Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 1 of 123 PageID #: 1
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
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`§
`Case No.
`§
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`JURY TRIAL DEMANDED
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`§
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`§
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`§
`§
`§
`§
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`v.
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`RAYTHEON TECHNOLOGIES CORP.,
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`
`Defendant.
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`
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`Plaintiff AGIS Software Development LLC (“AGIS Software” or “Plaintiff”) files this
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`Complaint against Defendant Raytheon Technologies Corporation (“Raytheon” or “Defendant”)
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`for patent infringement under 35 U.S.C. § 271 and alleges as follows:
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`THE PARTIES
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`1.
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`Plaintiff AGIS Software is a limited liability company, organized and existing
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`under the laws of the State of Texas, and maintains its principal place of business at 100 W.
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`Houston Street, Marshall, Texas 75670. AGIS Software is the owner of all right, title, and interest
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`in and to U.S. Patent Nos. 8,213,970, 9,445,251, 9,467,838, 9,820,123, and 9,749,829 (the
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`“Patents-in-Suit”).
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`2.
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`On information and belief, Defendant Raytheon is a corporation organized and
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`existing under the laws of the State of Delaware and maintains a place of business in this District,
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`at 2501 West University Drive, McKinney, Texas 75701. Raytheon is registered to conduct
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`business in the State of Texas and has a registered agent, CT Corporation System, 1999 Bryan
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`Street, Suite 900, Dallas, Texas 75201.
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`

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`3.
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`On information and belief, Defendant directly and/or indirectly develops, designs,
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`manufactures, distributes, markets, offers for sale, and/or sells infringing products and services in
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`the United States, including in the Eastern District of Texas, and otherwise directs infringing
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`activities to this District in connection with its products and services.
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`JURISDICTION AND VENUE
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`4.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, 35 U.S.C. §§ 1, et seq. This Court has subject matter jurisdiction over this action pursuant
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`to 28 U.S.C. §§ 1331, 1338(a), and 1367.
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`5.
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`This Court has specific and personal jurisdiction over Defendant in this action
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`because Defendant has committed acts within this Judicial District giving rise to this action and
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`has established minimum contacts with this forum, such that the exercise of jurisdiction over
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`Defendant would not offend traditional notions of fair play and substantial justice. Defendant
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`conducts business and has committed acts of patent infringement and/or has induced acts of patent
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`infringement by others in this Judicial District and/or has contributed to patent infringement by
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`others in this Judicial District, the State of Texas, and elsewhere in the United States by, among
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`other things, offering to sell and selling products and/or services that infringe the Patents-in-Suit.
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`6.
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`Venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1391 and 1400(b)
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`because Defendant has regular and established places of business in this Judicial District.
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`Defendant, through its own acts and/or through the acts of others, makes, uses, sells, distributes,
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`exports from, imports, and/or offers to sell infringing products within this Judicial District,
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`regularly does and solicits business in this Judicial District, and has the requisite minimum contacts
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`with this Judicial District, such that this venue is a fair and reasonable one.
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`2
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`PATENTS-IN-SUIT
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`7.
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`On July 3, 2012, the United States Patent and Trademark Office duly and legally
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`issued U.S. Patent No. 8,213,970 (the “’970 Patent”) entitled “Method of Utilizing Forced Alerts
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`for Interactive Remote Communications.” On September 1, 2021, the United States Patent and
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`Trademark Office issued an Inter Partes Review Certificate for the ’970 Patent cancelling claims
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`1 and 3-9. On December 9, 2021, the United States Patent and Trademark Office issued an
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`Ex Parte Reexamination Certificate for the ’970 Patent determining claims 2 and 10 (as amended)
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`and claims 11-13 to be valid and patentable. A true and correct copy of the ’970 Patent, which
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`includes the September 1, 2021 Inter Partes Review Certificate and the December 9, 2021 Ex Parte
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`Reexamination Certificate, is attached hereto at Exhibit A.
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`8.
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`On September 13, 2016, the United States and Trademark Office duly and legally
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`issued U.S. Patent No. 9,445,251 (the “’251 Patent”) entitled “Method to Provide Ad Hoc and
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`Password Protected Digital and Voice Networks.” On June 8, 2021, the United States Patent and
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`Trademark Office issued an Ex Parte Reexamination Certificate of the ’251 Patent determining
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`claims 1-35 to be valid and patentable. A true and correct copy of the ’251 Patent, which includes
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`the June 8, 2021 Ex Parte Reexamination Certificate, is attached hereto as Exhibit B.
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`9.
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`On October 11, 2016, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 9,467,838 (the “’838 Patent”) entitled “Method to Provide Ad Hoc
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`and Password Protected Digital and Voice Networks.” On May 27, 2021, the United States Patent
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`and Trademark Office issued an Ex Parte Reexamination Certificate of the ’838 Patent determining
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`claims 1-84 to be valid and patentable. A true and correct copy of the ’838 Patent, which includes
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`the May 27, 2021 Ex Parte Reexamination Certificate, is attached hereto as Exhibit C.
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`10.
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`On November 14, 2017, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 9,820,123 (the “’123 Patent”) entitled “Method to Provide Ad Hoc
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`and Password Protected Digital and Voice Networks.” On September 24, 2021, the United States
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`Patent and Trademark Office issued an Ex Parte Reexamination Certificate for the ’123 Patent
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`confirming the validity and patentability of claims 1-48. A true and correct copy of the ’123 Patent,
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`which includes the September 24, 2021 Ex Parte Reexamination Certificate, is attached hereto as
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`Exhibit D.
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`11.
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`On August 29, 2017, the United States and Trademark Office duly and legally
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`issued U.S. Patent No. 9,749,829 (the “’829 Patent”) entitled “Method to Provide Ad Hoc and
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`Password Protected Digital and Voice Networks.” On August 16, 2021, the United States Patent
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`and Trademark Office issued an Ex Parte Reexamination Certificate for the ’829 Patent confirming
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`the validity and patentability of claims 1-68. A true and correct copy of the ’829 Patent, which
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`includes the August 16, 2021 Ex Parte Reexamination Certificate, is attached hereto as Exhibit E.
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`12.
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`AGIS Software is the sole and exclusive owner of all rights, title, and interest in the
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`Patents-in-Suit, and holds the exclusive right to take all actions necessary to enforce its rights to
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`the Patents-in-Suit, including the filing of this patent infringement lawsuit. AGIS Software also
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`has the right to recover all damages for past, present, and future infringement of the Patents-in-
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`Suit and to seek injunctive relief as appropriate under the law.
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`FACTUAL ALLEGATIONS
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`13. Malcolm K. “Cap” Beyer, Jr., a graduate of the United States Naval Academy and
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`a former U.S. Marine, is the CEO of AGIS Software and a named inventor of the AGIS Software
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`patent portfolio. Mr. Beyer founded Advanced Ground Information Systems, Inc. (“AGIS, Inc.”)
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`shortly after the September 11, 2001 terrorist attacks because he believed that many first responder
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`and civilian lives could have been saved through the implementation of a better communication
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`system. He envisioned and developed a new communication system that would use integrated
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`software and hardware components on mobile devices to give users situational awareness superior
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`to systems provided by conventional military and first responder radio systems.
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`14.
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`AGIS, Inc. developed prototypes that matured into its LifeRing system. LifeRing
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`provides first responders, law enforcement, and military personnel with what is essentially a
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`tactical operations center built into hand-held mobile devices. Using GPS-based location
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`technology and existing or special-purpose cellular communication networks, LifeRing users can
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`exchange location, heading, speed, and other information with other members of a group, view
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`each other’s locations on maps and satellite images, and rapidly communicate and coordinate their
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`efforts.
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`15.
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`AGIS Software was formed in 2017 and has since opened two offices in Texas,
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`including one office located at 2226 Washington Avenue, #2, Waco, Texas 76702. AGIS Software
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`also maintains a data center in Texas.
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`16. Mr. Beyer has maintained longstanding ties to Texas and the Eastern District. In
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`1987, Mr. Beyer founded Advanced Programming Concepts, an Austin-based company focused
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`on real-time tactical command and control systems. Advanced Programming Concepts was later
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`acquired by Ultra Electronics, Inc. and is now the Advanced Tactical Systems unit of Ultra
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`Electronics, Inc., which is still based in Austin, Texas.
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`17.
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`AGIS Software licenses its patent portfolio, including the ’970, ’251, ’838, ’123,
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`and ’829 Patents, to AGIS, Inc. AGIS, Inc. has marked its products accordingly. AGIS Software
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`and all previous assignees of the Patents-in-Suit have complied with the requirements of 35 U.S.C.
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`§ 287(a).
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`18.
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`Defendant has infringed and continues to infringe the Patents-in-Suit by making,
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`using, selling, offering to sell, distributing, exporting from, and/or importing, and by actively
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`inducing others to make, use, sell, offer to sell, distribute, export from, and/or import products that
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`infringe the Patents-in-Suit. Such products include at least the Raytheon TAK, TAK Server,
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`ATAK, WebTAK, and WinTAK applications, solutions and servers (the “Accused Products”).0F
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`1
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`The Accused Products infringe each of the Asserted Patents.
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`19.
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`The Accused Products include functionalities that allow users to form and/or join
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`networks or groups, share and view locations with other users, display symbols corresponding to
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`locations (including locations of other users) on a map, and communicate with other users via text,
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`voice, and multimedia-based communication. Additionally, the Accused Products include
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`functionalities to allow users to form and/or join networks or groups. Additionally, the users may
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`form groups that include their own devices in order to track their own lost or stolen devices, as
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`shown below; to send and receive communications from their own lost or stolen Accused Products;
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`and to remotely control the lost or stolen Accused Products. The Accused Products include the
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`functionalities to display map information, including symbols corresponding with users, entities,
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`and locations. Additionally, the Accused Products include functionalities to form groups that
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`include their own devices in order to track, remotely monitor, and control, and/or communicate
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`with other users’ devices.
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` The Accused Products
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`include functionalities
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`to enable
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`communications, such as voice calls between users. The Accused Products practice the claims of
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`the Asserted Patents to improve user experiences and to improve Defendant’s position in the
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`market.
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`1 See, e.g., https://bbn-tak.myshopify.com/; https://bbn-tak.myshopify.com/pages/tak-academy;
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`2
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`1F
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`3
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`2F
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`2 https://bbn-tak.myshopify.com/
`3 https://bbn-tak.myshopify.com/
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`4
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`3F
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`4 https://tak.gov/
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`5
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`4F
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`6
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`5F
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`5 https://www.civtak.org/atak-about/
`6 https://www.civtak.org/atak-about/
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`COUNT I
`(Infringement of the ’970 Patent)
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`20.
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`Paragraphs 1 through 19 are incorporated herein by reference as if fully set forth in
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`their entireties.
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`21.
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`AGIS Software has not licensed or otherwise authorized Defendant to make, use,
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`offer for sale, sell, or import any Accused Products and/or products that embody the inventions of
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`the ’970 Patent.
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`22.
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`Defendant
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`infringes, contributes
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`to
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`the
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`infringement of, and/or
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`induces
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`infringement of the ’970 Patent by making, using, selling, offering for sale, distributing, exporting
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`from, and/or importing into the United States products and/or methods covered by one or more
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`claims of the ’970 Patent including, but not limited to, the Accused Products.
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`23.
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`Defendant has and continues to directly infringe at least claim 10 of the ’970 Patent,
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`either literally or under the doctrine of equivalents, by making, using, selling, offering for sale,
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`distributing, exporting from, and/or importing into the United States the Accused Products without
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`authority and in violation of 35 U.S.C. § 271(a).
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`24.
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`Defendant has and continues to indirectly infringe at least claim 10 of the ’970
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`Patent by actively, knowingly, and intentionally inducing others to directly infringe, either literally
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`or under the doctrine of equivalents, by making, using, selling, offering for sale, distributing,
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`exporting from, and/or importing into the United States the Accused Products and by instructing
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`users of the Accused Products to perform methods claimed in the ’970 Patent. For example,
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`Defendant, with knowledge that the Accused Products infringe the ’970 Patent at least as of the
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`date of this Complaint, actively, knowingly, and intentionally induced, and continues to knowingly
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`and intentionally induce direct infringement of the ’970 Patent in violation of 35 U.S.C. § 271(b).
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`10
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`25.
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`For example, Defendant has indirectly infringed and continues to indirectly infringe
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`at least claim 10 of the ’970 Patent in the United States because Defendant’s customers use the
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`Accused Products including, but not limited to, at least the Raytheon TAK, TAK Server, ATAK,
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`WebTAK, and WinTAK applications, solutions and servers, alone or in conjunction with other
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`Accused Products, in accordance with Defendant’s instructions and thereby directly infringe at
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`least claim 10 of the ’970 Patent in violation of 35 U.S.C. § 271. Defendant directly and/or
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`indirectly intentionally instructs its customers to infringe through training videos, demonstrations,
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`brochures, installations and/or user guides, such as those located at one or more of the following:
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`https://bbn-tak.myshopify.com/;
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`https://www.civtak.org/atak-about/;
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`https://www.civtak.org/documentation/; https://wiki.civtak.org/index.php?title=ATAK_Manual;
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`and through Raytheon’s agents and representatives located within this Judicial District. Defendant
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`is thereby liable for infringement of the ’970 Patent under 35 U.S.C. § 271(b).
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`26.
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`For example, Defendant directly infringes and/or indirectly infringes by instructing
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`its customers to infringe by performing claim 10 of the ’970 Patent, including: a method of
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`receiving, acknowledging, and responding to a forced message alert from a sender PDA/cell phone
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`to a recipient PDA/cell phone, wherein the receipt, acknowledgment, and response to said forced
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`message alert is forced by a forced message alert software application program, said method
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`comprising the steps of: receiving an electronically transmitted electronic message; identifying
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`said electronic message as a forced message alert, wherein said forced message alert comprises a
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`voice or text message and a forced message alert application software packet, which triggers the
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`activation of the forced message alert software application program within the recipient PDA/cell
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`phone; transmitting an automatic acknowledgment of receipt to the sender PDA/cell phone, which
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`triggers the forced message alert software application program to take control of the recipient
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`PDA/cell phone and show the content of the text message and a required response list on the
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`display recipient PDA/cell phone or to repeat audibly the content of the voice message on the
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`speakers of the recipient PDA/cell phone and show the required response list on the display
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`recipient PDA/cell phone; and transmitting a selected required response from the response list in
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`order to allow the message required response list to be cleared from the recipient’s cell phone
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`display, whether said selected response is a chosen option from the response list, causing the forced
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`message alert software to release control of the recipient PDA/cell phone and stop showing the
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`content of the text message and a response list on the display recipient PDA/cell phone and/or stop
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`repeating the content of the voice message on the speakers of the recipient PDA/cell phone;
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`displaying the response received from the PDA/cell phone that transmitted the response on the
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`sender of the forced alert PDA/cell phone; and providing a list of the recipient PDA/cell phones
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`that have automatically acknowledged receipt of a forced alert message and their response to the
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`forced alert message; and displaying a geographical map with georeferenced entities on the display
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`of the sender PDA/cell phone; obtaining location and status data associated with the recipient
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`PDA/cellphone; and presenting a recipient symbol on the geographical map corresponding to a
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`correct geographical location of the recipient PDA/cellphone based on at least the location data.
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`For example, the Accused Products include features as shown below.
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`12
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`

`

`if
`
`AK Civilian Overview
`
`mapdis
`hed ne
`
`t
`
`AK
`
`agery,
`n promote
`
`tion and mappingfra
`der environment. The
`
`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 13 of 123 PageID #: 13
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`
`
`The Nort
`control map
`
`NorthUpar
`[North Arrow]
`a
`ect the [Rotation] buttonto ente’
`nin Manual M.
`
`i
`ode.
`
`to call
`1 3
`MapRotati
`the maporie
`
`n, signified bythe a
`tationforfurther adj
`[Magnifier] buttons
`lect the [Back] but
`
`has a co
`cti
`
`
`
`13
`
`

`

`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 14 of 123 PageID #: 14
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`Unclassified
`
`g of terrain and map ites
`3D wie
`ATAK Civilianfeat
`(DTED required). Te enable 3D \
`lang press on the
`[North Arrow] to call out the additional c
`a
`ect (3D). Atilt anglei
`the edgeof
`[North Arrow
`Touch the screen with t
`nger and simultaneously
`appropr
`Swi
`e
`screen to tilt the view
`angle. Once the
`5
`is set,
`Wewing angle
`the [3D Lock] buttan to retain this view while
`panning the map. While viewing the map from ain angle, sore map iterns
`will appear raised abovethe map surface if they have defined elevations.
`
`avdilable.
`
`location. The options available an the
`s current
`itry, Fine Adjust/Enter Coordinate/MGRS Location
`i
`GPS Error, Range & Bearing Line, GPS Lockto Self, Tracking Breadcrumbs, Place a Marker at the user's curre
`cation and Details.
`yas a colored circle. The color of
`thecircle
`the user's Team affiliat
`ering inside thecircle to identify therole
`Team Member markers that include a diagonalline indicate that the GPS locationis mot available.
`team member has GPS reception.
`
`mport Manager or can
`and other types from products such as Pix40 can be imparted via
`OBJ models
`ATAK Civilian supports the use of 3D mod
`be mar
`ly placed inthe atak/overlays folder prior to startup. If using Import Manager browse to the .O8Jfile and import onlythat file, or browse
`ta a
`ZIP file
`that contains the OBJ file (and others) and impart only that file.If usi
`g manual placement tothe ata k/overlays folder, place a ZIP file containing
`tup.
`the .OBJfile (and others) inte the directory and they will be imported on
`
`a 3D Model icon will appear on the map.
`Once imported,
`Zoom inte the area of the ican until a loading ring ap
`pears. After
`the loading process has finishe
`model will be projected onta the map. Enable the map
`and tilt the
`view angle to see
`the 3D modeling.
`madels will appear
`heir own categoryim
`jled on/off or removed
`
`Unclassified
`
`tool. Select the [Point Dropper] icon to place internationally standardized
`t using the Point Dropper
`The user can enter locations ofin
`ricons on the map, edit the data and share
`the markers with other network members.
`
`Available roles include: Team Member, Team Lead
`in center), Sniper
`(5),
`edic (+), Forward Observer (FO), RTO (RB) or K9 (KS). The options available when another user's
`
`Self-Marker is selected are: Inner Ring-Delete, Polar Coordinate Entry, Fine Adjust/Enter Coordinate/MGRS Location
`Range & Bearing Line, GPS Lock on Friendly, Video Player
`(if available), Communication Options (if canfiqured by that
`user), Custom Threat Rings, Tracking Breadcrumbs and Detail
`
`Outer Ring (Communication Options)—Data Package, Email, SMS Messaging, GeaChat, VOIP and Cellular Phone, when
`
`
`
`14
`
`

`

`
`
`a
`con ser, 2
`
`tions are: Unknow
`map interf,
`ta
`
`Det
`
`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 15 of 123 PageID #: 15
`
`Friendly Object
`
`Unclassified
`
`
`
`RadialMenus
`Unknown Object
`
`Neutral Object
`
`Red Object
`
`
`
`15
`
`

`

`the [Bloodhound
`tom Reticle
`
`Setup Bloodhound
`
`a
`
`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 16 of 123 PageID #: 16
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`(Bloodhound
`
`e
`
`
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`16
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`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 17 of 123 PageID #: 17
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`Contacts
`
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`
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`17
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`

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`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 18 of 123 PageID #: 18
`Case 2:24-cv-00598-RWS-RSP Document1 Filed 07/29/24 Page 180
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`Unclassified
`
`Text-based Chat massages may be sent to active network members by using the GeaChat function. To enter GeoChat Group Manage-
`ment, select the [Contacts] icon andselect [(GeoChat] from the drop-down menu.
`
`GeoChat Group Managementisinitiated through Contacts. Select the [Contacts] icon, then
`select GeoChatfrom the drop-down. The user can mowcreate, edit and delete chat groups,
`as well as sub-groups. To create a chat group,select the [Groups] line (not the communica-
`tions button). Select the [Add Group] icon to create the name
`of the group and addcontacts to the group andthen select
`[Create]. Ifa parent group is being created, no contacts need
`‘to be addedat this level. To add a nested group,tap the parent
`group, select the [Add Group] icon to create the nameof the
`sub-group and add contacts. Groups may be managed using
`the options to add/delete contacts orto add/delete GeoChat
`group.
`
`To addusers to a group,select the [Groups]line (not the communications button), then select the name of the groupto addusers. Select the [Add
`Users] icon. A window will open allowing the groupcreater to add users to the selected group. Select the [Add] button when all the users to be added
`are checked.
`
`eee)
`Groupe [
`aT
`
`Group and person-to-person messagingis available. To view messages from or send messages to an individual,
`tap on the desired contact’s [Communication] icon. Selecting the [Pam To] icon, located at the tapright of the
`call sign in an individual chat,will pan the map interface to that user's location. Select [All Chat Rooms] to view
`all messages from orsend messages to those present on the network or TAK Server. Other groupings available for
`viewing or sending messages are: Forward Observer, Groups, HO, K9, Medic, RTO, Sniper, Team Lead and Teams.
`If the user's current role is Forward Observer, HO, K9,
`ic, RTO, Sn
`rTeam Lead, that user can view orsend
`messages to all other contacts with the same role. Ifa GeoChat messageis sent from the toplevel of Teams,it will
`be sent to all contacts, similar to [All Chat Rooms].
`
`Peleew Esa
`Whena sub-Teamis chosen, messages can only be sent tothat user's active (My Team) team color. Whena parent
`eee} cadet
`group is chosen, messages are sent to all members of the parent group,a5 well as all of the sub-groups. When a
`Cara sub-groupis chosen, messages are sent only to members of the sub-group. Individuals within GeoChat may be
`Vel
`fa
`ramovedfromthe Contacts menu by toggling thevisibility of individuals or groups within Overlay Manager.
`
`stay available fora short time.
`
`Selecting in the Free Text Entry area will open an onscreen keyboard.
`At the bottom of the Chat area are pre-defined messages that may be
`used to quickly create a message to send. Tap the current menu button
`to scroll through the different menus of canned messages,
`including:
`DFLT1, DFLT2, ASLT], ASLT2, RECON) and RECON2. These pre-defined
`messages present an easy way to transmit a brief message to othernet-
`work members concerning position or otherimportant communication.
`The pre-defined messages may be changedby
`long pressing on the button andchanging its
`label and correspondingvalue.
`A numbered red dot will appear on the [Contacts] icon when a message has
`been received successfully. The number denotes the number of unread mes-
`sages that have beenreceived. Select this icon to viewthe contactlist. The user
`name who sent the message will appearwith a numberedred dot next to their
`name. Alternatively, the text of the message can be read by dragging down
`fromthe top to see the Androidnotifications window.This notification will only
`
`
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`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 19 of 123 PageID #: 19
`Case 2:24-cv-00598-RWS-RSP Document1 Filed 07/29/24 Page 190
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`Unclassified
`
`the [Wid-
`Select
`eo Player]
`icon
`to bring up the
`Video player. The
`Video Player supports play-
`ing video streams from IP
`cameras and H.264 encod-
`ers. The menu allows adding,
`editing, deleting, playing or
`sending videos to other net-
`work members.
`
`Optionsfor the video player include: viewing video snapshots, adding a new
`videoalias, downloading an alias from the TAK Server, selecting the Multi-Se-
`lect Action option to either Export or Delete aliases or searching for a specific
`alias.
`Select the desired listed videoalias orfile name to begin playing the stored or
`streaming video. The video will display half the width of the screen.
`
`{Video
`
`To view a videoatfull screen,slide the pull bar. To retum to half screen,
`slide the pull bar back to the right.
`Select the [Back] button to retum to the list of available videos.
`
`To add stored video file, select the [Import Manager] icon, select [Local SD), and navigate to the videofile and select [OK] to add the video to the list of
`available videos. The user can also manually place video files in “atak\tools\wideos”to have them listed after ATAK is restarted. When a videois playing
`at half width,slide the pull bar to the right to hice the video but maintain the connection. Slide the pull bar to the left to unhide the video. The status of
`the video player is reflected in the main Android toolbar lacated at the top of the screen.
`
`Select the [Snapshot] icon to save the currentframe of the video as a JPEG image file,the icon will flash green to indicate that the snapshot
`has occurred. The file will be saved in the “\atak\tools\wideosnaps”folder.
`
`The usercan view the saved snap shots by selecting the [Video Snapshots]
`icon. The user has the option of sorting the images by time taken or by the
`name of the snapshot. The user can also search within the snapshots taken
`by their name. By selecting an image,the image will be displayed within the window.
`The user will have the options of cycling though the images, [Send] to a TAK user, or
`edit in [Image Markup). (Image Markup would need to be installed.)
`Fa live UDP stream is being viewed,it can be recorded by tapping the [Record]icon. The icon will change to a green square while recording.
`Select the [Green Square] to end the recording. The recordings are saved in a folderin “\atak\tools\wideos\"
`Note: This is only available for UDP streams.
`To close the video player, select the [M]located at the bottem right corner of the video player or select the [Back] button.
`
`ences > Address Lookup Preferences.
`
`Unclassified
`
`the
`Select
`Select from the [MGRS] (military grid reference system), [DD]
`To]
`[Go
`(decimal degrees), [DM] (degrees- minutes), [DMS] (degrees-min-
`icon to en-
`utes-seconds), [UTM] (Universal Transverse Mercator) or [ADDR]
`tabs on the GoTo interface and enter the location data ofinterest.
`ter details and navigate
`The address provider name appears beneath the Elevation Data
`to a specific location on
`the map.
`when the user selects the [ADDR]tab.
`The user can enter the Latitude, Longitude and Elevation in the space provided for [MGR] ,
`[DD], [D-M] or [D-M-5] searches. If DTED is installed, the elevation value can be automatically
`populated by tapping the [Pull From DTED] button.The user can select a desired marker type
`(Spot, Unknown, Neutral, Red, or Friendly) to be placed at the entered coordinates.If [No Point]
`is selected, the map will pan to the location but will not add a point.
`
`Note: The address provider name appears be-
`neath the Elevation Data when the userselects the
`[ADDR]tab.
`
`The Address Lookup provider used for the ADDR
`tab can be configured in the Settings > Tool Prefer-
`
`
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`

`Case 2:24-cv-00598-RWS-RSP Document 1 Filed 07/29/24 Page 20 of 123 PageID #: 20
`
`Thé Geo Fence tool allows users to create a virtual fence that triggers entry/exit notifications if map
`items of interest cross the virtual boundary lines. The Geo Fence options are added to the existing
`drawing tools. After a shape has been added, the Geo Fence Tool can be accessed either by selecting
`the [Geo Fence] joon from the menu items or selecting it from the radial.
`The Enabled Field slider will move to Tracking by default when a new Geo Fence windowis created. Toggle the
`slider between Tracking and Off to enable/disable the Geo Fence. Use the Triggerfield to define which types of
`Geo Fence breach to monitor. Choose between Entry, Exit or Both. Use the Monitor field to define which entities
`the Geo Fencewill track.
`
`Cui
`
`on
`
`Unclassified
`
`The device's GPS can be used to track movements with the Track History tool. These tracked paths can be
`exported to a TAK server, toa route or to a KML, KMZ, GPX or CSVfile. A GPS position must be established
`before tracking cam begin.
`
`at
`uy
`
`Deee Led
`
`ct
`
`
`
`Selecting the [Track History] icon will open Track Details for the current active track.
`The track title, color and style can be modified.Initiate a newtrack by selecting the
`[Add Track] icon. Accept or edit the default track name and select the [OK] buttan to
`begin the newtrack. User location data is recorded as breadcrumbsin a newtrackfile.
`
`boobs
`sidan
`Ue eC
`
`Use the Track Search function to view track information that has been previously saved locally or on a TAK Server. The tool
`searches the track database for matches against the specified time range and by usercallsign. Matching tracks are displayed
`a alist, and can be selected to view on the map interface.
`
`Select the [Track Search] icon to access the function.
`Specify callsign and time frame, check the box for Server
`he
`Search (ifdesired), then select [Search]. The track list will
`appear. The query results can be sorted by Track Name
`LEAL
`or Start Time. Select any of the query results to move
`S25) ili A
`to that track. Once selected, the name, color, and style
`few
`lade
`of a selected track can be modified or the track can be
`Fedo cid
`i
`3
`‘
`cleared. Convert a track to a TAK route or export it as a
`
`
`KML, KMZ, GPX or CSV file by selecting the desired track and then [Export]. Entera file er,WE. d
`name then select [Next] and choose the export format. Select [Done] or [Send] when the =
`export completes.
`When viewing the track list, the Track History Toolbar will appear at the top ofthe screen. The options include [Add a
`Track], [Multi-select), [Track Search), [Clear Tracks] and [Exit]. The Track History List allows the user to select tracks
`of other