`Case 2:22-cv-00263-JRG-RSP Document 67-2 Filed 06/16/23 Page 1 of 4 PagelD #: 2338
`
`EXHIBIT B
`EXHIBIT B
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 67-2 Filed 06/16/23 Page 2 of 4 PageID #: 2339
`
`Additional Intrinsic
`Evidence
`’970 Patent at FIGs. 1a, 1b;
`4:12-18; 4:55-59; 5:10-44;
`6:1-65.
`
`Extrinsic Support
`
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`connection with this claim
`term.
`
`EXHIBIT B: Plaintiff AGIS Software Development LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`AGIS’s Proposed
`Construction
`’970 Patent Claim 2 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”
`’970 Patent Claim 2 Governed by 35 U.S.C. §
`112(6).
`
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`means for displaying a
`geographical map with
`georeferenced entities
`on the display of the
`sender PDA/cell phone
`
`1
`
`2
`
`means for obtaining
`location and status data
`associated with the
`
`’970 Patent at Abstract;
`FIGs. 1a, 1b; 3:52-67;
`4:12-18; 4:60-5:27; 5:51-
`57; 6:1-7:4.
`
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 67-2 Filed 06/16/23 Page 3 of 4 PageID #: 2340
`
`No. Claim Term/Phrase
`
`recipient PDA/cell
`phone
`
`Patent/Claims
`
`Additional Intrinsic
`Evidence
`
`Extrinsic Support
`
`connection with this claim
`term.
`
`3
`
`means for presenting a
`recipient symbol on the
`geographical map
`corresponding to a
`correct geographical
`location of the recipient
`PDA/cell phone
`
`’970 Patent at FIGs. 1a, 1b;
`4:12-46; 5:10-7:4.
`
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`connection with this claim
`term.
`
`EXHIBIT B: Plaintiff AGIS Software Development LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`AGIS’s Proposed
`Construction
`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”
`’970 Patent Claim 2 Governed by 35 U.S.C. §
`112(6).
`
`Function: “presenting a
`recipient symbol on the
`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
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 67-2 Filed 06/16/23 Page 4 of 4 PageID #: 2341
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`Additional Intrinsic
`Evidence
`
`Extrinsic Support
`
`EXHIBIT B: Plaintiff AGIS Software Development LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`AGIS’s Proposed
`Construction
`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”
`’970 Patent Claim 2 Plain and ordinary meaning.
`
`predetermined network
`of participants, wherein
`each participant has a
`similarly equipped
`PDA/cell phone
`
`which triggers the
`forced message alert
`software application
`program to take control
`of the recipient
`PDA/cell phone
`status data
`
`4
`
`5
`
`6
`
`
`
`’970 Patent at 2:7-35; 3:29-
`40; 3:52-67; 4;12-46; 5:17-
`27; 7:8-16; 7:47-63.
`
`AGIS Software Dev. LLC v.
`T-Mobile USA, Inc., No.
`2:21-cv-00072-JRG, Dkt.
`213 (E.D. Tex. Nov. 10,
`2021)
`
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`connection with this claim
`term.
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`connection with this claim
`term.
`
`’970 Patent Claim
`10
`
`Plain and ordinary meaning.
`
`’970 Patent at FIGs. 1b, 4;
`8:37-57.
`
`’970 Patent Claims
`2, 10
`
`Plain and ordinary meaning.
`
`’970 Patent at Abstract;
`FIG. 1a, 1b; 3:52-67; 4:12-
`18; 5:17-27; 6:38-7:4.
`
`AGIS may rely on the
`expert testimony of
`Mr. Michael Brogioli in
`connection with this claim
`term.
`
`
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