Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 1 of 169 PageID #: 1
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`
`
`v.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
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`§
`Case No.
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`JURY TRIAL DEMANDED
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`§
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`§
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`§
`§
`§
`§
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`§
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`PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`
`
`Defendants.
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`
`
`
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`Plaintiff, AGIS Software Development LLC (“AGIS Software” or “Plaintiff”) files this
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`original Complaint against Defendants Samsung Electronics Co., Ltd. (“Samsung Electronics”)
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`and Samsung Electronics America, Inc. (“Samsung Electronics America”) (collectively,
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`“Samsung” or “Defendants”) for patent infringement under 35 U.S.C. § 271 and alleges as follows:
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`THE PARTIES
`
`1.
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`Plaintiff AGIS Software is a limited liability company organized and existing under
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`the laws of the State of Texas and maintains its principal place of business at 100 W. Houston
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`Street, Marshall, Texas 75670. AGIS Software is the owner of all right, title, and interest in and
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`to U.S. Patent Nos. 8,213,970, 9,467,838, 9,749,829, and 9,820,123 (the “Patents-in-Suit”).
`
`2.
`
`Defendant Samsung Electronics is a corporation organized and existing under the
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`laws of the Republic of Korea, with its principal place of business at 129 Samsung-Ro, Yeongtong-
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`Gu, Suwon-Si, Gyeonggi-Do, 443-742, Republic of Korea. Upon information and belief, Samsung
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`Electronics does business in Texas, directly or through intermediaries, and offers its products
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`

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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 2 of 169 PageID #: 2
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`and/or services, including those accused herein of infringement, to customers and potential
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`customers located in Texas, including in this Judicial District.
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`3.
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`Defendant Samsung Electronics America, is a corporation organized under the laws
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`of New York, with its principal place of business at 85 Challenger Road, Ridgefield Park, New
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`Jersey 07660. Upon information and belief, Samsung Electronics America has corporate offices
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`in the Eastern District of Texas at 6625 Excellence Way, Plano, Texas 75023,1 2601 Preston Road,
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`#1214, Frisco, Texas 75023,2 6625 Excellence Way, Plano, Texas 75023, 1303 East Lookout
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`Drive, Richardson, Texas 75082, and 2800 Technology Drive, Suite 200, Plano, Texas 75074.
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`4.
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`Defendants have authorized sellers and sales representatives that offer and sell
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`products pertinent to this Complaint through the State of Texas, including in this Judicial District,
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`and to consumers throughout this Judicial District, such as: Best Buy, 422 West TX-281 Loop,
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`Suite 100, Longview, Texas 75605; AT&T Store, 1712 East Grand Avenue, Marshall, Texas
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`75670; Sprint Store, 1806 East End Boulevard North, Suite 100, Marshall, Texas 75670; T-Mobile,
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`900 East End Boulevard North, Suite 100, Marshall, Texas 75670; Verizon authorized retailers,
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`including Russell Cellular, 1111 East Grand Avenue, Marshall, Texas 75670; Victra, 1006 East
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`End Boulevard, Marshall, Texas 75670; and Cricket Wireless authorized retailer, 120 East End
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`Boulevard South, Marshall, Texas 75670.
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`JURISDICTION AND VENUE
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`5.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, 35 U.S.C. §§ 1, et seq. This Court has subject matter jurisdiction over this action pursuant
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`to 28 U.S.C. §§ 1331, 1338(a), and 1367.
`
`
`1 https://news.samsung.com/us/samsung-electronics-america-open-flagship-north-texas-campus/
`2 https://news.samsung.com/us/new-frisco-tx-samsung-experience-store-open-galaxy/
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`2
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`6.
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`This Court has specific and personal jurisdiction over each of the Defendants
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`consistent with the requirements of the Due Process Clause of the United States Constitution and
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`the Texas Long Arm Statute. Upon information and belief, each Defendant has sufficient
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`minimum contacts with the forum because each Defendant transacts substantial business in the
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`State of Texas and in this Judicial District. Further, each Defendant has, directly or through
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`subsidiaries or intermediaries, committed and continues to commit acts of patent infringement in
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`the State of Texas and in this Judicial District as alleged in this Complaint, as alleged more
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`particularly below.
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`7.
`
`Venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1391 and 1400(b)
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`because Defendants are subject to personal jurisdiction in this Judicial District, have committed
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`acts of patent infringement in this Judicial District, and have regular and established places of
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`business in this Judicial District. Defendants, through their own acts and/or through the acts of
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`others, make, use, sell, and/or offer to sell infringing products within this Judicial District,
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`regularly do and solicit business in this Judicial District, and have the requisite minimum contacts
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`with this Judicial District, such that this venue is a fair and reasonable one. Further, on information
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`and belief, Defendants have admitted or not contested proper venue in this Judicial District in other
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`patent infringement actions.
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`PATENTS-IN-SUIT
`
`8.
`
`On July 3, 2012, the United States Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 8,213,970 (the “’970 Patent”) entitled “Method of Utilizing Forced Alerts
`
`for Interactive Remote Communications.” On September 1, 2021, the United States Patent and
`
`Trademark Office issued an Inter Partes Review Certificate for the ’970 Patent cancelling claims
`
`1 and 3-9. On December 9, 2021, the United States Patent and Trademark Office issued an
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`3
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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 4 of 169 PageID #: 4
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`Ex Parte Reexamination Certificate for the ’970 Patent determining claims 2 and 10 (as amended)
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`and claims 11-13 to be valid and patentable. A true and correct copy of the ’970 Patent, which
`
`includes the September 1, 2021 Inter Partes Review Certificate and the December 9, 2021
`
`Ex Parte Reexamination Certificate, is attached hereto as Exhibit A.
`
`9.
`
`On October 11, 2016, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 9,467,838 (the “’838 Patent”) entitled “Method to Provide Ad Hoc
`
`and Password Protected Digital and Voice Networks.” On May 27, 2021, the United States Patent
`
`and Trademark Office issued an Ex Parte Reexamination Certificate for the ’838 Patent confirming
`
`the validity and patentability of claims 1-84. A true and correct copy of the ’838 Patent, which
`
`includes the May 27, 2021 Ex Parte Reexamination Certificate, is attached hereto as Exhibit B.
`
`10.
`
`On August 29, 2017, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 9,749,829 (the “’829 Patent”) entitled “Method to Provide Ad Hoc
`
`and Password Protected Digital and Voice Networks.” On August 16, 2021, the United States
`
`Patent and Trademark Office issued an Ex Parte Reexamination Certificate for the ’829 Patent
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`confirming the validity and patentability of claims 1-68. A true and correct copy of the ’829 Patent,
`
`which includes the August 16, 2021 Ex Parte Reexamination Certificate, is attached hereto as
`
`Exhibit C.
`
`11.
`
`On November 14, 2017, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 9,820,123 (the “’123 Patent”) entitled “Method to Provide Ad Hoc
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`and Password Protected Digital and Voice Networks.” On September 24, 2021, the United States
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`Patent and Trademark Office issued an Ex Parte Reexamination Certificate for the ’123 Patent
`
`confirming the validity and patentability of claims 1-48. A true and correct copy of the ’123 Patent,
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`4
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`

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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 5 of 169 PageID #: 5
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`which includes the September 24, 2021 Ex Parte Reexamination Certificate, is attached hereto as
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`Exhibit D.
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`12.
`
`AGIS is the sole and exclusive owner of all right, title, and interest in the Patents-
`
`in-Suit, and holds the exclusive right to take all actions necessary to enforce its rights to the
`
`Patents-in-Suit, including the filing of this patent infringement lawsuit. AGIS also has the right to
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`recover all damages for past, present, and future infringement of the Patents-in-Suit and to seek
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`injunctive relief as appropriate under the law.
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`FACTUAL ALLEGATIONS
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`13. Malcolm K. “Cap” Beyer, Jr., a graduate of the United States Naval Academy and
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`a former U.S. Marine, is the CEO of AGIS Software and a named inventor of the AGIS patent
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`portfolio. Mr. Beyer founded Advanced Ground Information Systems, Inc. (“AGIS, Inc.”) shortly
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`after the September 11, 2001 terrorist attacks because he believed that many first responder and
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`civilian lives could have been saved through the implementation of a better communication
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`system. He envisioned and developed a new communication system that would use integrated
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`software and hardware components on mobile devices to give users situational awareness superior
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`to systems provided by conventional military and first responder radio systems.
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`14.
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`AGIS, Inc. developed prototypes that matured into its LifeRing system. LifeRing
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`provides first responders, law enforcement, and military personnel with what is essentially a
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`tactical operations center built into hand-held mobile devices. Using GPS-based location
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`technology and existing or special-purpose cellular communication networks, LifeRing users can
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`exchange location, heading, speed, and other information with other members of a group, view
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`each other’s locations on maps and satellite images, and rapidly communicate and coordinate their
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`efforts.
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`5
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`

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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 6 of 169 PageID #: 6
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`15.
`
`AGIS Software licenses its patent portfolio, including the ’970, ’838, ’829, and
`
`’123 Patents, to AGIS, Inc. AGIS, Inc. has marked its products accordingly. AGIS Software and
`
`all previous assignees of the Patents-in-Suit have complied with the requirements of 35 U.S.C.
`
`§ 287(a).
`
`16.
`
`Defendants manufacture, use, sell, offer for sale, and/or import into the United
`
`States the Samsung Tactical, TAK, ATAK, and CivTAK, applications, products, and solutions,
`
`which also include related servers and services for supporting Samsung Tactical, TAK, ATAK,
`
`and CivTAK (“Accused Products”). Further, Defendants manufacture, use, sell, offer for sale,
`
`and/or import into the United States electronic devices, all of which are configured and/or adapted
`
`with certain map-based communication applications, products, and solutions such as Samsung
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`Tactical, TAK, ATAK, and CivTAK, such as the Galaxy S20 Tactical Edition, Galaxy XCover
`
`FieldPro, Galaxy XCover Pro, GT-I7500 Galaxy, i5700 Galaxy Spica, Galaxy S, Galaxy SL,
`
`Galaxy S II, Galaxy S Advance, Galaxy S III, Galaxy S Duos, Galaxy S III Mini, Galaxy S II Plus,
`
`Galaxy S4, Galaxy S4 Active, Galaxy S4 Mini, Galaxy S4 Zoom, Galaxy S Duos 2, Galaxy S III
`
`Slim, Galaxy S5, Galaxy S III Neo, Galaxy S5 Active, Galaxy S5 Mini, Galaxy S Duos 3, Galaxy
`
`S5 Plus, Galaxy S6, Galaxy S6 Edge, Galaxy S5 Neo, Galaxy S6 Active, Galaxy S6 Edge+, Galaxy
`
`S7, Galaxy S7 Edge, Galaxy S7 Active, Galaxy S8, Galaxy S8+, Galaxy S8 Active, Galaxy S9,
`
`Galaxy S9+, Galaxy S10e, Galaxy S10, Galaxy S10+, Galaxy S10 5G, Galaxy S21, Galaxy S20
`
`FE, Galaxy Alpha, Galaxy A3, Galaxy A5, Galaxy A7, Galaxy A8, Galaxy A3, Galaxy A5, Galaxy
`
`A7, Galaxy A8, Galaxy A8+, Galaxy A6, Galaxy A6+, Galaxy A8 Star, Galaxy A7, Galaxy A9,
`
`Galaxy A6s, Galaxy A8s, Galaxy A30, Galaxy A50, Galaxy A10, Galaxy A20, Galaxy A40,
`
`Galaxy A70, Galaxy A20e, Galaxy A80, Galaxy A40s, Galaxy A60, Galaxy A10s, Galaxy A20s,
`
`Galaxy A10e, Galaxy C5, Galaxy C7, Galaxy C9, Galaxy C9 Pro, Galaxy C7 Pro, Galaxy C5, Pro,
`
`6
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`Galaxy C8, Galaxy J, Galaxy J1, Galaxy J5, Galaxy J7, Galaxy J2, Galaxy J1 Ace, Galaxy J1 Nxt,
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`Galaxy J1 Mini, Galaxy J5 (2016), Galaxy J3 Pro, Galaxy J7, Galaxy J Max, Galaxy J1 Ace Neo,
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`Galaxy J1 (2016), Galaxy J5 Prime, Galaxy J7, Prime, Galaxy J1 Mini Prime, Galaxy J2 Prime,
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`Galaxy J3 Emerge, Galaxy J7 V, Galaxy J3 Prime, Galaxy J7 Pro, Galaxy J7 Max, Galaxy J7 Nxt,
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`Galaxy J3 Luna Pro, Galaxy J7 Sky Pro, Galaxy J7+, Galaxy J2 Pro, Galaxy J7 Prime 2, Galaxy
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`J7 Duo, Galaxy J4, Galaxy J6, Galaxy J3 (2018), Galaxy J7 (2018), Galaxy J2 Core, Galaxy J4+,
`
`Galaxy J6+, Galaxy J4 Core, Galaxy M, Galaxy M10, Galaxy M20, Galaxy M30, Galaxy M40,
`
`Galaxy E5, Galaxy E7, Galaxy Grand, Galaxy Core, Galaxy Core Plus, Galaxy Grand 2, Galaxy
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`Grand Neo, Galaxy Core Prime, Galaxy Grand Prime Plus, Galaxy Grand Prime Pro, Galaxy Mega
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`5.8, Galaxy Mega 6.3, Galaxy Mega 2, Galaxy Mini, Galaxy Mini 2, Galaxy Trend, Galaxy Trend
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`Lite, Galaxy Trend Plus, Galaxy Ace, Galaxy Ace Plus, Galaxy Ace 2, Galaxy Ace 3, Galaxy Ace
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`Style, Galaxy Ace 4, Galaxy On7, Galaxy On5, Galaxy On5 Pro, Galaxy On7 Pro, Galaxy On8,
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`Galaxy On Nxt, Galaxy On Max, Galaxy On7 Prime, Galaxy On6, Galaxy On8 (2018), Galaxy R,
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`Galaxy R Style, Galaxy Y, Galaxy Y Duos, Galaxy Young, Galaxy Young 2, Galaxy Pocket,
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`Galaxy Pocket Plus, Galaxy Pocket Neo, Galaxy Pocket Duos, Galaxy Pocket 2, Galaxy U, Galaxy
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`Neo, Galaxy Pro, Galaxy Precedent, Galaxy Z, Galaxy Rush, Galaxy 5, Galaxy W, Galaxy Fit,
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`Galaxy Gio, Galaxy Prevail, Galaxy Nexus, Galaxy Discover, Galaxy Reverb, Galaxy Stellar,
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`Galaxy Appeal, Galaxy Express, Galaxy Express 2, Galaxy Fame, Galaxy Star, Galaxy Win,
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`Galaxy Win Pro, Galaxy Star Pro, Galaxy Fame Lite, Galaxy Round, Galaxy Light, Galaxy V,
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`Galaxy V Plus, Galaxy V2, Galaxy K Zoom, Galaxy Folder, Galaxy Active Neo, Galaxy Folder
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`2, Galaxy Fold, Galaxy Note, Galaxy Note II, Galaxy Note 3, Galaxy Note 4, Galaxy Note Edge,
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`Galaxy Note 5, Galaxy Note 7, Galaxy Note Fan Edition, Galaxy Note 8, Galaxy Note 9, Galaxy
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`Note 10, Galaxy Note 10+, Galaxy Note 10+ 5G, Galaxy Tab, Galaxy Tab 7.0, Galaxy Tab 10.1,
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`7
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`Galaxy Tab 10.1N, Galaxy Tab 10.1v, Galaxy Tab 8.9, Galaxy Tab 7.0 Plus, Galaxy Tab 7.7,
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`Galaxy Tab 2 7.0, Galaxy Tab 2 10.1, Galaxy Tab 3 7.0, Galaxy Tab 3 Lite 7.0, Galaxy Tab 3 8.0,
`
`Galaxy Tab 3 10.1, Galaxy Tab 4 7.0, Galaxy Tab 4 8.0, Galaxy Tab 4 10.1, Galaxy Tab Pro 8.4,
`
`Galaxy Tab Pro 10.1, Galaxy Tab Pro 12.2, Galaxy Tab S 8.4, Galaxy Tab S 10.5, Galaxy Tab S2
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`8.0, Galaxy Tab S2 9.7, Galaxy Tab S3 9.7, Galaxy Tab S4 10.5, Galaxy Tab E 8, Galaxy Tab E
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`9.6, Galaxy Tab A 8.0, Galaxy Tab A 9.7, Galaxy Tab A 6.0, Galaxy Tab A 7.0, Galaxy Tab A
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`10.1, Galaxy Tab A 10.5, Galaxy Tab Pro S 12.0, Galaxy Book 10.6, Galaxy Book 12.0, Galaxy
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`Tab Active, Galaxy Tab Active 2, Galaxy View, Galaxy Note 8.0, Galaxy Note 10, Galaxy Note
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`10.1, Galaxy Note Pro 12.2, Galaxy Gear, Gear Sport, Gear S3 Frontier, Galaxy Watch, Galaxy
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`Watch Active, and Galaxy Watch Active 2. These Galaxy devices are also Accused Products. The
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`Accused Products comprise any and all versions of the Tactical, TAK, ATAK, and CivTAK
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`solutions, applications, and services including but not limited to, the ATAK-CIV, ATAK-MIL,
`
`and ATAK-MIL versions. The Accused Products, which include software components such as,
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`but not limited to, Samsung Tactical, TAK, and ATAK solutions, are configured to interact with
`
`Defendants’ servers which provide corresponding services related to at least Samsung Tactical,
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`TAK, and ATAK utilized by Samsung’s customers when operating the Accused Products, such as
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`the Galaxy devices identified herein. Such servers, which are made, sold, used, offered for sale,
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`and/or imported into the United States by Defendants, are also Accused Products.
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`17.
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`The Accused Products include functionalities that allow users to form and/or join
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`networks or groups, share and view locations with other users, display symbols corresponding to
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`locations (including locations of other users) on a map, and communicate with other users via text,
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`voice, and multimedia-based communication. Additionally, the Accused Products include
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`functionalities to allow users to form and/or join networks or groups. The Accused Products
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`8
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`include the functionalities to display map information, including symbols corresponding with
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`users, entities, and locations. Additionally, the Accused Products include functionalities to form
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`groups that include their own devices in order to track, remotely monitor and control, and/or
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`communicate with other users’ devices. The Accused Products include functionalities to enable
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`communications, such as voice calls between users. The Accused Products practice the claims of
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`the Asserted Patents to improve user experiences and to improve Samsung’s position in the market.
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`
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` 3
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`3 https://www.samsung.com/us/business/solutions/industries/government/tactical-edition/
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`9
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`4
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`4 https://www.samsung.com/us/business/solutions/industries/public-safety/smartphones-
`tablets/?cid=com-btb-sky-blg-us-other-na-100219-112001-na-na-
`na&attributioncampaignid=7011Q000001VMa2QAG
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`10
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`
`
`COUNT I
`(Infringement of the ’970 Patent)
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`5
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`18.
`
`Paragraphs 1 through 17 are incorporated herein by reference as if fully set forth in
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`their entireties.
`
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`5 https://www.civtak.org/atak-about/
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`11
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`19.
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`AGIS Software has not licensed or otherwise authorized Defendants to make, use,
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`offer for sale, sell, or import any Accused Products and/or products that embody the inventions of
`
`the ’970 Patent.
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`20.
`
`Defendants infringe, contribute to the infringement of, and/or induce infringement
`
`of the ’970 Patent by making, using, selling, offering for sale, distributing, exporting from, and/or
`
`importing into the United States products and/or methods covered by one or more claims of the
`
`’970 Patent including, but not limited to, the Accused Products.
`
`21.
`
`Defendants have and continue to directly infringe at least claim 10 of the ’970
`
`Patent, either literally or under the doctrine of equivalents, by making, using, selling, offering for
`
`sale, distributing, exporting from, and/or importing into the United States the Accused Products
`
`without authority and in violation of 35 U.S.C. § 271(a).
`
`22.
`
`Defendants have and continue to indirectly infringe at least claim 10 of the ’970
`
`Patent by actively, knowingly, and intentionally inducing others to directly infringe, either literally
`
`or under the doctrine of equivalents, by making, using, selling, offering for sale, distributing,
`
`exporting from, and/or importing into the United States the Accused Products and by instructing
`
`users of the Accused Products to perform methods claimed in the ’970 Patent. For example,
`
`Defendants, with knowledge that the Accused Products infringe the ’970 Patent at least as of the
`
`date of this Complaint, actively, knowingly, and intentionally induced, and continue to knowingly
`
`and intentionally induce direct infringement of the ’970 Patent in violation of 35 U.S.C. § 271(b).
`
`23.
`
`For example, Defendants have indirectly infringed and continue to indirectly
`
`infringe at least claim 10 of the ’970 Patent in the United States because Defendants’ customers
`
`use the Accused Products, including at least the Samsung Tactical, TAK, and ATAK applications
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`and services installed on the Accused Products, in accordance with Defendants’ instructions and
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`12
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`thereby directly infringe at least claim 10 of the ’970 Patent in violation of 35 U.S.C. § 271.
`
`Defendants directly and/or indirectly intentionally instruct their customers to infringe through
`
`training videos, demonstrations, brochures, installations and/or user guides, such as those located
`
`at
`
`one
`
`or
`
`more
`
`of
`
`the
`
`following:
`
`https://www.samsung.com/us/business/solutions/industries/government/tactical-
`
`edition/#COMMAND_AND_CONTROL;
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`https://www.samsung.com/us/business/solutions/services/mobility-software/e-fota/;
`
`https://image-us.samsung.com/SamsungUS/samsungbusiness/pdfs/brochures/S20_TE-tactical-
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`brochure-FINAL_July_2021.pdf;
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`https://insights.samsung.com/2021/09/01/atak-enhances-
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`collaboration-and-awareness-for-public-safety-2/;
`
`https://www.civtak.org/atak-about/;
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`https://www.civtak.org/documentation/; https://wiki.civtak.org/index.php?title=ATAK_Manual;
`
`https://www.pargovernment.com/tactical-
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`sa/docs/S20_brochure.pdf;https://insights.samsung.com/2021/09/22/7-ways-samsungs-galaxy-
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`xcover-pro-supports-first-responders/; and Samsung agents and representatives located within this
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`Judicial District. Defendants are thereby liable for infringement of the ’970 Patent under 35 U.S.C.
`
`§ 271(b).
`
`24.
`
`For example, Defendants directly infringe and/or indirectly infringe by instructing
`
`their customers to infringe by performing claim 10 of the ’970 Patent, including: a method of
`
`receiving, acknowledging and responding to a forced message alert from a sender PDA/cell phone
`
`to a recipient PDA/cell phone, wherein the receipt, acknowledgment, and response to said forced
`
`message alert is forced by a forced message alert software application program, said method
`
`comprising the steps of: receiving an electronically transmitted electronic message; identifying
`
`said electronic message as a forced message alert, wherein said forced message alert comprises a
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`13
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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 14 of 169 PageID #: 14
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`voice or text message and a forced message alert application software packet, which triggers the
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`activation of the forced message alert software application program within the recipient PDA/cell
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`phone; transmitting an automatic acknowledgment of receipt to the sender PDA/cell phone, which
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`triggers the forced message alert software application program to take control of the recipient
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`PDA/cell phone and show the content of the text message and a required response list on the
`
`display recipient PDA/cell phone or to repeat audibly the content of the voice message on the
`
`speakers of the recipient PDA/cell phone and show the required response list on the display
`
`recipient PDA/cell phone; and transmitting a selected required response from the response list in
`
`order to allow the message required response list to be cleared from the recipient’s cell phone
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`display, whether said selected response is a chosen option from the response list, causing the forced
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`message alert software to release control of the recipient PDA/cell phone and stop showing the
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`content of the text message and a response list on the display recipient PDA/cell phone and/or stop
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`repeating the content of the voice message on the speakers of the recipient PDA/cell phone;
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`displaying the response received from the PDA/cell phone that transmitted the response on the
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`sender of the forced alert PDA/cell phone; and providing a list of the recipient PDA/cell phones
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`that have automatically acknowledged receipt of a forced alert message and their response to the
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`forced alert message; and displaying a geographical map with georeferenced entities on the display
`
`of the sender PDA/cell phone; obtaining location and status data associated with the recipient
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`PDA/cellphone; and presenting a recipient symbol on the geographical map corresponding to a
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`correct geographical location of the recipient PDA/cellphone based on at least the location data.
`
`For example, the Accused Products include features as shown below.
`
`14
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`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 15 of 169 PageID #: 15
`Case 2:22-cv-00263-JRG-RSP Document1 Filed 07/14/22 Page 15 of 169 PagelD #: 15
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`Tactical Edition
`
`Multi-ethernet capabilities
`Dedicated connections with multiple mission systems including
`laser range finders, external GPS devices, drones and more keep you
`connected in degraded and highly contested network environments.
`
`Next-generation networks
`As technologies evolve, you need a powerful, mission-ready device
`that can take full advantage of next-generation military networks.
`The Galaxy 520 Tactical Edition supports Private SIM, 56, CARS and
`is ready for Wi-Fi é.
`
`5G | Achrs
`
`=e
`
`
`
`15
`15
`
`

`

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`Command and control
`
`
`
`Situational awareness
`
`The Galaxy 520 Tactical Edition integrates voice, video,
`and tactical data to provide a commonoperational picture
`of the battlespace. This complete and accurate real-time
`intelligence enhances the precision and effectivenessof
`your tactical teams.
`
`Tactical user experience
`Unique features found only on the Galaxy 520 Tactical
`Edition deliver fast and simple access to the information and
`applications operators need on-mission.
`
`Better intelligence
`The pro-grade 44 MPcamera on the Galaxy 520 Tactical
`Edition allows you to discretely capture and share crisp high-
`resolution photo or 8K video intelligence, even in low light
`without the use of a flash. View and analyze intelligence in
`greater detail than ever before with the Galaxy 520 Tactical
`Edition'’s Dynamic AMOLED 2.0, a 20Hz' display.
`
`Extend your mission
`The Galaxy 520 Tactical Edition battery is 20% larger
`than the previous tactical solution andit's intelligentIt
`optimizes your app wsage in the field giving you extended
`power to complete the mission. When you need a recharge,
`Super Fast Charging* and fast Wireless Charging 2.0 give
`you powerin a flash. And Wireless PowerShare allows
`you to easily charge a teammember’s phone in the field
`just by touching the devices.*
`
`
`
`
`
`
`
`
`
`
`16
`16
`
`

`

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`
` 6
`
`
`6 https://www.pargovernment.com/tactical-sa/docs/S20_brochure.pdf
`
`17
`
`

`

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`
`
`7 https://image-us.samsung.com/SamsungUS/samsungbusiness/pdfs/flyer/S20_TE-
`salesflyer_FINAL_July_2021.pdf
`
`18
`
`7
`
`

`

`Unclassified
`
`ATAK Civilian Overview
`
`Situational Awaren:
`mandenter,
`
`cage. All chang
`right corr
`
`this guide
`the toolbar
`
`froma fh
`inthe lo
`
`Gero. ee
`hese
`pint|
`_ .
`+!
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 1 Filed 07/14/22 Page 19 of 169 PageID #: 19
`
`thefirs!
`
`While in North Up
`[North Arrow] icon
`Track Up mapo}
`ditional controls
`
`m
`
`tation.
`
`Lon
`
`the [North Arrow]
`anual Rotation/Lock
`e
`e [Rotation] buttonto er
`anual
`in Manual N
`
`ignified byth
`< the orientationforfurther adjustment.
`
`tl
`
`a separates
`p canalsok
`ned
`or the [Padlock] icon t
`to center the screen on the Self Marker
`n betweenportrait andlandscape.
`
`1
`
`n the map. The
`about the u
`tools
`
`
`
`19
`
`

`

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`Unclassified
`
`3D View
`
`3D Models
`
`ATAK Civilian features 3D viewing ofterrain and map items
`(DTED required). Te enable 3D view,
`lang press on the
`[North Arrow] to call out the additional controls menu
`and select (3D). A tilt angle indicator will appear around
`the edge of the [North Arrow] when 3D view is active.
`Towch the screen with two fingers and simultaneously
`swipe up or down an the screen te tilt the view angle. Once the appropriate
`viewing angle is set, select the [3D Lock] buttan to retain this view while
`panning the map. While viewing the map from ain angle, sore map iterns
`
`will appear raised above the map surface if they have defined elevations.
`from there.
`
`ATAK Civilian supports the use of 3D models. OBJ models and other types from products such as Pix40 can be imported via the Import Manager or can
`be manually placed in the atak/overlays folder prior to startup.If using Import Manager browse to the .O8J file and import only that file, or browse ta a
`ZIP file that contains the OBfile (and others) and impart only thatfile.If using manual placement to the ata k/overlays folder, place a ZIP file cantaining
`the .OBJ file (and others)into the directory and they will be imported on startup.
`
`Once imported, a 3D Model icon will appear on the map.
`Zoom into the area of the icon until a loading ring ap
`pears. After the loading pracess has finished,
`the 3D
`model will be projected onta the map. Enable the map
`3D View andtilt the view angle to see the 3D modeling.
`Loaded 30 models will appear as their own category in
`Overlay Manager and can be toggled on/off or removed
`
`Unclassified
`
`Placement
`
`The user can enter locations of interest using the Point Dropper tool. Select the [Point Dropper icon to place internationally standardized
`markers. and other icons on the map, edit the data and share the markers with other network members.
`
`
`
`Self-Marker
`
`The Self-Marker is displayed as a blue arrowhead at the user's current location. The options available an the
`Self-Marker radial are: Compass Rose, Polar Coordinate Entry, Fine Adjust/Enter Coordinate/MGRS Location,
`GPS Error, Range & Bearing Line, GPS Lock to Self, Tracking Breadcrumbs, Place a Markerat the user's current lo
`cation and Details. Other TAK users appear on the display as a colored circle. The color of the circle represents
`the user's Tear affiliation, with additional lettering inside the circle to identify the role the user on the team.
`Team Member markers that include a diagonal line indicate that the GPS location is not available. A solid icon indicated that
`the team member has GPS reception.
`
`
`
`available.
`
`Available roles include: Team Member, Team Lead (designated by a TL in the center of the marker), Headquarters (HO
`in center), Sniper (8), Medic (+), Forward Observer (FO), RTO (R) or K9 (K9). The options available when another user's
`Self-Marker is selected are: Inner Ring - Delete, Polar Coordinate Entry, Fine Adjust/Enter Coordinate/MGRS Location,
`Range & Bearing Line, GPS Lock on Friendly, Video Player (if available), Communication Options(if canfigured by that
`user}, Custom Threat Rings, Tracking Breadcrumbs and Details.
`
`Outer Ring (Communication Optians) -— Data Package, Email, SM5 Messaging, GeaChat, VOIP and Cellular Phone, when
`
`20
`20
`
`

`

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`Unclassified
`
`Point Dropper
`
`De
`
`Selecting the [Point Dropper]icon will open the Point Dropper menu, containing marker
`symbology with one ar mare ican sets, a Recently Added button and an leanset Manager
`button.
`
`The Markers symbology affiliatians are: Unknown, Neutral, Red and Friendly.
`
`Select the
`
` affiliation, then a location on the map interface to drop the marker. To add a marker by
`
`Marker Mapping.
`
`manually entering coordinates, long press on the map interface and enter the MGRS location. Change the standard nam
`ing convention by entering values inte the custam prefix and index fields or leave blank to use the defaults. |f values are
`entered, the next marker will be dropped with the prefix name and starting number(s) of letter(s) and every subsequent
`marker will be assigned the next consecutive number(s} or letter(s).
`
`WELT
`
`
`The user can select the mission specific pallet ta open paint options including Waypoint (WP),
`Sensar of Observation Point (OP).
`
`The user can move betweeniconsets by either swiping in the icon set area or selecting on the
`[lconset Name]field to bring up the leon Pallet drop-down.
`
`Et
`
`
`
`The last paint placed is shown at the battemof the Paint Dropper window. The infar
`mation far all recently placed points can be accessed by selecting the [Clock] icon.
`This displays the marker ican, name, coordinates, elevation and range & bearing infor
`mation. The user can