Case 1:22-cv-01331-MSN-IDD Document 48 Filed 03/01/23 Page 1 of 65 PageID# 497
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`GEOSCOPE TECHNOLOGIES PTE. LTD.,
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`
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`v.
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`GOOGLE LLC,
`
`
`Plaintiff,
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`Case No. 1:22-cv-01331 (MSN-IDD)
`
`
`
`Defendant,
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`JURY TRIAL DEMANDED
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`
`
`
`
`
`
`
`
`DEFENDANT GOOGLE LLC’S ANSWER AND AFFIRMATIVE DEFENSES TO
`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant Google LLC (“Defendant” or “Google”), by and through its attorneys,
`
`respectfully submit this Answer and Affirmative Defenses to the Complaint for Patent
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`Infringement (Dkt. 1) (“Complaint”) of Geoscope Technologies Pte. Ltd. (“Plaintiff” or
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`“Geoscope”). Any allegations not expressly admitted are denied. This answer follows the
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`numbering provided in Geoscope’s complaint. To the extent that the section headings of
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`Geoscope’s complaint contain allegations, those allegations are denied unless expressly
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`admitted. Geoscope’s complaint contains various footnotes not reproduced herein. To the extent
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`Geoscope’s footnotes contain allegations, those allegations are denied unless expressly admitted.
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`I. THE PARTIES
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`1.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 1, and therefore denies them.
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`2.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 2, and therefore denies them.
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`1
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`3.
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`Defendant admits that Google LLC is a company registered in Delaware, with its
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`principal place of business at 1600 Amphitheatre Parkway, Mountain View, California, 94043.
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`Defendant further admits that it maintains an office at 1900 Reston Metro Plaza, Reston, Virginia
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`20190 and conducts business operations within the Eastern District of Virginia. Defendant
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`otherwise denies the allegations in Paragraph 3.
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`II. JURISDICTION AND VENUE
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`4.
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`The allegations in Paragraph 5 set forth legal conclusions that require no
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`response. To the extent that a response is required, Defendant admits that this action invokes the
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`United States patent laws. Defendant denies any remaining allegations in Paragraph 4.
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`5.
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`The allegations in Paragraph 5 set forth legal conclusions that require no
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`response. To the extent that a response is required, Defendant admits that this action invokes the
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`United States patent laws, and that this Court has subject matter jurisdiction over patent law
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`claims. Defendant denies any remaining allegations in Paragraph 5.
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`6.
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`Defendant admits that it maintains an office at 1900 Reston Metro Plaza, Reston,
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`Virginia 20190. Defendant further admits that it has advertised for positions and has hired
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`employees at its office at 1900 Reston Metro Plaza, Reston, Virginia 20190. The remaining
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`allegations in Paragraph 6 set forth legal conclusions that require no response. To the extent that
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`a response is required, Defendant admits this Court has personal jurisdiction over Defendant for
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`purposes of this particular action only. Defendant denies any remaining allegations in Paragraph
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`6.
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`7.
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`Defendant admits that it maintains an office at 1900 Reston Metro Plaza, Reston,
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`Virginia 20190 and data centers in Loudon County. Defendant further admits that it is registered
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`to do business in Virginia and has advertised for positions and has hired employees in this
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`District. The remaining allegations in Paragraph 7 set forth legal conclusions that require no
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`2
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`response. To the extent that a response is required, Defendant states that it does not contest
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`venue in this District for purposes of this particular action but denies that venue in this District is
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`convenient and appropriate. Defendant denies any remaining allegations in Paragraph 7.
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`8.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 8, and therefore denies them.
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`9.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 9, and therefore denies them.
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`10.
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`Defendant admits that the cover sheets of the Asserted Patents identify the listed
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`inventors as residing in Vienna, VA; Dulles, VA; Herndon, VA; and Leesburg, VA. Defendant
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`is without knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations in Paragraph 10, and therefore denies them.
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`11.
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`The allegations in Paragraph 11 set forth legal conclusions that require no
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`response. To the extent that a response is required, Defendant states that it does not contest
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`venue in this District for purposes of this particular action but denies that venue in this District is
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`a convenient venue for Defendant or its witnesses. Defendant denies any remaining allegations
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`in Paragraph 11.
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`III. THE ASSERTED PATENTS
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`12.
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`Defendant admits that U.S. Patent No. 7,561,104 (the “’104 Patent”) is entitled
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`“METHOD TO MODIFY CALIBRATION DATA USED TO LOCATE A MOBILE UNIT,”
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`and that the patent cover sheet states that the ’104 Patent was issued on July 14, 2009.
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`Defendant admits that the cover sheet states that the ’104 Patent claims priority to U.S.
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`Provisional Patent Application No. 60/899,379 (the “’379 Provisional”), filed on February 5,
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`2007. Defendant admits that a document purporting to be a copy of the ’104 Patent is attached to
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`the Complaint as Exhibit A. Defendant denies the remaining allegations of Paragraph 12.
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`3
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`13.
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`The allegations of Paragraph 13 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 13.
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`14.
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`The allegations of Paragraph 14 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegation of
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`Paragraph 14.
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`15.
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`Defendant admits that U.S. Patent No. 8,400,358 (the “’358 Patent”) is entitled
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`“METHOD TO MODIFY CALIBRATION DATA USED TO LOCATE A MOBILE UNIT,”
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`and that the patent cover sheet states that the ’358 Patent was issued on March 19, 2013.
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`Defendant admits that the cover sheet states that the ’358 Patent states that it is a continuation of
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`the application that issued as the ’104 Patent, and that the cover sheet states that the ’358 Patent
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`claims priority to the ’379 Provisional, filed on February 5, 2007. Defendant admits that a
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`document purporting to be a copy of the ’358 Patent is attached to the Complaint as Exhibit B.
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`Defendant denies the remaining allegations of Paragraph 15.
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`16.
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`The allegations of Paragraph 16 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 16.
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`17.
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`The allegations of Paragraph 17 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 17.
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`18.
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`Defendant admits that U.S. Patent No. 8,786,494 (the “’494 Patent”) is entitled
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`“METHOD TO MODIFY CALIBRATION DATA USED TO LOCATE A MOBILE UNIT,”
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`and that the patent cover sheet states that the ’494 Patent was issued on July 22, 2014.
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`4
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`Defendant admits that the cover sheet states that the ’494 Patent states that it is a continuation of
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`the application that issued as the ’358 Patent, and that the cover sheet states that the ’494 Patent
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`claims priority to the ’379 Provisional, filed on February 5, 2007. Defendant admits that a
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`document purporting to be a copy of the ’494 Patent is attached to the Complaint as Exhibit C.
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`Defendant denies the remaining allegations of Paragraph 18.
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`19.
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`The allegations of Paragraph 19 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 19.
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`20.
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`The allegations of Paragraph 20 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 20.
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`21.
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`Defendant admits that U.S. Patent No. 8,406,753 (the “’753 Patent”) is entitled
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`“SYSTEM AND METHOD FOR GENERATING A LOCATION ESTIMATE USING
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`UNIFORM AND NON-UNIFORM GRID POINTS,” and that the patent cover sheet states that
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`the ’753 Patent was issued on March 26, 2013. Defendant admits that the cover sheet states that
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`the ’753 Patent claims priority to the ’379 Provisional, filed on February 5, 2007. Defendant
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`admits that a document purporting to be a copy of the ’753 Patent is attached to the Complaint as
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`Exhibit D. Defendant denies the remaining allegations of Paragraph 21.
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`22.
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`The allegations of Paragraph 22 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 22.
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`5
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`23.
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`The allegations of Paragraph 23 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 23.
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`24.
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`Defendant admits that U.S. Patent No. 9,097,784 (the “’784 Patent”) is entitled
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`“SYSTEM AND METHOD TO COLLECT AND MODIFY CALIBRATION DATA,” and that
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`the patent cover sheet states that the ’784 Patent was issued on August 4, 2015. Defendant
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`admits that the cover sheet states that the ’784 Patent claims priority to the ’379 Provisional,
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`filed on February 5, 2007. Defendant admits that a document purporting to be a copy of the ’784
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`Patent is attached to the Complaint as Exhibit E. Defendant denies the remaining allegations of
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`Paragraph 24.
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`25.
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`The allegations of Paragraph 25 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 25.
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`26.
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`The allegations of Paragraph 26 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 26.
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`27.
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`Defendant admits that U.S. Patent No. 8,320,264 (the “’264 Patent”) is entitled
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`“METHOD AND APPARATUS FOR DETERMINING PATH LOSS BY ACTIVE SIGNAL
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`DETECTION,” and that the patent cover sheet states that the ’264 Patent was issued on
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`November 27, 2012. Defendant admits that the cover sheet states that the ’264 Patent claims
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`priority to U.S. Provisional Patent Application No. 60/681,475 (the “’475 Provisional”), filed on
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`May 17, 2005. Defendant admits that a document purporting to be a copy of the ’264 Patent is
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`6
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`attached to the Complaint as Exhibit F. Defendant denies the remaining allegations of Paragraph
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`27.
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`28.
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`The allegations of Paragraph 28 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 28.
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`29.
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`The allegations of Paragraph 29 set forth legal conclusions to which no response
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`is required. To the extent that a response is required, Defendant denies the allegations of
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`Paragraph 29.
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`30.
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`Defendant denies the allegations of Paragraph 30.
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`IV. FACTUAL ALLEGATIONS
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`A. Introduction
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`31.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 31, and therefore denies them.
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`32.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 32, and therefore denies them.
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`33.
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`Defendant denies the second sentence of paragraph 33. Defendant is without
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`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
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`of Paragraph 33, and therefore denies them.
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`34.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the remaining allegations of Paragraph 34, and therefore denies them.
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`35.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 35, and therefore denies them.
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`7
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`B. Location-based Services, Geolocation of Mobile Devices, and the Asserted Patents
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`36.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 36, and therefore denies them.
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`37.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 37, and therefore denies them.
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`38.
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`Defendant admits that it maintains a website at
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`https://policies.google.com/technologies/location-data?hl=en-US, which states in part that
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`Providing useful, meaningful experiences is at the core of what
`Google does, and location information plays an important role in
`doing just that. From driving directions, to making sure your
`search results include things near you, to showing you when a
`restaurant is typically busy, location can make your experiences
`across Google more relevant and helpful. Location information
`also helps with some core product functionality, like providing a
`website in the right language or helping to keep Google’s services
`secure.
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`Defendant further admits that https://policies.google.com/technologies/location-data?hl=en-US
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`also states that:
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`Many devices, like phones or computers, can work out their
`precise location. You can allow Google and other apps to provide
`you with useful features based on where your device is located. For
`example, if you’re running late to meet your friends, you’ll
`probably want to use a navigation app to know the quickest way to
`get to your destination. To get turn-by-turn directions, you may
`need to turn on your device’s location and give the app the
`permission to access it. Or for some searches like “coffee shop”,
`“bus stop” or “atm”, results will usually be more helpful when
`precise location is available.
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`Defendant denies the remaining allegations of Paragraph 38.
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`39.
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`Defendant admits that users can enable features on certain mobile devices that
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`allow the mobile device to determine their location by relying on signals such as GPS.
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`Defendant is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations in Paragraph 39, and therefore denies them.
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`40.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 40, and therefore denies them.
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`41.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 41, and therefore denies them.
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`42.
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`Defendant admits only that
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`https://www.wired.com/images_blogs/threatlevel/2010/06/googcongress.pdf appears to be a
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`letter dated June 9, 2010, sent from Mr. Palbo Chavez, Google’s Director of Public Policy to
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`several members of the U.S. House of Representatives. Defendant further states that Mr.
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`Chavez’s letter states:
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`Information about the location of WiFi networks improves the
`accuracy of the location-based services, such as Google Maps or
`driving directions, that Google provides to consumers. For
`example, a user of Google Maps for mobile phones can turn on a
`smart phone’s “My Location” feature to identify his or her
`approximate location based on GPS signals (where available) and
`signals from the cell towers and WiFi networks visible to the
`device. Because GPS and cell tower location data can be unreliable
`or inaccurate, in some cases using the location of WiFi access
`points can enable a smart phone to pinpoint its own location more
`quickly and accurately
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`Defendant denies the remaining allegations of Paragraph 42.
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`43.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 43, and therefore denies them.
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`44.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 44, and therefore denies them.
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`45.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 45, and therefore denies them.
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`46.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 46, and therefore denies them.
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`47.
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`The allegations of Paragraph 47 purport to characterize the alleged inventions of
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`the Asserted Patents and set forth legal conclusions to which no response is required. To the
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`extent a response is required, Defendant denies the allegations of Paragraph 47.
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`48.
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`The allegations of Paragraph 48 purport to characterize the alleged inventions of
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`the ’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required.
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`To the extent a response is required, Defendant denies the accuracy of the language in Paragraph
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`48, which is an incomplete and inaccurate characterization of the ’104, ’358, and ’494 Patents,
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`and further denies any remaining allegations of Paragraph 48.
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`49.
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`The allegations of Paragraph 49 purport to characterize the alleged inventions of
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`the ’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required.
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`To the extent a response is required, Defendant denies the accuracy of the language in Paragraph
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`49, which is an incomplete and inaccurate characterization of the ’104, ’358, and ’494 Patents,
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`and further denies any remaining allegations of Paragraph 49.
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`50.
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`The allegations of Paragraph 50 purport to characterize the file history of the
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`’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required. To
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`the extent a response is required, Defendant denies the accuracy of the language in Paragraph 50,
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`which is an incomplete and inaccurate characterization of the ’358 Patent file history, and further
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`denies any remaining allegations of Paragraph 50.
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`51.
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`The allegations of Paragraph 51 purport to characterize the alleged inventions of
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`the ’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required.
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`To the extent a response is required, Defendant denies the accuracy of the language in Paragraph
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`10
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`51, which is an incomplete and inaccurate characterization of the ’104, ’358, and ’494 Patents,
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`and further denies any remaining allegations of Paragraph 51.
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`52.
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`The allegations of Paragraph 52 purport to characterize the file history of the
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`’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required. To
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`the extent a response is required, Defendant denies the allegations of Paragraph 52 and further
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`denies any remaining allegations of Paragraph 52.
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`53.
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`The allegations of Paragraph 53 purport to characterize the alleged inventions of
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`the ’104, ’358, and ’494 Patents and set forth legal conclusions to which no response is required.
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`To the extent a response is required, Defendant denies the accuracy of the language in Paragraph
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`53, which is an incomplete and inaccurate characterization of the ’104, ’358, and ’494 Patents,
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`and further denies any remaining allegations of Paragraph 53.
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`54.
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`The allegations of Paragraph 54 purport to characterize the claims of the ’104,
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`’358, and ’494 Patents and set forth legal conclusions to which no response is required. To the
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`extent a response is required, Defendant denies the accuracy of the language in Paragraph 54,
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`which is an incomplete and inaccurate characterization of claim 1 of the ’104 Patent, and further
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`denies the remaining allegations of Paragraph 54.
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`55.
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`The allegations of Paragraph 55 purport to characterize the claims of the ’358
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`Patent and set forth legal conclusions to which no response is required. To the extent a response
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`is required, Defendant denies the accuracy of the language in Paragraph 55, which is an
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`incomplete and inaccurate characterization of claims 1 and 41 of the ’358 Patent, and further
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`denies the remaining allegations of Paragraph 55.
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`56.
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`The allegations of Paragraph 56 purport to characterize the claims of the ’494
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`Patent and set forth legal conclusions to which no response is required. To the extent a response
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`is required, Defendant denies the accuracy of the language in Paragraph 56, which is an
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`incomplete and inaccurate characterization of claims 1 and 25 of the ’494 Patent, and further
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`denies the remaining allegations of Paragraph 56.
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`57.
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`58.
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`Defendant denies the allegations of Paragraph 57.
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`The allegations of Paragraph 58 purport to characterize the alleged inventions of
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`the ’753 Patent and set forth legal conclusions to which no response is required. To the extent a
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`response is required, Defendant denies the allegations of Paragraph 58.
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`59.
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`The allegations of Paragraph 59 purport to characterize the alleged inventions of
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`the ’753 Patent and set forth legal conclusions to which no response is required. To the extent a
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`response is required, Defendant denies the accuracy of the language in Paragraph 59, which is an
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`incomplete and inaccurate characterization of the ’753 Patent, and further denies any remaining
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`allegations of Paragraph 59
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`60.
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`The allegations of Paragraph 60 purport to characterize the alleged inventions of
`
`the ’753 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 60, which is an
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`incomplete and inaccurate characterization of the ’753 Patent, and further denies any remaining
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`allegations of Paragraph 60.
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`61.
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`The allegations of Paragraph 61 purport to characterize the file history of the ’753
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`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 61, which is an
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`incomplete and inaccurate characterization of the ’753 Patent file history, and further denies any
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`remaining allegations of Paragraph 61.
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`62.
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`The allegations of Paragraph 62 purport to characterize the claims of the ’753
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`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 62, which is an
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`incomplete and inaccurate characterization of claim 1 of the ’753 Patent, and further denies the
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`remaining allegations of Paragraph 62.
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`63.
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`64.
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`Defendant denies the allegations of Paragraph 63.
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`The allegations of Paragraph 64 purport to characterize the alleged inventions of
`
`the ’784 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the allegations of Paragraph 64.
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`65.
`
`The allegations of Paragraph 65 purport to characterize the alleged inventions of
`
`the ’784 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 65, which is an
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`incomplete and inaccurate characterization of the ’784 Patent, and further denies any remaining
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`allegations of Paragraph 65.
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`66.
`
`The allegations of Paragraph 66 purport to characterize the alleged inventions of
`
`the ’784 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 66, which is an
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`incomplete and inaccurate characterization of the ’784 Patent, and further denies any remaining
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`allegations of Paragraph 66.
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`67.
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`The allegations of Paragraph 67 purport to characterize the file history of the ’784
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`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 67, which is an
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`incomplete and inaccurate characterization of the ’784 Patent file history, and further denies any
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`remaining allegations of Paragraph 67.
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`68.
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`The allegations of Paragraph 68 purport to characterize the alleged inventions of
`
`the ’784 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 68, which is an
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`incomplete and inaccurate characterization of the ’784 Patent, and further denies any remaining
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`allegations of Paragraph 68.
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`69.
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`The allegations of Paragraph 69 purport to characterize the claims of the ’784
`
`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 69, which is an
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`incomplete and inaccurate characterization of claim 1 of the ’784 Patent, and further denies the
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`remaining allegations of Paragraph 69.
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`70.
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`71.
`
`Defendant denies the allegations of Paragraph 70.
`
`The allegations of Paragraph 71 purport to characterize the alleged inventions of
`
`the ’264 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the allegations of Paragraph 71.
`
`72.
`
`The allegations of Paragraph 72 purport to characterize the alleged inventions of
`
`the ’264 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 72, which is an
`
`incomplete and inaccurate characterization of the ’264 Patent, and further denies any remaining
`
`allegations of Paragraph 72.
`
`73.
`
`The allegations of Paragraph 73 purport to characterize the file history of the ’264
`
`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`
`
`14
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`

`

`Case 1:22-cv-01331-MSN-IDD Document 48 Filed 03/01/23 Page 15 of 65 PageID# 511
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`
`
`is required, Defendant denies the accuracy of the language in Paragraph 73, which is an
`
`incomplete and inaccurate characterization of the ’264 Patent file history, and further denies any
`
`remaining allegations of Paragraph 73.
`
`74.
`
`The allegations of Paragraph 74 purport to characterize the alleged inventions of
`
`the ’264 Patent and set forth legal conclusions to which no response is required. To the extent a
`
`response is required, Defendant denies the accuracy of the language in Paragraph 74, which is an
`
`incomplete and inaccurate characterization of the ’264 Patent, and further denies any remaining
`
`allegations of Paragraph 74.
`
`75.
`
`The allegations of Paragraph 75 purport to characterize the file history of the ’264
`
`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 75, which is an
`
`incomplete and inaccurate characterization of the ’264 Patent file history, and further denies any
`
`remaining allegations of Paragraph 75.
`
`76.
`
`The allegations of Paragraph 76 purport to characterize the claims of the ’264
`
`Patent and set forth legal conclusions to which no response is required. To the extent a response
`
`is required, Defendant denies the accuracy of the language in Paragraph 76, which is an
`
`incomplete and inaccurate characterization of claim 1 of the ’264 Patent, and further denies the
`
`remaining allegations of Paragraph 76.
`
`77.
`
`78.
`
`Defendant denies the allegations of Paragraph 77.
`
`Defendant denies the allegations of Paragraph 78.
`
`C. The Accused Instrumentality
`
`79.
`
`Defendant admits that it provides a service known as “Google Location Services”
`
`or “Google Location Accuracy.” Defendant further admits that it maintains a website at
`
`https://policies.google.com/technologies/location-data?hl=en-US, which states in part:
`
`
`
`15
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`Case 1:22-cv-01331-MSN-IDD Document 48 Filed 03/01/23 Page 16 of 65 PageID# 512
`
`
`
`On most Android devices, Google, as the network location
`provider, provides a location service called Google Location
`Services (GLS), known in Android 9 and above as Google
`Location Accuracy. This service aims to provide a more accurate
`device location and generally improve location accuracy. Most
`mobile phones are equipped with GPS, which uses signals from
`satellites to determine a device’s location – however, with Google
`Location Services, additional information from nearby Wi-Fi,
`mobile networks, and device sensors can be collected to determine
`your device’s location. It does this by periodically collecting
`location data from your device and using it in an anonymous way
`to improve location accuracy.
`
`You can disable Google Location Services at any time in your
`device’s location settings. Your device’s location will continue to
`work even if GLS is turned off, but the device will rely only on
`GPS to estimate device location for apps with the necessary
`permission. Google Location Services is distinct from your
`device’s location setting.
`
`Defendant further admits it maintains a website at
`
`https://support.google.com/nexus/answer/3467281?hl=en, which states in part that “Location in
`
`Search: To get more helpful results when you search on Google, learn how to manage location
`
`permissions for websites and apps.” Defendant denies the remaining allegations of Paragraph
`
`79.
`
`80.
`
`Defendant admits that it maintains a website at
`
`https://policies.google.com/technologies/location-data?hl=en-US, which states in part:
`
`On most Android devices, Google, as the network location
`provider, provides a location service called Google Location
`Services (GLS), known in Android 9 and above as Google
`Location Accuracy. This service aims to provide a more accurate
`device location and generally improve location accuracy. Most
`mobile phones are equipped with GPS, which uses signals from
`satellites to determine a device’s location – however, with Google
`Location Services, additional information from nearby Wi-Fi,
`mobile networks, and device sensors can be collected to determine
`your device’s location. It does this by periodically collecting
`location data from your device and using it in an anonymous way
`to improve location accuracy.
`
`
`
`16
`
`

`

`Case 1:22-cv-01331-MSN-IDD Document 48 Filed 03/01/23 Page 17 of 65 PageID# 513
`
`
`
`You can disable Google Location Services at any time in your
`device’s location settings. Your device’s location will continue to
`work even if GLS is turned off, but the device will rely only on
`GPS to estimate device location for apps with the necessary
`permission. Google Location Services is distinct from your
`device’s location setting.
`
`Defendant denies the remaining allegations of Paragraph 80.
`
`81.
`
`Defendant admits that it maintains a website at
`
`https://developers.google.com/location-context/fused-location-provider, which states in part:
`
`Apps can take advantage of the signals provided by multiple
`sensors in the device to determine device location. However,
`choosing the right combination of signals for a specific task in
`different conditions is not simple. Finding a solution that is also
`battery-efficient is even more complicated.
`
`The fused location provider is a location API in Google Play
`services that intelligently combines dif