IPR2021-00987, No. 1017-15 Exhibit - Exhibit 1017 (P.T.A.B. May. 21, 2021)

U.S. Patent No. 8,489,599
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`EXHIBIT SN01
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`U.S. Patent No. 8,489,599
`Palo Alto Research Center Inc. v. Snap, Inc., Case No. 2:20-cv-10755-AB (C.D. Cal.)
`Plaintiff’s Disclosure of Asserted Claims and Infringement Contentions
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`The information in these infringement contentions is exemplary and only intended to evidence PARC’s theory(ies) of infringement.
`PARC provides these infringement contentions before obtaining discovery from Defendant. PARC expects that Defendant and/or third
`parties will produce additional information regarding the Defendant’s products beyond that which is publicly available.
`
`The Accused Functionalities, identified below, include Snapchat’s targeted advertising functionalities, tools, and/or products available to
`Snapchat’s customers/clients/users. The Accused Functionalities include at least Snapchat’s Ad Manager, Ad Server, Snapchat API, and
`any other technologies, tools, and software, among other things, that may reside at a Snapchat mobile application, desktop
`executables/scripts, and/or Snapchat’s servers and data centers that are involved in creating targeted advertising campaigns. The Accused
`Functionalities are available to customers/clients/users on at least the following Snapchat properties: www.snapchat.com; Snapchat’s
`mobile applications (e.g., the Snapchat app available in the App Store and on Google Play).
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`The Accused Functionalities are made available by Defendant, and result in ads displayed to users via various web browsers, including
`mobile and non-mobile versions of Google Chrome, Google Android, Apple’s Safari, Microsoft’s Internet Explorer, Microsoft’s Edge,
`Opera, Mozilla Firefox, and others. The Accused Functionalities also display ads to users via various mobile applications. The citations
`and discussion below applies to all instances of the Accused Functionalities unless specifically noted. Where functionality below is
`described in terms of non-mobile environments, similar functionality in mobile environments also applies (and vice-versa). Where
`functionality below is described in terms of web-based environment, similar functionality in mobile application-based environments also
`applies (and vice-versa).
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`Note: As used herein, the term “ad(s)” or “advertisement(s)” refers to any notice or announcement promoting or recommending a product,
`service, event, or job vacancy created through the Accused Functionalities. Examples of an ad include, but are not limited to, an image, a
`video, a link, a message, a card, or a post placed throughout the aforementioned Snapchat properties that is sponsored or otherwise
`endorsed.
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`SNAP EXHIBIT 1017
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`U.S. Patent No. 8,489,599
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`[pre] 1. A method for delivering
`context-based content to a first
`user, the method comprising:
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`Claim 1
`To the extent that the preamble is a limitation, it is met.
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`Snapchat uses, sells, offers for sale, or otherwise provides a method for delivering context-based
`content to a first user.
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`For example, Snapchat’s Accused Functionalities deliver targeted ads to users based on their location,
`their device type, and operating system as shown in the following exemplary citations:
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`U.S. Patent No. 8,489,599
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`Source: https://forbusiness.snapchat.com/advertising/targeting
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`U.S. Patent No. 8,489,599
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`Source: Snapchat Ads Manager
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`U.S. Patent No. 8,489,599
`[a] receiving at least one content
`package, wherein
`the content
`package includes at least one
`content piece and a set of rules
`associated with
`the content
`package, wherein the set of rules
`includes a trigger condition and
`an
`expected
`response,
`and
`wherein
`the
`trigger condition
`specifies a context that triggers a
`presentation of the content piece;
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`Snapchat receives at least one content package, wherein the content package includes at least one
`content piece and a set of rules associated with the content package, wherein the set of rules includes
`a trigger condition and an expected response, and wherein the trigger condition specifies a context
`that triggers a presentation of the content piece.
`
`For example, Snapchat’s Accused Functionalities receive ad campaigns containing ads. The ad
`campaigns include at least one ad and a set of rules for ad targets, such as user location, device type,
`operating system, and/or the time of day, each of which may trigger presenting an ad to one or more
`users. The rules also include an expected response and a trigger condition as shown in the exemplary
`citations below. The expected response may include advertising and/or campaign objective(s) (e.g.,
`whether a user is expected to see, click, view, or otherwise interactive with an ad) being satisfied. The
`trigger condition may include a user operating a particular device, a user’s device running a specified
`operating system, a user being in a certain location for an given event/at a particular time of day,
`among other conditions, which, when met, lead to an ad being displayed to the user. The Snapchat
`Accused Instrumentalities allows advertisers to track and optimize how their ads are seen, clicked,
`viewed, or otherwise interacted with. This is shown in the exemplary citations below:
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`Source: https://forbusiness.snapchat.com/advertising/targeting
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`U.S. Patent No. 8,489,599
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`Source: https://snap.com/en-US/privacy/privacy-policy
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`Source: Snapchat Ads Manager
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`Source: https://businesshelp.snapchat.com/s/article/objectives?language=en_US
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`Source: https://forbusiness.snapchat.com/advertising/objectives
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`Source: https://forbusiness.snapchat.com/blog/how-to-advertise-on-snapchat-with-instant-create
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`Source: https://businesshelp.snapchat.com/s/article/create-first-campaign?language=en_US
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`Source: https://forbusiness.snapchat.com/blog/the-snap-pixel-how-it-works-and-how-to-
`installit#:~:text=The%20Snap%20Pixel%20is%20a%20piece%20of%20JavaScript%20code%20place
`d,Snapchatters%20take%20on%20your%20website
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`For additional metrics, see also: https://developers.snapchat.com/api/docs/#additional-
`metrics)
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`Source: https://marketingland.com/snapchat-launches-multiple-e-commerce-ad-options-in-time-for-
`holiday-shopping-249063
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`See also claim element [1pre]; https://forbusiness.snapchat.com/advertising (discussing Snapchat
`advertising); https://forbusiness.snapchat.com/advertising/objectives (discussing Snapchat advertising
`objectives); https://forbusiness.snapchat.com/advertising/targeting (discussing Snapchat advertising
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`targeting); https://forbusiness.snapchat.com/blog/how-to-create-a-retargeting-campaign-on-snapchat
`(describing Snapchat advertising re-targeting);
`https://forbusiness.snapchat.com/advertising/measurement (discussing Snapchat advertising
`measurement); https://www.snap.com/en-US/ad-policies (discussing Snapchat ad policies);
`https://forbusiness.snapchat.com/resources/advertising-guides (providing Snapchat advertising
`guides); https://forbusiness.snapchat.com/blog/creative-best-practices-snapchat-for-business
`(describing Snapcht ads best practices); https://forbusiness.snapchat.com/resources/ad-specs
`(describing Snapchat ad specifications); https://forbusiness.snapchat.com/resources/creative-tools
`(describing Snapchat ad creative tools); https://forbusiness.snapchat.com/advertising/industry/app
`(describing app ads on Snapchat); https://forbusiness.snapchat.com/advertising/industry/ecommerce
`(describing ecommerce ads on Snapchat); https://www.youtube.com/playlist?list=PLZry9RsQ-
`S0Iw_38whqq-pMdeWwKmhn7U (providing Snapchat ad tutorials);
`https://forbusiness.snapchat.com/blog/how-to-advertise-on-snapchat-with-instant-create (describing
`Instant Create); https://forbusiness.snapchat.com/blog/how-to-promote-on-snapchat-with-advanced-
`create (describing Advanced Create); https://forbusiness.snapchat.com/advertising/pricing (describing
`Snapchat ad pricing); https://forbusiness.snapchat.com/blog/the-snap-pixel-how-it-works-and-how-to-
`install-it (describing Snap Pixel); https://developers.snapchat.com/ads/ (Snapchat Marketing APIs)
`https://developers.snapchat.com/api/docs/ (describing Snapchat API documentation);
`https://developers.snapchat.com/api/docs/#ads (Snapchat API regarding Ads);
`https://developers.snapchat.com/api/docs/#targeting (Snapchat API regarding Targeting);
`https://developers.snapchat.com/api/docs/#snap-audience-match (Snapchat API regarding Audience);
`https://developers.snapchat.com/api/docs/#sam-lookalikes (Snapchat API regarding Lookalikes);
`https://developers.snapchat.com/api/docs/#example-targeting-specs (Snapchat API regarding Example
`Targeting Specs); https://developers.snapchat.com/api/docs/#audience-insights (Snapchat API
`regarding Audience Insights); https://developers.snapchat.com/api/docs/#delivery-status (Snapchat
`API regarding Delivery Status); https://developers.snapchat.com/api/docs/#audience-filters (Snapchat
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`[b] receiving a set of contextual
`information with respect to the
`first user;
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`API regarding Audience Filters); https://developers.snapchat.com/api/docs/#measurement (Snapchat
`API regarding Measurement); https://developers.snapchat.com/api/docs/#conversion-api (Snapchat
`API regarding Conversion API)
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`Snapchat receives a set of contextual information with respect to the first user.
`
`For example, Snapchat’s Accused Functionalities receive information about users, including
`information about user location (whether through GPS, IP address, WiFi, cell towers, or other
`information), which informs Snapchat about user location and user device type, and the operating
`system running on the user’s device as shown in the following exemplary citations:
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`
`Source: https://snap.com/en-US/privacy/privacy-policy
`
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`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
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`U.S. Patent No. 8,489,599
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`
`
`Source: https://developers.snapchat.com/api/docs/
`See also claim elements [1pre] and [1a]; https://forbusiness.snapchat.com/advertising (discussing
`Snapchat advertising); https://forbusiness.snapchat.com/advertising/objectives (discussing Snapchat
`advertising objectives); https://forbusiness.snapchat.com/advertising/targeting (discussing Snapchat
`advertising targeting); https://forbusiness.snapchat.com/blog/how-to-create-a-retargeting-campaign-
`on-snapchat
`(describing
`Snapchat
`advertising
`re-targeting);
`https://forbusiness.snapchat.com/advertising/measurement
`(discussing
`Snapchat
`advertising
`measurement); https://www.snap.com/en-US/ad-policies
`(discussing Snapchat
`ad policies);
`https://forbusiness.snapchat.com/resources/advertising-guides
`(providing Snapchat
`advertising
`guides);
`https://forbusiness.snapchat.com/blog/creative-best-practices-snapchat-for-business
`(describing Snapcht ads best practices); https://forbusiness.snapchat.com/resources/ad-specs
`(describing Snapchat ad specifications); https://forbusiness.snapchat.com/resources/creative-tools
`(describing Snapchat ad creative tools); https://forbusiness.snapchat.com/advertising/industry/app
`(describing app ads on Snapchat); https://forbusiness.snapchat.com/advertising/industry/ecommerce
`(describing ecommerce ads on Snapchat); https://www.youtube.com/playlist?list=PLZry9RsQ-
`
`- 66 -
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`
`
`
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`Page 66 of 99
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`

`U.S. Patent No. 8,489,599
`
`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`S0Iw_38whqq-pMdeWwKmhn7U
`(providing
`Snapchat
`ad
`tutorials);
`https://forbusiness.snapchat.com/blog/how-to-advertise-on-snapchat-with-instant-create
`(describing
`Instant Create); https://forbusiness.snapchat.com/blog/how-to-promote-on-snapchat-with-advanced-
`create (describing Advanced Create); https://forbusiness.snapchat.com/advertising/pricing (describing
`Snapchat ad pricing); https://forbusiness.snapchat.com/blog/the-snap-pixel-how-it-works-and-how-to-
`install-it (describing Snap Pixel); https://developers.snapchat.com/ads/ (Snapchat Marketing APIs)
`https://developers.snapchat.com/api/docs/
`(describing
`Snapchat
`API
`documentation);
`https://developers.snapchat.com/api/docs/#ads
`(Snapchat
`API
`regarding
`Ads);
`https://developers.snapchat.com/api/docs/#targeting
`(Snapchat API
`regarding
`Targeting);
`https://developers.snapchat.com/api/docs/#snap-audience-match (Snapchat API regarding Audience);
`https://developers.snapchat.com/api/docs/#sam-lookalikes (Snapchat API regarding Lookalikes);
`https://developers.snapchat.com/api/docs/#example-targeting-specs (Snapchat API regarding Example
`Targeting Specs); https://developers.snapchat.com/api/docs/#audience-insights
`(Snapchat API
`regarding Audience Insights); https://developers.snapchat.com/api/docs/#delivery-status (Snapchat
`API regarding Delivery Status); https://developers.snapchat.com/api/docs/#audience-filters (Snapchat
`API regarding Audience Filters); https://developers.snapchat.com/api/docs/#measurement (Snapchat
`API regarding Measurement); https://developers.snapchat.com/api/docs/#conversion-api (Snapchat
`API regarding Conversion API)
`Snapchat processes the contextual information to determine a current context for the first user.
`
`For example, based at least on the exemplary evidence cited in [1a] and [1b], and on further
`information and belief, Snapchat’s Accused Functionalities process information about the user,
`including signals information and other information to determine a user’s location and time zone, and
`information about a user’s device to determine whether the device is mobile (including tablet) or
`desktop (or laptop), the device’s operating system, web browser, application version, and the device’s
`display and graphics capabilities.
`Snapchat determines whether the current context satisfies the trigger condition.
`
`For example, based at least on the exemplary evidence cited in [1a] - [1c], before presenting an ad to
`- 67 -
`
`U.S. Patent No. 8,489,599
`
`the contextual
`[c] processing
`information
`to determine
`a
`current context for the first user;
`
`[d] determining whether
`current context
`satisfies
`trigger condition;
`
`the
`the
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`
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`U.S. Patent No. 8,489,599
`
`U.S. Patent No. 8,489,599
`
`[e] in response to the trigger
`condition
`being
`satisfied,
`presenting the content piece to
`the first user;
`
`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`the user, Snapchat’s Accused Functionalities determine whether the user is in an advertiser’s desired
`location, within an advertiser’s desired time window, or using an advertiser’s preferred device type.
`Snapchat, in response to the trigger condition being satisfied, presents the content piece to the first
`user.
`
`For example, based at least on the exemplary evidence cited in [1a] - [1d], once Snapchat’s Accused
`Functionalities determine that the user is in an advertiser’s desired location, within an advertiser’s
`desired time window, or using an advertiser’s preferred device type, Snapchat’s Accused
`Functionalities present an ad to the user.
`
`
`
`
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`Source: https://marketingland.com/snapchat-launches-multiple-e-commerce-ad-options-in-time-for-
`holiday-shopping-249063
`
`See also claim elements [1pre], [1a], [1b], [1c], [1d]; https://forbusiness.snapchat.com/advertising
`(discussing Snapchat advertising); https://forbusiness.snapchat.com/advertising/objectives (discussing
`Snapchat advertising objectives); https://forbusiness.snapchat.com/advertising/targeting (discussing
`- 69 -
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`U.S. Patent No. 8,489,599
`
`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`Snapchat advertising targeting); https://forbusiness.snapchat.com/blog/how-to-create-a-retargeting-
`campaign-on-snapchat
`(describing
`Snapchat
`advertising
`re-targeting);
`https://forbusiness.snapchat.com/advertising/measurement
`(discussing
`Snapchat
`advertising
`measurement); https://www.snap.com/en-US/ad-policies
`(discussing Snapchat
`ad policies);
`https://forbusiness.snapchat.com/resources/advertising-guides
`(providing Snapchat
`advertising
`guides);
`https://forbusiness.snapchat.com/blog/creative-best-practices-snapchat-for-business
`(describing Snapcht ads best practices); https://forbusiness.snapchat.com/resources/ad-specs
`(describing Snapchat ad specifications); https://forbusiness.snapchat.com/resources/creative-tools
`(describing Snapchat ad creative tools); https://forbusiness.snapchat.com/advertising/industry/app
`(describing app ads on Snapchat); https://forbusiness.snapchat.com/advertising/industry/ecommerce
`(describing ecommerce ads on Snapchat); https://www.youtube.com/playlist?list=PLZry9RsQ-
`S0Iw_38whqq-pMdeWwKmhn7U
`(providing
`Snapchat
`ad
`tutorials);
`https://forbusiness.snapchat.com/blog/how-to-advertise-on-snapchat-with-instant-create
`(describing
`Instant Create); https://forbusiness.snapchat.com/blog/how-to-promote-on-snapchat-with-advanced-
`create (describing Advanced Create); https://forbusiness.snapchat.com/advertising/pricing (describing
`Snapchat ad pricing); https://forbusiness.snapchat.com/blog/the-snap-pixel-how-it-works-and-how-to-
`install-it (describing Snap Pixel); https://developers.snapchat.com/ads/ (Snapchat Marketing APIs)
`https://developers.snapchat.com/api/docs/
`(describing
`Snapchat
`API
`documentation);
`https://developers.snapchat.com/api/docs/#ads
`(Snapchat
`API
`regarding
`Ads);
`https://developers.snapchat.com/api/docs/#targeting
`(Snapchat API
`regarding
`Targeting);
`https://developers.snapchat.com/api/docs/#snap-audience-match (Snapchat API regarding Audience);
`https://developers.snapchat.com/api/docs/#sam-lookalikes (Snapchat API regarding Lookalikes);
`https://developers.snapchat.com/api/docs/#example-targeting-specs (Snapchat API regarding Example
`Targeting Specs); https://developers.snapchat.com/api/docs/#audience-insights
`(Snapchat API
`regarding Audience Insights); https://developers.snapchat.com/api/docs/#delivery-status (Snapchat
`API regarding Delivery Status); https://developers.snapchat.com/api/docs/#audience-filters (Snapchat
`API regarding Audience Filters); https://developers.snapchat.com/api/docs/#measurement (Snapchat
`API regarding Measurement); https://developers.snapchat.com/api/docs/#conversion-api (Snapchat
`API regarding Conversion API)
`
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`U.S. Patent No. 8,489,599
`[f] receiving a response from the
`first user corresponding to the
`presented content piece;
`
`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`Snapchat receives a response from the first user corresponding to the presented content piece, and
`determines whether the received response matches the expected response.
`
`For example, Snapchat’s Accused Functionalities track whether the user saw, clicked, viewed, or
`otherwise interacted with the presented ad— as shown in the following exemplary citations:
`
`U.S. Patent No. 8,489,599
`
`
`
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
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`U.S. Patent No. 8,489,599
`
`Source: Snapchat Ads Manager
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`
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`
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`Source: https://businesshelp.snapchat.com/s/article/create-first-campaign?language=en_US
`
`
`
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`
`Source: https://businesshelp.snapchat.com/s/article/ad-performance-metrics?language=en_US
`
`
`
`
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`U.S. Patent No. 8,489,599
`
`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`Source: https://tinuiti.com/blog/paid-social/snapchat-ads/
`
`
`
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`U.S. Patent No. 8,489,599
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`Exemplary Evidence of Plaintiff’s Theory(ies) for Targeted Advertising (599)
`
`U.S. Patent No. 8,489,599
`
`
`
`
`
`- 81 -

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