IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MULLEN INDUSTRIES LLC,
`
`Plaintiff,
`v.
`
`APPLE INC.,
` Defendant.
`
`Case No. 6:22-cv-00145-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Pursuant to the Court’s Standing Order Governing Proceedings—Patent Cases, Plaintiff
`
`Mullen Industries LLC serves its preliminary infringement contentions in the form of charts,
`
`attached hereto, setting forth where in the accused products and services each element of each
`
`asserted claim is found. Plaintiff identifies that for each asserted claim of each of U.S. Patent Nos.
`
`11,246,024; 11,234,117; 11,122,418; 11,109,218; 11,096,039; 9,635,540; 9,204,283; and
`
`8,374,575, the priority date is March 25, 2002, corresponding to the filing date of U.S. Provisional
`
`Patent Application No. 60/367,967. Plaintiff identifies that for each asserted claim of U.S. Patent
`
`No. 11,190,633, the priority date is March 14, 2003, corresponding to the filing date of U.S.
`
`Provisional Patent Application No. 60/455,218. A copy of the file history for each patent-in-suit
`
`is produced herewith. Collectively, the asserted patents are referred to as the “Patents-in-Suit.”
`
`Apple directly and literally infringes each asserted claim of the Patents-in-Suit. On
`
`information and belief, Apple also induces its third-party manufacturer, Flex Ltd., located in this
`
`District to directly infringe asserted claims of U.S. Patent Nos. 11,234,117 and 11,122,418 by
`
`actively encouraging such third-party manufacturer to make infringing Mac Pro computers in this
`
`District. As set forth in Plaintiff’s First Amended Complaint (e.g., ¶¶ 9-27), Apple knew that the
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 1 of 882
`
`

`

`acts it induced its third-party manufacturer to undertake constituted infringement of the ’117 and
`
`’418 Patents, or alternatively, Apple was willfully blind to such infringement.
`
`At present, Apple has provided no discovery, including regarding (i) the accused products
`
`and services, (ii) Apple’s manufacturer of accused products in this District, (iii) the performance
`
`by such manufacturer and/or another entity of the accused processes (e.g., through testing) in this
`
`District and/or elsewhere in the United States, (iv) Apple’s knowledge of the Patents-in-Suit, and
`
`(v) Apple’s knowledge of its infringement of the Patents-in-Suit. As such, these preliminary
`
`infringement contentions are based on the information that is known and publicly available to
`
`Plaintiff at this time. Plaintiff reserves the right to supplement, amend, and/or modify these
`
`contentions based on additional information obtained through discovery, Markman proceedings,
`
`Defendant’s arguments in this case including as to claim construction and/or alleged
`
`noninfringement, or otherwise. For example, to the extent Apple argues that it does not directly
`
`and/or literally practice any claim element, Plaintiff reserves the right to demonstrate with the
`
`benefit of discovery (e.g., discovery of Apple’s source code for the accused products and server
`
`system) indirect infringement and/or infringement under the doctrine of equivalents. Plaintiff also
`
`reserves the right to amend its contentions based on a change in circumstances, expert discovery,
`
`any rulings of the Court, and any other case or proceedings, if any. In addition, Plaintiff reserves
`
`the right to rely upon, at trial or otherwise, any evidence or information from any source hereinafter
`
`discovered or obtained.
`
`In the accompanying claim charts, representative Apple device model numbers are shown.
`
`For avoidance of doubt, the accused products also include all Apple Mac computers, iPhones,
`
`iPads, iPod touch devices, and Watches released by Apple subsequent to the model numbers
`
`2
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 2 of 882
`
`

`

`identified in the attached claim charts, and each server system for providing location-based
`
`features, including through Apple Find My, Find My Friends, Find People, and/or Apple Maps.
`
`Dated: May 6, 2022
`
`Respectfully submitted,
`
`/s/ Peter F. Snell
`Stafford Davis
`State Bar No. 24054605
`sdavis@stafforddavisfirm.com
`Catherine Bartles
`State Bar No. 24104849
`cbartles@stafforddavisfirm.com
`THE STAFFORD DAVIS FIRM, PC
`815 South Broadway Avenue
`Tyler, Texas 75701
`Tel: 903-593-7000
`Fax: 903-705-7369
`
`Peter F. Snell (admitted pro hac vice)
`MINTZ LEVIN COHN FERRIS
`GLOVSKY AND POPEO, P.C.
`666 Third Avenue
`New York, NY 10017
`(212) 935-3000
`pfsnell@mintz.com
`
`Attorneys for Plaintiff
`Mullen Industries LLC
`
`3
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 3 of 882
`
`

`

`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the foregoing document
`
`and accompanying attachments has been served on counsel for Defendant by email per agreement
`
`of the parties that service can be accomplished via email.
`
`/s/ Peter F. Snell
`Peter F. Snell
`
`4
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 4 of 882
`
`

`

`U.S. Patent No. 8,374,575
`
`Claims 1, 2, 3, 6, 8, 13, 23, 24, 26, 28, 30, 31, 32, 35, 37, 38, 39, 40, 42, 44
`Apple iCloud Server System
`
`- 1 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 5 of 882
`
`

`

`1. A method comprising:
`
`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`To the extent the preamble is limiting, Apple’s iCloud server system performs a method including
`providing location-based services and features to Apple wireless telephonic devices such as Mac
`computers, iPhones, iPads, Apple Watches, and iPod touch devices accessing, for example, Apple Find My
`or Find My Friends and Apple Maps (e.g., on Mac computers with macOS, iPhones with iOS 13 and later,
`iPads with iPadOS 13 and later, and iPod touch devices with iOS), or Apple Find People and Apple Maps
`(e.g., on Apple Watches with watchOS 6 and later). E.g.:
`
`- 2 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 6 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`- 3 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 7 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://www.apple.com/icloud/find-my/.
`
`- 4 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 8 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`- 5 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 9 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://www.apple.com/maps/.
`
`- 6 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 10 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://www.apple.com/apple-watch-series-7/.
`
`https://support.apple.com/guide/watch/find-people-
`apd1132106dc/watchos#:~:text=Open%20the%20Find%20People%20app%20on%20your%20Apple%20
`Watch%20to,return%20to%20your%20friends%20list.
`
`- 7 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 11 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://www.apple.com/icloud/.
`
`- 8 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 12 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`…
`
`…
`
`…
`
`https://www.apple.com/legal/privacy/data/en/location-services/.
`
`- 9 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 13 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`…
`
`https://www.apple.com/legal/privacy/law-enforcement-guidelines-us.pdf.
`
`- 10 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 14 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`The Apple iCloud server system is capable of communicating with, for example, Apple Mac computers,
`Apple iPod touch devices, Apple iPhones iOS 13 and later and all Apple iPads iPadOS 13 and later, all of
`which have Apple Find My or Find My Friends and Apple Maps programming preinstalled. E.g.:
`
`https://www.t-mobile.com/support/devices/apple/apple-ios-15/pre-installed-on-ios-15 (iOS 15);
`https://www.t-mobile.com/support/devices/apple/apple-ios-14/pre-installed-on-ios-14 (iOS 14);
`
`- 11 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 15 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`https://www.t-mobile.com/support/devices/apple/apple-ios-13/pre-installed-apps-apple-iphone-on-ios-13
`(iOS 13); https://www.t-mobile.com/support/devices/apple/apple-ipados-15/pre-installed-on-ipados-15
`(iPadOS 15); https://www.t-mobile.com/support/devices/apple/ipados-14/pre-installed-on-ipados-14
`(iPadOS 14); https://www.t-mobile.com/support/devices/apple/ipados-13/pre-installed-apps-apple-ipados-
`13 (iPadOS 13).
`
`The Apple iCloud server system is also capable of communicating with Apple iPhones and Apple iPads for
`which Apple installs Apple Find My and Apple Maps subsequent to initial sale by causing such iPhones
`and iPads to execute software updates. E.g.:
`
`https://www.republicworld.com/technology-news/apps/what-happened-to-the-find-my-friends-app-on-ios-
`13.html.
`
`The Apple iCloud server system is capable of communicating with iPhone SE, iPhone 6s, and later
`generation iPhones including, for example, iPhone 7, iPhone 8, iPhone XS, and iPhone 11 for which Apple
`- 12 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 16 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`has installed Find My and Apple Maps after initial sale of such devices by installing iOS 13, iOS 14, and
`iOS 15 (and sub-releases of same) via software updates on such devices. E.g.:
`
`https://developer.apple.com/forums/thread/122664 (iOS 13); https://9to5mac.com/2020/09/18/iphones-
`supported-by-ios-14/ (iOS 14); https://www.cnet.com/tech/mobile/ios-15-is-coming-will-your-iphone-be-
`able-to-run-apples-latest-os/ (iOS 15).
`
`The Apple iCloud server system is also capable of communicating with iPad Air 2 and later generation
`iPads including, for example, iPad Air, 3rd generation, iPad mini 4, iPad mini, 5th generation, iPad, 5th and
`6th generations, and iPad Pro models on which Apple has installed Find My and Apple Maps after initial
`sale of such devices by installing iPadOS 13, iPadOS 14, and iPadOS 15 (and sub-releases of same) via
`software updates on such devices. E.g.:
`
`- 13 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 17 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://www.computerworld.com/article/3282811/which-iphones-ipads-support-apples-ios-13-and-
`ipados.html (iPadOS 13); https://appleinsider.com/articles/20/06/22/ios-14-supports-all-devices-that-ran-
`ios-13 (iPadOS 14); https://9to5mac.com/2021/09/20/all-ipads-that-support-ipados-15/ (iPadOS 15).
`
`The Apple iCloud server system is also capable of communicating with, for example, all Apple Watches
`watchOS 6 and later on which the Apple Find People and Apple Maps programming is preinstalled. E.g.:
`
`- 14 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 18 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://support.apple.com/guide/watch/apps-on-apple-watch-apdf1ebf8704/watchos.
`
`In addition, the Apple iCloud server system is capable of communicating with Apple iPhones and Apple
`iPads running versions iOS 8 through iOS 12 and Apple Watches running watchOS 3 through 5 on which
`Apple has preinstalled or installed by way of software updates after initial sale the Apple Find My Friends
`and Apple Maps programming. E.g.:
`
`- 15 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 19 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(pre)
`"1. A method comprising:"
`
`https://support.apple.com/en-us/HT201493.
`
`The Apple iCloud server system’s capability to communicate with each Apple iPhone programmed with
`Apple Find My and Apple Maps is representative of the Apple iCloud server system’s capability to
`communicate with all Apple Mac computers, Apple iPhones and iPads iOS 8 through 15 (including all
`sub-releases of thereof), all Apple iPads iOS 8 through 12 and iPadOS 13 through 15, all iPod touch
`devices, and all Apple Watches watchOS 3 through 6 programmed with (i) Apple Find My, Apple Find
`My Friends, and/or Apple Find People and (ii) Apple Maps. See id.; see also e.g.
`https://www.republicworld.com/technology-news/apps/what-happened-to-the-find-my-friends-app-on-ios-
`13.html (“The dedicated Find My Friends app was removed by apple after the iOS 13.1 update; however,
`the feature still exists. After removing the application from the Home screen, the company has combined
`the Find My Friends application with the Find My iPhone app with the recent release of iOS 13. The two
`apps have been clubbed within the same application titled Find My.”).
`
`- 16 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 20 of 882
`
`

`

`obtaining a location of a first wireless
`telephone;
`
`U.S. Patent No. 8,374,575: Claim 1(a)
`"obtaining a location of a first wireless telephone;"
`Apple’s iCloud server system obtains a location of a first wireless telephone.
`
`For example, Apple’s iCloud server system obtains the location of the first wireless telephone from a
`positioning system of the first wireless telephone.
`
`Each Apple iPhone, iPad, and Watch includes a global positioning system (“GPS”) from which the Apple
`iCloud server system obtains the device’s location. E.g.:
`
`https://support.apple.com/kb/SP851?locale=en_US (iPhone 13 – Technical Specifications).
`
`https://support.apple.com/kb/SP844?locale=en_US (iPad Pro, 12.9-inch (5th generation) – Technical
`Specifications).
`
`https://support.apple.com/kb/SP860?locale=en_US (Apple Watch Series 7 – Technical Specifications).
`
`As another example, Apple’s iCloud server system is capable of obtaining a location of each Apple iPod
`touch device on the basis of, for example, Wi-Fi signals in the vicinity of the device (e.g.,
`https://www.second-sense.org/2016/11/ipod-touch-low-cost-alternative/;
`- 17 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 21 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(a)
`"obtaining a location of a first wireless telephone;"
`https://support.apple.com/kb/SP796?locale=en_US) (iPod touch (7th generation) – Technical
`Specifications)).
`
`- 18 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 22 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(b)
`"transmitting said location from said first wireless telephone to a remote server;"
`transmitting said location from said first
`Apple’s iCloud server system obtains a location of a first wireless telephone by the transmitting of said
`wireless telephone to a remote server;
`location from said first wireless telephone to a remote server. See e.g., the evidence cited for claim
`element 1(a).
`
`- 19 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 23 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`changing, at the direction of said first
`Apple’s iCloud server system changes, at the direction of said first wireless telephone, a list of users on
`wireless telephone, a list of users on said
`said Apple iCloud server system for a profile associated with said first wireless telephone that are allowed
`remote server for a profile associated with
`to access said location, wherein each user of said list of users is representative of one of a plurality of
`said first wireless telephone that are allowed
`wireless telephones.
`to access said location, wherein each user of
`said list of users is representative of one of a
`plurality of wireless telephones;
`
`For example, Apple’s iCloud server system changes, at the direction of each Apple iPhone, Apple iPad,
`Apple Watch, and Apple iPod touch device programmed with Apple Find My, Find My Friends, or Find
`People, a list of users for a profile associated with the iPhone, iPad, Watch, or iPod touch device that are
`allowed to access the location of the iPhone, iPad, Watch, or iPod touch device. Each Apple iPhone,
`Apple iPad, Apple Watch, and iPod touch device programmed with Apple Find My, Find My Friends, or
`Find People includes options to add and/or remove individuals who can access the iPhone’s, iPad’s,
`Watch’s, or iPod touch device’s location from Apple’s iCloud server. Such options, when selected,
`instruct Apple’s iCloud server system to change in a profile associated with the device a list of users
`authorized to view the device’s location data, where each such authorized user is associated with a wireless
`telephone (iPhone, iPad, Watch, or iPod touch device).
`
`Each Apple iPhone, Apple iPad, Apple Watch, and Apple iPod touch device programmed with Apple Find
`My, Find My Friends, or Find People includes, for example, an option to share the device’s location (e.g.,
`“Share My Location”) with a user of another device (e.g., as identified by or associated with phone
`number), which when selected instructs Apple’s iCloud server system to add the selected user to the list of
`users authorized to view the device’s location data:
`
`- 20 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 24 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`
`…
`
`- 21 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 25 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`
`https://support.apple.com/en-us/HT210514. In the example above, each of “Marisa Cavanna,” “Jesse
`Cavanna,” “Karina Cavanna,” and “Madi Cavanna” in the list of “People” is a user of an associated
`wireless telephone. Id.
`
`As another example, each Apple iPhone, Apple iPad, Apple Watch, and Apple iPod touch device
`programmed with Apple Find My, Find My Friends, or Find People is capable of displaying an option to
`share the device’s location when another device shares its location with the device (e.g., option to “Share”
`the device’s location with a device associated with the user “Marisa Cavanna”), which when selected
`instructs Apple’s iCloud server system to add the selected user (“Marisa Cavanna”) to the list of users
`authorized to view the device’s location data:
`
`- 22 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 26 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`
`Id.
`
`As additional examples, each Apple iPhone, Apple iPad, Apple Watch, and Apple iPod touch device
`programmed with Apple Find My, Find My Friends, or Find People is capable of displaying options to
`stop sharing the device’s location with everyone, or a particular user, which when selected instructs
`Apple’s iCloud server system to modify as appropriate list of users authorized to view the device’s location
`data:
`
`- 23 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 27 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`
`Id.; see also e.g.:
`
`- 24 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 28 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`
`- 25 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 29 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(c)
`"changing, at the direction of said first wireless telephone, a list of users on said remote server for a profile associated with said first wireless telephone that
`are allowed to access said location, wherein each user of said list of users is representative of one of a plurality of wireless telephones;"
`https://support.apple.com/guide/watch/find-people-
`apd1132106dc/watchos#:~:text=Open%20the%20Find%20People%20app%20on%20your%20Apple%20
`Watch%20to,return%20to%20your%20friends%20list.
`
`https://www.idownloadblog.com/2020/09/23/find-people-find-my-friends-apple-watch/.
`
`- 26 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 30 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(d)
`"transmitting said location from said remote server to at least one of said users of said list of users;"
`transmitting said location from said remote
`Apple’s iCloud server system said location from Apple’s iCloud server system to at least one of said users
`server to at least one of said users of said
`of said list of users.
`list of users;
`
`For example, Apple’s iCloud server system is capable of transmitting the location of an Apple iPhone,
`Apple iPad, Apple Watch, and Apple iPod touch device to at least one of the users of the list of users that
`are authorized to access the location of the iPhone, iPad, Watch, or Apple iPod touch device. See e.g., the
`evidence cited for claim element 1(c). See also e.g.:
`
`https://support.apple.com/en-us/HT210514 (e.g., showing on a user’s iPhone the location, transmitted to
`the iPhone by Apple’s iCloud server system, as “Palo Alto, CA” for each of “Jesse Cavanna,” “Karina
`Cavanna,” and “Madi Cavanna”).
`
`- 27 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 31 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(d)
`"transmitting said location from said remote server to at least one of said users of said list of users;"
`
`https://support.apple.com/en-us/HT210514 (e.g., showing on a user’s iPhone the location, transmitted to
`the iPhone by Apple’s iCloud server system, for “Jesse Cavanna” on a map and in text (“Palo Alto, CA”)).
`
`- 28 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 32 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(d)
`"transmitting said location from said remote server to at least one of said users of said list of users;"
`
`https://www.idownloadblog.com/2020/09/23/find-people-find-my-friends-apple-watch/ (e.g., showing on a
`user’s Apple Watch the location, transmitted to the Apple Watch by Apple’s iCloud server system, as
`“Home” for each of “Jason” and “Mike” (left-most display) and also displaying the location for “Jason” on
`a map (middle display)).
`
`- 29 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 33 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(e)
`"determining a second location associated with one of said plurality of wireless telephones; and"
`determining a second location associated
`Apple’s iCloud server system determines a second location associated with one of said plurality of wireless
`with one of said plurality of wireless
`telephones.
`telephones; and
`
`For example, Apple’s iCloud server system determines the location of each Apple iPhone, Apple iPad,
`Apple Watch, and Apple iPod touch device programmed with Apple Find My, Find My Friends, or Find
`People for which location sharing is enabled. See e.g., the evidence cited for claim element 1(a).
`
`- 30 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 34 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`Apple’s iCloud server system provides directional information to said one of said plurality of wireless
`telephones, wherein said directional information is representative of directions between said location and
`said second location.
`
`providing directional information to said
`one of said plurality of wireless telephones,
`wherein said directional information is
`representative of directions between said
`location and said second location.
`
`For example, Apple’s iCloud server system provides directional information to each Apple iPhone, Apple
`iPad, Apple Watch, and Apple iPod touch device programmed with Apple Find My, Find My Friends, or
`Find People.
`
`Apple’s iCloud server system provides for display on each such Apple iPhone, Apple iPad, Apple Watch,
`and Apple iPod touch device the locations of the wireless telephones associated with the device user’s
`friends. Upon a user’s selection of an option to receive “Directions” to one of such wireless telephones,
`Apple’s iCloud server system provides for display on each such Apple iPhone, Apple iPad, Apple Watch,
`and Apple iPod touch device directions from the location of the iPhone, iPad, Watch, or iPod touch device
`to the selected wireless telephone. E.g.:
`
`- 31 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 35 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`
`https://support.apple.com/en-us/HT210514.
`
`See also:
`
`- 32 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 36 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`
`Redacted iPhone Apple Maps display (showing that selection of “Directions” regarding a friend in Apple
`Find My launches Apple Maps with directions, provided by Apple’s iCloud server system, from “My
`Location” to the friend’s location).
`
`See also e.g.:
`
`- 33 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 37 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`
`https://support.apple.com/guide/watch/get-directions-or-contact-a-friend-apd21475d656/watchos.
`
`- 34 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 38 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`
`…
`
`- 35 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 39 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 1(f)
`"providing directional information to said one of said plurality of wireless telephones, wherein said directional information is representative of directions
`between said location and said second location."
`
`https://www.idownloadblog.com/2020/09/23/find-people-find-my-friends-apple-watch/ (e.g., showing
`option to receive “Directions” from the location of the Apple Watch to the location of a wireless telephone
`associated with “Jason”).
`
`- 36 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 40 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 2
`"2. The method of claim 1, wherein said changing comprises adding an additional user to said list of users."
`2. The method of claim 1, wherein said
`Apple’s iCloud server system adds an additional user to said list of users. See e.g., the evidence cited for
`changing comprises adding an additional
`claim element 1(c) (e.g., Apple’s iCloud server system adding an additional user to the list of users
`user to said list of users.
`authorized to access a wireless telephone’s location in response to a user of the wireless telephone
`selecting an option to share such location with the additional user).
`
`- 37 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 41 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 3
`"3. The method of claim 1, further comprising transmitting the address of said location to said at least one of said users of said list of users."
`3. The method of claim 1, further
`Apple’s iCloud server system transmits the address of said location to said at least one of said users of said
`comprising transmitting the address of said
`list of users. E.g.:
`location to said at least one of said users of
`said list of users.
`
`Redacted iPhone Apple Maps display (showing that Apple’s iCloud server system transmits to the iPhone
`the address to which directions are provided from “My Location”).
`
`- 38 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 42 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 3
`"3. The method of claim 1, further comprising transmitting the address of said location to said at least one of said users of said list of users."
`
`Redacted iPhone Find My display (showing that Apple’s iCloud server system transmits to the iPhone the
`street address (redacted) in the United States of the location of a friend listed under “People”).
`
`See also e.g., the evidence cited for claim element 1(f) (e.g., showing that Apple’s iCloud server system
`also makes location information and directions available to users of iPads and Apple Watches).
`
`- 39 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 43 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 6
`"6. The method of claim 1, further comprising determining a third location associated with one of said plurality of wireless telephones."
`6. The method of claim 1, further
`Apple’s iCloud server system determines a third location associated with one of said plurality of wireless
`comprising determining a third location
`telephones. For example, Apple’s iCloud server system is capable of determining the location of each
`associated with one of said plurality of
`Apple iPhone, Apple iPad, Apple Watch, and Apple iPod touch device programmed with Apple Find My,
`wireless telephones.
`Find My Friends, or Find People for which location sharing is enabled. See e.g., the evidence cited for
`claim element 1(a).
`
`- 40 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 44 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 8
`"8. The method of claim 1, further comprising determining the distance between said first wireless telephone and at least one of said plurality of wireless
`telephones."
`Apple’s iCloud server system determines the distance between said first wireless telephone and at least one
`of said plurality of wireless telephones. E.g.:
`
`8. The method of claim 1, further
`comprising determining the distance
`between said first wireless telephone and at
`least one of said plurality of wireless
`telephones.
`
`Redacted iPhone Apple Maps display (showing that Apple’s iCloud server system transmits to the iPhone
`the distance (e.g., “27 mi[les]”) from “My Location” to a friend’s location).
`
`- 41 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 45 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 8
`"8. The method of claim 1, further comprising determining the distance between said first wireless telephone and at least one of said plurality of wireless
`telephones."
`
`Redacted iPhone Find My display (showing that Apple’s iCloud server system transmits to the iPhone for
`display the distance (e.g., “4.2 miles”) from the iPhone to a friend listed under “People”).
`
`- 42 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 46 of 882
`
`

`

`U.S. Patent No. 8,374,575: Claim 8
`"8. The method of claim 1, further comprising determining the distance between said first wireless telephone and at least one of said plurality of wireless
`telephones."
`
`https://www.idownloadblog.com/2020/09/23/find-people-find-my-friends-apple-watch/ (showing that
`Apple’s iCloud server system transmits to the Apple Watch for display the distance (e.g., “0mi[iles]”) from
`the Apple Watch to the location of Jason’s wireless telephone).
`
`See also e.g., the evidence cited for claim element 1(f).
`- 43 -
`
`Petitioner Apple, Inc.
`Exhibit 1031 - Page 47 of 882
`
`

`

`13. A method com