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)
`
`Page 3 of 22
`
`
`
`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)
`
`Page 3 of 22
`
`
`
`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)
`
`Page 4 of 22
`
`
`
`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)
`
`Page 5 of 22
`
`Continued on next page
`
`
`
`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)
`
`Page 6 of 22
`
`Continued on next page
`
`
`
`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
`
`Evidence of Infringement
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 8 of 22
`
`Continued on next page
`
`
`
`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)
`
`Page 9 of 22
`
`
`
`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)
`
`Page 10 of 22
`
`Continued on next page
`
`
`
`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
`
`
`
`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)
`
`Page 12 of 22
`
`Continued on next page
`
`
`
`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-68)
`
`Page 16 of 22
`
`
`
`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)
`
`Page 17 of 22
`
`Continued on next page
`
`
`
`DreamHeights (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 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 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 di-
`rectly infringes Claim 9 by testing and demonstrating DreamHeights. Each
`element in Claim 9 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 9 is September 11, 1987.
`
`A control signal in DreamHeights causes a controller of the station to control
`a peripheral device, such as a speaker. The control signals set audio settings
`for DreamHeights, as shown below.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 18 of 22
`
`
`
`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)
`
`Page 19 of 22
`
`Continued on next page
`
`
`
`DreamHeights (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 DreamHeights.
`
`Continued on next page
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 20 of 22
`
`
`
`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)
`
`Page 21 of 22
`
`Continued on next page
`
`
`
`DreamHeights (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 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 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 DreamHeights. The
`priority date for Claim 11 is September 11, 1987.
`
`DreamHeights is made available for play on an ultimate receiver station that
`is a storage device, such as a mobile device.
`
`Chart 21 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 22 of 22
`
`
`
`Hanging with Friends (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 Hanging with Friends as a “mobile game” to its users playing
`on personal computing devices such as, for example, mobile handheld devices.
`A user of Hanging with Friends 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 infringes Claim 1 by testing and demonstrating Hanging with
`Friends. 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 Hanging with Friends.
`The priority date for Claim 1 is September 11, 1987.
`
`Hanging with Friends 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, Hanging with Friends 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 30 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 1 of 22
`
`
`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 30 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 2 of 22
`
`
`
`Hanging with Friends (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 Hanging with Friends computer program is
`operative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Hanging with Friends 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 completing the programming. For example, upon accessing prestored
`data, Hanging with Friends 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, selected
`avatars, selected balloon colors, or words played, and placing the resulting
`information, such as the selected balloon colors or the word played, in the
`portion to be completed.
`
`Continued on next page
`
`Chart 30 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 3 of 22
`
`
`
`Hanging with Friends (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 Hanging with Friends to enable the
`station to deliver complete programming as described and shown above. For
`example, with reference to the figures below, Hanging with Friends 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 create a game (highlighted in the second figure below).
`
`Continued on next page
`
`Chart 30 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 4 of 22
`
`
`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 30 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 5 of 22
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