`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`FALL LINE PATENTS, LLC,
`
`Plaintiff,
`
`v.
`
`CHOICE HOTELS INTERNATIONAL,
`INC.,
`
`Defendant.
`
`CIVIL ACTION NO. 6:17-CV-00407
` (Consolidated Lead Case)
`
`JURY TRIAL DEMANDED
`
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`Fall Line provides the following disclosures under Patent Local Rules 3-1 and 3-2. These
`
`disclosures and contentions are made with respect to United States Patent No. 9,454,748
`
`(“Asserted Patent”).
`
`I.
`
`Patent Rule 3-1
`
`(a) Identification of Infringed Claims
`
`Choice Hotels: claims 19-22 of the Asserted Patent.
`
`Uber: claims 19-22 of the Asserted Patent.
`
`(b) Identification of Accused Instrumentalities/Methods
`
`For each of the above claims, the Accused Instrumentalities are as follows:
`
`For Choice Hotels, the Choice Hotels mobile android app, the use of the mobile app by the
`
`end user, the mobile app running on a mobile device, and the associated back-end servers.
`
`For Uber, the Uber mobile android app, the use of the mobile app by the end user, the mobile
`
`app running on a mobile device, and the associated back-end servers.
`
`Starbucks Corporation, et al. – Ex. 1008
`U.S. Patent No. 9,454,748
`
`
`
`(c) Claim Charts
`
`The claim charts required by Patent Local Rule 3-1(c) are attached as Exhibit 1 (Choice
`
`Hotels) and Exhibit 2 (Uber).
`
`(d) Doctrine of Equivalents
`
`In the attached claim charts, Fall Line asserts that each claim limitation is literally infringed.
`
`Fall Line reserves the right to assert additional theories under the doctrine of equivalents in
`
`response to claim construction positions that defendants may take.
`
`(e) Priority Claims to Earlier Patent Applications
`
`Each of the asserted claims of the Asserted Patent is entitled to a priority date of August 19,
`
`2002.
`
`(f) Fall Line’s Instrumentalities
`
`Fall Line does not intend to rely on the assertion that any of its own applications practice the
`
`Asserted Patent.
`
`II.
`
`Patent Rule 3-2
`
`(a) Fall Line is producing documents responsive to Patent Rule 3-2(a) numbered
`
`FALL_0002668-2738. These documents have been designated as confidential under the
`
`protective order and are required be treated as attorneys eyes only.
`
`(b) Fall Line is producing documents responsive to Patent Rule 3-2(b) numbered
`
`FALL_0002602-2738. These documents have been designated as confidential under the
`
`protective order and are required be treated as attorneys eyes only.
`
`(c) Fall Line is producing documents responsive to Patent Rule 3-2(c) numbered
`
`FALL_000001-2601.
`
`2
`
`
`
`Dated: October 16, 2017
`
`/s/ Michael D. Ellis
`Matthew J. Antonelli
`Texas Bar No. 24068432
`matt@ahtlawfirm.com
`Zachariah S. Harrington
`Texas Bar No. 24057886
`zac@ahtlawfirm.com
`Larry D. Thompson, Jr.
`Texas Bar No. 24051428
`larry@ahtlawfirm.com
`Michael D. Ellis
`Texas Bar No. 24081586
`michael@ahtlawfirm.com
`
`ANTONELLI, HARRINGTON
`& THOMPSON LLP
`4306 Yoakum Blvd., Ste. 450
`Houston, TX 77006
`(713) 581-3000
`
`Attorneys for Fall Line Patents, LLC
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 16th day of October, 2017, I electronically served the
`
`foregoing via email to all counsel of record.
`
`/s/ Michael D. Ellis
`Michael D. Ellis
`
`4
`
`
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