Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 1 of 176 PageID #: 389
`Case 1:16-cv-00455-RGA Document1-3 Filed 06/17/16 Page 1 of 176 PagelD #: 389
`
`
`
`EXHIBIT 7
`EXHIBIT 7
`
`
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 2 of 176 PageID #: 390
`
`Accused Product: Grand Theft Auto Five/Grand Theft Auto Online
`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 PC Windows, Xbox One, Xbox 360, PS3 and PS4 versions of Grand Theft Auto Five, including its
`online mode Grand Theft Auto Online (together, “GTA-V”).
`
`Acceleration Bay contends that the Accused Product infringes at least each of the claims identified below 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 Accused Product meets the recited claim language because the Multiplayer
`modes of GTA-V, as a computer network for providing a game environment, support 16 players on Xbox 360 and
`PS3 and 30 players (with 2 extra spaces for viewers) on Xbox One, PS4 and PC).
`http://www.rockstargames.com/V/GTAOnline; http://gta.wikia.com/Grand_Theft_Auto_Online; also see
`http://gta.wikia.com/Grand_Theft_Auto_V
`
`This recited claim language is also met because in GTA-V, players may travel around and interact with other
`players and the map/environment at will and can take part in many gameplay activities, including assaults on local
`gangs, robbing armored trucks, and challenging other players to impromptu races.
`http://gta.wikia.com/Grand_Theft_Auto_Online. Examples of these infringing game modes include without
`limitation Voice Chat; multiplayer Jobs, use of Social Club and Crews to join and organize multiplayer jobs, Heists,
`Races (such as lap race, point to point, GTA Race, rally race), Capture (contend, GTA, hold, raid), Last Team
`Standing, Mission, Versus Mission, Survival, Parachuting, Team Death-match, Come Out to Play, Hasta la Vista
`and Siege Mentality.
`
`For example and without limitation, Rockstar Games Social Club is a digital rights management, multiplayer and
`
`1
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 3 of 176 PageID #: 391
`
`communications service provided by Rockstar Games for use with their latest generation of games, including GTA-
`V. http://en.wikipedia.org/wiki/Rockstar_Games_Social_Club. When consumers purchase the Accused Product,
`they gain full access to Social Club features in-game and on the website. http://socialclub.rockstargames.com/about.
`Consumers, however, will need to log in to www.rockstargames.com/socialclub with a registered and activated
`Social Club account together with their Social Club account linked with their PLAYSTATION®Network Sign-In
`ID, Xbox LIVE® Gamertag, or Games for Windows LIVE® Gamertag. Id.
`
`2
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 4 of 176 PageID #: 392
`
`http://socialclub.rockstargames.com/about
`
`3
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 5 of 176 PageID #: 393
`
`
`For example and without limitation, Rockstar utilizes the same servers used for Rockstar Games Social Club to
`provide GTA-V’s multiplayer modes. http://www.idigitaltimes.com/gta-v-online-details-700-multiplayer-missions-
`confirmed-rockstar-exec-report-362495 (Rockstar’s executive Leslie Benzies stating: “We’ll use the Rockstar Social
`Club servers to create our ‘cloud,’ which control everything. We have servers spread across several of our offices,
`like New York or San Diego, who are responsible for managing information generated persistent GTA online. How
`driving is, however, different from other similar games less problematic. But yes, it is a traditional server based on
`the ‘cloud’.”). This system involving the Rockstar Social Club servers and the “cloud” is a hybrid peer-to-peer
`system where participants of the system, either the numerous Rockstar Social Club servers or players of the Accused
`
`
`
`4
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 6 of 176 PageID #: 394
`
`Product, are connected in an infringing manner.
`
`As a further example and without limitation, the Accused Product implements the Rockstar Social Club's crew
`system with two types of crews. http://gta.wikia.com/Grand_Theft_Auto_Online. Private crews are mainly aimed
`at a group of friends or associates to play online together and can hold as many as 1,000 people. Id. Public crews
`are much larger and can have unlimited members. Id. Crews consist of a group of players that can battle against
`other crews and even form alliances with them. http://gta.wikia.com/Crews (see below). The Accused Product
`allows characters to band together in a Crew and assist one another in criminal activities. Id.
`
`Crew also allows players to engage in Jobs with the assistance of other Crew Members. Crews can also join
`together to play sports, compete in races and simply hang out. http://www.ign.com/wikis/gta-5/GTA_Online;
`http://www.ign.com/wikis/gta-5/Hanging_Out
`
`As a further example and without limitation, Team Death Matches in the Accused Product offers players the
`opportunity to compete against 16 players in high intensity shootouts. http://www.ign.com/wikis/gta-
`5/Deathmatches.
`
`
`
`5
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 7 of 176 PageID #: 395
`
`https://www.youtube.com/watch?v=_wXW5V3tjdI
`
`
`
`6
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 8 of 176 PageID #: 396
`
`https://www.youtube.com/watch?v=gJ-6UA-59Js
`
`
`
`7
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`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 9 of 176 PageID #: 397
`
`https://www.youtube.com/watch?v=v1U_nZuq2rsine (GTA-
`The Accused Product meets the recited claim language because it provides a computer network of which each
`participant has connections to at least three neighbor participants.
`
`The following confirm that GTA-V uses direct peer-to-peer connections between participants and multiple neighbor
`participants to exchange gameplay data:
`
`
`
`
`1-b. each
`participant
`having
`connections to
`at least three
`neighbor
`participants,
`
`8
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 10 of 176 PageID #: 398
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`Case 1:16-cv-00455-RGA Document1-3 Filed 06/17/16 Page 10 of 176 PagelD #: 398
`
`
`
`
`
`- Port 4500 (UDP) Please also see the [Additional Ports to Forward for GTA Online] section below.
`
`If you have moderate or strict NAT, the problem you describe is most likely caused by a conflict with another
`player using an incompatible NAT type. Microsoft recommends an open NAT type to connect with players as
`easily as possible. If you have a firewall or network hardware, such as a router, you might need to make a
`configuration change in order to obtain an open NAT. This configuration change is sometimes called “opening
`ports” or "port forwarding.” For help, see:
`
`° Your NAT type will be under the “Current Network Status” column in the center of this page:
`
`The NAT types can be one of the following:
`
`= OPEN: Can play games with any other NAT type.
`- MODERATE: Can play games with open or moderate NAT types.
`: STRICT: Can only play against open NAT types.
`
`http2//supportxbox.com/en-US/xbox-live/connecting/nat-error-solution
`http://support.xbox.com/en-US/xbox-live/connecting/network-ports-used-xbox-live
`
`*box Live requires the following ports to be open:
`
`- Port 88 (UDP)
`- Port 3074 (UDP and TCP)
`
`- Port 53 (UDP and TCP)
`- Port 80 (TCP)
`+ Port 500 (UDP)
`- Port 3544 (UDP)
`
`
`
`9
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 11 of 176 PageID #: 399
`
`
`https://support.rockstargames.com/hc/en-us/articles/200525767
`
`Rockstar Support has also indicated by Twitter that GTA-V uses peer-to-peer connections to connect participants:
`
`
`
`10
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 12 of 176 PageID #: 400
`
`
`
`https://twitter.com/RockstarSupport/status/206974346923737088
`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 Accused Product meets the recited claim language because gameplay data,
`such as inputs from participants, are distributed to neighbor participants using direct peer-to-peer connections which
`allow each participant to send data to the other participants by sending the data through its connections to 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
`
`11
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 13 of 176 PageID #: 401
`
`Case 1:16-cv-00455-RGA Document1-3 Filed 06/17/16 Page 13 of 176 PagelD #: 401
`
`° Your NAT type will be under the “Current Network Status” column in the center of this page:
`
`
`
`- Port 4500 (UDP) Please also see the [Additional Ports to Forward for GTA Online] section below.
`
`If you have moderate or strict NAT, the problem you describe is most likely caused by a conflict with another
`player using an incompatible NAT type. Microsoft recommends an open NAT type to connect with players as
`easily as possible. If you have a firewall or network hardware, such as a router, you might need to make a
`configuration change in order to obtain an open NAT. This configuration change is sometimes called “opening
`ports” or "port forwarding.” For help, see:
`
`The NAT types can be one of the following:
`
`= OPEN: Can play games with any other NAT type.
`- MODERATE: Can play games with open or moderate NAT types.
`: STRICT: Can only play against open NAT types.
`
`http2//supportxbox.com/en-US/xbox-live/connecting/nat-error-solution
`http://support.xbox.com/en-US/xbox-live/connecting/network-ports-used-xbox-live
`
`*box Live requires the following ports to be open:
`
`- Port 88 (UDP)
`- Port 3074 (UDP and TCP)
`
`- Port 53 (UDP and TCP)
`- Port 80 (TCP)
`+ Port 500 (UDP)
`- Port 3544 (UDP)
`
`
`
`12
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 14 of 176 PageID #: 402
`
`
`
`
`https://support.rockstargames.com/hc/en-us/articles/200525767
`
`
`
`13
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 15 of 176 PageID #: 403
`
`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 participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because the
`Accused Product utilizes peer-to-peer topologies where participants forward data from one neighbor
`participant to other neighbor participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because
`gameplay data, such as inputs from participants, are distributed to neighbor participants.
`
`1-d. wherein
`each
`participant
`sends data that
`it receives
`from a
`neighbor
`participant to
`its other
`neighbor
`participants,
`
`14
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 16 of 176 PageID #: 404
`
`
`https://support.rockstargames.com/hc/en-us/articles/200525767
`
`
`
`15
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 17 of 176 PageID #: 405
`
`1-e. further
`wherein the
`network is m-
`regular, where
`m is the exact
`number of
`neighbor
`participants of
`each
`participant
`and
`
`1-f. further
`wherein the
`number of
`participants is
`at least two
`greater than m
`thus resulting
`
`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 participants of each participant.
`
`For example and without limitation, the Accused Product creates m-regular game sessions with multiple players
`during different network gaming states and for different game 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 through a communication channel and can utilize different connections,
`such as sockets and tunnels. For example, the Accused Product creates m-regular topologies of players when setting
`up logical and physical network topologies for the Accused Product using different networking frameworks, SDKs
`and APIs. The frameworks, SDKs and APIs utilized by the Accused Product to create these m-regular topologies
`include internally developed frameworks, SDKs and APIs and those related to voice over IP (“VOIP”). They also
`include the ability to set the maximum number of peers and players. The Accused Product uses these frameworks,
`SDKs and APIs to:
`
`
` connect players to other players for matchmaking in a game session;
` determine which game a player should be matched to;
` ensure no players are overloaded for optimal gameplay and bandwidth;
` create logical and physical network topologies for the game;
` create network connections through tunnels, sockets and ports;
` manage the game session during gameplay;
`
`route game data using optimal paths and relays;
` distribute VoIP chat data among the players; and
` manage states when players leave, are kicked, or are disconnected from a game session.
`
`
`In addition, 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 are 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 but not limitation, the Accused Product creates a non-complete graph 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
`
`16
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 18 of 176 PageID #: 406
`
`in a non-
`complete
`graph.
`
`
`
`frameworks, SDKs and APIs utilized by the Accused Product. The frameworks, SDKs and APIs utilized by the
`Accused Product to create these non-complete graphs include internally developed frameworks, SDKs and APIs and
`APIs related to VOIP. The Accused Product utilizes topologies that naturally include a non-complete graph, 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 more than four players are connected.
`
`
`
`
`
`17
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 19 of 176 PageID #: 407
`
`Accused Product: Grand Theft Auto Five/Grand Theft Auto Online
`6,829,634
`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 PC Windows, Xbox One, Xbox 360, PS3 and PS4 versions of Grand Theft Auto Five, including its
`online mode Grand Theft Auto Online (together, “GTA-V”).
`
`Acceleration Bay contends that the Accused Product infringes at least each of the claims identified below both literally and under the
`doctrine of equivalents.
`
`Gameplay of the Accused Products 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 that supports a plurality of participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because the Accused
`Product utilizes peer-to-peer topologies where participants can forward data from one neighbor participant to other
`neighbor participants.
`
`For example and without limitation, the Accused Product includes functionality for establishing a non-routing table
`based computer network for different multi-player game sessions.
`
`For example and without limitation, the Accused Product meets the recited claim language because the Multiplayer
`modes of GTA-V support 16 players on Xbox 360 and PS3 and 30 players (with 2 extra spaces for viewers) on
`Xbox One, PS4 and PC). http://www.rockstargames.com/V/GTAOnline;
`http://gta.wikia.com/Grand_Theft_Auto_Online; also see http://gta.wikia.com/Grand_Theft_Auto_V
`
`This recited claim language is also met because in GTA-V, players may travel around and interact with other
`players and the map/environment at will and can take part in many gameplay activities, including assaults on local
`gangs, robbing armored trucks, and challenging other players to impromptu races.
`
`18
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 20 of 176 PageID #: 408
`
`http://gta.wikia.com/Grand_Theft_Auto_Online. Examples of these infringing game modes include without
`limitation Voice Chat; multiplayer Jobs, use of Social Club and Crews to join and organize multiplayer jobs, Heists,
`Races (such as lap race, point to point, GTA Race, rally race), Capture (contend, GTA, hold, raid), Last Team
`Standing, Mission, Versus Mission, Survival, Parachuting, Team Death-match, Come Out to Play, Hasta la Vista
`and Siege Mentality.
`
`For example and without limitation, Rockstar Games Social Club is a digital rights management, multiplayer and
`communications service provided by Rockstar Games for use with their latest generation of games, including GTA-
`V. http://en.wikipedia.org/wiki/Rockstar_Games_Social_Club. When consumers purchase the Accused Product,
`they gain full access to Social Club features in-game and on the website. http://socialclub.rockstargames.com/about.
`Consumers, however, will need to log in to www.rockstargames.com/socialclub with a registered and activated
`Social Club account together with their Social Club account linked with their PLAYSTATION®Network Sign-In
`ID, Xbox LIVE® Gamertag, or Games for Windows LIVE® Gamertag. Id.
`
`For example and without limitation, Rockstar utilizes the same servers used for Rockstar Games Social Club to
`provide GTA-V’s multiplayer modes. http://www.idigitaltimes.com/gta-v-online-details-700-multiplayer-missions-
`confirmed-rockstar-exec-report-362495 (Rockstar’s executive Leslie Benzies stating: “We’ll use the Rockstar Social
`Club servers to create our ‘cloud,’ which control everything. We have servers spread across several of our offices,
`like New York or San Diego, who are responsible for managing information generated persistent GTA online. How
`driving is, however, different from other similar games less problematic. But yes, it is a traditional server based on
`the ‘cloud’.”). This system involving the Rockstar Social Club servers and the “cloud” is a hybrid peer-to-peer
`system where participants of the system, either the numerous Rockstar Social Club servers or players of the Accused
`Product, are connected in an infringing manner.
`
`As a further example and without limitation, the Accused Product implements the Rockstar Social Club's crew
`system with two types of crews. http://gta.wikia.com/Grand_Theft_Auto_Online. Private crews are mainly aimed
`at a group of friends or associates to play online together and can hold as many as 1,000 people. Id. Public crews
`are much larger and can have unlimited members. Id. Crews consist of a group of players that can battle against
`other crews and even form alliances with them. http://gta.wikia.com/Crews (see below). The Accused Product
`allows characters to band together in a Crew and assist one another in criminal activities. Id.
`
`Crew also allows players to engage in Jobs with the assistance of other Crew Members. Crews can also join
`together to play sports, compete in races and simply hang out. http://www.ign.com/wikis/gta-5/GTA_Online;
`
`19
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 21 of 176 PageID #: 409
`
`http://www.ign.com/wikis/gta-5/Hanging_Out
`
`As a further example and without limitation, Team Death Matches in the Accused Product offers players the
`opportunity to compete against 16 players in high intensity shootouts. http://www.ign.com/wikis/gta-
`5/Deathmatches.
`
`
`
`As a further example and without limitation, the Accused Product’s Come Out to Play mode allows multiple online
`players to play against each other by choosing either a team of Hunters or Runners.
`http://www.rockstargames.com/newswire/article/52397/adversary-modes-daily-objectives-and-more-new-updates-
`also
`
`As a further example and without limitation, the Accused Product’s Siege Mentality mode allows four players to
`fight to survive against six other players. http://www.rockstargames.com/newswire/article/52397/adversary-modes-
`daily-objectives-and-more-new-updates-also.
`
`
`
`20
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 22 of 176 PageID #: 410
`
`
`As a further example and without limitation, the Accused Product’s Hasta La Vista mode allows multiple players to
`play against each other by choosing either a team of Truckers or a team of Cyclists.
`http://www.rockstargames.com/newswire/article/52397/adversary-modes-daily-objectives-and-more-new-updates-
`also.
`
`
`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 participant
`of the gameplay can be connected to at least three neighbor 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.
`
`The following confirm that GTA-V uses direct peer-to-peer connections between participants and multiple neighbor
`participants to exchange gameplay data:
`
`
`1-b. each
`participant
`having
`connections to
`at least three
`neighbor
`participants,
`
`21
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 23 of 176 PageID #: 411
`
`Case 1:16-cv-00455-RGA Document1-3 Filed 06/17/16 Page 23 of 176 PagelD #: 411
`
`° Your NAT type will be under the “Current Network Status” column in the center of this page:
`
`
`
`- Port 4500 (UDP) Please also see the [Additional Ports to Forward for GTA Online] section below.
`
`If you have moderate or strict NAT, the problem you describe is most likely caused by a conflict with another
`player using an incompatible NAT type. Microsoft recommends an open NAT type to connect with players as
`easily as possible. If you have a firewall or network hardware, such as a router, you might need to make a
`configuration change in order to obtain an open NAT. This configuration change is sometimes called “opening
`ports” or "port forwarding.” For help, see:
`
`The NAT types can be one of the following:
`
`= OPEN: Can play games with any other NAT type.
`- MODERATE: Can play games with open or moderate NAT types.
`: STRICT: Can only play against open NAT types.
`
`http2//supportxbox.com/en-US/xbox-live/connecting/nat-error-solution
`http://support.xbox.com/en-US/xbox-live/connecting/network-ports-used-xbox-live
`
`*box Live requires the following ports to be open:
`
`- Port 88 (UDP)
`- Port 3074 (UDP and TCP)
`
`- Port 53 (UDP and TCP)
`- Port 80 (TCP)
`+ Port 500 (UDP)
`- Port 3544 (UDP)
`
`
`
`22
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 24 of 176 PageID #: 412
`
`
`https://support.rockstargames.com/hc/en-us/articles/200525767
`
`Rockstar Support has also indicated by Twitter that GTA-V uses peer-to-peer connections to connect participants:
`
`
`
`23
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 25 of 176 PageID #: 413
`
`
`
`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,
`
`https://twitter.com/RockstarSupport/status/206974346923737088
`The Accused Product meets the recited claim language because 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 participants, are distributed to neighbor participants.
`
`For example and without limitation, the Accused Product meets the recited claim language because the Accused
`Product utilizes peer-to-peer topologies where participants forward data from one neighbor participant to other
`neighbor participants.
`
`The following confirms that GTA-V uses direct peer-to-peer connections between participants and multiple
`neighbor participants to exchange gameplay data:
`
`
`24
`
`

`

`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 26 of 176 PageID #: 414
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`Case 1:16-cv-00455-RGA Document1-3 Filed 06/17/16 Page 26 of 176 PagelD #: 414
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`° Your NAT type will be under the “Current Network Status” column in the center of this page:
`
`
`
`- Port 4500 (UDP) Please also see the [Additional Ports to Forward for GTA Online] section below.
`
`If you have moderate or strict NAT, the problem you describe is most likely caused by a conflict with another
`player using an incompatible NAT type. Microsoft recommends an open NAT type to connect with players as
`easily as possible. If you have a firewall or network hardware, such as a router, you might need to make a
`configuration change in order to obtain an open NAT. This configuration change is sometimes called “opening
`ports” or "port forwarding.” For help, see:
`
`The NAT types can be one of the following:
`
`= OPEN: Can play games with any other NAT type.
`- MODERATE: Can play games with open or moderate NAT types.
`: STRICT: Can only play against open NAT types.
`
`http2//supportxbox.com/en-US/xbox-live/connecting/nat-error-solution
`http://support.xbox.com/en-US/xbox-live/connecting/network-ports-used-xbox-live
`
`*box Live requires the following ports to be open:
`
`- Port 88 (UDP)
`- Port 3074 (UDP and TCP)
`
`- Port 53 (UDP and TCP)
`- Port 80 (TCP)
`+ Port 500 (UDP)
`- Port 3544 (UDP)
`
`
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`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 27 of 176 PageID #: 415
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`
`https://support.rockstargames.com/hc/en-us/articles/200525767
`
`Rockstar Support has also indicated by Twitter that GTA-V uses peer-to-peer connections to connect participants:
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`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 28 of 176 PageID #: 416
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`
`
`https://twitter.com/RockstarSupport/status/206974346923737088
`The Accused Product meets the recited claim language because 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 topologies where participants forward data from one neighbor participant to other
`neighbor participants, as set forth above.
`
`
`The Accused Product meets the recited claim language because data are sequentially numbered in order to queue
`and rearrange data received out of order.
`
`For example and without limitation, gameplay messages are numbered so that they can be arranged if received out
`of order.
`
`For example and without limitation, TCP provides functionality so that messages transmitted over the Internet that
`are received out of order can be queued and rearranged. https://en.wikipedia.org/wiki/Out-of-order_delivery
`
`1-d. wherein
`each
`participant
`sends data that
`it receives
`from a
`neighbor
`participant to
`its other
`neighbor
`participants,
`1-e. wherein
`data is
`numbered
`sequentially
`so that data
`received out
`of order can
`be queued and
`rearranged,
`
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`1-f. further
`wherein the
`network is m-
`regular and m-
`connected,
`where m is the
`number of
`neighbor
`participants of
`each
`participant,
`and
`
`The Accused Product meets the recited claim language because the network is m-regular and m-connected, where m
`is the number of neighbor participants of each participant.
`
`For example and without limitation, the Accused Product creates m-regular game sessions with multiple players
`during different network gaming states and for different game 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 through a communication channel and can utilize different connections,
`such as sockets and tunnels. For example, the Accused Product creates m-regular topologies of players when setting
`up logical and physical network topologies for the Accused Product using different networking frameworks, SDKs
`and APIs. The frameworks, SDKs and APIs utilized by the Accused Product to create these m-regular topologies
`include internally developed frameworks, SDKs and APIs, such as the Rage framework and those related to VOIP.
`They also include the ability to set the maximum number of peers and players. The Accused Product uses these
`frameworks, SDKs and APIs to:
`
`
` connect players to other players for matchmaking in a game session;
` determine which game a player should be matched to;
` ensure no players are overloaded for optimal gameplay and bandwidth;
` create logical and physical network topologies for the game;
` create network connections through tunnels, sockets and ports;
` manage the game session during gameplay;
`
`route game data using optimal paths and relays;
` distribute VoIP chat data among the players; and
` manage states when players leave, are kicked, or are disconnected from a game session.
`
`
`For example and without limitation, the Accused Product utilizes the Rage framework for matchmaking, player
`distribution, and connections to the game session within a multiplayer game. The Rage framework attempts to
`ensure the gameplay and bandwidth are not overloaded so players are evenly distributed on the logical and physical
`networks. In an evenly-distributed multiplayer game, the network of players are m-regular. The Rage framework
`includes setting-up peer-to-peer topologies in different configurations using common components, such as a
`network player manager for managing the players in a session, the connection manager for managing connections
`for sending data between remote peers, and network interface for utilizing the underlying network functionality.
`
`In addition, there are multiple logical and physical layers of the network topology that maintain a regular network in
`
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`Case 1:16-cv-00455-RGA Document 1-3 Filed 06/17/16 Page 30 of 176 PageID #: 418
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`order to optimize performance based on the type of data that are being transmitted. These additional layers of the
`network topology will be identified in upcoming depositions.
`
`For example and without limitation, the Accused Product also creates m-connected game sessions of players during
`different network gaming states, where connections are communication channels made through passing data through
`sockets and tunnels, and where each of the players is optimally connected to other players in the game session,
`without missing connections that would interrupt gameplay or game data. For example, the Accused Product
`creates an m-connected topology o