H. Artoush Ohanian 604 West 13th Street Austin, Texas 78701 512-298-2005 artoush@ohanianiprom FOR SETTLEMENT PURPOSES ONLY PURSUANT TO FRE 408 Jan 7th, 2020 Mr James Buatti Sr Legal Counsel Wikimedia Foundation (Wikipedia) 1 Montgomery Street Suite 1600 San Francisco, CA 94105 Re: Infringement of WordLogic Patents by Wikipedia Inc. Dear Mr Buatti: We represent WordLogic Corporation and 602531 British Columbia Ltd. (collectively referred to herein as ?WordLogic?) in the licensing and enforcement of WordLogic?s United States Patent Nos. 7,293,231 (?the ?231 patent?), 7,681,124 (?the 124 patent?), 7,716,579 (?the ?5 79 patent?) and 8,552,984 (?the ?984 patent?). I am writing to familiarize you with the WordLogic patents, advise you of infringement and hopefully reach an amicable resolution of this issue. Generally, the WordLogic patents are directed to methods and systems for processing text and data entry on personal computers, handheld devices and other touch screen devices. More speci?cally, the claims of the patents cover various predictive text touch keyboards for handheld devices, as well as the predictive text features and functionality of many websites, media players, navigational systems and game consoles. Please ?nd enclosed copies of the ?231, ?124, ?579 and ?984 patents. As shown in the claim chart below, the predictive text search box featured on the WIKIPEDIA website infringes at least claim 19 of the 124 patent, and likely other claims in the WordLogic patents. We hope that WIKIPEDIA will work with us to reach a reasonable and amicable resolution of this matter. BACKGROUND WordLogic is a global leader and innovator in the ?eld of predictive text input technology for computerized devices. WordLogic has been developing its proprietary technology since the late 1990?s. WordLogic?s technology has been recognized as a leader in the ?eld, including the 2014 North American Enabling Technology Leadership Award for Predictive Keyboard Applications. WordLogic?s patented technology was developed for use on a wide variety of devices and applications, including smart phones, tablets, websites, media players, navigational systems and game consoles, and licensed for use on many popular products on the market today. In addition to licensing, WordLogic has incorporated its patented technology in its own products, including iKnowU?, a contextually aware predictive keyboard for mobile devices that makes typing easier, faster and more accurate for mobile users. WordLogic?s technology also includes Gesturing and Wordchunking, features that increase the speed and accuracy of typing. WordLogic?s ReachTM technology understands the context of what a person is typing, and instantly provides access to other applications or data sources to retrieve relevant information. Please see for additional information on WordLogic?s products and technology. WordLogic has been actively pursuing the licensing and enforcement of its patented technology since 2012. Since that time, dozens of companies have become licensed under the WordLogic patents. We are currently contacting companies utilizing WordLogic?s patented predictive text technology in the hope of reaching a reasonable licensing arrangement that will allow them to continue utilizing the technology. The 124 patent and the ?984 patent are the subject of ongoing litigation initiated in the Northern District of Illinois in a matter entitled WordLogic Corp. er al v. lecksy, Inc, 16 CV 11714 (N .D. Ill. Feb. 2, 2017}?now transferred to the Northern District of California. In this case, the ?124 patent was challenged under ?101 of the Patent Act and that challenge was denied. Furthermore, claim 19 described in detail below was speci?cally analyzed under ?l01 in the Opinion and Order denying the challenge. INFRINGEMENT OF THE WORDLOGIC PATENTS Please have your patent lawyers care?illy review the claims of WordLogic?s patents. We are con?dent that we can prove that WIKIPEDIA directly infringes claims of at least the 124 patent. A representative claim chart detailing direct infringement of claim 19 of the 124 patent is shown below. US. Patent No. 7,681,124 Claim 19 WIKIPEDIA Website 19. A computer-readable The WIKIPEDIA website includes a predictive text search box medium comprising codes that operates on software that directs a processing unit on how for directing a processing to process text that is entered in the search box from a personal unit to process text entered computer or personal handheld computing device. into a personal computing device, by: receiving and displaying a partial text entry, comprising receiving at least part of the partial text entry via a keyboard, the partial text entry comprising at least a ?rst The predictive text search box receives and displays text in the search box. .1. V- Special page in #1 mei?mA Search resultsw a, The Free FDA character; in response to In response to the ?rst character typed, the website obtains a plurality of receipt of the ?rst completion candidates, and each completion candidate includes a portion character of the that matches the ?rst character typed. partial text entry, obtaining a For example, typing the letter generates the following list of completion plurality of candidates: completion candidates from among a group of completion candidates, wherein each of the plurality of completion candidates includes a portion matching the partial text entryWIKIPEDIA The Free Specaal page Searshresults I Mam page Contents Featured content Cunent events Random article Donate to store Spam Sweden Soviet Unlon Interaction Help Scotland About Wikipedia Community portal Recent changes Contact page ?palr Smith Alnca Smgaoorc . . IJS Spoon! Counsel (gut/101.9) Tools Upload ?le Spamal pages South Korea E'r'r'l?'ire' displaying the plurality of completion candidates in a search list within a graphical user interface; The completion candidates are displayed in a search list on a computer screen or the screen of a handheld personal device. detecting The website detects user input, namely, clicking on a particular completion user input candidate in the search, that corresponds with selecting a particular completion correspondin candidate. to selection of a particular For example, ?Spain? may be selected from the search list by clicking on it. completion candidate from among ,2 the plurality ?f of completion ?i a; Sma?page candidates x? g: . ?1 A Search results the search mmemympem . list; Spam modifying When a particular completion candidate is selected, the search term displayed in the display of the search box is modi?ed to match the completion candidate selected. the partial text entry to For example, if ?Spain? is selected from the search list, the search term correspond to displayed in the search box is modi?ed. the particular completion . .v 4; candldate f? i ?u f" Special page selected from among the wimi'gmA Searchiiesulta . The Free Enuytlopedin plurallty of lq spam 0 Search completion mm spa," candidates at 5:33;: content . spamsh on War 7: least while :?rm I Spain national football [cam the particular 372:: Spaniards completion ?Bram? Spain .umed States relations C??dld?t? Heir} Spain--Un:tcd Kingdom relations (Spanish remains ?gmgirm Spain during World War II selected; :Cng?i?aaxas Spain men's national basketoah team - Spain woman?s national woman ream us 0 pain SF 3153?? . Spain at me 2020 Summer Olympics detecting The website detects modi?cation of the search term by a user Via a keyboard, modi?cation which may be by adding letters to the search term, or by deleting letters from the of the partial search term. text entry by the user Via the keyboard; obtaining Modi?cation of the search term via a keyboard causes a new search list to be and obtained and displayed. Each of the modi?ed plurality of completion candidates displaying in in the search list includes a portion that matches the modi?ed search term, as the search list shown below. a modi?ed plurality of completion candidates from among the group of completion candidates, if the partial text entry is modi?ed via Special page A Search results 7 7 l? om A Not logged in Talk Contributions Create account Log in the keyboard, wherein each View history I 5 i of the 3 modi?ed Spam plurality of 1 Sweden completion Switzerland candidates Soviet Union includes a semiarid . South Africa portlon Singapore matChing the Special Counsel investigation (201 7?201 9) partial text South Korea entry, and containing A. obtaining If one of the new completion candidates is selected from the modi?ed search and list, a further modi?ed list of completion candidates is obtained and displayed. displaying in Each of the further modi?ed plurality of completion candidates in the search list the search list includes a portion that matches the selected search term. a further modi?ed plurality of For example, if ?Spaniards? is selected from the search list, the following list of completion further modi?ed completion candidates is displayed. candidates from among the group of completion candidates, if a completion candidate is accepted via the search list from the modi?ed plurality of completion candidates, wherein each of the further modi?ed plurality of completion candidates includes a portion matching the accepted completion candidate. WIKIPEDIA The Free Main page Contents =eaimeu conienl Current events Random article Donate lo Wlkipeaia WlkIDedIa store Interaction Help About Wiklpedla Community penal Racer? changes Contact page Tools Upioad rue Spemai pages Priniable versaon A. Search, Soecral page Spaniardsl Spaniards Spaniards In Mexico . Spaniards inn Spaniards In ihc Ur?iicd Kingdom Spaniards Bav Spaniards in New Mexico I. there are a Spaniards in Paris Spaniards in Baltimore - . . . Spaniards in Sweden Iona GUInea 5 Spaniards Mount Lisl oi Spaniards I 7' professional rugby union player for Worcester Warriors; considered the greaiest Spaniard 10 ever play the game 57 KB {5.326 words) - 08:49. 2 Januarv 2020 CONCLUSION We recognize that WIKIPEDIA has several options for addressing WordLogic?s infringement concerns, including litigation and/or WIKIPEDIA attempting to invalidate the patents by ?ling an Inter Partes Review (IPR) with the Patent Of?ce. Although we are con?dent in the validity and infringement of the WordLogic patents, we appreciate the inherent risks and costs to a patent owner in pursuing litigation and/or facing the uncertainties of IPR proceedings. To that end, and to encourage the continued use of WordLogic patented technology, Wordlogic is offering a discounted, lump sum fee of $30,000 in exchange for a paid-up one? time license. Please contact me at 512-791-7963 or artoush@ohanianip.com to discuss a licensing arrangement, or let me know if you need additional time to review. You may also contact WordLogic Licensing agent Pete Sirianni at (561)699-8043 or at siriannip07@me.com . If I do not hear from you by that date I will assume you are not interested in discussing a quick resolution, and we will proceed with the litigation. Thank you for your consideration, and I look forward to working with you. Sincerely, m. Ar? . - H. Artoush Ohanian