IPR2013-00156, No. 1002-2 Exhibit - Zynga Ex 1002 Part 2 of 8 PMC Infringement Contentions (P.T.A.B. Feb. 22, 2013)

Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`4.
`The method of claim 1,
`wherein said control signal com-
`prises a series or stream of se-
`quentially transmitted control
`instructions,
`
`Evidence of Infringement
`Zynga provides Dream Zoo as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Dream Zoo directly infringes Claim 4 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 4 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 4 by testing and demonstrating Dream Zoo. Each element
`in Claim 4 includes a “software limitation” under P.R. 3-1(g). Additional
`evidence of infringement may be supplied as needed in accordance with the
`Local Rules and the Docket Control Order following the production of source
`code, source code documentation, ﬂowcharts, and/or other source code re-
`lated documents or testimony for Dream Zoo. The priority date for Claim 4
`is September 11, 1987.
`
`Dream Zoo uses a control signal that comprises a series of sequentially trans-
`mitted control instructions. For example, one transmitted control instruction
`may cause execution to enable delivery of complete programming of Dream
`Zoo regarding giving birth to a baby Giraﬀe with the option to speed up the
`birthing process, while a second transmitted control instruction may cause
`execution to enable delivery of complete programming of Dream Zoo regard-
`ing congratulations on the birth of the baby Giraﬀe, and the option to tell
`friends about the birth. See the examples shown below.
`
`Continued on next page
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`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 11 of 18
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
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`Continued on next page
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`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 18
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`said method further comprising
`the step of storing in said con-
`trol signal two or more control
`instructions in a speciﬁc order
`with information designating a
`time period.
`
`Evidence of Infringement
`The two control instructions are stored in the order of their occurrence. In
`the ﬁgures below, the control instructions are stored according to a speciﬁc
`order in which the control instruction to speed up the birthing process is
`always transmitted before the control instruction to tell friends about the
`birth. Further, the control signal also includes information designating a
`time period, such as the time period needed for delivery of the baby Giraﬀe
`or the day the baby Giraﬀe was born.
`
`Continued on next page
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`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 13 of 18
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 18
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`Continued on next page
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`6.
`The method of claim 1,
`wherein said portion to be com-
`pleted comprises generally ap-
`plicable information.
`
`Evidence of Infringement
`Zynga provides Dream Zoo as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Dream Zoo directly infringes Claim 6 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 6 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 6 by testing and demonstrating Dream Zoo. The priority
`date for Claim 6 is September 11, 1987.
`
`The portion to be completed in Dream Zoo includes generally applicable
`information. For example, such generally applicable information includes
`images, sounds, or background layouts that are common to many players
`and that are completed by accessing prestored data. See ﬁgure below:
`
`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 15 of 18
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`Continued on next page
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`9.
`The method of claim 1,
`wherein a control signal causes a
`controller operatively connected
`to said storage station to control
`a peripheral device,
`
`Evidence of Infringement
`Zynga provides Dream Zoo as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Dream Zoo directly infringes Claim 9 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 9 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 9 by testing and demonstrating Dream Zoo. Each element
`in Claim 9 includes a “software limitation” under P.R. 3-1(g). Additional
`evidence of infringement may be supplied as needed in accordance with the
`Local Rules and the Docket Control Order following the production of source
`code, source code documentation, ﬂowcharts, and/or other source code re-
`lated documents or testimony for Dream Zoo. The priority date for Claim 9
`is September 11, 1987.
`
`A control signal in Dream Zoo causes a controller of the station to control a
`peripheral device, such as a speaker. The control signals set audio settings
`for Dream Zoo, as shown below.
`
`Continued on next page
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`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 16 of 18
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`said method further comprising
`the step of storing said control
`signal.
`
`As shown below in an image from a subsequent playing of the game, audio
`control signals (including audio settings) are stored to control the speakers
`during play of Dream Zoo.
`
`Continued on next page
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`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 17 of 18
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`

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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`11. The method of claim 1,
`wherein said storage device is an
`ultimate receiver station.
`
`Zynga provides Dream Zoo as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Dream Zoo directly infringes Claim 11 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 11
`by inducing and contributing to the direct infringement of its users. Zynga
`directly infringes Claim 11 by testing and demonstrating Dream Zoo. The
`priority date for Claim 11 is September 11, 1987.
`
`Dream Zoo is made available for play on an ultimate receiver station that is
`a storage device, such as a mobile device.
`
`Chart 17 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 18
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`1. A method of enabling a
`station of a particular kind to
`deliver complete programming,
`said station including a storage
`device, and said method com-
`prising the steps of:
`
`said
`storing programming at
`storage device, said program-
`ming comprising a computer
`program and a portion to be
`completed by accessing pre-
`stored data at said station of a
`particular kind,
`
`Evidence of Infringement
`Zynga provides Drop7 as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of Drop7 directly infringes Claim 1 by performing the method steps on a
`personal computing device. Zynga indirectly infringes Claim 1 by inducing
`and contributing to the direct infringement of its users. Zynga directly in-
`fringes Claim 1 by testing and demonstrating Drop7. Each element in Claim
`1 includes a “software limitation” under P.R. 3-1(g). Additional evidence of
`infringement may be supplied as needed in accordance with the Local Rules
`and the Docket Control Order following the production of source code, source
`code documentation, ﬂowcharts, and/or other source code related documents
`or testimony for Drop7. The priority date for Claim 1 is September 11, 1987.
`
`Drop7 is stored on a storage device and includes a computer program and
`a portion to be completed by accessing prestored data at the station. For
`example, Drop7 accesses prestored data such as game data and game images.
`As shown below, the programming, which is the game viewed and played,
`includes a computer program and a portion to be completed, and is stored
`at the storage device along with prestored data.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 18
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 18
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`Continued on next page
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`wherein said computer program
`is operative to complete said
`portion when executed at said
`station of a particular kind, said
`execution of said computer pro-
`gram enabling a processor at
`said station of a particular kind
`to select a speciﬁc datum from
`said prestored data and place
`information, which results from
`a processing of said selected da-
`tum,
`into said portion to be
`completed, thereby completing
`said programming; and
`
`Evidence of Infringement
`When executed on the station, the Drop7 computer program is operative to
`complete the portion to be completed by, for example, accessing prestored
`data. Execution of the Drop7 computer program enables a processor at the
`station to select a speciﬁc datum from the prestored data. The selected
`datum is processed, and information resulting from the processing of the
`selected datum is placed into the portion to be completed, thereby complet-
`ing the programming. For example, upon accessing prestored data, Drop7
`displays the portion to be completed, such as the game image displayed at
`the station, and completes it by selecting and processing datum from the
`prestored data, such as proﬁle names, game play state, or game scores, and
`placing the resulting information, such as the user’s score, in the portion to
`be completed.
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 18
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`Continued on next page
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`storing a control signal, which is
`operative at at least one partic-
`ular kind of station, said control
`signal operative to cause said
`execution of said computer pro-
`gram,
`
`Evidence of Infringement
`A control signal is operative to cause execution of a computer program in-
`cluded as part of the programming for Drop7 to enable the station to deliver
`complete programming as described and shown above. For example, with
`reference to the ﬁgures below, Drop7 stores a control signal that includes an
`icon that is operative to cause execution of the computer program. Control
`instructions, which are part of the stored control signal, are also included
`in the computer program, such as the control instruction to start a “New
`Game” (highlighted in the second ﬁgure below).
`
`Continued on next page
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`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 18
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`whereby said station of a par-
`ticular kind is enabled to deliver
`complete programming.
`
`Evidence of Infringement
`The station is enabled to deliver complete programming of Drop7. See ﬁgure
`below for an example of the station delivering complete programming.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 7 of 18
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`

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`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`3.
`The method of claim 1,
`wherein said prestored data des-
`ignates subscriber data,
`
`Evidence of Infringement
`Zynga provides Drop7 as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of Drop7 directly infringes Claim 3 by performing the method steps on a
`personal computing device. Zynga indirectly infringes Claim 3 by inducing
`and contributing to the direct infringement of its users. Zynga directly in-
`fringes Claim 3 by testing and demonstrating Drop7. Each element in Claim
`3 includes a “software limitation” under P.R. 3-1(g). Additional evidence of
`infringement may be supplied as needed in accordance with the Local Rules
`and the Docket Control Order following the production of source code, source
`code documentation, ﬂowcharts, and/or other source code related documents
`or testimony for Drop7. The priority date for Claim 3 is September 11, 1987.
`
`Prestored data designates subscriber data in Drop7. Such prestored data
`is used, for example, to maintain continuity between successive playings
`of Drop7. For example, the prestored subscriber data may include proﬁle
`names, game play state, or game scores. As one example, when access to
`the Internet on the mobile device is disabled, as in the ﬁgure below, the sub-
`scriber data, such as the game score, is still available because it is prestored.
`The score is available on the device as prestored data, as are other subscriber
`data.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 9 of 18
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`

`
`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`said method further comprising
`the step of storing subscriber
`data.
`
`Evidence of Infringement
`Drop7 stores subscriber data so that it can be used in a subsequent playing
`of Drop7 as prestored data.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 11 of 18
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`

`
`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`6.
`The method of claim 1,
`wherein said portion to be com-
`pleted comprises generally ap-
`plicable information.
`
`Evidence of Infringement
`Zynga provides Drop7 as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`Drop7 directly infringes Claim 6 by performing the method steps on a per-
`sonal computing device. Zynga indirectly infringes Claim 6 by inducing and
`contributing to the direct infringement of its users. Zynga directly infringes
`Claim 6 by testing and demonstrating Drop7. The priority date for Claim 6
`is September 11, 1987.
`
`The portion to be completed in Drop7 includes generally applicable infor-
`mation. For example, such generally applicable information includes images,
`sounds, or background layouts that are common to many players and that
`are completed by accessing prestored data. See ﬁgure below:
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 13 of 18
`
`Continued on next page
`
`

`
`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`9.
`The method of claim 1,
`wherein a control signal causes a
`controller operatively connected
`to said storage station to control
`a peripheral device,
`
`Evidence of Infringement
`Zynga provides Drop7 as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of Drop7 directly infringes Claim 9 by performing the method steps on a
`personal computing device. Zynga indirectly infringes Claim 9 by inducing
`and contributing to the direct infringement of its users. Zynga directly in-
`fringes Claim 9 by testing and demonstrating Drop7. Each element in Claim
`9 includes a “software limitation” under P.R. 3-1(g). Additional evidence of
`infringement may be supplied as needed in accordance with the Local Rules
`and the Docket Control Order following the production of source code, source
`code documentation, ﬂowcharts, and/or other source code related documents
`or testimony for Drop7. The priority date for Claim 9 is September 11, 1987.
`
`A control signal in Drop7 causes a controller of the station to control a
`peripheral device, such as a speaker. The control signals set audio settings
`for Drop7, as shown below.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 18
`
`

`
`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`said method further comprising
`the step of storing said control
`signal.
`
`Evidence of Infringement
`As shown below in an image from a subsequent playing of the game, audio
`control signals (including audio settings) are stored to control the speakers
`during play of Drop7.
`
`Continued on next page
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 16 of 18
`
`

`
`Drop7 (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`11. The method of claim 1,
`wherein said storage device is an
`ultimate receiver station.
`
`Evidence of Infringement
`Zynga provides Drop7 as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`Drop7 directly infringes Claim 11 by performing the method steps on a per-
`sonal computing device. Zynga indirectly infringes Claim 11 by inducing and
`contributing to the direct infringement of its users. Zynga directly infringes
`Claim 11 by testing and demonstrating Drop7. The priority date for Claim
`11 is September 11, 1987.
`
`Drop7 is made available for play on an ultimate receiver station that is a
`storage device, such as a mobile device.
`
`Chart 20 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 18
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`

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`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`1. A method of enabling a
`station of a particular kind to
`deliver complete programming,
`said station including a storage
`device, and said method com-
`prising the steps of:
`
`said
`storing programming at
`storage device, said program-
`ming comprising a computer
`program and a portion to be
`completed by accessing pre-
`stored data at said station of a
`particular kind,
`
`Evidence of Infringement
`Zynga provides DreamHeights as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of DreamHeights directly infringes Claim 1 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 1 by
`inducing and contributing to the direct infringement of its users. Zynga di-
`rectly infringes Claim 1 by testing and demonstrating DreamHeights. Each
`element in Claim 1 includes a “software limitation” under P.R. 3-1(g). Ad-
`ditional evidence of infringement may be supplied as needed in accordance
`with the Local Rules and the Docket Control Order following the production
`of source code, source code documentation, ﬂowcharts, and/or other source
`code related documents or testimony for DreamHeights. The priority date
`for Claim 1 is September 11, 1987.
`
`DreamHeights is stored on a storage device and includes a computer program
`and a portion to be completed by accessing prestored data at the station.
`For example, DreamHeights accesses prestored data such as game data and
`game images. As shown below, the programming, which is the game viewed
`and played, includes a computer program and a portion to be completed,
`and is stored at the storage device along with prestored data.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 22
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`

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`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 22
`
`Continued on next page
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`wherein said computer program
`is operative to complete said
`portion when executed at said
`station of a particular kind, said
`execution of said computer pro-
`gram enabling a processor at
`said station of a particular kind
`to select a speciﬁc datum from
`said prestored data and place
`information, which results from
`a processing of said selected da-
`tum,
`into said portion to be
`completed, thereby completing
`said programming; and
`
`Evidence of Infringement
`When executed on the station, the DreamHeights computer program is op-
`erative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the DreamHeights computer program enables
`a processor at the station to select a speciﬁc datum from the prestored data.
`The selected datum is processed, and information resulting from the process-
`ing of the selected datum is placed into the portion to be completed, thereby
`completing the programming. For example, upon accessing prestored data,
`DreamHeights displays the portion to be completed, such as the game image
`displayed at the station, and completes it by selecting and processing datum
`from the prestored data, such as user preferences, a coin value, or a dollar
`value, and placing the resulting information, such as the avatar selected by
`the user in their preferences or the dollar value for the user, in the portion
`to be completed.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 22
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`

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`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`storing a control signal, which is
`operative at at least one partic-
`ular kind of station, said control
`signal operative to cause said
`execution of said computer pro-
`gram,
`
`A control signal is operative to cause execution of a computer program in-
`cluded as part of the programming for DreamHeights to enable the station
`to deliver complete programming as described and shown above. For exam-
`ple, with reference to the ﬁgures below, DreamHeights stores a control signal
`that includes an icon that is operative to cause execution of the computer
`program. Control instructions, which are part of the stored control signal,
`are also included in the computer program, such as the control instruction
`to “Build a store” (highlighted in the second ﬁgure below).
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 22
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`whereby said station of a par-
`ticular kind is enabled to deliver
`complete programming.
`
`Evidence of Infringement
`The station is enabled to deliver complete programming of DreamHeights.
`See ﬁgure below for an example of the station delivering complete program-
`ming.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 7 of 22
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`3.
`The method of claim 1,
`wherein said prestored data des-
`ignates subscriber data,
`
`Evidence of Infringement
`Zynga provides DreamHeights as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of DreamHeights directly infringes Claim 3 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 3 by
`inducing and contributing to the direct infringement of its users. Zynga di-
`rectly infringes Claim 3 by testing and demonstrating DreamHeights. Each
`element in Claim 3 includes a “software limitation” under P.R. 3-1(g). Ad-
`ditional evidence of infringement may be supplied as needed in accordance
`with the Local Rules and the Docket Control Order following the production
`of source code, source code documentation, ﬂowcharts, and/or other source
`code related documents or testimony for DreamHeights. The priority date
`for Claim 3 is September 11, 1987.
`
`Prestored data designates subscriber data in DreamHeights. Such prestored
`data is used, for example, to maintain continuity between successive playings
`of DreamHeights. For example, the prestored subscriber data may include
`user preferences, a coin value, or a dollar value. As an example, the subscriber
`data, such as the avatar selected by the user in their preferences or the
`dollar value remaining, is available throughout game play as is shown in the
`ﬁgure below. When access to the Internet on the mobile device is disabled,
`as in the ﬁgure below, the subscriber data, still the subscriber’s selected
`avatar or dollar value remaining, is still available because it is prestored.
`The subscriber’s data is available on the device as prestored data, as are
`other subscriber data.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 9 of 22
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`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`said method further comprising
`the step of storing subscriber
`data.
`
`Evidence of Infringement
`DreamHeights stores subscriber data so that it can be used in a subsequent
`playing of DreamHeights as prestored data.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 11 of 22
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`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`4.
`The method of claim 1,
`wherein said control signal com-
`prises a series or stream of se-
`quentially transmitted control
`instructions,
`
`Evidence of Infringement
`Zynga provides DreamHeights as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of DreamHeights directly infringes Claim 4 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 4 by
`inducing and contributing to the direct infringement of its users. Zynga di-
`rectly infringes Claim 4 by testing and demonstrating DreamHeights. Each
`element in Claim 4 includes a “software limitation” under P.R. 3-1(g). Ad-
`ditional evidence of infringement may be supplied as needed in accordance
`with the Local Rules and the Docket Control Order following the production
`of source code, source code documentation, ﬂowcharts, and/or other source
`code related documents or testimony for DreamHeights. The priority date
`for Claim 4 is September 11, 1987.
`
`DreamHeights uses a control signal that comprises a series of sequentially
`transmitted control instructions. For example, one transmitted control in-
`struction may cause execution to enable delivery of complete programming
`for a ﬁrst player or a ﬁrst turn, while a second transmitted control instruc-
`tion may cause execution to enable delivery of complete programming for a
`second player or a second turn. See the examples shown below.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 13 of 22
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`said method further comprising
`the step of storing in said con-
`trol signal two or more control
`instructions in a speciﬁc order
`with information designating a
`time period.
`
`The two control instructions are stored in the order of their occurrence or
`by order of player. In the ﬁgures below, the control instructions are stored
`according to a speciﬁc order in which the ﬁrst control instruction to initi-
`ate the speeding up of the construction of the store is always transmitted
`before the second control instruction to conﬁrm the option to speed up the
`construction of the store. Further, the control instructions also include infor-
`mation designating a time period, such as the time period remaining before
`the construction of the store is completed.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 14 of 22
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`The method of claim 1,
`6.
`wherein said portion to be com-
`pleted comprises generally ap-
`plicable information.
`
`Zynga provides DreamHeights as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of DreamHeights directly infringes Claim 6 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 6 by
`inducing and contributing to the direct infringement of its users. Zynga
`directly infringes Claim 6 by testing and demonstrating DreamHeights. The
`priority date for Claim 6 is September 11, 1987.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 15 of 22
`
`

`
`DreamHeights (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`The portion to be completed in DreamHeights includes generally applicable
`information. For example, such generally applicable information includes
`images, sounds, or background layouts that are common to many players
`and that are completed by accessing prestored data. See ﬁgure below:
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-6

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