Case 3:20-cv-06262-LB Document 1 Filed 09/03/20 Page 1 of 45
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`Matthew K. Blackburn (SBN 261959)
`mblackburn@diamondmccarthy.com
`DIAMOND McCARTHY LLP
`150 California Street Suite 2200
`San Francisco, California 94111
`T: 415.692.5200 ‖ F: 415.263.9200
`
`Allan B. Diamond (pro hac vice to be filed)
`adiamond@diamondmccarthy.com
`John Sample (pro hac vice to be filed)
`john.sample@diamondmccarthy.com
`DIAMOND McCARTHY LLP
`909 Fannin Street, 37th Floor
`Houston, Texas 77010
`T: 713.333.5100 ‖ F: 713.333.5199
`
`Attorneys for Plaintiffs
`NANTWORKS, LLC and
`NANT HOLDINGS IP, LLC
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`NANTWORKS, LLC, and NANT
`HOLDINGS IP, LLC,
`Plaintiffs,
`
`Case No. 3:20-cv-06262
`COMPLAINT FOR PATENT INFRINGEMENT
`JURY TRIAL DEMANDED
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`v.
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`NIANTIC, INC.,
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`Defendant.
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`Plaintiffs NantWorks, LLC (“NantWorks”) and Nant Holdings IP, LLC
`(“Nant IP”) (collectively, “Plaintiffs ”), by and through their undersigned counsel, bring this
`action for patent infringement under 35 U.S.C. § 271 against defendant Niantic, Inc.
`(“Niantic” or “Defendant”) alleging, based upon personal knowledge with respect to
`themselves and their own acts and on information and belief as to other matters, as follows:
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`COMPLAINT FOR PATENT INFRINGEMENT
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`INTRODUCTION
`This is a civil action by plaintiffs NantWorks and Nant IP against
`1.
`defendant Niantic to stop its infringement of U.S. Patent Nos. 10,403,051 (the
`“’051 Patent”), 10,614,477 (the “’477 Patent”), and 10,664,518 (the “’518 Patent”)
`(collectively, the “Asserted Patents”), which claim groundbreaking augmented reality
`(“AR”) and gaming systems and methods for using them.
`Plaintiffs develop various technologies to advance healthcare,
`2.
`commerce, and digital entertainment. NantWorks founder, Dr. Patrick Soon - Shiong, comes
`from a medical background, and has pioneered revolutionary new therapies for both cancer
`and diabetes by combining medical, engineering, and other disciplines. He is passionate
`about the innovative potential of converging disparate technologies and creative talents, and
`his inventions have been recognized by the issuance of hundreds of patents worldwide
`ranging from breakthrough cancer therapies to mobile location - based services. Dr. Soon -
` Shiong also is an avid investor in entrepreneurial companies with game - changing
`technologies in the fields of healthcare, education, science, and technology.
`Through multiyear efforts, involving investments of tens of millions of
`3.
`dollars and the work of dozens of employees, Plaintiffs have developed a wide array of
`proprietary intellectual property relating to digital entertainment, including AR. As
`innovators, Plaintiffs safeguard their valuable intellectual property and have patented the
`cutting - edge features of their AR, image recognition, and gaming technologies that make
`digital entertainment products useful, efficient, and engaging for the end - user, including the
`Asserted Patents.
`Defendant Niantic directly infringes the Asserted Patents by making,
`4.
`using, offering to sell, and/or selling in the United States and/or importing into the United
`States AR games (including its Pokémon Go Application (“Pokémon Go App”) and its
`Harry Potter Application (“Harry Potter App”)). When these AR games are downloaded
`onto mobile devices, permitted to interact with backend servers, and used by Niantic, its
`employees, or its agents, these games practice the inventions claimed in one or more claims
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`COMPLAINT FOR PATENT INFRINGEMENT
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`of each of the Asserted Patents, as detailed below.
`Defendant Niantic also indirectly infringes the Asserted Patents by
`5.
`inducing its customers and/or consumer end - users to directly infringe the Asserted Patents.
`Niantic induces infringement by providing AR games, including its Pokémon Go App and
`its Harry Potter App, that when downloaded onto mobile devices, which devices are
`permitted to interact with backend servers, and used by customers and/or consumer end -
` users for AR gaming, as directed and intended by Niantic, cause those customers and/or
`end - users to practice the inventions claimed in one or more claims of the Asserted Patents,
`as detailed below.
`Plaintiffs bring this suit to stop Niantic’s free - riding on their patented
`6.
`technologies, and they seek damages and other relief for Niantic’s infringement of the
`Asserted Patents.
`
`THE PARTIES
`Plaintiff NantWorks, LLC is a Delaware limited liability company
`7.
`with its principal place of business located at 9920 Jefferson Boulevard, Culver City,
`California 90232. NantWorks is the exclusive licensee of patents covering digital
`entertainment (such as AR and gaming technologies), including the Asserted Patents.
`Plaintiff Nant Holdings IP, LLC is a Delaware limited liability
`8.
`company with its principal place of business located at 9920 Jefferson Boulevard, Culver
`City, California 90232. Nant IP owns patents covering digital entertainment (such as AR
`and gaming technologies), including the Asserted Patents.
`Defendant Niantic, Inc. is a Delaware corporation with its principal
`9.
`place of business located at 2 Bryant Street, Suite 220, San Francisco, California 94105.
`Niantic maintains offices in San Francisco, California, operates and owns the websites
`located at www.nianticlabs.com and niantic.helpshift.com, and markets, offers, and
`distributes throughout the United States (including in California and within this District) AR
`gaming applications, including the Pokémon Go App and the Harry Potter App, that
`infringe the Asserted Patents as set out herein.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`JURISDICTION AND VENUE
`10. This is an action for patent infringement arising under the Patent Laws
`of the United States, 35 U.S.C. § 1 et seq. This Court has exclusive subject matter
`jurisdiction over this Complaint and the matters asserted herein under 28 U.S.C. §§ 1331
`and 1338(a).
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`11. This Court has both general and specific personal jurisdiction over
`Niantic, who has established minimum contacts with this forum such that the exercise of
`jurisdiction over Niantic would not offend traditional notions of fair play and substantial
`justice. Niantic is registered to do business in the State of California (Registration
`No. C3815285). Niantic maintains regular and established places of business in California,
`including its principal place of business in this District, and conducts continuous and
`systematic business in California, including in this District and elsewhere in California. In
`addition, Niantic has committed, and continues to commit, acts that infringe the Asserted
`Patents in violation of 35 U.S.C. § 271 in California (including in this District) by, among
`other things, making, using, testing, offering to sell, selling, and/or importing products and
`services that infringe the Asserted Patents, as set forth herein. In conducting business in
`California and in this District, Niantic derives substantial revenue from the infringing
`products being used, offered for sale, sold, and/or imported in California and this District.
`These acts by Niantic have caused injury to Plaintiffs in California, including in this
`District.
`
`12. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b),
`at least because Niantic has committed and continues to commit acts of direct and indirect
`patent infringement in this District giving rise to this action, regularly conducts business in
`this District, has a regular and established place of business in this District and employs
`engineers and/or other personnel within this District, including at its principal place of
`business in San Francisco, and is subject to personal jurisdiction in this District.
`INTRADISTRICT ASSIGNMENT
`13. This is an intellectual property action to be assigned on a district - wide
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`Case 3:20-cv-06262-LB Document 1 Filed 09/03/20 Page 5 of 45
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`basis under Civil Local Rule 3 - 2(c).
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`BACKGROUND
`NantWorks’ Innovation
`14. Although the potential of digital entertainment (including AR and
`gaming) was clear by 2011, developers faced daunting technical challenges in trying to
`incorporate these technologies into mobile devices. Digital entertainment products had to
`deliver on the promise of a fun and engaging experience at speeds and with a visual quality
`that was unknown at that time in mobile devices.
`15. That same year NantWorks was founded and invested in Fourth Wall
`Studios, a Culver City, California - based company, to develop immersive storytelling
`techniques for gaming. This began a four - year effort toward developing original digital
`entertainment content to enable interaction with fictional worlds using mobile devices,
`browsers, and even social networks.
`16. Nantworks’ engineers initially began conceptualizing an AR game,
`which they would later call “Scavenger Hunt,” and by December 2012 they had a fully 
`operational application which allowed teams of Nantworks’ employees to use their mobile
`devices and search for AR objects around the company’s office during a NantWorks’
`holiday party.
`
`17. By 2013, Nantworks’ AR technologies had caught the attention of
`Jakks Pacific (a leading toy and consumer products company), which partnered with
`Nantworks to develop AR toys using Nantworks’ groundbreaking image recognition
`technology to allow children to interact with associated AR characters using their mobile
`device’s camera:
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`COMPLAINT FOR PATENT INFRINGEMENT
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`https://www.reuters.com/article/us-disneytoys/disney-joins-jakks-la-billionaire-to-bring-
`toys-to-life-idUSBRE9070CU20130108.
`18. These early successes tangibly demonstrated AR’s promise in many
`contexts (including not just gaming, but also in - store product promotion and even
`medicine). However, providing realistic AR on mobile devices has proven to be very
`difficult. Existing mobile platforms required development of proprietary intellectual
`property, which led to the ’051 Patent and the ’518 Patent. Efforts to develop AR - based
`games led to development of other proprietary intellectual property, including the
`’477 Patent.
`
`19. Nant IP solely owns the Asserted Patents, and NantWorks is the
`exclusive licensee of the Asserted Patents (with the full and exclusive rights to bring suit to
`enforce the Asserted Patents), each of which is described below.
`
`NantWorks’ ’051 Patent
`20. U.S. Patent No. 10,403,051, entitled “Interference based augmented
`reality hosting platforms,” was duly and legally issued by the U.S Patent and Trademark
`Office on September 3, 2019. A true and correct copy of the ’051 Patent is attached as
`Exhibit A. The ’051 Patent identifies Patrick Soon - Shiong as the inventor. The patent
`application from which the ’051 Patent issued was filed on November 9, 2018. The
`’051 Patent claims priority through a series of applications to, inter alia, U.S. Provisional
`Appl. No. 61/473,324, filed April 8, 2011.
`21. The ’051 Patent explains that AR “represents a presentation of virtual
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`objects along side real - world elements.” See, e.g., ’051 Patent, 1/32 - 33. In one prior AR
`system, users were given access to multiple, distinct, and separate AR layers, and users had
`to manually select which layer of AR content to see. See, e.g., id., 1/53 - 61. The ’051 Patent
`explains that “users should be able to seamlessly access or interact with [AR] content as
`naturally as they would interact with real - world elements.” See, e.g., id., 1/63 - 67.
`22. Then, the ’051 Patent explains that “[s]ome progress had been made
`towards creating a seamless integration between user and augmented reality environments.”
`See, e.g., id., 2/1 - 3. After introducing several existing AR systems that allow some AR
`content contextualization, the ’051 Patent notes that these systems “fail to appreciate that
`objects within an environment or scene can interfere with each other to give rise to an
`augmented reality experience.” See, e.g., id., 2/3 - 29; see also id., 2/37 - 41.
`23. Also, “existing infrastructures fail to treat [AR] objects as distinct
`manageable objects in an infrastructure agonistic [sic agnostic ] manner… .” See, e.g., id.,
`3/8 - 11. Without the ability provided by the ’051 Patent, certain AR objects would always
`appear on top of all other AR objects and could not appear to go behind any other AR
`objects. For example, a gaming avatar (an AR object that is always visible) would not be
`able to go behind or around other AR objects.
`24. As AR objects proliferate, “individuals still require presentation of
`relevant [AR] content especially when features, real or virtual, of an [AR] can interfere with
`each other.” See, e.g., id., 3/15 - 20.
`25. The claims of the ’051 Patent are directed to technological
`improvements in delivering a realistic AR experience with AR objects within an
`environment or scene that can interfere with each other. The claims of the ’051 Patent relate
`to particular solutions that provide AR objects within an environment or scene that can
`interfere with each other. The ’051 Patent, for example, discloses the use of at least one
`context related to the AR capable device and pertinent to the environment based at least on
`device location, identifying relevant AR objects representing available AR objects
`corresponding to the at least one context, and determining whether to alter presence of a
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`relevant AR object based on at least the device location and the virtual element attribute.
`See, e.g., id., 3/43 - 52; see also id,. 21/47 - 22/2. “Augmented reality context can now be
`used to determine how elements in a scene, a location relevant to an individual, can interfere
`with each other to give rise to relevant [AR] experiences.” See, e.g., id., 3/49 - 52; see also
`id,. 3/30 - 34.
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`26. As the ’051 Patent explains, relevant AR objects can have an altered
`presence due to interference among elements within a scene. See, e.g., id., 17/63 - 66. The
`nature of relevant AR objects, the context, and other factors relating to the scene can trigger
`enhanced or suppressed presence. See, e.g., id., 18/18 - 21; see also id., 18/42 - 45. For
`example, Figure 4 of the ’051 Patent shows that an AR object can be either an enhanced
`presence (reference numeral 446A below) or a suppressed presence (reference numeral
`446B below):
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`The technology of the ’051 Patent enables this type of interaction as well as others, allowing
`a much more compelling AR experience.
`27. Exemplary claim 1 of the ’051 Patent, for example, reads as follows:
`1. An augmented reality (AR) platform system comprising:
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`an AR object repository storing available AR objects in a first
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`non - transitory computer readable memory; and
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`an AR server coupled with the AR object repository and,
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`upon execution of software instructions stored in a second non -
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` transitory computer readable memory by a processor, is
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`configured to:
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`obtain digital data representative of an environment of an AR
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`capable mobile device, the digital data including a device
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`location of the AR capable device and a virtual element
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`attribute;
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`determine at least one context related to the AR capable device
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`and pertinent to the environment based at least on the device
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`location;
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`identify relevant AR objects from the AR object repository
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`representing available AR objects corresponding to the at least
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`one context;
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`determine whether to alter presence of a relevant AR object
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`based on at least the device location and the virtual element
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`attribute; and
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`cause the AR capable device to render the relevant AR object
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`according to its altered presence.
`(Id., 21/47 - 22/2).
`28. According to the U.S. Patent and Trademark Office (“USPTO”)
`examiner, the best prior art was U.S. Patent Publication No. 2010/0017722 to Cohen
`(“Cohen”), which disclosed an AR gaming platform. ’051 Patent File History, Notice of
`Allowance, April 10, 2019, at 2 – 3. However, Cohen lacked several claimed features of the
`’051 Patent, including among other features, “determin[ing] whether to alter presence of a
`relevant AR object based on at least the device location and a virtual element attribute” and
`“caus[ing] the AR capable device to render the relevant AR object according to its altered
`presence.” Id. at 3 – 4.
`29. AR platform systems that determined whether to alter presence of a
`relevant AR object based on at least the device location and the virtual element attribute
`were not common or conventional at the time of the ’051 Patent.
`30. The inventor of the ’051 Patent recognized that prior AR systems
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`failed to deliver an experience with objects within an environment or scene that can
`interfere with each other to give rise to an AR experience. To the contrary, existing AR
`systems sought to avoid interference among elements of the augmented reality by simply
`forcing individuals to select which features to experience. See, e.g., ’051 Patent, 3/25 - 27.
`Also, interference among elements was not managed according to the properties or
`attributes of the specific AR elements. See, e.g. ,id., 3/27 - 29.
`31. As taught by the ’051 Patent, the disclosed invention determines
`whether to alter presence of a relevant AR object based on at least the device location and
`the virtual element attribute. See, e.g. ,id., Abstract, and 5/36 - 44.
`32. Given the state of the art at the time of the invention of the
`’051 Patent, the inventive concepts of the ’051 Patent were not conventional, well -
` understood, or routine. The ’051 Patent discloses, among other things, an unconventional
`and technological solution to an issue arising specifically in the context of AR capable
`devices, and the delivery of AR content to such devices. The solution implemented by the
`’051 Patent provides a specific and substantial improvement over prior AR systems,
`resulting in an improved system for the delivery of AR to end - users. The ’051 Patent
`achieves this result by determining at least one context related to the AR capable device and
`pertinent to the environment based at least on the device’s location; identifying relevant AR
`objects from the AR object repository representing available AR objects corresponding to
`the at least one context; and determining whether to alter presence of a relevant AR object
`based on at least the device location and the virtual element attribute. See, e.g., id., Abstract
`and 21/59 - 67.
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`33. Consistent with the problem addressed being rooted in providing AR
`for AR capable devices, the ’051 Patent’s solutions also are rooted in that same technology
`that cannot be performed with pen and paper or in the human mind. This technical context is
`reflected in the ’051 Patent’s claims. For example, claim 1 recites “an AR object repository
`storing available AR objects in a first non - transitory computer readable memory,” “an AR
`server coupled with the AR object repository,” and “an AR capable mobile device.” See id.,
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`21/49 - 56.
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`34. A person having ordinary skill in the art at the time of the inventions
`of the ’051 Patent would not have understood how the inventions could or would be
`performed solely using pen and paper or in the human mind. Using pen and paper would
`ignore the stated purpose of the ’051 Patent of providing AR content to an AR capable
`mobile device and the problem it was specifically designed to address, which arose in the
`context of needing an improved system and method for delivering AR content to mobile
`devices. Doing so would also run counter to the inventor’s detailed description of the
`inventions and the length of the claims, and be a practical impossibility.
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`NantWorks’ ’477 Patent
`35. U.S. Patent No. 10,614,477, entitled “Subscription bill service,
`systems and methods,” was duly and legally issued by the U.S Patent and Trademark Office
`on April 7, 2020. A true and correct copy of the ’477 Patent is attached as Exhibit B. The
`’477 Patent identifies Patrick Soon - Shiong as the inventor. The patent application from
`which the ’477 Patent issued was filed on May 24, 2019. The’477 Patent claims priority
`through a series of applications to, inter alia, U.S. Provisional Appl. No. 61/562,385, filed
`November 21, 2011.
`36. The claims of the ’477 Patent are directed to technological
`improvements in in - game transaction infrastructure technologies. See, e.g., ’477 Patent,
`1/26 - 27. The ’477 Patent explains that “existing transaction systems provide a single
`provider the ability to conduct a transaction with a single user” and “lack the ability to
`offer … consumers a system that can reconcile aspects of a transaction among multiple …
`user accounts.” See, e.g., id., 1/38 - 43, 1/62 - 64, and 1/67 - 2/2. Also, “existing transaction
`systems apparently fail to reconcile aspects of a transaction based at least in part on derived
`object attributes.” See, e.g., id., 1/64 - 67.
`37. The claims of the ’477 Patent disclose particular solutions to the
`technical problem of facilitating in - game transactions between two players. The
`’477 Patent, for example, discloses the use of determining, within a computer game, at least
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`one object attribute based on physical location data associated with a first player whose
`physical location has been acquired by a location sensor, determining transaction amounts
`of game points the accounts of two players based on a reconciliation matrix and the at least
`one object attribute based on the physical location data, and reconciling a game transaction,
`when a criterion based on the physical location data of the first player is met within the
`computer game, among the first account and the second account in accordance with the
`determined transaction amounts.
`38. Exemplary claim 20 of the ’477 Patent, for example, reads as follows:
`20. A reconciliation system, comprising:
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`at least one processor communicatively coupled with at least
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`one memory storing instructions that, when executed by the at
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`least one processor, cause the at least one processor to:
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`determine, within a computer game, at least one object
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`attribute based on physical location data associated with a first
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`player whose physical location has been acquired by a location
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`sensor;
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`determine transaction amounts of game points for a first
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`account of the first player and a second account of a second
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`player, the transaction amounts being determined based on a
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`reconciliation matrix and the at least one object attribute
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`based on the physical location data; and
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`cause reconciliation of a game transaction, when a criterion
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`based on the physical location data of the first player is met
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`within the computer game, among the first account and the
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`second account in accordance with the determined transaction
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`amounts,
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`wherein the game transaction comprises a first transfer of at
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`least a first amount of game points associated with the first
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`Case 3:20-cv-06262-LB Document 1 Filed 09/03/20 Page 14 of 45
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`account based on at least a portion of the transaction
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`attributed to a first entity associated with the first account and
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`a second transfer of at least a second amount of game points
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`associated with the second account based on at least a portion
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`of the transaction attributed to a second entity associated with
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`the second account.
`(Id., 34/1 - 27).
`39. According to the USPTO examiner, the claims of the ’477 Patent
`issued because, among other reasons, the prior art fails to teach the reconciliation step when
`a criterion based on the physical location data of the first player is met within the computer
`game. ’477 Patent File History, Notice of Allowance, November 14, 2019, at 4.
`40. Determining transaction amounts of game points based on a
`reconciliation matrix and the at least one object attribute based on the physical location data
`and then reconciling a game transaction, when a criterion based on the physical location
`data of the first player is met within the computer game was not common or conventional at
`the time of the ’477 Patent.
`41. The inventor of the ’477 Patent recognized that prior transaction
`infrastructure technologies were ill - suited for on - line transactions because they only
`allowed a single provider the ability to conduct a transaction with a single user and lacked
`the ability to offer providers or consumers a system that can reconcile aspects of a
`transaction among multiple providers or user accounts.
`42. Given the state of the art at the time of the inventions of the
`’477 Patent, the inventive concepts of the ’477 Patent were not conventional, well -
` understood, or routine. The ’477 Patent discloses, among other things, an unconventional
`and technological solution to an issue arising specifically in the context of computer
`gaming, and the ability of two players of the computer game to reconcile a transaction
`between themselves. The solution implemented by the ’477 Patent provides a specific and
`substantial improvement over prior systems used for this purpose, resulting in an improved
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`Case 3:20-cv-06262-LB Document 1 Filed 09/03/20 Page 15 of 45
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`system for reconciling in - game transactions between two players using mobile devices.
`Rather than relying on one - dimensional transaction systems that provide a set transactional
`price or value for a specific object, the ’477 Patent inventor introduced the use of location
`and context to the process of reconciling in - game transactions in order to enhance the game
`experience. The ’477 Patent achieves this result by reconciling a game transaction when a
`criterion based on the physical location data of the first player is met within the computer
`game. See, e.g., ’477 Patent, 31/51 - 53.
`43. Consistent with the problem addressed being rooted in computer
`gaming, the ’477 Patent’s solutions also are rooted in that same technology that cannot be
`performed with pen and paper or in the human mind. This technical context is reflected in
`the ’477 Patent’s claims. For example, the claims recite “determin[ing], within a computer
`game, at least one object attribute based on physical location data associated with a first
`player whose physical location has been acquired by a location sensor,” “determin[ing]
`transaction amounts of game points for a first account of the first player and a second
`account of a second player, the transaction amounts being determined based on a
`reconciliation matrix and the at least one object attribute based on the physical location
`data,” and “caus[ing] reconciliation of a game transaction, when a criterion based on the
`physical location data of the first player is met within the computer game, among the first
`account and the second account in accordance with the determined transaction amounts.”
`See, e.g., id., 34/6 - 20.
`44. A person having ordinary skill in the art at the time of the inventions
`of the ’477 Patent would not have understood how the inventions could or would be
`performed solely using pen and paper or in the human mind. Using pen and paper would
`ignore the stated purpose of the ’477 Patent of reconciling transactions within a computer
`game and the problem it was specifically designed to address, which arose in the context of
`needing an improved system and method for reconciling in - game transactions between two
`players. Doing so would also run counter to the inventor’s detailed description of the
`inventions and the length of the claims, and be a practical impossibility.
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`Case 3:20-cv-06262-LB Document 1 Filed 09/03/20 Page 16 of 45
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`NantWorks’ ’518 Patent
`45. U.S. Patent No. 10,664,518, entitled “Wide Area Augmented Reality
`Location - Based Services,” was duly and legally issued by the U.S Patent and Trademark
`Office on May 26, 2020. A true and correct copy of the ’518 Patent is attached as Exhibit
`C. The ’518 Patent identifies David McKinnon, Kamil Wnuk, Jeremi Sudol, Matheen
`Siddiqui, John Wiacek, Bing Song, and Nicholas J. Witchey as the inventors. The patent
`application from which the ’518 Patent issued was filed on October 26, 2017. The ’518
`Patent claims priority through a series of applications to, inter alia, U.S. Provisional Appl.
`No. 61/892,238, filed October 17, 2013.
`46.
`The claims of the ’518 Patent are directed to improved AR service
`technologies. See, e.g., ’518 Patent, 1/15 - 16. The ’518 Patent explains, with the
`popularization of AR, attempts had been made to employ object recognition and location
`tracking. See, e.g., id., 1/26 - 31. One prior art system “schedule[s] content distribution to a
`mobile device by storing different locations, collecting user location data over a period of
`time, collecting wireless signal strength data, and scheduling pre - caching of content to the
`device if the user is predicted to be at a location with poor signal strength.” See, e.g., id.,
`1/48 - 55.
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`47. However, these known references “fail to consider that areas have
`various views of interest, and fail to differentiate between sub - areas based on AR content
`densities.” See, e.g., id., 2/1 - 5. Existing location - based AR systems “fail to contemplate
`segmenting an area into clusters based on what is viewable or what AR content is
`available.” See, e.g., id., 2/5 - 8.
`48.
`The ’518 Patent discloses particular solutions to the technical problem
`of providing AR content to mobile devices. The ’518 Patent, for example, explains that “a
`device (e.g., a mobile device, a kiosk, a tablet, a cell phone, a laptop, a watch, a vehicle, a
`server, a computer, etc.)” is configured “to obtain at least a portion of the subset based on
`the tile map (e.g., based on the device'