Match Group, LLC v. Bumble Trading Inc.

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

Exhibit B

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Exhibit B From: Soni, Naina To: John Summers; Brad Caldwell; match@caldwellcc.com; palmer@namanhowell.com; melissa@gillamsmithlaw.com Cc: Deron Dacus; z/Bumble-Match.com; Drayton, Joe; Whelan, Rose; Caplan, Matt; Rhodes, Michael; Scordino, Ellen; Pietrantonio, Frank; Shrieves, Beth Subject: [Match v. Bumble] Proposed Terms for Claim Construction Date: Thursday, April 04, 2019 1:34:05 PM John, To streamline the issues for claim construction, Bumble will not be proposing a construction or providing evidence today for some of the terms identified last week, specifically: • To enable initial communication • Item of information • Online dating profile(s) • First card of a stack of cards • Stor[ing] the positive preference indication associated with the first item of information in response to detecting the gesture • Interface • Processor • Graphical notification • Presenting user interface controls such that all user interface controls configured to cause another item of information of the plurality of items of information to be displayed are associated with performing an action on the first item of information (and the variation identified) • Caus[ing] the graphical user interface to display to the first user the graphical representation of the first potential match (and variations identified) • Allowing (we will, however, be proposing a construction of "without allowing") Since Match did not identify these claim terms as requiring construction, we believe these claim terms are no longer at issue for the purposes of claim construction and should be given their plain and ordinary meaning, but please let us know if Match disagrees. In addition, we wanted to clarify how we are handling the "associated" and "associated with a social networking platform" terms. We will be providing a position on the term "associated" alone. We will also be providing a position on "social networking platform" alone. We will not be providing specific constructions for the other variations of the "associated" terms identified in our disclosure last week. Regards, Naina Soni Cooley LLP 1299 Pennsylvania Avenue, NW • Suite 700 Washington, DC 20004-2400 Office: +1 202 728 7153 • Fax: +1 202 842 7899 • Cell: +1 240 755 4505 Email: nsoni@cooley.com • www.cooley.com This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. If you are the intended recipient, please be advised that the content of this message is subject to access, review and disclosure by the sender's Email System Administrator.