Case 2:19-cv-04544-PSG-MAA Document 2-6 Filed 05/24/19 Page 1 of 14 Page ID #:129
`
`Exhibit F
`
`Two Tap
`Exhibit 1008
`Page 001
`
`
`
`Exhibit F
`
`Two Tap
`Exhibit 1008
`Page 001
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 2 of 14 Page ID #:130
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`Infringement Analysis
`
`US. Patent No. 9 697 563 - Claim 1
`
`Plaintiff 72LuX, Inc. d/b/a Shoppable.com (“Shoppable”) hereby submits the following preliminary infringement analysis illustrating
`how the Accused Two Tap Product (herein, “Two Tap” or the “Accused Product”) infringes US. Patent No. 9,697,563 (the “’563
`Patent”). For purposes of this analysis, Claim 1 of the ‘563 Patent is used as an exemplary claim to illustrate Defendants’
`infringement of the ‘563 Patent.
`
`This infringement chart is based on publicly available information. Shoppable reserves the right to modify its infringement analysis
`on the basis of information discovered about the Accused Product that Shoppable obtains during discovery.
`
`1. A method comprising:
`
`Claim 1
`
`retrieving, by a processing device, merchandise data from a plurality
`of independent merchants which is stored in a merchandise database;
`
`consolidating the retrieved merchandise data into a common format;
`
`
`
`\
`
`
`
`Accused Product
`
`I
`
`Two Tap infringes the method described in Claim 1, as
`follows:
`
`Using Two Tap, merchandise data is retrieved by a
`processing device from multiple independent merchants
`and stored in a merchandise database:
`
`“The Pass-Through model allows the same functionality
`and feature set to be available for thousands of
`supported merchants” — https://twotap.com/why-twotap/
`
`“Two Tap is powered by a robust API platform that can
`send orders to thousands ofmerchants.”
`http s ://twotap_. com/why-twotap/
`
`Two Tap consolidates the retrieved merchandise data into a
`common format:
`
`“Product catalog attributes are compatible with /cart.
`When using third party sources you often have to make
`
`Two Tap
`Exhibit 1008
`Page 002
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 3 of 14 Page ID #:131
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`Claim 1
`
`l
`
`Accused Product
`
`V
`
`sure their attribute format matches the way Twe Tap
`wants the data.” http://docstwotap.com/docs/product-
`catalog
`
`“Two Tap delivers a unified feature set across all
`supported merchants making your job much easier.
`Built using the most advanced set of tools, real-time
`product data is delivered allowing shoppers to make
`accurate buying decisions.”
`https://twotap.com/integrating-twotap/
`
`“Using Two Tap’s API moans access to the same set of
`features across all of our supported merchants.”
`https://twotap.com/integrating-twotap/
`
`Using Two Tap, the merchandise database is available to
`multiple publishers:
`
`“Two Tap allows resellers (apps, vendors,
`marketplaces, etc) to place orders on supplier
`eCommerce sites using code.”
`http_s://docs.twotap.com/docs/getting—started
`
`making the merchandise database available to multiple publishers;
`
`Two Tap stores, by the processing device, at least one
`group of merchandise data formed in view of the
`storing, by the processing device, at least one group of merchandise
`data formed in View of the merchandise data and content on a site of merchandise data and content on a site of one of the
`
`one of the multiple publishers;
`
`multiple publishers:
`
`
`
`Two Tap
`Exhibit 1008
`Page 003
`
`
`
`Case 2:19-cv-04544-PSG-MAA Document 2-6 Filed 05/24/19 Page 4 of 14 Page ID #:132
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, er a]
`
`Claim 1
`
`Accused Product
`
`“The product catalog is connected to the real-time
`availability infrastructure. Meaning, even though Two
`Tap updates the feeds once a day, a hit to /cart (which
`checks inventory in real—time) will update the product
`catalog as well. This is helpful, as some suppliers
`update their feeds multiple times a day, but most of
`them do it daily. And product information becomes
`stale quite quickly. With Two Tap's product catalogs
`and /cart this means it's impossible for two shoppers to
`see an out of stock product.”
`https://docs.twotap.com/docs/product-catalog
`
`Using Two Tap, the group of merchandise data is
`embedded by the processing device on the content of the
`site of the one of the multiple publishers:
`
`
`
`embedding, by the processing device, the group of merchandise data
`on the content of the site of the one of the multiple publishers;
`
`speed of the store.
`
`“It’s a no brainer. Allow your shoppers to seamlessly
`order the products your editorial content showcases.”
`https://twotap_.com/publishers/ (website discontinued)
`
`“Two Tap Instant allows direct selling of products
`directly in both desktop and mobile sites.”
`https://twotap.com/integrating-twotap/
`
`“Given a list of product URLs, the /cart API endpoint
`hits the product pages in real time and retrieves
`structured product information and availability.
`
`Fetching product information usually takes 5 to 15
`seconds, depending on the number of attributes and the
`
`Two Tap
`Exhibit 1008
`Page 004
`
`
`
`Case 2:19-cv-04544-PSG-MAA Document 2-6 Filed 05/24/19 Page 5 of 14 Page ID #:133
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, el al
`
`Claim 1
`
`Accused Product
`
`Different companies handle the delay in different ways:
`
`
`
`generating, by the processing device, one or more merchandise
`frames in view of the embodiment;
`
`rendering, by the processing device, the one or more merchandise
`frames directly onto the site of the one of the multiple publishers;
`
`generating an e—commerce frame comprising merchandise data from
`the group of merchandise data that is selected by a user of the site of
`the one of the multiple publishers,
`
`Resellers that use their own scrapers or product catalogs
`use /cart as ground truth. Meaning they accept an order
`and attempt to place it in the background. If /cart returns
`out of stock they know the product's availability has
`changed since the last time they or the third party
`catalog provider scraped it. This allows them to mark
`the product as out of stock internally and prevent other
`shoppers from checking out.
`
`Curation resellers that have less than 10,000 products
`hit /cart in the background daily and use the cache_time
`variable below to display the last information seen to
`consumers.
`
`B2B resellers usually prefer the real time stock
`information and don't mind the delay.”
`https://docs.twotap,com/docs/product-availability
`
`
`
`Using Two Tap, the processing device generates one or
`more merchandise frames in view of the embodiment. See
`
`Fig. 2 below.
`
`Using Two Tap, the processing devices renders the
`merchandise frames directly onto the site of the publishers.
`See Fig. 2 below.
`
`Using Two Tap, the system generates an e-commerce
`frame comprising merchandise data from the group of
`merchandise data that is selected by the user of the site of
`the one of the multiple publishers. See Fig. 2 below.
`
`Two Tap
`Exhibit 1008
`Page 005
`
`
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 6 of 14 Page ID #:134
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`Claim 1
`
`l
`
`Accused Product
`
`V
`
`Using Two Tap, the e-commerce frame is a shopping bag
`of the selected merchandise data.
`
`wherein the e—commerce frame is a shopping bag of the selected
`merchandise data;
`
`generating, by the processing device, a universal checkout frame that
`includes:
`
`“The Cart interface is stateless, which means you can't
`add products to an existing cart. For multi-products/
`multi-retailers we recommend you store the list of
`product URLs locally (localstorage, NSUserDefaults),
`and open the interface once the user taps your checkout
`button.” http://docs.twotap.com/docs/cart-interface
`
`“Two Tap Cart helps organizations implement a
`seamless checkout experience keeping the user directly
`in your branded environment. Two Tap Cart works on
`both mobile and desktop and requires no integration or
`infrastructure maintenance by the retailer. It is the piece
`of the puzzle that’s been missing.”
`https://twotap.com/integrating—twotap/#tt-checkout
`
`See also Figs. 2 and 3 below.
`
`Using Two Tap, the processing device generates a
`universal checkout frame that includes the features
`
`discussed in this claim, as further described below.
`
`
`
`“Frontend - Cart page /cart with cache_time=-1
`
`By the time a shopper hits the cart page you have stored
`somewhere a list of product urls. On the cart page you
`call /cart and use cache_time=-l, otherwise Two Tap
`will do a real time product check which usually takes 8-
`15560 (more about this below). As the shopper is
`entering her information you use /cart/estimates to show
`
`Two Tap
`Exhibit 1008
`Page 006
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 7 of 14 Page ID #:135
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`the estimated purchase prices (coupon values, sales tax,
`
`shipping price, final price). Once the shopper taps your "Place Order" you take that
`
`information to your backend, and let her leave your
`experience. You add the purchase to her "My orders"
`tab in your app, and set it to "processing".
`
`Backend — /cart and /purchase
`
`In the backend you run /cart to check real time stock
`availability, then call /purchase to actually inject the
`order to the supplier sites.
`
`You will be using either the HTTP or SMS integration
`flow, where Two Tap hits an endpoint on your end with
`injection updates. That way you avoid polling
`/purchase/status repeatedly
`
`Once Two Tap sends the first http_update_callback you
`can start communicating back to the consumer. You can
`send her an email or a push notification notifying about
`the state of her order.” https://docs.twotap.com/docs/api
`
`“Integrate the Universal Shopping Cart and enable
`consumers to shop without leaving your app or website.
`Two Tap takes the full responsibility of displaying
`accurate information about products to consumers and
`sending fiilfilling orders in a timely, reliable and secure
`fashion.” https://twotap.com/publishers/ (website
`discontinued)
`
`
`
`
`
`Two Tap
`Exhibit 1008
`Page 007
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 8 of 14 Page ID #:136
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, el a]
`
`Claim 1
`
`Accused Product
`
`a single order of multi-merchandise data comprising first
`merchandise data and second merchandise data that is selected from
`
`the one or more merchandise frames,
`
`wherein the first merchandise data corresponds to merchandise
`provided by a first independent merchant from the plurality of
`independent merchants,
`
`Two Tap’s universal checkout frame includes a single
`order of multi—merchandise data comprising a first
`merchandise data and second merchandise data that is
`selected from the one or more merchandise frames. See
`
`Fig. 1 below (shows merchandise available from Alice &
`Olivia, JCreW and Stuart Weitzman); see also Figs. 3-4
`below.
`
`“For multi-products / multi-retailers we recommend you
`store the list of product URLs locally (localstorage,
`NSUserDefaults), and open the interface once the user
`taps your checkout button.”
`http://docs.twotap.com/docs/cart-interface
`
`The first merchandise data selected using Two Tap’s
`system corresponds to merchandise provided by a first
`independent merchant from a plurality of independent
`merchants. See Fig. 1 below (shows merchandise available
`from Alice & Olivia, JCrew and Stuart Weitzman)
`
`“For multi-products / multi—retailers we recommend you
`store the list of product URLs locally (localstorage,
`NSUserDefaults), and open the interface once the user
`taps your checkout button.”
`http_://docs.twotap.com/docs/cart—interface
`
`
`
`Two Tap
`Exhibit 1008
`Page 008
`
`
`
`Case 2:19-cv-O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 9 of 14 Page ID #:137
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, er al
`
`Claim 1
`
`Accused Product
`
`
`
`wherein the second merchandise data corresponds to merchandise
`provided by a second independent merchant from the plurality of
`independent merchants, and
`
`an order summary of the multi-merchandise data comprising a name
`of the first independent merchant and a name of the second
`independent merchant; and
`
`rendering the universal checkout frame directly onto the site of the
`one of the multiple publishers.
`
`The second merchandise data selected using Two Tap’s
`system corresponds to merchandise provided by a second
`independent merchant from the plurality of independent
`merchants. See Fig. 1 below (shows merchandise available
`from Alice & Olivia, JCrew and Stuart Weitzman); see
`also Figs. 3-4 below.
`
`“For multi-products / multi-retailers we recommend you
`store the list of product URLs locally (localstorage,
`NSUserDefaults), and open the interface once the user
`taps your checkout button.”
`http://docs.twotap.com/docs/cart-interface
`
`Using Two Tap, an order summary of the multi-
`merchandise data comprises a name of the first
`independent merchant and a name of the second
`
`independent merchant. See Figs. 3-4
`
`Using Two Tap, the universal checkout frame is rendered
`directly onto the site of the one of the multiple publishers.
`
`“The Cart HTMLS interface is a pre—created checkout
`interface on top of our API‘ It is white-label and
`designed as mobile-first.”
`http_s://docs.twotap.com/docs/cart-interface
`
`“Integrate the Universal Shopping Cart and enable
`consumers to shop without leaving your app or website.
`‘ Two Tap takes the full responsibility of displaying accurate
`
`Two Tap
`Exhibit 1008
`Page 009
`
`
`
`Case 2:19—cv—O4544-PSG-MAA Document 2—6 Filed 05/24/19 Page 10 of 14 Page ID #:138
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`https://twotap.com/publishers/ (website discontinued)
`
`information about products to consumers and sending
`fulfilling orders in a timely, reliable and secure fashion.”
`
`Two Tap
`Exhibit 1008
`Page 010
`
`
`
`Case 2:19-cv—O4544-PSG-MAA Document 2-6 Filed 05/24/19 Page 11 of 14 Page ID #:139
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`FIGURE 1
`
`a re “ups“‘tWOtaPrCOmvwh;—‘-twu:tap
`file
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`x oSfiareBacmsm WdzEx v|
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`
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`
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`
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`
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`
`x @comrt v @5431
`
`Types of Integrations
`
`wnTapispoweredbya robustAP] platformthatcan sendorders;tothousands ofmerchants
`
`Choose the best suited experience for your product, from one line of code integrations to full
`blown shopping carts built directly on top of the Two Tap APl.
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`
`v
`
`Source:
`
`twotap.com
`
`10
`
`Two Tap
`Exhibit 1008
`Page 011
`
`
`
`Case 2:19-cv-04544-PSG-MAA Document 2-6 Filed 05/24/19 Page 12 of 14 Page ID #:140
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`FIGURE 2
`
`-
`
`X
`
`.
`.
`4
`l a httpS' ‘twotap comvrntegratmgtwotap'
`r
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`
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`
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`
`1%? Two Tap Cart
`
`The Simplest Way to Integrate Two Tap
`
`Two Tap Cart helps organizations implement a seamless checkout
`experience keeping the user directly in your branded
`environment. Two Tap Cart works on both mobile and desktop
`and requires no integration or infrastructure maintenance by the
`retailer. It is the piece of the puzzle that's been missing.
`
`Audience = Product Discovery Apps, Gifting and Donations. Advanced Publishers. Internet of Things
`
`Pass-Through Model
`
`Custom Design
`
`The payment processing. order fulfillment
`
`Create your own checkout experience
`
`and confirmation are managed by our
`retailer partners allowing the control.
`customer support and transparencv to
`
`using Two Taps-feature set across
`hundreds of supported retailers. Two
`Tap's API supports real-time attributes
`
`Source:
`
`twotapcom
`
`11
`
`Two Tap
`Exhibit 1008
`Page 012
`
`
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et (11
`
`FIGURE 3
`
`D v 0’
`
`(”Two Tap It
`
`a Relaxed Buw-BackTopforWo... WPittedDress|Camel|Women|...
`
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`
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`
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`
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`
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`
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`x osharEBmwser WebEx V‘
`
`
`
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`
`
`HAP
`
`Old Navy
`
`
`
`
`
`
`
`
`
`
`Relaxed Bow—Back Top for
`Women
`
`$4838
` 1 E $8.00
`
`
`
`—select-
`
`7‘:
`
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`
`will Have a couponlgift card?
`
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`
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`
`
`
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`
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`
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`
`a
`
`0l
`
`
`
`Source:
`
`twotapit. com
`
`12
`
`Two Tap
`Exhibit 1008
`Page 013
`
`
`
`72Lux, Inc. d/b/a Shoppable. com v. Honey Science Corp, et al
`
`FIGURE 4
`
`
`
`
`D v 0’
`
`(”Two Tap It
`
`a Relaxed Bow-Back Top forWo...
`
`1m Fitted Dress | Camel |Women l---
`
`flelp
`
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`
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`x OSharEBmwser WehEx V ‘
`
`
`
`
`
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`
`Mill Have a couponlgift card?
`
`3 Cheapest delivery
`
`k Fastest delivery
`
`9 Usually in 7715 business days.
`
`- select -
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Estimated Cost Summary
`
`View breakdown by store
`Subtotal
`Shipping price
`Es’iimateci Saies tax
`
`Final price
`
`)
`3?? 99
`$12.99
`$9.55
`
`$100.53
`
`START CHECKOUT
`
`
`
`«m VISA G3» a
`
`Source:
`
`twotapit. com
`
`13
`
`Two Tap
`Exhibit 1008
`Page 014
`
`
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