TRILLER EXHIBIT 1013-001
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`Frank E. Scherkenbach (SBN 142549 / scherkenbach@fr.com)
`Adam J. Kessel (Admitted pro hac vice / kessel@fr.com)
`Proshanto Mukherji (Admitted pro hac vice / mukherji@fr.com)
`Jeffrey Shneidman (Admitted pro hac vice / shneidman@fr.com)
`FISH & RICHARDSON P.C.
`One Marina Park Drive
`Boston, MA 02210
`Telephone: (617) 542-5070
`Facsimile: (617) 542-8906
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`Michael R. Headley (SBN 220834 / headley@fr.com)
`FISH & RICHARDSON P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Telephone: (650) 839-5070
`Facsimile: (650) 839-5071
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`Attorneys for Plaintiffs
`BYTEDANCE INC., TIKTOK INC., and TIKTOK PTE. LTD.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`OAKLAND DIVISION
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`BYTEDANCE INC., TIKTOK INC., AND
`TIKTOK PTE. LTD.,
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`Case No. 4:20-cv-07572-JSW
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`Plaintiffs,
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`v.
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`TRILLER, INC.,
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`Defendant.
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`PLAINTIFFS’ DISCLOSURE OF
`ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS
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`REDACTED
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`Pursuant to Patent Local Rules 3-1 and 3-2, Plaintiffs TikTok Inc. and TikTok Pte. Ltd.
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`(collectively “TikTok” or “Plaintiffs”) provide Defendant Triller, Inc. (“Triller”) with the
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`following preliminary disclosure of asserted claims and infringement contentions. Given the
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`limited information Triller has disclosed thus far through discovery, TikTok’s disclosure is based
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`on public information relating to Triller’s products, including Triller’s software application for the
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`

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`TRILLER EXHIBIT 1013-002
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`iOS operating system and Triller’s software application for the Android operating system
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`(collectively, “the Accused Products”).
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`All sources identified in TikTok’s disclosure of asserted claims and infringement
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`contentions (as well as the attached claim charts) are exemplary. TikTok reserves the right to
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`supplement these disclosures with additional evidence because Triller has not yet provided
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`discovery regarding its products, the discovery period has not yet ended, and the Court has not yet
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`construed any claim terms. TikTok also reserves the right to identify other Accused Products that
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`are made, used, sold, offered for sale, and/or imported into the United States by Triller, as
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`appropriate.
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`DISCLOSURES UNDER RULE 3-1
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`(A) Asserted Claims (Patent L.R. 3-1(a))
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`Based on information obtained to date, TikTok asserts that Triller has infringed and/or is
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`infringing the following claims of the following United States patents (collectively, “the Asserted
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`Claims” of “the Asserted Patents”):
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` U.S. Patent No. 9,648,132 (“the ’132 patent”) claims 1, 2, 3, 6, 22, 26, 27, and 31
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` U.S. Patent No. 9,992,322 (“the ’322 patent”) claims 30, 31, 32, 35, 51, 55, and 56
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` U.S. Patent No. 9,294,430 (“the ’430 patent”) claims 1, 19, 23, 24, and 28
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`(B) Accused Products (Patent L.R. 3-1(b))
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`Based on information obtained to date, TikTok asserts that Triller has infringed and/or is
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`infringing the asserted claims with its software application for the iOS operating system and
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`Triller’s software application for the Android operating system (collectively, “the Accused
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`Products”), commonly referred to as the Triller app.
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`(C) Claim Charts (Patent L.R. 3-1(c))
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`The claim charts labeled Exhibits F1-F3 identify specifically the element-by-element
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`analyses of Triller’s infringement of the Asserted Claims of TikTok’s Asserted Patents.
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`(D) Indirect Infringement (Patent L.R. 3-1(d))
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`Triller both induces and contributes to the infringement of others through the marketing
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`and distribution of the Accused Products, i.e. the Triller app. In particular, Triller has induced and
`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`2
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`TRILLER EXHIBIT 1013-003
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`contributed to infringement of the Asserted Claims by encouraging and instructing users of the
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`Triller app to perform activities that infringe the patents-in-suit with full knowledge of the patents
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`and their infringement, including using the Accused Products in the U.S., and Triller has so
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`encouraged and instructed with the intent to cause others to perform those acts. These acts were
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`undertaken, additionally, knowing that the accused functionality of the products is default
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`functionality and that the Triller app therefore has no substantial non-infringing uses. For the
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`accused products, Triller has made available to customers in the United States materials including
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`website pages, videos, and other promotional materials instructing customers on how to use the
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`products in an infringing manner. Providing such materials to U.S. based customers with the
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`specific intent to induce those customers to infringe has thereby induced infringement of the
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`Asserted Claims; and with knowledge that the Triller app has no substantial non-infringing uses,
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`their acts additionally contribute to infringement by others. Additional detail regarding specific
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`acts of direct infringement, including the volume of infringement and details of Triller’s
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`inducement and contributory infringement, will be the subject of discovery that TikTok has sought
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`(and will continue to seek) from Triller and will seek from additional third parties.
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`(E) Literal Infringement and Doctrine of Equivalents (Patent L.R. 3-1(e))
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`Based on the information presently available and on information and belief, each limitation
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`of each of the Asserted Claims of the Asserted Patents is literally met by the Accused Products as
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`described in the accompanying Exhibits F1 – F3.
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`To the extent Triller argues that any claim limitations are not literally satisfied, TikTok
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`may supplement these contentions to show that those limitations are also met under the doctrine of
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`equivalents because the differences between the claim limitation and the corresponding element in
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`the Accused Products are insubstantial or perform substantially the same function as the claimed
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`limitation, and do so in substantially the same way to create substantially the same result. TikTok
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`also reserves the right to allege that certain claim limitations are satisfied under the doctrine of
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`equivalents once the Court construes any disputed claim terms.
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`TRILLER EXHIBIT 1013-004
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`(F) Priority Date (Patent L.R. 3-1(f))
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`As indicated on the face of TikTok’s Asserted Patents, all three of the patents claim
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`priority as of May 5, 2006, based on the filing of provisional patent applications in Great Britain.
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`(G) Embodiments of the Asserted Claims (Patent L.R. 3-1(g))
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`At least the following Asserted Claims of the Asserted Patents are embodied in the
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`MusicStation software product and Plaintiffs’ own TikTok app when executed on a mobile device
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`running the iOS or Android operating systems:
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`REDACTED
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`(H)
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`Infringement Timing (Patent L.R. 3-1(h))
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`Based on public information, TikTok believes that Triller is and has been infringing each
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`of the Asserted Claims of the Asserted Patents since the release of the Triller app in 2015, that
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`damages began to accrue as of the launch of the Triller app, and that TikTok is entitled to damages
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`for Triller’s use of the patented technology from the initial launch of the Triller app through the
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`life of the patents-in-suit.
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`(I) Willful Infringement (Patent L.R. 3-1(i))
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`TikTok alleges that Triller willfully infringes all three of the Asserted Patents based on
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`Triller’s knowledge of the patents since at least November 11, 2020, based on Triller’s continued
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`infringement of the Asserted Patents with the Triller app with full knowledge of its infringement
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`since that time.
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`DISCLOSURES UNDER RULE 3-2
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`(A) Documents Evidencing Disclosures/Offers to Sell (Patent L.R. 3-2(a))
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`There were no offers to sell, public disclosures, or sales of the claimed inventions prior to
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`the date of the application for the Asserted Patents.
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`(B) Documents Evidencing Conception, etc. (Patent L.R. 3-2(b))
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`TikTok has produced documents evidencing the conception, reduction to practice, design,
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`and development of each claimed invention at BDTT_TRIL_CA_0000001-6561.
`PLAINTIFFS’ DISCLOSURE OF ASSERTED
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`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`TRILLER EXHIBIT 1013-005
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`(C) File Histories (Patent L.R. 3-2(c))
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`TikTok has produced the file histories for each of the patents-in-suit at
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`BDTT_TRIL_CA_0000001 - BDTT_TRIL_CA_0006561.
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`(D) Ownership (Patent L.R. 3-2(d))
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`TikTok has produced documents that show ownership of the Asserted Patents at
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`BDTT_TRIL_CA_0006570 - BDTT_TRIL_CA_0006580.
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`(E) Products Practicing the Claimed Inventions (Patent L.R. 3-2(e))
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`TikTok has produced documents showing the operation of the embodying MusicStation
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`software at BDTT_TRIL_CA_0000001-6561. Additional documents sufficient to show the
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`operation of the TikTok app practicing claims of the Asserted Patents are available for inspection
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`upon reasonable advance notice at TikTok’s Transparency and Accountability Center.
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`(F) Agreements Transferring an Interest in the Asserted Patents (Patent L.R. 3-2(f))
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`TikTok has produced relevant agreements and licenses at BDTT_TRIL_CA_0006562 -
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`BDTT_TRIL_CA_0006580.
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`(G) All Agreements Supporting Damages (Patent L.R. 3-2(g)-(h))
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`TikTok is not presently aware of any licenses or agreements that are comparable to a
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`license that would result from a hypothetical reasonable royalty negotiation in this case.
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`(H) Documents Regarding Embodying Instrumentalities (Patent L.R. 3-2(i))
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`TikTok is not making any claims regarding marking or Lost Profits in this case.
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`(I) All Documents Concerning Any F/RAND Commitment (Patent L.R. 3-2(j))
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`TikTok does not contend that that any of the Asserted Patents is subject to a FRAND
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`commitment or agreement.
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`TRILLER EXHIBIT 1013-006
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`Dated: August 27, 2021
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`FISH & RICHARDSON P.C.
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`By: /s/ Michael R. Headley
` Michael R. Headley
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`Attorneys for Plaintiffs
`BYTEDANCE INC., TIKTOK INC., and
`TIKTOK PTE. LTD.
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`TRILLER EXHIBIT 1013-007
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`PROOF OF SERVICE
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`I am employed in the County of San Mateo. My business address is Fish & Richardson
`P.C., 500 Arguello Street, Suite 500, Redwood City, California 94063. I am over the age of 18 and
`not a party to the foregoing action.
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`I am readily familiar with the business practice at my place of business for collection and
`processing of correspondence for personal delivery, for emailing, for mailing with United States
`Postal Service, for facsimile, and for overnight delivery by Federal Express, Express Mail, or
`other overnight service.
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`On August 27, 2021, I caused copies of the following document(s):
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS
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`to be served on the interested parties in this action by placing a true and correct copy of the
`documents in a sealed envelope addressed as follows:
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`Attorneys for Defendant
`TRILLER, INC.
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`Elizabeth Day
`eday@feinday.com
`FEINBERG DAY KRAMER ALBERTI LIM
`TONKOVICH & BELLOLI LLP
`577 Airport Boulevard, Suite 250
`Burlingame, CA 94010
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`Brian N. Platt
`bplatt@wnlaw.com
`Brent P. Lorimer
`blorimer@wnlaw.com
`WORKMAN NYDEGGER
`60 East South Temple Suite 1000
`Salt Lake City, UT 84111
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`XX ELECTRONIC
`MAIL:
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`The document was transmitted by electronic mail to the addressees’
`email addresses as stated above.
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`I declare that I am employed in the office of a member of the bar of this Court at whose
`direction the service was made.
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`I declare under penalty of perjury that the above is true and correct. Executed on August
`27, 2021, at Redwood City, California.
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`/s/ Christie Horsley
`Christie Horsley
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`PLAINTIFFS’ DISCLOSURE OF ASSERTED
`CLAIMS & INFRINGEMENT CONTENTIONS
`Case No 4:20-cv-07572-JSW
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`Exhibit F1 – Infringement of U.S. Patent 9,648,132
`by Triller’s Android Application and iOS Application
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`The allegations in the following claim chart are exemplary. Plaintiffs TikTok Inc. and TikTok Pte. Ltd. (collectively “TikTok” or
`“Plaintiffs”) reserve the right to update these allegations as the case progresses through discovery, when Defendant Triller, Inc.
`(“Triller” or “Defendant”) produces source code and technical materials regarding the accused products, and based on any claim
`constructions adopted by the Court. In addition, based on the information presently available and on information and belief, each
`limitation of each of the Asserted Claims of U.S. Patent 9,648,132 (“the ’132 Patent”) is literally met by the Accused Products. To the
`extent Triller argues that any claim limitations are not literally satisfied, TikTok may supplement these contentions to show that those
`limitations are met under the doctrine of equivalents if the differences between the claim limitation and the corresponding element in
`the Accused Products are insubstantial or perform substantially the same function as the claimed limitation, and do so in substantially
`the same way to create substantially the same result. Plaintiffs also reserve the right to allege that claim limitations are satisfied under
`the doctrine of equivalents once the Court construes any disputed claim terms.
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`Claim 1
`A portable wireless computing
`device comprising a hardware
`processor programmed with a
`software application embodied on a
`non-transitory storage medium,
`that enables an end-user to interact
`with other users in which
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`Triller’s Android Application and iOS Application
`Triller is a software application embodied on a non-transitory storage medium, that enables
`an end-user to interact with other users. A portable wireless computing device comprising
`a hardware processor is programmed with the Triller software application. See, e.g.:
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`TRILLER EXHIBIT 1013-008
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`The Triller software application enables an end-user to interact with other users. See, e.g.,
`1(c).
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`TRILLER EXHIBIT 1013-009
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`(a) the software application allows
`the end-user to, over a wireless
`connection, create on a remote
`server one or more user accounts
`with associated profiles for that
`end-user; and
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`The Triller software application allows the end-user to, over a wireless connection, create on
`a remote server one or more user accounts with associated profiles for that end-user. See,
`e.g.:
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`Android Screenshots
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`TRILLER EXHIBIT 1013-0010
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`iOS Screenshots
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`TRILLER EXHIBIT 1013-0011
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`(b) the software application allows
`the end-user to, over the wireless
`connection, view profiles created
`by other users of a service; and
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`The Triller software application allows the end-user to, over the wireless connection, view
`profiles created by other users of a service. See, e.g.:
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`Android Screenshots
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`TRILLER EXHIBIT 1013-0012
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`iOS Screenshots
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`TRILLER EXHIBIT 1013-0013
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`(c) the software application allows
`the end-user to, over the wireless
`connection, interact with other
`users of the service; and
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`The Triller software application allows the end-user to, over the wireless connection, interact
`with other users of the service. See, e.g.:
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`Android Screenshots
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`TRILLER EXHIBIT 1013-0014
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`iOS Screenshots
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`TRILLER EXHIBIT 1013-0015
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`(d) the software application allows
`the end-user to, over the wireless
`connection, send and receive
`messages to and from other users
`of the service; and
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`The Triller software application allows the end-user to, over the wireless connection, send
`and receive messages to and from other users of the service. See, e.g.:
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`Android Screenshots
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`TRILLER EXHIBIT 1013-0016
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`iOS Screenshots
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`TRILLER EXHIBIT 1013-0017
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`(e) the software application allows
`the end-user to, over the wireless
`connection, link his or her user
`account on the remote server to
`user accounts on the remote server
`of other users of the same service
`or of other services.
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`The Triller software application allows the end-user to, over the wireless connection, link his
`or her user account on the remote server to user accounts on the remote server of other users
`of the same service or of other services. See, e.g.:
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`Android Screenshots
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`TRILLER EXHIBIT 1013-0018
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`iOS Screenshots
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`TRILLER EXHIBIT 1013-0019
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`Claim 2
`The device of claim 1 wherein the
`software application uses a
`multitasking architecture to
`balance the computational
`demands of network access; and
`the computational demands of a
`user interface of the software
`application.
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`Triller’s Android Application and iOS Application
`The Triller software application uses a multitasking architecture to balance the computation
`demands of network access and the computational demands of a user interface of the
`software application. See, e.g.:
`
`
`Android and iOS
`
`
`
`As shown above, the Triller software application enables a user to simultaneously upload
`and post a new video (4% progress of upload as shown by the red arrow above) while also
`playing a video in a user interface (shown by the red rectangle above) and displaying the
`upload progress on the user interface. On information and belief, to perform these actions
`simultaneously, the Triller software application must balance (1) the computational demands
`
`
`
`
`
`13
`
`TRILLER EXHIBIT 1013-0020
`
`

`

`of accessing the network to upload the video and (2) the computational demands of the user
`interface of the software application to play the video and/or to display the upload progress.
`
`The below images show the Triller software application using a multitasking architecture
`that employs multiple threads running in parallel to balance these operations. Reviewing
`the operations performed by a particular thread (e.g., thread 0x2d9d35) demonstrates that
`network access functionality and user interface functionality, among other
`operations/programs, are provided by distinct threads.
`
`
`
`
`
`
`
`
`
`
`14
`
`TRILLER EXHIBIT 1013-0021
`
`

`

`Claim 3
`The device of claim 2, wherein the
`software application uses the
`multitasking architecture to
`balance the computational
`demands of one or both of: a DRM
`program; media operations.
`
`Triller’s Android Application and iOS Application
`The Triller software application uses the multitasking architecture to balance the
`computational demands of one or both of a DRM program and media operations. See, e.g.:
`
`
`DRM program (Android and iOS)
`
`
`On information and belief, the Triller software application uses a DRM program, including
`at least the DRM programs 7digital and MediaDrm (accessible via API in Android
`ExoPlayer). As explained above with respect to claim 2, the Triller software application
`uses distinct threads in a multitasking architecture to balance the computational demands of
`different operations/programs within the Triller software application, including the DRM
`program. See, e.g.:
`
`
`
`See “TRILLER Taps Top Streaming Artists And Music Industry Notables As Investors And
`Strategic Partners; Breaks 26.5 Million Monthly Average Users Overtaking TikTok In The
`United States” at 2 (accessible at: https://www.prnewswire.com/news-releases/triller-taps-
`top-streaming-artists-and-music-industry-notables-as-investors-and-strategic-partners-
`breaks-26-5-million-monthly-average-users-overtaking-tiktok-in-the-united-states-
`300977300.html (last accessed August 16, 2021)).
`
`
`
`
`15
`
`TRILLER EXHIBIT 1013-0022
`
`

`

`
`See “TRILLER Taps Top Streaming Artists And Music Industry Notables As Investors And
`Strategic Partners; Breaks 26.5 Million Monthly Average Users Overtaking TikTok In The
`United States” at 3 (accessible at: https://www.prnewswire.com/news-releases/triller-taps-
`top-streaming-artists-and-music-industry-notables-as-investors-and-strategic-partners-
`breaks-26-5-million-monthly-average-users-overtaking-tiktok-in-the-united-states-
`300977300.html (last accessed August 16, 2021)).
`
`
`
`
`16
`
`TRILLER EXHIBIT 1013-0023
`
`

`

`
`See “Triller Signs With 7digital In Plans To Topple TikTok Globally” at 1-2 (accessible at
`https://themusicnetwork.com/triller-signs-with-7digital/ (last accessed August 16, 2021));
`see also “As TiKTok Hangs In The Balance, Triller Solidifies Its Content Delivery
`Infrastructure” (accessible at https://www.digitalmusicnews.com/2020/08/13/triller-7digital-
`agreement/ (last accessed August 16, 2021)).
`
`
`
`
`17
`
`TRILLER EXHIBIT 1013-0024
`
`

`

`
`See “7digital / Triller: Description, Go Live Time, Territories, How They Sell Your Music,
`Pay Rate” at 2-3 (accessible at https://support.tunecore.com/hc/en-
`
`
`
`18
`
`TRILLER EXHIBIT 1013-0025
`
`

`

`us/articles/115006692448-7digital-Triller-Description-Go-Live-Time-Territories-How-
`They-Sell-Your-Music-Pay-Rate (last accessed August 16, 2021)).
`
`
`See “Building A Subscription Streaming Service” at 1 (accessible at:
`https://docs.7digital.com/docs/building-a-streaming-service (last accessed August 16,
`
`
`
`
`
`19
`
`TRILLER EXHIBIT 1013-0026
`
`

`

`2021)); see also https://docs.7digital.com/reference (last accessed August 16, 2021);
`https://docs.7digital.com/docs (last accessed August 16, 2021).
`
`
`
`See “Digital Rights Management” (accessible at: https://developer.android.com/reference/
`android/media/MediaDrm.html (las accessed August 16, 2021)).
`
`
`
`
`20
`
`TRILLER EXHIBIT 1013-0027
`
`

`

`See “MediaDrm” (accessible at https://developer.android.com/reference/android/
`media/MediaDrm.html (last accessed August 16, 2021)).
`
`
`Media Operations (Android and iOS)
`
`
`
`
`The Triller software application provides media operations, including video playback and
`uploading videos. As explained above with respect to claim 2, the Triller software
`application uses distinct threads in a multitasking architecture to balance the computational
`demands of different operations/programs within the Triller software application, including
`these media operations. See, e.g.:
`
`
`
`
`21
`
`TRILLER EXHIBIT 1013-0028
`
`

`

`Fre)
`
`aE
`Chi Saad
`
`
`
`22
`
`Prinars)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`TRILLER EXHIBIT 1013-0029
`
`

`

`Claim 6
`The device of claim 1 wherein the
`software application is a music
`application and uses track meta-
`data that is formed as a separate
`meta-data layer and defines
`attributes of tracks, the meta-data
`being external to a music track to
`make sharing and browsing of
`track information possible without
`needing to distribute the related
`music track files.
`
`Triller’s Android Application and iOS Application
`The Triller software application is a music application that uses track meta-data that is
`formed as a separate meta-data layer and defines attributes of tracks, the meta-data being
`external to a music track to make sharing and browsing of track information possible without
`needing to distribute the related music track files. See, e.g.:
`
`
`Android and iOS
`
`
`
`
`
`
`
`
`23
`
`TRILLER EXHIBIT 1013-0030
`
`

`

`Lotmeaset)
`
`
`
`Response
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`24
`
`TRILLER EXHIBIT 1013-0031
`
`

`

`Claim 22
`The device of claim 1 wherein the
`service provides over a wireless
`connection, recommendations to
`the user of people, media content
`or any other items which the user
`might like, based on the user's
`viewing, listening and/or
`purchasing history, on the viewing,
`listening and/or purchasing history
`of any other users or on any other
`criteria.
`
`Triller’s Android Application and iOS Application
`The Triller software application is such that the service provides, over a wireless connection,
`recommendations to the user of people, media content or any other items which the user
`might like, based on the user’s viewing, listening and/or purchasing history, or the viewing,
`listening, and/or purchasing history of any other users or on other criteria. See, e.g.:
`
`
`Exemplary Screenshots
`
`
`
`
`
`
`
`
`25
`
`TRILLER EXHIBIT 1013-0032
`
`

`

`caSS
`RISING
`STARS
`
`ea@ne
`
`
`
`
`
`
`
`26
`
`Ba
`ios
`
`rzUC (1CM
`
`zOLm CeT
`
`oO
`
`»4
`
`% l
`
`aa
`
`rc)
`
`Org
`Follow)
`
`DP 2.2k
`
`Looking for somethingfresh to listen to this
`emer
`
`r RTTEALae ug
`Tk.
`(| @@ )
`
`omg
`
`TRILLER EXHIBIT 1013-0033
`
`

`

`@silksonic
`
`wh
`La
`oor
`
`sf
`
`2
`—_charlidameli
`
`
`
`Q T
`
`UTtg
`
`M ca A :
`
`WS i
`Coa) Dae eT)
`
`~X
`kimberlyloaiza
`
`aAUCLely
`
`b-
`
`@_ajawilson22 Orato)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`27
`
`TRILLER EXHIBIT 1013-0034
`
`

`

`Claim 26
`The device of claim 1 wherein the
`software application communicates
`with the remote server wirelessly
`via one or more of CSD, GPRS,
`2G, 2.5G, 3G, WAP, SMS,
`Bluetooth, Infrared, Wi-Fi,
`WiMAX, the Global Mobile
`Network or via any other wireless
`communications technology.
`
`Triller’s Android Application and iOS Application
`The Triller software application communicates with the remote server wirelessly via one or
`more of CSD, GPRS, 2G, 2.5G, 3G, WAP, SMS, Bluetooth, Infrared, Wi-Fi, WiMAX, the
`Global Mobile Network or via another wireless communications technology. See, e.g.:
`
`
`Exemplary Screenshots
`
`
`
`
`
`
`
`
`
`28
`
`TRILLER EXHIBIT 1013-0035
`
`

`

`ee oC)
`
`@) en med4
`@richthekid#prada#RichT... Readmore
`Peomeim
`
`
`
`
`
`
`
`29
`
`Cx
`
`Following
`
`Trills
`
`For You
`
`Se
`
`@malevich
`
`‘Prada’ by Rich The Kid. @malevich
`
`..)
`
`&
`i
`f
`.
`
`"
`
`A
`
`TRILLER EXHIBIT 1013-0036
`
`

`

`reaL
`
`rT (1Cm
`
`OLN CT
`
`ie)
`
`TrillerTV
`CX
`
`© Merch
`
`Prada by Rich The Kid
`
`@malevich
`vi i amlLs
`‘Prada’ by Rich The Kid. @malevich
`@richthekid #prada #RichT... Read more
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`30
`
`TRILLER EXHIBIT 1013-0037
`
`

`

`Claim 27
`The device of claim 1 wherein the
`software application uses a
`multithreaded architecture to
`balance the computational
`demands of network access; and
`the computational demands of one
`or more of: a user interface of the
`software application; a DRM
`program; media operations.
`
`Triller’s Android Application and iOS Application
`The Triller software application uses a multithreaded architecture to balance the
`computational demands of network access, and the computational demands of one or more
`of a user interface of the software application, a DRM program, and media operations. See,
`e.g.:
`
`
`Multithreaded Architecture, Network Access, User Interface (Android and iOS)
`
`
`
`As shown above, the Triller software application enables a user to simultaneously upload
`and post a new video (4% progress of upload as shown by the red arrow above) while also
`playing a video in a user interface (shown by the red rectangle above) and displaying the
`upload progress on the user interface. On information and belief, to perform these actions
`
`
`
`
`
`31
`
`TRILLER EXHIBIT 1013-0038
`
`

`

`simultaneously, the Triller software application must balance (1) the computational demands
`of accessing the network to upload the video, (2) the computational demands of the user
`interface of the software application to play the video and/or to display the upload progress,
`and (3) other programs/operations running on the Triller software application, such as a
`DRM program.
`
`The below images show the Triller software application using a multithreaded architecture
`that employs multiple threads running in parallel to balance these programs/operations.
`Reviewing the operations performed by a particular thread (e.g., thread 0x2d9d35)
`demonstrates that network access functionality, user interface functionality, a DRM
`program, and media operations, among other operations/programs, are provided by distinct
`threads.
`
`
`
`
`
`
`
`
`32
`
`TRILLER EXHIBIT 1013-0039
`
`

`

`
`
`
`
`DRM program (Android and iOS)
`
`
`On information and belief, the Triller software application uses a DRM program, including
`at least the DRM programs 7digital and MediaDrm (accessible via API in Android
`ExoPlayer). As explained above, the Triller software application uses distinct threads in a
`multithreaded architecture to balance the computational demands of different
`operations/programs within the Triller software application, including the DRM program.
`See, e.g.:
`
`
`
`See “TRILLER Taps Top Streaming Artists And Music Industry Notables As Investors And
`Strategic Partners; Breaks 26.5 Million Monthly Average Users Overtaking TikTok In The
`United States” at 2 (accessible at: https://www.prnewswire.com/news-releases/triller-taps-
`top-streaming-artists-and-music-industry-notables-as-investors-and-strategic-partners-
`
`
`
`33
`
`TRILLER EXHIBIT 1013-0040
`
`

`

`breaks-26-5-million-monthly-average-users-overtaking-tiktok-in-the-united-states-
`300977300.html (last accessed August 16, 2021)).
`
`
`
`See “TRILLER Taps Top Streaming Artists And Music Industry Notables As Investors And
`Strategic Partners; Breaks 26.5 Million Monthly Average Users Overtaking TikTok In The
`United States” at 3 (accessible at: https://www.prnewswire.com/news-releases/triller-taps-
`top-streaming-artists-and-music-industry-notables-as-investors-and-strategic-partners-
`breaks-26-5-million-monthly-average-users-overtaking-tiktok-in-the-united-states-
`300977300.html (last accessed August 16, 2021)).
`
`
`
`
`34
`
`TRILLER EXHIBIT 1013-0041
`
`

`

`
`See “Triller Signs With 7digital In Plans To Topple TikTok Globally” at 1-2 (accessible at
`https://themusicnetwork.com/triller-signs-with-7digital/ (last accessed August 16, 2021));
`see also “As TiKTok Hangs In The Balance, Triller Solidifies Its Content Delivery
`Infrastructure” (accessible at https://www.digitalmusicnews.com/2020/08/13/triller-7digital-
`agreement/ (last accessed August 16, 2021)).
`
`
`
`
`35
`
`TRILLER EXHIBIT 1013-0042
`
`

`

`
`See “7digital / Triller: Description, Go Live Time, Territories, How They Sell Your Music,
`Pay Rate” at 2-3 (accessible at https://support.tunecore.com/hc/en-
`
`
`
`36
`
`TRILLER EXHIBIT 1013-0043
`
`

`

`us/articles/115006692448-7digital-Triller-Description-Go-Live-Time-Territories-How-
`They-Sell-Your-Music-Pay-Rate (last accessed August 16, 2021)).
`
`
`See “Building A Subscription Streaming Service” at 1 (accessible at:
`https://docs.7digital.com/docs/building-a-streaming-service (last accessed August 16,
`
`
`
`
`
`37
`
`TRILLER EXHIBIT 1013-0044
`
`

`

`2021)); see also https://docs.7digital.com/reference (last accessed August 16, 2021);
`https://docs.7digital.com/docs (last accessed August 16, 2021).
`
`
`
`See “Digital Rights Management” (accessible at: https://developer.android.com/reference/
`android/media/MediaDrm.html (las accessed August 16, 2021)).
`
`
`
`
`38
`
`TRILLER EXHIBIT 1013-0045
`
`

`

`See “MediaDrm” (accessible at https://developer.android.com/reference/android/
`media/MediaDrm.html (last accessed August 16, 2021)).
`
`
`Media Operations (Android and iOS)
`
`
`
`
`The Triller software application provides media operations, including video playback and
`uploading videos. As explained above, the Triller software application uses distinct threads
`in a multithreaded architecture to balance the computational demands of different
`operations/programs within the Triller software application, including these media
`operations. See, e.g.:
`
`
`
`
`39
`
`TRILLER EXHIBIT 1013-0046
`
`

`

`Fre)
`
`aE
`Chi Saad
`
`
`
`40
`
`Prinars)
`
`
`
`
`
`
`
`
`
`
`
`