive messages from other
`devices (second device) such as, for example, other Apple iOS products. The Accused Products are capable
`of forming groups as set forth below.
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`For example, an Accused Product is joined to a group (e.g. Apple services such as the iCloud and iMessage
`services) using an Apple ID. Alternatively, any device with a browser or a device-location application can
`sign on to an Apple service. The Apple ID corresponds to one or more groups. These groups include, for
`example, the iCloud network, “friends” or “families” as defined by association with device-location features
`and applications (e.g., Find My iPhone, Find My Friends, and Family Sharing.)
`
`In establishing these groups, each Accused Product receives messages from other devices, e.g. other Accused
`Products, related to forming a group.
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`For example, in the case of “Find iPhone,” multiple devices can be associated to the same Apple ID identifier,
`thereby resulting in a single Apple ID corresponding to a group of devices.
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`C-6
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-7
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-8
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`Additionally, verification messages within an iTunes account are messages from a second device related to
`joining a group (e.g. the iTunes account group).
`https://support.apple.com/library/content/dam/edam/applecare/images/en_US/appleid/ios10-iphone7-apple-id-
`sign-in-allow.jpg
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`C-9
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-10
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://support.apple.com/apple-id
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`https://support.apple.com/en-us/HT205362
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`C-11
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://support.apple.com/en-us/HT204230
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`C-12
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`US9445251B2
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
`Additionally, in the case of iMessages and Find My Friends, each Accused Product can receive messages
`from other Apple devices, such as other Accused Products, that relate to sharing location and messages. See,
`e.g., the “Road Trip” group below and associated messages. The receipt of the message includes receiving a
`message for a new group iMessage where the users have location sharing enabled.
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`https://www.cio.com/article/2455171/mobile/apple-gets-serious-about-social-adds-familiar-functions-to-
`imessage.html
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`As a further example, the Find My Friends app provides “friends followers, and temporary event limits.”
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`C-13
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`Friends, followers, and temporary events limits
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` You can follow up to 50 friends.
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` You can have up to 50 friends follow you.
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` You can participate in up to 10 temporary events.
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` Each temporary event can contain up to 50 friends.
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` Temporary friends don't count against your permanent friends limits.
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`https://support.apple.com/en-us/HT201493
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`The Accused Products practice, based on receiving the message from the second device, participating in the
`group, wherein participating in the group includes sending first location information to a server and receiving
`second location information from the server, the first location information comprising a location of the first
`device, the second location information comprising a plurality of locations of a respective plurality of second
`devices included in the group.
`
`For example, users enable location services on the Accused Products and share their device-location data to
`an Apple online service such as the iCloud service (e.g., one or more Apple servers). When a user “shares”
`their device-location data, the location of the device is communicated to an Apple online service such as the
`iCloud service.
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`Within each group, each device sends information related to its location to an apple online service. That
`location information is communicated to each member of the group. Each of these groups exist as, for
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`C-14
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`[1B] based on
`receiving the message
`from the second
`device, participating
`in the group, wherein
`participating in the
`group includes
`sending first location
`information to a
`server and receiving
`second location
`information from the
`server, the first
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
`example, a relationship stored on the Accused Products and/or Apple servers.
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`US9445251B2
`location information
`comprising a location
`of the first device, the
`second location
`information
`comprising a plurality
`of locations of a
`respective plurality of
`second devices
`included in the group;
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`C-15
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-16
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-17
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://developer.apple.com/library/content/documentation/UserExperience/Conceptual/LocationAwar
`enessPG/Introduction/Introduction.html#//apple_ref/doc/uid/
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`https://developer.apple.com/library/content/documentation/UserExperience/Conceptual/LocationAwar
`enessPG/CoreLocation/CoreLocation.html#//apple_ref/doc/
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`Furthermore, on information and belief, the following software methods are used in part to provide and
`receive location updates from Apple’s servers.
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`C-18
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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``
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`C-19
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://developer.apple.com/documentation/corelocation/cllocationmanager
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`This limitation is met when sharing a location manually, or automatically sharing a location when location
`sharing is enabled amongst the chat group participants.
`The Accused Products practice presenting, via an interactive display of the first device, a first interactive,
`georeferenced map and a plurality of user-selectable symbols corresponding to the plurality of second
`devices, wherein the symbols are positioned on the first georeferenced map at respective positions
`corresponding to the locations of the second devices, and wherein the first georeferenced map includes data
`relating positions on the first georeferenced map to spatial coordinates.
`
`For example, the Accused Products display at least one user-selectable map with symbols corresponding to
`respective Accused Products of friends, family, or other iCloud users. Each symbol corresponds to the
`approximate device-location of the Accused Products. The maps are georeferenced maps (e.g., standard map,
`transit, and satellite maps) and points on these maps correspond to spatial coordinates. Alternatively, any
`device signed onto the iCloud service can display the user-selectable map with symbols representing Accused
`Products as described above.
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`C-20
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`[1C] presenting, via
`an interactive display
`of the first device, a
`first interactive,
`georeferenced map
`and a plurality of
`user-selectable
`symbols
`corresponding to the
`plurality of second
`devices, wherein the
`symbols are
`
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
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`Each of the Accused Products further includes, on the map, information corresponding to each of the other
`Accused Devices within the group. This information includes, for example, names, locations, and avatar
`images.
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`US9445251B2
`positioned on the first
`georeferenced map at
`respective positions
`corresponding to the
`locations of the
`second devices, and
`wherein the first
`georeferenced map
`includes data relating
`positions on the first
`georeferenced map to
`spatial coordinates;
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`C-21
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-22
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-23
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-24
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`[1D] sending, from
`the first device to the
`server, a request for a
`second georeferenced
`map different from
`the first
`georeferenced map,
`wherein the request
`specifies a map
`location;
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`
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`The Accused Products practice sending, from the first device to the server, a request for a second
`georeferenced map different from the first georeferenced map, wherein the request specifies a map location.
`
`As set forth above, each of the Accused Products includes the ability to view georeferenced maps, e.g., with
`the Apple Maps app or other applications with maps embedded. For example, the Accused Products request
`map data from one or more servers. In response to one of a number of user actions (e.g. zoom, drag or change
`focus, change map type, select another device or user), new map data is requested to complete the user’s
`action and the displayed map is replaced or updated accordingly. The Accused Products request new map
`data is requested from one or more servers. Alternatively, any device signed-in to the iCloud service may
`request the map data described above. Each of these requests will specify an area of a map, such as a map tile
`(either panned or zoomed) that corresponds to a location on the map.
`
`Another example of this limitation includes toggling between map types. In response to user action, a second
`map can be called with satellite imagery, which would be retrieved from a different server source having
`satellite information. These maps are delivered based on a request specifying a location. Another example is
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`C-25
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`US9445251B2
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
`when a user zooms into a standard map and a transmit map is retrieved and overlaid or otherwise included to
`form a second map with transit data pulled from a transit data server.
`
`For example, the Accused Products may request map data from one or more servers including: © 2012-2016
`Apple Inc.; © 1992 – 2015 TomTom; © BEV; © DAV; Michelin data © Michelin 2015; GeoBasis-
`DE/Geobasis NRW 2015; © Base data Bakosurtanal; © Royal Jordanian Geographic center; © FICHIER DE
`BASE DES ADRESSES GEOCODEES; © ROSREESTR; © Swisstopo; Apeldoorn 2015; Code-Point®
`Open data; Clear Channel Broadcasting © 2015; © 2014 Acxiom; © 2016 Apontador; © 2015 Booking.com;
`© 2016 CarCharging, Inc.; © 2016 ChargePoint, Inc.; © 2014 CoreLogic Inc; © 2015 DAC Group; © 2015
`Das Örtliche; © 2013 DigitalGlobe; © 2013 Microsoft Corp; © 2014 DMTI; © 2015 Factual; © 2016 DTG
`BV; © 2016 Fonecta Oy; © 2015 Foursquare; © 2015 GasBuddy/OpenStore, LLC; © 2012 Getchee; © 2016
`Golden Pages; © 2015 GreatSchools, Inc; © 2014 Hexagon; © 2012 Intermap; © 2015 Tripadvisor; © 2012
`Waze; © 2015 Yelp; 511 NY; among others.
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`This limitation is further met when the first map is refreshed or otherwise updated. These updates can occur
`in real time.
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`http://gspe21.ls.apple.com/html/attribution-46.html
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`C-26
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-27
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`http://help.apple.com/iphone/10/#/iph1df24639
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`See, also, Apple’s MapKit software interface
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`C-28
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://developer.apple.com/reference/mapkit/mkmapviewdelegate
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`C-29
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`[1E] receiving, from
`the server, the second
`georeferenced map,
`wherein the second
`georeferenced map
`includes the requested
`location and data
`relating positions on
`the second
`georeferenced map to
`spatial coordinates;
`
`
`The Accused Products receive, from the server, the second georeferenced map, wherein the second
`georeferenced map includes the requested location and data relating positions on the second georeferenced
`map to spatial coordinates.
`
`For example, Apple receives map data from one or more servers (e.g. one or more Apple servers including
`map servers, iCloud servers, and gateway servers). In response to one of a number of user actions (e.g. zoom,
`drag or change focus, change map type, select another device or user) and corresponding requests, new map
`data is received to complete the user’s action and the displayed map is replaced or updated accordingly. The
`Accused Products receive new map data from one or more servers. Alternatively, any device signed-in to the
`iCloud service may receive the map data described above.
`
`For example, the Accused Products may receive map data from one or more servers including: © 2012-2016
`Apple Inc.; © 1992 – 2015 TomTom; © BEV; © DAV; Michelin data © Michelin 2015; GeoBasis-
`DE/Geobasis NRW 2015; © Base data Bakosurtanal; © Royal Jordanian Geographic center; © FICHIER DE
`BASE DES ADRESSES GEOCODEES; © ROSREESTR; © Swisstopo; Apeldoorn 2015; Code-Point®
`Open data; Clear Channel Broadcasting © 2015; © 2014 Acxiom; © 2016 Apontador; © 2015 Booking.com;
`© 2016 CarCharging, Inc.; © 2016 ChargePoint, Inc.; © 2014 CoreLogic Inc; © 2015 DAC Group; © 2015
`Das Örtliche; © 2013 DigitalGlobe; © 2013 Microsoft Corp; © 2014 DMTI; © 2015 Factual; © 2016 DTG
`BV; © 2016 Fonecta Oy; © 2015 Foursquare; © 2015 GasBuddy/OpenStore, LLC; © 2012 Getchee; © 2016
`Golden Pages; © 2015 GreatSchools, Inc; © 2014 Hexagon; © 2012 Intermap; © 2015 Tripadvisor; © 2012
`Waze; © 2015 Yelp; 511 NY; among others.
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`C-30
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`US9445251B2
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`
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`Apple
`See Ex. L [http://gspe21.ls.apple.com/html/attribution-46.html]
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`See, also, Apple’s MapKit software interface
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`C-31
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://developer.apple.com/reference/mapkit/mkmapviewdelegate
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`C-32
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`See Ex. R
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`The Accused Products practice presenting, via the interactive display of the first device, the second
`georeferenced map and the plurality of user-selectable symbols corresponding to the plurality of second
`devices, wherein the symbols are positioned on the second georeferenced map at respective positions
`corresponding to the locations of the second devices.
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`For example, the Accused Products present a second map in response to a number of scenarios, including one
`or more user actions (e.g. zoom, drag or change focus, change map type, select another device or user), as
`described above. Additionally, a user may choose to navigate to a user or device represented by the symbol,
`which in turn requested new map data and the display of a new map. With respect to a second set of second
`devices, the new map data will display symbols representing Accused Products at their respective locations.
`Because the new map represents a different map area, it will include the second set of symbols representing
`Accused Products at their respective locations.
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`See also Claim limitation [1C] above.
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`C-33
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`[1F] presenting, via
`the interactive display
`of the first device, the
`second georeferenced
`map and the plurality
`of user-selectable
`symbols
`corresponding to the
`plurality of second
`devices, wherein the
`symbols are
`positioned on the
`second georeferenced
`map at respective
`positions
`corresponding to the
`locations of the
`second devices;
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-34
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-35
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-36
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`C-37
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
`
`Apple
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`The Accused Products identify user interaction with the interactive display selecting one or more of the user-
`selectable symbols corresponding to one or more of the second devices and positioned on the second
`georeferenced map and user interaction with the display specifying an action and, based thereon, using an
`Internet Protocol to send data to the one or more second devices via the server, wherein the first device does
`not have access to respective Internet Protocol addresses of the second devices.
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`For example, a user may interact with the map by using an input device or by touching the screen of the
`Accused Product at or around the location of the symbol. Then the user may select a corresponding action
`either directly or after navigating to another related menu after selecting the symbol corresponding to that
`user. Responsive to the chosen action, data can be sent to the chosen device over one or more Apple services
`such as the iCloud service, iMessage service, or Facetime service (i.e. server). Exemplary user actions
`include sending a message, sending media such as pictures, video, or prerecorded sound, initiating a call, or
`sending a sound to be played on the device, locking the device, or erasing the device.
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`C-38
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`[1G] and identifying
`user interaction with
`the interactive display
`selecting one or more
`of the user-selectable
`symbols
`corresponding to one
`or more of the second
`devices and
`positioned on the
`second georeferenced
`map and user
`interaction with the
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`

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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
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`US9445251B2
`display specifying an
`action and, based
`thereon, using an
`Internet Protocol to
`send data to the one
`or more second
`devices via the server,
`wherein the first
`device does not have
`access to respective
`Internet Protocol
`addresses of the
`second devices.
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`
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`Select a symbol
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`C-39
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`Exemplary Messaging options
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`Messages may include sound, video,
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`text, or combinations thereof
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`C-40
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`US9445251B2
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`Apple
`Communication between Accused Products can and do occur (upon information and belief) when a first
`device does not have a second device’s IP address. Instead, communication and location services are
`established by the requirement of signing-in to one or more Apple server services with a user’s Apple ID.
`One or more Apple servers forwards information from the First Device to one or more Second Devices and
`from one or more Second Devices to the First Device.
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`On information and belief, the communication of device-location information does not reveal a device’s IP
`address. Moreover, at least for iMessage and email communications, such communications are routed
`through Apple’s servers and the IP address of the sender/receiver is not revealed. Regarding FaceTime, such
`communication is at least initiated over Apple’s servers. On information and belief, such communications are
`encrypted and do not reveal IP addresses to individual devices.
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`Additionally, the First Device may communicate with one or more second devices using Find iPhone and
`Apple’s servers as follows:
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`C-41
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`http://www.apple.com/icloud/find-my-iphone.html
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`C-42
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`http://www.apple.com/icloud/find-my-iphone.html
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`C-43
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`http://www.apple.com/icloud/find-my-iphone.html#gallery-details-display-message
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`C-44
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://support.apple.com/kb/PH2699?locale=en_US&viewlocale=en_US
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`https://support.apple.com/kb/PH2701?locale=en_US&viewlocale=en_US
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`C-45
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`https://support.apple.com/en-us/HT201472
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`http://help.apple.com/icloud/#/mmfc0f0c67
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`Each of the Accused Products perform the method of claim 1, wherein the data includes a short message
`service message, a text message, an image, or a video. As set forth above, each Accused Product can send the
`following communications.
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`2. The method of
`claim 1, wherein the
`data includes a short
`message service
`message, a text
`message, an image, or
`a video.
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`C-46
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`Apple
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`Additionally, within iMessage, the Accused Products may send videos, images, sound, and text. Additionally
`within the Find iPhone app, the Accused Products can communicate sound and text.
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`C-47
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
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`3. The method of
`claim 1, wherein the
`first device is a
`personal digital
`assistant (PDA) or a
`personal computer
`(PC).
`4. The method of
`claim 1, wherein the
`second map is a
`satellite image.
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`
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`Apple
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`Each of the Accused Products performs the method of claim 1, wherein the first device is a personal digital
`assistant (PDA) or a personal computer (PC).
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`For example, one of skill in the art would understand that the Accused Products are at least personal digital
`assistants (PDA) within the ordinary meaning of the term because the Accused Products perform all of the
`functions of a PDA.
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`Each of the Accused Products performs the method of claim 1, wherein the second map is a satellite image.
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`Each of the Accused Products performs this method when the “satellite” button is selected:
`
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`5. The method of
`claim 1, further
`comprising sending,
`
`
`
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`Each of the Accused Products performs the method of claim 1, further comprising sending, by the first device,
`updated location information comprising an updated location of the first device, the updated location
`information being sent based on passage of a predetermined time interval since sending previous location
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`
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`C-48
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`Exhibit C for U.S. Patent No. 9,445,251 Against Apple Accused Products
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`US9445251B2
`by the first device,
`updated location
`information
`comprising an
`updated location of
`the first device, the
`updated location
`information being
`sent based on passage
`of a predetermined
`time interval since
`sending previous
`location information
`comprising a previous
`location of the first
`device, displacement
`of the first device by
`a predetermined
`distance relative to a
`previous location of
`the first device, or
`both.
`6. The method of
`claim 1, further
`comprising
`identifying second
`user interaction with
`the interactive display
`selecting at least one
`of the user-selectable
`symbols
`corresponding to at
`
`
`
`
`
`Apple
`information comprising a previous location of the first device, displacement of the first device by a
`predetermined distance relative to a previous location of the first device, or both.
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`For example the Accused Products utilize a location manager service such as CLLocationManager that
`monitors, among other things, periods of time that are predetermined, or displacement from a predetermined
`distance.
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`This method is thus performed at least when a user passes a geographic threshold that results in a location
`update (e.g., “leaves” notification). For example, Apple utilizes the following framework that meets this
`limitation as implemented on the Accused Products:
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`https://developer.apple.com/documentation/corelocation/cllocationmanager
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`Each of the Accused Products performs the method of claim 1, further comprising identifying second user
`interaction with the interactive display selecting at least one of the user-selectable symbols corresponding to
`at least one of the second devices and user interaction with the display specifying an action and, based
`thereon, initiating a phone call or phone conference with the at least one second device.
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`For example, the Accused Products include software that registers touch events with an interactive display,
`where tou