Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 1 of 72 PageID #: 4537
`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 1 of 72 PagelD #: 4537
`
`EXHIBIT G
`EXHIBIT G
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 2 of 72 PageID #: 4538
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 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 1, 6, 10, 16,
`19, 24, 37, 54, 55 and 84 (the “Asserted Claims”) of U.S. Patent No. 9,467,838 (the “838 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 Samsung products comprising and/or running Find My Device, an application provided on all
`
`Samsung devices with Android operating systems located on each Samsung Android-based device. 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
`
`
`
`D2-1
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 3 of 72 PageID #: 4539
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`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 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.
`
`
`
`D2-2
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 4 of 72 PageID #: 4540
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`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.
`
`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 ʼ838 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.
`
`
`
`D2-3
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 5 of 72 PageID #: 4541
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`1[P]. A computer-
`implemented method
`comprising:
`
`[1A] performing, by a
`first device:
`
`Exemplary Supporting Evidence Regarding Accused Products
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance of a computer-implemented method comprising: performing by a first device.
`
`
`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.
`
`
`Android Device Manager is the predecessor to Find My Device and has been available as a standard, pre-
`installed feature since 2013 and downloadable as a software application. See
`https://www.androidpolice.com/2017/05/17/android-device-manager-updated-first-time-two-years-
`renamed-find-device-apk-download/. The current iteration, Find My Device, often called the “new and
`improved Android Device Manager” or “rebranded Android Device Manager” is now part of the standard
`Google Play Protect suite which is “built in and enabled on all devices,” i.e., the Accused Products running
`Android OS. See, e.g., https://www.androidcentral.com/find-my-device;
`https://support.google.com/android/answer/6160491?hl=en; https://android.googleblog.com/2013/08/find-
`your-lost-phone-with-android.html;
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en;
`https://www.blog.google/products/android/google-play-protect/.
`
`Further, to the extent this element is performed at least in part by Defendants’ software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance, by a first device [the operations of claim 1].
`
`
`
`
`D2-4
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 6 of 72 PageID #: 4542
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`[1B] joining a
`communication network
`corresponding to a
`group, wherein joining
`the communication
`network comprises
`transmitting a message
`including an identifier
`corresponding to the
`group;
`
`Exemplary Supporting Evidence Regarding Accused Products
`For example, the Samsung products, such as Android-based devices include Find My Device applications
`and/or 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.
`
`The representative Samsung Galaxy S22+ is an example of the first device.
`
`Further, to the extent this element is performed at least in part by Defendants’ software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance of: joining a communication network corresponding to a group, wherein joining the
`communication network comprises transmitting a message including an identifier corresponding to the
`group.
`
`This element is infringed literally, or in the alternative, under the doctrine of equivalents.
`
`The claimed step of transmitting a message including an identifier corresponding to the group is performed
`by the communication hardware and software executed on the Accused Products, alone or in combination
`with servers and public communication carriers. In modern digital cellphone communication systems,
`such as LTE, which is packet-based, SMS messages are transmitted at least partially via Internet Protocol,
`or its equivalent.
`
`The Accused Products require a user to join the corresponding network by signing-in to the device with an
`identifier (e.g., Google Account). This join limitation is performed on the Accused Products via Find My
`Device and related services. The sign-in process may take place within the Android settings and Find My
`Device software on the Accused Product or in the settings prompts of the Accused Product. Alternatively,
`the sign-in process may partially or completely take place using credentials already provided when the user
`associates a Account with the Accused Product, e.g., during initial setup of the Accused Product. Subject
`to discovery, one or more additional or substitute identifiers may to correspond to the group. The sign-in
`process involves a user entering its Account and additional authentication data on the interface of the
`Accused Product and sending a message containing the Account and additional authentication data over a
`
`
`
`D2-5
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 7 of 72 PageID #: 4543
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`network to the group. The group comprises the multiple identifiers, individuals, profiles, and/or devices
`associated with the group. The below depicts a group of three devices.
`
`
`
`
`https://play.google.com/store/apps/details?id=com.google.android.apps.adm&hl=en_US
`
`
`Further regarding Find My Device, the Accused Products alternatively require a user to send a request
`containing the identifier (e.g., Account). Subject to discovery, additional identifiers may be assigned or
`used to correspond to the group. The request may be an invitation or message that associates or relates a
`Account with additional Accounts for the purposes of sharing locations within the group. The group
`comprises the multiple identifiers, individuals, profiles, and/or devices associated with the group. The
`relationships or associations may comprise more than two devices.
`
`https://www.blog.google/products/maps/share-your-trips-and-real-time-location-google-maps/
`
`
`
`
`D2-6
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 8 of 72 PageID #: 4544
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`Source: https://support.google.com/accounts/answer/3265955?hl=en.
`
`Users can log-in their account using an email associated with the account or using a account.
`
`
`
`
`
`
`
`D2-7
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 9 of 72 PageID #: 4545
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://www.blog.google/products/android/google-play-protect/.
`
`
`Source:
`
`
`
`D2-8
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 10 of 72 PageID #:
`4546
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://support.google.com/android/answer/6160491
`
`
`
`
`
`
`D2-9
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 11 of 72 PageID #:
`4547
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://support.google.com/android/answer/6160491
`
`
`
`
`
`
`D2-10
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 12 of 72 PageID #:
`4548
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`https://support.google.com/android/answer/6160491
`Further, to the extent this element is performed at least in part by Samsung’s software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`
`
`
`
`
`D2-11
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 13 of 72 PageID #:
`4549
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`The Accused Products require a user to join the corresponding network by: signing-in to the device with an
`identifier (e.g., Account) or linking the device to the identifier by remote means. The message received by
`the first device relates to the second device joining into a group with the first device.
`
`
`
`D2-12
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 14 of 72 PageID #:
`4550
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`D2-13
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 15 of 72 PageID #:
`4551
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`
`
`D2-14
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 16 of 72 PageID #:
`4552
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`
`
`D2-15
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 17 of 72 PageID #:
`4553
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`Further, to the extent this element is performed at least in part by Defendants’ software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`
`
`
`D2-16
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 18 of 72 PageID #:
`4554
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`[1C] 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
`information comprising
`one or more locations of
`one or more respective
`second devices included
`in the group;
`
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance of: 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 information
`comprising one or more locations of one or more respective second devices included in the group.
`
`The claimed steps of sending first location information to a server and receiving second location
`information from the server are both performed by the communication hardware and software executing on
`the Accused Product, alone or in combination with servers and communication carriers.
`
`
`For example, Find My Device allows Android OS users to track other phones, tablets, and computers
`linked to the same Account. For example, Find My Device provides a list of the status for each device that
`tracks location status, response to location requests / time since last update, and actual locations. Find My
`Device is pre-loaded on the Accused Products as part of Google Play Protect and is also included as part of
`Google Play Services and Google Mobile Services.
`
`Find My Device is configured to send device locations to the server and to receive device locations
`regarding other devices.
`
`
`
`
`D2-17
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 19 of 72 PageID #:
`4555
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`D2-18
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 20 of 72 PageID #:
`4556
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`
`
`D2-19
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 21 of 72 PageID #:
`4557
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`
`
`
`D2-20
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 22 of 72 PageID #:
`4558
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`The Accused Products require a user to join the corresponding network by: signing-in to the device with an
`identifier (e.g., Google Account) or linking the device to the identifier by remote means. The message
`received by the first device relates to the second device joining into a group with the first device.
`
`
`
`D2-21
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 23 of 72 PageID #:
`4559
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`
`
`D2-22
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 24 of 72 PageID #:
`4560
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`Further, to the extent this element is performed at least in part by Defendants’ software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`
`
`
`D2-23
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 25 of 72 PageID #:
`4561
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`[1D] 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;
`
`Exemplary Supporting Evidence Regarding Accused Products
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance of: 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.
`
`The claimed step of presenting an interactive display is performed by the modules in the Android OS and
`other software responsible for displaying information on the Accused Products display screen, in
`combination with other support modules.
`
`The Accused Products via Find My Device applications and/or services, which are included on the
`Accused Products, display at least one user-selectable map with symbols corresponding to respective other
`devices. Each symbol corresponds to the approximate device-location of the Accused Products. The maps
`are georeferenced maps (e.g., standard map, transit, and satellite maps) and points on these maps
`correspond to spatial coordinates.
`
`The Accused Products via the Find My Device applications and/or servicesdisplay, to the user on the
`display of the first device, a map with one or more symbols corresponding to one or more second devices.
`The map is interactive because the user may control the display of the map, e.g., pan, zoom, and/or effect
`change to the map in an otherwise interactive manner. The map is georeferenced for at least the reason that
`one or more symbols are associated with spatial locations, i.e., coordinates. The symbols are user-
`selectable because a user may touch the display to select the device associated with the symbol.
`
`Exemplary Screenshots
`
`
`
`
`D2-24
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 26 of 72 PageID #:
`4562
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`
`
`D2-25
`
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 27 of 72 PageID #:
`4563
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`
`
`
`
`
`
`D2-26
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 28 of 72 PageID #:
`4564
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`[1E] sending, to a
`second server, a request
`for second
`georeferenced map data
`different from the first
`georeferenced map data;
`
`Exemplary Supporting Evidence Regarding Accused Products
`Further, to the extent this element is performed at least in part by Defendants’ software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Samsung
`and to the extent Defendants require additional information in accordance with P.R. 3-1 and for any other
`reasons.
`Samsung infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing
`to the performance of: sending, to a second server, a request for second georeferenced map data different
`from the first georeferenced map data.
`
`The claimed step of sending a request for a second georeferenced map is performed by the communication
`hardware and software executing on the Accused Products, alone or in combination with servers and
`communication carriers.
`
`The Accused Products, via Find My Device, display, to the user on the display of the first device, a map
`with one or more symbols corresponding to one or more second devices. The first device requests different
`map data from a second server. For example, the request occurs responsive to user input (e.g., zoom, drag,
`pan, change focus, change map type, refresh or reload request, symbol or device selection, another device
`or user selection, change in position of first device, change in position of a second device). For example,
`the request occurs responsive to an automatic and/or pre-determined control caused by an instruction from
`within the first device or from the one or more second devices, e.g. a refresh or in response to real-time
`changes in position. The different map data includes an update to the first data or a replacement of the first
`data. On information and belief, the new map data may come from one or more second sources such as
`multiple virtual or physical servers.
`
`For example, Find My Device requests and receives map data from various sources and servers, both
`internally and externally. In response to one of a number of device actions (e.g. zoom, pan, drag or change
`focus, change map type, select another device), new map data is retrieved to complete the user’s action and
`the displayed map is replaced or updated accordingly. The new map data may come from one of various
`sources and servers. The Accused Products request and receive the map data described above.
`
`
`
`
`
`D2-27
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 29 of 72 PageID #:
`4565
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`On information and belief, the Find My Device maps include data from various sources.
`
`https://www.google.com/intl/en_us/help/legalnotices_maps.html
`
`
`
`
`Exemplary Screenshots
`
`
`
`
`D2-28
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 72-8 Filed 06/28/23 Page 30 of 72 PageID #:
`4566
`Exhibit D2 – Claim Chart for U.S. Patent No. 9,467,838 Against Samsung Accused Products
`
`Claim – 9,467,838
`
`Exemplary Supporting Evidence Regarding Accused Products
`
`
`
`
`