Exhibit B to the Complaint

1

U.S. Patent No. 9,300,723 v. Wondershare Technology Group Co Ltd

Claims 22, 24, 27, 29, 30.

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 1 of 63 PageID #: 20
Exhibit B to the Complaint

2

1. Claim Chart

Claim Analysis

[22.P] 

A 

metho

d of 

transfe

rring a 

media 

file 

from a 

wirele

ss

mobile 

device 

to a 

media 

system 

over a 

comm

unicati

on 

networ

k, the 

media 

system 

includi

ng a 

securit

y 

measu

Wondershare (“Company”) performs and/or induces others to perform a method of transferring a media file from a wireless 

mobile device to a media system over a communication network, the media system including a security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Company provides a MobileTrans App, a data transfer application installed on both Android phone and iPhone. 

The MobileTrans App utilizes a wireless internet connection (“communication network”) that allows the iPhone (“wireless 

mobile device”) to send files (“transferring a media file”) to the Android phone (“media system”).

Furthermore, the Android phone and the iPhone do not require users to input the email and the password every time they 

communicate. Instead, the email and password input are necessary ("security measure") during the initial connection process, 

and thereafter, the devices automatically exchange data without requiring users to re-enter the email and password.

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 2 of 63 PageID #: 21
Exhibit B to the Complaint

3

re, 

compr

ising:

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

wireless 

mobile 

device

media 

system

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 3 of 63 PageID #: 22
Exhibit B to the Complaint

4

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:07

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 4 of 63 PageID #: 23
Exhibit B to the Complaint

5

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:09

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 5 of 63 PageID #: 24
Exhibit B to the Complaint

6

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:10

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 6 of 63 PageID #: 25
Exhibit B to the Complaint

7

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:11

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 7 of 63 PageID #: 26
Exhibit B to the Complaint

8

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 8 of 63 PageID #: 27
Exhibit B to the Complaint

9

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 9 of 63 PageID #: 28
Exhibit B to the Complaint

10

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 (annotated)

WLAN 

network

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 10 of 63 PageID #: 29
Exhibit B to the Complaint

11

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 11 of 63 PageID #: 30
Exhibit B to the Complaint

12

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 12 of 63 PageID #: 31
Exhibit B to the Complaint

13

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:21

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 13 of 63 PageID #: 32
Exhibit B to the Complaint

14

Source: https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.1] 

dispos

ing the 

media 

Company performs and/or induces others to perform the step of disposing the media system in an accessible relation to at least 

one interactive computer network that has a wireless range structured to permit authorized access to said at least one interactive 

computer network, wherein the wireless mobile device within said wireless range, wherein said wireless mobile device is 

detectable by said media system.

media system 

security 

measure

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 14 of 63 PageID #: 33
Exhibit B to the Complaint

15

system 

in an 

access

ible 

relatio

n to at

least 

one 

interac

tive 

compu

ter 

networ

k that 

has a 

wirele

ss 

range 

structu

red to 

permit 

author

ized 

access 

to said

at least 

one 

interac

tive 

compu

ter 

networ

k, 

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the MobileTrans App is installed on both Android phone (“media system”) and iPhone (wireless mobile device). 

The phones utilize the file transfer feature to send/receive files via a WLAN connection (“interactive computer network”). The 

Android phone makes use of the WLAN connection for wirelessly transmitting files to the nearby (“wireless range”) iPhone. 

The Android phone needs to scan a QR code (“authorized access”) through the MobileTrans app to establish a connection with 

the nearby (“wireless range”) iPhone. After a successful scan, the Android phone transfers the files to the iPhone through the 

established WLAN connection. Additionally, if the user cannot connect through QR code scanning, the MobileTrans app offers 

a functionality where the Android phone can connect to a local wireless internet connection. To connect to a local wireless 

router, the user must input a username and password for authorized access. Since wireless routers have an inherent wireless 

range. Given that the WLAN connection has a defined range, and the Android phone establishes the WLAN connection while 

the iPhone connects to the established WLAN for receiving files. Therefore, it would be apparent to a person of ordinary skill 

in the art that the iPhone is disposed within said wireless range and it is detectable by the Android phone.

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

wireless 

mobile 

device

media 

system

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 15 of 63 PageID #: 34
Exhibit B to the Complaint

16

wherei

n the

wirele

ss 

mobile 

device 

within 

said 

wirele

ss 

range,

wherei

n said 

wirele

ss 

mobile 

device 

is 

detect

able 

by 

said

media 

system

,

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:10 (annotated)

media 

system

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 16 of 63 PageID #: 35
Exhibit B to the Complaint

17

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:11 (annotated)

Android 

phone 

sends 

media files 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 17 of 63 PageID #: 36
Exhibit B to the Complaint

18

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

media

system wireless 

mobile 

device

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 18 of 63 PageID #: 37
Exhibit B to the Complaint

19

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

media 

system 

disposing

in an 

accessible 

relation

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 19 of 63 PageID #: 38
Exhibit B to the Complaint

20

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 (annotated)

interactive 

computer 

network

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 20 of 63 PageID #: 39
Exhibit B to the Complaint

21

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19 (annotated)

media 

system 

disposed 

in an 

accessible 

relation 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 21 of 63 PageID #: 40
Exhibit B to the Complaint

22

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.2] 

initiall

y 

dispos

ing at 

least 

one 

digital 

media 

Company performs and/or induces others to perform the step of initially disposing at least one digital media file on the wireless 

mobile device, said media system being structured to detect said wireless mobile device disposed within said wireless range.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the iPhone (“wireless mobile device”) utilizes the WLAN connection for wirelessly sending (“initially disposing”)

the files (“digital media file”) to the nearby (“wireless range”) Android phone (“media system”). It would be apparent to a 

person of ordinary skill in the art that the Android phone (“media system”) being structured to detect said wireless mobile 

device.

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 22 of 63 PageID #: 41
Exhibit B to the Complaint

23

file on 

the

wirele

ss 

mobile 

device

, said 

media 

system 

being 

structu

red to 

detect 

said 

wirele

ss 

mobile 

device 

dispos

ed

within 

said 

wirele

ss 

range,

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

wireless 

mobile 

device

media 

system

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 23 of 63 PageID #: 42
Exhibit B to the Complaint

24

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:10 (annotated)

media 

system

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 24 of 63 PageID #: 43
Exhibit B to the Complaint

25

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:11 (annotated)

media 

system 

sends the 

digital 

media file 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 25 of 63 PageID #: 44
Exhibit B to the Complaint

26

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.3] 

structu

ring a 

comm

unicati

on link 

to 

dispos

Company performs and/or induces others to perform the step of structuring a communication link to dispose said media system 

and said wireless mobile device in a communicative relation with one another via said at least one interactive computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the user initiates the login process to their Wondershare account using the Android phone ("media system"). This 

involves entering login credentials such as email and password. After the login process, the Android phone ("media system") 

displays the QR code, which is then scanned by the iPhone ("wireless mobile device") to establish a connection with the Android 

wireless 

mobile 

device

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 26 of 63 PageID #: 45
Exhibit B to the Complaint

27

e said 

media

system 

and 

said 

wirele

ss 

mobile 

device 

in a 

comm

unicative 

relatio

n with 

one 

anothe

r via 

said at 

least 

one

interac

tive 

compu

ter 

networ

k,

phone through a WLAN ("interactive computer network"). Consequently, this procedure establishes a communication channel 

("structuring a communication link to dispose") between the Android phone and the iPhone.

Source: https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079 (annotated)

user login to 

Wondershare 

account

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 27 of 63 PageID #: 46
Exhibit B to the Complaint

28

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:10 (annotated)

media 

system

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 28 of 63 PageID #: 47
Exhibit B to the Complaint

29

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

media 

system 

wireless 

mobile 

device

media 

system 

displays 

the QR 

code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 29 of 63 PageID #: 48
Exhibit B to the Complaint

30

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

iPhone 

scans the 

QR code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 30 of 63 PageID #: 49
Exhibit B to the Complaint

31

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 (annotated)

interactive 

computer 

network

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 31 of 63 PageID #: 50
Exhibit B to the Complaint

32

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.4] 

initiati

ng 

said 

comm

unicati

on link 

by 

said 

media 

Company performs and/or induces others to perform the step of initiating said communication link by said media system.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the user of Android phone (“media system”) initiates login process by inputting the login credentials such as email 

and password. This process established the communication channel between the Android phone and the iPhone.

communication 

link establishes 

between media 

system and 

wireless mobile 

device

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 32 of 63 PageID #: 51
Exhibit B to the Complaint

33

system

,

Source: https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079 (annotated)

user login to 

Wondershare 

account

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 33 of 63 PageID #: 52
Exhibit B to the Complaint

34

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:10 (annotated)

media 

system

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 34 of 63 PageID #: 53
Exhibit B to the Complaint

35

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

media 

system 

displays 

the QR 

code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 35 of 63 PageID #: 54
Exhibit B to the Complaint

36

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

iPhone 

scans the 

QR code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 36 of 63 PageID #: 55
Exhibit B to the Complaint

37

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 37 of 63 PageID #: 56
Exhibit B to the Complaint

38

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.5] 

transm

itting 

by 

said 

wirele

ss 

mobile 

device 

Company performs and/or induces others to perform the step of transmitting by said wireless mobile device to the media system

said at least one digital media file therebetween via said communication link.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, in file transfer feature, the iPhone ("wireless mobile device ") utilizes the established communication channel to 

send (“transmitting”) files (“digital media file”) to the iPhone (“media system”).

media 

system 

initiates a 

connection

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 38 of 63 PageID #: 57
Exhibit B to the Complaint

39

to the 

media

system 

said at 

least 

one 

digital 

media 

file 

thereb

etwee

n

via 

said 

comm

unicati

on 

link, 

and

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

wireless 

mobile device

media 

system

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 39 of 63 PageID #: 58
Exhibit B to the Complaint

40

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:11 (annotated)

Android 

phone 

sends the 

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 40 of 63 PageID #: 59
Exhibit B to the Complaint

41

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 41 of 63 PageID #: 60
Exhibit B to the Complaint

42

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[22.6] 

wherei

n said 

comm

unicati

on link 

is 

structu

red to 

bypass

Company performs and/or induces others to perform the step of wherein said communication link is structured to bypass the 

security measure of the media system for a limited permissible use of the communication link by the wireless mobile device for 

only transferring the at least one digital media file to, and displaying the at least one digital media file on, the media system.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Android phone and the iPhone do not require users to input the email and the password ("security measure") 

every time they communicate. Instead, the email and password input are necessary during the initial connection process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the email and password. Therefore, upon 

information and belief, the communication link is structured to bypass the security measure of the media system. Furthermore, 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 42 of 63 PageID #: 61
Exhibit B to the Complaint

43

the 

securit

y 

measu

re of 

the 

media 

system 

for a 

limite

d

permis

sible 

use of 

the 

comm

unicati

on link 

by the 

wire

less 

mobile 

device 

for 

only 

transfe

rring 

the at 

least 

one

digital 

media 

file to, 

the iPhone utilizes the communication channel exclusively for transmitting the files to the Android phone (“bypass the security 

measure of the media system for a limited permissible use of the communication link by the wireless mobile device for only 

transferring the at least one digital media file”). The Android phone display the files which are received from the iPhone. 

Source: https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079 (annotated)

media terminal 

security 

measure

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 43 of 63 PageID #: 62
Exhibit B to the Complaint

44

and 

displa

ying 

the at 

least 

one

digital 

media 

file on, 

the 

media 

system

.

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

media 

system

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 44 of 63 PageID #: 63
Exhibit B to the Complaint

45

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

iPhone 

scans a QR 

code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 45 of 63 PageID #: 64
Exhibit B to the Complaint

46

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 46 of 63 PageID #: 65
Exhibit B to the Complaint

47

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 47 of 63 PageID #: 66
Exhibit B to the Complaint

48

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[24] 

The 

metho

d of 

claim 

22, 

wherei

n the 

transm

ission 

Company performs and/or induces others to perform the step of transmission of the at least one digital media file from the 

wireless mobile device to the media system completely bypasses the security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Android phone and the iPhone do not require users to input the email and the password ("security measure") 

every time they communicate. Instead, the email and password input are necessary during the initial connection process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the email and password. Therefore, upon 

information and belief, the channel created between the iPhone and the Android phone bypass the security measure.

media 

system 

displays 

the 

digital 

media 

file 

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 48 of 63 PageID #: 67
Exhibit B to the Complaint

49

of the 

at least 

one 

digital 

media 

file 

from 

the 

wirele

ss 

mobile

device 

to the 

media 

system 

compl

etely 

bypass

es the 

securit

y 

measu

re. Source: https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079 (annotated)

media system 

security 

measure

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 49 of 63 PageID #: 68
Exhibit B to the Complaint

50

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

wireless 

mobile 

device

media 

system

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 50 of 63 PageID #: 69
Exhibit B to the Complaint

51

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

media 

system 

displays 

QR code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 51 of 63 PageID #: 70
Exhibit B to the Complaint

52

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

iPhone 

scans a QR 

code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 52 of 63 PageID #: 71
Exhibit B to the Complaint

53

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 (annotated)

WLAN

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 53 of 63 PageID #: 72
Exhibit B to the Complaint

54

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:19 (annotated)

media 

system

connection

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 54 of 63 PageID #: 73
Exhibit B to the Complaint

55

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[27] 

The 

metho

d of 

claim 

22, 

wherei

n the 

comm

unicati

Company performs and/or induces others to perform the step of the communication link is at least one of a peer-to-peer 

connection, bluetooth connection, and a WiFi connection.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the iPhone transmits the files to the nearby Android phone using the WLAN connection (“WiFi connection”).

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 55 of 63 PageID #: 74
Exhibit B to the Complaint

56

on link 

is at 

least 

one of 

a peertopeer 

conne

ction, 

blueto

oth 

conne

ction, 

and a 

WiFi 

conne

ction.

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 56 of 63 PageID #: 75
Exhibit B to the Complaint

57

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:14 (annotated)

Android 

displays 

the QR 

code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 57 of 63 PageID #: 76
Exhibit B to the Complaint

58

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:16 (annotated)

iPhone 

scans the 

QR code

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 58 of 63 PageID #: 77
Exhibit B to the Complaint

59

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:17 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[29] 

The 

metho

d of 

claim 

22, 

further 

compr

ising 

Company performs and/or induces others to perform the step of presenting the at least one digital media file on a display.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Android displays (“presenting”) the received files (“digital media file”).

WLAN

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 59 of 63 PageID #: 78
Exhibit B to the Complaint

60

presen

ting 

the at 

least 

one 

digital 

media 

file on 

a 

displa

y.

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 60 of 63 PageID #: 79
Exhibit B to the Complaint

61

Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:20

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

[30] 

The 

metho

d of 

claim 

22, 

wherei

n the 

at least 

one 

Company performs and/or induces others to perform the step of at least one digital media file is provided by the wireless mobile 

device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the iPhone (“wireless mobile device") transmits the files (“at least one digital media file”) to the Android phone.

display 

digital 

media file

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 61 of 63 PageID #: 80
Exhibit B to the Complaint

62

digital 

media 

file is 

provid

ed by 

the 

wirele

ss 

mobile 

device

.

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html (annotated)

Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall supplement 

these contentions pursuant to production of such source code by the Defendant.

digital 

media file

wireless mobile 

device

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 62 of 63 PageID #: 81
Exhibit B to the Complaint

63

2. List of References

1. https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html, last accessed on December 29, 2023.

2. https://accounts.wondershare.com/web/loginnew?_gl=1%2a1p2a9bm%2a_gcl_au%2aMjAxMzkyNTU2NC4xNzAyODg0MDc3%2a_ga%2aMTEyMjM1MjAwNC4xNz

AyODg0MDc5%2a_ga_24WTSJBD5B%2aMTcwMzgzMDY4My42LjAuMTcwMzgzMDY5MS41Mi4wLjA.&_ga=2.25957

4346.1909711405.1703824421-1122352004.1702884079, last accessed on December 29, 2023.

3. https://www.youtube.com/watch?v=WuBk-YjJll4, last accessed on December 29, 2023.

4. https://mobiletrans.wondershare.com/phone-to-phone-transfer.html, last accessed on December 29, 2023.

5. https://mobiletrans.wondershare.com, last accessed on December 29, 2023.

Case 2:24-cv-00046-JRG-RSP Document 1-2 Filed 01/25/24 Page 63 of 63 PageID #: 82