Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 1 of 33 PageID #:
`7976
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`7976
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 2 of 33 PageID #:
`7977
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Pursuant to Local Patent Rule 4-5(d), Plaintiff AGIS Software Development LLC and Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`
`
`hereby provide a Joint Claim Construction Chart containing the claim terms and phrases for the claims for U.S. Patent Nos. 8,213,970; 9,467,838; 9,749,829; and 9,749,829. In
`
`addition, the parties hereby identify the claim number(s) where the terms and phrases appear.
`
`Claim Language
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`[AGREED]
`
`AGREED TERMS
`[AGREED]
`
`“application software that allows an operator
`to create and transmit forced message alerts”
`
`
`“a forced message alert
`software application
`program”
`
`’970 Patent: claims 2,
`10, 11, 12
`
`’970 Patent, claim 2
`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; a data
`transmission means that
`facilitates the
`transmission of
`electronic files between
`said PDA/cell phones in
`different locations; a
`sender PDA/cell phone
`and at least one recipient
`PDA/cell phone for each
`electronic message; 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
`
`1
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 3 of 33 PageID #:
`7978
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`phone; 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, 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 PDA/cell phone
`as soon as said forced
`message alert is received
`by the recipient
`PDA/cell phone; 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; means for
`receiving and displaying
`a listing of which
`recipient PDA/cell
`phones have
`automatically
`acknowledged the forced
`message alert and which
`recipient PDA/cell
`
`2
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 4 of 33 PageID #:
`7979
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`phones have not
`automatically
`acknowledged the forced
`message alert; means for
`periodically resending
`said forced message alert
`to said recipient
`PDA/cell phones that
`have not automatically
`acknowledged the forced
`message alert; 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;
`and means for displaying
`a geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cell phone; means
`for obtaining location
`status data associated
`with the recipient
`PDA/cell phone; and
`means for presenting a
`recipient symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/cell phone, wherein
`the forced message alert
`software application
`program on the recipient
`
`3
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 5 of 33 PageID #:
`7980
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`PDA/cell phone
`includes:
`
`means for transmitting
`the acknowledgment of
`receipt to said sender
`PDA/cell phone
`immediately upon
`receiving a forced
`message alert from the
`sender PDA/cell phone;
`
`means for controlling of
`the recipient PDA/cell
`phone upon transmitting
`said automatic
`acknowledgement and
`causing, in cases where
`the force message alert is
`a text message, the text
`message and a response
`list to be shown on the
`display of the recipient
`PDA/cell phone or
`causes, in cases where
`the forced message alert
`is a voice message, the
`voice message being
`periodically repeated by
`the speakers of the
`recipient PDA/cell
`phone while said
`response list is shown on
`the display;
`
`means for allowing a
`manual response to be
`manually selected from
`the response list or
`manually recorded and
`
`4
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 6 of 33 PageID #:
`7981
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`transmitting said manual
`response to the sender
`PDA/cell phone; and
`
`means for allowing a
`manual response to be
`manually selected from
`the response list or
`manually recorded and
`transmitting said manual
`response to the sender
`PDA/cell phone; and
`
`means for clearing the
`text message and a
`response list from the
`display of the recipient
`PDA/cell phone or
`stopping the repeating
`voice message and
`clearing the response list
`from the display of the
`recipient PDA/cell
`phone once the manual
`response is transmitted.
`
`’970 Patent, claim 10
`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
`
`5
`
`
`
`
`
`Claim Language
`
`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 of a voice or
`text message and a
`forced message alert
`application software
`packet, which triggers
`the activation of the
`forced message alert
`software application
`program within the
`recipient PDA/cell
`phone;
`
`transmitting an
`automatic
`acknowledgement of
`receipt to the sender
`PDA/cell phone, which
`triggers the forced
`message alert software
`application program to
`take control of the
`recipient 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
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 7 of 33 PageID #:
`7982
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`6
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 8 of 33 PageID #:
`7983
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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
`display, whether said
`selected response is a
`chosen option from the
`response list, causing the
`forced message alert
`software to release
`control of the recipient
`PDA/cell phone and stop
`showing the content of
`the text message and a
`response list on the
`display recipient
`PDA/cell phone and or
`stop repeating the
`content of the voice
`message on the speakers
`of the recipient PDA/cell
`phone;
`
`displaying the response
`received from the PDA
`cell phone that
`transmitted the response
`on the sender of the
`
`7
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 9 of 33 PageID #:
`7984
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`forced alert PDA/cell
`phone; and
`
`providing a list of the
`recipient PDA/cell
`phones have
`automatically
`acknowledged receipt of
`a forced alert message
`and their response to the
`forced alert message;
`and displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cellphone;
`obtaining location and
`status data associated
`with the recipient
`PDA/cellphone; and
`presenting a recipient
`symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/ cellphone based
`on at least the location
`data.
`
`’970 Patent, claim 11
`The method as in claim
`10, wherein each
`PDA/cell phone within a
`predetermined
`communication network
`is similarly equipped and
`has the forced message
`alert software
`
`8
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 10 of 33 PageID #:
`7985
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`“manual response”
`
`’970 Patent: claim 2
`
`[AGREED]
`
`[AGREED]
`
`“recipient-selectable response message”
`
`
`
`
`Claim Language
`
`application program
`loaded on it.
`
`’970 Patent, claim 12
`The method as in claim
`10, wherein said forced
`message alert application
`software packet contains
`a response list, wherein
`said response list is a
`default list embedded in
`the forced message
`alert software
`application program.
`
`’970 Patent, claim 2
`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; a data
`transmission means that
`facilitates the
`transmission of
`electronic files between
`said PDA/cell phones in
`different locations; a
`sender PDA/cell phone
`and at least one recipient
`PDA/cell phone for each
`electronic message; a
`
`9
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 11 of 33 PageID #:
`7986
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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; 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, 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 PDA/cell phone
`as soon as said forced
`message alert is received
`by the recipient
`PDA/cell phone; 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
`
`10
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 12 of 33 PageID #:
`7987
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`phone display; means for
`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; means for
`periodically resending
`said forced message alert
`to said recipient
`PDA/cell phones that
`have not automatically
`acknowledged the forced
`message alert; 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;
`and means for displaying
`a geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cell phone; means
`for obtaining location
`status data associated
`with the recipient
`PDA/cell phone; and
`means for presenting a
`
`11
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 13 of 33 PageID #:
`7988
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`recipient symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/cell phone, wherein
`the forced message alert
`software application
`program on the recipient
`PDA/cell phone
`includes:
`
`means for transmitting
`the acknowledgment of
`receipt to said sender
`PDA/cell phone
`immediately upon
`receiving a forced
`message alert from the
`sender PDA/cell phone;
`
`means for controlling of
`the recipient PDA/cell
`phone upon transmitting
`said automatic
`acknowledgement and
`causing, in cases where
`the force message alert is
`a text message, the text
`message and a response
`list to be shown on the
`display of the recipient
`PDA/cell phone or
`causes, in cases where
`the forced message alert
`is a voice message, the
`voice message being
`periodically repeated by
`the speakers of the
`recipient PDA/cell
`
`12
`
`
`
`
`
`Claim Language
`
`phone while said
`response list is shown on
`the display;
`
`means for allowing a
`manual response to be
`manually selected from
`the response list or
`manually recorded and
`transmitting said
`manual response to the
`sender PDA/cell phone;
`and
`
`means for allowing a
`manual response to be
`manually selected from
`the response list or
`manually recorded and
`transmitting said
`manual response to the
`sender PDA/cell phone;
`and
`
`means for clearing the
`text message and a
`response list from the
`display of the recipient
`PDA/cell phone or
`stopping the repeating
`voice message and
`clearing the response list
`from the display of the
`recipient PDA/cell
`phone once the manual
`response is transmitted.
`’970 Patent, claim 10
`A method of receiving,
`acknowledging and
`responding to a forced
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 14 of 33 PageID #:
`7989
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`“required response list”
`
`’970 Patent: claim 10
`
`[AGREED]
`
`[AGREED]
`
`“list of responses, one of which must be
`selected before the list can be cleared from
`the display”
`
`
`13
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 15 of 33 PageID #:
`7990
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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 of a voice or
`text message and a
`forced message alert
`application software
`packet, which triggers
`the activation of the
`forced message alert
`software application
`program within the
`recipient PDA/cell
`phone;
`
`transmitting an
`automatic
`acknowledgement of
`receipt to the sender
`PDA/cell phone, which
`triggers the forced
`
`14
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 16 of 33 PageID #:
`7991
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`message alert software
`application program to
`take control of the
`recipient 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
`display, whether said
`selected response is a
`chosen option from the
`response list, causing the
`forced message alert
`software to release
`control of the recipient
`PDA/cell phone and stop
`showing the content of
`the text message and a
`response list on the
`display recipient
`PDA/cell phone and or
`stop repeating the
`
`15
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 17 of 33 PageID #:
`7992
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`content of the voice
`message on the speakers
`of the recipient PDA/cell
`phone;
`
`displaying the response
`received from the PDA
`cell phone that
`transmitted the response
`on the sender of the
`forced alert PDA/cell
`phone; and
`
`providing a list of the
`recipient PDA/cell
`phones have
`automatically
`acknowledged receipt of
`a forced alert message
`and their response to the
`forced alert message;
`and displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cellphone;
`obtaining location and
`status data associated
`with the recipient
`PDA/cellphone; and
`presenting a recipient
`symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/ cellphone based
`on at least the location
`data.
`
`
`16
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 18 of 33 PageID #:
`7993
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`“a CPU and a touch
`screen display a CPU
`and memory”
`
`’970 Patent: claim 2
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`[AGREED]
`
`AGREED TERMS
`[AGREED]
`
`“a CPU, a touch screen display, and
`memory”
`
`
`
`
`Claim Language
`
`’970 Patent, claim 2
`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; a
`data transmission means
`that facilitates the
`transmission of
`electronic files between
`said PDA/cell phones in
`different locations; a
`sender PDA/cell phone
`and at least one recipient
`PDA/cell phone for each
`electronic message; 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; means for
`attaching a forced
`message alert software
`packet to a voice or text
`message creating a
`forced message alert that
`
`17
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 19 of 33 PageID #:
`7994
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`is transmitted by said
`sender PDA/cell phone
`to the recipient PDA/cell
`phone, 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 PDA/cell phone
`as soon as said forced
`message alert is received
`by the recipient
`PDA/cell phone; 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; means for
`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; means for
`periodically resending
`said forced message alert
`
`18
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 20 of 33 PageID #:
`7995
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`to said recipient
`PDA/cell phones that
`have not automatically
`acknowledged the forced
`message alert; 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;
`and means for displaying
`a geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cell phone; means
`for obtaining location
`status data associated
`with the recipient
`PDA/cell phone; and
`means for presenting a
`recipient symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/cell phone, wherein
`the forced message alert
`software application
`program on the recipient
`PDA/cell phone
`includes:
`
`means for transmitting
`the acknowledgment of
`receipt to said sender
`
`19
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 21 of 33 PageID #:
`7996
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`PDA/cell phone
`immediately upon
`receiving a forced
`message alert from the
`sender PDA/cell phone;
`
`means for controlling of
`the recipient PDA/cell
`phone upon transmitting
`said automatic
`acknowledgement and
`causing, in cases where
`the force message alert is
`a text message, the text
`message and a response
`list to be shown on the
`display of the recipient
`PDA/cell phone or
`causes, in cases where
`the forced message alert
`is a voice message, the
`voice message being
`periodically repeated by
`the speakers of the
`recipient PDA/cell
`phone while said
`response list is shown on
`the display;
`
`means for allowing a
`manual response to be
`manually selected from
`the response list or
`manually recorded and
`transmitting said manual
`response to the sender
`PDA/cell phone; and
`
`means for allowing a
`manual response to be
`
`20
`
`
`
`
`
`Claim Language
`
`manually selected from
`the response list or
`manually recorded and
`transmitting said manual
`response to the sender
`PDA/cell phone; and
`
`means for clearing the
`text message and a
`response list from the
`display of the recipient
`PDA/cell phone or
`stopping the repeating
`voice message and
`clearing the response list
`from the display of the
`recipient PDA/cell
`phone once the manual
`response is transmitted.
`
`’970 Patent, claim 10
`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
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 22 of 33 PageID #:
`7997
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`[AGREED]
`
`[AGREED]
`
`Preamble is limiting.
`
`
`“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”
`
`’970 Patent: claim 10
`
`21
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 23 of 33 PageID #:
`7998
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`transmitted electronic
`message; identifying
`said electronic message
`as a forced message
`alert, wherein said
`forced message alert
`comprises of a voice or
`text message and a
`forced message alert
`application software
`packet, which triggers
`the activation of the
`forced message alert
`software application
`program within the
`recipient PDA/cell
`phone;
`
`transmitting an
`automatic
`acknowledgement of
`receipt to the sender
`PDA/cell phone, which
`triggers the forced
`message alert software
`application program to
`take control of the
`recipient 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
`
`22
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 24 of 33 PageID #:
`7999
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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
`display, whether said
`selected response is a
`chosen option from the
`response list, causing the
`forced message alert
`software to release
`control of the recipient
`PDA/cell phone and stop
`showing the content of
`the text message and a
`response list on the
`display recipient
`PDA/cell phone and or
`stop repeating the
`content of the voice
`message on the speakers
`of the recipient PDA/cell
`phone;
`
`displaying the response
`received from the PDA
`cell phone that
`transmitted the response
`on the sender of the
`forced alert PDA/cell
`phone; and
`
`providing a list of the
`recipient PDA/cell
`phones have
`
`23
`
`
`
`
`
`Claim Language
`
`automatically
`acknowledged receipt of
`a forced alert message
`and their response to the
`forced alert message;
`and displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cellphone;
`obtaining location and
`status data associated
`with the recipient
`PDA/cellphone; and
`presenting a recipient
`symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/ cellphone based
`on at least the location
`data.
`
`’970 Patent, claim 10
`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,
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 25 of 33 PageID #:
`8000
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`“selected response”
`
`’970 Patent: claim 10
`
`[AGREED]
`
`[AGREED]
`
`“recipient-selectable response message”
`
`
`24
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 26 of 33 PageID #:
`8001
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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 of a voice or
`text message and a
`forced message alert
`application software
`packet, which triggers
`the activation of the
`forced message alert
`software application
`program within the
`recipient PDA/cell
`phone;
`
`transmitting an
`automatic
`acknowledgement of
`receipt to the sender
`PDA/cell phone, which
`triggers the forced
`message alert software
`application program to
`take control of the
`recipient 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
`
`25
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 27 of 33 PageID #:
`8002
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`AGREED TERMS
`
`
`
`Claim Language
`
`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
`display, whether said
`selected response is a
`chosen option from the
`response list, causing the
`forced message alert
`software to release
`control of the recipient
`PDA/cell phone and stop
`showing the content of
`the text message and a
`response list on the
`display recipient
`PDA/cell phone and or
`stop repeating the
`content of the voice
`message on the speakers
`of the recipient PDA/cell
`phone;
`
`displaying the response
`received from the PDA
`cell phone that
`transmitted the response
`on the sender of the
`
`26
`
`
`
`
`
`Claim Language
`
`forced alert PDA/cell
`phone; and
`
`providing a list of the
`recipient PDA/cell
`phones have
`automatically
`acknowledged receipt of
`a forced alert message
`and their response to the
`forced alert message;
`and displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cellphone;
`obtaining location and
`status data associated
`with the recipient
`PDA/cellphone; and
`presenting a recipient
`symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/ cellphone based
`on at least the location
`data.
`
`
`’970 Patent, claim 2
`A communication
`system for transmitting,
`receiving, confirming
`receipt, and responding
`to an electronic message,
`comprising: a
`predetermined network
`of participants,
`
`Case 2:22-cv-00263-JRG-RSP Document 107-1 Filed 08/18/23 Page 28 of 33 PageID #:
`8003
`EXHIBIT A - JOINT CLAIM CONSTRUCTION CHART – AGREED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Constructi
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
