Case 2:22-cv-00263-JRG-RSP Document 39-6 Filed 12/27/22 Page 1 of 4 PageID #: 1148
`
`Exhibit E
`
`
`
`Exhibit E
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 39-6 Filed 12/27/22 Page 2 of 4 PageID #: 1149
`
`DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S AMENDED COMPLAINT
`
`AGIS I Complaint
`ECF 1, Case No. 2:19-cv-00362
`
`Amended Complaint
`ECF 29, Case No. 2:22-cv-00263
`
`[T]he exemplary Accused Devices allow
`users to establish groups and to exchange
`messages via interaction with Google’s
`servers and Samsung’s servers which provide
`the Samsung Cloud service, Google Cloud
`service, Google Maps service, Google
`Messages service, and Samsung Messages
`service, among other relevant services. The
`exemplary Accused Devices further allow
`users to retrieve map information from
`multiple sources including street-view maps.
`¶ 41 (’829 Patent allegations).
`
`[T]he exemplary Accused Products allow
`users to establish groups and to exchange
`messages via interaction with Samsung’s
`servers which provide the Samsung Tactical,
`TAK, and ATAK applications and services
`and Samsung Knox applications and services,
`among other relevant applications and
`services. The exemplary Accused Products
`further allow users to retrieve map
`information from multiple sources including
`street-view maps, as well as satellite
`renderings. ¶ 51 (’829 Patent allegations).
`
`The exemplary Accused Devices are
`programmed to form and join groups by
`transmitting messages. ¶ 42 (’829 Patent
`allegations).
`
`The exemplary Accused Products are
`programmed to form and join groups by
`transmitting messages. ¶ 52 (’829 Patent
`allegations).
`
`The exemplary Accused Devices are further
`programmed to facilitate participation in the
`groups by communicating with one or more
`servers and sending to and receiving location
`information, as depicted below. ¶ 43 (’829
`Patent allegations).
`
`The exemplary Accused Products are further
`programmed to facilitate participation in the
`groups by communicating with one or more
`servers and sending to and receiving location
`information, as depicted below. ¶ 53 (’829
`Patent allegations).
`
`This location information is presented on
`interactive displays on the exemplary
`Accused Devices which includes interactive
`maps and a plurality of user selectable
`symbols corresponding to other devices.
`These symbols are positioned on the map at
`positions corresponding to the locations of the
`other devices, as depicted below. ¶ 44 (’829
`Patent allegations).
`
`This location information is presented on
`interactive displays on the exemplary
`Accused Products which include interactive
`maps and a plurality of user selectable
`symbols corresponding to other devices.
`These symbols are positioned on the map at
`positions corresponding to the locations of the
`other devices as depicted below. ¶ 54 (’829
`Patent allegations).
`
`The exemplary Accused Devices are further
`programmed to permit users to request and
`display additional maps from additional
`servers by, for example, moving the map
`screen and/or by selecting satellite images or
`other types of maps. The exemplary Accused
`
`The exemplary Accused Products are further
`programmed to permit users to request and
`display additional maps by, for example,
`moving the map screen and/or by selecting
`satellite image maps. The exemplary Accused
`Products are further programmed to permit
`interaction with the display where a user may
`
`1
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 39-6 Filed 12/27/22 Page 3 of 4 PageID #: 1150
`
`DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S AMENDED COMPLAINT
`
`Devices are further programmed to permit
`interaction with the display where a user may
`select one or more symbols and where the
`exemplary Accused Devices further permit
`data to be sent to other devices based on that
`interaction. ¶ 45 (’829 Patent allegations).
`
`For example, the exemplary Accused Devices
`allow users to establish groups and to
`exchange messages via interaction with
`Google’s servers and Samsung’s servers
`which provide the Samsung Cloud service,
`Google Cloud service, Google Maps service,
`Google Messages service, and Samsung
`Messages service, among other relevant
`services. The exemplary Accused Devices
`further allow users to retrieve map
`information from multiple sources including
`street-view maps. ¶ 23 (’123 Patent
`allegations)
`
`select one or more symbols and where the
`exemplary Accused Products further permit
`data to be sent to other devices based on that
`interaction. ¶ 55 (’829 Patent allegations).
`
`For example, the exemplary Accused
`Products allow users to establish groups and
`to exchange messages via interaction with
`Samsung’s servers which provide the
`Samsung Tactical, TAK, and ATAK
`applications and services and Samsung Knox
`applications and services, among other
`relevant applications and services. The
`exemplary Accused Products further allow
`users to retrieve map information from
`multiple sources including street-view maps.
`¶ 66 (’123 Patent allegations)
`
`The exemplary Accused Devices are
`programmed to receive messages from other
`devices where those messages relate to
`joining groups, as depicted below. ¶ 24 (’123
`Patent allegations)
`
`The exemplary Accused Products are
`programmed to receive messages from other
`devices where those messages relate to
`joining groups, as depicted below. ¶ 67 (’123
`Patent allegations)
`
`The exemplary Accused Devices are further
`programmed to facilitate participation in the
`groups by communicating with a server and
`sending to and receiving location information,
`as depicted below. ¶ 25 (’123 Patent
`allegations)
`
`The exemplary Accused Products are further
`programmed to facilitate participation in the
`groups by communicating with a server and
`sending to and receiving location information,
`as depicted below. ¶ 68 (’123 Patent
`allegations)
`
`This location information is presented on
`interactive displays on the exemplary
`Accused Devices which includes interactive
`maps and a plurality of user selectable
`symbols corresponding to other devices.
`These symbols are positioned on the map at
`positions corresponding to the locations of the
`other devices, as depicted below. ¶ 26 (’123
`Patent allegations)
`
`This location information is presented on
`interactive displays on the exemplary
`Accused Products which include interactive
`maps and a plurality of user selectable
`symbols corresponding to other devices.
`These symbols are positioned on the map at
`positions corresponding to the locations of the
`other devices, as depicted below. ¶ 69 (’123
`Patent allegations)
`
`The exemplary Accused Devices are further
`programmed to permit users to request and
`
`The exemplary Accused Products are further
`programmed to permit users to request and
`
`2
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 39-6 Filed 12/27/22 Page 4 of 4 PageID #: 1151
`
`DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S AMENDED COMPLAINT
`
`display additional maps by, for example,
`moving the map screen and/or by selecting
`satellite image maps. The exemplary Accused
`Devices are further programmed to permit
`interaction with the display where a user may
`select one or more symbols and where the
`exemplary Accused Devices further permit
`data to be sent to other devices based on that
`interaction. ¶ 27 (’123 Patent allegations)
`
`display additional maps by, for example,
`moving the map screen and/or by selecting
`satellite image maps. The exemplary Accused
`Products are further programmed to permit
`interaction with the display where a user may
`select one or more symbols and where the
`exemplary Accused Products further permit
`data to be sent to other devices based on that
`interaction. ¶ 70 (’123 Patent allegations)
`
`3
`
`
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
