Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Exhibit 14

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EXHIBIT 14 Claim Chart U.S. Patent 10,203,854 Bumble Trading Inc. ("Bumble") has committed and continues to commit acts of infringement under 35 U.S.C. § 271 with its various accused products. The citations below are intended to be exemplary only and in no way foreclose Match from citing or relying on additional documents, information, and/or testimony at a later time. These contentions are preliminary in nature, and further analysis of the Accused Products, internal documentation, source code, and/or testimony from relevant witnesses may be necessary to more fully and accurately describe the infringing features of its accused products. Accordingly, Match reserves the right to supplement, correct, modify, and/or amend these contentions after sufficient discovery from Defendants. Match further reserves the right to supplement, correct, modify, and/or amend these contentions as discovery in this case progresses; in view of the Court's claim construction order; in view of any positions taken by Defendants, including but not limited to positions on claim construction, invalidity, and/or non-infringement; and in connection with the preparation and exchange of expert reports. As used in these contentions, Bumble's "Accused Instrumentalities" shall include all versions of the Bumble application, including all client-application and server-side components, including Bumble for iOS and Bumble for Android. "Bumble's servers" refers to server-side hardware, software, and data components, including both physical components, such as a rack server, and virtual components, such as a virtual machine residing on a hypervisor and functioning as a server. This also refers to such components hosted in facilities operated by Bumble or in facilities operated by third parties from whom Bumble obtains hosting services (e.g., content delivery networks or cloud service providers). Similarly, Bumble's servers refer to third party services that are accessed or utilized by Bumble, including registration, identity management, and push notification services. "The Bumble app" refers to the Bumble application as well as any third-party libraries utilized by the app or operating system services or components utilized by the app. In other contentions, Match referred to an "original version" and a "modified version" of the Bumble's Accused Instrumentalities. As used in those contentions, the "original version" referred to all versions of the Bumble's Accused Instrumentalities—including all client application and server-side components—released prior to the redesign that was released on or around September 2018. The "modified version" of the Bumble's Accused Instrumentalities referred to all versions of the Bumble's Accused Instrumentalities—including all client application and server-side components—released on or after that September 2018 redesign. Unless specific design changes occurring prior to the September 2018 redesign are expressly discussed, the evidence set forth below related to the "original version" of Bumble is representative of all versions of the Bumble prior to the initial release of the "modified version." Unless specific design changes occurring after the September 2018 redesign are expressly discussed, the evidence set forth below related to the "modified version" is representative of all versions of the Bumble's Accused Instrumentalities released since the modified version was first released. Further, unless otherwise noted, Match asserts that, for all places in which Match has presented evidence of a particular functionality from only one of the "original 1 Claim Chart U.S. Patent 10,203,854 The medium 2 Bumble's Accused Instrumentalities comprise the medium of claim 1, further comprising instructions configured to of Claim 1, perform the limitations of claim 1, wherein at least one or more the plurality of users on-line dating profiles is wherein at associated with a social networking platform. least one or more of the plurality of When a Bumble app user downloads and initially accesses the application, the user device is permitted and user on-line encouraged to set up a Bumble account that is associated with the user's Facebook account. Facebook is a social dating profiles networking platform. is associated with a social networking platform. 68 Claim Chart U.S. Patent 10,203,854 also https://www.youtube.com/watch?v=Yj Ggmd7R88#action=share; https://www.youtube.com/watch?v=fQRA1rKCGqA (showing how to create an account with Facebook). Every Bumble profile also includes traits associated with Bumble, which is itself a social networking platform. Bumble includes a plurality of user online-dating profiles with which it populates each of its BumbleDate, BumbleBizz, and BumbleBFF features. 71