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`EXHIBIT 7
`EXHIBIT 7
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`00454-RGA Document 1-3 Filed 06/17/16 Page 2 of 282 |
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` WARNING Before playing this game, read the Xbox 360® console,
`Xbox 360 Kinect® Sensor, and accessory manuals for important safety and health
`information.www.xbox.com/support.
`
`Important Health Warning: Photosensitive Seizures
`
`A very small percentage of people may experience a seizure when exposed to
`certain visual images, including flashing lights or patterns that may appear in
`video games. Even people with no history of seizures or epilepsy may have an
`undiagnosed condition that can cause “photosensitive epileptic seizures” while
`watching video games. Symptoms can include light-headedness, altered vision,
`eye or face twitching, jerking or shaking of arms or legs, disorientation, confusion,
`momentary loss of awareness, and loss of consciousness or convulsions that can
`lead to injury from falling down or striking nearby objects. Immediately stop
`playing and consult a doctor if you experience any of these symptoms.
`Parents, watch for or ask children about these symptoms— children and teenagers
`are more likely to experience these seizures. The risk may be reduced by being
`farther from the screen; using a smaller screen; playing in a well-lit room, and not
`playing when drowsy or fatigued. If you or any relatives have a history of seizures or
`epilepsy, consult a doctor before playing.
`
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`ContEnts
`
`Controls
`1
`on thE CoursE
`2
`GamE sCrEEn
`3
`sEttInGs
`6
`savInG and loadInG
`7
`7 maIn mEnu
`9
`CarEEr
`10 QuICk Play
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`11 lEGEnds of thE majors
`11
` auGusta PraCtICE faCIlIty
`& auGusta natIonal 1934
`(hIstorIC EdItIon only)
`12 onlInE
`15 lImItEd 90-day Warranty
`16 nEEd hElP?
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`Controls
`
`Move aimer
`Address ball
`Open/close stance
`Ball forward/back in stance
`Change shot preset
`Reset aim
`PGA Pro Tip (Practice Round only)
`Change clubs
`Zoom to target
`Check lie
`Putt preview
`Pause menu
`
`PrE-sWInG Controls
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`/
`/
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`(hold)
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`/
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`Move camera
`Change camera zoom
`Return to pre-swing stance
`
`Zoom Controls
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`1
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`Backswing
`Forward swing (only after backswing)
`Move Strike Meter
`Return to pre-swing stance
`Practice swing
`
`on thE CoursE
`
`Swing
`You have complete control over shaping all your shots with the swing system in
`Tiger Woods PGA TOUR ® 14. Move to determine your backswing, and then move to
`follow through and complete your swing. Follow the swing arc to know when to start
`your follow through. The speed of your movement, your aim, and the length of backswing
`determines the outcome of your shot. You can also designate swing controls to under
`Gameplay Settings if that’s more comfortable; this automatically sets the Strike Meter to .
`At higher difficulty levels, you must execute draws and fades by swinging your club diagonally
`(, or , ). The results are more sensitive to mishits.
`Before you swing, notice the Swing Plane is displayed in the lower left hand corner. This Swing
`Plane is the path you should follow with the swing stick for your backswing and follow through.
`If it displays at an angle, then you should swing diagonally. If you are off plane, the club head
`arc will not align with the swing arc and the controller will vibrate. When you are off plane, you
`will mishit the ball and result in an undesirable shot.
`Swing Speed
`Play close attention to the pace of your swing. Adjust the speed of both the backswing and
`follow through to perfect the timing of your swing. You can extend your backswing and speed
`up the forward swing to give an extra power boost. Look to the Swing Feedback Heads Up
`Display (HUD) in the lower-left corner of the screen after your swing for an analysis of your
`backswing and follow through.
`pre-Swing Stance
`Adjust your stance to create unique and dynamic shots. Move / to open your stance and
`add fade right or draw left for right-handed golfers and fade left or draw right for left-handed
`golfers. Move / to move the ball forward or backward in your stance, which alters the
`height of the ball's trajectory.
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`Strike Meter
`addrEss Controls
`
`Utilize the Strike Meter to dig the ball out of bunkers or to pick the ball cleanly when it’s in the
`rough. Fat or thin hits are not favorable and affect the shot power and ball trajectory. You can
`
`modify where the clubface strikes the ball with the to gain greater control over the height
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`of your shot or to move your club left/right on the ball. New this year, you also need to adjust
`left or right on the Strike Meter to account for sidehill lies. Alter your contact to suit the current
`
`circumstances. Hit under the ball to pop it up high, or hit near the top of the ball for a low shot.
`
`putting
`After you have lined up the putt with , move to draw back the putter and move to
`follow through. Follow the swing meter along the ground to know when to start your follow
`through. The speed of your movement, your aim, and the length of backswing determine the
`outcome of your putt.
`For extra help, press to enable the putt preview feature. It displays the path of the ball
`based on your current setup.
`iMproved chipping
`When your golfer is within chipping range, an arc meter displays along the ground, just as it
`does when putting.
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`GamE sCrEEn
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`PrE-sWInG sCrEEn
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`Scoring
`info
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`Flag
`indicator
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`Club
`selection
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`Wind
`meter
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`Aiming
`point
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`Stance
`Meter
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`3
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`2
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`Scoring
`info
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`Flag
`indicator
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`Aiming
`point
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`Club
`selection
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`Swing arc
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`Swing
`Plane
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`kinect®
`tarGEt Zoom
`Tiger Woods PGA TOUR 14 includes Kinect support throughout the entire gameplay experience.
`To use Kinect controls, choose the Xbox 360 Kinect Sensor option at the control select screen,
`which appears before you enter an event. When using Kinect, follow the on-screen guides to
`navigate menus, zoom to a target, address the ball, and swing. You can also use certain voice
`commands for in-game actions, such as setting up your shot.
`
`Wind
`meter
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`addrEss Ball
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`Distance
`numbers
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`Stance
`Meter
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`Wind
`meter
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`Aiming
`point
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`Strike
`Meter
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`navigate MenuS
`Raise and lower your right hand to move through menu options. To select a highlighted option,
`swipe your right hand. To cancel or return to a previous menu, swipe your left hand.
`ZooM to target
`To zoom in on your target, hold your left hand above your eyes. While zoomed in, hold your
`right hand in a fist out in front of you to being the aiming process, and move your fist to adjust
`your target. Open your right hand when you are finished positioning your target. Hold your left
`hand above your eyes again to return to your pre-swing stance.
`addreSS the Ball
`Face the Xbox 360 Kinect Sensor and put your hands together like you’re holding a golf club.
`You can also crouch to view your lie.
`Swing
`While facing the Xbox 360 Kinect Sensor, take a normal backswing and follow-through like
`you’re swinging a golf club. While the ball is in the air, hold out your right hand to add spin.
`voice coMMandS
`Any time you see the microphone icon in the game, speak the words next to it to perform
`that action.
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`4
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`5
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 6 of 282 PageID #: 394
`aSk a pga pro
`savInG and loadInG
`While setting up a shot in Practice Mode, press to access PGA Pro Tips. PGA Pro Tips give
`you recommendations on which golf club to use, your ideal stance, and more for your current
`shot. As you make adjustments, the Pro Tips turn bold to show that your shot aligns with
`their suggestions.
`
`sEttInGs
`gaMeplay SettingS
`Before you step foot on the course, select SETTINGS from the main menu, and then
`GAMEPLAY SETTINGS to adjust the Difficulty Level. You can toggle the Swing Stick to swing
`with or ; the opposite stick is then used to control the Strike Meter. You can also create
`a Custom Difficulty by adjusting Gameplay Settings individually.
`difficulty levelS
`There are five Difficulty Levels: Amateur, Pro, Tour Pro, Tournament, and Simulation. Each
`Difficulty Level gives you a preset combination of the Swing Difficulty, Swing Meter, Ball Spin,
`Putt Preview, Green Grid, Strike Meter, Zoom to Aim, Wind Display, and Shot Shaping settings.
`The higher your difficulty, the more challenging it is to score under par. Adjusting the difficulty
`also modifies the Status Points and Experience Points (XP) multiplier. The more difficult the
`settings, the more you will earn.
`SiMulation difficulty
`The new Simulation Difficulty gives experienced players an immersive challenge. Simulation
`Difficulty sets Swing Difficulty to expert and turns off the Swing Meter, Green Grid, and Zoom to
`Aim. By eliminating these particular HUD features, Simulation Difficulty focuses your attention
`on the green for the most realistic golfing experience possible. You are also required to perform
`fade and draw shots off the tee when swing difficulty is set to Simulation.
`preSentation SettingS
`Presentation Settings give you more control over how you view the green and the way the
`game is presented. Here, you can adjust Aiming Style, Ball Flight Camera (New Broadcast
`Cameras), Switch to Spin, First-Person Camera (when playing with Kinect), Ball Flight Trail,
`Putting Trail, Animations, Auto-Replay, Flag Indicator, Speed Play, and Metric. These settings
`let you play a speedy match with few animations or a more cinematic game that mimics being
`at a real tournament.
`
`Saving
`The autosave feature saves your progress after every hole. When playing the Career mode, use
`the Mid Round Save system to save in the middle of an event. When you access your career
`from the main menu, you can return to the beginning of the last hole you played or restart the
`round. If you’ve finished an event, you can move to the next one.
`origin account (ea)
`Your Origin Account (EA) is associated with your profile. You must be logged into an Origin
`Account (EA) to play online game modes on Xbox® LIVE via an Online Pass. If you choose not
`to log in, you will only be allowed to play offline. You can re-initiate online play at any time by
`connecting to Xbox LIVE, logging into your Origin Account (EA), and enabling your Online Pass.
`iMporting Xp
`Import a golfer profile from Tiger Woods PGA TOUR ® 13 to gain Experience Points (XP) that
`can be assigned to your new golfer. The amount of XP you gain is related to how much XP you
`earned with your imported golfer profile in the previous title.
`
`maIn mEnu
`
`pro Shop
`Within the Pro Shop, you can enter the Course Shop to view downloadable courses and course
`bundles, the Coin Shop to purchase Coin bundles, the Pin Shop to redeem boost Pin Packs, the
`Pin Collection to view your owned Pins, and the Season Ticket Shop to access EA SPORTS™
`Season Ticket and view additional discounts and benefits. You can also select the golfer you
`created to upgrade his or her Skill Attributes using earned Attribute Points.
`In the Pin Shop, use Coins to purchase Pin Packs that give your golfer a boost to attributes,
`equipment, or even the course. You can also review all your acquired Pins in Pin Collection.
`My golferS
`Create new golfers and adjust your golfers’ various skills, swing style, appearance, equipment,
`and more.
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`CarEEr
`
`career
`Begin your golfer’s career or create a new golfer. You can play the PGA TOUR as a male
`golfer or, for the first time ever, create a female golfer who can embark on the path to
`LPGA TOUR supremacy.
`legendS of the MajorS
`Create a golfer and play through the historical rounds of golf’s history. Select to play from the
`very first days of the sport all the way to present day. Only the first event of each era of golf
`history is available at first. More unlock as you progress.
`Quick play
`Play a Quick Tournament against friends or Computer (CPU) opponents, try a Practice Round,
`or browse the game’s New Features. Here, you’ll find host courses from all four Major
`tournaments: the Masters, the U.S. Open Championship, the Open Championship, and the
`PGA Championship.
`Play a weekly featured event against CPU opponents. You can select to edit your settings
`before heading out onto the green.
`connected tournaMentS
`Play tournaments with up to 24 players on Xbox LIVE when signed in with your Online Pass.
`country cluBS
`Search Country Clubs or create a New Country Club. Invite up to 100 golfers and compete in
`more ways than ever. As a Country Club member, you can connect, communicate, compete,
`and compare your statistics and progress against your friends, teammates, and the world.
`Xbox live
`Access online game features, such as online head to head games, after enabling your
`Online Pass.
`SettingS
`Adjust Gameplay Settings, Presentation Settings, Audio Settings, and select songs in
`EA TRAX™.
`ea SportS eXtraS
`Access the Tutorial to learn how to play directly from the legends of golf and USGA Rules to
`learn more about the sport. You can also view the Software Manual and Credits.
`
`progreSSion
`The new PGA TOUR and LPGA TOUR progression changes provide the most realistic golfing pro
`experience yet. Select CAREER and then CREATE GOLFER to begin your golfing career with the
`PGA TOUR for male golfers and LPGA TOUR for female golfers.
`After you create your golfer, select START YOUR CAREER to choose which Amateur
`Championship you want to play. Get a taste of the Majors if you place first, and work your way
`through the new Q-School qualifying rules. After that comes the Web.com Tour. Earn your
`PGA TOUR card and dominate the competition to become Masters champion and the best
`golfer in the world!
`notE: You can swap the standard course on the event calendar with any other course,
`including downloadable ones, in a variety of events.
`StatiSticS & leaderBoardS
`View your golfer’s career statistics, keeping track of the amount of rounds played, performance
`data, and overall ranking. New this year, you can view Season Stats to compare against the
`rest of the field. You can also track your Career Statistics in the Statistics & Leaderboards
`menu option found on the Career Menu.
`golf Bag
`See what equipment is currently in your bag and make adjustments to each club. You can find
`Golf Bag in the My Golfers menu.
`Swing Style
`In the Swing Style menu found in the Career Mode menu or under My Golfers, make adjustments
`to your golfer’s swing by selecting the swing Type, Shape, Trajectory, and Handedness.
`These settings allow you to customize your play style for optimal control. If you favor accuracy
`over distance, you might set your swing type to Control for a more forgiving Mishit Window. If
`you prefer to hit hard, a Power swing type and a Trajectory set to High helps your ball go the
`distance—though keep in mind that the wind affects the ball more when your ball is soaring
`higher in the air. Find the right balance for your golfer, based on your preferred play style.
`My SkillS
`The My Skills screen indicates your golfer’s skill attribute ratings, making it easy to understand
`where your golfer needs to improve the most.
`The bars show your golfer’s base attribute levels in six categories: Power, Accuracy,
`Workability, Spin, Recovery, and Putting. Earning XP in game lets you level up, awarding
`Attribute Points that you can use to increase your player’s attribute ratings.
`
`8
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`Relive the history of the Majors by stepping into the shoes of golfing greats. Read the timeline
`to learn about the legendary moments in golf’s history, then select a tournament to replay it.
`For instance, play as Bobby Jones in the 1873 Open Championship, or scroll toward the end
`of the timeline to play as Zach Johnson in the 2007 Masters. For each tournament, you can
`play to win or legend each challenge with an even better score, unlocking Legend Golfers and
`earning Status Points as you go.
`
`auGusta PraCtICE faCIlIty
`& auGusta natIonal 1934
`(hIstorIC EdItIon only)
`
`Tiger Woods PGA TOUR ® 14: The Masters ® Historic Edition gives you access to the 1934
`remake of the Augusta National golf course and the Augusta Practice Facility. In the
`extras menu, you can also take a walk-through of the 1934 Augusta National course as
`Jim Nantz narrates.
`In the Practice Facility you have full control over the course conditions and can choose from
`Driving Mode, Putting Mode, and Chipping Mode. You can change your target once you’re on
`the green. Utilize the Augusta Practice Facility to earn XP for your golfer.
`
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`eQuipMent
`lEGEnds of thE majors
`Each piece of equipment has special attributes that make it play just like it does in real life.
`Select EQUIPMENT to view your clubs, grips, shafts, and balls. Choose different equipment or
`purchase new equipment, so you’re ready to conquer any course. Every piece of equipment
`has stats that affect your golfer’s attributes.
`clothing
`Dress your golfer in the latest unlocked styles in the Clothing menu. Select from Shirts, Pants,
`Shoes, Gloves, Socks, Headwear, Glasses, and Watches. All items are unlocked by leveling up
`your golfer.
`photo gaMe face
`Take photos of yourself or your friends and create a digital double that plays in
`Tiger Woods PGA TOUR 14. Use any digital camera to take the photos, then upload them
`to the Tiger Woods PGA TOUR 14 website. You may also use your Xbox LIVE Vision to create a
`picture directly on your console. You can generate up to eight different faces to apply to your
`custom golfers.
`
`QuICk Play
`
`Quick Play’s offline modes give you instant access to events, with the option to play with
`friends in tournaments with up to four players.
`Quick tournaMentS
`Select QUICK TOURNAMENTS to compete against CPU opponents or friends in the final round
`of your favorite tournament. Each tournament plays like a real event, such as The Masters at
`Augusta National or the Honda Classic at PGA National.
`Select a Scenario, which sets up a challenge such as entering the tournament tied for the
`lead, trailing, or currently leading the field. With thousands of spectators’ eyes on your golfer,
`compete against a full field to try and win the tournament. This gives you a taste of the heart-
`pounding pressure and passion the pros feel every Sunday, in every round you play.
`practice
`Practice mode gives you a chance to brush up on your golfing skills and earn Status Points.
`Depending on how you want to play and the number of players, select from nine game modes:
`Stroke Play, Match Play, Skins, Bingo Bango Bongo, Stableford, Alternate Shot, Best Ball,
`Four Ball, and Battle Golf.
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`cluB chat SeSSionS
`onlInE
`Enter the game and start a chat session with your club members anywhere at anytime.
`Easily communicate with your members to setup online matches or play in a connected
`ea SportS country cluBS
`tournament together.
`Join a Friend’s Club, Public Club, or create your own Country Club and recruit other gamers.
`online Multiplayer
`As a Country Club member, you can connect, communicate, compete, and compare your
`Find an opponent based on your skill level, check out the latest EA News, set your gameplay
`statistics and progress against your friends, teammates, and the world. Work together to level
`options for the games you host, and visit the Xbox LIVE Marketplace to download exclusive
`up your club with Status Points and climb the leaderboards to become the most prestigious
`Tiger Woods PGA TOUR 14 content.
`Country Club in the world.
`connected tournaMentS
`in-cluB coMpetition
`Players in a Country Club will be ranked weekly and assigned titles based on the amount
`In Live Tournaments, players from across the world compete for top of the leaderboards in
`of Status Points they contributed to the club during the week. The top ranked player will be
`1 Round or 4 Round events.
`crowned Club Champion and earn access to Tournaments against other clubs! Players within
`You can now play simultaneously with up to 24 other players, and watch ball arcs fly through
`the same Country Club can also compete in Head to Head teammate matches and Club Live
`the air as you play. You can also voice chat with anyone playing the tournament or with
`Tournaments, and battle to become the weekly leader in each statistical category.
`members of your Country Club.
`To manage your team or create a Custom Club Live Tournament, visit the EA SPORTS
`During active pro tournaments, the Play the Pros option is available, and players are allowed to
`Country Clubs website.
`compete alongside actual pros.
`coinS & StatuS pointS
`online gaMe ModeS
`Earn Coins faster as part of a Country Club. Coins are awarded at the end of each week based
`Challenge your friends to a round of traditional Stroke Play or face off in Match Play. Additional
`on your performance relative to other club members. The higher your club rank, the better the
`modes include Skins, Best Ball, Four Ball, Alternate Shot, and the 3 Hole Mini-Game.
`Coin bonus.
`SiMultaneouS play
`You can also earn Coins in the all-new Club Loyalty Bonus. The more you play and the more
`your club members play in consecutive days, the bigger Coin bonuses you will earn.
`You don’t have to wait for other golfers to swing before taking your shot. Simultaneous Play
`All earned Status Points also help level up your Country Club and your club rank.
`lets you play quickly, as if you were playing by yourself, while indicating your opponents’ shots
`world coMpetition
`with real-time shot arcs. Each player’s shot arc has its own color.
`Compete with players from around the globe! Country Clubs are ranked by the amount of
`Status Points earned by all members of the team, and members can participate in Head to
`Head Club Matches. At the end of each week, all players are invited to Country Club Tour
`tournaments based on their earned ranking status for the week in their club.
`
`12
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`coinS
`Coins are the in-game currency and are used to purchase Pin Packs and golfer level upgrades.
`Coins can be earned at the end of a round, competing against club members in the weekly
`rankings, and returning each day to receive your Loyalty Bonus reward. Coins can also be
`purchased directly from the Xbox LIVE Marketplace. Your Coin Bank is viewable in the bottom
`right corner of certain menus. You must be connected online to earn Coins.
`pinS
`Enhance your performance with consumable Pins. Each Pin type gives you a special bonus.
`Before each round, you can add up to three Pins on your Bag Tag. Scroll over the Pin type to
`see how many Pins you have left. The bottom left of the screen displays available refills, which
`you can utilize once a Pin has been depleted. To use a refill, press .
`You can spend Coins you've earned or purchased on Pin Packs. Collect them all to earn
`special bonuses.
`golfer and BooSt pinS
`Improve the performance of your golfer and equipment to score better on the course and earn
`more Coins faster. These Pins can also include gameplay aids, such as shot previews and
`improved lies. Collect duplicates to level up and add more uses.
`collectaBle courSe pinS
`Collect all 18 holes of a course to earn the Course Pin for the top right corner of your Bag Tag.
`The Course Pin enhances the attributes of your equipped Pins and increases the number of
`Status Points you can earn on that course.
`refill pinS
`You can collect the same Pin again to refill your uses, or use a Refill Pin to keep your uses full.
`notE: You can level up your Pins to gain stronger bonuses. The first time you gain a Pin from
`a Pin pack, it’s bronze. When you gain that Pin again, it levels up to silver. The third time you
`acquire that Pin, it levels up a final time to gold.
`
`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 10 of 282 PageID #: 398
`lImItEd 90-day Warranty
`notE: Warranty does not apply to digital download products.
`electronic arts limited warranty
`Electronic Arts warrants to the original purchaser of this product that the recording medium on which
`the software program(s) are recorded (the “Recording Medium”) is free from defects in materials and
`workmanship for a period of 90 days from the date of purchase. If the Recording Medium is found to
`be defective within 90 days from the date of purchase, Electronic Arts agrees to replace the Recording
`Medium free of charge upon receipt of the Recording Medium at its service center, postage paid, with
`proof of purchase. This warranty is limited to the Recording Medium containing the software program that
`was originally provided by Electronic Arts. This warranty shall not be applicable and shall be void if, in the
`judgment of Electronic Arts, the defect has arisen through abuse, mistreatment or neglect.
`This limited warranty is in lieu of all other warranties, whether oral or written, express or implied, including
`any warranty of merchantability or fitness for a particular purpose, and no other representation of any
`nature shall be binding on or obligate Electronic Arts. If any such warranties are incapable of exclusion, then
`such warranties applicable to this product, including implied warranties of merchantability and fitness for
`a particular purpose, are limited to the 90-day period described above. In no event will Electronic Arts be
`liable for any special, incidental, or consequential damages resulting from possession, use or malfunction of
`this Electronic Arts product, including damage to property, and to the extent permitted by law, damages for
`personal injury, even if Electronic Arts has been advised of the possibility of such damages. Some states do
`not allow limitation as to how long an implied warranty lasts and/or exclusions or limitation of incidental or
`consequential damages so the above limitations and/or exclusion of liability may not apply to you. In such
`jurisdictions, the Electronic Arts’ liability shall be limited to the fullest extent permitted by law. This warranty
`gives you specific rights. You may also have other rights that vary from state to state.
`returns within the 90-day warranty period
`Please return the product along with (1) a copy of the original sales receipt showing the date of purchase,
`(2) a brief description of the difficulty you are experiencing, and (3) your name, address and phone number
`to the address below and Electronic Arts will mail a replacement Recording Medium to you. If the product
`was damaged through misuse or accident, this 90-day warranty is rendered void and you will need to follow
`the instructions for returns after the 90-day warranty period. We strongly recommend that you send your
`products using a traceable delivery method. Electronic Arts is not responsible for products not in
`its possession.
`ea warranty information
`If the defect in the Recording Medium resulted from abuse, mistreatment or neglect, or if the Recording
`Medium is found to be defective after 90 days from the date of purchase, choose one of the following options
`to receive our replacement instructions:
`Online Warranty Information: http://warrantyinfo.ea.com
`EA Warranty Mailing Address:
`Electronic Arts Customer Warranty, 7700 W Parmer Lane, Building C, Austin, TX 78729-8101
`
`Package Cover Photography: Getty Images
`notice
`Electronic Arts reserves the right to make improvements in the product described in this manual at anytime
`and without notice.
`
`14
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`15
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 11 of 282 PageID #: 399
`nEEd hElP?
`
`The EA Customer Experience team is here to ensure you get the most out of your game—
`anytime, anywhere.
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`16
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 12 of 282 PageID #: 400
`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 12 of 282 PagelD #: 400
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`
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`EXHIBIT 8
`EXHIBIT 8
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 13 of 282 PageID #: 401
`
`Accused Product: FIFA
`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.
`
`“Accused Product” refers to the Nintendo Wii (with respect to FIFA 15 only), PC Windows, PlayStation3, PlayStation4, Xbox One,
`and Xbox 360 versions of FIFA 15 and FIFA 16 (collectively, “FIFA”).
`
`Acceleration Bay contends that the Accused Product infringes at least each of the claims identified below both literally and under
`the doctrine of equivalents.
`
`Playing of the Accused Product is consistent with the below allegations.
`
`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 Accused Product meets the recited claim language because the EA
`software utilized for the FIFA games allows a plurality of users to participate simultaneously in a computer
`network that provides a game environment, including Online Team Play, Online Friendlies, Online Seasons,
`Tournament Mode, and voice over IP (“VoIP”) chat functionalities.
`[https://www.easports.com/fifa/news/2014/fifa-15-pro-clubs-and-other-modes;
`https://www.easports.com/fifa/news/2014/fifa-15-features-info-ps3-and-360]
`
`This is exemplified and described below:
`
`
`
`
`1
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 14 of 282 PageID #: 402
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`https://www.youtube.com/watch?v=QpuNxKs7Gz4.
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`2
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 15 of 282 PageID #: 403
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`https://www.youtube.com/watch?v=ubHikdgQDn4
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`There are various ways for users to join multiplayer games. For example, when FIFA is played online,
`participants are permitted to join a “Club” under the EA Sport Pro Club Championship mode. This mode
`supports the simultaneous participation of up to 22 players in an online game.
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`3
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 16 of 282 PageID #: 404
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 16 of 282 PagelD #: 404
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`4
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 17 of 282 PageID #: 405
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`
`In addition, https://help.ea.com/en/article/losing-connection-to-ea-servers/ identifies the “peer-to-peer
`connection, or a connection between [one player] and one or more other players” utilized by EA games to
`connect player participants:
`
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`5
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 18 of 282 PageID #: 406
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`1-b. each
`participant
`having
`connections to
`at least three
`neighbor
`participants,
`
`
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`
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`Players in a multiplayer mode may connect and communicate with other players through VoIP.
`The Accused Product meets the recited claim language because each participant has connections to at least three
`neighbor participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because each user
`playing the game can be connected to at least three neighbor users playing the game via peer-to-peer technology
`at the network and/or logical layers when the soccer game is played online in one of the multiplayer modes
`identified above.
`
`The below descriptions regarding functionalities of Electronic Arts games identify “peer-to-peer connection with
`fellow players” for the FIFA franchise:
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`6
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 19 of 282 PageID #: 407
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`http://www.fifauteam.com/connection-problems-fifa-16/
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`http://help.ea.com/au/article/transactions-and-matches-that-did-not-finish/;
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`http://help.ea.com/en/article/losing-connection-to-ea-servers/;
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`7
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`Case 1:16-cv-00454-RGA Document 1-3 Filed 06/17/16 Page 20 of 282 PageID #: 408
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`http://www.easports.com/eaforum/posts/list/840/8379038.page;
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`http://www.fifauteam.com/connection-problems-fifa-16/.