Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 1 of 18 Page ID
`#:1111
`
`EXHIBIT A
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 2 of 18 Page ID
`#:1112
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`1pre. A method
`for distribution of
`application
`programs to a
`target on-demand
`server on a
`network
`comprising the
`following
`executed on a
`centralized
`network
`management
`server coupled to
`the network:
`
`
`Ubisoft practices a method for distribution of application programs to a target on-demand server on a network from a
`centralized network management server coupled to the network.
`
`
`Ubisoft distributes its Uplay PC, Ubisoft game software (e.g., Assassin’s Creed Odyssey, Anno 1800, Far Cry 5, Ghost
`Recon Breakpoint, etc.), and its Uplay+ game service (including games or other applications distributed or streamed by
`Ubisoft through Uplay+) (application programs) from a centralized network management server coupled to the network to
`on-demand servers.
`
`The application programs are distributed and made available to end users/customers through a Content Delivery Network
`(“CDN”). The architecture of a CDN, such as the one Ubisoft uses to distribute the application programs, includes a
`centralized network management server and target on-demand server.
`
`The below diagram shows an example CDN architecture, which includes a centralized network management server (a.k.a.
`“origin” or “backend” server) and a target on-demand server (a.k.a. “edge” server).
`
`Source: codementor.io/devops/tutorial/devops-tutorial-nginx-reverse-proxy
`
`As shown in the below screenshot, Ubisoft uses at least Akamai’s CDN to distribute application programs from a centralized
`network management server to target on-demand servers.
`
`
`
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`3266504.v1
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`1
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 3 of 18 Page ID
`#:1113
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/our-customers/customer-stories-ubisoft.jsp
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/multimedia/documents/white-paper/optimizing-download-delivery-for-gaming-
`white-paper.pdf
`
`
`
`
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`
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`3266504.v1
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`2
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 4 of 18 Page ID
`#:1114
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`1a. providing an
`application
`program to be
`distributed to the
`network
`management
`server;
`
`
`Ubisoft practices a method that provides an application program to be distributed to the network management server.
`
`Ubisoft’s use of a CDN to distribute the application programs entails that Ubisoft provides the application programs to a
`centralized network management server (i.e., “origin” or “backend” server). Requests for the application programs that are
`not cached by an edge server are forwarded to a Ubisoft origin (centralized network management) server to which Ubisoft
`provides the application programs.
`
`
`
`
`
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`3266504.v1
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`3
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 5 of 18 Page ID
`#:1115
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/multimedia/documents/white-paper/optimizing-download-delivery-for-gaming-
`white-paper.pdf
`
`Ubisoft practices a method that specifies a source directory and a target directory for distribution of the application program.
`
`Uniloc uses the CDN to perform file transfer operations from an origin server to a target on-demand server. File exchange
`operations between servers involve a source and destination directory.
`
`
`1b. specifying a
`source directory
`and a target
`directory for
`distribution of
`the application
`program;
`
`
`
`3266504.v1
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`
`
`4
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 6 of 18 Page ID
`#:1116
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`
`3266504.v1
`
`5
`
`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 7 of 18 Page ID
`#:1117
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/multimedia/documents/white-paper/optimizing-download-delivery-for-gaming-
`white-paper.pdf
`
`Ubisoft practices a method that prepares a file packet associated with the application program and includes a segment
`configured to initiate registration operations for the application program at the target on-demand server.
`
`Using the CDN, Ubisoft retrieves the application programs from an origin server. Ubisoft prepares a file packet including
`a segment associated with registration operations for the application programs at the target on-demand server.
`
`
`
`
`6
`
`1c. preparing a
`file packet
`associated with
`the application
`program and
`including a
`segment
`configured to
`initiate
`registration
`operations for the
`application
`
`3266504.v1
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 8 of 18 Page ID
`#:1118
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`program at the
`target on-demand
`server; and
`
`
`
`
`
`
`
`
`3266504.v1
`
`7
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 9 of 18 Page ID
`#:1119
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/multimedia/documents/white-paper/optimizing-download-delivery-for-gaming-
`white-paper.pdf
`
`
`Ubisoft practices a method that distributes the file packet to the target on-demand server to make the application program
`available for use by a user at a client.
`
`Using the CDN, Ubisoft distributes the file packet including a segment to initiate registration operations for the application
`programs to make those application programs available for use by a user at the user’s computer.
`
`
`
`
`
`8
`
`1d. distributing
`the file packet to
`the target on-
`demand server to
`make the
`application
`program
`available for use
`by a user at a
`client.
`
`3266504.v1
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 10 of 18 Page ID
`#:1120
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`3. A method
`according to
`claim 1 wherein
`the segment
`configured to
`initiate
`registration
`operations
`includes an
`import data file
`and a call to an
`import program
`executing on the
`target on-demand
`server to install
`and register the
`file packet
`associated with
`the application
`program on the
`target on-demand
`server in a
`manner that
`makes it
`recognized and
`available to the
`user at the client.
`
`4. A method
`according to
`claim 3 wherein
`registration
`operations
`include
`
`3266504.v1
`
`
`Ubisoft practices the method of claim 1, wherein the segment configured to initiate registration operations includes an import
`data file and a call to an import program executing on the target on-demand server to install and register the file packet
`associated with the application program on the target on-demand server in a manner that makes it recognized and available
`to the user at the client.
`
`Refer to claim 1c.
`
`One or more of the file packet(s) relating to registration will involve at least one data file and an associated call to a program
`capable of evaluating and installing the registration operation(s) in question such that they are recognizable and made
`available to users at the client.
`
`
`
`
`Ubisoft practices the method of claim 3, wherein registration operations include maintaining at the target on-demand server
`a profile management list identifying application programs available for use by the user and wherein the method further
`comprises updating the profile management list at the target on-demand server to make the application program available
`for use by the user.
`
`Refer to claim 3.
`
`9
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 11 of 18 Page ID
`#:1121
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`maintaining at
`the target on-
`demand server a
`profile
`management list
`identifying
`application
`programs
`available for use
`by the user and
`wherein the
`method further
`comprises
`updating the
`profile
`management list
`at the target on-
`demand server to
`make the
`application
`program
`available for use
`by the user.
`
`5. A method
`according to
`claim 4 wherein
`the profile
`management list
`includes a
`designation of
`authorized users
`for application
`programs
`
`3266504.v1
`
`
`For example, Ubisoft maintains at the target on-demand server one or more profile lists that associate users with authorized
`applications, applications with authorized users, or identifies other restrictions or permissions as to the availability of use of
`the application program by the user. Ubisoft updates the profile lists in accordance with whether the user has a valid license
`for the application software, account credentials, whether the user’s account or license has been suspended or banned, save
`game data, and other restrictions and permissions to make the application available for use by the user.
`
`
`Ubisoft practices the method of claim 4, wherein the profile management list includes a designation of authorized users for
`application programs identified in the profile management list.
`
`Refer to claim 4.
`
`
`
`10
`
`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 12 of 18 Page ID
`#:1122
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`
`
`Ubisoft practices the method of claim 1, wherein distributing the file packet is preceded by executing a pre-distribution
`program at the network management server.
`
`Refer to claim 1pre-1d
`
`As shown in the screenshots below, before the claimed file packet is distributed to the target on-demand server, a
`predistribution program is run by Ubisoft on the network management (i.e., “origin” or “backend”) server.
`
`
`Claim
`identified in the
`profile
`management list.
`
`8. A method
`according to
`claim 1 wherein
`distributing the
`file packet is
`preceded by
`executing a pre-
`distribution
`program at the
`network
`management
`server.
`
`
`
`
`
`
`3266504.v1
`
`11
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`

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`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 13 of 18 Page ID
`#:1123
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Source: https://www.akamai.com/us/en/multimedia/documents/white-paper/optimizing-download-delivery-for-gaming-
`white-paper.pdf
`
`Ubisoft practices the method of claim 8, wherein executing a pre-distribution program includes determining an
`environment for the application program that exists on the target on-demand server.
`
`Refer to claim 8.
`
`Ubisoft’s practice of claim 8 includes determining an environment for the application program that exists on the target on-
`demand server.
`
`12
`
`9. A method
`according to
`claim 8 wherein
`executing a pre-
`distribution
`program includes
`determining an
`
`3266504.v1
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 14 of 18 Page ID
`#:1124
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`
`
`
`Source: https://en.wikipedia.org/wiki/Uplay
`
`
`
`Ubisoft practices the method of claim 9, wherein preparing a file packet includes including a selected version of an
`application launcher in the file packet, the selected version being selected based on the determined environment.
`
`Refer to claim 9.
`
`
`Claim
`environment for
`the application
`program that
`exists on the
`target on-demand
`server.
`
`10. A method
`according to
`claim 9 wherein
`preparing a file
`packet includes
`including a
`selected version
`of an application
`launcher in the
`file packet, the
`selected version
`being selected
`based on the
`determined
`environment.
`
`
`
`Claim
`12pre. An application program distribution system for distributing application programs to
`a target on-demand server on a network executing on a centralized network management
`server coupled to the network, the system comprising:
`
`Ubisoft (uplay.ubisoft.com)
`implements an application program
`Ubisoft
`distribution system for distributing application
`programs to a target on-demand server on a
`network executing on a centralized network
`management server coupled to the network.
`
`Refer to Claim 1pre
`
`3266504.v1
`
`13
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 15 of 18 Page ID
`#:1125
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`12a. means for providing to the network management server an application program to be
`distributed to remote servers;
`
`12b. means for specifying a source directory and a target directory for distribution of the
`application program;
`
`12c. means for preparing a file packet associated with the application program, the file
`packet including a segment configured to initiate registration operations for the application
`program at the target on-demand server; and
`
`12d. means for distributing the file packet to the target on-demand server to make the
`application program available for use by a user at a client.
`
`Ubisoft (uplay.ubisoft.com)
`application program distribution
`Ubisoft’s
`system includes means for providing to the
`network management server an application
`program to be distributed to remote servers.
`
`Refer to Claim 1a
`Ubisoft’s
`application program distribution
`system includes means for specifying a source
`directory and a target directory for distribution of
`the application program.
`
`Refer to Claim 1b
`Ubisoft’s
`application program distribution
`system includes means for preparing a file packet
`associated with the application program, the file
`packet including a segment configured to initiate
`registration operations
`for
`the application
`program at the target on-demand server.
`
`Refer to Claim 1c
`Ubisoft’s
`application program distribution
`system includes means for distributing the file
`packet to the target on-demand server to make the
`application program available for use by a user at
`a client.
`
`Refer to Claim 1d
`
`3266504.v1
`
`14
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`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 16 of 18 Page ID
`#:1126
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`14. A system according to claim 12 wherein the segment configured to initiate registration
`operations includes an import data file and a call to an import program executing on the
`target on-demand server to install and register the file packet associated with the
`application program on the target on-demand server in a manner that makes it recognized
`and available to the user at the client.
`
`
`17pre. A computer program product for distributing application programs to a target on-
`demand server on a network executing on a centralized network management server
`coupled to the network, the computer program product comprising:
`
`17a. a computer-readable storage medium having computer-readable program code
`embodied in said medium, said computer-readable program code comprising:
`
`
`17b. computer readable program code that provides to the network management server an
`application program to be distributed to remote servers;
`
`3266504.v1
`
`15
`
`Ubisoft (uplay.ubisoft.com)
`Ubisoft’s application program distribution
`system of claim 12 further includes the
`limitation, wherein the segment configured to
`initiate registration operations includes an import
`data file and a call to an import program
`executing on the target on-demand server to
`install and register the file packet associated with
`the application program on the target on-demand
`server in a manner that makes it recognized and
`available to the user at the client.
`
`Refer to claim 3.
`
`Ubisoft’s computer program product includes a
`computer readable program code for distributing
`application programs to a target on-demand
`server on a network executing on a centralized
`network management server coupled to the
`network.
`
`Refer to Claim 1pre
`Ubisoft’s computer program product includes a
`computer-readable
`storage medium having
`computer-readable program code embodied in
`said medium.
`
`Refer to Claim 1pre
`Ubisoft’s computer program product includes a
`computer readable program code that provides to
`the network management server an application
`program to be distributed to remote servers.
`
`Refer to Claim 1a
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 17 of 18 Page ID
`#:1127
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`17c. computer readable program code that specifies a source directory and a target
`directory for distribution of the application program;
`
`17d. computer readable program code means that prepares a file packet associated with the
`application program, the file packet including a segment configured to initiate registration
`operations for the application program at the target on-demand server; and
`
`17e. computer readable program code means that distributes the file packet to the target on-
`demand server to make the application program available for use by a user at a client.
`
`Ubisoft (uplay.ubisoft.com)
`Ubisoft’s computer program product includes a
`computer readable program code that specifies a
`source directory and a target directory for
`distribution of the application program.
`
`Refer to Claim 1b
`Ubisoft’s computer program product includes a
`computer readable program code means that
`prepares a file packet associated with the
`application program, the file packet including a
`segment configured
`to
`initiate
`registration
`operations for the application program at the
`target on-demand server.
`
`Refer to Claim 1c
`Ubisoft’s computer program product includes a
`computer readable program code means that
`distributes the file packet to the target on-demand
`server to make the application program available
`for use by a user at a client.
`
`Refer to Claim 1d
`
`
`3266504.v1
`
`16
`
`

`

`Case 8:19-cv-01150-DOC-KES Document 67-3 Filed 11/23/20 Page 18 of 18 Page ID
`#:1128
`INFRINGEMENT CHART – U.S. PAT. NO. 7,069,293 v. Ubisoft
`
`
`Claim
`19. A computer program product according to claim 17 wherein the segment configured to
`initiate registration operations includes an import data file and a call to an import program
`executing on the target on-demand server to install and register the file packet associated
`with the application program on the target on-demand server in a manner that makes it
`recognized and available to the user at the client.
`
`
`Ubisoft (uplay.ubisoft.com)
`Ubisoft’s computer program product of claim 17
`further includes the limitation, wherein the
`segment configured to initiate registration
`operations includes an import data file and a call
`to an import program executing on the target on-
`demand server to install and register the file
`packet associated with the application program
`on the target on-demand server in a manner that
`makes it recognized and available to the user at
`the client.
`
`Refer to claim 3.
`
`
`
`
`3266504.v1
`
`17
`
`