Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 1 of 90 PageID #: 4320
`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 1 of 90 PagelD #: 4320
`
`EXHIBIT E
`EXHIBIT FE
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 2 of 90 PageID #: 4321
`Exhibit C2 for U.S. Patent No. 8,213,970 Against Samsung Accused Products
`
`Based on information presently available, AGIS Software Development LLC (“AGIS”) contends that Defendants Samsung
`
`Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Defendants” or “Samsung”) infringe claims 2, 10-13 (the
`“Asserted Claims”) of U.S. Patent No. 8,213,970 (the “’970 Patent”) through the Accused Products which are manufactured, sold,
`offered for sale, used, imported into the United States, and/or exported from the United States by Samsung. The Accused Products
`include Samsung Android-based devices comprising and/or running Find My Device applications and services.
`
`The Accused Products include, but are not limited to, the following Samsung products: Galaxy S22+, Galaxy S20 Tactical
`Edition, Galaxy XCover FieldPro, Galaxy XCover Pro, GT-I7500 Galaxy, i5700 Galaxy Spica, Galaxy S, Galaxy SL, Galaxy S II,
`Galaxy S Advance, Galaxy S III, Galaxy S Duos, Galaxy S III Mini, Galaxy S II Plus, Galaxy S4, Galaxy S4 Active, Galaxy S4 Mini,
`Galaxy S4 Zoom, Galaxy S Duos 2, Galaxy S III Slim, Galaxy S5, Galaxy S III Neo, Galaxy S5 Active, Galaxy S5 Mini, Galaxy S
`Duos 3, Galaxy S5 Plus, Galaxy S6, Galaxy S6 Edge, Galaxy S5 Neo, Galaxy S6 Active, Galaxy S6 Edge+, Galaxy S7, Galaxy S7
`Edge, Galaxy S7 Active, Galaxy S8, Galaxy S8+, Galaxy S8 Active, Galaxy S9, Galaxy S9+, Galaxy S10e, Galaxy S10, Galaxy S10+,
`Galaxy S10 5G, Galaxy S21, Galaxy S20 FE, Galaxy Alpha, Galaxy A3, Galaxy A5, Galaxy A7, Galaxy A8, Galaxy A3, Galaxy A5,
`Galaxy A7, Galaxy A8, Galaxy A8+, Galaxy A6, Galaxy A6+, Galaxy A8 Star, Galaxy A7, Galaxy A9, Galaxy A6s, Galaxy A8s,
`Galaxy A30, Galaxy A50, Galaxy A10, Galaxy A20, Galaxy A40, Galaxy A70, Galaxy A20e, Galaxy A80, Galaxy A40s, Galaxy A60,
`Galaxy A10s, Galaxy A20s, Galaxy A10e, Galaxy C5, Galaxy C7, Galaxy C9, Galaxy C9 Pro, Galaxy C7 Pro, Galaxy C5, Pro, Galaxy
`C8, Galaxy J, Galaxy J1, Galaxy J5, Galaxy J7, Galaxy J2, Galaxy J1 Ace, Galaxy J1 Nxt, Galaxy J1 Mini, Galaxy J5 (2016), Galaxy
`J3 Pro, Galaxy J7, Galaxy J Max, Galaxy J1 Ace Neo, Galaxy J1 (2016), Galaxy J5 Prime, Galaxy J7, Prime, Galaxy J1 Mini Prime,
`Galaxy J2 Prime, Galaxy J3 Emerge, Galaxy J7 V, Galaxy J3 Prime, Galaxy J7 Pro, Galaxy J7 Max, Galaxy J7 Nxt, Galaxy J3 Luna
`Pro, Galaxy J7 Sky Pro, Galaxy J7+, Galaxy J2 Pro, Galaxy J7 Prime 2, Galaxy J7 Duo, Galaxy J4, Galaxy J6, Galaxy J3 (2018), Galaxy
`J7 (2018), Galaxy J2 Core, Galaxy J4+, Galaxy J6+, Galaxy J4 Core, Galaxy M, Galaxy M10, Galaxy M20, Galaxy M30, Galaxy M40,
`Galaxy E5, Galaxy E7, Galaxy Grand, Galaxy Core, Galaxy Core Plus, Galaxy Grand 2, Galaxy Grand Neo, Galaxy Core Prime, Galaxy
`Grand Prime Plus, Galaxy Grand Prime Pro, Galaxy Mega 5.8, Galaxy Mega 6.3, Galaxy Mega 2, Galaxy Mini, Galaxy Mini 2, Galaxy
`Trend, Galaxy Trend Lite, Galaxy Trend Plus, Galaxy Ace, Galaxy Ace Plus, Galaxy Ace 2, Galaxy Ace 3, Galaxy Ace Style, Galaxy
`Ace 4, Galaxy On7, Galaxy On5, Galaxy On5 Pro, Galaxy On7 Pro, Galaxy On8, Galaxy On Nxt, Galaxy On Max, Galaxy On7 Prime,
`Galaxy On6, Galaxy On8 (2018), Galaxy R, Galaxy R Style, Galaxy Y, Galaxy Y Duos, Galaxy Young, Galaxy Young 2, Galaxy
`Pocket, Galaxy Pocket Plus, Galaxy Pocket Neo, Galaxy Pocket Duos, Galaxy Pocket 2, Galaxy U, Galaxy Neo, Galaxy Pro, Galaxy
`Precedent, Galaxy Z, Galaxy Rush, Galaxy 5, Galaxy W, Galaxy Fit, Galaxy Gio, Galaxy Prevail, Galaxy Nexus, Galaxy Discover,
`Galaxy Reverb, Galaxy Stellar, Galaxy Appeal, Galaxy Express, Galaxy Express 2, Galaxy Fame, Galaxy Star, Galaxy Win, Galaxy
`Win Pro, Galaxy Star Pro, Galaxy Fame Lite, Galaxy Round, Galaxy Light, Galaxy V, Galaxy V Plus, Galaxy V2, Galaxy K Zoom,
`Galaxy Folder, Galaxy Active Neo, Galaxy Folder 2, Galaxy Fold, Galaxy Note, Galaxy Note II, Galaxy Note 3, Galaxy Note 4, Galaxy
`Note Edge, Galaxy Note 5, Galaxy Note 7, Galaxy Note Fan Edition, Galaxy Note 8, Galaxy Note 9, Galaxy Note 10, Galaxy Note 10+,
`Galaxy Note 10+ 5G, Galaxy Tab, Galaxy Tab 7.0, Galaxy Tab 10.1, Galaxy Tab 10.1N, Galaxy Tab 10.1v, Galaxy Tab 8.9, Galaxy
`Tab 7.0 Plus, Galaxy Tab 7.7, Galaxy Tab 2 7.0, Galaxy Tab 2 10.1, Galaxy Tab 3 7.0, Galaxy Tab 3 Lite 7.0, Galaxy Tab 3 8.0, Galaxy
`C2-1
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 3 of 90 PageID #: 4322
`Exhibit C2 for U.S. Patent No. 8,213,970 Against Samsung Accused Products
`
`Tab 3 10.1, Galaxy Tab 4 7.0, Galaxy Tab 4 8.0, Galaxy Tab 4 10.1, Galaxy Tab Pro 8.4, Galaxy Tab Pro 10.1, Galaxy Tab Pro 12.2,
`Galaxy Tab S 8.4, Galaxy Tab S 10.5, Galaxy Tab S2 8.0, Galaxy Tab S2 9.7, Galaxy Tab S3 9.7, Galaxy Tab S4 10.5, Galaxy Tab E
`8, Galaxy Tab E 9.6, Galaxy Tab A 8.0, Galaxy Tab A 9.7, Galaxy Tab A 6.0, Galaxy Tab A 7.0, Galaxy Tab A 10.1, Galaxy Tab A
`10.5, Galaxy Tab Pro S 12.0, Galaxy Book 10.6, Galaxy Book 12.0, Galaxy Tab Active, Galaxy Tab Active 2, Galaxy View, Galaxy
`Note 8.0, Galaxy Note 10, Galaxy Note 10.1, Galaxy Note Pro 12.2, Galaxy Gear, Gear Sport, Gear S3 Frontier, Galaxy Watch, Galaxy
`Watch Active, and Galaxy Watch Active 2.
`
`The Accused Products comprise the following versions (and all intervening updates and sub-versions) of the Android mobile
`operating systems: Android 1.5 (Cupcake); Android 1.6 (Donut); Android 2.0 (Éclair); Android 2.2 (Froyo); Android 2.3 (Gingerbread);
`Android 3.0 (Honeycomb); Android 4.0 (Ice Cream Sandwich); Android 4.1 (Jelly Bean); Android 4.4 (KitKat); Android 5.0 (Lollipop);
`Android 6.0 (Marshmallow); Android 7.0 (Nougat); Android 8.0 (Oreo); Android 9 (Pie); Android 10; Android 11; Android 12; Android
`12L; Android 13; Android One; Android Go; and any variants thereof, imported with the aforementioned Samsung products during and
`after 2016.
`
`Samsung directly infringes each of the Asserted Claims by providing, using, importing, testing, selling, offering for sale,
`importing into the United States, and/or exporting from the United States the Accused Products in violation of 35 U.S.C. § 271(a).
`
`Samsung indirectly infringes the Asserted Claims in violation of 35 U.S.C. § 271(b) by inducing third parties, including its users
`and/or customers, to directly infringe through its operation and use of the Accused Products. Samsung has knowingly and intentionally
`induced this direct infringement by, inter alia, (i) selling, offering to sell, importing, exporting, or otherwise providing the Accused
`Products to third parties with the intent that the Accused Products will be operated and used in a manner that practices the Asserted
`Claims; and (ii) marketing and advertising the Accused Products. Samsung’s marketing and promotional materials for the Accused
`Products are found, for example, on Samsung’s website, and in App stores of operating systems for which the Accused Products are
`made available. For example, Samsung’s website offers customers downloadable User Manuals for the Accused Products that instruct
`customers to, among other things, use the accused services in the Accused Products. Samsung’s website also offers support to customers,
`including instruction to, among other things, use the Accused Products to share location information with a group of users. On
`information and belief, Samsung directs customers to third-party sources to use the Accused Products in an infringing manner. On
`information and belief, Samsung knows that its actions will result in infringement of the Asserted Claims, or subjectively believes that
`there is a high probability that its actions will result in infringement of the Asserted Claims but has taken deliberate actions to avoid
`learning these facts.
`
`Samsung also contributorily infringes each of the Asserted Claims in violation of 35 U.S.C. § 271(c) by selling,
`
`importing, offering for sale, and otherwise providing the Accused Products which, when used, directly infringe the Asserted Claims.
`The Accused Products constitute a material part of the Asserted Claims.
`
`
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`C2-2
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 4 of 90 PageID #: 4323
`Exhibit C2 for U.S. Patent No. 8,213,970 Against Samsung Accused Products
`
`On information and belief, the charted versions of the Accused Products are representative of all versions of the Accused
`Products, including but not limited to all variants of the Accused Products made, sold, offered for sale, or used on any version of the
`Android operating systems.
`
`AGIS does not concede that any claims of the ʼ970 Patent that are not listed below are not infringed by the identified Accused
`Products. Moreover, the citations to certain documents and other information below are intended to be exemplary only and in no way
`foreclose AGIS from citing or relying on additional documents, information, source code, and/or testimony at a later time. These
`contentions are preliminary in nature, and an analysis of Samsung’s products, internal documentation, source code, and/or testimony
`from relevant witnesses may more fully and accurately describe the infringing features of its Accused Products. Accordingly, AGIS
`reserves the right to supplement, correct, modify, and/or amend these contentions once such additional information is made available to
`AGIS. Furthermore, AGIS reserves the right to supplement, correct, modify, and/or amend these contentions as discovery in this case
`progresses; in view of the Court’s claim construction order(s); in view of any positions taken by Samsung including, but not limited to,
`positions on claim construction,1 invalidity, and/or non-infringement; and in connection with the preparation and exchange of expert
`reports.
`
`The contents of every below claim cell on which another claim cell depends are expressly incorporated by reference in that
`dependent cell, as if set forth in their entirety therein.
`
`
`
`
`1 The construction of claim terms herein is consistent with the constructions in AGIS Software Dev. LLC v. Huawei Device USA, Inc.,
`No. 2:17-cv-00513-JRG, Dkt. No. 205 (Lead Case) (E.D. Tex. Oct. 10, 2018) and AGIS Software Dev. LLC v. Google, LLC, No. 2:19-
`cv-00361-JRG, Dkt. No. 147 (Lead Case) (E.D. Tex. Dec. 20, 2020). AGIS reserves the right to update its constructions and contentions
`in view of this Court’s claim construction order.
`
`
`
`C2-3
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`

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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 5 of 90 PageID #: 4324
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`
`
`
`
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Samsung infringes directly and indirectly, induces others to infringe, and/or contributes to the infringement of 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.
`
`The Accused Products meet the claim limitations by providing device-location tracking features such as those
`features described below. For example, the Accused Products meet the claim limitations because they include
`Find My Device and related services. The Find My Device application and services are provided on the
`Accused Products with built-in services accessible through Settings > Google > Security > Find My Device.
`Samsung provides multiple Accused Devices which each include the Find My Device applications (Android
`application and web application) and each which are compatible with Android requirements. For example,
`Samsung provides a first sender device with Find My Device and a second recipient device with Find My
`Device. Samsung provides numerous sender and recipient devices such that a sender device with Find My
`Device can communicate with multiple other recipient devices via Find My Device. For example, the network
`of participants comprises multiple Samsung devices associated via Find My Device and/or Google accounts and
`relationships. For example, the network of participants comprises the Find My Device network and/or the
`Google account and relationships.
`Each Accused Samsung device has a processor capable of executing the Android operating system, DRAM
`memory, and RF receiver and transmitter modules, as show in the images taken from a “teardown” of the
`exemplary Samsung Galaxy S22+.
`
`
`Claim —
`8,213,970
`2[P]. 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;
`
`
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`C2-4
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 6 of 90 PageID #: 4325
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
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`C2-5
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 7 of 90 PageID #: 4326
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
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`C2-6
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 8 of 90 PageID #: 4327
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Source: https://www.youtube.com/watch?v=qyEmChOMAN0&t=428s
`
`On information and belief, the “teardown” of the Samsung Galaxy S22+ is representative of the Accused
`Devices.
`
`
`
`C2-7
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 9 of 90 PageID #: 4328
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`The Accused Products are configured to permit Samsung customers to log in with their Google Account to
`access applications and services with their respective accounts.
`
`
`Source: https://support.google.com/accounts/answer/3265955?hl=en.
`
`
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`C2-8
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 10 of 90 PageID #:
`4329
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Users log-in to their Google account using an email associated with the Google account or using a Google
`account.
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`
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`C2-9
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 11 of 90 PageID #:
`4330
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Source: https://support.google.com/maps/answer/7326816?co=GENIE.Platform%3DAndroid&hl=en.
`
`The Accused Samsung devices include the device-location tracking features of Find My Device as provided in
`the claim limitation herein.
`
`
`
`Source: https://www.blog.google/products/android/google-play-protect/.
`
`Pursuant to the Discovery Order and to the extent any elements of this limitation are met at least in part by
`software components, AGIS reserves the right to amend these contentions upon inspection of Find My Device
`source code.
`
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to
`the infringement of a data transmission means that facilitates the transmission of electronic files between said
`PDA/cell phones in different locations. See, e.g., claim 2[P], which is incorporated herein by reference in its
`entirety.
`
`The Accused Products meet this limitation.
`
`
`[2A] a data
`transmission
`means that
`facilitates the
`transmission of
`electronic files
`between said
`PDA/cell phones
`
`C2-10
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 12 of 90 PageID #:
`4331
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`in different
`locations;
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`For example, the claimed data transmission means is the communication network server interface within each
`Accused Device, including the communication interfaces provided via Qualcomm Snapdragon chip and a
`wireless transmitter for communications via 3G or LTE or 5G. These communication interfaces provide server
`functionality for facilitating the transmission of electronic files between Accused Devices
`
`Each Accused Samsung device has a processor capable of executing the Android operating system, DRAM
`memory, and RF receiver and transmitter modules, as show in the images taken from a “teardown” of the
`exemplary Samsung Galaxy S22+.
`
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`C2-11
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 13 of 90 PageID #:
`4332
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
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`C2-12
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 14 of 90 PageID #:
`4333
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Source: https://www.youtube.com/watch?v=qyEmChOMAN0&t=428s
`
`For example, Samsung Android-based devices are designed to communicate and exchange messages with
`backend physical and/or virtual servers. For example, Find My Device is designed to communicate and
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`C2-13
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 15 of 90 PageID #:
`4334
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`[2B] a sender
`PDA/cell phone
`and at least one
`recipient
`PDA/cell phone
`for each
`electronic
`message;
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`exchange messages with backend physical and/or virtual Find My Device servers in order to process requests
`for processing and the exchange of data between Samsung Android-based devices. On information and belief,
`Samsung provides backend services for Find My Device as part of the Find My Device offering and/or via
`license and/or other agreement with one or more third parties.
`
`On information and belief, the “teardown” of the Samsung Galaxy S22+ is representative of the Accused
`Devices. Moreover, Samsung directly infringes each of the Asserted Claims by using, importing, testing,
`repairing, selling, importing, exporting, and/or offering for sale the Accused Products in violation of 35 U.S.C.
`§ 271(a).
`
`Pursuant to the Discovery Order and to the extent any elements of this limitation are met at least in part by
`software components, AGIS reserves the right to amend these contentions upon inspection of Find My Device
`source code.
`
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to
`the infringement of a sender PDA/cell phone and at least one recipient PDA/cell phone for each electronic
`message. See, e.g., claim 2[A] and 2[P], which are incorporated herein by reference in their entirety.
`
`For example, each Accused Product which is a Samsung Android-based device is configured to be a sender
`PDA/cell phone and a recipient PDA/cell phone. Samsung provides multiple Accused Devices which each
`include the Find My Device applications (Android application and web application) and each which are
`compatible with Android requirements. For example, Samsung provides a first sender device with Find My
`Device and a second recipient device with Find My Device. Samsung provides numerous sender and recipient
`devices such that a sender device with Find My Device can communicate with multiple other recipient devices
`via Find My Device. Each Samsung Android-based device is capable for exchanging electronic messages via
`Find My Device and any related services. Each claimed electronic message is sent from at least one Accused
`Product to another Accused Product.
`
`
`
`C2-14
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 16 of 90 PageID #:
`4335
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`[2C] 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;
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Pursuant to the Discovery Order and to the extent any elements of this limitation are met at least in part by
`software components, AGIS reserves the right to amend these contentions upon inspection of Find My Device
`source code.
`
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to
`the infringement of 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., claims 2[A]-[B], which are incorporated herein by reference in their entirety.
`
`
`For example, Find My Device is configured to permit each Samsung Android-based device to track another
`Samsung Android-based device. When a user signs into a Samsung Android-based device with an email or
`account and the user successfully authenticates with the Find My Device application and/or service, the
`Samsung Android-based device is configured to send remote commands using Find My Device. A non-
`exhaustive list of remote commands include a locate, lock, secure, play sound, erase, and wipe. For example,
`Find My Device is configured to provide a listing of options to create a command and further options to create
`specific commands. For example, Find My Device is configured to provide a listing of options to create a lock
`message, such as add message, add phone number, add PIN, and lock. Find My Device provides a list of the
`status for each device within the same Google Account” that tracks location status, responses to location
`requests / time since last update, and actual locations. See, e.g.,
`https://support.google.com/android/answer/6160491?hl=en.
`
`C2-15
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 17 of 90 PageID #:
`4336
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://support.google.com/android/answer/6160491?hl=en
`
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`C2-16
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 18 of 90 PageID #:
`4337
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
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`C2-17
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 19 of 90 PageID #:
`4338
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
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`C2-18
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 20 of 90 PageID #:
`4339
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`The sender PDA/cellphone and the forced message alert software can specify a response to be sent to the
`recipient PDA/cellphone, including, for example, entering a custom “Lock screen message,” entering a “Phone
`
`C2-19
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 21 of 90 PageID #:
`4340
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`number” to call, “emergency call,” entering the recipient’s password, pushing or swiping the unlock button, or
`fingerprint recognition to unlock the phone.
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`
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`C2-20
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 22 of 90 PageID #:
`4341
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
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`C2-21
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 23 of 90 PageID #:
`4342
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
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`Exemplary Supporting Evidence Regarding Accused Products
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`C2-22
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 24 of 90 PageID #:
`4343
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
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`C2-23
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 25 of 90 PageID #:
`4344
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
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`Claim —
`8,213,970
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`Exemplary Supporting Evidence Regarding Accused Products
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`C2-24
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 26 of 90 PageID #:
`4345
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
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`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
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`https://www.androidcentral.com/how-track-android-phone
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`C2-25
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 27 of 90 PageID #:
`4346
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
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`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.androidcentral.com/how-track-android-phone
`C2-26
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 28 of 90 PageID #:
`4347
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.androidcentral.com/how-track-android-phone
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`C2-27
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 29 of 90 PageID #:
`4348
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.androidcentral/com/find-my-device
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`C2-28
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 30 of 90 PageID #:
`4349
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.androidcentral.com/find-my-device
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`C2-29
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 31 of 90 PageID #:
`4350
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en_US
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`
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`C2-30
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 32 of 90 PageID #:
`4351
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Claim —
`8,213,970
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en_US
`
`Pursuant to the Discovery Order and to the extent any elements of this limitation are met at least in part by
`software components, AGIS reserves the right to amend these contentions upon inspection of Find My Device
`source code.
`
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to
`the infringement of 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. See, e.g., claim 2C, which is incorporated herein by reference in its entirety.
`
`
`[2D] means for
`attaching a
`forced message
`alert software
`packet to a voice
`or text message
`creating a forced
`
`C2-31
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`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 33 of 90 PageID #:
`4352
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`For example, the claimed means for attaching a forced message alert software packet to a voice or text message
`is the Accused Samsung device configured to perform the set of instructions (algorithm) that attaches the alert
`packet to the message for delivery via the Find My Device application and/or services.
`
`For example, the Sender device electronically transmits the message as a remote command to the Receiver
`device using Find My Device. Because the recipient phones have no control over the receipt of the message, the
`message is “forced.”
`
`The sender device sends a request and in response, the receiver devices sends an automatic acknowledgement
`which confirms that the device is in lock mode (also called “secured”) and provides the recipient’s location. For
`example, this automatic acknowledgement is shown to the Sender when the Find My Device App displays “lock
`requested” and also identified as “locked” and “secured.”
`
`The forced message alert causes automatic responses as shown in the response list in 2[C] above.
`
`The algorithm is set forth in the specification at:
`
`
`Referring now to FIG. 2, in order to set up a communication network that utilizes the forced
`message alert system, the forced message alert software application program must be installed on
`a plurality of PCs and/or PDA/cell phones. The application will provide for a forced alert message
`that can be designated for transmission according to several criteria: a.) A single PC and/or
`PDA/cell phone, b.) The list of users currently participating in the network, and c.) A user or
`administrator predefined list of network participants.
`
` A
`
` required response list which will be either preinstalled in the phone application software or sent
`with the forced message alert will be presented to the user operator upon receipt of the forced
`message. When the forced text or voice alert is received, the user operator is presented with the
`required response list. In order to clear the forced text message alert from the user operator’s PC
`or PDA/cell phone display, the user operator is required to select a reply from this list. If the alert
`is a voice message, the message keeps repeating at a defined rate until the user operator selects
`from the required response list. A military default response list would typically consist of choices
`
`C2-32
`
`Claim —
`8,213,970
`message alert
`that is
`transmitted by
`said sender
`PDA/cell phone
`to the recipient
`PDA/cell phone,
`
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`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-6 Filed 06/28/23 Page 34 of 90 PageID #:
`4353
`Exhibit C2 – U.S. Patent No. 8,213,970 – Samsung Galaxy S22+
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`such as, “will comply,” “will not comply,” and “have complied.” However, depending on the
`nature of the industry in which the users in the communication network are in, this default response
`list could vary significantly.
`
`The contact and identifying information for each PC and PDA/cell phone that is anticipated to be
`a member of the communication network and the default response list is loaded on to every member
`PC and PDA/cell phone in the preferred embodiment. This step makes sure the each user of the
`communication network has, in addition to the necessary software, the necessary information to
`send a forced message alert to any and every known member of the communication network. When
`operating in an open network mode where all that know the password can join the network, the
`default list is created or expanded as new members join.
`
`Referring now to FIG. 3A and FIG. 3B, the process of sending a forced message alert from a PC
`or PDA/cell phone begins with a sender selecting the forced message alert software application
`program on a sender PC or PDA/cell phone. The sender can then select by said sender PC or
`PDA/cell phone to type a text message or record a voice message or select the text alert or voice
`alert from a list. Once the sender types a text message or records a voice message or selects a voice
`or text message or records a voice message or selects a voice or text message on said PC or
`PDA/cell phone, the sender can then use a soft switch or selection from a list to send the forced
`