Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 1 of 8 PageID #: 1618
`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 1 of 8 PageID #: 1618
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`EXHIBIT A
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`EXHIBIT A
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 1 of 8 PageID #: 1618
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`EXHIBIT A
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`EXHIBIT A
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 2 of 8 PageID #: 1619
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`
`
`Plaintiff.
`
`
`
`
`
`
`Case No. 9:14-cv-80651-DMM
`
`
`ADVANCED GROUND INFORMATION
`SYSTEMS, INC.,
`
`
`
`
`
`v.
`
`LIFE360, INC.,
`
`
`
`
`
`
`
`Defendant.
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`PLAINTIFF ADVANCED GROUND INFORMATION SYSTEMS, INC.’S
`INITIAL DISCLOSURES
`
`Pursuant to Federal Rule of Civil Procedure 26(a)(1), and Local Civil Rule 26, Plaintiff
`
`
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`Advanced Ground Information Systems, Inc. (“AGIS”) serves the following disclosures. AGIS
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`reserves its right to object to the discovery or admission of any information included in the
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`following categories.
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`A.
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`Individuals Likely to Have Discoverable Information (Fed. R. Civ. P. 26(a)(1)(A)(i))
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`1.
`
`Malcolm K. Beyer, Jr.
`CEO and Director
`Advanced Ground Information Systems, Inc.
`92 Lighthouse Drive
`Jupiter, FL 33469
`(561) 714-3213
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`
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`
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`Mr. Beyer is the CEO and Director of AGIS. He is knowledgeable about the conception,
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`reduction to practice, research, development, prototyping, and implementation of the inventions
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`described and claimed in U.S. Patent numbers 7,031,728 (“the ’728 patent”), 7,764,954 (“the
`
`’954 patent”), 8,126,441 (“the ’441 patent”), and 7,672,681 (“the ’681 patent”) (collectively, the
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`
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 3 of 8 PageID #: 1620
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`“patents in suit”). He is also knowledgeable about AGIS’s business, contracts and products, as
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`well as the market for those products and valuation thereof.
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`2.
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`
`
`Sandel Blackwell
`President
`Advanced Ground Information Systems, Inc.
`11900 West 87th Street Parkway
`#140
`Lenexa, KS 66215
`(913) 217-7770
`
`Mr. Blackwell the President of AGIS. He is knowledgeable about AGIS’s business,
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`contracts and products including the prototyping and implementation of the inventions described
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`and claimed in the patents in suit, as well as the market for those products.
`
`3.
`
`
`
`
`
`
`Margaret Beyer
`Corporate Secretary
`Advanced Ground Information Systems, Inc.
`92 Lighthouse Drive
`Jupiter, FL 33469
`(561) 714-3213
`
`Mrs. Beyer is the Corporate Secretary of AGIS. She is knowledgeable about AGIS’s
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`business, contracts, and products.
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`4.
`
`Keller Beyer
`System Administrator
`Advanced Ground Information Systems, Inc.
`92 Lighthouse Drive
`Jupiter, FL 33469
`(561) 714-3213
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`
`
`
`
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`Mr. Beyer is the System Administrator of AGIS. He is knowledgeable about AGIS’s
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`current and past commercial products.
`
`5.
`
`
`
`
`
`
`Ronald Wisneski
`Chief Financial Officer
`Advanced Ground Information Systems, Inc.
`c/o Wisneski & Associates, P.A.
`810 Saturn Street, Suite 30
`Jupiter, FL 33477
`
`
`
`2
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`
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 4 of 8 PageID #: 1621
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`(561) 747-2772
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`
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`Mr. Wisneski is the CFO of AGIS. He is knowledgeable about AGIS’s financial
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`information.
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`6.
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`Barry Haley, Esq.
`Malin Haley DiMaggio & Bowen, P.A.
`1936 South Andrews Avenue
`Ft. Lauderdale, FL 33316
`(954) 763-3303
`
`Mr. Haley is the attorney of record for the patents in suit. He is knowledgeable about the
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`inventions described and claimed in the patents in suit and the prosecution of the patents in suit.
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`7.
`
`Russell Rice
`PO Box 3583
`Redmond, WA 98073-3583
`(425) 381-3777
`
`Mr. Rice is the retired CTO of AGIS. He is knowledgeable about the prototyping of the
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`inventions described and claimed in the patents in suit.
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`8.
`
`Chris Hulls
`CEO
`Life360 Inc.
`539 Bryant St.
`Suite 402
`San Francisco, CA 94107
`chris@life360.com
`
`Mr. Hulls is the CEO of Life360. On information and belief, he is knowledgeable about
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`Life360’s infringement of AGIS’s patents and correspondence between AGIS and Life360.
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`9.
`
`Life360 Inc.
`539 Bryant St.
`Suite 402
`San Francisco, CA 94107
`
`
`One or more individuals at Life360 Inc. are knowledgeable about the technical
`
`specifications and operation of the Life360 smartphone software application and the use thereof
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`
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`3
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`
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 5 of 8 PageID #: 1622
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`on smartphones and tablets. One or more individuals at Life360, Inc. are also knowledgeable
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`about the market for its Life360 smartphone software application, the valuation of the software
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`and licenses in the field.
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`10.
`
`The ADT Corporation
`1501 Yamato Road
`Boca Raton, FL 33431
`
`On information and belief, one or more individuals at The ADT Corporation are
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`knowledgeable about the market for products made by Life360 and the valuation of these
`
`products and of Life360.
`
`B.
`
`Identification of Documents and Things (Fed. R. Civ. P. 26(a)(1)(A)(ii))
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
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`9.
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`10.
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`11.
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`12.
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`The ’728 patent, its prosecution history, and the references cited therein.
`
`The ’954 patent, its prosecution history, and the references cited therein.
`
`The ’441 patent, its prosecution history, and the references cited therein.
`
`The ’681 patent, its prosecution history, and the references cited therein.
`
`Documents related to the research and development of the inventions described
`and claimed in the patents in suit.
`
`Documents related to the assignment and ownership of the patents in suit.
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`Documents related to products that embody the patents in suit.
`
`Documents related to the market for products covered by the patents in suit.
`
`Documents related to the damages caused by Life360’s infringing activities.
`
`Documents related to any license agreements for products covered by the patents
`in suit.
`
`The publicly available technical specifications and documentation of the Android
`operating system and the smartphones and tablets that run the Life360 smartphone
`software application.
`
`The publicly available technical specifications and documentation of the iOS
`operating system and the smartphones and tablets that run the Life360 smartphone
`software application.
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`
`
`4
`
`
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 6 of 8 PageID #: 1623
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`13.
`
`The publicly available technical specifications and documentation of the
`Windows Phone operating system and the smartphones and tablets that run the
`Life360 smartphone software application.
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`Categories 1–10 are stored at least at the offices of Kenyon & Kenyon LLP, One
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`Broadway, New York, NY 10004; Advanced Ground Information Systems, Inc., 92 Lighthouse
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`Drive, Jupiter, FL 33469; the United States Patent and Trademark Office, Randolph Building,
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`401 Dulany Street, Alexandria, VA 22314; Life360 Inc., 539 Bryant St., Suite 402, San
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`Francisco, CA 94107; and The ADT Company, 1501 Yamato Road, Boca Raton, FL 33431.
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`C.
`
`Computation of Damages (Fed. R. Civ. P. 26(a)(1)(A)(iii))
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`As discovery has not yet commenced, damages cannot be computed at this time.
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`Computations of damages will be the subject of expert discovery in accordance with Fed. R. Civ.
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`P. 26(a)(2). AGIS seeks damages and increased damages pursuant to 35 U.S.C. § 284, as well as
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`pre and post-judgment interest, attorneys’ fees, and costs.
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`D.
`
`Insurance Agreements (Fed. R. Civ. P. 26(a)(1)(A)(iv)
`
`AGIS is not aware of any insurance agreements subject to production pursuant to Fed. R.
`
`Civ. P. 26(a)(1)(A)(iv).
`
`
`Date: July 18, 2014
`
`
`
`
`
`
`/s/ Vincent Rubino, III
`____________________________________________
`Mark A. Hannemann*
`New York Bar No. 2770709
`E-mail: mhannemann@kenyon.com
`Thomas Makin*
`New York Bar No. 3953841
`E-mail: tmakin@kenyon.com
`Matthew Berkowitz*
`New York Bar No. 4397899
`E-mail: mberkowitz@kenyon.com
`Rose Cordero Prey*
`New York Bar No. 4326591
`E-mail: rcordero@kenyon.com
`Anne Elise Li*
`
`5
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`C a s e 2 : 1 7 - c v - 0 0 5 1 3 - J R G
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` D o c u m e n t
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`New York Bar No. 4480497
`E-mail: ali@kenyon.com
`Vincent Rubino, III*
`New York Bar No. 4557435
`E-mail: vrubino@kenyon.com
`KENYON & KENYON, LLP
`One Broadway
`New York, NY 10004-1007
`Telephone:
`(212) 425-7200
`Facsimile:
`(212) 425-5288
`* admitted pro hac vice
`
`and
`Ury Fischer
`Florida Bar No. 048534
`E-mail: ufischer@lottfischer.com
`Adam Diamond
`Florida Bar No. 091008
`E-mail: adiamond@lottfischer.com
`LOTT & FISCHER, PL
`355 Alhambra Circle, Suite 1100
`Coral Gables, FL 33134
`Telephone: (305) 448-7089
`Facsimile: (305) 446-6191
`
`Attorneys for Plaintiff Advanced Ground Information
`Systems, Inc.
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`6
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`Case 2:17-cv-00513-JRG Document 74-5 Filed 01/05/18 Page 8 of 8 PageID #: 1625
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`CERTIFICATE OF SERVICE
`
`I, Vincent Rubino, hereby certify that on July 18, 2014, I caused the attached document to
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`
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`be served by email on the following person(s):
`
`Gabriel M. Ramsey
`Neel Chatterjee
`Benjamin J. Hofilena, Jr.
`James Maune
`ORRICK, HERRINGTON
`& SUTELIFFE, LLP
`2050 Main Street
`Suite 1100
`Irvine, CA 92614
`Tel: (949) 852-7721
`Email: gramsey@orrick.com
`nchatterjee@orrick.com
`bhofilena@orrick.com
`jmaune@orrick.com
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`
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`Eric Christu
`Daniel Joseph Barsky
`SHUTTS & BOWEN LLP
`525 Okeechobee Boulevard Suite 1100
`West Palm Beach, FL 33401
`Tel: (561) 650-8556
`Fax: (561) 671-5900
`Email: EChristu@shutts.com
`
`
`
`__/s/ Vincent Rubino, III__________
`Vincent Rubino, III
`
`
`
`7
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