Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 1 of 37 PageID #: 21208
`Case 2:17-cv-00514—JRG Document 267-2 Filed 03/04/19 Page 1 of 37 PageID #: 21208
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 2 of 37 PageID #: 21209
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`In these Infringement Contentions, AGIS Software Development LLC (“AGIS”) contends that at least the following claims of
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`U.S. Patent No. 8,213,970 (the “’970 Patent”) identified below are infringed by the Accused Products (e.g., phones and tablets) which
`are manufactured, sold, offered for sale, and/or used by LG Electronics, Inc. (“LG”).
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`The Accused Products comprise LG products running the Android mobile operating system and manufactured, used, or sold
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`during and after 2011. For example, the Accused Products comprise the following Android-based phones: V30 (H931, LS998U,
`H932, H932U, VS996, US998, AS998), X charge (US601, SP320, M327, M322), Q6 (US700), G6+ (US997U), G6 (US997, VS988,
`AS993, H871, H872, LS993), Fiesta 2 (L173BL, L164VL), V20 (LS997, H910, H918, US996, VS995), X venture (US701, H700),
`Stylo 3 (LS777), Stylo 3 Plus (MP450, TP450), Tribute HD (LS676), Rebel 2 (L57BL, L58BL, L58VL), Fiesta LTE (L63BL,
`L64VL), Stylo 3 LTE (L83BL, L84VL), K20 plus (MP260, TP260), Grace LTE (L59BL), K3 (AS110, US110, LS450), Stylo 3
`(LS777, M430), Phoenix 3 (M150), Risio 2 (M154), K8 2017 (US215), Stylo 2 V (VS835), K20 (M255, RS501), K20 V (VS501),
`Aristo (M210), Harmony (M257), G5 (VS987, AS992, H820, H830, LS992, RS988, US992), Aristo Silver (MS210), Aristo Cobalt
`Blue (MS210UK), Stylo 2 Plus (MS550BK, K550), Fortune (M153), Tribute HD (LS676), X power (K212, K450, LS755, US610),
`K10 (MS428, K425, K428SG), Stylo 2 (LS775, K540), G Vista (VS880), Escape 3 (K373), Classic (L18VC), Rebel LTE (L43AL,
`L44VL), Treasure LTE (L51AL, L52VL), Premier LTE (L61AL, L62VL), Stylo 2 LTE (L82VL), K7 (MS330, AS375, K330), K8
`(RS500, US375), G4 (US991), K4 (VS425), Optimus Zone 3 (VS425PP), K8 V (VS500, VS500PP), Phoenix 2 (K371), Tribute 5
`(LS675), Spree (K120), G Vista 2 (H740), Escape 2 (H443), Risio (H343), Access LTE (L31L), Leon LTE (H345, MS345), G Stylo
`(H631, MS631, H634, LS770), Volt 2 (LS751), Tribute 2 (LS665), Escape 2 (H445), Logos (US550), Transpyre (VS810PP), G3
`(D850, LS990, D851, AS985, VS985, AS990, US990), Ultimate 2 (L41C), Tribute (LS660), G3 Vigor (D725), Realm (LS620), G
`Vista (D631), Volt (LS740), Optimus Fuel (L34C), Optimus L90 (D415), Optimus F3Q (D520), D820 (D820), G2 (VS9801, D800,
`D801, LS980), Optimus F6 (D500), Enact (VS890), Optimus F3 (VM720, LS720), Rumor Reflex S (LN272S), Optimus F7 (LG870,
`US780), Optimus F5 (AS870), Optimus G Pro (E980), Lucid2 (VS870), Spirit 3G (MS870), LGE960 (LGE960), Optimus REGARD
`(LW770), Mach (LS860), Optimus G (LS970, E970), Optimus L9 (P769), Venice (LG730), Escape (P870), Spectrum 2 (VS930),
`Splendor (US730), Intuition (VS950), Motion 4 (MS770), Optimus Plus (AS695), Elite (LS696), Viper (LS840), Optimus M+
`(MS695), Lucid (VS840), Nitro (P930), Spectrum (VS920), Marquee (LG855), Connect 4G(MS830), Optimus Q (LGL55C), Optimus
`2 (AS680), Ignite (AS855), myTouch Q (LGC800DG, LGC800VL), Optimus One (P504), myTouch (LGE739BK), DoublePlay
`(C729), Optimus Slider (VM701), Esteem (MS910), Enlighten (VS700), Marquee (LS855), Thrill 4G (P925), Revolution (VS910),
`Genesis (US760), G2x (P999), Thrive (P506), Phoenix (P505), Optimus C (LW690), Optimus V (WM670), Optimus U (US670),
`Optimus M (MS690), Axis (LGAS740), Apex (US740), Vortex (VS660), Optimus S (LS670), Ally (VS740), and Optimus T (P509).
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`A-1
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 3 of 37 PageID #: 21210
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`AGIS reserves the right to amend this list of accused phones as discovery progresses. For example, the Accused Products comprise
`the following Android-based tablets: G Pad F2 8.0 (LK460), G Pad X II 8.0 Plus (V530), G Pad X II 10.1 (UK750), G Pad F 8.0 2nd
`Gen (AK495, UK495), G Pad X 8.0 (V520, V521), G Pad II 10.1 Full HD (V940N), G Pad X 10.1 (V930), G Pad II 8.0 HD+ (V498),
`G Pad 8.0 (V480), G Pad 10.1 (V700), G Pad 7.0 (V400), G Pad F 8.0 1st Gen (AK495, V495, V496, UK495), G Pad X 8.3 (VK815,
`VK810), G Pad F 7.0 (LK430), G Pad 7.0 LTE (VK410, UK410, V410), G Pad 10.1 LTE (VK700), G Pad 8.3 Google Play Edition
`(V510), G Pad 8.3 Black (V500). AGIS reserves the right to amend this list of accused tablets as discovery progresses. For example,
`the Accused Products comprise LG products, including but not limited to the phones and tablets as described herein, running the
`following versions (and all intervening updates and sub-versions) of the Android mobile operating system: Android 2.3, 4.0, 4.1, 4.2,
`4.3, 4.4, 5.0, 5.1, 6.0, 7.0, 7.1, 8.0, and 8.1. For example, the Accused Products comprise LG products, including but not limited to the
`phones and tablets as described herein, running any versions of the following Android-based applications and/or software: Android
`Device Manager, Find My Phone, Find My Device, Google Latitude, Google Plus, Google Hangouts, Google Maps, Google Assistant,
`Google Search, Google Messages, Android Messenger, Google Allo, Google Duo, GMail, and Google Chrome. For example, the
`Accused Products comprise LG products, including but not limited to the phones and tablets described herein, participating in any
`networks and/or services related to the execution and/or use of the Android mobile operating system versions and Android-based
`applications and/or software described herein.
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`AGIS does not concede that any claims of the ’970 Patent that are not listed below are not infringed by the identified products.
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`Moreover, the citations to certain documents and other information below are intended to be exemplary only and in no way foreclose
`AGIS from citing or relying on additional documents, information, source code, and/or testimony at a later time. These contentions
`are preliminary in nature, and an analysis of LG’s products, internal documentation, source code, and/or testimony from relevant
`witnesses may more fully and accurately describe the infringing features of its accused products. Accordingly, AGIS reserves the
`right to supplement, correct, modify, and/or amend these contentions once such additional information is made available to AGIS.
`Furthermore, AGIS reserves the right to supplement, correct, modify, and/or amend these contentions as discovery in this case
`progresses; in view of the Court’s claim construction order(s); in view of any positions taken by LG, including but not limited to
`positions on claim construction, invalidity, and/or non-infringement; and in connection with the preparation and exchange of expert
`reports.
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`A-2
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 4 of 37 PageID #: 21211
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`Claim
`1[P]. A communication system for
`transmitting, receiving, confirming
`receipt, and responding to an
`electronic message, comprising: a
`predetermined network of
`participants, wherein each participant
`has a similarly equipped PDA/cell
`phone that includes a CPU and a
`touch screen display a CPU and
`memory;
`
`Accused Products
`The Accused Products together constitute a “communication system” for transmitting,
`receiving, confirming receipt, and responding to an electronic message, comprising: a
`predetermined network of participants, wherein each participant has a similarly equipped
`PDA/cell phone that includes a CPU and a touch screen display, a CPU, and memory.
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`LG makes, uses, sells, and otherwise provides this communication system by making, using,
`selling, and importing Android OS devices such as Accused Products.
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`The Accused Products meet the claim limitations by providing device-location tracking
`features such as those features described below. For example, the Accused Products meet the
`claim limitations because they are pre-installed with Android mobile operating systems
`containing code for providing device-location tracking features as provided in the claims
`limitations herein. For example, the Accused Products run applications and/or software that
`run within the Android mobile operating system and that use components of the Android
`mobile operating system to provide device-location tracking features. Upon information and
`belief, in addition to the components and features of the Android mobile operating system
`itself, the following applications and/or software run within the Android mobile operating
`system and use components of the Android mobile operating system to provide device-
`location tracking features: Android Device Manager, Find My Device.
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`Android Device Manager is the predecessor to Find My Device and has been available as a
`standard, pre-installed feature since 2013 and downloadable as a software application. The
`current iteration, Find My Device, often called the “new and improved Android Device
`Manager” or “rebranded Android Device Manager” is now part of the standard Google Play
`Protect suite which is “built in and enabled on all devices,” i.e., the Accused Products running
`Android OS. AGIS sets forth the Find My Device feature of the Accused Products as
`representative of this method. AGIS reserves the right to supplement these contentions to the
`extent that LG requires additional information in accordance with P.R. 3-1 and for any other
`reason for which it may deem necessary.
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`A-3
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 5 of 37 PageID #: 21212
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`See, e.g., https://www.androidcentral.com/find-my-device;
`https://support.google.com/android/answer/6160491?hl=en;
`https://android.googleblog.com/2013/08/find-your-lost-phone-with-android.html;
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en;
`https://www.blog.google/products/android/google-play-protect/
`Each “Google Account” is associated with a pre-determined number of devices, which include
`a CPU and a touchscreen, and which are registered when a customer acquires an Accused
`Product, such as a LG Android OS based device.
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`A-4
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 6 of 37 PageID #: 21213
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`https://support.google.com/websearch/answer/6128427
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`A-5
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 7 of 37 PageID #: 21214
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`https://support.google.com/websearch/answer/6128427
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`A-6
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 8 of 37 PageID #: 21215
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`[1A] a data transmission means that
`facilitates the transmission of
`electronic files between said
`PDA/cell phones in different
`locations;
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`[1B] a sender PDA/cell phone and at
`least one recipient PDA/cell phone
`for each electronic message;
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`[1C] a forced message alert software
`application program including a list
`of required possible responses to be
`selected by a participant recipient of
`a forced message response loaded on
`each participating PDA/cell phone;
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`This claim term is governed by 35 U.S.C. 112(6).
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`Function: facilitating the transmission of electronic files between said PDA/cell phones in
`different locations.
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`Structure: Communications network server; Communication network interfaces ’970 Patent at
`1:39-43; 2:36-43; Figs. 2, 3A, 3B, and 4.
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`The Accused Products meet this limitation. LG provides access to one or more
`communication network servers via a modem interface such as a 3G or LTE modem.
`LG makes, uses, imports, sells or otherwise provides Android devices, such as the Accused
`Products, to its customers. These devices include PDA/cell phones, i.e. smartphones, tablets,
`and other devices with cellular connections. Each claimed electronic message is sent from at
`least one Accused Product to another Accused Product, which share a common “Google
`Account.”
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`See claim 1[P]
`LG makes, uses, imports, sells, or otherwise provides a forced message alert software
`application program including a list of required possible responses to be selected by a
`participant recipient of a forced message response loaded on each participating PDA/cell
`phone.
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`For example, LG’s Find My Device software application, which LG provides as a pre-installed
`feature and a downloadable as a software application allows Android OS users to track other
`LG devices, such as PDA/cell phones and tablets, linked to the same Google Account. Find
`My Devices provides a list of the status for each device within the same Google Account” that
`tracks location status, responses to location requests / time since last update, and actual
`locations.
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`A-7
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 9 of 37 PageID #: 21216
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`https://support.google.com/android/answer/6160491?hl=en
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`The forced message alert software includes with it a list of required possible responses to be
`selected by a particular recipient, such as “call owner,” “emergency call,” or entering the
`recipients password, pushing or swiping the unlock button, or fingerprint recognition to unlock
`the phone.
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`A-8
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 10 of 37 PageID #: 21217
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`[1D] means for attaching a forced
`message alert software packet to a
`voice or text message creating a
`forced message alert that is
`transmitted by said sender PDA/cell
`phone to the recipient PDA/cell
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`Each of the Accused Products includes or provides support for a means for attaching a forced
`message alert software packet to a voice or text message creating a forced message alert that is
`transmitted by said sender PDA/cell phone to the recipient PDA/cell phone.
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`This claim term is governed by 35 U.S.C. 112(6).
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`A-9
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 11 of 37 PageID #: 21218
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`phone,
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`[1E]said forced message alert
`software packet containing a list of
`possible required responses and
`requiring the forced message alert
`software on said recipient PDA/cell
`phone to transmit an automatic
`acknowledgment to the sender
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`Function: attaching a forced message alert software packet to a voice or text message creating
`a forced message alert that is transmitted by said sender PDA/cell phone to the recipient
`PDA/cell phone.
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`Structure: Algorithm set forth in Fig 2, 3A, 3B. 7:8-63.
`
`LG’s Find My Device feature allows Android OS users to track other phones, tablets, and
`computers linked to the same Google Account. Find My Device provides a list of the status for
`each device that tracks location status, response to location requests / time since last update,
`and actual locations.
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`The Sender electronically transmits the message to the Receiver through the use of the
`Accused Products. Because this is a security feature, the recipient phones have no control over
`the receipt of the message and thus the message is “forced.”
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`The forced message alert causes automatic responses as shown in the response list in 1[C]
`above.
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`This claim is literally met by one or more TCP/IP or other protocol packets (including LG’s
`specific protocols via one or more communication network servers via a modem interface such
`as a 3G or LTE modem.. To the extent that the claims literally cover only a single packet, the
`limitation would still be met under the doctrine of equivalents. One of ordinary skill in the art
`would readily appreciate that packetized communications can be subdivided into multiple
`packet-sizes. These packets may be further subdivided in order to pass over different network
`layers. Thus, this limitation is equivalently met by packetized communication transmitting a
`forced message.
`Each of the Accused Products includes or provides support for the Find My Device capability,
`which includes forced message alert packets as set forth above in 1[D]. Furthermore, these
`packets contain a list of possible required responses and requiring the forced message alert
`software on said recipient PDA/cell phone to transmit an automatic acknowledge to the sender
`PDA/cell phone as soon as said forced message alert is received by the recipient PDA/cell
`phone.
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`A-10
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 12 of 37 PageID #: 21219
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`PDA/cell phone as soon as said
`forced message alert is received by
`the recipient PDA/cell phone;
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`Touching the “lock” button electronically transmits the message. Because this is a security
`feature, the recipient phones have no control over the receipt of the message and thus is
`“forced.” To enter lock mode, the sender attaches a phone number and message. Once the
`forced message is received by the recipient, an automatic acknowledgement is displayed by
`the sender cell phone (stating that the recipient’s phone is “locked.” At least the phone
`number constitutes a list of required responses, i.e. to call the sender.
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`The sender device sends a request and in response, the receiver device sends an automatic
`acknowledgement which confirms that the device is in lock mode and provides the recipients
`location. This automatic acknowledgement is shown to the Sender when the Find My Device
`App states “lock requested” and then “locked.”
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`A-11
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 13 of 37 PageID #: 21220
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`The forced message alert software packet from the sender device contains a list of possible
`required responses as shown above in claim 1[C]. To the extent this limitation is not literally
`met, each of these responses are at least the equivalent of a required response because they
`perform the same function (alerting the receiver device) in substantially the same way (locking
`the phone and making it otherwise unusable until one of the required manual actions is
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`A-12
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 14 of 37 PageID #: 21221
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`[1F] means for requiring a required
`manual response from the response
`list by the recipient in order to clear
`recipient's response list from
`recipient's cell phone display;
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`[1G] means for receiving and
`displaying a listing of which
`recipient PDA/cell phones have
`automatically acknowledged the
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`performed) to achieve substantially the same result (the lost message is conveyed to the
`receiver phone and responsive action is taken.)
`Each of the Accused Products has a means for requiring manual response from the response
`list by the recipient in order to clear recipient’s response list from recipient’s cell phone
`display.
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`This claim is governed by 35 U.S.C. 112(6).
`
`Function: requiring a required manual response from the response list by the recipient in order
`to clear recipient’s response list from recipient’s cell phone display.
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`Structure: Algorithm set forth in Figure 4 and 8:16-57; 11:1-21.
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`This algorithm is implemented in software provided by LG on the recipient phone device.
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`Additionally, lock mode cannot be disabled on the recipient device without entering the
`password. Furthermore, a locked device may also be able to receive phone calls, but receiving
`a phone call does not affect this limitation and the phone remains otherwise locked.
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`As set forth above in claim 1[C], required responses incorporated into LG’s software used in
`the Accused Products include “call owner,” “emergency call,” or the unlock button which
`requires entering the recipient’s password, pushing or swiping the unlock button, or fingerprint
`recognition to unlock the phone. Each of these responses is a required response because the
`receiver device is otherwise inoperable unless these responses are selected. To the extent this
`limitation is not literally met, each of these responses are at least the equivalent of a required
`response because they perform the same function (alerting the receiver device) in substantially
`the same way (locking the phone and making it otherwise unusable until one of the required
`manual actions is performed) to achieve substantially the same result (the lost message is
`converted to the receiver phone and responsive action is taken.
`Each of the Accused Products include a means for receiving and displaying a listing for which
`recipient PDA/cell phones have automatically acknowledged the forced message alert and
`which recipient PDA/cell phones have not automatically acknowledged the forced message
`alert.
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`A-13
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 15 of 37 PageID #: 21222
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`forced message alert and which
`recipient PDA/cell phones have not
`automatically acknowledged the
`forced message alert;
`
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`This claim is governed by 35 U.S.C. 112(6).
`
`Function: receiving and displaying a listing of which recipient PDA/cell phones have
`automatically acknowledged the forced message alert and which recipient PDA/cell phones
`have not automatically acknowledged the forced message alert.
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`Structure: PDA/cell phone hardware including touch screen 16, and wireless transmitter or
`cellular modem. ’970 Patent at col. 4:12-46.1
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`Each of the Accused Products includes a display that can display which devices have
`automatically acknowledged the forced message (e.g. entering lock mode and providing
`updates on receiver location, battery, and network connectivity.)
`
`
`1 In the alternative, to the extent that LG may allege that this implementation is software-implemented, the structure for such display
`software is set forth in the algorithms in Figures 2, 3A, 3B, 6:38-7:4; 7:17-8:15.
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`A-14
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 16 of 37 PageID #: 21223
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`[1H] means for periodically
`resending said forced message alert
`to said recipient PDA/cell phones
`that have not automatically
`acknowledged the forced message
`alert;
`
`
`Each Accused Product includes a means for periodically resending said forced message alert
`to said recipient PDA/cell phones that have not automatically acknowledged the forced
`message alert.
`
`This claim term is governed by 35 U.S.C. 112(6).
`
`Function: periodically resending said forced message alert to said recipient PDA/cell phones
`that have not automatically acknowledged the forced message alert.
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`A-15
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 17 of 37 PageID #: 21224
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`Structure: PDA/cell phone hardware including a wireless transmitter or cellular modem. ’970
`Patent at col. 4:12-46.
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`This limitation is met by the cellular or wireless connectivity of each Accused Product, which
`periodically resend forced message alerts to the recipient phone. For example, the device will
`display the “Lock requested” message but will not display “locked” message until the second
`device has been locked. The periodic resending of the message is demonstrated when a lock is
`requested while the second device does not have a data connection. The “locked” message
`will only display after the second device’s data connection has been restored, demonstrating
`that the lock message is resent periodically to PDA/cell phones that have not automatically
`acknowledged the forced message alert.
`LG uses a means for receiving and displaying a listing of which recipient PDA/cell phones
`have transmitted a manual response to said forced message alert and details the response from
`each recipient PDA/cell phone that responded.
`
`This claim term is governed by 35 U.S.C. 112(6).
`
`Function: receiving and displaying a listing of which recipient PDA/cell phones have
`transmitted a manual response to said forced message alert and details the response from each
`recipient PDA/cell phone that has responded.
`
`Structure: PDA/cell phone hardware including touch screen 16, and wireless transmitter or
`cellular modem. ’970 Patent at col. 4:12-46.2
`
`Each of the Accused Products includes a display that can display which recipient devices have
`transmitted a manual response (e.g., calling back or sending a text message to the sender
`device.)
`Each Accused Product transmits information over a TCP/IP connection.
`
`
`[1I] and means for receiving and
`displaying a listing of which
`recipient PDA/cell phones have
`transmitted a manual response to said
`forced message alert and details the
`response from each recipient
`PDA/cell phone that responded.
`
`3. The system as in claim 1, wherein
`said data transmission means is
`
`
`2 In the alternative, to the extent that LG may allege that this implementation is software-implemented, the structure for such display
`software is set forth in the algorithms in Figures 2, 3A, 3B, 6:38-7:4; 7:17-8:15.
`
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`A-16
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 18 of 37 PageID #: 21225
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`TCP/IP or another communications
`protocol.
`4. The system as in claim 1, wherein
`the response list that is transmitted
`within the forced message alert
`software packet is a default response
`list that is embedded in the forced
`message alert software application
`program.
`
`
`See Claim [1A] above.
`Each Accused Product includes a response list that is transmitted within the forced message
`alert software packet is a default response list that is embedded in the forced message alert
`software application program.
`
`See Claim [1F] above.
`
`Default options include “emergency call,” or pushing or swiping or swiping to unlock or
`fingerprint recognition to unlock the phone. As shown below, messages and call back number
`are “optional.”
`
`
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`A-17
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 19 of 37 PageID #: 21226
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`For example, the forced message initiating lock mode may be sent without entering optional
`information, and thus the default list will be sent.
`Each Accused Product includes a response list that is transmitted within the forced message
`alert software packet is a custom response list that is created at the time the specific forced
`message alert is created on the sender PDA/cell phone.
`
`See Claim [1F] above.
`
`The forced message alert may be standard or customized.
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`A-18
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`5. The system as in claim 1, wherein
`the response list that is transmitted
`within the forced message alert
`software packet is a custom response
`list that is created at the time the
`specific forced message alert is
`created on the sender PDA/cell
`
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 20 of 37 PageID #: 21227
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`phone.
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`For example, forced message initiating lock mode may be sent with optional information, and
`thus the specific list will be sent at the time the forced message is created.
`
`
`6[A]. A method of sending a forced
`message alert to one or more
`recipient PDA/cell phones within a
`predetermined communication
`network, wherein the receipt and
`response to said forced message alert
`by each intended recipient PDA/cell
`
`
`LG infringes directly and/or indirectly by performing, inducing other to perform, and/or
`contributing to the performance of: a method of sending a forced message alter to one or more
`recipient PDA/cell phones within a predetermined communication network, wherein the
`receipt and response to said forced message alert by each intended recipient PDA/cell phone is
`tracked, said method comprising the steps of:
`
`The Accused Products meet the claim limitations by providing device-location tracking
`
`
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`A-19
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 21 of 37 PageID #: 21228
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`phone is tracked, said method
`comprising the steps of:
`
`features such as those features described below. For example, the Accused Products meet the
`claim limitations because they are pre-installed with Android mobile operating systems
`containing code for providing device-location tracking features as provided in the claims
`limitations herein. For example, the Accused Products run applications and/or software that
`run within the Android mobile operating system and that use components of the Android
`mobile operating system to provide device-location tracking features. Upon information and
`belief, in addition to the components and features of the Android mobile operating system
`itself, the following applications and/or software run within the Android mobile operating
`system and use components of the Android mobile operating system to provide device-
`location tracking features: Android Device Manager, Find My Device.
`
`Android Device Manager is the predecessor to Find My Device and has been available as a
`standard, pre-installed feature since 2013 and downloadable as a software application. The
`current iteration, Find My Device, often called the “new and improved Android Device
`Manager” or “rebranded Android Device Manager” is now part of the standard Google Play
`Protect suite which is “built in and enabled on all devices,” i.e., the Accused Products running
`Android OS. AGIS sets forth the Find My Device feature of the Accused Products as
`representative of this method. AGIS reserves the right to supplement these contentions to the
`extent that LG requires additional information in accordance with P.R. 3-1 and for any other
`reason for which it may deem necessary.
`
`See, e.g., https://www.androidcentral.com/find-my-device;
`https://support.google.com/android/answer/6160491?hl=en;
`https://android.googleblog.com/2013/08/find-your-lost-phone-with-android.html;
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en;
`https://www.blog.google/products/android/google-play-protect/
`
`Each “Google Account” is associated with a pre-determined number of devices, which include
`a CPU and a touchscreen, and which are registered when a customer acquires an Accused
`Product, such as a LG Android OS based device.
`
`
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`A-20
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 22 of 37 PageID #: 21229
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`A-21
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 23 of 37 PageID #: 21230
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`https://support.google.com/websearch/answer/6128427
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`A-22
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 24 of 37 PageID #: 21231
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`https://support.google.com/websearch/answer/6128427
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`A-23
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`Case 2:17-cv-00514-JRG Document 267-2 Filed 03/04/19 Page 25 of 37 PageID #: 21232
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`Exhibit A for US Patent No. 8,213,970 Against LG Accused Products
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`6[B] accessing a forced message
`alert software application program
`on a sender PDA/cell phone;
`
`The user of the Accused Products (the sender) performs the step of “accessing a forced
`message alert software application program on a sender PDA/cell phone” by accessing the
`Find My Device app.
`
`6[C] creating the forced message
`alert on said sender PDA/cell phone
`by attaching a voice or text message
`to a forced message alert application
`software packet to said voice