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UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff(s),
`
`
`
`SIGHTLINE PAYMENTS LLC
`
`
`
`v.
`
`EVERI HOLDINGS INC., EVERI PAYMENTS
`INC., EVERI GAMES HOLDING INC., AND
`EVERI GAMES INC.,
`
`
`
`Defendants.
`
`
`
`
`
`Case No. 6:21-cv-1015
`
`PLAINTIFF’S EXCHANGE OF
`PRELIMINARY CLAIM
`CONSTRUCTIONS
`
`
`
`
`
`
`
`Plaintiff Sightline Payments LLC (“Sightline”) serves herewith its proposed constructions
`
`pursuant to Judge Albright’s November 17, 2021 Standing Order Governing Proceedings – Patent
`
`Cases (the “Standing Order”) and Scheduling Order entered by the Court (D.I. 27) of each claim
`
`term, phrase, or clause previously identified by the parties for claim construction purposes.
`
`I.
`
`INTRODUCTION
`
`The following proposed constructions are preliminary. Sightline reserves the right to revise
`
`or otherwise modify these proposed constructions until the parties lodge their CLAIM CONSTRUCTION
`
`BRIEFING in accordance with the Standing Order. This includes the right to make revisions and
`
`modifications following receipt and review of Defendants Everi Holdings Inc., Everi Payments Inc.,
`
`Everi Games Holding Inc., and Everi Games Inc.’s (collectively, “Everi”) proposed constructions,
`
`meet and confers with counsel for Everi as required by the Standing Order, and/or receipt of any
`
`information from Everi or any third-party that might otherwise impact what Sightline believes to be
`
`a legally proper construction of any term.
`
`
`
`EVERI EX. 1031
`Everi v. Sightline IPR2022-00707
`
`

`

`II.
`
`PRELIMINARY CONSTRUCTIONS
`
`TERM
`
`PRELIMINARY CONSTRUCTION
`
`gaming account
`
`Plain and Ordinary Meaning
`
`issuer processor computing system
`
`Plain and Ordinary Meaning
`
`player
`
`Plain and Ordinary Meaning
`
`player credentials
`
`Plain and Ordinary Meaning
`
`player identifier
`
`Plain and Ordinary Meaning
`
`stored value account
`
`Plain and Ordinary Meaning
`
`stored value payment vehicle
`
`Plain and Ordinary Meaning
`
`transaction processor computing system
`
`Plain and Ordinary Meaning
`
`wagering account
`
`Plain and Ordinary Meaning
`
`III. MEET AND CONFER
`
`
`
`
`
`
`
`Sightline proposes an initial meet and confer on March 10, 2022 followed by a subsequent
`
`meet and confer on March 16, 2022.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EVERI EX. 1031
`Everi v. Sightline IPR2022-00707
`
`

`

`Dated: March 2, 2022
`
`
`
`
`
`
`Respectfully submitted,
`
`POLSINELLI PC
`
`
`
`By: /s/ Melenie Van
`(TXBA No. 24002989)
`
`Jonathan R. Spivey
`(TXBA No. 24072504)
`
`LaTasha M. Snipes
`(TXBA No. 15730600)
` Michael D. Pegues
`
`Jahnathan L.D. Braquet (TXBA No. 24125998)
`
`POLSINELLI PC
`
`1000 Louisiana Street, Suite 6400
`
`Houston, Texas 77002
`
`Telephone:
`
`Facsimile:
`
`Email:
`
`
`
`
`
`
`
`
`
`
`Colby B. Springer (pro hac vice)
`
`Joshua L. Rayes (pro hac vice)
`
` Melenie Van (pro hac vice)
`
`Three Embarcadero Center, Suite 2400
`
`San Francisco, California 94111
`
`Telephone:
`
`Facsimile:
`
`Email:
`
`
`
`
`
`
`
`
`COUNSEL FOR SIGHTLINE PAYMENTS LLC
`
`(713) 374-1600
`(713) 374-1601
`jspivey@polsinelli.com
`tsnipes@polsinelli.com
`mpegues@polsinelli.com
`jbraquet@polsinelli.com
`
`(415) 248-2100
`(415) 248-2101
`cspringer@polsinelli.com
`jrayes@polsinelli.com
`mvan@polsinelli.com
`
`EVERI EX. 1031
`Everi v. Sightline IPR2022-00707
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 2, 2022, I electronically served the foregoing on all counsel of
`
`record at the electronic mail addresses agreed to by counsel.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Melenie Van
`Melenie Van
`
`
`
`
`
`EVERI EX. 1031
`Everi v. Sightline IPR2022-00707
`
`

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