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And quick communication. I will contact you again if there is anything else. Yesol Baek Co-Founder, Star Pack Products, Australia Professional, great communicators, great results. Would not hesitate to use firm’s services for trademark registration again. Thanks! MATTHEW HODGE Founder Star Pack, Australia Great work as always for Trademark Search from Lex Protector. DAVIDSON HEPBURN MD Gold Tiger Holdings, FL, USA Lex Protector helped us file several trademarks and copyright. They were easy to reach, always available and were quick to understand the legal requirements of our business. Recommended! ERIC LOGAN CEO VitaminBestBuy, NY, USA Hired them for Patent filing and Trade Mark. They were great to work with. Will be using them again. Cornelius John Vanderkolk CEO, Scilent Action, USA I was very happy with their work, they successfully had links removed under the DMCA Takedown processes on several websites, it was very cost effective and stress free way to protect our brand. Riel Roussopoulos CMO, IXLD Media Inc, Canada Lex Protector made this very easy for me, they took care of everything in a very professional way. Top notch service! Javier Benia O’Neill Director, QB Media, Uruguay Not the first time we have worked with LexProtector and we continue to be very satisfied with the quality of work and support. Knowledge on international law is exceptional, this vendor keeps on top of us to ensure they are able to deliver within set deadlines and expectations, will continue to work with. Janie Lee Brown Operations Manager, Morgan McKinley, UAE

& O’Connor, 46 F.4th 148, 155 (3d Cir. 2022); In re Plavic Mktg., Sales Pracs. & Prods. Liab. Litig. (No. II), 974 F.3d 228, 231 (3d Cir. 2020); Davis v. Wells Fargo, 824 F.3d 333, 349 (3d Cir. 2016). But when, as here, the defendant contends that the asserted claim lacks a plausible factual basis in the form of an inventive concept, the patent owner is required to respond with more than “conclusory allegations of inventiveness.” Zillow, 50 F.4th at 1379; Simio LLC v. FlexSim Software Prods., Inc., 983 F.3d 1353, 1365 (Fed. Cir. 2020). Rather, what is required are “plausible and specific allegations that aspects of the claims are inventive.” Cellspin Soft, Inc. v. Fitbit, Inc., 927 F.3d 1306, 1317 (Fed. Cir. 2019). The point was well summarized by Judge Robart, who noted that although the movant bears the burden of proof under Rule 12(b)(6), “the court must determine whether [the patent owner’s] factual allegations give rise to a plausible inference of an inventive concept, and thus whether the Patent claims something more than a well-understood, routine, and conventional method, system, or components. . . . Thus, the fact that [the movant] presents no affirmative evidence does not save [the patent owner’s] complaint from dismissal.” Uniloc USA, Inc. v. HTC Am., Inc., No. 17-1558, 2018 WL 3008870, at *11 (W.D. Wash. June 15, 2018), vacated on other grounds, 776 F. App’x 704 (Fed. Cir. 2019); see also T-Jat Sys. 2006, Ltd. v. Expedia, Inc. (DE), No. 16-581, 2018 WL 1525496, at *6 (D. Del. Mar. 28, 2018) (“Plaintiff makes no ‘concrete allegations’ to support its allegation that the ‘particular characteristics’ are not ‘well-understood, routine, and conventional,” and thus “there is no dispute of fact” as to that issue.). 25 In this case, as in the cited cases, there has been no concrete factual allegation as to the inventive concept, either in the original complaint or in GeoComply’s proposed amended complaint, as discussed below. b. The specification In support of its contention that claim 1 recites an inventive concept, GeoComply points to several statements in the ’805 patent specification that purport to explain the benefits of the claimed invention. Those statements include the following: • The invention “may have unmatched accuracy as it determines a player location within meters.” • The invention “may use multiple positioning technologies to increase reliability of results across diverse topologies.” • The invention “may use a sophisticated rules based algorithm to deliver intelligent weighting to results.” • The invention “may be easily integrated into gaming applications and services through use of a very simple application program interface (API).” • The invention “may be highly configurable, and may have location & security parameters which can be

For identifying similar inventions within a short frame of time. The purpose of the search is to reveal any obvious obstacles that might prevent the client from filing his invention. Read more 13FILE HISTORY REVIEW A patent file history is a record of all communication and documentation involved in the patent prosecution process. For a complete patent analysis, a file history review is conducted. This is usually done to assess the strength of a claim. Read more 14TRADEMARK SEARCHES Trademark searches are performed to determine whether a trademark is used in commerce. An appropriate searching strategy will consider the nature of the mark, the nature of the goods/services the mark covers and the timeline for bringing the mark to commerce. Read more 15OTHER SERVICES PTA Calculations, Client & Associate Communications, Multi-Jurisdiction Family Updating, Retrieval of reference copies etc - feel free to contact us for additional paralegal support services. Read more

SMS Archiving Technology Patent Awarded to CellTrustSMS archiving technology patented by CellTrust is fundamental for successful e-compliance enforcement for the highly regulated financial services, government and healthcare industriesScottsdale, Arizona – February 7, 2018 – CellTrust Corporation, a global leader in enterprise mobile communications compliance enforcement, traceability and security, today announced it has been awarded its “System and method for tracking SMS messages” patent US 9,775,012 by the United States Patent and Trademark Office (USPTO) for the SMS archiving technology in its SL2™ product.CellTrust’s flagship SL2 utilizes the technology and intellectual property protected by the patent to ensure text messages are archived – a critical component of e-discovery and compliance enforcement for highly-regulated industries. The second generation of CellTrust SecureLine, SL2, launched in April 2017, has been successfully implemented with tens of thousands of licenses around the world. US Patent 9,775,012 is the latest addition to CellTrust’s existing US and international portfolio of 35 patents and 63 licensed patent rights related to tracking SMS and mobile communication.“Protecting our intellectual property has long been an important part of our mission at CellTrust,” said Sean Moshir, Chairman and CEO. “As the leader for SMS traceability and compliance, we will continue to innovate and protect our Intellectual property.”CellTrust has been working on enterprise mobile communications compliance enforcement, traceability and security for more than a decade and has invested significant resources to understand and engineer for the complex compliance issues facing the financial services, government and healthcare industries. For example: FINRA Regulatory Notice/Guidance from April

Court Description: MEMORANDUM OPINION AND ORDER, Xpoint's motion to dismiss for ineligibility under 35 U.S.C. §101 is GRANTED. Xpoint's motion to dismiss for non-infringement is GRANTED as to the allegation of infringement of claim 10 of the '805 pa tent under the theory set forth in Count II of the complaint. Xpoint's motion to dismiss for non-infringement is DENIED with respect to the remainder of GeoComply's allegations of infringement. Leave to amend will not be granted with respec t to either patent eligibility or the infringement of claim 10 under the theory set forth in Count II of the complaint. A corresponding judgment will be filed contemporaneously with this order. In light of the decision granting Xpoint's motion to dismiss under 35 U.S.C. §101, GeoComply's motion for a preliminary injunction, Dkt. No. 62, is DENIED as moot. (See Order for further details). Signed by Judge William C. Bryson on 2/10/2023. (twk) Download PDF GeoComply Solutions Inc. v. XPoint Services LLC Doc. 84 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE GEOCOMPLY SOLUTIONS INC., Plaintiff, v. XPOINT SERVICES LLC, Defendant. § § § § § § § § § § § Civil Action No. 22-1273-WCB MEMORANDUM OPINION AND ORDER In this patent infringement action, defendant Xpoint Services LLC (“Xpoint”) has moved to dismiss the complaint filed by plaintiff GeoComply Solutions Inc. (“GeoComply”) under Federal Rule of Civil Procedure 12(b)(6) on two grounds. Dkt. No. 16. First, Xpoint contends that the claims asserted against it are directed to subject matter rendered patent-ineligible under 35 U.S.C. §101. Second, Xpoint contends that GeoComply’s complaint does not sufficiently allege infringement of any of the asserted claims. For the reasons set forth below, the motion to dismiss is GRANTED with respect to the portion of Xpoint’s motion based on 35 U.S.C. § 101 and GRANTED IN PART with respect to the portion of Xpoint’s motion based on infringement. I. Background GeoComply has developed software that is used by online gaming providers to determine the location of persons who attempt to use the providers’ software applications. Many online gaming services, including sports betting services, are legal in some jurisdictions and illegal in others. Some users who are located in a jurisdiction in which activities such as sports betting are prohibited may attempt to “spoof” or otherwise mask their locations to make it appear that they 1 Dockets.Justia.com are in a jurisdiction in which such activities are legal. GeoComply’s products purport to enable online gaming providers to determine a user’s actual location and grant access only to those users who are located in a jurisdiction in which the provider’s services are legal. GeoComply owns U.S. Patent No. 9,413,805 (“the ’805 patent”). The patent is generally