Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 1 of 38 PageID #: 8714
`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 1 of 38 PageID #: 8714
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`
` EXHIBIT 2
`EXHIBIT 2
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 2 of 38 PageID #: 8715
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`A-1
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`
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`Remix / One mini 2 (CDMA), One S, One S C2, One S9, One SC, One ST, One SV, One SV CDMA, One V, One VX, One X, One X
`Supreme Camera, One M9s, One Max, One max (CDMA), One ME, One mini, One mini 2, One mini 2 (GSM), One Remix, One
`Sim, One E9, One E9+, One M8s, One M9, One M9 (CDMA), One M9 (GSM), One M9 Prime Camera, One M9+, One M9+
`(M8 Eye), One (M8), One (M8) (CDMA), One (M8) (GSM), One (M8) CDMA, One (M8) dual sim, One A9, One A9s, One Dual
`myTouch 3G Slide, myTouch 4G, myTouch 4G Slide, One, One (E8), One (E8) CDMA, One (M7 / CDMA), One (M7 / GSM), One
`MAX 4G, MDA Compact / xda II mini / JAM (Magician), Merge, Mogul / XV6800 / PPC6800 / P4000, myTouch 3G / Magic,
`HD7S, Hero, Hero (CDMA), Hero S, Imagio, Incredible S, Inspire 4G, J, JAMin / S200 (Prophet), Jetstream, Lead, Legend, Magic,
`Explorer, First, Flyer, Flyer Wi-Fi, Freestyle, Fuze / Touch Pro (GSM), G1, G2, Glacier, Gratia, HD mini, HD2, HD7, HD7 / HD7S,
`Evo 4G+, EVO Design 4G, EVO Design 4G / Hero S (CDMA), EVO Shift 4G, EVO V 4G / EVO 3D (CDMA), EVO View 4G,
`DROID ERIS, Droid Incredible, DROID Incredible 2, DROID Incredible 4G LTE, EVO 3D, EVO 3D CDMA, Evo 4G, Evo 4G LTE,
`Desire Q, Desire S, Desire SV, Desire U, Desire V, Desire VC, Desire VT, Desire X, Desire XC, Desire Z, Dream, DROID DNA,
`Desire 826 dual sim, Desire 828 dual sim, Desire 830, Desire C, Desire C (CDMA), Desire Eye, Desire HD, Desire L, Desire P,
`816G dual sim, Desire 820, Desire 820 dual sim, Desire 820G+ dual sim, Desire 820q dual sim, Desire 820s dual sim, Desire 825,
`630, Desire 650, Desire 700, Desire 700 dual sim, Desire 728 dual sim, Desire 728 Ultra, Desire 816, Desire 816 dual sim, Desire
`Desire 626 (GSM), Desire 626 (USA), Desire 626G+, Desire 626s, Desire 626s (CDMA), Desire 626s (GSM), Desire 628, Desire
`612, Desire 612 (CDMA), Desire 616 dual sim, Desire 620, Desire 620G dual sim, Desire 625, Desire 626, Desire 626 (CDMA),
`526G+ dual sim, Desire 530, Desire 555, Desire 600 dual sim, Desire 601, Desire 601 dual sim, Desire 610, Desire 610 (GSM), Desire
`sim, Desire 510, Desire 510 (CDMA), Desire 510 (GSM), Desire 516 dual sim, Desire 520, Desire 526, Desire 526 (CDMA), Desire
`Desire 310, Desire 310 dual sim, Desire 320, Desire 326G dual sim, Desire 400 dual sim, Desire 500, Desire 501, Desire 501 dual
`Desire / Desire 601 (CDMA), Desire 10 Compact, Desire 10 Lifestyle, Desire 10 Pro, Desire 200, Desire 210 dual sim, Desire 300,
`Butterfly 2, Butterfly 3, Butterfly S, ChaCha, Dash / S620 / S621 (Excalibur), Dash 3G / Snap (GSM), Desire, Desire (CDMA),
`8125 / 8100 / MDA (USA) / K-JAM / P4300 (Wizard), 8XT, Amaze 4G, Aria, Arrive, Arrive / 7 Pro (CDMA), Bolt, Butterfly,
`Lifestyle, 2125 / 2100 (Faraday), 3125 / Smartflip / 8500 (Star Trek), 5800 / Fusion / S720, 7 Mozart, 7 Pro, 7 Surround, 7 Trophy,
`during and after 2011. For example, the Accused Products comprise the following Android-based phones and tablets: 10, 10 evo, 10
`The Accused Products comprise HTC products running the Android mobile operating system and manufactured, used, or sold
`
`
`
`are manufactured, sold, offered for sale, and/or used by HTC Corporation (“HTC”).
`U.S. Patent No. 8,213,970 (the “’970 Patent”) identified below are infringed by the Accused Products (e.g., phones and tablets) which
`In these Infringement Contentions, AGIS Software Development LLC (“AGIS”) contends that at least the following claims of
`
`
`
`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 3 of 38 PageID #: 8716
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`A-4
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`HTC Android OS based device.
`and a touchscreen, and which are registered when a customer acquires an Accused Product, such as a
`Each “Google Account” is associated with a pre-determined number of devices, which include a CPU
`https://www.blog.google/products/android/google-play-protect/
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en;
`https://android.googleblog.com/2013/08/find-your-lost-phone-with-android.html;
`https://support.google.com/android/answer/6160491?hl=en;
`See, e.g., https://www.androidcentral.com/find-my-device;
`
`with P.R. 3-1 and for any other reason for which it may deem necessary.
`supplement these contentions to the extent that HTC requires additional information in accordance
`Device feature of the Accused Products as representative of this method. AGIS reserves the right to
`Device feature of the Accused Products as representative of this method.
`enabled on all devices,” i.e., the Accused Products running Android OS. AGIS sets forth the Find My
`AGIS sets forth the Find My
`Accused Products
`
`Claim -8,213,970
`
`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 4 of 38 PageID #: 8717
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`A-8
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`required possible responses to be selected by a participant recipient of a forced message response
`required possible responsesto be selected by a participant recipient of a forced message response
`Each Accused HTC System has a forced message alert software application program including a list of
`Each Accused HTC System has a forced message alert software application program including a list of
`allows an operator to create and transmit forced message alerts.”
`The term “a forced message alert software application program” means “application software that
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`
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`1[P], which are incorporated herein by reference in their entirety.
`phone and at least one recipient PDA/cell phone for each electronic message. See, e.g., claim 1A and
`to the performance of the participants of the predetermined network by providing a sender PDA/cell
`HTC infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
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`
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`to another Accused Product, which share a common “Google Account.”
`with cellular connections. Each claimed electronic message is sent from at least one Accused Product
`to its customers. These devices include PDA/cell phones, i.e. smartphones, tablets, and other devices
`HTC makes, uses, imports, sells or otherwise provides Android devices, such as the Accused Products,
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`
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`using software in each Accused HTC device.
`provided by Google, in cooperation with the communication interfaces, such as 3G or LTE, accessed
`The claimed data transmission means is the communication network servers, including servers
`files between said PDA/cell phones in different locations.
`Each Accused HTC System has a data transmission means that facilitates the transmission of electronic
`Structure: communications network server; and equivalents thereof.
`
`
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`locations.
`Function: facilitating the transmission of electronic files between said PDA/cell phones in different
`
`This claim term is governed by 35 U.S.C. 112(6).
`Accused Products
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`
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`to be selected by a
`required possible responses
`program including a list of
`software application
`[1C] a forced message alert
`
`each electronic message;
`recipient PDA/cell phone for
`phone and at least one
`[1B] a sender PDA/cell
`
`locations;
`phones in different
`files between said PDA/cell
`transmission of electronic
`means that facilitates the
`[1A] a data transmission
`Claim - 8,213,970
`
`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 5 of 38 PageID #: 8718
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`A-9
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`1See, e.g., https://support.google.com/android/answer/6160491?hl=en.
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`
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`described below.
`pushing or swiping the unlock button, or fingerprint recognition to unlock the phone, for example, as
`particular recipient, such as “call owner,” “emergency call,” or entering the recipient’s password,
`The forced message alert software also includes a list of required possible responses to be selected by a
`location status, responses to location requests / time since last update, and actual locations.1
`Devices provides a list of the status for each device within the same Google Account” that tracks
`other HTCdevices, such as PDA/cell phones and tablets, linked to the same Google Account. Find My
`installed feature and is downloadable as a software application that allows Android OS users to track
`transmits the forced message alerts. HTC provides the Find My Device application software as a pre-
`My Device (referred to herein collectively as “Find My Device”) application software that creates and
`The application software is the part of the Android Device Manager and later versions, such as Find
`My Device(Previously Android Device Manager)application.
`My Device(Previously Android Device Manager)application.
`on the Accused HTC device that initiates and/or receives a forced message alert, for example, the Find
`on the Accused HTC device that initiatesand/or receives a forced message alert, for example, the Find
`The claimed forced message alert software application program is the application program executing
`The claimed forced message alert software application program is the application program executing
`loaded on each participating PDA/cell phone.
`loaded on each participating PDA/cell phone.
`Accused Products
`
`PDA/cell phone;
`loaded on each participating
`forced message response
`participant recipient of a
`Claim -8,213,970
`
`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 6 of 38 PageID #: 8719
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`A-11
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`https://www.androidcentral.com/how-track-android-phone
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`
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`Accused Products
`
`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 7 of 38 PageID #: 8720
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`A-12
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`https://www.androidcentral.com/find-my-device
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`
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`
`
`Accused Products
`
`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 8 of 38 PageID #: 8721
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`A-13
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`https://www.androidcentral.com/find-my-device
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`
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`Accused Products
`
`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 9 of 38 PageID #: 8722
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`A-14
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`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en
`
`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
`
`Accused Products
`
`Claim - 8,213,970
`
`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 10 of 38 PageID #: 8723
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`A-16
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`consist of choices such as, “will comply,” “will not comply,” and “have complied.” However,
`operator selects from the required response list. A military default response list would typically
`list. If the alert is a voice message, the message keeps repeating at a defined rate until the user
`operator's PC or PDA/cell phone display, the user operator is required to select a reply from this
`with the required response list. In order to clear the forced text message alert from the user
`forced message. When the forced text or voice alert is received, the user operator is presented
`sent with the forced message alert will be presented to the user operator upon receipt of the
`A required response list which will be either preinstalled in the phone application software or
`
`user or administrator predefined list of network participants.
`and/or PDA/cell phone, b.) The list of users currently participating in the network, and c.) A
`message that can be designated for transmission according to several criteria: a.) A single PC
`on a plurality of PCs and/or PDA/cell phones. The application will provide for a forced alert
`message alert system, the forced message alert software application program must be installed
`Referring now toFIG. 2, in order to set up a communication network that utilizes the forced
`
`The algorithm required by the Court’s construction is set forth in the specification at:
`more communication network servers via a modem interface, such as a 3G or LTE modem).
`The packet is delivered via TCP/IP orother protocols (including HTC’s specific protocols via one or
`Device App displays “lock requested” and then “locked” and “secured.”
`Device App displays “lock requested” and then “locked” and “secured.”
`This automatic acknowledgement is shown to the Sender when the Find My
`the recipients location. This automatic acknowledgement is shown to the Sender when the Find My
`acknowledgement which confirms that the device is in lock mode (also called “secured”) and provides
`The sender device sends a request and in response, the receiver device sends an automatic
`receipt of the message andthus the message is “forced.”
`Accused Devices. Because this is a security feature, the recipient phones have no control over the
`The Sender electronically transmits the message to the Receiver through the use of the software on the
`tracks location status, response to location requests / time since last update, and actual locations.
`linked to the same Google Account. Find My Device provides a list of the status for eachdevice that
`HTC’s Find My Device feature allows Android OS users to track other phones, tablets, and computers
`servers.
`Accused Products
`
`Claim -8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 11 of 38 PageID #: 8724
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`A-19
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`PDA/cell phone” such as the lost phone from a listing of devices.
`Find My Device, as set forth in the example use-case below, can designate a “single PC and/or
`Accused Devices.
`Device running the Find My Device code via the Chrome browser, which also is preinstalled on the
`ability to view other devices on a map and to lock those devices is provided by the HTC Accused
`component of Google Play Protect. (Previously called Android Device Manager). Additionally, the
`wiping, playing a sound, or displaying a message, comes pre-loaded on Android OS devices as a
`words, Find My Device functionality that allows other devices to control the smartphone by locking,
`program (i.e. Find My Device)
`program (i.e. Find My Device) is installed on a plurality of PCs and/or PDA/cell phones. In other
`Regarding this first portion of the required algorithm, the forced message alert softwareapplication
`Regarding this first portion of the required algorithm,the forced message alert softwareapplication
`
`user or administrator predefined list of network participants.
`
`Accused Products
`
`Claim -8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 12 of 38 PageID #: 8725
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`A-20
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`response list. A military default response list would typically consist of choices such as, “will comply,”
`message, the message keeps repeating at a defined rate until the user operator selects from the required
`phone display, the user operator is required to select a reply from this list. If the alert is a voice
`response list. In order to clear the forced text message alert from the user operator's PC or PDA/cell
`When the forced text or voice alert is received, the user operator is presented with the required
`the forced message alert will be presented to the user operator upon receipt of the forced message.
`A required response list which will be either preinstalled in the phone application software or sent with
`
`Regarding the next portion of the algorithm:
`See Screenshot_20181207-123836.png.
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`
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
`
`
`
`Accused Products
`
`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 13 of 38 PageID #: 8726
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`A-23
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`Regarding the next portion of the algorithm,
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`
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`See Screenshot_20181202-015322.png and Screenshot_20181207-131050.png.
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`
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`captures below:
`no longer displayed. Further evidence of the communication of this content is indicated in the screen
`the initiator device. Once the device has been unlocked, it exits lock mode and the lock mode screen is
`home button, a message with the content “sound stopped” is transmitted to the server and ultimately to
`stating that the sound is playing is depicted on the sender-device. When the target device touches the
`Accused Products
`
`Claim - 8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 14 of 38 PageID #: 8727
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`A-24
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`The first step in utilizing the Find My Device functionality is to select the forced message alert
`The first step in utilizing the Find My Device functionality is to select the forced message alert
`
`communications network.
`a server whose function is to retransmit the messages to the correct users in the
`PC or PDA/cell phone designated to receive the forced message alert either directly or through
`forced alert message is then transmitted via TCP/IP or other digital transmission means to every
`select can either be included in the forced alert message or be preloaded in each phone. The
`predefined list ofnetwork participants. The response list from which the message receiver must
`The current PC or PDA/cell phone network participants or c.) A user or administrator
`switch or selection from a list to send the forced alert to: a.) Another network participant, b.)
`or selects a voice or text message on said PC or PDA/cell phone, the sender can then use a soft
`alert or voice alert from a list. Once the sender types a text message or records a voice message
`sender PC or PDA/cell phone to type a text message or record a voice message or select the text
`application program on a sender PC or PDA/cell phone. The sender canthen select by said
`PC or PDA/cell phone begins with a sender selecting the forced message alert software
`Referring now toFIG. 3AandFIG. 3B, the process of sending a forced message alert from a
`
`Regarding the next portion of the algorithm:
`software itself.
`Accordingly, the devices are preconfigured to perform these algorithmic steps, which are built into the
`are displayed on the Find My Device display.
`Google account, the devices that are members of the communications network, i.e.,the linked devices,
`Each Android OS device is preloaded with Find My Device. Once configured and associated with a
`
`password can join the network, the default list is created or expanded as new members join.
`communication network. When operating in an open network mode where all that know the
`information to send a forced message alert to any and every known member of the
`user of the communication network has, in addition to the necessary software, the necessary
`member PC and PDA/cell phone in the preferred embodiment. This step makes sure the each
`be a member of the communication network and the default response list is loaded on to every
`The contact and identifying information for each PC and PDA/cell phone that is anticipated to
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
`
`Accused Products
`
`Claim -8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 15 of 38 PageID #: 8728
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`A-25
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`Find My Device App as depicted in the figures below.
`send the alert to (at least) one other network participant. These steps are accomplished by utilizing the
`The next two steps are to optionally compose the lock screen message and return phone number, and to
`App by selecting the icon.
`App by selecting the icon.
`software application program on the sender PC or PDA/cell phone, i.e.tolaunch the Find My Device
`software application program on the sender PC or PDA/cell phone, i.e.tolaunch the Find My Device
`Accused Products
`
`Claim -8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 16 of 38 PageID #: 8729
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`A-26
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`correct users in the communications network.,” all Find My Device messages are transmitted via
`message alert either directly or through a server whose function is to retransmit the messages to the
`other digital transmission means to every PC or PDA/cell phone designated to receive the forced
`Regarding the next step of the algorithm, “The forced alert message is then transmitted via TCP/IP or
`
`See Screenshot_20181202-000717.png.
`
`
`
`
`
`See Screenshot_20181207-131144.png.
`Accused Products
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`Claim - 8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 17 of 38 PageID #: 8730
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`A-29
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 18 of 38 PageID #: 8731
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`A-30
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`integrated PDA/cell phone and PC.
`or PDA/cell phone displays an indication of the response from each recipient cell phone,
`message. As these electronic transmissions with manual responses are received, the sender PC
`manual responses to the forced message alert from the PC or PDA/cell phone that received the
`The sender PC or PDA/cell phone also monitors for and receives electronic transmissions with
`
`Finally, regarding the remaining portion of the algorithm:
`
`
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 19 of 38 PageID #: 8732
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`A-34
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`responsive action is taken.)
`substantially the same result (the lost message or sound is conveyed to the receiver phone and
`unusable, or repeating a sound, until one of the required manual actions is performed) to achieve
`(alerting the receiver device) in substantially the same way (locking the phone and making it otherwise
`responses are at least the equivalent of a required response because they perform the same function
`responses as shown above in claim 1[C]. To the extent this limitation is not literally met, each of these
`The forced message alert software packet from the sender device contains a list of possible required
`requested” and then “locked.”
`requested” and then “locked.”
`This automatic acknowledgement is shown to theSender when the Find My Device App states, “lock
`This automatic acknowledgement is shown to the Sender when the Find My Device App states, “lock
`acknowledgement which confirms that the device is in lock mode and provides the recipients location.
`The sender device sends a request and in response, the receiver device sends an automatic
`call the sender.
`Accused Products
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`Claim -8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 20 of 38 PageID #: 8733
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`A-35
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 21 of 38 PageID #: 8734
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`A-36
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 22 of 38 PageID #: 8735
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`A-41
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`Additionally, lock mode cannot be disabled on the recipient device without entering the password.
`message is conveyed to the receiver phone and responsive action is taken.)
`until one of the required manual actions is performed) to achieve substantially the same result (the lost
`receiver device) in substantially the same way (locking the phone and making it otherwise unusable
`at least the equivalent of a required response because they perform the same function (alerting the
`responses as shown above. To the extent this limitation is not literally met, each of these responses are
`The forced message alert software packet from the sender device contains a list of possible required
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`
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 23 of 38 PageID #: 8736
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`A-44
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`automatically acknowledged the forced message (e.g., entering lock mode and providing updates on
`Each of the Accused HTC devices includes a display that can display which devices have
`
`LG’s Find My Device App implements these functionalities for Android devices.
`
`
`
`See Screenshot_20181202-000411.png.
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`

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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 24 of 38 PageID #: 8737
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`A-45
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`[1H] means for periodically This claim term is governed by 35 U.S.C. 112(6).
`
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`was captured.
`alert software application displays the last known location and the time that the last known location
`of a communication link, or if the device location is not available for some reason, the forced message
`automatically acknowledge the forced message, for example, if the device is turned off or not in range
`receiver location, battery, and network connectivity.) For Accused HTC devices that are unable to
`Accused Products
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`Claim - 8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 25 of 38 PageID #: 8738
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`4. The system as in claim 1, HTC infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
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`A-48
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`See Claim [1A] above.
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`1, which is incorporated herein by reference in its entirety.
`wherein said data transmission means is TCP/IP or another communications protocol. See, e.g., claim
`to the performance of the participants of the predetermined network to perform operations comprising
`HTC infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
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`communications protocol.
`TCP/IP or another
`transmission means is
`wherein said data
`3. The system as in claim 1,
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`transmitted a manual response (e.g., calling back or sending a text message to the sender device.)
`Accused Products
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`Claim - 8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 26 of 38 PageID #: 8739
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`A-49
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`claim 1, which is incorporated herein by reference in its entirety.
`response list that is embedded in the forced message alert software application program. See, e.g.,
`wherein the response list that is transmitted within the forced message alert software packet is a default
`to the performance of the participants of the predetermined network to perform operations comprising
`Accused Products
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`recognition to unlock the phone. As shown below, messages and call back number are “optional.”
`Default options include “emergency call,” or pushing or swiping or swiping to unlock or fingerprint
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`See Claim [1F] above.
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`application program.
`message alert software
`embedded in the forced
`response list that is
`software packet is a default
`forced message alert
`that is transmitted within the
`wherein the response list
`Claim - 8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 27 of 38 PageID #: 8740
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`A-51
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`device-location tracking features as provided in the claims limitations herein. For example, the
`because they are pre-installed with Android mobile operating systems containing code for providing
`as those features described below. For example, the Accused Products meet the claim limitations
`The Accused Products meet the claim limitations by providing device-location tracking features such
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`
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`herein by reference in its entirety.
`performance of each step of this method as set forth below. See, e.g., claim 1, which is incorporated
`HTC performs either directly or indirectly, induces others to perform, and/or contributes to the
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`response to said forced
`wherein the receipt and
`communication network,
`predetermined
`phones within a
`or more recipient PDA/cell
`a forced message alert to one
`6[A]. A method of sending
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 28 of 38 PageID #: 8741
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`A-56
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`2See, e.g., https://support.google.com/android/answer/6160491?hl=en.
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`location requests / time since last update, and actual locations.
`location requests / time since last update, and actual locations.2
`of the status for each device within the same Google Account” that tracks location status, responses to
`of the status for each device within the same Google Account” that tracks location status, responses to
`as PDA/cell phones and tablets, linked to the same Google Account. Find My Devices provides a list
`as PDA/cell phones and tablets, linked to the same Google Account. Find My Devices provides a list
`downloadable as a software application that allows Android OS users to track other HTCdevices, such
`downloadable as a software application that allows Android OS users to track other HTCdevices, such
`HTC’s Find My Device software application, which HTCprovides as a pre-installed feature, is also
`HTC’s Find My Device software application, whichHTCprovidesas a pre-installed feature, is also
`been selected by a user for execution.
`the forced message application program by the Android operating system when the application has
`The claimed step of accessing a forced message alert software application program is the initiation of
`program on a sender PDA/cell phone.
`Each Accused HTC device performs the step of accessing a forced message alert software application
`allows an operator to create and transmit forced message alerts.”
`The term “a forced message alert software application program” means “application software that
`Accused Products
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`sender PDA/cell phone;
`application program on a
`message alert software
`6[B] accessing a forced
`Claim -8,213,970
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 29 of 38 PageID #: 8742
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`reference in their entirety.
`packet to said voice or text message. See, e.g., claims 1 and 6[B], which are incorporated herein by
`PDA/cell phone by attaching a voice or text message to a forced message alert application software
`to the performance of steps of the method comprising: creating the forced message alert on said sender
`HTC infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
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`sound, lock mode, or erase phone and following any necessary prompts.
`For example, this limitation is met when a user of the Accused Products chooses form the options play
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`message;
`to said voice or text
`application software packet
`forced message alert
`a voice or text message to a
`PDA/cell phone by attaching
`message alert on said sender
`6[C] creating the forced
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 30 of 38 PageID #: 8743
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`(sound) with substantially the same result (the user alerted as to the forced message).
`substantially the same function (alerting users of a forced message alert) in substantially the same way
`limitation of voice. Furthermore, “play sound” is the equivalent of voice, because it performs
`To the extent this claim is construed to require both voice and text, play sound literally meets the
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`message packet, because the sound is played on the recipient phone automatically without the
`back number and a message). The play sound option also triggers the creation and sending of a forced
`Entering lock mode creates a forced message alert packet including textual messages (e.g., the call-
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`Exhibit A for US Patent No. 8,213,970 Against HTC Accused Products
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`Accused Products
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`Claim - 8,213,970
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`Case 2:17-cv-00514-JRG Document 125-4 Filed 01/28/19 Page 31 of 38 PageID #: 8744
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`reference in their entirety.
`alert to said recipient PDA/cell phones. See, e.g., claims 1 and 6[D], which are incorporated herein by
`to the performance of steps of the me