PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`[1A] A method for conveying
`information related to locations of a
`plurality of mobile devices of users
`in a plurality of user groups,
`comprising:
`
`Accused Instrumentalities1
`
`Defendant makes, uses, sells, offers to sell, and/or imports the Accused Instrumentalities.2
`PerDiem contends that Defendant directly infringes this claim because it makes, uses, sells, offers to sell,
`and/or imports the Accused Instrumentalities, which include and/or practice each and every element of this
`claim. In addition, or alternatively, PerDiem contends that Defendant and additional actor(s) form a joint
`enterprise to directly infringe this claim because they make, use, sell, offers to sell, and/or import the Accused
`Instrumentalities, which include and/or practice each and every element of this claim. See Akamai Techs., Inc.
`v. Limelight Networks, Inc., No. 2009-1372, 2015 WL 4760450, at *3 (Fed. Cir. Aug. 13, 2015).
`Additionally, Defendant indirectly infringes this claim by (1) inducing, with knowledge of the patent, its
`customers’ (e.g., fleet managers, asset managers, or other customers) use of the Accused Instrumentalities to
`practice each and every one of the following claim elements with knowledge that such practice infringes this
`claim and intent to cause such infringement (as evidenced for example, in instructional materials provided by
`Defendant such as instructions to operate the Accused Instrumentality); and/or (2) contributing to direct
`infringement by customers (e.g., fleet managers, asset managers, or other customers) that use an Accused
`Instrumentality to practice each and every one of the following claim elements, with knowledge that the
`infringing components of the Accused Instrumentalities have no substantial non-infringing uses and that the
`combination for which such components were made infringes the claim.
`They are capable of tracking and notifying a supervisor or manager of an employee’s current location; they
`
`1 Discovery in this case has not yet begun. Accordingly, PerDiem expects that these contentions may be subject to supplementation and/or
`amendment after further discovery and disclosure of Defendant’s non-infringement positions in order to focus the issues in this case. For example,
`PerDiem may supplement these contentions in response to information learned during discovery to rebut allegations of non-infringement under the
`doctrine of equivalents. Additionally, PerDiem expects that these contentions may be subject to amendment or supplementation to identify and
`accuse additional products and services released, developed, or made available after the date on which these contentions are served.
`2 The Accused Instrumentalities include all products and services that convey information for fleets of vehicles or other groups of assets,
`including but not limited to Teletrac’s Solutions, Teletrac’s Fleet Director, Teletrac’s GPS Fleet Tracking, Navman Wireless Fleet and Vehicle
`Tracking Solutions, and Navman Wirelesss Online AVL2, Navman Wireless Drive, Navman Wireless DIRECTOR, Navman Wireless Adaptive
`Intelligence, Navman Wireless Software Plans (including Essential, Fleet+, and Complete); and all related or similar hardware and software.
`
`06371-00001/7197405.1
`
`1
`
`TELETRAC Ex. 1011
`
`1
`
`
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`[1A] A method for conveying
`information related to locations of a
`plurality of mobile devices of users
`in a plurality of user groups,
`comprising:
`
`Accused Instrumentalities1
`
`Defendant makes, uses, sells, offers to sell, and/or imports the Accused Instrumentalities.2
`PerDiem contends that Defendant directly infringes this claim because it makes, uses, sells, offers to sell,
`and/or imports the Accused Instrumentalities, which include and/or practice each and every element of this
`claim. In addition, or alternatively, PerDiem contends that Defendant and additional actor(s) form a joint
`enterprise to directly infringe this claim because they make, use, sell, offers to sell, and/or import the Accused
`Instrumentalities, which include and/or practice each and every element of this claim. See Akamai Techs., Inc.
`v. Limelight Networks, Inc., No. 2009-1372, 2015 WL 4760450, at *3 (Fed. Cir. Aug. 13, 2015).
`Additionally, Defendant indirectly infringes this claim by (1) inducing, with knowledge of the patent, its
`customers’ (e.g., fleet managers, asset managers, or other customers) use of the Accused Instrumentalities to
`practice each and every one of the following claim elements with knowledge that such practice infringes this
`claim and intent to cause such infringement (as evidenced for example, in instructional materials provided by
`Defendant such as instructions to operate the Accused Instrumentality); and/or (2) contributing to direct
`infringement by customers (e.g., fleet managers, asset managers, or other customers) that use an Accused
`Instrumentality to practice each and every one of the following claim elements, with knowledge that the
`infringing components of the Accused Instrumentalities have no substantial non-infringing uses and that the
`combination for which such components were made infringes the claim.
`They are capable of tracking and notifying a supervisor or manager of an employee’s current location; they
`
`1 Discovery in this case has not yet begun. Accordingly, PerDiem expects that these contentions may be subject to supplementation and/or
`amendment after further discovery and disclosure of Defendant’s non-infringement positions in order to focus the issues in this case. For example,
`PerDiem may supplement these contentions in response to information learned during discovery to rebut allegations of non-infringement under the
`doctrine of equivalents. Additionally, PerDiem expects that these contentions may be subject to amendment or supplementation to identify and
`accuse additional products and services released, developed, or made available after the date on which these contentions are served.
`2 The Accused Instrumentalities include all products and services that convey information for fleets of vehicles or other groups of assets,
`including but not limited to Teletrac’s Solutions, Teletrac’s Fleet Director, Teletrac’s GPS Fleet Tracking, Navman Wireless Fleet and Vehicle
`Tracking Solutions, and Navman Wirelesss Online AVL2, Navman Wireless Drive, Navman Wireless DIRECTOR, Navman Wireless Adaptive
`Intelligence, Navman Wireless Software Plans (including Essential, Fleet+, and Complete); and all related or similar hardware and software.
`
`06371-00001/7197405.1
`
`1
`
`TELETRAC Ex. 1011
`
`1
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`also include valuable features, such as “smart geofencing capabilities” and “monitoring zones around driver’s
`homes and customer sites.”
`
`See http://www.teletrac.com/fleet-management-software/gps-mapping/polygon-landmarks.
`
`06371-00001/7197405.1
`
`2
`
`2
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.navmanwireless.com/why-us/benefits/increase-productivity/.
`Companies can organize their vehicles or other assets into groups such as “enhanced vehicle groups” or “sub-
`fleets.”
`
`06371-00001/7197405.1
`
`3
`
`3
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.youtube.com/watch?v=VpY-kCqsgOI.
`
`06371-00001/7197405.1
`
`4
`
`4
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf at
`42.
`
`06371-00001/7197405.1
`
`5
`
`5
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`http://community.teletrac.com/knowledge-center/help-file#ControlPanelTab.
`Security Groups allow different levels of security depending on the user.
`
`06371-00001/7197405.1
`
`6
`
`6
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`http://community.teletrac.com/knowledge-center/help-file.
`
`https://www.navmanwireless.com/fleet-tracking-support/fleet-tracking-faq/#is-there-any-way-to-restrict-
`software-users-from-viewing-certain-vehicles-on-my-fleet.
`
`06371-00001/7197405.1
`
`7
`
`7
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`Defendant will notify a supervisor or manager of a company group if an employee in the company group
`arrives or departs a job, or engages in after-hours motion, or are in/out of key regions.
`
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf at
`16-17.
`
`06371-00001/7197405.1
`
`8
`
`8
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be.
`
`06371-00001/7197405.1
`
`9
`
`9
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`http://community.teletrac.com/knowledge-center/help-file#ControlPanelTab; see also
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`http://www.teletrac.com/gps-fleet-tracking/geo-fencing; http://www.teletrac.com/teletrac/content/orphan-
`pages/10282014-fleet-director-software-features-guide.pdf; https://www.navmanwireless.com/gps-fleet-
`management-solutions/compare-plans/; https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`
`06371-00001/7197405.1
`
`10
`
`10
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file.
`Defendant allows a supervisor or manager to track a fleet from a smartphone of tablet.
`
`See http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-
`guide.pdf at 1.
`
`06371-00001/7197405.1
`
`11
`
`11
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/.
`The method includes the steps set forth in the claim below.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`06371-00001/7197405.1
`
`12
`
`12
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`[1B] creating a plurality of
`information-sharing environments
`over a network of computing
`devices comprising interfaces for
`configuring the plurality of
`information-sharing environments
`for users based on varying levels of
`administrative privileges,
`
`Accused Instrumentalities1
`
`Defendant creates a plurality of information-sharing environments over a network of computing devices
`comprising interfaces for configuring the plurality of information-sharing environments for users based on
`varying levels of administrative privileges.
`For example, Defendant provides a login screen.
`
`See http://www.teletrac.com/login.htm.
`
`06371-00001/7197405.1
`
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to maintain varying levels of administrator privileges. At the first level,
`Defendant controls the creation of fleets of vehicles or other groups of assets and to prevent a customer from
`13
`
`13
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`tracking another company’s vehicles or other assets. At the second level, Defendant permits certain
`individuals (e.g., supervisors or managers) (see http://community.teletrac.com/knowledge-center/help-file;
`https://www.navmanwireless.com/fleet-tracking-support/fleet-tracking-faq/) to track or set geofences and alerts
`for their company’s vehicles or other assets, but not another company’s vehicles or other assets. See
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Defendant provides interfaces for configuring the plurality of information-sharing environments for users
`based on varying levels of administrative privileges. For example, Defendant provides a platform that allows a
`supervisor or manager to set Real-Time, Live Alerts or other alerts. See
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf at
`17; http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf
`at 16.
`Security Groups allow different levels of security depending on the user.
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/.
`The Accused Instrumentalities also allow a supervisor or manager to setup geofences and alerts. See
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`
`06371-00001/7197405.1
`
`14
`
`14
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Defendant has touted the importance of these features.
`
`See http://www.teletrac.com/gps-fleet-tracking/geo-fencing.
`
`06371-00001/7197405.1
`
`15
`
`15
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.navmanwireless.com/what-we-do/fleet-tracking/real-time-analytics/.
`
`06371-00001/7197405.1
`
`16
`
`16
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`https://www.youtube.com/watch?v=DQYpM5owJmc (describing the importance and cost saving of Geofence
`Events).
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`[1C] wherein the plurality of
`information-sharing environments
`comprise a first information-
`
`The plurality of information-sharing environments comprise a first information-sharing environment and a
`plurality of second information-sharing environments.
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`
`06371-00001/7197405.1
`
`17
`
`17
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`sharing environment and a plurality
`of second information-sharing
`environments,
`
`Accused Instrumentalities1
`
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to control the creation of fleets of vehicles or other groups of assets (or
`sub-fleets or sub-groups) and to prevent a customer from tracking another company’s vehicles or other assets.
`Defendant permits certain individuals (e.g., supervisors or managers) to track or set geofences and alerts for
`their company’s fleets of vehicles or other groups of assets (or sub-fleets or sub-groups), but not another
`company’s vehicles or other assets. See http://www.teletrac.com/teletrac/content/orphan-pages/10282014-
`fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`[1D] said plurality of second
`information-sharing environments
`comprising a plurality of
`independently configurable
`location information sharing
`environments created within the
`
`The plurality of second information-sharing environments comprise a plurality of independently configurable
`location information sharing environments created within the first information sharing environment
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to control the creation of fleets of vehicles or other groups of assets (or
`sub-fleets or sub-groups) and to prevent a customer from tracking another company’s vehicles or other assets.
`
`06371-00001/7197405.1
`
`18
`
`18
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`first information sharing
`environment;
`
`Accused Instrumentalities1
`
`Defendant permits certain individuals (e.g., supervisors or managers) to track or set geofences and alerts for
`their company’s fleets of vehicles or other groups of assets (or sub-fleets or sub-groups), but not another
`company’s vehicles or other assets. See http://www.teletrac.com/teletrac/content/orphan-pages/10282014-
`fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`[1E] configuring the first
`information-sharing environment
`based on a first level of
`administrative privilege to
`associate one or more users that use
`the plurality of location
`information sharing environment
`with each one of the plurality of
`user groups;
`
`Defendant configures the first information-sharing environment based on a first level of administrative
`privilege to associate one or more users that use the plurality of location information sharing environment with
`each one of the plurality of user groups.
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to control the creation of fleets of vehicles or other groups of assets (or
`sub-fleets or sub-groups) and to prevent a customer from tracking another company’s vehicles or other assets.
`See http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-
`guide.pdf; https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for
`
`06371-00001/7197405.1
`
`19
`
`19
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`Geofences); see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`Defendant configures each one the plurality of location information-sharing environments for each user group
`independent of one another based on at least one second level of administrative privilege by specifying one or
`more levels of location information access privilege for at least one authorized user (e.g., supervisor or
`manager) in each user group.
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to permit certain individuals (e.g., supervisors or managers) to track or set
`geofences and alerts for their company’s fleets of vehicles or other groups of assets (or sub-fleets or sub-
`groups), but not another company’s vehicles or other assets. See
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`
`[1F] configuring each one the
`plurality of location information-
`sharing environments for each user
`group independent of one another
`based on at least one second level
`of administrative privilege by
`specifying one or more levels of
`location information access
`privilege for at least one authorized
`user in each user group; and
`
`06371-00001/7197405.1
`
`20
`
`20
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`[1G] managing conveyance of
`information related to location of
`the plurality of the mobile devices
`in the plurality of user groups
`based on a plurality of location
`information access privileges
`associated with a plurality of
`authorized users.
`
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`Defendant manages conveyance of information related to location of the plurality of the mobile devices (e.g.
`vehicles, smartphones, or other mobile devices) in the plurality of user groups based on a plurality of location
`information access privileges associated with a plurality of authorized users (e.g., supervisors or managers).
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to permit certain individuals (e.g., supervisors or managers) to track or set
`geofences and alerts for their company’s fleets of vehicles or other groups of assets (or sub-fleets or sub-
`groups), but not another company’s vehicles or other assets. See
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for Geofences);
`see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`
`06371-00001/7197405.1
`
`21
`
`21
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`[2] The method of claim 1,
`wherein the one or more levels of
`location information access
`privilege for the at least one
`authorized user in each user group
`is specified based on the first level
`of administrative privilege.
`
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`The levels of location information access for an authorized user (e.g., supervisor or manager) in each user
`group is specified based on the first level of administrative privilege.
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to control the creation of fleets of vehicles or other groups of assets (or
`sub-fleets or sub-groups) and to prevent a customer from tracking another company’s vehicles or other assets.
`See http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-
`guide.pdf; https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be (describing Live Alerts for
`Geofences); see also http://www.teletrac.com/gps-fleet-tracking/geo-fencing;
`http://www.teletrac.com/teletrac/content/orphan-pages/10282014-fleet-director-software-features-guide.pdf;
`https://www.navmanwireless.com/gps-fleet-management-solutions/compare-plans/;
`https://www.youtube.com/watch?v=VUOjjfYJZnE&feature=youtu.be;
`https://www.youtube.com/watch?v=DQYpM5owJmc; https://www.navmanwireless.com/what-we-do/fleet-
`tracking/real-time-analytics/; https://www.youtube.com/watch?v=VpY-kCqsgOI;
`https://www.navmanwireless.com/gps-fleet-management-solutions/onlineavl2/features/mobileavl2/;
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/; https://www.navmanwireless.com/fleet-tracking-support/downloads/.
`Because this claim element may be implemented, at least in part, by software in the Accused Instrumentalities,
`pursuant to P.R. 3-4(a), Defendant must produce source code for each Accused Instrumentality. Ioli Trust et
`al. v. Avigilon Corp, 2012 WL 5830711 (E.D. Tex. Nov. 16, 2012). PerDiem reserves the right to supplement
`
`06371-00001/7197405.1
`
`22
`
`22
`
`
`
`PerdiemCo, LLC v. Teletrac, Inc. and Navman Wireless North America Ltd.
`EXHIBIT C TO PERDIEM’S PRELIMINARY INFRINGEMENT CONTENTIONS (9/16/2015)
`
`U.S. Pat. No. 8,717,166
`
`Accused Instrumentalities1
`
`[3] The method of claim 2,
`wherein a user identification code
`is associated with the at least one
`authorized user in each user group,
`wherein the user identification code
`is associated with a group
`identification code[] in one or more
`user information databases based
`on the first level of administrative
`privilege.
`
`its infringement contentions for this limitation after Defendant produces source code for each Accused
`Instrumentality.
`
`A user identification code is associated with an authorized user (e.g., supervisor or manager) in each user
`group, wherein the user identification code (e.g., identifier for supervisor or manager) is associated with a
`group identification code in user information database(s) based on the first level of administrative privilege.
`For example, Defendant provides a login screen. See http://www.teletrac.com/login.htm;
`https://www.navmanwireless.com/fleet-tracking-support/downloads/. Defendant uses the login screen, as well
`as additional hardware and software, to permit certain individuals (e.g., supervisors or managers) (see
`http://community.teletrac.com/knowledge-center/help-file; https://www.navmanwireless.com/fleet-tracking-
`support/fleet-tracking-faq/) to set geofences and alerts for their company’s vehicles or other assets, but not
`another company’s vehicles or other assets. Each supervisor or manager has at least a
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