EXHIBIT A 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 1 of 21
Claim, Limitation Relevant section of trial transcript Failure of Proof 

885 patent, Claim 1 

A computer system for 

providing image-based 

rendering of real property, 

the computer system 

comprising 

576:2-25 

processor implementing 

program commands and 

processing data; memory 

storing program commands 

and processing the data; 

the memory being 

operatively coupled to the 

processor 

577:1-2 Insufficient evidence. Insufficient 

identification of a processor and memory 

operatively coupled with commands. 

user interface visually 

presenting an image-based 

rendering of real property, 

the user interface being 

operatively coupled with 

the memory and the 

processor 

577:24-578:23 Insufficient evidence of: specific user 

interface; “operatively coupled”; “the 

memory and processor” 

wherein the program 

commands cause the 

processor to: 

578:24-579:8 Insufficient evidence. Insufficient 

identification of program commands for 

all elements 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 2 of 21
obtain two or more 

photorealistic viewpoints 

from capture locations in a 

plurality of spaces of the 

real property using ground 

truth image data, the 

ground truth image data 

including images of the 

real property captured from 

capture locations 

579:9-581:10 Insufficient evidence of program 

commands. 

combine and process two 

or more instances of 

ground truth data to create 

a plurality of synthesized 

viewpoints 

Insufficient evidence of program 

commands. 

generate a virtual model of 

a current space from the 

plurality of spaces, in the 

real property from the 

perspective of a current 

viewpoint 

the current viewpoint is 

being one of the plurality 

of photorealistic 

viewpoints or one of the 

synthesized viewpoints 

associated with the current 

space. 

583:22-584:23 

 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 3 of 21
identify the current space 

in the real property where 

the current viewpoint is 

located using metadata 

associated with the ground 

truth image data 

Insufficient evidence of program 

commands 

visually present the virtual 

model on a first portion of 

the user interface, a map 

overlay on a second 

portion of the user 

interface and a text overlay 

on a third portion of the 

user interface 

the map overlay indicating 

a position of the current 

viewpoint in the current 

space, the text overlay 

including a first label 

identifying the current 

space in the real property 

where the current 

viewpoint is located 

586:12-588:12 Insufficient evidence of program 

commands 

generating a plurality of 

spatial boundaries of the 

plurality of spaces of the 

real property, each of the 

plurality of spatial 

boundaries defining a 

parcel outline of a 

corresponding space 

588:12-593:5 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 4 of 21
among the plurality of 

spaces. 

generate the ground truth 

image data by annotating 

the images of the real 

property with second labels 

indicating the capture 

locations using the 

plurality of spatial 

boundaries. 

593:23-595:4. Insufficient evidence of program 

commands 

wherein the virtual model, 

the map overlay and the 

text overlay are 

functionally linked based 

on the position of the 

current viewpoint in the 

real property. 

595:5-11 

 

Insufficient evidence of program 

commands 

wherein identifying the 

current space in the real 

property where the current 

viewpoint is located using 

the metadata associated 

with the ground truth 

image data includes 

identifying the first label 

using the second labels 

indicating the capture 

location 

596:17-598:4 Insufficient evidence of program 

commands 

885 patent, claim 3 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 5 of 21
the computer system of 

claim 1 wherein the 

synthetic viewpoints 

enable rotation about a 

vertical axis and a pitch 

598:15-599:10 Insufficient evidence of program 

commands 

program commands further 

causes the processor to 

receive an offer to schedule 

an in-person tour of the 

real property 

599:23-600:5 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 6 of 21
Claim, Limitation Trial Transcript Discussion Issue 

973 patent, Claim 1 

A computer-readable 

memory medium 

containing program 

commands for controlling 

a computer processor, 

when executed, to provide 

image-based rendering of a 

real property, by 

performing a method 

comprising 

613:16-615:2 Insufficient evidence of computer 

readable memory medium with program 

commands that control a processor to 

perform the required method steps. 

obtaining two or more 

views from capture 

locations in a plurality of 

spaces of the real property 

using ground truth image 

data, the ground truth 

image data, including 

images of the real property 

captured from the capture 

locations 

615:9-616:3 Insufficient evidence of program 

commands 

defining a plurality of 

spatial boundaries of the 

plurality of spaces of the 

real property, each spatial 

boundary delineating a 

volume of one or more of 

the plurality of spaces, at 

616:4-618:23 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 7 of 21
least one of the plurality of 

spatial boundaries defining 

a parcel outline of the real 

property, and at least one 

of the plurality of spatial 

boundaries defining a 

space located within the 

parcel outline; 

annotating the ground truth 

image data by annotating at 

least some of the captured 

images of the real property 

with information indicating 

a capture location of a 

corresponding image 

relative to a corresponding 

spatial boundary, each 

capture location identifying 

a location within the 

corresponding spatial 

boundary defined space or 

identifying the space 

delineated by the 

corresponding spatial 

boundary; 

618:24-620:22 Insufficient evidence of program 

commands 

combining and processing 

two or more instances of 

the ground truth image data 

621:5-622:10 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 8 of 21
to create a plurality of 

synthesized views, 

wherein the synthesized 

views comprise one or 

more of composites, 

transitions, or projections 

derived from processing 

ground truth image data. 

wherein the synthesized 

views are associated with 

the corresponding spaces 

of the plurality of spaces of 

the real property 

622:21-623:1 Insufficient evidence of program 

commands 

generating and rendering a 

virtual model of a current 

space within the plurality 

of spaces of the real 

property from a perspective 

of a current view, the 

current view being one of 

the plurality of views 

obtained using ground 

truth image data or one of 

the plurality of synthesized 

views derived from 

processing ground truth 

data and associated with 

the current space; 

623:6-625:3 

 

Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 9 of 21
identifying the current 

space in the real property 

where the current view is 

located using the capture 

locations indicated by the 

annotated ground truth 

image data 

625:4-625:24 

 

Insufficient evidence of program 

commands 

visually presenting, on the 

user interface, at least a 

portion of the virtual 

model, a map user interface 

element, and a text user 

interface element, the map 

user interface element 

indicating a position of the 

current view in the current 

space, the text user 

interface element including 

a label identifying the 

current space in the real 

property within which the 

current view is located; 

625:25-627:4 Insufficient evidence of program 

commands 

wherein the portion of the 

virtual model, the map user 

interface element and the 

text user interface element 

is functionally linked based 

on the position of the 

current view in the real 

property. 

627:5-627:13 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 10 of 21
973 patent, claim 4 

the computer readable 

memory medium of claim 

1 wherein the map user 

interface element is a 2D 

projection of the rendered 

virtual model. 

628:2-628:18 Insufficient evidence of program 

commands 

973 patent, claims 16 

The computer-readable 

memory medium of claim 

1 wherein the method 

further comprises: 

facilitating a transaction 

regarding the real property. 

629:13-630:10 Insufficient evidence of program 

commands 

973 patent, claim 17 

The computer-readable 

memory medium of claim 

16 wherein the transaction 

further comprises one or 

more of: scheduling a tour, 

initiating messaging, 

initiating audio 

communication, customer 

relationship management, 

transaction document 

signing or tracking, on-line 

negotiations, offer 

submissions, inspection 

629:13-630:10 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 11 of 21
support, financing support, 

real-estate transaction 

workflows, data tracking, 

or reporting functions. 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 12 of 21
Claim, Limitation Trial Transcript Discussion Issue 

673 patent, Claim 1 

 A method, comprising: 564:4-570:2 

receiving image data of a 

plurality of spaces in a 

property, the image data 

including a plurality of 

images captured from a 

plurality of viewpoints; 

See above Insufficient evidence 

creating a plurality of 

panoramas of the plurality 

of spaces using the image 

data; 

See above Insufficient evidence 

rendering a virtual model 

of a selected space among 

the plurality of spaces 

using the plurality of 

panoramas; 

See above Insufficient evidence 

causing a device to display 

the virtual model with a 

first label indicating a 

location of the selected 

space; and

See above Insufficient evidence 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 13 of 21
defining spatial boundaries 

of the plurality of spaces in 

the property using the 

image data, the plurality of 

spaces including a plurality 

of rooms in the property, 

See above Insufficient evidence 

wherein the image data 

includes metadata 

associated with the 

plurality of images, the 

metadata indicating capture 

locations of the images, 

See above Insufficient evidence 

wherein rendering the 

virtual model of the 

selected space includes 

rendering a 3D scene of the 

selected space using the 

plurality of panoramas, and 

See above Insufficient evidence 

wherein rendering the 3D 

scene includes: 

determining camera 

geometry using the 

plurality of images; 

receiving a selected 

viewpoint in the selected 

space;

See above Insufficient evidence 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 14 of 21
generating a point cloud of 

the 3D model; 

determining a geometric 

proxy for the selected 

viewpoint using the 

determined camera 

geometry and the point 

cloud; and 

generating the 3D model 

using the geometric proxy. 

673 patent, claim 2 

The method of claim 1, 

further comprising: 

calibrating the plurality of 

panoramas using the 

camera geometry, 

wherein the camera 

geometry is determined by 

a first pass feature 

detection using the 

plurality of images. 

570:11-573:6 Insufficient evidence. 

673 patent, claim 10 

A system, comprising: 

a processor; 

a memory storing nontransitory program 

commands, which, when 

executed by the processor, 

cause the processor to:

532:17-534:19 Insufficient evidence to show that there is 

“a processor” and “a memory” that has 

commands which when executed cause 

the processor to do anything. Failure to 

identify a particular processor. 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 15 of 21
receive image data of a 

plurality of spaces in a 

property, the image data 

including a plurality of 

images captured from a 

plurality of viewpoints; 

536:21-539:18 Insufficient evidence of program 

commands 

create a plurality of 

panoramas of the plurality 

of spaces using the image 

data; 

540:23-543:21 Insufficient evidence of program 

commands 

render a virtual model of a 

selected space among the 

plurality of spaces using 

the plurality of panoramas; 

543:22-546:4 Insufficient evidence of program 

commands 

cause a device to display 

the virtual model with a 

first label indicating a 

location of the selected 

space, 

546:10-547:24 Insufficient evidence of program 

commands 

wherein the image data 

includes metadata 

associated with the 

plurality of images, the 

metadata indicating capture 

locations of the images, 

547:20-549:7 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 16 of 21
wherein the program 

commands cause the 

processor to render the 

virtual model of the 

selected space by rendering 

a 3D scene of the selected 

space using the plurality of 

panoramas, and 

550:4-22 Insufficient evidence of program 

commands 

wherein the program 

commands cause the 

processor to render the 3D 

scene by: 

determining camera 

geometry using the 

plurality of images; 

receiving a selected 

viewpoint in the selected 

space; 

generating a point cloud of 

the 3D model; 

determining a geometric 

proxy for the selected 

viewpoint using the 

determined camera 

geometry and the point 

cloud; and 

generating the 3D model 

using the geometric proxy. 

550:23-560:1 Insufficient evidence of program 

commands 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 17 of 21
Claim, Limitation Trial Transcript Discussion Issue 

111 patent, Claim 18 

 A method, comprising: 

receiving image data of a 

plurality of spaces in a 

plurality of rooms in a real 

estate property, the image 

data including a plurality 

of images captured from a 

plurality of viewpoints, 

each image corresponding 

to a respective one of the 

plurality of rooms; 

601:15-603:2 Insufficient evidence. 

creating a plurality of 

panoramas of the plurality 

of spaces by processing 

and/or compositing the 

image data; 

603:3-20 Insufficient evidence 

defining a plurality of 

spatial boundaries of the 

plurality of spaces in the 

plurality of rooms in the 

real estate property using 

the image data, each of the 

spatial boundaries 

603:23-607:19 Insufficient evidence 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 18 of 21
delineating a volume of 

one or more of the plurality 

of spaces, wherein the 

volume delineated by a 

first spatial boundary 

corresponds to a first floor 

of the real estate property 

and the volume delineated 

by a second spatial 

boundary corresponds to a 

second floor of the real 

estate property, and 

wherein the defined first 

spatial boundary and 

second spatial boundary 

are further delineations 

within a third spatial 

boundary corresponding to 

a parcel outline of the real 

estate property; 

in response to receiving a 

user indication of a floor of 

the real estate property, 

using the defined spatial 

boundary corresponding to 

the indicated floor, 

rendering a virtual model 

of a selected space of the 

one or more spaces 

delineated by the spatial 

boundary corresponding to 

the indicated floor using 

607:23-609:9 Insufficient evidence 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 19 of 21
one or more of the created 

plurality of panoramas that 

correspond to one or more 

rooms located within the 

spatial boundary 

corresponding to the 

indicated floor; and 

causing a device to display 

the virtual model with a 

first label indicating a 

location of the selected 

space in one of the 

generated plurality of 

spatial boundaries. 

609:9-22 Insufficient evidence 

111 patent, claim 22 

The method of claim 

18 wherein the receiving a 

user indication of a floor of 

the real estate property and 

the rendering a virtual 

model of a selected space 

of the one or more spaces 

delineated by the generated 

spatial boundary 

corresponding to the 

indicated floor, further 

comprises: 

610:2-11 

Insufficient evidence 

generating and displaying a 

floor plan corresponding to 610:12-21 Insufficient evidence. 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 20 of 21
a portion of the real estate 

property; and 

receiving a user indication 

of navigation to a floor of 

the real estate property for 

performing a virtual tour of 

the real estate property by 

receiving an indication to a 

corresponding location on 

the floor plan; and 

611:10-16 Insufficient evidence 

rendering a virtual model 

of a space that corresponds 

to the indicated 

corresponding location on 

the floor plan. 

611:17-612:3 Insufficient evidence. 

Case 6:20-cv-00376-ADA Document 220-1 Filed 05/17/22 Page 21 of 21