Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 1 of 315 PageID #: 763
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 1 of 315 PagelD #: 763
`
`
`
`EXHIBIT 8
`EXHIBIT 8
`
`
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 2 of 315 PageID #: 764
`
`Accused Product: Destiny
`6,701,344
`The statements and documents cited below are solely provided by way of example by Acceleration Bay, LLC ("Acceleration Bay"
`or "Plaintiff"), and are not to be used by way of limitation or for purposes of construing the claim terms.
`
`“Accused Product” refers to the PlayStation 3, PlayStation 4, Xbox One and Xbox 360 versions of Destiny (including without
`limitation Destiny Limited Edition, Destiny Standard Edition, Destiny: The Taken King – Collector’s Edition, Destiny: The Taken
`King – Digital Collector’s Edition, Destiny: The Taken King – Legendary Edition, Destiny: The Taken King – Limited Edition,
`Iron Banner, Prison of Elders, Trials of Osiris, the Dark Below and The House of Wolves).
`
`Acceleration Bay contends that the Accused Product infringes both literally and under the doctrine of equivalents.
`
`Gameplay of the Accused Product is consistent with the following contentions.
`
`Claim 1
`1-a. A computer
`network for
`providing a
`game
`environment for
`a plurality of
`participants,
`
`
`The Accused Product meets the recited claim language because it provides a computer network for providing a
`game environment for a plurality of participants.
`
`For example and without limitation, the following screen capture shows that the Accused Product provides a
`computer network for providing a game environment that allows multiple participants to play the game online
`concurrently, including in sessions of 16 player participants:
`
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 3 of 315 PageID #: 765
`
`http://vgboxart.com/viewfullsize/66658/Destiny/
`
`Such computer network for providing a game environment includes, for example and without limitation, Public
`Event, Tower, Crucible, Strike, Fireteam, Iron Banner, and in game voice over Internet protocol (“VoIP”) voice
`chat functionality.
`
`As a further example and without limitation, the following screen captures show that the Accused Product
`provides a computer network for providing a game environment for a plurality of player participants by utilizing
`a “mesh-based” network that supports “millions of players online at once”:
`
`
`
`
`
`2
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 4 of 315 PageID #: 766
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`
`
`3
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 5 of 315 PageID #: 767
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`For example and without limitation, the following screen captures show that the Accused Product provides voice
`chat features to allow multiple players to chat with each other in game using the peer-to-peer technology:
`
`
`
`4
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 6 of 315 PageID #: 768
`
`Opt-in Voice Channels
`
`As part of Destiny Update 1.0.3, scheduled for deployment on November 18th, youwill have access to two options
`for talking to the Guardians with whom youfight.
`
`lo)Mlilemanlsere) 9) plea eel
`
`Team Chat
`After the update, you'll be able to join a new channelthatwill provide for Team Chat. This will include the players
`you meet via Matchmaking, as well as members of your Fireteam who make the same selection. This option will be
`available in any matchmadeactivity — including Strikes and in team-based Crucible matches. Team Chatis signified
`
`TOGGLE VOICE CHANNEL ove
`w= Strike Team Chat
`“O
`
`TOGGLE VOICE CHANNEL a
`™@) Fireteam Chat
`O
`
`leatEEL
`
`Since launch, you've been able to use Fireteam Chat to speak to the Guardiansincludedin your pre-formed party.
`This includes players whojoin you in orbit before you begin an activity together. Fireteam Chatis signified by the
`speakericon.
`
`5
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 7 of 315 PageID #: 769
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 7 of 315 PagelD #: 769
`
`Team Chat Availability
`
`Upon landing in an activity where opt-in voice is enabled, you'll receive a notification that says Team voice chat now
`available. Look to the lower left of your screen for the prompt.
`
`[click to enlarge - see lowerleft]
`
`That's your invitation to join them.
`
`_
`
`
`
`
`
`Whena player accesses the channel, you'll see a promptthat says [Player] has entered the Team voice channel.
`
`Seimei
`
`
`
`6
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 8 of 315 PageID #: 770
`
`1-b. each
`participant
`having
`connections to
`
`https://www.bungie.net/en/News/Article/12376/7_voice-chat-beta-in-destiny
`The Accused Product meets the recited claim language because it provide a computer network in which each
`participant has connections to at least three neighbor game players’ consoles and/or game servers as participants.
`
`For example and without limitation, the following screen capture shows that the Accused Product uses a “peer-
`
`
`
`7
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 9 of 315 PageID #: 771
`
`at least three
`neighbor
`participants,
`
`to-peer system” and “creates connection between your console…and other players…,” permitting each
`participant’s console to have connections to multiple neighbor participants:
`
`
`https://www.bungie.net/en/Support/Troubleshoot?oid=12915
`
`As a further example and without limitation, based on publicly available information, the Accused Product
`utilizes a “hybrid” peer-to-peer network topology, where additional game player’s consoles as participants can
`forward data from one neighbor participant to another neighbor participant and non-client servers called
`“activity hosts” can also communicate with each other as additional participants in the network:
`
`
`
`8
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 10 of 315 PageID #: 772
`
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 10 of 315 PagelD #: 772
`
`
`
`.. and uniquely complicated networking topology
`
`Over the next hour, I’m going to talk through the decisions that led us to this unique
`
`architecture, and both the advantages and disadvantages that have resulted from our
`choices.
`
`
`
`Instead of just using a Peer-to-peer architecture like our previous Halo games, or
`implementing traditional dedicated servers, we built a hybrid approach that we call
`“Activity Hosts.”
`9
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 11 of 315 PageID #: 773
`
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 11 of 315 PagelD #: 773
`
`
`
`DESTINY ¥
`
`Dedicated Servers!
`
`Need to be cost-feasible
`
`Need to perserve peer-to-peer responsiveness
`Can weinstead “fix” our Host Migration
`problems?
`
`At this point, I’m sure some of you are thinking —just use dedicated servers! If we
`just never Host Migrate, because we put all our Physics Hosts in the cloud, we never
`have to solve all these pesky problems.
`
`There's a couple strong reasons we didn’t simply run dedicate servers that were
`traditional Physics Hosts.
`
`For one thing, they need to be cost-feasible. To support our launch, we'd have
`needed hundreds of thousands of headless P53-Parity executables in the cloud, and
`10
`that becomes a significant continuous cost to maintain, especially if our player-
`retention continues to stay as strong as it has.
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 12 of 315 PageID #: 774
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 12 of 315 PagelD #: 774
`
`
`Additionally, peer-to-peer networking supports maximally responsive action
`gameplay.
`In many cases we can match you with players that are in the samecity as
`you, and you get extremely low latency with your Physics Host — much better than
`what we could do with Dedicated Servers. We don’t want to increase our latency for
`firing bullets and doing damage — that violates our “Feels like a Single-Player Shooter”
`goal.
`
`50 — can we keep our traditional Physics Hosts around, but “fix” the Host Migration
`problems that Halo had?
`
`11
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 13 of 315 PageID #: 775
`
`
`http://twvideo01.ubm-us.net/o1/vault/gdc2015/presentations/Truman_Justin_Shared_World_Shooter.pdf
`
`12
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 14 of 315 PageID #: 776
`
`The Accused Product meets the recited claim language because it provides a computer network in which an
`originating participant sends data to the other participants by sending the data through each of its connections to
`its neighbor participants.
`
`For example and without limitation, the following screen captures show that the Accused Product uses a peer-to-
`peer system that “creates connection between your console…and other players…” and the “mesh-based
`network” that allow each game player’s console as a participant to send data to other participants by sending the
`data through its connections to its neighbor participants:
`
`
`1-c. wherein an
`originating
`participant
`sends data to
`the other
`participants by
`sending the data
`through each of
`its connections
`to its neighbor
`participants and
`
`https://www.bungie.net/en/Support/Troubleshoot?oid=12915
`
`
`
`
`
`13
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 15 of 315 PageID #: 777
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`
`
`
`14
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 16 of 315 PageID #: 778
`
`As a further example and without limitation, based on publicly available information, the Accused Product
`utilizes a “hybrid” peer-to-peer network topology, where additional game player’s consoles as participants can
`forward data from one neighbor participant to another neighbor participant and non-client servers called
`“activity hosts” can also communicate with each other as additional participants in the network:
`
`15
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 17 of 315 PageID #: 779
`
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 17 of 315 PagelD #: 779
`
`
`
`
`
`Physics Client
`Bob
`
`Physics Client
`Charlie
`
`
`
`
`.. and uniquely complicated networking topology
`
`Over the next hour, I’m going to talk through the decisions that led us to this unique
`
`architecture, and both the advantages and disadvantages that have resulted from our
`choices.
`
`
`
`Instead of just using a Peer-to-peer architecture like our previous Halo games, or
`implementing traditional dedicated servers, we built a hybrid approach that we call
`“Activity Hosts.”
`16
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 18 of 315 PageID #: 780
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 18 of 315 PagelD #: 780
`
`
`
`DESTINY ¥
`
`Dedicated Servers!
`
`Need to be cost-feasible
`
`Need to perserve peer-to-peer responsiveness
`Can weinstead “fix” our Host Migration
`problems?
`
`At this point, I’m sure some of you are thinking —just use dedicated servers! If we
`just never Host Migrate, because we put all our Physics Hosts in the cloud, we never
`have to solve all these pesky problems.
`
`There's a couple strong reasons we didn’t simply run dedicate servers that were
`traditional Physics Hosts.
`
`For one thing, they need to be cost-feasible. To support our launch, we'd have
`needed hundreds of thousands of headless P53-Parity executables in the cloud, and
`17
`that becomes a significant continuous cost to maintain, especially if our player-
`retention continues to stay as strong as it has.
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 19 of 315 PageID #: 781
`
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 19 of 315 PagelD #: 781
`
`
`Additionally, peer-to-peer networking supports maximally responsive action
`gameplay.
`In many cases we can match you with players that are in the samecity as
`you, and you get extremely low latency with your Physics Host — much better than
`what we could do with Dedicated Servers. We don’t want to increase our latency for
`firing bullets and doing damage — that violates our “Feels like a Single-Player Shooter”
`goal.
`
`50 — can we keep our traditional Physics Hosts around, but “fix” the Host Migration
`problems that Halo had?
`
`18
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 20 of 315 PageID #: 782
`
`
`http://twvideo01.ubm-us.net/o1/vault/gdc2015/presentations/Truman_Justin_Shared_World_Shooter.pdf
`
`19
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 21 of 315 PageID #: 783
`
`1-d. wherein
`each participant
`sends data that
`it receives from
`a neighbor
`participant to its
`other neighbor
`participants,
`
`The Accused Product meets the recited claim language because it provides a computer network in which each
`participant sends data that it receives from a neighbor participant to its other neighbor game players’ consoles
`and/or game servers as participants.
`
`For example and without limitation, based on publicly available information, the Accused Product utilizes a
`“hybrid” peer-to-peer network topology, where additional game player’s consoles as participants can forward
`data from one neighbor participant to another neighbor participant and non-client servers called “activity hosts”
`can also communicate with each other as additional participants in the network:
`
`20
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 22 of 315 PageID #: 784
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 22 of 315 PagelD #: 784
`
`
`
`
`
`Physics Client
`Bob
`
`Physics Client
`Charlie
`
`
`
`
`.. and uniquely complicated networking topology
`
`Over the next hour, I’m going to talk through the decisions that led us to this unique
`
`architecture, and both the advantages and disadvantages that have resulted from our
`choices.
`
`
`
`Instead of just using a Peer-to-peer architecture like our previous Halo games, or
`implementing traditional dedicated servers, we built a hybrid approach that we call
`“Activity Hosts.”
`21
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 23 of 315 PageID #: 785
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 23 of 315 PagelD #: 785
`
`
`
`DESTINY ¥
`
`Dedicated Servers!
`
`Need to be cost-feasible
`
`Need to perserve peer-to-peer responsiveness
`Can weinstead “fix” our Host Migration
`problems?
`
`At this point, I’m sure some of you are thinking —just use dedicated servers! If we
`just never Host Migrate, because we put all our Physics Hosts in the cloud, we never
`have to solve all these pesky problems.
`
`There's a couple strong reasons we didn’t simply run dedicate servers that were
`traditional Physics Hosts.
`
`For one thing, they need to be cost-feasible. To support our launch, we'd have
`needed hundreds of thousands of headless P53-Parity executables in the cloud, and
`22
`that becomes a significant continuous cost to maintain, especially if our player-
`retention continues to stay as strong as it has.
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 24 of 315 PageID #: 786
`
`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 24 of 315 PagelD #: 786
`
`
`Additionally, peer-to-peer networking supports maximally responsive action
`gameplay.
`In many cases we can match you with players that are in the samecity as
`you, and you get extremely low latency with your Physics Host — much better than
`what we could do with Dedicated Servers. We don’t want to increase our latency for
`firing bullets and doing damage — that violates our “Feels like a Single-Player Shooter”
`goal.
`
`50 — can we keep our traditional Physics Hosts around, but “fix” the Host Migration
`problems that Halo had?
`
`23
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 25 of 315 PageID #: 787
`
`
`http://twvideo01.ubm-us.net/o1/vault/gdc2015/presentations/Truman_Justin_Shared_World_Shooter.pdf
`
`For example and without limitation, the following screen capture shows that the Accused Product uses a “peer-
`to-peer system” and “creates connection between your console…and other players…” where game players’
`
`24
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 26 of 315 PageID #: 788
`
`consoles are peers/participants:
`
`
`https://www.bungie.net/en/Support/Troubleshoot?oid=12915
`
`
`
`
`1-e. further
`wherein the
`network is m-
`regular, where
`m is the exact
`number of
`neighbor
`participants of
`
`http://www.eurogamer.net/articles/2013-06-21-destiny-how-to-save-online-worlds
`Based on a review of publicly available information, the Accused Product meets the recited claim language
`because it provides a computer network that is m-regular, where m is the exact number of neighbor game
`players’ consoles and/or game servers as participants of each participant.
`
`
`For example and without limitation, the Accused Product creates m-regular connectivity meshes of players
`during different network game sessions and for different game session data. For example, m-regular can
`indicate that each of the players is optimally connected to other players to ensure that all nodes are connected to
`the same number of nodes to ensure that no node is overloaded. For example, the Accused Product creates m-
`
`
`
`25
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 27 of 315 PageID #: 789
`
`regular topologies of players when setting up logical and physical network topologies for the Accused Product
`using different networking libraries, SDKs and APIs. The libraries, SDKs and APIs utilized by the Accused
`Product to create these m-regular topologies include software provided by Demonware as well as internally
`developed libraries, SDKs and APIs. They also include the ability to set the maximum number of peers and
`players. The Accused Product uses these libraries, SDKs and APIs to:
`
` 
`
` connect players to other players for matchmaking;
` determine which game a player should be matched to;
` ensure no players are overloaded for optimal gameplay in a connectivity mesh;
` create a game session with logical and physical network topologies for the game;
` create network connections through sockets and ports;
` manage the game during gameplay and to relay content through different NAT configurations;
`
`route game data using optimal paths and relays;
` distribute VoIP chat data among the players; and
` manage states when different players leave, are kicked, or are disconnected.
`
`
`For example but not limitation, the Accused Product performs matchmaking and player distribution within a
`multiplayer game. The Accused Product attempts to evenly distributed players on the logical and physical
`networks. In an evenly-distributed multiplayer game, the network of players is m-regular. The Accused Product
`includes setting-up peer-to-peer mesh topologies in different configurations, including optimized peer meshes.
`In addition, it appears that there are multiple logical and physical layers of the network topology that maintain a
`regular network in order to optimize performance based on the type of data that is being transmitted.
`The Accused Product meets the recited claim language because it provides a computer network in which the
`number of participants is at least two greater than m thus resulting in a non-complete graph.
`
`For example and without limitation, the Accused Product creates a non-complete mesh of players during
`different game sessions, for example where not every player in the game session is directly connected, either
`logically or physically, to every other player in the game. For example, the Accused Product creates a non-
`complete graph of players when setting up a logical and physical network topology for the Accused Product
`using different networking libraries, SDKs and APIs. The Accused Product utilizes topologies that naturally
`include a non-complete optimized mesh, as well as topologies that include a non-complete graph as the result of
`inability to connect to peers, failover states, or during host migration of player hosted games. The chance of a
`non-complete graph grows with the total number of players added to the game, and becomes very likely once
`
`each participant
`and
`
`1-f. further
`wherein the
`number of
`participants is at
`least two greater
`than m thus
`resulting in a
`non-complete
`graph.
`
`26
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 28 of 315 PageID #: 790
`
`more than four players are connected.
`
`
`
`
`
`
`27
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 29 of 315 PageID #: 791
`
`6,829,634
`
`Accused Product: Destiny
`
`The statements and documents cited below are solely provided by way of example by Acceleration Bay, LLC ("Acceleration Bay"
`or "Plaintiff"), and are not to be used by way of limitation or for purposes of construing the claim terms.
`
`“Accused Product” refers to the PlayStation 3, PlayStation 4, Xbox One and Xbox 360 versions of Destiny (including without
`limitation Destiny Limited Edition, Destiny Standard Edition, Destiny: The Taken King – Collector’s Edition, Destiny: The Taken
`King – Digital Collector’s Edition, Destiny: The Taken King – Legendary Edition, Destiny: The Taken King – Limited Edition,
`Iron Banner, Prison of Elders, Trials of Osiris, the Dark Below and The House of Wolves).
`
`Acceleration Bay contends that the Accused Product infringes both literally and under the doctrine of equivalents.
`
`Gameplay of the Accused Product is consistent with the following contentions.
`Claim 1
`
`
`1-a. A non-
`routing table
`based computer
`network having
`a plurality of
`participants,
`
`The Accused Product meets the recited claim language because it provides a non-routing table based computer
`network having a plurality of game players’ consoles and/or game servers as participants.
`
`For example and without limitation, the following screen capture shows that the Accused Product allows
`multiple participants to play the game online concurrently, including in sessions of 16 player participants:
`
`
`28
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 30 of 315 PageID #: 792
`
`http://vgboxart.com/viewfullsize/66658/Destiny/
`
`All of the Accused Product’s game modes incorporate multiplayer functionality, including for example and
`without limitation, Public Event, Tower, Crucible, Strike, Fireteam, Iron Banner, and in game VOIP voice chat
`functionality.
`
`As a further example and without limitation, the following screen captures show that the Accused Product
`utilizes a “mesh-based” network that supports “millions of players online at once”:
`
`
`
`29
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 31 of 315 PageID #: 793
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`
`
`30
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 32 of 315 PageID #: 794
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`
`
`31
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 33 of 315 PageID #: 795
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`For example and without limitation, the following screen captures show that the Accused Product provides
`voice chat features to allow multiple players to chat with each other in game using the peer-to-peer technology:
`
`
`
`32
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 34 of 315 PageID #: 796
`
`As part of Destiny Update 1.0.3, scheduled for deployment on November18th, you will have access to two options
`for talking to the Guardians with whom youfight.
`
`TOGGLE VOICE CHANNEL ove
`w= Strike Team Chat
`“O
`
`TOGGLE VOICE CHANNEL We
`™@)) Fireteam Chat
`OQ
`
` OySAeyeReinat
`by the megaphoneicon.
`
`
`
`see
`
`After the update, you'll be able to join a new channelthatwill provide for Team Chat.This will include the players
`you meetvia Matchmaking, as well as members of your Fireteam who make the same selection. This optionwill be
`available in any matchmadeactivity — including Strikes and in team-based Crucible matches. Team Chatis signified
`
`CRONE
`
`Since launch, you've been able to use Fireteam Chat to speak to the Guardians includedin your pre-formed party.
`This includes players whojoin you in orbit before you begin an activity together. Fireteam Chatis signified by the
`speakericon.
`
`
`
`33
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`blocked from using Team Chatif your networking settings are not properly configured.
`
`Team Chat Errors
`
`lf voice options are unavailable, it could be that you're connected to a party chat service tied to your console. To
`benefit from the new Team Chatvoice feature, you'll need to be using the Destiny game channel. A player using a
`platform-specific channel will see a different promptin the lowerright of the user interface. You may also be
`
`
`
`34
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`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 36 of 315 PageID #: 798
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`https://www.bungie.net/en/News/Article/12376/7_voice-chat-beta-in-destiny
`
`
`
`35
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`

`

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`1-b. each
`participant
`having
`connections to
`at least three
`neighbor
`participants,
`
`The Accused Product meets the recited claim language because it provides a network in which each participant
`has connections to at least three neighbor game players’ consoles and/or game servers as participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because each
`participant can be connected to at least three neighbor game players’ consoles and/or game servers as
`participants via peer to peer technology at the network and/or logical layers when the game is played online in
`one of the multiplayer modes identified above.
`
`
`36
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 38 of 315 PageID #: 800
`
`http://www.gameinformer.com/b/features/archive/2013/12/06/the-matchmaking-technology-of-
`destiny.aspx?PostPageIndex=1
`
`
`
`
`37
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 39 of 315 PageID #: 801
`
`
`As a further example, the following screen capture shows eight participants interacting with each other using
`peer-to-peer connections:
`
`
`https://www.youtube.com/watch?v=dPcrmT0of5g
`
`The Accused Product meets the recited claim language because it provides a network in which an originating
`participant sends data to the other participants by sending the data through each of its connections to its
`neighbor participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because gameplay
`data, such as inputs from game players’ consoles, are distributed to neighbor game players’ consoles and/or
`game servers as participants.
`
`
`
`
`1-c. wherein an
`originating
`participant
`sends data to the
`other
`participants by
`sending the data
`through each of
`
`38
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 40 of 315 PageID #: 802
`
`its connections
`to its neighbor
`participants,
`
`As a further example and without limitation, based on publicly available information, the Accused Product
`utilizes a “hybrid” peer-to-peer network topology, where additional game player’s consoles as participants can
`forward data from one neighbor participant to another neighbor participant and non-client servers called
`“activity hosts” can also communicate with each other as additional participants in the network:
`
`39
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 41 of 315 PageID #: 803
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`Case 1:16-cv-00453-RGA Document1-4 Filed 06/17/16 Page 41 of 315 PagelD #: 803
`
`
`
`
`Charlie
`
`Instead of just using a Peer-to-peer architecture like our previous Halo games, or
`implementing traditional dedicated servers, we built a hybrid approach that we call
`“Activity Hosts.”
`40
`
`Bob
`
`.. and uniquely complicated networking topology
`
`Over the next hour, I’m going to talk through the decisions that led us to this unique
`
`architecture, and both the advantages and disadvantages that have resulted from our
`choices.
`
`
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 42 of 315 PageID #: 804
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`
`
`Need to perserve peer-to-peer responsiveness
`Can weinstead “fix” our Host Migration
`problems?
`
`
`i ne a
`
`Dedicated Servers!
`
`Need to be cost-feasible
`
`At this point, I'm sure some of you are thinking — just use dedicated servers! If we
`just never Host Migrate, because we put all our Physics Hosts in the cloud, we never
`have to solve all these pesky problems.
`
`There's a couple strong reasons we didn’t simply run dedicate servers that were
`traditional Physics Hosts.
`
`For one thing, they need to be cost-feasible. To support our launch, we'd have
`needed hundreds of thousands of headless P53-Parity executables in the cloud, and
`41
`that becomes a significant continuous cost to maintain, especially if our player-
`retention continues to stay as strong as it has.
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 43 of 315 PageID #: 805
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`
`
`Additionally, peer-to-peer networking supports maximally responsive action
`gameplay.
`In many cases we can match you with players that are in the samecity as
`you, and you get extremely low latency with your Physics Host — much better than
`what we could do with Dedicated Servers. We don’t want to increase our latency for
`firing bullets and doing damage — that violates our “Feels like a Single-Player Shooter”
`goal.
`
`
`
`50 — can we keep ourtraditional Physics Hosts around, but “fix” the Host Migration
`problems that Halo had?
`
`42
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 44 of 315 PageID #: 806
`
`
`http://twvideo01.ubm-us.net/o1/vault/gdc2015/presentations/Truman_Justin_Shared_World_Shooter.pdf
`
`For example and without limitation, the following screen captures show that the Accused Product uses a “peer-
`to-peer system” and “creates connection between your console…and other players…”:
`
`43
`
`

`

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`
`
`
`https://www.bungie.net/en/Support/Troubleshoot?oid=12915
`
`
`As a further example, the following screen capture shows eight participants interacting with each other using
`the peer-to-peer connections:
`
`
`
`
`44
`
`

`

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`
`1-d. wherein
`each participant
`sends data that
`it receives from
`a neighbor
`participant to its
`other neighbor
`participants,
`
`
`
`https://www.youtube.com/watch?v=dPcrmT0of5g
`The Accused Product meets the recited claim language because it provides a network in which each participant
`sends data that it receives from a neighbor participant to its other neighbor participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because the
`Accused Product utilizes peer-to-peer topology where participants can forward data from one neighbor
`participant to other neighbor participants.
`
`As a further example and without limitation, based on publicly available information, the Accused Product
`utilizes a “hybrid” peer-to-peer network topology, where additional game player’s consoles as participants can
`forward data from one neighbor participant to another neighbor participant and non-client servers called
`“activity hosts” can also communicate with each other as additional participants in the network:
`
`45
`
`

`

`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 47 of 315 PageID #: 809
`
`Case 1:16-cv-00453-RGA Document 1-4 Filed 06/17/16 Page 47 of 315 PagelD #: 809
`
`
`
`
`Charlie
`
`Instead of just using a Peer-to-peer architecture like our previous Halo games, or
`implementing traditional dedicated servers, we built a hybrid approach that we call
`“Activity Hosts.”
`46
`
`Bob
`
`.. and uniquely complicated networking topology
`
`Over the next hour, I’m going to talk through the decisions that led us to this unique
`
`