IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`FALL LINE PATENTS, LLC,
`
`Plaintiff,
`
`v.
`
`7-ELEVEN, INC.,
`
`Defendant.
`
`CIVIL ACTION NO. 5:24-cv-167-
`RWS
`
`(Consolidated Lead Case)
`
`JURY TRIAL DEMANDED
`
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS
`
`Fall Line provides the following disclosures under Patent Local Rules 3-1
`
`and 3-2. These disclosures and contentions are made with respect to United States
`
`Patent No. 9,454,748 (“Asserted Patent”).
`
`I.
`
`PATENT RULE 3-1
`
`(a) Identification of Infringed Claims
`
`7-Eleven: claim 7 of the Asserted Patent.
`
`Academy: claim 7 of the Asserted Patent.
`
`Advance Auto Parts: claim 7 of the Asserted Patent.
`
`ALDI: claim 7 of the Asserted Patent.
`
`AutoZone: claim 7 of the Asserted Patent.
`
`Best Buy: claim 7 of the Asserted Patent.
`
`1
`
`Instacart, Ex. 1054
`
`
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`FALL LINE PATENTS, LLC,
`
`Plaintiff,
`
`v.
`
`7-ELEVEN, INC.,
`
`Defendant.
`
`CIVIL ACTION NO. 5:24-cv-167-
`RWS
`
`(Consolidated Lead Case)
`
`JURY TRIAL DEMANDED
`
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS
`
`Fall Line provides the following disclosures under Patent Local Rules 3-1
`
`and 3-2. These disclosures and contentions are made with respect to United States
`
`Patent No. 9,454,748 (“Asserted Patent”).
`
`I.
`
`PATENT RULE 3-1
`
`(a) Identification of Infringed Claims
`
`7-Eleven: claim 7 of the Asserted Patent.
`
`Academy: claim 7 of the Asserted Patent.
`
`Advance Auto Parts: claim 7 of the Asserted Patent.
`
`ALDI: claim 7 of the Asserted Patent.
`
`AutoZone: claim 7 of the Asserted Patent.
`
`Best Buy: claim 7 of the Asserted Patent.
`
`1
`
`Instacart, Ex. 1054
`
`
`
`Brookshire: claim 7 of the Asserted Patent.
`
`Cracker Barrel: claim 7 of the Asserted Patent.
`
`DoorDash: claim 7 of the Asserted Patent.
`
`Enterprise: claim 7 of the Asserted Patent.
`
`Lowe’s: claim 7 of the Asserted Patent.
`
`Olive Garden: claim 7 of the Asserted Patent.
`
`LongHorn Steakhouse: claim 7 of the Asserted Patent.
`
`Sprouts: claim 7 of the Asserted Patent.
`
`(b) Identification of Accused Instrumentalities/Methods
`
`For each of the above claims, the Accused Instrumentalities are as follows:
`
`For 7-Eleven, the 7-Eleven and 7NOW mobile Android apps, the 7-Eleven
`
`and 7NOW mobile iOS apps, the use of the mobile apps, the mobile apps running
`
`on a mobile device, and the associated back-end servers.
`
`For Academy, the Academy Sports + Outdoors mobile Android app, the
`
`Academy Sports + Outdoors mobile iOS app, the use of the mobile apps, the
`
`mobile apps running on a mobile device, and the associated back-end servers.
`
`For Advance Auto Parts, the Advance Auto Parts mobile Android app, the
`
`Advance Auto Parts mobile iOS app, the use of the mobile apps, the mobile apps
`
`running on a mobile device, and the associated back-end servers.
`
`
`
`2
`
`
`
`For ALDI, the ALDI mobile Android app, the ALDI mobile iOS app, the
`
`use of the mobile apps, the mobile apps running on a mobile device, and the
`
`associated back-end servers.
`
`For AutoZone, the AutoZone mobile Android app, the AutoZone mobile
`
`iOS app, the use of the mobile apps, the mobile apps running on a mobile device,
`
`and the associated back-end servers.
`
`For Best Buy, the Best Buy mobile Android app, the Best Buy mobile iOS
`
`app, the use of the mobile apps, the mobile apps running on a mobile device, and
`
`the associated back-end servers.
`
`For Brookshire, the Brookshire’s, Super 1 Foods, and FRESH by
`
`Brookshire’s mobile Android apps; the Brookshire’s, Super 1 Foods, and FRESH
`
`by Brookshire’s mobile iOS apps; the use of the mobile apps; the mobile apps
`
`running on a mobile device; and the associated back-end servers.
`
`For Cracker Barrel, the Cracker Barrel mobile Android app, the Cracker
`
`Barrel mobile iOS app, the use of the mobile apps, the mobile apps running on a
`
`mobile device, and the associated back-end servers.
`
`For DoorDash, the DoorDash mobile Android app, the DoorDash mobile
`
`iOS app, the use of the mobile apps, the mobile apps running on a mobile device,
`
`and the associated back-end servers.
`
`
`
`3
`
`
`
`For Enterprise, the Enterprise, National, and Alamo mobile Android apps;
`
`the Enterprise, National, and Alamo mobile iOS apps; the use of the mobile apps;
`
`the mobile apps running on a mobile device; and the associated back-end servers.
`
`For Lowe’s, the Lowe’s mobile Android app, the Lowe’s mobile iOS app,
`
`the use of the mobile apps, the mobile apps running on a mobile device, and the
`
`associated back-end servers.
`
`For Olive Garden, the Olive Garden mobile Android app, the Olive Garden
`
`mobile iOS app, the use of the mobile apps, the mobile apps running on a mobile
`
`device, and the associated back-end servers.
`
`For LongHorn Steakhouse, the LongHorn Steakhouse mobile Android app,
`
`the LongHorn Steakhouse mobile iOS app, the use of the mobile apps, the mobile
`
`apps running on a mobile device, and the associated back-end servers.
`
`For Sprouts, the Sprouts Farmers Market mobile Android app, the Sprouts
`
`Farmers Market mobile iOS app, the use of the mobile apps, the mobile apps
`
`running on a mobile device, and the associated back-end servers.
`
`(c) Claim Charts
`
`The claim charts required by Patent Local Rule 3-1(c) are attached as
`
`Exhibits 1–20.
`
`
`
`4
`
`
`
`(d) Doctrine of Equivalents
`
`In the attached claim charts, Fall Line asserts that each claim limitation is
`
`literally infringed. Fall Line reserves the right to assert additional theories under
`
`the doctrine of equivalents in response to claim construction positions that
`
`defendants may take.
`
`(e) Priority Claims to Earlier Patent Applications
`
`The asserted claim of the Asserted Patent is entitled to a priority date of
`
`August 19, 2002.
`
`(f) Fall Line’s Instrumentalities
`
`Fall Line does not intend to rely on the assertion that any of its own
`
`applications practice the Asserted Patent.
`
`II.
`
`PATENT RULE 3-2
`
`(a)
`
`Fall Line is producing documents responsive to Patent Rule 3-2(a)
`
`numbered FALL_0002668–2738. These documents have been designated as
`
`confidential under the protective order and are required to be treated as attorneys’
`
`eyes only.
`
`(b) Fall Line is producing documents responsive to Patent Rule 3-2(b)
`
`numbered FALL_0002602–2738. These documents have been designated as
`
`confidential under the protective order and are required to be treated as attorneys’
`
`eyes only.
`
`
`
`5
`
`
`
`(c)
`
`Fall Line is producing documents responsive to Patent Rule 3-2(c)
`
`numbered FALL_000001–2601.
`
`
`Dated: March 13, 2025
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Matthew J. Antonelli
`Matthew J. Antonelli (lead attorney)
`Texas Bar No. 24068432
`matt@ahtlawfirm.com
`Zachariah S. Harrington
`Texas Bar No. 24057886
`zac@ahtlawfirm.com
`Larry D. Thompson, Jr.
`Texas Bar No. 24051428
`larry@ahtlawfirm.com
`Rehan M. Safiullah
`Texas Bar No. 24066017
`rehan@ahtlawfirm.com
`Hannah D. Price
`Texas Bar No. 24116921
`hannah@ahtlawfirm.com
`ANTONELLI, HARRINGTON
`& THOMPSON LLP
`4306 Yoakum Blvd., Ste. 450
`Houston, TX 77006
`(713) 581-3000
`
`Attorneys for Fall Line Patents, LLC
`
`6
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 13th day of March 2025, I electronically filed the
`
`foregoing with the Clerk of the Court using the CM/ECF system, which will send
`
`notification of such filing to all counsel of record.
`
`
`
`
`
`
`
`
`
`
`
`/s/ Matthew J. Antonelli
`Matthew J. Antonelli
`
`
`
`
`
`
`7
`
`
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