Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 1 of 122 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`Plaintiff,
`
`
`EBUDDY TECHNOLOGIES B.V.,
`
`
`
`v.
`
`LINKEDIN CORPORATION
`
`
`
`
`
`
`
`
`
`C.A. No.
`
`
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Defendant.
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`Plaintiff, eBuddy Technologies B.V. (hereinafter, “EBT” or “Plaintiff”), by and through
`
`its undersigned counsel, files this Original Complaint against Defendant LinkedIn Corporation
`
`(hereinafter, “LinkedIn” or “Defendant”), as follows:
`
`NATURE OF THE ACTION
`
`1. This is a patent infringement action to stop Defendant’s infringement of United States
`
`Patent Nos. 8,510,395 (the “‘395 Patent”)(attached as Exhibit 1), 9,584,453 (the “‘453
`
`Patent)(attached as Exhibit 2), 8,230,135 (the “‘135 Patent”)(attached as Exhibit 3) and 8,402,179
`
`(the “‘179 Patent”)(attached as Exhibit 4) (collectively, the “Patents-in-Suit”).
`
`PARTIES
`
`2. Plaintiff eBuddy Technologies B.V. is a private limited liability company incorporated
`
`under the laws of the Netherlands.
`
`3. Upon information and belief, Defendant LinkedIn is a corporation organized and existing
`
`under the laws of the State of Delaware, with a place of business at 2029 Stierlin Court, Mountain
`
`View, California 94043, and can be served through its registered agent, Corporation Service
`
`Company, 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 2 of 122 PageID #: 2
`
`
`
`JURISDICTION AND VENUE
`
`4. This action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.,
`
`including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction
`
`over this case for patent infringement under 28 U.S.C. §§ 1331 and 1338(a).
`
`5. This Court has personal jurisdiction over LinkedIn, including because LinkedIn is a
`
`Delaware corporation; LinkedIn has minimum contacts within the State of Delaware; LinkedIn
`
`has purposefully availed itself of the privileges of conducting business in the State of Delaware;
`
`LinkedIn regularly conducts business within the State of Delaware; and Plaintiff’s cause of action
`
`arises directly from LinkedIn’s business contacts and other activities in the State of Delaware,
`
`including at least by virtue of LinkedIn’s infringing methods, systems, computer-readable media,
`
`and products, which have been, and are currently, at least practiced, made, and/or used in the State
`
`of Delaware. Defendant is subject to this Court’s specific and general personal jurisdiction,
`
`pursuant to Constitutional Due Process and the Delaware Long Arm Statute. Defendant is subject
`
`to this Court’s general personal jurisdiction due at least to its continuous and systematic business
`
`contacts in Delaware, including related to operations conducted in Delaware and the infringements
`
`alleged herein. Further, on information and belief, LinkedIn is subject to this Court’s specific
`
`jurisdiction, including because LinkedIn has committed patent infringement in the State of
`
`Delaware, including as detailed herein. In addition, LinkedIn induces infringement of the Patents-
`
`in-Suit by customers and/or infringing users located in Delaware. Further, on information and
`
`belief, LinkedIn regularly conducts and/or solicits business, engages in other persistent courses of
`
`conduct, and/or derives substantial revenue from goods and services provided to persons and/or
`
`entities in Delaware.
`
`2
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 3 of 122 PageID #: 3
`
`6. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 and 1400(b), including
`
`because LinkedIn resides in the State of Delaware at least by virtue of the fact that it is incorporated
`
`in this state and at least some of the direct and/or indirect infringement of the Patents-in-Suit occurs
`
`in this District.
`
`THE PATENTS-IN-SUIT
`
`7. EBT is the owner of all right, title, and interest in the Patents-in-Suit, including the right to
`
`sue for past, present, and future infringement thereof and to collect damages for any such past,
`
`present, or future infringement. The inventions disclosed and claimed in the ‘395 and ‘453 Patents
`
`comprising, inter alia, contact aggregation between different messaging services, provide
`
`numerous benefits over any prior systems or methods. The inventions disclosed and claimed in the
`
`‘135 and ‘179 Patents comprising, inter alia, event notification, provide numerous benefits over
`
`any prior systems, methods, or non-transitory computer-readable media.
`
`The ‘395 and ‘453 Patents
`
`8. The matters described and claimed by the ‘395 Patent generally include, inter alia, systems
`
`comprising a network login engine; a network contacts database embodied in one or more non-
`
`transitory computer readable mediums; a web server coupled to the network contacts database; a
`
`contact aggregation engine coupled to the network login engine and the network contacts database;
`
`wherein, in operation, the contact aggregation engine: controls the network login engine to login
`
`or facilitate login to a first network associated with a first messaging service provider and a second
`
`network associated with a second messaging service provider, updates the networks contacts
`
`database with contact information obtained from the first messaging service provider and the
`
`second messaging service provider, maintains an aggregated contact list that comprises a first
`
`contact list associated with the contact information from the first messaging service provider and
`
`3
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 4 of 122 PageID #: 4
`
`a second contact list associated with the contact information from the second messaging service
`
`provider, stores the aggregated contact list in a non-transitory computer readable medium at the
`
`web server, and provides the aggregated contact list to a display device.
`
`9. The matters described and claimed by the ‘395 Patent also generally include, inter alia,
`
`methods comprising joining a high level network; joining a first low level network associated with
`
`a first messaging service provider and a second low level network associated with a second
`
`messaging service provider; obtaining a first contact list associated with the first messaging service
`
`provider; obtaining a second contact list associated with the second messaging service provider;
`
`maintaining an aggregated contact that comprises the first contact list and the second contact list;
`
`logging into the high level network; displaying the aggregated contact list.
`
`10. The asserted claims of the ‘395 Patent, when viewed as a whole, including as an ordered
`
`combination, are not merely the recitation of well-understood, routine, or conventional
`
`technologies or components. The claimed inventions were not well-known, routine, or
`
`conventional at the time of the invention, including with regard to message services, including
`
`web-based messaging services, over ten years ago, and represent specific improvements over the
`
`prior art systems and methods.
`
`11. The matters described by the ‘453 Patent generally include, inter alia, systems for contact
`
`list aggregation across a plurality of different networks comprising a network interface; a network
`
`login engine coupled to the network interface; a network contacts database embodied in one or
`
`more non-transitory computer-readable mediums; a server coupled to the network contacts
`
`database; a contact aggregation engine coupled to the network login engine and the network
`
`contacts database; wherein, in operation, the contact aggregation engine controls the network login
`
`engine to login or facilitate login to a plurality of low level networks associated with a plurality of
`
`4
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 5 of 122 PageID #: 5
`
`messaging services through a high level network using the network interface to access contact
`
`information from the plurality of messaging services, updates the networks contacts database based
`
`on the contact information associated with the plurality of low level networks to create an
`
`aggregated contact list, stores the aggregated contact list in a non-transitory computer-readable
`
`medium at the server, and provides the aggregated contact list including the contact information
`
`to a display device.
`
`12. The matters described by the ‘453 Patent also generally include, inter alia, methods for
`
`contact list aggregation across a plurality of different networks comprising joining a high level
`
`network; joining a plurality of low level networks associated with a plurality of messaging services
`
`through the high level network; obtaining a first contact list associated with the plurality of low
`
`level networks; maintaining a second contact list associated with the high level network;
`
`maintaining a contact list associated with the plurality of low level networks for the plurality of
`
`messaging services; logging into the high level network; displaying contacts from the plurality of
`
`low level networks and the high level network in an aggregated contact list, the contacts retrieved
`
`by logging into the high level network.
`
`13. The matters described by the ‘453 Patent also generally include, inter alia, non-transitory
`
`computer readable medium comprising executable instructions, the instructions being executable
`
`by a processor to perform a method for contact list aggregation across a plurality of different
`
`networks, the method comprising: joining a high level network; joining a plurality of low level
`
`networks associated with a plurality of messaging services through the high level network;
`
`obtaining a first contact list associated with the plurality of low level networks; maintaining a
`
`second contact list associated with the high level network; maintaining a contact list associated
`
`with the plurality of low level networks for the plurality of messaging services; logging into the
`
`5
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 6 of 122 PageID #: 6
`
`high level network; displaying contacts from the plurality of low level networks and the high level
`
`network in an aggregated contact list, the contacts retrieved by logging into the high level network.
`
`14. The asserted claims of the ‘453 Patent, when viewed as a whole, including as an ordered
`
`combination, are not merely the recitation of well-understood, routine, or conventional
`
`technologies or components. The claimed inventions were not well-known, routine, or
`
`conventional at the time of the invention, including with regard to message services, including
`
`web-based messaging services over ten years ago, and represent specific improvements over the
`
`prior art systems and methods.
`
`15. At the time of the ‘395 and ‘453 patented inventions, including in instant messaging
`
`systems, adding contacts to a user’s contact list was cumbersome and inefficient. Contacts were
`
`typically added by finding a contact in the messaging service, typically followed by sending an
`
`invitation request via that specific messaging service so that the recipient could also accept the
`
`sender to his/her contact list (or reject the sender so that the sender could not send messages to the
`
`recipient). Conventionally, each such list of contacts was contained wholly within the user’s
`
`account for each specific, separate messaging service used by the particular user. Conventionally,
`
`this manual method of aggregating contacts was required for each separate messaging service used
`
`by the user. However, even this conventional functionality was limited to cases where both users
`
`were already existing users of a particular system. If one of the users was not a member of a
`
`particular messaging service, further, cumbersome steps were required that included, inter alia,
`
`inviting a user to join the messaging service (e.g., via phone call or email invitation) and requiring
`
`that user to then sign up and/or create an account for the messaging service.
`
`16. At the time of said inventions, prior art systems and methods were not able to aggregate
`
`contacts between different instant messaging services or to view contact information of one instant
`
`6
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 7 of 122 PageID #: 7
`
`messaging service in another instant messaging service. At that time, the most common and
`
`practical way to aggregate contacts was by manually typing each name and e-mail address (and/or
`
`other contact information) into the user’s contact list.
`
`17. The ‘395 and ‘435 claimed inventions address technical problems, including that, at the
`
`time of the ‘395 and ‘435 inventions, aggregation of contacts from a plurality of messaging
`
`services was unavailable and/or was cumbersome (e.g., having to manually transfer contact files
`
`from one service to another); prone to potential errors (e.g., input errors from manually inputting
`
`contact data) and subject to incompatibility issues (e.g., a contact list from one service was not
`
`usable or accessible by another service).
`
`18. The ‘395 and ‘435 claimed inventions provide specific technological solutions, including
`
`permitting, allowing and/or facilitating logging in to first, second or plurality of networks
`
`associated with a first, second, and/or plurality of messaging services; obtaining and/or accessing
`
`contact information from the first, second and/or plurality of low level networks associated with
`
`the first, second and/or plurality of messaging services and aggregating the contacts associated
`
`with the first, second and/or plurality of low level networks associated with the first, second and/or
`
`plurality of messaging services with the contact from and/or associated with the high level
`
`network.
`
`19. The ‘395 and ‘435 claimed inventions provide additional specific technological solutions
`
`including allowing and/or facilitating logging into a plurality of low level networks to obtain a
`
`contact list from the plurality of low level networks and aggregating the contact lists from the
`
`plurality of low level networks, including aggregating the contact lists from the plurality of low
`
`level networks with contacts from the high level network.
`
`7
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 8 of 122 PageID #: 8
`
`20. The ‘395 and ‘435 claimed inventions achieve their inventive improvement in
`
`unconventional ways. Without limitation, it was unconventional at the time of the ‘395 and ‘435
`
`inventions to log in to and/or facilitate logging in to a plurality of low level networks from a high
`
`level network to, inter alia, obtain contact lists from the plurality of low level networks and
`
`aggregate the contact lists from the low level networks via a contact aggregation engine of the high
`
`level network; and it was unconventional to have a network based, application neutral content
`
`application, as opposed to the conventional local application specific contacts lists that – if the
`
`contacts could be ported at all - had to be manually aggregated via a file exported from one local
`
`application and then imported into another local application.
`
`21. Other systems and methods less efficient and more cumbersome than those claimed by the
`
`‘395 and ‘453 Patents included exporting a contact list from one application or device as a file,
`
`and then importing the file on another application or device. However, this was inefficient and
`
`cumbersome, and it required multiple actions by the user. For example, U.S. Patent No. 7,469,379
`
`to Kaplan (“Kaplan”), which was cited and addressed extensively during prosecution of both the
`
`’395 and ‘453 Patents, describes an inferior, prior art system wherein a wireless network maintains
`
`a message contact list on a network server and makes the contact list available to devices that can
`
`connect to a radio frequency (“RF”) card serviced by a single messaging service provider. The
`
`single contact list of Kaplan could be provided to different devices to which the RF card was
`
`connected. However, Kaplan did not describe, inter alia, the contact aggregation engine of the
`
`claimed inventions, nor did Kaplan describe obtaining a first contact list associated with a first
`
`messaging service provider and a second contact list associated with a second messaging service
`
`provider or maintaining an aggregated contact list that comprises the first and second contact lists.
`
`Further, Kaplan did not describe accessing a plurality of low level networks through a high level
`
`8
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 9 of 122 PageID #: 9
`
`network to access a contact databases, or the plurality of low level networks associated with a
`
`plurality of messaging services as claimed in the ’395 and ‘453 Patents.
`
`22. In addition, conventional systems and methods required manual updating, by typing in new
`
`contacts, or doing a new export/import with the risk of double and/or inconsistent contacts because
`
`the export typically included all contacts again.
`
`23. These prior art methods and systems for aggregating contacts were in use and available;
`
`however, they were and still are inferior to the inventions of the ’395 and ‘453 Patents including
`
`because, as described herein, they are more cumbersome, error prone and less efficient, and they
`
`require more steps. Reasons that prior art systems and methods were inferior include their lack of
`
`an inventive contact aggregation engine, their lack of an inventive network login engine associated
`
`with a network for logging to other networks which allows, inter alia, a user to aggregate contacts
`
`from such other networks, their lack of a network, e.g., Internet, based application neutral, content
`
`aggregation solution, and/or their lack of an inventive process for logging into low level networks
`
`through a high level network. Inventive concepts embodied in the ’395 and ‘453 claimed
`
`inventions thus comprise a network login engine for logging into other networks which allows,
`
`inter alia, a user to aggregate contacts from such other networks; a network, e.g., Internet, based
`
`application neutral content aggregation solution as contrasted with state of the art application
`
`specific contact lists that could only be aggregated by exporting contacts from a locally run
`
`application into a file and then back into a locally run separate application, and/or their inventive
`
`process for logging into low level networks through a high level network. Importantly, including
`
`as noted herein and in the ‘395 and ‘453 Patents, this functionality is not merely an automation or
`
`combination of existing and/or generic components that existed in the art, such as exporting one
`
`contact list from one messaging service and importing it in a contact list of another messaging
`
`9
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 10 of 122 PageID #: 10
`
`service. In fact, computers were already used in connection with inferior prior art systems and
`
`methods, albeit in inferior ways that lacked the inventiveness of the claimed inventions, including
`
`those inferior systems and methods described herein and in the ‘395 and ‘453 Patents.
`
`24. The technology claimed in the ’395 and ‘453 Patents does not unduly preempt other
`
`system and/or methods, including any for aggregating contacts. For example, the claims do not
`
`preempt individually adding contacts to a contact database. Nor do the claims preempt exporting
`
`a file containing contact data from one system and them importing that file, including the contact
`
`data, into a second system. Nor do the claims unduly preempt lesser ways of aggregating contacts
`
`that involve less than the inventive sum of the claimed features.
`
`25. The inventions claimed in the ’395 and ‘453 Patents are directed, among other things, to
`
`solutions to the foregoing and other problems or shortcomings in the art at the time of the invention.
`
`The claimed inventions of the ’395 and ‘453 Patents comprise novel and inventive techniques and
`
`methods for contact list aggregation across networks, including those involving logging into low
`
`level networks through a high level network. For example, using certain technology claimed in
`
`the ’395 and ‘453 Patents, it becomes possible to, among other things, add contacts from one
`
`network or service to a contact list maintained at or by another network or service. This provides
`
`an inventive, more efficient, less error prone, user friendly way to add or aggregate contact
`
`information from multiple messaging services across multiple networks. As opposed to prior art
`
`systems, the inventions claimed in the ’395 and ‘453 Patents, among other things, eliminate the
`
`requirement that contact details be memorized, typed in, and/or copied one-by-one, which also
`
`avoids typographical and other user-based errors. Moreover, contacts are aggregated centrally, so
`
`they can be made available on multiple user devices from a single high level network service. Also,
`
`they can be automatically updated and synchronized, including without manual user interaction.
`
`10
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 11 of 122 PageID #: 11
`
`Including in this way and other ways, the efficiency, interoperability and accuracy of contact
`
`databases is increased, and they may be kept more up to date, and even continuously up to date,
`
`with fewer steps, fewer errors, and less effort.
`
`26. The functionality of contact lists and contact information as known at the time of the
`
`invention (e.g., exporting and importing files containing contact information or individually
`
`adding contact information to an existing contact list) would be implemented on a user device such
`
`as by logging in from the user device to a server and updating contact information, which would
`
`be performed by the user on the user device. Thus, adding a contact aggregation engine and/or
`
`network login engine, as claimed and described in the ’395 and ‘453 Patents, including to the
`
`claimed systems and methods as a whole, was not known, conventional, straightforward or generic.
`
`In addition to the foregoing, at the time of the inventions of the ’395 and ‘453 Patents, a messaging
`
`system assumed that a user (including through a user device) logged in to a single messaging server
`
`system. One messaging system logging into one or more other messaging server systems, including
`
`to obtain one or more low level contact lists and then maintain an aggregate contact list, is a
`
`substantially different approach that was novel and inventive at the time of the invention and
`
`required more than the generic application of computers and/or existing technology.
`
`27. Further, a messaging system with a network login engine that logs in or facilitates login to
`
`other networks associated with service providers was inventive and not conventional. Further, a
`
`contact aggregation engine that controls the network login engine and updates the network contacts
`
`database with contact information from the other networks and stores the aggregated contact list
`
`in a non-transitory computer readable medium was inventive and not conventional.
`
`28. Among other things, the inventors of the ’395 and ‘453 Patents wanted to make contact
`
`information of a user’s contacts in a plurality of messaging services available, including in the
`
`11
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 12 of 122 PageID #: 12
`
`inventive claimed ways, in another messaging service. In this way, a user would, inter alia, be
`
`able to continue using their preferred messaging service while maintaining, viewing and/or
`
`accessing contacts from other messaging services.
`
`29. Importantly, including as noted above, this functionality is not merely an automation or
`
`combination of existing and/or generic components that existed in the art, such as exporting one
`
`contact list from one messaging service and importing it in a contact list of another messaging
`
`service. Further, at the time of inventions of the ‘395 and ‘453 patents, messaging services
`
`typically used proprietary formats and/or protocols which made it difficult to aggregate contacts
`
`across multiple platforms. Additionally, at this time, messaging services typically comprised a
`
`stand-alone (e.g., not web-based) application on the user’s computer.
`
`30. Further advantages and inventive features of the claimed inventions of the ’395 and ‘453
`
`Patents include that the system or method may comprise a user profile database. By storing user-
`
`specific information that the network login engine uses to login or facilitate login to the one or
`
`more networks, contact information can be retrieved and an up-to-date aggregate contact list can
`
`be maintained, with minimum effort by the user. Further, the user-specific information stored or
`
`maintained by the system may be used by the network login engine to login or facilitate login to
`
`one or more networks, including one or more low-level networks. For example, the user can
`
`provide login information once, and the system can login on behalf of the user without further user
`
`action to maintain an up-to-date aggregate contact list, including by the system accessing the low
`
`level network using the stored information and retrieving the user’s contact list for that network to
`
`update the user’s high level network contact list.
`
`31. Using the inventive technology described and claimed in the ’395 and ‘453 Patents, it
`
`becomes possible to add contacts to a contacts database in a first messaging service from another
`
`12
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 13 of 122 PageID #: 13
`
`second messaging service, making it much easier for a user to reach all the user’s contacts from
`
`the first messaging service (e.g., the user’s contacts from multiple messaging service providers are
`
`efficiently aggregated into a single contacts database). This provides, among other things, a user-
`
`friendly and efficient way to add or aggregate contact information from multiple messaging
`
`services. The user typically enters login information for the second messaging provider into the
`
`network login engine of the first messaging system and the contact aggregation engine (including
`
`in conjunction with the network login engine) aggregates contacts of both systems into a single
`
`contacts database. Contact details do not have to be memorized, typed in, or copied one-by-one,
`
`which, as noted above, also avoids errors. Moreover, contacts are aggregated centrally, so they can
`
`be made available on multiple user devices. Also, contact details may be automatically updated
`
`and synchronized, which enables better and more complete contact information (e.g., checking
`
`double contacts, merging contact information, checking inconsistent contact details). All of these
`
`and the other advantages of the claimed inventions illustrate their inventiveness and superiority
`
`over inferior systems and methods in existence at the time of invention.
`
`32. The claims of the ’395 and ‘453 Patents are directed to, among other things, specific
`
`improvements in computer networking and database functionality and capabilities. Among other
`
`things, the claimed inventions improve functionality of contact database systems. Including as
`
`noted in the ’395 and ‘453 Patents, the claimed technologies comprise innovative systems and
`
`processes which increase at least ease-of-use, accuracy and efficiency in contact acquisition and
`
`management of contact databases. The ’395 and ‘453 Patents thus provided concrete applications,
`
`including via use of network login engines, network architecture and integrations, user profiles
`
`and/or contacts aggregated from high and low level networks, that improve computer and database
`
`technology, including for aggregating contacts across networks. Further, by aggregating the user’s
`
`13
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 14 of 122 PageID #: 14
`
`contacts under a single application and/or web service, the user is not required to run multiple
`
`applications or access multiple web services simultaneously. This, in turn, reduces the use of the
`
`user’s computing device and resources thereon.
`
`33. The inventive systems and methods comprise in some instances components and/or
`
`functionality including in the form of a network login engine functionality that logs in or facilitates
`
`login to networks associated with messaging service providers. Such systems and methods also
`
`comprise contact aggregation engine functionality that controls the network login engine and
`
`updates the network contacts database with contact information from the other messaging service
`
`providers and stores the aggregated contact list in a non-transitory computer readable medium.
`
`These and other claimed patented features are novel and inventive technical components and/or
`
`functionality and are not abstract ideas or merely combinations of generic components.
`
`34. Including in accordance with the facts noted above, the noted inventive improvements of
`
`the claimed inventions over the prior art represent meaningful limitations and/or inventive
`
`concepts based upon the state of the art over a decade ago. Further, including in view of specific
`
`improvements, including those noted herein, the inventions of the asserted claims, including when
`
`such claims are viewed as a whole and in ordered combination, are not routine, well-understood,
`
`conventional, generic, existing, commonly used, well known, previously known, typical, and the
`
`like over a decade ago, including because, until the inventions of the asserted claims of the ’395
`
`and ‘453 Patents, the claimed inventions were not existing or even considered in the field.
`
`35. Including in accordance with the facts noted above, the asserted claims, including as a
`
`whole and where applicable in ordered combination, comprise, inter alia, a non-conventional and
`
`non-generic arrangement of communications between networks of messaging service providers,
`
`including to login in or facilitate login to a network including to aggregate contacts into a contacts
`
`14
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 15 of 122 PageID #: 15
`
`database that is a technical improvement to the communications between the devices and web
`
`services, including those improvements noted above.
`
`36. The claims of the ‘395 Patent are necessarily implemented in a networked computer
`
`environment, including to allow, e.g., login or facilitating login to a first network … and a second
`
`network (see, e.g., claim 1); and joining a high level network, joining a first low level network …
`
`and a second low level network (see, e.g., claim 7).
`
`37. The claims of the ‘453 Patent are also necessarily implemented in a networked computer
`
`environment, including to allow, e.g., login or facilitating login to a first network … and a second
`
`network (see, e.g., claim 1); and joining a high level network, joining a first low level network …
`
`and a second low level network (see, e.g., claim 7).
`
`38. The claims of the ‘453 Patent are further necessarily implemented in a networked computer
`
`environment, including as a non-transitory computer readable medium comprising executable
`
`instructions, the instructions being executed by a processor including to allow, e.g., joining a high
`
`level network, joining a plurality of low level networks and logging into the high level network
`
`(see, e.g., claim 12).
`
`39. Including in accordance with the facts noted above, the claimed inventions are necessarily
`
`rooted in computer technology, i.e., network login engine and contacts aggregation engine
`
`functionality, and comprise improvement over prior technologies in order to overcome problems,
`
`including those noted above, specifically arising in the realm of computer networks and database
`
`management (including for messaging service providers) including in combination with the
`
`aggregation of contacts from multiple messaging service providers. The claimed solutions amount
`
`to an inventive concept for resolving particular problems and inefficiencies, including those noted
`
`above, including in connection with logging into and/or facilitating the login into a plurality of
`
`15
`
`

`

`Case 1:20-cv-01501-UNA Document 1 Filed 11/06/20 Page 16 of 122 PageID #: 16
`
`messaging service providers to obtain and aggregat