HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`APPENDIX TO DECLARATION OF DR. TIM A. WILLIAMS:
`
`Exempla Evidence of Bright Data Practicing Claims of U.S. Patent No. 10,257,319
`
`Summary: In my opinion, Bright Data’s residential proxy services practice at least claims 1-3, 17-18, 21-22, and 24-29 of US. Patent
`No. 10,257,319 as shown below.
`
`4
`
`Exemplary Evidence of Bright Data Practicing the Claim
`The Practicing Products are residential proxy services, each of which provides a system
`A methodfor use
`Claim 1
`design and method for use with a web server that responds to Hypertext Transfer Protocol
`with a first client
`Preamble
`(HTTP) requests andstoresafirst content identified by a first content identifier, the
`device, for use with a
`method being performed bya first client device.
`first server that
`comprises a web
`serverthat is a
`Hypertext Transfer
`Protocol (HTTP)
`server that responds
`to HTTP requests,
`the first server stores
`a first content
`identified by a first
`content identifier,
`and for use with a
`second server, the
`method bythe first
`client device
`comprising:
`
`Bright Data‘s residential proxy service is based on its Residential Proxy Network
`comprising hardware products, software/firmware/application products, or any
`combination thereof, either stand-alone or integrated with other products, used for, or in
`conjunction with this service, including butnot limited to Bright Data’s Proxy Manager,
`Bright Data’s Chromeextension, Bright Data’s Android applications, Bright Data’s
`Unblocker, Bright Data’s Data Collection Automation product and Bright Data’s API, as
`practicing the claims of the ‘319 Patent(“Practicing Products”). The Bright Data
`residential proxy service also includes an Android SDK, Windows SDK and Mac SDK,
`which provide the proxy client devices (e.g., connect peers) for Bright Data’s Practicing
`Products.
`
`The Practicing Products support sending HTTP requests to a web server that responds to
`HTTPrequests. The Practicing Products fetch over the Internet a first content, such as
`digital data. As shown in the examples below, the Practicing Products can be used to
`receive digital data such as pricing information from a web server. This first contentis
`identified by a first content identifier, which may include butis not limited to a URL or
`information derived from a URL.Thefirst content may includebits, nibbles, bytes,
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`
`The Practicing Products comprise proxy client devices with residential IP addresses. A
`customer can send HTTP requests to the second server, e.g., Super Proxy, the second
`server can send HTTP requests to the proxy client device, which can send HTTP requests
`to the web server, which is an HTTP web server. The web server responds to HTTP
`requests by sending the requested content to the proxy client device, which sends the
`requested content back to the customervia the second server.
`
`See, é.g.,
`
`The Practicing Products comprise proxy client devices, including client devices such as
`laptops, desktops, tablets, smart TVs, mobile devices including smart phones which have,
`for example, downloaded Bright Data’s SDK, each of which has its own identifier such as
`a residential IP address. Through the execution of Bright Data’s software, including the
`SDKinstalled on the proxy client devices, these proxy client devices perform the claimed
`methodsteps of the ‘319 Patent, including the sending ofits identifier to Bright Data’s
`second server(e.g. Super Proxy), the receiving of requests for content from Bright Data’s
`second server(e.g., Super Proxy), the sending of the requests to a first server that is a web
`server, the receiving of the corresponding requested content from the first server, and the
`sending of that content to Bright Data’s second server(e.g., Super Proxy) to go onto the
`customer.
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`72 million+ real residential IPs
`
`fv) Fastest residential speeds
`
`The industry's most popular &
`most trusted residential network
`
`@
`
`99.99%uptime- extremely stable
`
`Exemplary Evidence of Bright Data Practicing the Claim The world’s #1 Residential Proxy Networkenables you to access any website
`
`content regardless of location, while avoiding IP bans and CAPTCHAs. Bright
`Data’s Residential Proxies provide the most comprehensive geographic
`coverage, covering 195 locations including country andcity-level website
`targeting. With 72 million+ real IPs, shared by real people in our community
`sharing network,
`the Residential Network enables youto scale your data
`collection projects with the highest speeds andsuccessrates
`
`100% ethically-sourced proxies in e Gather vast amountsof public
`
`web datawith total anonymity
`
`resource-sharing community
`
`https://brightdata.com/proxy-types (EX. 2029)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary
`
`For optimized performance and the fastest response times, leverage Bright Data
`Super Proxy Servers located across the globe. Super proxies have efficient traffic
`
`ratios and a network that can handle huge fluctuations in traffic with increased
`speeds because of their size and locations.
`
`Broadest geographic coverage
`
`@
`
`The industry's best-performing
`
`@ Super ProxyServers
`
`Fastest responsetime in the
`
`Q industry
`
`@
`
`Easy integration for developers
`
`Works superblywell regardless of
`@ traffic scale
`
`2,600+ Super Proxy Servers
`@ stationed close to our peers
`across the globefor fastest service
`
`https://brightdata.com/proxy-types (EX. 2029)
`°
`:
`Whenshould | use the residential network?
`
`Evidence of Bright Data Practicing the Claim © SUPER PROXYSERVERS
`
`The Residential network contains real users IPs, with real ISP signature. When using the residential type ofIPs, it is
`harder for targetsites to deliver misleading information and require less efforts on your side to get the real data you
`need. In addition. the residential network gives you access to a vast network, which helps you to scale up according
`to your needs. To summarize, you should usethe residential network if the signature ofthe IP is important for your
`different activities, and/orif you are getting blocked by your targetsite.
`
`
`
`8 months ago.Updated | Follow
`
`
`
`https://help.brightdata.com/he/en-us/articles/4413 156951825-When-should-I-use-the-
`residential-network- (EX. 2035)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Whatarethe benefits of using a residential network?
`
`Gain the ability to access and crawl sophisticated target websites that your business would not otherwise have access to because of location-based blockades. You'll be
`able to craw!, view information and collect data using real user IPs-see how your ads appear to consumers around the world, or what prices are being displayed to
`customers in anotherlocation. Send an increased number ofconcurrent requests meaning your data collection efforts will almost never be slowed down by proxies or
`target sites.
`
`https://brightdata.com/proxy-types/residential-proxies (EX. 2014)
`
`How doesBright Data acquire its residential IPs?
`
`Bright Data hasbuilt a unique consumer IP model by which all involved parties are fairly compensatedfor their voluntary participation. App owners install a unique
`Software DevelopmentKit (SDK)to their applications and receive monthly remuneration based on the number of users who opt-in. App users can voluntarily opt-in
`and are compensated throughan ad-free user experience or enjoy an upgraded version ofthe appthey are using for free. These consumers or ‘peers’ serve as the
`basis of our network and can opt-out at any time. This modelhas broughtinto existence an unrivaled,first of its kind, ethically sound, and compliant network of real
`consumers.
`
`are always successful and accessis never cut in the middle of the month.”’)
`
`https://brightdata.com/proxy-types/residential-proxies (EX. 2014)
`
`Minimum costs for buying IPs when your project requires sending 1000
`requests per hour
`
`Project
`
`components
`
`FaeOeee Beh
`rik alles
`
`edicated data
`hse
`
`er
`
`Bandwidth (14.5GB a month)
`
`ole teal
`
`tdata.com/hc/en-us/articles/4413 16160744 1-Cost-effectiveness-of-
`:
`residential-IPs (EX. 2036)(“ Your information is always reliable because your requests
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`See also https://help.brightdata.com/hce/en-us/articles/4413167165969-Using-the-system
`(EX. 2037)(“You send your requests to the Super Proxy, and the Super Proxy relays them
`through a Proxy Peer on our network.”’)
`
`See also https://help.brightdata.com/hc/en-us/articles/4413222000017-Which-ports-and-
`protocols-are-supported-by-Bright-Data- (EX. 2038)(“Whichports and protocols are
`supported by Bright Data? Ports 80 and 443are available by default, supporting HTTP
`and HTTPSprotocols...”)
`
`See also https://help.brightdata.com/hc/en-us/articles/4413213552273-How-do-I-
`integrate-Bright-Data-as-my-proxy-network- (EX. 2039)(“How do I integrate Bright Data
`as my proxy network? The recommended wayto integrate Bright Data is through the
`open source Proxy Manager. Alternatively, you can find the Bright Data API here. For
`Firefox, chrome, or any other browser, use the Browsers APIintegration tool”’)
`
`For a discussion of the source code, please see claims la-d.
`
`See also https://help.brightdata.com/hc/en-us/articles/4413213588369-How-do-I-
`integrate-Bright-Data-into-a-web-browser-automation-tool- (EX. 2040)(“How do I
`integrate Bright Data into a web browser automation tool? Integrating Bright Data into a
`web browserautomation tool such as Selenium or Puppeteer can be done byroute to
`Bright Data super proxy port which iszproxy.lum-superproxy.i0:22225 and authenticate
`with your Bright Data Zone credentials....”’)
`
`See also https://help.brightdata.com/hc/en-us/articles/4413213983633-What-is-Bni
`Data-Proxy-Browser-Extension- (EX. 2041)(“Whatis Bright Data Proxy Browser
`Extension? It’s a browser extension that allows you to use Bright Data from your browser
`with minimum setup....”)(Note, step-by-step GIF on webpage)
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`receiving, from the
`secondserver, the
`first content
`identifier;
`
`Exemplary Evidence of Bright Data Practicing the Claim
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the step of receiving, from the second server, the first content identifier.
`
`See analysis of claim 1 preamble andthe other limitations of claim 1, which are fully
`incorporated by reference.
`
`The Practicing Products support sending HTTP requests to a web serverthat responds to
`HTTP requests. The Practicing Products fetch over the Intemeta first content, such as
`digital data. As shown in the examples below, the Practicing Products can be used to
`receive digital data such as pricing information from a webserver. This first contentis
`identified by a first content identifier, which may include butis not limited to a URL or
`information derived from a URL. Thefirst content may includebits, nibbles, bytes,
`characters, words, or strings, or may be composed offiles, or programs.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`For example, the customerclient device sends, e.g., an HTTP request comprisingthe first
`content identifier to the second server, e.g., Super Proxy, which in turn, sends the HTTP
`request comprising the first content identifier to the proxy client device. The proxy client
`device sends the HTTP request comprising the first content identifier to the web server in
`orderto fetch the requested content from the web server. Thus, the proxy client device
`receives the first content identifier from the second serverin order to fetch the requested
`content from the webserver.
`
`See, e.g., Bright Data Network Diagram, EX. 2018
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`
`
`
`
`
` For example, the web socket connections used by the client device and proxy server can
`support HTTP.
`
` sending, to the first
`
`This elementis literally present in the Practicing Products, because the Practicing
`serveroverthe
`Products performthe step of sending, to the first server over the Internet, a Hypertext
`
`Internet, a Hypertext|Transfer Protocol (HTTP) request that comprises the first content identifier.
`Transfer Protocol
`
`HTTP) request that
`
`SecTTne (EX. 2022)
`’ SecTTnn (2X. 2022)
`
`4 SecTT
`(EX. 2022)
`
`Se nn (2X. 2022)
`‘ SecAnn(FX 2022)
`
`7 See
`(EX. 2022)
`
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`See analysis of claim 1 preamble and the otherlimitations of claim 1, whichare fully
`incorporated by reference.
`
`The proxy client devices of the Practicing Products send, to the web server over an
`Internet, HTTP requests that comprise the first content identifier.
`
`Thefirst contentis identified by a first content identifier, which may include butis not
`limited to a URL orinformation derived from a URL.Theproxy client device receives
`the first content identifier from the second server, whichit sends to a web server.
`
`The first content may includea part or wholefiles, text, numbers, audio, voice,
`multimedia, video, images, music, computer program, or a part or a whole of a web-site
`page. The first content may be identified by a uniform resource locator (URL).
`
`comprisesthe first
`contentidentifier;
`
`and HTTPSprotocols...”)
`
`
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for claim la. See also bttps://help.brightdata.com/he/en-us/articles/4413222000017-Which-
`
`protocols-are-supported-by-Bright-Data- (EX. 2038)(“Which ports and protocols are
`supported by Bright Data? Ports 80 and 443 are available by default, supporting HTTP
`
`a (EX. 2022)
`
`'° See nn (EX. 2022)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Claim No.
`
`receiving, the first
`content from thefirst
`server over the
`Internet in response
`to the sending of the
`first content
`identifier; and
`
`See analysis of claim 1 preamble and the other limitations of claim 1, which are fully
`incorporated by reference.
`
`The proxyclient device of the Practicing Products receives the first content from the web
`server overthe Internet in response to the sending ofthe first contentidentifier.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for claim 1b.
`
`Exemplary Evidence of Bright Data Practicing the Claim
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the step of receiving, the first content from the first server over the
`Internet in response to the sending ofthe first content identifier.
`
`server.
`
`sending, the first
`content by the first
`client device to the
`second server, in
`response to the
`receiving ofthefirst
`contentidentifier.
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the step of sending the first content by the first client device to the
`secondserver, in responseto the receiving ofthe first content identifier.
`
`See analysis of claim 1 preamble and the other limitations of claim 1, which are fully
`incorporated by reference.
`
`A proxy client device of the Practicing Products sends the received first content, to the
`secondserver, in responseto the receiving of the first content identifier.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for Claim 1a and 1b. The content, received by the proxy client
`device from the web server, is then sent from the proxy client device to the proxy
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`
`
`Exemplary Evidence of Bright Data Practicing the Claim
`
`This elementis literally present in the Practicing Products, because the Practicing
`The method
`Claim 2
`according to claim 1,|Products perform the method according to claim 1, whereinthe first client device is
`whereinthe first
`identified by a Media Access Control (MAC) address or a hostname, and wherein the
`client device is
`method further comprising sending, by thefirst client device, during, as part of, or in
`identified by a Media|response to, a start-up of the first client device, a first message to the second server, and
`Access Control
`whereinthe first message comprises the first IP address, the MAC address, or the
`(MAC) address ora_|hostname.
`hostname, and
`wherein the method|See analysis of claim 1, which is fully incorporated by reference.
`further comprising
`sending, by the first|A proxy client device of Bright Data’s Practicing Products may beidentified by a Media
`
`client device, during,|Access Control (MAC) address or a hostname, and the client device may send, as part of,
`
`
`? Secinnn” (2X. 2022)
`8— (EX. 2022)
`s 5ee (EX. 2023)
`
`
`'? See ne (EX. 2022)
`'Secnee (EX. 2022)
`re (EX. 2023)
`
`'8 See nn (EX2023)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`
`
`Additionally, the proxy client devices send messagesto the second serverto register with
`the second serverand identify their residential IP addresses. A proxy client device of the
`Practicing Products receives, from the secondserver, the first content identifier.
`
`As one non-limiting example, when a proxy client device connects to the Internetit
`initiates communication overthe Internet with a second server. This communication
`comprises sending a first message withits identifier, such as its residential IP address.
`
`Exemplary Evidence of Bright Data Practicing the Claim
`
`or in responseto, a start-up of the client device, a message to the secondserver,
`as part of, or in
`comprising the first IP address, the MAC address, or the hostname. Internet and Wifi
`responseto, a start-
`up ofthe first client|enabled devices including the client devices that become proxies in the claimed method
`device, a first
`are identified by a Media Access Control (MAC) address.
`
`message to the
`secondserver, and
`
`wherein the first
`
`messages comprises
`the first IP address,
`
`the MACaddress, or
`the hostname.
`
`
`
`
`
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See the source code discussion forclaim la.
`
`0 SecTTTPn (EX. 2022)
`aTOO (EX. 2024)
`
`>? See Pn” (2X. 2024)
`3 SecTTnnn (EX2021)
`=—————————— (EX. 2021)
`
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`
`Exemplary Evidence ofBright Data Practicing the Claim
`
`
`
`
`This elementis literally present in the Practicing Products, because the Practicing
`The method
`Claim 3
`
`
`according to claim 2,|Products perform the method according to claim 2, for use with a first application stored
`for use with a first
`in the first client device and associated witha first version number, wherein thefirst
`application stored in|message comprisesthe first version number.
`
`
`the first client device
`and associated with a
`first version number,
`
`
`wherein the first
`message comprises
`
`
`the first version
`
`number.
`
`
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See analysis of claims 1 and 2, whichis fully incorporated by reference.
`
`Theproxy client device stores an application associated with a first version number, and
`the proxy client device will send a message to the Super Proxy (see claim 2) that includes
`the first version number.
`
`* Secinn” (EX. 2022)
`” Secine (xX. 2022)
`6a (EX. 2022)
`
`”See nn (EX. 2022)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`This elementis literally present in the Practicing Products, because the Practicing
`The method
`Claim 17
`according to claim 1,|Products perform the method according to claim 1, further comprising periodically
`further comprising
`communicating between the second serverandthefirst client device.
`periodically
`communicating
`between the second
`server andthefirst
`client device.
`
`See analysis of claim 1, whichis fully incorporated by reference.
`
`The Practicing Products further comprise periodically communicating between the second
`serverandthe first client device. For example, a proxy client device of Bright Data’s
`Practicing Products may periodically send a message that comprisesa status of the client
`device in responseto a request for the status of the client device. Further, the proxy client
`device and secondserver of Bright Data’s Practicing Products periodically communicate,
`including by exchanging ‘keep alive’ messages.
`
`reference.
`
`As a non-limiting example, the Practicing Products include a proxy client device
`receiving multiple requests from a second serverand, for example, the second server
`pinging the proxy client device to confirm its availability.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for claim 1.
`
`Claim 18
`
`The method
`according to claim
`17, wherein the
`periodically
`communicating
`comprises
`
`This elementisliterally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 17, wherein the periodically
`communicating comprises exchanging ‘keep alive’ messages wherein the periodically
`communicating comprises exchanging ‘keep alive’ messages.
`
`See analysis of claims | and 17, whichis fully
`
`incorporated by
`
`Secsne (EX. 2022)
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Claim No.
`
`exchanging ‘keep
`alive’ messages.
`
`For example, a proxy client device of Bright Data’s Practicing Products may periodically
`send a message that comprises a status of the client device in response to a request for the
`status of the client device. Further, the proxy client device and secondserver of Bright
`Data’s Practicing Products periodically communicate, including by exchanging ‘keep
`alive’ messages.
`
`respectively with the
`
`This elementis literally present in the Practicing Products, because the Practicing
`The method
`Claim 21
`according to claim 1,|Products perform the method according to claim 1, wherein the first or second serveris a
`wherein the first or
`Transmission Control Protocol/Internet Protocol (TCP/IP) server that communicates over
`second serveris a
`the Internet based on, or according to, using TCP/IP protocol or connection, and wherein
`Transmission Control|
`the first client device is a Transmission Control Protocol/Internet Protocol (TCP/IP) client
`Protocol/Internet
`that communicates with the first or second server over the Internet based on, or according
`Protocol (TCP/IP)
`to, TCP/IP protocol.
`server that
`communicates over|See analysis of claim 1, which is fully incorporated by reference.
`the Internet based on,
`or according to, using|For example, the Super Proxy is a TCP/IP server that communicates over the Internet
`TCP/IP protocol or
`based on, or according to, using TCP/IP protocol or connection.
`connection, and
`wherein the first
`client device is a
`Transmission Control
`Protocol/Internet
`Protocol (TCP/IP)
`client that
`communicates
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for claim 17
`
`The proxy client device is a TCP/IP client that communicates with the Super Proxy over
`the Internet based on, or according to, TCP/IP protocol.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for Claim 1.
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`For example, the web socket connections used in the client device and proxy server use
`the TCP protocol.
`
`Claim No.
`
`Claim 22
`
`first or second server
`over the Internet
`based on, or
`according to, TCP/IP
`protocol or
`connection.
`The method
`according to claim 1,
`wherein the first
`client device
`communicates over
`the Internet based on,
`or according to, one
`out of UDP, DNS,
`TCP, FTP, POP#,
`SMTP,
`or SQLstandards.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024 See source code discussion for Claim 1.
`
`Additionally, the analysis of claim 1 including as non-limiting examples the preamble and
`claim 1b show that the proxy client device communicates by sending URLs, or Uniform
`Resource Locators, that are sent using the domain nameof the web server. The domain
`nameis resolved to an IP address using DNS,so the client device also meets this claim by
`using DNS.For example: “DNSprimarily uses the User Datagram Protocol (UDP) on
`port number 53 to serve requests... DNS queries consist of a single UDP request from the
`client followed by a single UDPreply from the server.”
`https://en.wikipedia.org/wiki/Domain Name System (EX. 2042)
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 1, wherein the first client device
`communicates over the Internet based on, or according to, one out of UDP, DNS, TCP,
`FTP, POP, SMTP,or SQL standards.
`
`See analysis of claim 1, whichis fully incorporated by reference.
`
`See also analysis of claim 21, whichis fully incorporated by reference. The analysis of
`claim 21 in particular includes all limitations of this case using TCP, whichis one of the
`listed standards in claim 22, and therefore the analysis of claim 21 also means the
`Practicing Products practice claim 22.
`
`Thus, in relying on DNS, the communication also uses the UDP standard.
`
`

`

`Transmission Control Protocol/Internet Protocol (TCP/IP) server, wherein thefirst client
`
`Similarly, the client devices and the second server of Bright Data’s Practicing Products
`may communicate over the Internet based on, or according to, using TCP/IP protocol or
`connection. The client devices of Bright Data’s Practicing Products may communicate
`over the Internet based on, or according to, one out of UDP, DNS, TCP, FTP, POP,
`SMTP,or SQL standards.
`
`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`
`a C
`
`laim 24
`
`The method
`according to claim 1,
`further comprising
`establishing, by the
`first client device, a
`Transmission Control
`Protocol (TCP)
`connection with the
`second server using
`TCP/IP protocol.
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 1, further comprising establishing, by the
`first client device, a Transmission Control Protocol (TCP) connection with the second
`server using TCP/IP protocol.
`
`See analysis of claims 1, 21, and 22, whichis fully incorporated by reference.
`
`A proxy client device of the Practicing Products establishes a Transmission Control
`Protocol (TCP) connection with a second server, e.g., the Super Proxy.
`
`Asone non-limiting example, when a client device connects to the Internet it initiates
`communication overthe Internet with a second server, such as, for example, a Super
`Proxy proxy server. This communication comprises establishing a TCP connection.
`
`See, e.g., Bright Data Network Diagram, EX. 2018
`
`Claim 25
`
`The method
`according to claim 1,
`wherein the first or
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 1, whereinthe first or second serveris a
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`See analysis of claims 1, 21, 22, and 24, whichis fully incorporated by reference.
`
`For example, the Super Proxy is a TCP/IP server and the proxy client communicates with
`the Super Proxy over the Internet based on, or according to, TCP/IP protocol.
`
`Exemplary Evidence of Bright Data Practicing the Claim
`Claim No.
`Transmission Control|device communicates over the Internet with the first or second server based on, or
`according to, using TCP/IP protocol or connection.
`Protocol/Internet
`Protocol (TCP/IP)
`server, wherein the
`first client device
`communicates over
`the Internet with the
`first or second server
`based on, or
`according to, using
`TCP/IP protocol or
`connection.
`
`BrightData-in-Android-settings (EX. 2043)(“Using BrightData in Android settings")
`
`The method
`accordingto claim 1,
`further comprising
`storing, operating, or
`using, a client
`operating system.
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 1, further comprising storing, operating,
`or using, a client operating system.
`
`See analysis of claim 1, which1s fully incorporated by reference.
`
`The proxy client devices of the Practicing Products perform the steps of claim 1 further
`comprising storing, operating, or using, a client operating system. In addition, a proxy
`client device of Bright Data’s Practicing Products uses a software application that
`includes computerinstructions, such as the SDK, that when executed by a computer
`processor, causes the processor to perform the sending of the request, the receiving and
`storing of the content, the receiving of the content identifier, and the sending ofthe part
`of, or the whole of, the stored first content, which is preceded by the proxy client device
`downloading the software application and installing the downloaded software application.
`
`For example, the proxy client device may store, operate, or use an Android operating
`system. See https://help.brightdata.com/hc/en-us/articles/4413168253969-Using-
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for Claim 1. The source code references for the client device
`functions referto files which are meant to be compiled and built to run on for example the
`Android operating system.
`
`The Practicing Products support three main operating systems including Android,
`Windows, and MacOS.
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products perform the method according to claim 1, wherein the steps are sequentially
`executed.
`
`See analysis of claim 1, whichis fully incorporated by reference.
`
`The proxy client device of the Practicing Products perform the steps of claim 1
`sequentially.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for Claim 1.
`
`hard drive or compactdisc that is provided to app developers to incorporate into their
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products comprise a non-transitory computer readable medium containing computer
`instructions that, when executed by a computer processor, cause the processor to perform
`the method according to claim 1.
`
`The method
`according to claim 1,
`wherein the steps are
`sequentially
`executed.
`
`Claim 28
`
`A non-transitory
`computer readable
`medium containing
`computer instructions
`that, when executed
`by a computer
`processor, cause the
`processor to perform
`the method according
`
`See analysis of claim 1, whichis fully incorporated by reference.
`
`For example, the Practicing Products include a software application, such as the SDK,
`that includes computer instructions. The SDK may be located on, for example, an external
`
`

`

`HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS’ EYES ONLY
`SOURCE CODE
`
`Exemplary Evidence of Bright Data Practicing the Claim
`applications. The SDKisinstalled on a proxy client device that, when executed, causes
`the processorof the proxy client device to perform the methodsteps of claim 1.
`
`The proxy client device may also download the software application from the Internet and
`install the downloaded software application that, when executed, causes the processor of
`the proxy client device to perform the method steps of claim 1.
`
`See, e.g., Bright Data Source Code, EXS. 2021-2024
`
`See source code discussion for claim 1.
`
`For example, the SDKis located on a proxyclient device.
`
`This elementis literally present in the Practicing Products, because the Practicing
`Products comprise a proxy client device comprising a non-transitory computer readable
`meaning containing computerinstructions that, when executed by a computer processor,
`cause the processor to perform the method accordingto claim 1.
`
`Claim 29
`
`A client device
`comprising a non-
`transitory computer
`readable medium
`containing computer
`instructionsthat,
`when executed by a
`computer processor,
`cause the processor
`to perform the
`method according to
`claim 1.
`
`See analysis of claims 1 and 28, whichis fully incorporated by reference.
`
`