Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language 1. [1a] An apparatus, comprising: a server; Representative Evidence of Infringement Claim 1 The Accused Uber Apps1 includes a server. For example, on information and belief, the Accused Uber Apps include one or more servers that communicate with the applications that run on wireless devices: [1b] a database representing an The Accused Uber Apps include a database representing an account for a first individual, the account account for a first individual, the having an associated buddy list that identifies multiple users. account having an associated buddy list that identifies multiple users; and For example, according to Uber’s website, a rider must have an Uber account before requesting a ride using the Accused Uber Apps. 1
The Accused Uber Apps include, for example, Uber’s mobile device applications on iOS, Android, and Microsoft operating systems for use in connection with Uber’s ride‐sharing services, as well as servers and software configured or adapted to operate with Uber’s mobile device applications. The Accused Uber Ride‐
Sharing Apps permit a rider to request a ride from a driver through the Uber Ride‐Sharing App or through GoogleMaps on the rider’s mobile device and allow a driver to accept a ride request from a rider. 1 UBER-1023 - Page 1
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement Upon information and belief, the Accused Uber Apps store the Uber account in a database. To the extent the Accused Uber Apps store the Uber account in something other than a database, such a difference would be insubstantial and the Accused Uber Apps would perform substantially the same function, in substantially the same way, to achieve substantially the same result as storing an account in a database. Upon information and belief, the Accused Uber Apps formulate a list of drivers (e.g., a buddy list) associated with the present location of the rider. For example, according to Uber documents, when a rider opens the Uber App, the rider is shown multiple available drivers near the rider. 2 UBER-1023 - Page 2
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement [1c] software responsive to a request The Accused Uber Apps include software responsive to a request from the first individual to obtain a from the first individual to obtain a map, to obtain a last known position for multiple users identified by the buddy list, and to plot the last map, to obtain a last known position for known location of at least two of the multiple users on the map, and to transmit the map with plotted multiple users identified by the buddy locations to the first individual. list, and to plot the last known location of at least two of the multiple users on For example, according to Uber documents, the Accused Uber Apps respond to a request from a first the map, and to transmit the map with individual (a rider) to show a map which indicates the last known location of multiple users (available plotted locations to the first individual; drivers) near the rider’s location. 3 UBER-1023 - Page 3
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement [1d] where the software is to request and store position information associated with cell phones of plural ones of the multiple users and where the software is to permit the first individual to change geography represented by the map and to transmit to the first individual a map representing the changed geography with plotted position of at least one of the multiple users, each in a manner The Accused Uber Apps include software to request and store position information associated with cell phones of plural ones of the multiple users and where the software is to permit the first individual to change geography represented by the map and to transmit to the first individual a map representing the changed geography with plotted position of at least one of the multiple users, each in a manner not requiring concurrent voice communications. For example, according to Uber documents, the Accused Uber Apps display a map on a rider’s cell phone showing the location of available drivers near the rider’s location. The Accused Uber Apps generate this map using software that automatically requests and stores GPS position from drivers’ cell phones. 4 UBER-1023 - Page 4
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language not requiring concurrent voice communications; and Representative Evidence of Infringement The Accused Uber Apps transmit this map with plotted locations to the rider and permit the rider to change the geography represented by the map by zooming and/or panning the map. Once the map is zoomed and/or panned the Accused Uber Apps transmit a new map representing the changed geography to the rider along with the plotted locations of one or more drivers. The Accused Uber Apps do not require concurrent voice communications. [1e] wherein the software to obtain the The Accused Uber Apps include software that obtains the map in a manner having a default map is to obtain the map in a manner geographic resolution. having a default geographic resolution. 5 UBER-1023 - Page 5
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement For example, the Accused Uber Apps display a map having a default geographic resolution. 2. The apparatus of claim 1, further comprising a database that stores last known location for each of the multiple users. Claim 2 The Accused Uber Apps include a database that stores last known location for each of the multiple users. For example, on information and belief, the Accused Uber Apps store the last known location for riders and drivers in a database. To the extent the Accused Uber Apps store the last known location for each of the multuple users in something other than a database, such a difference would be insubstantial and the Accused Uber Apps would perform substantially the same function, in substantially the same way, to achieve substantially the same result as a storing the last known 6 UBER-1023 - Page 6
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement location for each of the multiple users in a database. Claim 5 5. The apparatus of claim 1, where the The Accused Uber Apps include software to permit the first individual to change geography software is to permit the first individual represented by the map by zooming geographic resolution from a first geography to a second to change geography represented by geography. the map by zooming geographic resolution from a first geography to a For example, the Accused Uber Apps respond to a request from a first individual (a rider) to show a second geography. map which indicates the last known location of multiple users (available drivers) near the rider’s location. 7 UBER-1023 - Page 7
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language 6. The apparatus of claim 1, where the software to obtain the map is to obtain the map from a server of a third party map provider. Representative Evidence of Infringement The Accused Uber Apps transmit this map with plotted locations to the rider and permit the rider to change the geography represented by the map by zooming the map. Once the map is zoomed, the Accused Uber Apps transmit a new map representing the changed geography to the rider along with the plotted locations of one or more drivers. Claim 6 The Accused Uber Apps include software to obtain the map is to obtain the map from a server of a third party map provider. For example, on information and belief, the Accused Uber Apps obtain the map from the server of third party map providers such as Google and/or Mapbox. Claim 9 9. The apparatus of claim 1, where a The Accused Uber Apps further comprise software where a specific one of the multiple users is specific one of the multiple users is associated with a time limit for location sharing, and where the software is to disable transmission of associated with a time limit for location a map representing plotted position of the specific one after the time limit has expired. sharing, and where the software is to disable transmission of a map For example, after a rider and driver have shared their location for a predetermined time, the Accused representing plotted position of the Uber Apps will disable transmission of a map representing plotted position of the driver after the time specific one after the time limit has has expired. expired. 8 UBER-1023 - Page 8
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement 19. [19a] An apparatus, comprising: a server; Claim 19 The Accused Uber Apps includes a server. For example, on information and belief, the Accused Uber Apps include one or more servers that communicate with the applications that run on wireless devices: 9 UBER-1023 - Page 9
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement The Accused Uber Apps include a database representing an account for a first individual, the account having an associated buddy list that identifies multiple users. [19b] a database representing an account for a first individual, the account having an associated buddy list that identifies multiple users; For example, according to Uber’s website, a rider must have an Uber account before requesting a ride using the Accused Uber Apps. 10 UBER-1023 - Page 10
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement Upon information and belief, the Accused Uber Apps store the Uber account in a database. To the extent the Accused Uber Apps store the Uber account in something other than a database, such a difference would be insubstantial and the Accused Uber Apps would perform substantially the same function, in substantially the same way, to achieve substantially the same result as storing an account in a database. Upon information and belief, the Accused Uber Apps formulate a list of drivers (e.g., a buddy list) associated with the present location of the rider. For example, according to Uber documents, when a rider opens the Uber App, the rider is shown multiple available drivers near the rider. 11 UBER-1023 - Page 11
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement [19c] software to request and store position information associated with cell phones of plural ones of the multiple users by receiving information from cell phones associated with the respective multiple users in a manner not requiring concurrent voice communications; and The Accused Uber Apps include software to request and store position information associated with cell phones of plural ones of the multiple users by receiving information from cell phones associated with the respective multiple users in a manner not requiring concurrent voice communications. For example, according to Uber documents, the Accused Uber Apps display a map on a rider’s cell phone showing the location of available drivers near the rider’s location. Upon information and belief, the Accused Uber Apps generate this map using software that automatically requests and stores GPS position from drivers’ cell phones. 12 UBER-1023 - Page 12
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language Representative Evidence of Infringement [19d] software responsive to a request The Accused Uber Apps include software responsive to a request from the first individual to obtain a map, to obtain a last known position for multiple users identified by the buddy list, to plot the last from the first individual to obtain a map, to obtain a last known position for known location of at least two of the multiple users on the map, to transmit the map with plotted multiple users identified by the buddy locations to the first individual, and to permit the first individual to change geography represented by list, to plot the last known location of at the map by zooming the map and to responsively transmit to the first individual a map representing the changed geography with plotted position of at least one of the multiple users, each in a manner least two of the multiple users on the map, to transmit the map with plotted not requiring concurrent voice communications. locations to the first individual, and to permit the first individual to change For example, according to Uber documents, the Accused Uber Apps respond to a request from a first geography represented by the map by individual (a rider) to show a map which indicates the last known location of multiple users (available 13 UBER-1023 - Page 13
Exhibit A – USPN 8,798,593 Patent Infringement Contentions
Claim Language zooming the map and to responsively transmit to the first individual a map representing the changed geography with plotted position of at least one of the multiple users, each in a manner not requiring concurrent voice communications. Representative Evidence of Infringement drivers) near the rider’s location. The Accused Uber Apps transmit this map with plotted locations to the rider and permit the rider to change the geography represented by the map by zooming and/or panning the map. Once the map is zoomed and/or panned the Accused Uber Apps transmit a new map representing the changed geography to the rider along with the plotted locations of one or more drivers. The Accused Uber Apps do not require concurrent voice communications. 14 UBER-1023 - Page 14