Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 1 of 51 PageID #:
`9887
`
`EXHIBIT N
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 2 of 51 PageID #:
`9888
`
`Exhibit A23
`U.S. Pat. No. 7,031,728 filed on September 21, 2004 (“Beyer ’728”)
`
`U.S. Pat. No. 7,031,728 (“Beyer ’728”) is entitled “Cellular Phone/PDA Communication System.”
`Beyer ’728 was issued on April 18, 2006 from an application filed on September 21, 2004. Beyer
`’728 discloses and/or renders obvious Claims 2 and 10-13 of U.S. Patent No. 8,213,970 alone
`and/or in combination with other references, as set forth in the chart below. Defendants incorporate
`in this chart all applicable qualifications, clarifications, and other statements made in Defendants’
`Invalidity Contentions. This invalidity claim chart is based on Defendants’ present understanding
`of Claims 2 and 10-13 and AGIS’s apparent construction of the claims, as set forth in AGIS’s
`Infringement Contentions. Defendants are not adopting AGIS’s apparent constructions, nor do
`Defendants admit the accuracy of any particular construction. To the extent the Court finds that
`this reference does not expressly disclose certain limitations in the asserted claims, such limitations
`would have been inherent and/or obvious. By mapping claim language to this reference,
`Defendants do not imply or admit that the claim language satisfies 35 U.S.C. § 112. To the extent
`any cell lacks citations to the charted reference, this should not be taken as an admission that the
`reference does not disclose the corresponding limitation but rather indicates that Defendants do
`not presently intend to rely on the reference as disclosing the limitation based on Defendants’
`present understanding of the claim limitation.
`
`
`
`
`
`
`
`1
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 3 of 51 PageID #:
`9889
`
`U.S. Patent No.
`8,213,970
`[2.pre] A
`communication
`system for
`transmitting,
`receiving,
`confirming
`receipt, and
`responding to an
`electronic
`message,
`comprising:;
`
`Beyer ’728
`
`Beyer ’728 discloses and renders obvious a communication system
`for transmitting, receiving, confirming receipt, and responding to an
`electronic message, comprising:
`
`See, e.g., Beyer ’728 at 7:18-24 (“[T]he present invention is shown
`generally at 10 that includes a small handheld cellular phone/PDA
`communications system in housing 12 that includes . . . an LCD
`display 16. The small area 16a is the Navigation Bar that depicts the
`telephone, GPS and other status data and the active software.”).
`See also e.g., id. at 7:62-67 (“Mounted inside housing 12 as part of
`the PDA is the display function screen and the CPU. The CPU
`includes databases that provide for a geographical map and
`georeferenced entities that is shown as display portion 16b that
`includes as part of the display various areas of interest in the
`particular local map section.”).
`See also e.g., id. at FIG. 1, 8:19-25 (“When looking at FIG. 1,
`permanent geographical locations and buildings are shown. For
`example, the police station is shown and when the symbol is touched
`by the stylus or finger, the latitude and longitude of the symbol’s
`location, as shown in the display section 16c, is displayed at the
`bottom left of the screen.”).
`
`
`
`2
`
`

`

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`
`
`
`See also e.g., id. at 3:62-4:3 (“To operate the present invention, the
`operator (“cellular phone one” or “phone one”) starts the system by
`selecting the software which causes: . . . a map of the geographic area
`where the operator is located and operator’s own unit symbol to
`appear at the correct latitude and longitude on the map. . . [and] the
`locations of people, vehicles, buildings, and the like that are part of
`the database appear as symbols on the map.”).
`Beyer ’728 discloses and renders obvious a predetermined network of
`participants, wherein each participant has a similarly equipped
`
`3
`
`[2.a] a
`predetermined
`
`
`
`

`

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`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;
`
`[2.b] a data
`transmission
`means that
`facilitates the
`transmission of
`electronic files
`between said
`PDA/cell phones
`
`
`
`PDA/cell phone that includes a CPU and a touch screen display a
`CPU and memory.
`
`See e.g., Beyer ’728 at 4:39-50 (“To initialize the communications
`net, the cellular phone one operator selects from a list, the other users
`(or all of them), that the operator desires to be part of the
`communications net. The system then polls the selected phones to
`activate and become part of the communications net. The selected
`phones then transmit their positions to all the other phones in the
`established net. Through interaction with one or more other software
`enabled cellular phones, symbols are generated on the operator’s
`display based on the participant’s latitude and longitude that is
`exchanged between the cellular phones.”).
`See e.g., id. at Abstract (“A cellular, PDA communication system for
`allowing a plurality of cellular phone users to monitor each other’s
`location and status, to initiate cellular phone calls by touching a
`symbol on the display screen with a stylus or finger which can also
`include conference calling.”).
`See also e.g., id. at 1:22-24 (“A communications system is generally
`comprised of three basic elements: transmitter, information channel,
`and receiver.”).
`See also e.g., id. at 1:37-46 (“Digital Smart Message Service (SMS)
`and TCP/IP messages can be transmitted using cellular technology
`such as various versions of GSM and CDMA or via a WiFi local area
`network . . . Another implementation permits the cellular phone users
`to also view the location of other GPS equipped units.”).
`See also e.g., id. at 10:46 (“All the participant’s cellular phones that
`are a part of the communications net include an integrated or
`electronically connected GPS navigational system. Each phone can
`call the other cellular phones and request that they broadcast their
`latitude and longitude locations and status information.”
`See also e.g., id. at Figs. 1, 3.
`
`Beyer ’728 discloses and renders obvious a data transmission means
`that facilitates the transmission of electronic files between said
`PDA/cell phones in different locations.
`
`See e.g., Beyer ’728 at Abstract (“A cellular, PDA communication
`system for allowing a plurality of cellular phone users to monitor
`each other’s location and status, to initiate cellular phone calls by
`
`4
`
`

`

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`in different
`locations;
`
`touching a symbol on the display screen with a stylus or finger which
`can also include conference callling.”).
`See also e.g., id. at 1:22-24 (“A communications system is generally
`comprised of three basic elements: transmitter, information channel,
`and receiver.”).
`
`See also e.g., id. at 1:37-46 (“Digital Smart Message Service (SMS)
`and TCP/IP messages can be transmitted using cellular technology
`such as various versions of GSM and CDMA or via a WiFi local area
`network . . . Another implementation permits the cellular phone users
`to also view the location of other GPS equipped units.”).
`See, e.g., id. at 7:18-24 (“[T]he present invention is shown generally
`at 10 that includes a small handheld cellular phone/PDA
`communications system in housing 12 that includes . . . an LCD
`display 16. The small area 16a is the Navigation Bar that depicts the
`telephone, GPS and other status data and the active software.”).
`See also e.g., id. at 7:62-67 (“Mounted inside housing 12 as part of
`the PDA is the display function screen and the CPU. The CPU
`includes databases that provide for a geographical map and
`georeferenced entities that is shown as display portion 16b that
`includes as part of the display various areas of interest in the
`particular local map section.”).
`See also e.g., id. at FIG. 1, 8:19-25 (“When looking at FIG. 1,
`permanent geographical locations and buildings are shown. For
`example, the police station is shown and when the symbol is touched
`by the stylus or finger, the latitude and longitude of the symbol’s
`location, as shown in the display section 16c, is displayed at the
`bottom left of the screen.”).
`
`
`
`5
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 7 of 51 PageID #:
`9893
`
`
`
`See also e.g., id. at 3:62-4:3 (“To operate the present invention, the
`operator (“cellular phone one” or “phone one”) starts the system by
`selecting the software which causes: . . . a map of the geographic area
`where the operator is located and operator’s own unit symbol to
`appear at the correct latitude and longitude on the map. . . [and] the
`locations of people, vehicles, buildings, and the like that are part of
`the database appear as symbols on the map.”).
`
`
`
`
`6
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 8 of 51 PageID #:
`9894
`
`[2.c] a sender
`PDA/cell phone
`and at least one
`recipient
`PDA/cell phone
`for each
`electronic
`message;
`
`Beyer ’728 discloses and renders obvious a sender PDA/cell phone
`and at least one recipient PDA/cell phone for each electronic
`message.
`
`Beyer ’728 discloses and renders obvious 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.
`
`See e.g., Beyer ’728 at Abstract (“A cellular, PDA communication
`system for allowing a plurality of cellular phone users to monitor
`each other’s location and status, to initiate cellular phone calls by
`touching a symbol on the display screen with a stylus or finger which
`can also include conference calling.”).
`See also e.g., id. at 1:22-24 (“A communications system is generally
`comprised of three basic elements: transmitter, information channel,
`and receiver.”).
`See also e.g., id. at 1:37-46 (“Digital Smart Message Service (SMS)
`and TCP/IP messages can be transmitted using cellular technology
`such as various versions of GSM and CDMA or via a WiFi local area
`network . . . Another implementation permits the cellular phone users
`to also view the location of other GPS equipped units.”).
`See also e.g., id. at 7:18-24 (“[T]he present invention is shown
`generally at 10 that includes a small handheld cellular phone/PDA
`communications system in housing 12 that includes . . . an LCD
`display 16. The small area 16a is the Navigation Bar that depicts the
`telephone, GPS and other status data and the active software.”).
`See also e.g., id. at 7:45-50 (“The GPS system is capable of
`determining the latitude and longitude and through SMS, TCP/IP,
`WiFi or other digital messaging software, to also transmit this latitude
`and longitude information to other cellular phones via cellular
`communications, WiFi or radio.”).
`See also e.g., id. at 1:6-15 (“This invention generally relates to an
`integrated communications system using a plurality of cellular
`PDA/GPS phones for the management of a group of people through
`the use of a communications net, and, specifically, provide each user
`with a cellular phone that has features that permit all the users to
`know each other’s locations and status.”).
`See also e.g., id. at 2:18-31 (“The present software invention
`overcomes many of these problems shown in the prior art by
`
`
`
`7
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 9 of 51 PageID #:
`9895
`
`[2.d] 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;
`
`providing a cellular phone/PDA/GPS user: a) the ability to selectively
`poll each of the other PDA/GPS phones to start reporting their
`positions and status information directly to all or selected users
`equipped with cellular phone/PDA communication/GPS system in the
`communications net so that each of the systems that data is
`transmitted to is provided a display of the location, status and other
`information of the other users; b) the ability to exchange other entities
`of interest information and to assign these entities a category (car,
`person, tank, accident, or other entity) by touching the display screen
`at their locations on the map, and selecting the appropriate category
`switch.”).
`See also id. at Figs. 1, 3.
`Beyer ’728 discloses and renders obvious 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.
`
`See e.g., Beyer ’728 at Abstract (“A cellular, PDA communication
`system for allowing a plurality of cellular phone users to monitor
`each other’s location and status, to initiate cellular phone calls by
`touching a symbol on the display screen with a stylus or finger which
`can also include conference calling.”).
`See also e.g., id. at 1:22-24 (“A communications system is generally
`comprised of three basic elements: transmitter, information channel,
`and receiver.”).
`See also e.g., id. at 1:37-46 (“Digital Smart Message Service (SMS)
`and TCP/IP messages can be transmitted using cellular technology
`such as various versions of GSM and CDMA or via a WiFi local area
`network . . . Another implementation permits the cellular phone users
`to also view the location of other GPS equipped units.”).
`See also e.g., id. at 7:18-24 (“[T]he present invention is shown
`generally at 10 that includes a small handheld cellular phone/PDA
`communications system in housing 12 that includes . . . an LCD
`display 16. The small area 16a is the Navigation Bar that depicts the
`telephone, GPS and other status data and the active software.”).
`See also e.g., id. at 7:45-50 (“The GPS system is capable of
`determining the latitude and longitude and through SMS, TCP/IP,
`WiFi or other digital messaging software, to also transmit this latitude
`and longitude information to other cellular phones via cellular
`communications, WiFi or radio.”).
`
`
`
`8
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 10 of 51 PageID #:
`9896
`
`See also e.g., id. at 1:6-15 (“This invention generally relates to an
`integrated communications system using a plurality of cellular
`PDA/GPS phones for the management of a group of people through
`the use of a communications net, and, specifically, provide each user
`with a cellular phone that has features that permit all the users to
`know each other’s locations and status.”).
`See also e.g., id. at 2:18-31 (“The present software invention
`overcomes many of these problems shown in the prior art by
`providing a cellular phone/PDA/GPS user: a) the ability to selectively
`poll each of the other PDA/GPS phones to start reporting their
`positions and status information directly to all or selected users
`equipped with cellular phone/PDA communication/GPS system in the
`communications net so that each of the systems that data is
`transmitted to is provided a display of the location, status and other
`information of the other users; b) the ability to exchange other entities
`of interest information and to assign these entities a category (car,
`person, tank, accident, or other entity) by touching the display screen
`at their locations on the map, and selecting the appropriate category
`switch.”).
`See also id. at Figs. 1, 3.
`Beyer ’728 discloses and renders obvious 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.
`
`See e.g., Beyer ’728 at Abstract (“A cellular, PDA communication
`system for allowing a plurality of cellular phone users to monitor
`each other’s location and status, to initiate cellular phone calls by
`touching a symbol on the display screen with a stylus or finger which
`can also include conference callling.”).
`See also e.g., id. at 1:22-24 (“A communications system is generally
`comprised of three basic elements: transmitter, information channel,
`and receiver.”).
`See also e.g., id. at 1:37-46 (“Digital Smart Message Service (SMS)
`and TCP/IP messages can be transmitted using cellular technology
`such as various versions of GSM and CDMA or via a WiFi local area
`
`9
`
`[2.e] 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
`
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 11 of 51 PageID #:
`9897
`
`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;
`
`[2.f] means for
`requiring a
`required manual
`response
`from the
`response list
`by the recipient
`in order to clear
`recipient’s
`response
`
`
`
`network . . . Another implementation permits the cellular phone users
`to also view the location of other GPS equipped units.”).
`See also e.g., id. at 7:18-24 (“[T]he present invention is shown
`generally at 10 that includes a small handheld cellular phone/PDA
`communications system in housing 12 that includes . . . an LCD
`display 16. The small area 16a is the Navigation Bar that depicts the
`telephone, GPS and other status data and the active software.”).
`See also e.g., id. at 7:45-50 (“The GPS system is capable of
`determining the latitude and longitude and through SMS, TCP/IP,
`WiFi or other digital messaging software, to also transmit this latitude
`and longitude information to other cellular phones via cellular
`communications, WiFi or radio.”).
`See also e.g., id. at 1:6-15 (“This invention generally relates to an
`integrated communications system using a plurality of cellular
`PDA/GPS phones for the management of a group of people through
`the use of a communications net, and, specifically, provide each user
`with a cellular phone that has features that permit all the users to
`know each other’s locations and status.”).
`See also e.g., id. at 2:18-31 (“The present software invention
`overcomes many of these problems shown in the prior art by
`providing a cellular phone/PDA/GPS user: a) the ability to selectively
`poll each of the other PDA/GPS phones to start reporting their
`positions and status information directly to all or selected users
`equipped with cellular phone/PDA communication/GPS system in the
`communications net so that each of the systems that data is
`transmitted to is provided a display of the location, status and other
`information of the other users; b) the ability to exchange other entities
`of interest information and to assign these entities a category (car,
`person, tank, accident, or other entity) by touching the display screen
`at their locations on the map, and selecting the appropriate category
`switch.”).
`Beyer ’728 discloses and renders obvious 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.
`
`See e.g., Beyer ’728 at 10:32-34 (“Referring now to FIG. 3, a flow
`chart is shown of the activities provided in the present invention and
`the methodology.”), FIG. 3 (“Provide a database having a list of
`participants and corresponding cellphone numbers; Provide software
`
`10
`
`

`

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`9898
`
`list from
`recipient’s cell
`phone display;
`
`that permits the exchange of GPS position data, messages,
`photographs and videos.”)
`
`
`See also e.g., id. at 4:39-50 (“To initialize the communications net,
`the cellular phone one operator selects from a list, the other users (or
`all of them), that the operator desires to be part of the
`communications net. The system then polls the selected phones to
`activate and become part of the communications net. The selected
`phones then transmit their positions to all the other phones in the
`established net. Through interaction with one or more other software
`enabled cellular phones, symbols are generated on the operator’s
`display based on the participant’s latitude and longitude that is
`exchanged between the cellular phones.”).
`See also e.g., id. at 10:46 (“All the participant’s cellular phones that
`are a part of the communications net include an integrated or
`electronically connected GPS navigational system. Each phone can
`
`
`
`11
`
`

`

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`
`call the other cellular phones and request that they broadcast their
`latitude and longitude locations and status information.”
`
`See e.g., id. at 2:5–17 (“In spite of the rapid advance in cellular phone
`technology, it would also be desirable to actuate a remote cellular
`phone to annunciate an audio message to alert the remote user that
`there is an emergency (or for another reason) and that the calling
`cellular phone should be called immediately. Furthermore, it would
`be desirable to cause the remote phone to display a text message,
`photograph, video clip or video transmission, to announce the caller's
`name and to be able to control a remote phone and cause the remote
`phone to call another phone number (as an example, to automatically
`establish an 800 number conference call), to vibrate, or increase the
`loudness of an announcement without any action by the remote phone
`operator.”).
`
`See, e.g., id. at 5:55–6:4 (“Another embodiment of the invention can
`include a unique feature in which cellular phone one can send a
`digital message using SMS, TCP/IP or another protocol to another
`cellular phone on the communications net by touching a display
`screen symbol on the geographical screen and then selecting the
`appropriate software switch to transmit a digital message that would
`then remotely activate a program in the remote cellular phone to play
`a recorded audio file to announce an emergency and that a call to
`cellular phone one is required immediately. Since each of the remote
`cellular phones has the same software as cellular phone one and
`includes a PDA and the ability to receive digital messages, the ability
`to control remote cellular phones to make verbal announcements,
`display images, place return calls, place calls to another phone
`number, vibrate, change sound intensity and process and display pre-
`stored data, images and video can be achieved.”).
`
`See, e.g., id. at 9:52–10:6 (“Another feature available in the cellular
`phone/PDA system shown in FIG. 1 is its ability to activate a remote
`cellular phone to make verbal announcements, display images, place
`return calls, place calls to another phone number, vibrate, change
`sound intensity and process and display pre-stored data, images and
`video. As an example, on the PDA screen display 16, a software
`switch will be provided that would allow cellular phone one to call in
`an emergency situation and that would basically initiate an
`emergency audio response call. Using the stylus or finger again, a
`symbol such as 30 would be touched with the stylus or finger
`indicating a call to be made. The software switch labeled “call” would
`cause other software switches to appear, one of which would be “call
`provide emergency audio response” which when touched by the
`
`
`
`12
`
`

`

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`9900
`
`stylus or finger 14 would cause the cellular phone one system to
`automatically call the telephone number represented by symbol 30.
`The cellular phone 30 includes software that when it receives the
`SMS or TCP/IP message, can activate an audio message that
`announces “emergency please call cellular phone one immediately.”
`The announcement would be done through the cellular phone
`speaker.” Thus, the system is capable of initiating a cellular phone
`call by touch only, initiating conference call by touch only and
`activating a remote cellular phone to announce an emergency and
`other messages and elicit the audio response in the remote cellular
`phone by touch only.”)
`
`See, e.g., id. at 11:43–55 (“Another important feature of the present
`invention is that the operator or initiator of cellular phone one can by
`touching a switch on the display, send through the PDA system, a
`signal and digital message to all the cellular phones in the
`communications net or to designated cellular phone(s), represented by
`their symbols on the geographic display, an emergency message
`which requires a response. When received, the software in the remote
`cellular phone causes the remote cellular phone to initiate an audio
`message to the cellular phone user that there is an emergency (or
`another message) and to call the initiator immediately. This is
`accomplished by the message sent from cellular phone one to the
`software in the remote cellular phone(s).”)
`
`Beyer ’728 discloses and renders obvious 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.
`
`See e.g., Beyer ’728 at 10:32-34 (“Referring now to FIG. 3, a flow
`chart is shown of the activities provided in the present invention and
`the methodology.”), FIG. 3 (“Provide a database having a list of
`participants and corresponding cellphone numbers; Provide software
`that permits the exchange of GPS position data, messages,
`photographs and videos.”).
`
`
`13
`
`[2.g] 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;
`
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 15 of 51 PageID #:
`9901
`
`
`
`
`
`See also e.g., id. at 4:39-50 (“To initialize the communications net,
`the cellular phone one operator selects from a list, the other users (or
`all of them), that the operator desires to be part of the
`communications net. The system then polls the selected phones to
`activate and become part of the communications net. The selected
`phones then transmit their positions to all the other phones in the
`established net. Through interaction with one or more other software
`enabled cellular phones, symbols are generated on the operator’s
`display based on the participant’s latitude and longitude that is
`exchanged between the cellular phones.”).
`
`See also e.g., id. at 10:46 (“All the participant’s cellular phones that
`are a part of the communications net include an integrated or
`electronically connected GPS navigational system. Each phone can
`call the other cellular phones and request that they broadcast their
`latitude and longitude locations and status information.”
`
`
`
`
`14
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 16 of 51 PageID #:
`9902
`
`See also e.g., id. at 4:26-39 (“[T]he operator can activate different
`maps, change map scales, select which fixed entities are desired to be
`displayed, display the information concerning the symbol the operator
`has touched, initiate phone voice calls, send messages (text,
`photographs and videos), enter symbols and information
`representative of other entities, view the locations and statuses of the
`other communications net participants, establish conference calls,
`pre-establish conference sub-nets that, when activated, cause all the
`phone numbers that are specified to be conference for voice, text and
`photograph and video communications, and transmit messages to
`remote phones which cause the remote phones to make calls, verbal
`announcements, vibrate, increase sound levels and other functions.”)
`
`See e.g., id. at 2:5–17 (“In spite of the rapid advance in cellular phone
`technology, it would also be desirable to actuate a remote cellular
`phone to annunciate an audio message to alert the remote user that
`there is an emergency (or for another reason) and that the calling
`cellular phone should be called immediately. Furthermore, it would
`be desirable to cause the remote phone to display a text message,
`photograph, video clip or video transmission, to announce the caller's
`name and to be able to control a remote phone and cause the remote
`phone to call another phone number (as an example, to automatically
`establish an 800 number conference call), to vibrate, or increase the
`loudness of an announcement without any action by the remote phone
`operator.”).
`
`See, e.g., id. at 5:55–6:4 (“Another embodiment of the invention can
`include a unique feature in which cellular phone one can send a
`digital message using SMS, TCP/IP or another protocol to another
`cellular phone on the communications net by touching a display
`screen symbol on the geographical screen and then selecting the
`appropriate software switch to transmit a digital message that would
`then remotely activate a program in the remote cellular phone to play
`a recorded audio file to announce an emergency and that a call to
`cellular phone one is required immediately. Since each of the remote
`cellular phones has the same software as cellular phone one and
`includes a PDA and the ability to receive digital messages, the ability
`to control remote cellular phones to make verbal announcements,
`display images, place return calls, place calls to another phone
`number, vibrate, change sound intensity and process and display pre-
`stored data, images and video can be achieved.”).
`
`See, e.g., id. at 9:52–10:6 (“Another feature available in the cellular
`phone/PDA system shown in FIG. 1 is its ability to activate a remote
`cellular phone to make verbal announcements, display images, place
`return calls, place calls to another phone number, vibrate, change
`
`
`
`15
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 122-15 Filed 09/07/23 Page 17 of 51 PageID #:
`9903
`
`sound intensity and process and display pre-stored data, images and
`video. As an example, on the PDA screen display 16, a software
`switch will be provided that would allow cellular phone one to call in
`an emergency situation and that would basically initiate an
`emergency audio response call. Using the stylus or finger again, a
`symbol such as 30 would be touched with the stylus or finger
`indicating a call to be made. The software switch labeled “call” would
`cause other software switches to appear, one of which would be “call
`provide emergency audio response” which when touched by the
`stylus or finger 14 would cause the cellular phone one system to
`automatically call the telephone number represented by symbol 30.
`The cellular phone 30 includes software that when it receives the
`SMS or TCP/IP message, can activate an audio message that
`announces “emergency please call cellular phone one immediately.”
`The announcement would be done through the cellular phone
`speaker.” Thus, the system is capable of initiating a cellular phone
`call by touch only, initiating conference call by touch only and
`activating a remote cellular phone to announce an emergency and
`other messages and elicit the audio response in the remote cellular
`phone by touch only.”)
`
`See, e.g., id. at 11:43–55 (“Another important feature of the present
`invention is that the operator or initiator of cellular phone one can by
`touching a switch on the display, send through the PDA system, a
`signal and digital message to all the cellular phones in the
`communications net or to designated cellular phone(s), represented by
`their symbols on the geographic display, an emergency message
`which requires a response.