Exhibit 1: Infringement Claim Chart US10043188 vs OKC
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`
`
`Contents
`I.  Constructions .............................................................................................................. 1 
`II.  Evidence Reviewed ..................................................................................................... 1 
`III.  Claim 1 ........................................................................................................................ 2 
`IV.  Claim 5 ........................................................................................................................ 6 
`V.  Claim 9 ...................................................................................................................... 11 
`VI.  Claim 15 .................................................................................................................... 14 
`
`
`I.
`
`CONSTRUCTIONS
`See constructions for the following construed terms in Exhibit 2: Claim Construction for US10043188 vs. OKC
`First organization
`Program data
`Position
`Applicant entry
`Applicant hyperlink
`Reference class
`Reference source
`Reference electronic response
`Suggested reference list
`Computing device
`
`
`
`
`II.
`EVIDENCE REVIEWED
`Prosecution History
` US Patent 10043188
`Infringement Evidence
` Guardian-Software-Demo (“GA Demo video”) Originally at
`https://guardianalliancetechnologies.com/watch-demo/, later removed. Copy retained by Plaintiff.
` Guardian Full Demo v2 (“Guardian Full Demo v2”) https://www.youtube.com/watch?v=EgB5gMhcrX8
` Guardian Alliance Technologies - Investigation Software Overview (“GA Overview”)
`
`https://www.youtube.com/watch?time_continue=76&v=1gfZ0lm5HhU
` Oklahoma City in response to its November 2017 Request for Proposal 181003 for a Police Applicant
`Tracking Software for the Oklahoma City Police Department.
` Oklahoma City Police Department website (“OKC PD website”)
`https://www.okc.gov/departments/police/recruiting/application-process
` Departments pay a steep price for inefficiency – but it's not what you think; Article posted on Arizona State
`Troopers Association website (“AZ Troopers Article’): https://aztroopers.org/enews/departments-pay-a-
`steep-price-for-inefficiency-but-its-not-what-you-think
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`GUARDIAN EXHIBIT 1019
`Guardian Alliance Technologies, Inc. v. Miller
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`1
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`

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`III.
`
`CLAIM 1
`
`Claims
`1. A method for a computing device with a processor
`and a system memory to assist an investigator in
`conducting a background investigation of an applicant
`for a position within a first organization, comprising
`the steps of:
`
`receiving a first set of program data comprising
`information identifying the applicant, the position, the
`first organization, and the investigator;
`
`Evidence of infringement.
`The GA Demo video demonstrates the GA service, a
`method for assisting an investigator in conducting a
`background investigation of an applicant for a position
`within an organization.
`The GA service is a cloud-based service provided by
`remote servers leased from Amazon (GA Demo Video
`@ 0:30 – 1:13), so the “computing device” is a remote
`server under the control of GA. The existence of the
`components computing device - a processor and
`memory (computer readable medium) with instructions
`on how to provide the GA service – can be inferred as
`all computing devices have these components.
`OKC has access to the GA service and has been using
`all features of it. “The biggest positive change that
`Guardian Alliance Technologies brought to our
`department was the process efficiency that allowed us
`to automate many of the labor-intensive tasks like
`sending out a request for more information or asking
`for references.... With this new process we’re now on
`track to process approximately 2,300 to 2,500
`applications this year.” (AZ Troopers Article quoting
`Greg Taylor, project manager for OKC Police
`Department). “By using the platform, investigators can
`contact all of an applicant’s employers and references
`with the click of a button, automatically store all
`contact correspondence for neighborhood checks,
`contact other law enforcement agencies using securely
`stored data, track completed areas of investigation and
`easily pull final investigation reports without having to
`draft them from scratch” (AZ Troopers Article
`describing OKC Police Department use of the GA
`service).
`Under a direct infringement theory, access to the GA
`service gives OKC control over the GA service, at least
`the extent that OKC makes the GA service perform the
`method recited in this claim, which means OKC is
`performing the method.
`Under an indirect theory of infringement, GA
`maintains control over the GA service and the access
`granted OKC allows OKC to request (induce) GA to
`have the GA service to perform the recited method,
`which GA then causes the GA service to perform.
`In the GA Demo video, basic contact information is
`entered in through the Supervisor Portal, including
`name, phone number and email. - GA Demo Video @
`4:03. Later, the Applicant enters their SSN when they
`are sent a hyperlink to fill out their Personal History
`Statement (PHS). Afterwards, the Applicant is
`identified by SSN, which becomes linked not just the
`applicant entry for this position at this agency, but for
`all agencies. - GA Demo Video @ 4:28. “program data
`identifying the applicant” will read on either the basic
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`storing a new applicant entry in the system memory,
`the new applicant entry associated with the first set of
`program data;
`
`transmitting an applicant hyperlink to an applicant
`email address associated with the applicant, the
`applicant hyperlink for viewing the applicant set of
`electronic documents;
`
`contact information or the SSN since both are received
`at some point by the GA server.
`Position is a data field in the New Applicant tab that
`becomes part of the applicant entry – See GA Demo
`Video @ 3:57.
`Agency (first organization) is displayed on the
`Applicant’s Dashboard. – see GA Demo Video @ 4:41;
`Guardian Full Demo v2 @19:10. It is not clear from
`this video if this is part of the application entry or if it
`is tacked on separately. Agency is not displayed as a
`field in the Supervisor nor the Investigator Portals.
`However, information linking the Agency to the
`applicant entry is received by the GA server at some
`point.
`The claim step “receiving a first set of program data”
`reads on the GA server receiving information
`identifying the applicant, the position, the first
`organization, and the investigator, regardless of
`whether this information is received by the GA server
`in one bundle or coming in separately, possibly at
`different times.
`Basic contact information is entered in through the
`Supervisor Portal, including name, phone number and
`email. - GA Demo Video @ 4:03
`“once the applicant has been entered, you can assign
`them to an investigator, and the applicant will appear in
`the investigator’s dashboard.” – see GA Demo Video
`@ 4:08. This almost certain means this information has
`been saved to the GA server.
`“clicking on the applicant brings us to the details for
`that investigation.”– see GA Demo Video @ 6:35.
`“regardless of your classification all Guardian users
`access the platform through a secure online portal that
`encrypts data stored on gov cloud Amazon web
`servers.” GA Overview 1:05-1:16.
` “The applicant will receive an email inviting them to
`the Guardian system” - GA Demo Video @ 4:16-30;
`Guardian Full Demo v2 @18:26. The video does not
`show the contents of the email, but since the video says
`the GA system is cloud-based (GA Demo Video @
`0:30 – 1:13), it is a reasonable inference that the email
`has a hyperlink for viewing the documents. The
`Applicant Portal appears to be a web page which
`suggests a hyperlink was sent.
`The Applicant Portal has a section called “forms” that
`show a set of electronic documents. For each, there is a
`download and upload icon. The portal states “All items
`in the checklist must be turned into your investigator.”
`Though the video did not demonstrate this feature, the
`Applicant Portal appears to have electronic documents
`for viewing. The applicant questionnaire is itself an
`electronic document.
`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
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`receiving an applicant electronic response with a
`reference set of program data, wherein the reference set
`of program data comprises information regarding a
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`reference source, wherein the reference source is a
`person, the program data including a reference email
`address associated with the reference source;
`determining a reference class of the reference source
`based on the reference set of program data;
`
`selecting a reference set of electronic documents based
`on the reference class of the reference source;
`
`transmitting a reference hyperlink to the reference
`email address, the reference hyperlink for viewing the
`reference set of electronic documents associated with
`the position;
`
`receiving a reference electronic response to the
`reference set of electronic documents from the
`reference source;
`
`storing the reference electronic response in the system
`memory, associating the reference electronic response
`with the new applicant entry; and
`
`[Relatives/Personal References]” - GA Demo Video @
`9:50-10:00
`
`“family members are categorized by their relationship
`to the applicant.” - GA Demo Video @ 10:00-10:03
`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
`[Relatives/Personal References]” - GA Demo Video @
`9:50-10:00
`“All the data [from the PHS] is extracted into the
`appropriate categories.” - GA Demo Video @ 4:45-
`4:47
`The GA Demo video does not directly show that
`employers are also automatically extracted from the
`PHS and categorized as employers based on
`information in the PHS but states that it does occur.
`“…you can do the same type of thing with the
`contacting of the applicant’s previous employers.” -
`GA Demo Video @ 10:53
`Thus, a reasonable inference can be made that the
`Guardian service handles previous employers similar to
`handling of the personal references and determines the
`reference class of each based on information from the
`PHS.
`The demo video shows that a questionnaire can be sent
`to a selected relative. - GA Demo Video @ 10:25-
`10:31. This questionnaire appears specific for relatives.
`It is different than the questionnaire sent to previous
`employers, which is tailored to employers - GA Demo
`Video @ 11:15-11:21.
`The claim term “set of reference documents” reads on
`the questionnaire in the GA Demo Video.
`“you can easily email a questionnaire to every family
`member and reference all at once.... Each reference is
`going to receive a questionnaire that they can fill out
`from their computer or actually right from their phone,
`if they like....” - GA Demo Video @ 10:25-10:31
`The GA Demo Video does not show the contents of the
`email, so it does not show a reference hyperlink.
`However, the Full Demo v2 shows the email which
`reads: “Below you will find a link included in the email
`that will direct you to an online questionnaire.”
`Guardian Full Demo v2 @40:24 – 40:51.
`“their responses are automatically saved right here next
`to their names.” - GA Demo Video @ 10:42-10:43
`If the responses are saved by the GA server, they have
`been received by the GA server.
`“their responses are saved right here next to their
`names.” - GA Demo Video @ 10:42-10:43
`The responses from the references are not actually
`stored on the screen next to their names. The responses
`are certainly stored on the GA server and a link to the
`stored responses is displayed on the screen next to their
`names.
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`The link to the response is displayed on a web page for
`the applicant, identified by the applicant’s name and
`picture. Thus, the response has been associated with
`the new applicant entry.
`“Guardian...grabs all the known residences and work
`locations from the applicant’s PHS and will
`automatically grab the cities and figure out what
`counties they are actually in... displays agencies within
`that location.” - GA Demo Video @ 11:30-12:00
`“So what's happening is the system is automatically
`looking at any places of residence any places of work
`any places of Education and it is listing out the cities
`and the counties that are associated with those
`locations in preparation for your law enforcement
`agency checks.” - Guardian Full Demo v2 @34:36-
`34:54
`The GA server generates a suggested reference list of
`one or more law enforcement agencies based on the
`applicant address. Specifically, it looks to see what
`county the applicant’s address is in then generates a list
`of all known agencies in that county.
`
`generating a suggested reference list of one or more
`law enforcement agencies based on an applicant
`residential address.
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`IV.
`
`CLAIM 5
`
`Claims
`5. A non-transitory computer-readable medium having
`stored thereon instructions which, when executed by a
`processor of a computing device with a system
`memory, cause the computing device to perform the
`steps of a method to assist an investigator in
`conducting a background investigation of an applicant
`for a position within a first organization, the steps of
`the method comprising:
`
`Evidence of infringement.
`The GA Demo video demonstrates the GA service, a
`method for assisting an investigator in conducting a
`background investigation of an applicant for a
`position within an organization.
`The GA service is a cloud-based service provided by
`remote servers leased from Amazon (GA Demo
`Video @ 0:30 – 1:13), so the “computing device” is
`a remote server under the control of GA. The
`existence of the components computing device - a
`processor and memory (computer readable medium)
`with instructions on how to provide the GA service –
`can be inferred as all computing devices have these
`components.
`OKC has access to the GA service and has been
`using all features of it. “The biggest positive change
`that Guardian Alliance Technologies brought to our
`department was the process efficiency that allowed
`us to automate many of the labor-intensive tasks like
`sending out a request for more information or asking
`for references.... With this new process we’re now on
`track to process approximately 2,300 to 2,500
`applications this year.” (AZ Troopers Article quoting
`Greg Taylor, project manager for OKC Police
`Department). “By using the platform, investigators
`can contact all of an applicant’s employers and
`references with the click of a button, automatically
`store all contact correspondence for neighborhood
`checks, contact other law enforcement agencies
`using securely stored data, track completed areas of
`investigation and easily pull final investigation
`reports without having to draft them from scratch”
`(AZ Troopers Article describing OKC Police
`Department use of the GA service).
`Under a direct infringement theory, this access gives
`OKC control over the GA service, at least the extent
`of allowing OKC to use the non-transitory computer-
`readable medium (memory) encoded with the
`instructions to perform the method recited in this
`claim.
`Under an indirect theory of infringement, GA
`maintains control over the GA service and the access
`granted OKC allows OKC to request (induce) GA to
`use the non-transitory computer-readable medium
`(memory) encoded with the instructions to perform
`the recited method, which GA then so uses.
`In the GA Demo video, basic contact information is
`entered in through the Supervisor Portal, including
`name, phone number and email. - GA Demo Video
`@ 4:03. Later, the Applicant enters their SSN when
`they are sent a hyperlink to fill out their Personal
`History Statement (PHS). Afterwards, the Applicant
`is identified by SSN, which becomes linked not just
`the applicant entry for this position at this agency,
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`receiving a first set of program data comprising
`information identifying the applicant, the position, the
`first organization, and the investigator;
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`but for all agencies. - GA Demo Video @ 4:28.
`“program data identifying the applicant” will read on
`either the basic contact information or the SSN since
`both are received at some point by the GA server.
`Position is a data field in the New Applicant tab that
`becomes part of the applicant entry – See GA Demo
`Video @ 3:57.
`Agency (first organization) is displayed on the
`Applicant’s Dashboard. – see GA Demo Video @
`4:41; Guardian Full Demo v2 @19:10. It is not clear
`if this is part of the application entry or if it is tacked
`on separately. Agency is not displayed as a field in
`the Supervisor nor the Investigator Portals. However,
`information linking the Agency to the applicant entry
`is received by the GA server at some point.
`The claim step “receiving a first set of program data”
`reads on the GA server receiving information
`identifying the applicant, the position, the first
`organization, and the investigator, regardless of
`whether this information is received by the GA
`server in one bundle or coming in separately,
`possibly at different times.
`Basic contact information is entered in through the
`Supervisor Portal, including name, phone number
`and email. - GA Demo Video @ 4:03
`“once the applicant has been entered, you can assign
`them to an investigator, and the applicant will appear
`in the investigator’s dashboard.” – see GA Demo
`Video @ 4:08. This almost certain means this
`information has been saved to the GA server.
`“clicking on the applicant brings us to the details for
`that investigation.”– see GA Demo Video @ 6:35.
`“regardless of your classification all Guardian users
`access the platform through a secure online portal
`that encrypts data stored on gov cloud Amazon web
`servers.” GA Overview 1:05-1:16.
`“The applicant will receive an email inviting them to
`the Guardian system” - GA Demo Video @ 4:16-30;
`Guardian Full Demo v2 @18:26. The video does not
`show the contents of the email, but since the video
`says the GA system is cloud-based (GA Demo Video
`@ 0:30 – 1:13), it is a reasonable inference that the
`email has a hyperlink for viewing the documents.
`The Applicant Portal appears to be a web page which
`suggests a hyperlink was sent.
`The Applicant Portal has a section called “forms”
`that show a set of electronic documents. For each,
`there is a download and upload icon. The portal
`states “All items in the checklist must be turned into
`your investigator.” Though the video did not
`demonstrate this feature, the Applicant Portal
`appears to have electronic documents for viewing.
`The applicant questionnaire is itself an electronic
`document.
`
`storing a new applicant entry in the system memory,
`the new applicant entry associated with the first set of
`program data;
`
`transmitting an applicant hyperlink to an applicant
`email address associated with the applicant, the
`applicant hyperlink for viewing the applicant set of
`electronic documents;
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`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
`[Relatives/Personal References]” - GA Demo Video
`@ 9:50-10:00
`
`“family members are categorized by their
`relationship to the applicant.” - GA Demo Video @
`10:00-10:03
`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
`[Relatives/Personal References]” - GA Demo Video
`@ 9:50-10:00
`“All the data [from the PHS] is extracted into the
`appropriate categories.” - GA Demo Video @ 4:45-
`4:47
`The GA Demo video does not directly show that
`employers are also automatically extracted from the
`PHS and categorized as employers based on
`information in the PHS but states that it does occur.
`“…you can do the same type of thing with the
`contacting of the applicant’s previous employers.” -
`GA Demo Video @ 10:53
`Thus, a reasonable inference can be made that the
`Guardian service handles previous employers similar
`to handling of the personal references and
`determines the reference class of each based on
`information from the PHS.
`
`receiving an applicant electronic response with a
`reference set of program data, wherein the reference set
`of program data comprises information regarding a
`reference source, wherein the reference source is a
`person, the program data including a reference email
`address associated with the reference source;
`
`determining a reference class of the reference source
`based on the reference set of program data;
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`selecting a reference set of electronic documents based
`on the reference class of the reference source;
`
`transmitting a reference hyperlink to the reference
`email address, the reference hyperlink for viewing the
`reference set of electronic documents;
`
`The demo video shows that a questionnaire can be
`sent to a selected relative. - GA Demo Video @
`10:25-10:31. This questionnaire appears specific for
`relatives. It is different than the questionnaire sent to
`previous employers, which is tailored to employers -
`GA Demo Video @ 11:15-11:21.
`The claim term “set of reference documents” reads
`on the questionnaire in the GA Demo Video.
`“you can easily email a questionnaire to every family
`member and reference all at once.... Each reference
`is going to receive a questionnaire that they can fill
`out from their computer or actually right from their
`phone, if they like....” - GA Demo Video @ 10:25-
`10:31
`The GA Demo Video does not show the contents of
`the email, so it does not show a reference hyperlink.
`However, the Full Demo v2 shows the email which
`reads: “Below you will find a link included in the
`email that will direct you to an online questionnaire.”
`Guardian Full Demo v2 @40:24 – 40:51.
`“their responses are automatically saved right here
`next to their names.” - GA Demo Video @ 10:42-
`10:43
`If the responses are saved by the GA server, they
`have been received by the GA server.
` “their responses are saved right here next to their
`names.” - GA Demo Video @ 10:42-10:43
`The responses from the references are not actually
`stored on the screen next to their names. The
`responses are certainly stored on the GA server and a
`link to the stored responses is displayed on the
`screen next to their names.
`The link to the response is displayed on a web page
`for the applicant, identified by the applicant’s name
`and picture. Thus, the response has been associated
`with the new applicant entry.
`“Guardian...grabs all the known residences and work
`locations from the applicant’s PHS and will
`automatically grab the cities and figure out what
`counties they are actually in... displays agencies
`within that location.” - GA Demo Video @ 11:30-
`12:00
`“So what's happening is the system is automatically
`looking at any places of residence any places of
`work any places of Education and it is listing out the
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`receiving a reference electronic response to the
`reference set of electronic documents from the
`reference source;
`
`storing the reference electronic response in the system
`memory, associating the reference electronic response
`with the new applicant entry; and
`
`generating a suggested reference list of one or more
`law enforcement agencies based on an applicant
`residential address.
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`cities and the counties that are associated with those
`locations in preparation for your law enforcement
`agency checks.” - Guardian Full Demo v2 @34:36-
`34:54
`The GA server generates a suggested reference list of
`one or more law enforcement agencies based on the
`applicant address. Specifically, it looks to see what
`county the applicant’s address is in then generates a
`list of all known agencies in that county.
`
`
`
`
`
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`V.
`
`CLAIM 9
`
`Claims
`9. (Currently amended) A computing device configured
`to assist an investigator in conducting a background
`investigation of an applicant for a position within a first
`organization, comprising:
`
`Evidence of infringement.
`The GA Demo video demonstrates the GA service, a
`method for assisting an investigator in conducting a
`background investigation of an applicant for a
`position within an organization.
`The GA service is a cloud-based service provided by
`remote servers leased from Amazon (GA Demo
`Video @ 0:30 – 1:13), so the “computing device” is
`a remote server under the control of GA.
`OKC has access to the GA service and has been
`using all features of it. “The biggest positive change
`that Guardian Alliance Technologies brought to our
`department was the process efficiency that allowed
`us to automate many of the labor-intensive tasks like
`sending out a request for more information or asking
`for references.... With this new process we’re now on
`track to process approximately 2,300 to 2,500
`applications this year.” (AZ Troopers Article quoting
`Greg Taylor, project manager for OKC Police
`Department). “By using the platform, investigators
`can contact all of an applicant’s employers and
`references with the click of a button, automatically
`store all contact correspondence for neighborhood
`checks, contact other law enforcement agencies
`using securely stored data, track completed areas of
`investigation and easily pull final investigation
`reports without having to draft them from scratch”
`(AZ Troopers Article describing OKC Police
`Department use of the GA service).
`Under a direct infringement theory, access to the GA
`service gives OKC control over the computing
`device, at least the extent of allowing OKC to use the
`computing device to perform the method steps
`recited in this claim.
`Under an indirect theory of infringement, GA
`maintains control over computing device and the
`access granted OKC allows OKC to request (induce)
`GA to use the computing device to perform the
`recited method steps, which GA then so uses.
`
`The evidence for this element is based at least in part
`on reasonable inferences from observation.
`The GA service is provided as a cloud-based service
`provided by remote servers leased from Amazon
`(GA Demo Video @ 0:30 – 1:13), so the “computing
`device” is a remote server under the control of GA.
`The existence of its components can be reasonably
`inferred, including a processor and system memory
`with instructions on how to provide the GA service.
`The evidence for this element is based at least in part
`on reasonable inferences from observation.
`The GA service is provided as a cloud-based service
`provided by remote servers leased from Amazon
`(GA Demo Video @ 0:30 – 1:13), so the “computing
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`a processor; and
`
`a system memory, the system memory having
`instruction stored therein that when executed by the
`processor, cause the computing device to perform the
`steps of:
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`receiving a first set of program data comprising
`information identifying the applicant, the position, the
`first organization, and the investigator;
`
`storing a new applicant entry in the system memory,
`the new applicant entry associated with the first set of
`program data;
`
`device” is a remote server under the control of GA.
`The existence of its components can be inferred,
`including a processor and system memory with
`instructions on how to provide the GA service.
`The evidence that the recited step is performed by
`the processor is based at least in part on reasonable
`inferences from observation.
`In the GA Demo video, basic contact information is
`entered in through the Supervisor Portal, including
`name, phone number and email. - GA Demo Video
`@ 4:03. Later, the Applicant enters their SSN when
`they are sent a hyperlink to fill out their Personal
`History Statement (PHS). Afterwards, the Applicant
`is identified by SSN, which becomes linked not just
`the applicant entry for this position at this agency,
`but for all agencies. - GA Demo Video @ 4:28.
`“program data identifying the applicant” will read on
`either the basic contact information or the SSN since
`both are received at some point by the GA server.
`Position is a data field in the New Applicant tab that
`becomes part of the applicant entry – See GA Demo
`Video @ 3:57.
`Agency (first organization) is displayed on the
`Applicant’s Dashboard. – see GA Demo Video @
`4:41; Guardian Full Demo v2 @19:10. It is not clear
`if this is part of the application entry or if it is tacked
`on separately. Agency is not displayed as a field in
`the Supervisor nor the Investigator Portals. However,
`information linking the Agency to the applicant entry
`is received by the GA server at some point.
`The claim step “receiving a first set of program data”
`reads on the GA server receiving information
`identifying the applicant, the position, the first
`organization, and the investigator, regardless of
`whether this information is received by the GA
`server in one bundle or coming in separately,
`possibly at different times.
`Basic contact information is entered in through the
`Supervisor Portal, including name, phone number
`and email. - GA Demo Video @ 4:03
`“once the applicant has been entered, you can assign
`them to an investigator, and the applicant will appear
`in the investigator’s dashboard.” – see GA Demo
`Video @ 4:08. This almost certain means this
`information has been saved to the GA server.
`“clicking on the applicant brings us to the details for
`that investigation.”– see GA Demo Video @ 6:35.
`“regardless of your classification all Guardian users
`access the platform through a secure online portal
`that encrypts data stored on gov cloud Amazon web
`servers.” GA Overview 1:05-1:16.
`The evidence that the recited step is performed by
`the processor is based at least in part on reasonable
`inferences from observation.
`
`transmitting an applicant hyperlink to an applicant
`email address associated with the applicant, the
`applicant hyperlink for viewing the applicant set of
`electronic documents;
`MIME.004
`
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`“The applicant will receive an email inviting them to
`the Guardian system” - GA Demo Video @ 4:16-30;
`Guardian Full Demo v2 @18:26. The video does not
`show the contents of the email, but since the video
`says the GA system is cloud-based (GA Demo Video
`@ 0:30 – 1:13), it is a reasonable inference that the
`email has a hyperlink for viewing the documents.
`The Applicant Portal appears to be a web page which
`suggests a hyperlink was sent.
`The Applicant Portal has a section called “forms”
`that show a set of electronic documents. For each,
`there is a download and upload icon. The portal
`states “All items in the checklist must be turned into
`your investigator.” Though the video did not
`demonstrate this feature, the Applicant Portal
`appears to have electronic documents for viewing.
`The applicant questionnaire is itself an electronic
`document.
`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
`[Relatives/Personal References]” - GA Demo Video
`@ 9:50-10:00
`
`“family members are categorized by their
`relationship to the applicant.” - GA Demo Video @
`10:00-10:03
`“Guardian has automatically extracted all the
`information out of the PHS that relates to this tab
`[Relatives/Personal References]” - GA Demo Video
`@ 9:50-10:00
`“All the data [from the PHS] is extracted into the
`appropriate categories.” - GA Demo Video @ 4:45-
`4:47
`The GA Demo video does not directly show that
`employers are also automatically extracted from the
`PHS and categorized as employers based on
`information in the PHS but states that it does occur.
`“…you can do the same type of thing with the
`contacting of the applicant’s previous employers.” -
`GA Demo Video @ 10:53
`Thus, a reasonable inference can be made that the
`Guardian service handles previous employers similar
`to handling of the personal references and
`determines the reference class of each based on
`information from the PHS.
`The demo video shows that a questionnaire can be
`sent to a selected relative. - GA Demo Video @
`10:25-10:3