Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 1 of 26 PageID #: 16392
`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 1 of 26 PageID #: 16392
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`EXHIBIT 11
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`EXHIBIT 11
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 2 of 26 PageID #: 16393
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`(cid:3)
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`v.
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`APPLE, INC.,
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`Plaintiff,
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`Defendant.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Case No. 2:17-CV-0516-JRG
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`JURY TRIAL DEMANDED
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`PLAINTIFF AGIS SOFTWARE DEVELOPMENT LLC’S SECOND SUPPLEMENTAL
`OBJECTIONSAND RESPONSES TO DEFENDANT APPLE INC.’S
`THIRD SET OF INTERROGATORIES TO PLAINTIFF (NOS. 12-15)
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`PLEASE TAKE NOTICE that, pursuant to Rules 26 and 33 of the Federal Rules of Civil
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`Procedure and the Local Rules of this Court, Plaintiff AGIS Software Development LLC
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`(“AGIS” or “Plaintiff”) hereby responds to Defendant Apple Inc.’s (“Apple” or “Defendant”)
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`Third Set of Interrogatories to Plaintiff (Nos. 12-15). These Interrogatories are continuing in
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`nature and require supplementation in accordance with the Federal Rules of Civil Procedure as
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`follows:
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`These responses are made solely for the purposes of this action, and are made without
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`waiving, or intending to waive, the right at any time to revise, correct, modify, supplement or
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`clarify any response provided herein or the right to object on any proper grounds to the use of
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`these responses, for any purpose in whole or in part, in any subsequent proceedings or any other
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`action. The right to raise any applicable objections at any time is expressly reserved. A response
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`to any interrogatory herein should not be taken as an admission or acceptance of the existence of
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`any facts set forth or assumed by such interrogatory, or that such response constitutes admissible
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`(cid:3)
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`

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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 3 of 26 PageID #: 16394
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`(cid:3)
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`Data Sheet filed on February 27, 2015. Accordingly, each application of the ’251, ’055, ’838,
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`and ’829 Patents was properly identified as pre-AIA application and each of the ’251, ’055, ’838,
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`and ’829 Patents are subject to pre-AIA law.
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`Discovery in this case is still ongoing and AGIS continues to investigate this matter.
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`AGIS reserves the right to supplement or amend its response to this interrogatory.
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`INTERROGATORY NO. 14
`INTERROGATORY NO. 14
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`Identify any reference cited and relied upon by Apple in its December 1, 2017 invalidity Identify any reference cited and relied upon by Apple in its December 1, 2017 invalidity
`contentions that AGIS contends is not prior art for purposes of 35 U.S.C. §§ 102 and 103 (e.g.,
`contentions that AGIS contends is not prior art for purposes of 35 U.S.C. §§ 102 and 103 (e.g.,
`because is not a printed publication, was not in public use, was not available to the public, or for
`because is not a printed publication, was not in public use, was not available to the public, or for
`any other reason) and the complete factual and legal bases for such contention.
`any other reason) and the complete factual and legal bases for such contention.
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`RESPONSE TO INTERROGATORY NO. 14:
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this interrogatory as containing multiple distinct subparts, each of which count
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`towards Apple’s total number of interrogatories, and AGIS is willing to meet and confer to
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`properly narrow the scope of the interrogatory. AGIS objects to this interrogatory to the extent it
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`seeks production of documents or information that is in the public domain and, therefore, of no
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`greater burden for Apple than Plaintiff to obtain. AGIS objects to this interrogatory to the extent
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`it seeks identification and production of documents based on legal conclusions or questions of
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`pure law. AGIS further objects to this request as premature at least to the extent it seeks expert
`AGIS further objects to this request as premature at least to the extent it seeks expert
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`opinion or testimony, and AGIS will not produce such information until the appropriate time
`opinion or testimony, and AGIS will not produce such information until the appropriate time
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`under this Court’s scheduling order. AGIS further objects to this interrogatory to the extent it
`under this Court’s scheduling order.
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`purports to require AGIS to identify “complete factual and legal bases” concerning requested
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`subject matter. AGIS further objects to this Topic on the ground it seeks information not within
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`the custody, possession, or control of AGIS. AGIS further objects to this Topic on the ground it
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`seeks information not within the custody, possession, or control of AGIS. AGIS objects to this
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`(cid:3)
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`6
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 4 of 26 PageID #: 16395
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`(cid:3)
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`interrogatory to the extent it is overly broad and/or unduly burdensome, and not proportional to
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`the needs of the case. AGIS objects to this interrogatory to the extent it calls for confidential
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`and/or proprietary information of any individual or entity other than AGIS.
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`Notwithstanding its general and specific objections, AGIS answers as follows:
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`Discovery in this case is still ongoing and AGIS continues to investigate this matter. The
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`Patents-in-Suit are presumed valid, and it is Defendant’s burden to establish invalidity by clear
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`and convincing evidence. The Asserted Claims are valid under 35 U.S.C. §§ 102 and 103.
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`AGIS’s discovery, investigation and analysis are ongoing. Moreover, Apple continues to
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`produce documents that appear to be related to, among other things, the subject of this
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`Interrogatory. AGIS reserves the right to supplement or amend its response to this interrogatory.
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`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 14:
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`
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this Interrogatory as seeking information that is irrelevant, overly broad, and
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`unduly burdensome because Apple no longer asserts many of the references cited and formerly
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`relied upon by Apple in its December 1, 2017 invalidity contentions. Apple elected a final
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`subset of alleged prior art on August 29, 2018, and this Response addresses only the elected
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`references.
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`Notwithstanding its general and specific objections, AGIS answers as follows: The
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`following references are not prior art to the respective patents-in-suit as contended by Apple in
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`its August 29, 2018 election of prior art references:
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`(cid:129) United States Patent No. 7,609,669 to Sweeney is not prior art because the filing date
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`listed on the face of the patent is February 14, 2005.
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`(cid:3)
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`7
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 5 of 26 PageID #: 16396
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`(cid:3)
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`(cid:3)
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`(cid:129) United States Patent Application No. 08/0219416 to Roujinsky is not prior art because
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`the filing date listed on the face of the published patent application is February 15, 2008.
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`While Roujinsky appears to claim priority to August 10, 2006 and/or August 15, 2005 on
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`the face of the patent application, the features for which Apple relies on in Roujinsky are
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`not adequately supported under 35 U.S.C. Section 112(a) by the descriptions
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`corresponding to the alleged priority dates.
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`(cid:129) AGIS’s LifeRing product is not prior art because Apple has not alleged or shown that the
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`invention was in public use or on sale in this country, more than one year prior to the date
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`of application for patent in the United States, and Apple has not alleged that it was in
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`public use, on sale, or offered for sale more than a year prior to the earliest filing date of
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`each of the patents-in-suit. AGIS’s LifeRing product and its prototypes are not prior art
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`because Apple alleges that the product was made available to the public “at least by
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`October 30, 2005.” Apple has not shown that the LifeRing product and its prototypes
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`were “in public use” or “on sale.” Apple has not shown that any LifeRing documents are
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`printed publications.
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`(cid:129) The Force XXI Battle Command, Brigade and Below system is not prior art because
`The Force XXI Battle Command, Brigade and Below system is not prior art because
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`Apple has not alleged or shown that the invention was in public use or on sale in this
`Apple has not alleged or shown that the invention was in public use or on sale in this
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`country, more than one year prior to the date of application for patent in the United
`country, more than one year prior to the date of application for patent in the United
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`States, and Apple has not alleged that it was in public use, on sale, or offered for sale
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`States, and Apple has not alleged that it was in public use, on sale, or offered for sale u
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`more than a year prior to the earliest filing date of each of the patents-in-suit. The Force
`more than a year prior to the earliest filing date of each of the patents-in-suit. The Force
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`XXI Battle Command, Brigade and Below is not prior art because Apple has not shown
`XXI Battle Command, Brigade and Below is not prior art because Apple has not shown
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`that the Force XXI Battle Command, Brigade and Below was in “public use” or “on
`that the Force XXI Battle Command, Brigade and Below was in “public use” or “on
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`sale.” The Force XXI Battle Command, Brigade and Below system is not prior art
`sale.” The Force XXI Battle Command, Brigade and Below system is not prior art
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`8
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 6 of 26 PageID #: 16397
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`(cid:3)
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`(cid:3)
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`because Apple has not shown that any purported use was “ready for patenting.” The because Apple has not shown that any purported use was “ready for patenting.” The
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`Force XXI Battle Command, Brigade and Below system is not prior art because Apple
`Force XXI Battle Command, Brigade and Below system is not prior art because Apple
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`has not shown that any purported use constitutes “the invention,” occurred before the
`has not shown that any purported use constitutes “the invention,” occurred before the
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`critical date, and was in fact public. The Force XXI Battle Command, Brigade and Below
`critical date, and was in fact public. The Force XXI Battle Command, Brigade and Below
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`system is not prior art because the documents cited in Apple’s invalidity contentions do d
`system is not prior art because the documents cited in Apple’s invalidity contentions do
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`not show sufficiently that the purported use was neither accessible to the public nor
`not show sufficiently that the purported use was neither accessible to the public nor
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`commercially exploited. The Force XXI Battle Command, Brigade and Below system is
`commercially exploited. The Force XXI Battle Command, Brigade and Below system is
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`not prior art because Apple has not shown that there existed a sale, or offer to sell, more
`not prior art because Apple has not shown that there existed a sale, or offer to sell, more
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`than 1 year before the effective filing date of the U.S. application and the subject matter
`than 1 year before the effective filing date of the U.S. application and the subject matter
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`of the sale, or offer to sell, fully anticipated the claimed inventions in the patents-in-suit
`of the sale, or offer to sell, fully anticipated the claimed inventions in the patents-in-suit
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`or would have rendered the claimed inventions obvious by its addition to the prior art.
`or would have rendered the claimed inventions obvious by its addition to the prior art.
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`The Force XXI Battle Command, Brigade and Below documents cited by Apple are not
`The Force XXI Battle Command, Brigade and Below documents cited by Apple are not
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`
`themselves prior art because Apple has not asserted the Force XXI Battle Command, d
`themselves prior art because Apple has not asserted the Force XXI Battle Command,
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`Brigade and Below documents as printed publications and the Force XXI Battle
`Brigade and Below documents as printed publications and the Force XXI Battle
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`Command, Brigade and Below documents are not printed publications.
`Command, Brigade and Below documents are not printed publications.
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`(cid:129) U.S. Patent No. 7,353,034 to Haney is not prior art because the filing date listed on the
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`face of the patent is April 4, 2005.
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`(cid:129) The ActiveCampus system is not prior art because Apple has not alleged or shown that
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`the invention was in public use or on sale in this country, more than one year prior to the
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`date of application for patent in the United States, and Apple has not alleged that it was in
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`public use, on sale, or offered for sale more than a year prior to the earliest filing date of
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`each of the patents-in-suit. The ActiveCampus system is not prior art because Apple has
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`not shown that the ActiveCampus was in “public use” or “on sale.” The ActiveCampus
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`9
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 7 of 26 PageID #: 16398
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`(cid:3)
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`investigation and analysis are ongoing. AGIS reserves the right to supplement or amend its
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`response to this interrogatory.
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`INTERROGATORY NO. 15
`INTERROGATORY NO. 15
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`Identify each reference cited and relied upon by Apple in its December 1, 2017 invalidity Identify each reference cited and relied upon by Apple in its December 1, 2017 invalidity
`contentions that AGIS contends does not disclose one or more limitations of one or more
`contentions that AGIS contends does not disclose one or more limitations of one or more
`asserted claims under 35 U.S.C. §§ 102 and 103, and, for each reference, identify the limitations
`asserted claims under 35 U.S.C. §§ 102 and 103, and, for each reference, identify the limitations
`that AGIS contends are not disclosed by the reference and the complete factual and legal bases
`that AGIS contends are not disclosed by the reference and the complete factual and legal bases
`for such contention.
`for such contention.
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`RESPONSE TO INTERROGATORY NO. 15:
`RESPONSE TO INTERROGATORY NO. 15:
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this interrogatory as containing multiple distinct subparts, each of which count
`
`towards Apple’s total number of interrogatories, and AGIS is willing to meet and confer to
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`properly narrow the scope of the interrogatory. AGIS objects to this interrogatory to the extent it
`
`seeks identification and production of documents based on legal conclusions or questions of pure
`
`law. AGIS further objects to this request as premature at least to the extent it seeks expert
`AGIS further objects to this request as premature at least to the extent it seeks expert
`
`opinion or testimony, and AGIS will not produce such information until the appropriate time
`opinion or testimony, and AGIS will not produce such information until the appropriate time
`
`under this Court’s scheduling order. AGIS further objects to this interrogatory to the extent it
`under this Court’s scheduling order. A
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`purports to require AGIS to identify “complete factual and legal bases” concerning requested
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`subject matter. AGIS further objects to this Topic on the ground it seeks information not within
`
`the custody, possession, or control of AGIS. AGIS objects to this interrogatory to the extent it is
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`overly broad and/or unduly burdensome, and not proportional to the needs of the case.
`
`Notwithstanding its general and specific objections, AGIS answers as follows:
`
`Discovery in this case is still ongoing and AGIS continues to investigate this matter. The
`
`Patents-in-Suit are presumed valid, and it is Defendant’s burden to establish invalidity by clear
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`and convincing evidence. The Asserted Claims are valid under 35 U.S.C. §§ 102 and 103
`
`(cid:3)
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`15
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 8 of 26 PageID #: 16399
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`(cid:3)
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`known methods to obtain the claimed invention. Defendants have not presented "articulated
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`reasoning with some rational underpinning to support the legal conclusion of obviousness.’”
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`KSR International Co. v. Teleflex Inc., 550 U.S. 398, at 418, 82 USPQ2d 1396 (2007).
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`Accordingly, none of the combinations based on Zimmers or the knowledge of a person having
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`ordinary skill in the art would render the claims obvious.
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`The elected references fail to disclose and/or suggest claims 2, 5, 6, 12, 15, 18, 27, 29, 31
`The elected references fail to disclose and/or suggest claims 2, 5, 6, 12, 15, 18, 27, 29, 31
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`and 35 of the ’251 Patent for at least the following non-limiting, exemplary reasons.
`and 35 of the ’251 Patent for at least the following non-limiting, exemplary reasons.
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`The Force XXI Battle Command, Brigade and Below system (FBCB2) fails to disclose
`The Force XXI Battle Command, Brigade and Below system (FBCB2) fails to disclose
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`and/or suggest claims 2, 5, 6, 12, 15, 18, 27, 29, 31 and 35 of the ’251 Patent for at least the
`and/or suggest claims 2, 5, 6, 12, 15, 18, 27, 29, 31 and 35 of the ’251 Patent for at least the
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`following non-limiting, exemplary reasons. As a preliminary matter, to the extent the claims of
`following non-limiting, exemplary reasons. As a preliminary matter, to the extent the claims of
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`the ’251 Patent are means-plus-function terms, FBCB2 fails to disclose both the structure and
`the ’251 Patent are means-plus-function terms, FBCB2 fails to disclose both the structure and
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`function of every term.
`function of every term.
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`Regarding claim 1, FBCB2 fails to disclose “a first device, receiving a message from a
`Regarding claim 1, FBCB2 fails to disclose “a first device, receiving a message from a
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`second device, wherein the message relates to joining a group.”
`second device, wherein the message relates to joining a group.”
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`Furthermore, FBCB2 fails to disclose the limitation “based on receiving the message
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`Furthermore, FBCB2 fails to disclose the limitation “based on receiving the message n
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`from the second device, participating in the group, wherein participating in the group includes
`from the second device, participating in the group, wherein participating in the group includes
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`sending first location information to a server and receiving second location information from the
`sending first location information to a server and receiving second location information from the
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`server, the first location information comprising a location of the first device, the second location
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`server, the first location information comprising a location of the first device, the second location a
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`information comprising a plurality of locations of a respective plurality of second devices
`information comprising a plurality of locations of a respective plurality of second devices
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`included in the group.”
`included in the group.”
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`Furthermore, FBCB2 fails to disclose the limitation “presenting, via an interactive
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`Furthermore, FBCB2 fails to disclose the limitation “presenting, via an interactiven
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`display of the first device, a first interactive, georeferenced map and a plurality of user-selectable
`display of the first device, a first interactive, georeferenced map and a plurality of user-selectable
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`(cid:3)
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`33
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 9 of 26 PageID #: 16400
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`(cid:3)
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`symbols corresponding to the plurality of second devices, wherein the symbols are positioned on symbols corresponding to the plurality of second devices, wherein the symbols are positioned on
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`the first georeferenced map at respective positions corresponding to the locations of the second
`the first georeferenced map at respective positions corresponding to the locations of the second
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`devices, and wherein the first georeferenced map includes data relating positions on the first
`devices, and wherein the first georeferenced map includes data relating positions on the first
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`georeferenced map to spatial coordinates.”
`georeferenced map to spatial coordinates.”
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`Furthermore, FBCB2 fails to disclose the limitation “sending, from the first device to the n
`Furthermore, FBCB2 fails to disclose the limitation “sending, from the first device to the
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`server, a request for a second georeferenced map different from the first georeferenced map,
`server, a request for a second georeferenced map different from the first georeferenced map,
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`wherein the request specifies a map location.”
`wherein the request specifies a map location.”
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`Furthermore, FBCB2 fails to disclose the limitation “receiving, from the server, then
`Furthermore, FBCB2 fails to disclose the limitation “receiving, from the server, the
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`second georeferenced map, wherein the second georeferenced map includes the requested ff
`second georeferenced map, wherein the second georeferenced map includes the requested
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`location and data relating positions on the second georeferenced map to spatial coordinates.”
`location and data relating positions on the second georeferenced map to spatial coordinates.”
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`Furthermore, FBCB2 fails to disclose the limitation “presenting, via the interactiven
`Furthermore, FBCB2 fails to disclose the limitation “presenting, via the interactive
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`display of the first device, the second georeferenced map and the plurality of user-selectable
`display of the first device, the second georeferenced map and the plurality of user-selectable
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`symbols corresponding to the plurality of second devices, wherein the symbols are positioned on
`symbols corresponding to the plurality of second devices, wherein the symbols are positioned on
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`the second georeferenced map at respective positions corresponding to the locations of the
`the second georeferenced map at respective positions corresponding to the locations of the
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`second devices.”
`second devices.”
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`Furthermore, FBCB2 fails to disclose the limitation “identifying user interaction with the
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`Furthermore, FBCB2 fails to disclose the limitation “identifying user interaction with then
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`interactive display selecting one or more of the user-selectable symbols corresponding to one or
`interactive display selecting one or more of the user-selectable symbols corresponding to one or
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`more of the second devices and positioned on the second georeferenced map and user interaction
`more of the second devices and positioned on the second georeferenced map and user interaction
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`with the display specifying an action and, based thereon, using an Internet Protocol to send data
`with the display specifying an action and, based thereon, using an Internet Protocol to send data
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`to the one or more second devices via the server, wherein the first device does not have access to
`to the one or more second devices via the server, wherein the first device does not have access to
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`respective Internet Protocol addresses of the second devices.”
`respective Internet Protocol addresses of the second devices.”
`
`Regarding claim 2, FBCB2 fails to disclose the limitation “wherein the data includes a
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`Regarding claim 2, FBCB2 fails to disclose the limitation “wherein the data includes a ii
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`short message service message, a text message, an image, or a video.”
`short message service message, a text message, an image, or a video.”
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`(cid:3)
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`34
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 10 of 26 PageID #: 16401
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`(cid:3)
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`Regarding claim 5, FBCB2 fails to disclose the limitation “sending, by the first device, Regarding claim 5, FBCB2 fails to disclose the limitation “sending, by the first device, ii
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`updated location information comprising an updated location of the first device, the updated
`updated location information comprising an updated location of the first device, the updated
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`location information being sent based on passage of a predetermined time interval since sending f
`location information being sent based on passage of a predetermined time interval since sending
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`previous location information comprising a previous location of the first device, displacement of
`previous location information comprising a previous location of the first device, displacement of
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`the first device by a predetermined distance relative to a previous location of the first device, or
`the first device by a predetermined distance relative to a previous location of the first device, or
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`both.”
`both.”
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`Regarding claim 6, FBCB2 fails to disclose the limitation “identifying second user ii
`Regarding claim 6, FBCB2 fails to disclose the limitation “identifying second user
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`interaction with the interactive display selecting at least one of the user-selectable symbols
`interaction with the interactive display selecting at least one of the user-selectable symbols
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`corresponding to at least one of the second devices and user interaction with the display
`corresponding to at least one of the second devices and user interaction with the display
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`specifying an action and, based thereon, initiating a phone call or phone conference with the at
`specifying an action and, based thereon, initiating a phone call or phone conference with the at
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`least one second device.”
`least one second device.”
`
`Regarding claim 12, FBCB2 fails to disclose the limitation “using a Global Positioning
`Regarding claim 12, FBCB2 fails to disclose the limitation “using a Global Positioning
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`Satellite (GPS) receiver of the first device to obtain data indicative of the location of the first
`Satellite (GPS) receiver of the first device to obtain data indicative of the location of the first
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`device, wherein sending the first location information to the server comprises using the Internet
`device, wherein sending the first location information to the server comprises using the Internet
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`Protocol (IP) to send the first location information to the server.”
`Protocol (IP) to send the first location information to the server.”
`
`Regarding claim 13, FBCB2 fails to disclose the limitation “identifying, by the first
`Regarding claim 13, FBCB2 fails to disclose the limitation “identifying, by the first
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`device, user interaction with the display selecting a particular user-selectable symbol positioned
`device, user interaction with the display selecting a particular user-selectable symbol positioned
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`on the second georeferenced map and corresponding to a particular second device, wherein
`on the second georeferenced map and corresponding to a particular second device, wherein
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`identifying the user interaction selecting the particular user-selectable symbol comprises:
`identifying the user interaction selecting the particular user-selectable symbol comprises:
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`detecting user selection of a portion of the interactive display corresponding to a position
`detecting user selection of a portion of the interactive display corresponding to a position
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`on the second georeferenced map;”
`on the second georeferenced map;”
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`Furthermore, FBCB2 fails to disclose the limitation “based at least in part on coordinates
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`Furthermore, FBCB2 fails to disclose the limitation “based at least in part on coordinates n
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`of the selected position on the second georeferenced map and on the data relating positions on
`of the selected position on the second georeferenced map and on the data relating positions on
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`(cid:3)
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`35
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`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 11 of 26 PageID #: 16402
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`(cid:3)
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`the second georeferenced map to spatial coordinates, determining spatial coordinates of a the second georeferenced map to spatial coordinates, determining spatial coordinates of a
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`location represented by the selected position on the second georeferenced map.”
`location represented by the selected position on the second georeferenced map.”
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`Furthermore, FBCB2 fails to disclose the limitation “identifying the particular user-n
`Furthermore, FBCB2 fails to disclose the limitation “identifying the particular user-
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`selectable symbol based, at least in part, on the spatial coordinates represented by the selected
`selectable symbol based, at least in part, on the spatial coordinates represented by the selected
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`position.”
`position.”
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`Regarding claim 14, FBCB2 fails to disclose the limitation “wherein identifying the
`Regarding claim 14, FBCB2 fails to disclose the limitation “wherein identifying the
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`particular user-selectable symbol based, at least in part, on the spatial coordinates represented by
`particular user-selectable symbol based, at least in part, on the spatial coordinates represented by
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`the selected position comprises:
`the selected position comprises:
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`searching a database of entities for an entity located nearest to the spatial coordinates
`searching a database of entities for an entity located nearest to the spatial coordinates
`
`represented by the selected position, wherein the entities represented by data in the database
`represented by the selected position, wherein the entities represented by data in the database
`
`include the second devices, wherein the database data include locations of the respective entities,
`include the second devices, wherein the database data include locations of the respective entities,
`
`and wherein the database is searchable by location.”
`and wherein the database is searchable by location.”
`
`
`Furthermore, FBCB2 fails to disclose the limitation “based on a result of searching then
`Furthermore, FBCB2 fails to disclose the limitation “based on a result of searching the
`
`database, identifying the particular second device as the entity located nearest to the spatial
`database, identifying the particular second device as the entity located nearest to the spatial
`
`coordinates represented by the selected position, wherein the particular user-selectable symbol
`coordinates represented by the selected position, wherein the particular user-selectable symbol
`
`corresponds to the particular second device.”
`corresponds to the particular second device.”
`
`Regarding claim 15, FBCB2 fails to disclose the limitation “wherein the entity is a first
`Regarding claim 15, FBCB2 fails to disclose the limitation “wherein the entity is a first
`
`entity, and wherein the method further comprises performing by the first device:
`entity, and wherein the method further comprises performing by the first device:
`
`receiving user input via user interaction with the interactive display of the first device, the
`receiving user input via user interaction with the interactive display of the first device, the
`
`user input specifying a location and a symbol corresponding to a second entity other than the first
`user input specifying a location and a symbol corresponding to a second entity other than the first
`
`device and the second devices.”
`device and the second devices.”
`
`(cid:3)
`
`36
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`

`

`Case 2:17-cv-00513-JRG Document 257-11 Filed 01/04/19 Page 12 of 26 PageID #: 16403
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`(cid:3)
`
`
`
`
`
`Furthermore, FBCB2 fails to disclose the limitation “based on the user input, adding the Furthermore, FBCB2 fails to disclose the limitation “based on the user input, adding the n
`
`user-specified symbol to the interactive display at a position on the second georeferenced map
`user-specified symbol to the interactive display at a position on the second georeferenced map
`
`corresponding to the user-specified location of the second entity.”
`corresponding to the user-specified location of the second entity.”
`
`Regarding claim 16, FBCB2 fails to disclose the limitation “transmitting the user-
`Regarding claim 16, FBCB2 fails to disclose the limitation “transmitting the user-
`
`specified symbol and location of the second entity to the second devices for addition of the user-
`specified symbol and location of the second entity to the second devices for addition of the user-
`
`specified symbol to respective interactive displays of the second devices at respective positions
`specified symbol to respective interactive displays of the second devices at respective positions
`
`on respective georeferenced maps corresponding to the user-specified location of the second
`on respective georeferenced maps corresponding to the user-specified location of the second
`
`entity.”
`entity.”
`
`Regarding claim 17, FBCB2 fails to disclose the limitation “wherein the user input
`Regarding claim 17, FBCB2 fails to disclose the limitation “wherein the user input
`
`further specifies information associated with the second entity, and wherein the method further
`further specifies information associated with the second entity, and wherein the method further
`
`comprises performing, by the first device: transmitting the user-specified information associated
`comprises performing, by the first device: transmitting the user-specified information associated
`
`with the s