Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 1 of 37 PageID #:
`8009
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`EXHIBIT B
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`

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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 2 of 37 PageID #:
`8010
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`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.
`
`Term/Patent(s) &
`Claim(s)
`“means for displaying
`a geographical map
`with georeferenced
`entities on the display
`of the sender PDA/cell
`phone”
`
`’970 Patent: claim 2
`
`No.
`
`1
`
`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 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
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`
`
`Governed by 35 U.S.C.
`§ 112(6).
`
`Function: “displaying a
`geographical map with
`georeferenced entities on the
`display of the sender PDA/cell
`phone”
`
`Structure: “the sender
`PDA/cell phone including
`display 16 and configured to
`implement the algorithm
`described in the ’970 patent at
`4:55-59, 5:37-44, 6:27-37”
`
`Governed by 35 U.S.C.
`§ 112(6).
`
`Function: “displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cell phone”
`
`Structure: “PDA/cell phone
`hardware including display
`16 and a wireless receiver
`and/or transreceiver; and
`equivalents thereof”
`
`Alternatively:
`
`Function: “displaying a
`geographical map with
`georeferenced entities on
`the display of the sender
`PDA/cell phone”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 4:55-59, 5:10-14, 5:37-
`40, 6:33-37, and equivalents
`thereof”
`
`1
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`

`

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`No.
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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 3 of 37 PageID #:
`8011
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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
`
`2
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`

`

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`
`No.
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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 4 of 37 PageID #:
`8012
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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.
`
`3
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`

`

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`No.
`
`2
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 5 of 37 PageID #:
`8013
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`Term/Patent(s) &
`Claim(s)
`
`“means for obtaining
`location and status
`data associated with
`the recipient PDA/cell
`phone”
`
`’970 Patent: claim 2
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`
`
`Governed by 35 U.S.C.
`§ 112(6).
`
`Function: “obtaining
`location and status data
`associated with the recipient
`PDA/cell phone”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 2:38-43 and 3:52-62, and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 12(6).
`
`Function: Indefinite because
`the function of “obtaining
`location and status data
`associated with the recipient
`PDA/cell phone,” recites
`“status data” that is indefinite
`
`Structure: Does not require
`construction because “status
`data” in the function is
`indefinite
`
`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 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
`
`4
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`No.
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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 6 of 37 PageID #:
`8014
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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 PDA/cell phone immediately
`upon receiving a forced message
`alert from the sender PDA/cell
`phone;
`
`
`5
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`

`

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`No.
`
`3
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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 7 of 37 PageID #:
`8015
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Claim Language
`
`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 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 2
`A communication system for
`transmitting, receiving, confirming
`receipt, and responding to an
`electronic message, comprising: a
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`“means for presenting
`a recipient symbol on
`the geographical map
`corresponding to a
`correct geographical
`
`Governed by 35 U.S.C.
`§ 112(6).
`
`Function: “presenting a
`recipient symbol on the
`6
`
`
`
`Governed by 35 U.S.C.
`§ 112(6).
`
`Function: “presenting a
`recipient symbol on the
`
`

`

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`No.
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 8 of 37 PageID #:
`8016
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Term/Patent(s) &
`Claim(s)
`location of the
`recipient PDA/cell
`phone”
`
`’970: claim 2
`
`Claim Language
`
`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 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
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`geographical map
`corresponding to a correct
`geographical location of the
`recipient PDA/cell phone”
`
`Structure: insufficiently
`disclosed and therefore
`indefinite
`
`geographical map
`corresponding to a correct
`geographical location of the
`recipient PDA/cell phone”
`
`Structure: “PDA/cell phone
`hardware including display
`16 and a wireless receiver
`and/or transreceiver; and
`equivalents thereof”
`
`Alternatively:
`
`Function: “presenting a
`recipient symbol on the
`geographical map
`corresponding to a correct
`geographical location of the
`recipient PDA/cell phone”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 6:25-27, 6:33-37, and
`equivalents thereof”
`
`7
`
`

`

`
`
`No.
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 9 of 37 PageID #:
`8017
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
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`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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
`
`8
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`

`

`
`
`No.
`
`4
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`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 10 of 37 PageID #:
`8018
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Claim Language
`
`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 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
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Plain and ordinary meaning.
`
`
`
`“activates . . . to lock the
`display of the recipient
`PDA/cell phone until a
`response is selected from the
`response list”
`
`“which triggers the
`forced message alert
`software application
`program to take
`control of the recipient
`PDA/cell phone”
`
`’970 Patent: claim 10
`
`9
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`

`

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`
`No.
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 11 of 37 PageID #:
`8019
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`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 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
`
`10
`
`

`

`
`
`No.
`
`5
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 12 of 37 PageID #:
`8020
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Claim Language
`
`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 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, 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
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Plain and ordinary meaning.
`
`Indefinite.
`
`
`
`“status data”
`
`’970 Patent: claims 2,
`10
`
`11
`
`

`

`
`
`No.
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 13 of 37 PageID #:
`8021
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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 to said recipient
`PDA/cell phones that have not
`automatically acknowledged the
`
`12
`
`

`

`
`
`No.
`
`Case 2:22-cv-00263-JRG-RSP Document 107-2 Filed 08/18/23 Page 14 of 37 PageID #:
`8022
`EXHIBIT B - JOINT CLAIM CONSTRUCTION CHART – DISPUTED TERMS
`
`Term/Patent(s) &
`Claim(s)
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Court’s Construction
`
`Claim Language
`
`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 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
`
`13
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`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 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
`
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`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 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;
`
`
`15
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`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.
`
`’838 Patent, Claim 1: A computer-
`implemented method comprising:
`performing, by a first device:
`joining a communication network
`corresponding to a group, wherein
`joining the communication network
`comprises transmitting a message
`including an identifier corresponding
`to the group;
`
`participating in the group, wherein
`participating in the group includes
`sending first location information to
`a first server and receiving second
`location information from the first
`server, the first location information
`comprising a location of the first
`device, the second location
`
`Term/Patent(s) &
`Claim(s)
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`Defendants’ Construction
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`Court’s Construction
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`“more than two participants
`associated together” with
`“participants” construed as
`“users” or “devices”
`
`“group”
`
`’838 Patent, claims 1,
`19, 54
`
`’829 Patent, claims 1,
`34, 35
`
`’123 Patent, claims 1,
`14, 17, 23, 36
`
`
`
`As reflected in Samsung’s
`briefing opposing AGIS’s
`motion for leave to amend the
`P.R. 4-3 statement (Dkt. 90),
`Samsung disagrees that further
`construction or briefing of this
`term is required. The parties
`have agreed to adopt the
`construction of “more than
`two participants associated
`together” (Dkt. 70) and no
`further construction or briefing
`is required.
`
`16
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`information comprising one or more
`locations of one or more respective
`second devices included in the
`group;
`
`presenting, via an interactive display
`of the first device, a first interactive,
`georeferenced map and a first set of
`one or more user-selectable symbols
`corresponding to a first set of one or
`more of the second devices, wherein
`the first set of symbols are positioned
`on the first georeferenced map at
`respective positions corresponding to
`the locations of the first set of second
`devices, and wherein first
`georeferenced map data relate
`positions on the first georeferenced
`map to spatial coordinates;
`
`sending, to a second server, a request
`for second georeferenced map data
`different from the first georeferenced
`map data;
`
`receiving, from the second server,
`the second georeferenced map data;
`
`presenting, via the interactive display
`of the first device, a second
`georeferenced map and a second set
`of one or more user- selectable
`symbols corresponding to a second
`set of one or more of the second
`devices, wherein the second set of
`symbols are positioned on the second
`georeferenced map at respective
`positions corresponding to the
`locations of the second set of second
`devices, and wherein the second
`georeferenced map data relate
`positions on the second
`
`17
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`georeferenced map to spatial
`coordinates; and
`
`identifying user interaction with the
`interactive display selecting one or
`more of the second set of user-
`selectable symbols corresponding to
`one or more of the second devices
`and positioned on the second
`georeferenced map and us