Zynga Slots (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 Zynga Slots computer program is op-
`erative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Zynga Slots 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,
`Zynga Slots displays the portion to be completed, such as the game image
`displayed at the station, and completes it by selecting and processing da-
`tum from the prestored data, such as game play state, the number of coins
`available, total earnings, or the user’s last win, and placing the resulting in-
`formation, such as the number of coins available to the user, in the portion
`to be completed.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 19
`
`
`
`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 Zynga Slots computer program is op-
`erative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Zynga Slots 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,
`Zynga Slots displays the portion to be completed, such as the game image
`displayed at the station, and completes it by selecting and processing da-
`tum from the prestored data, such as game play state, the number of coins
`available, total earnings, or the user’s last win, and placing the resulting in-
`formation, such as the number of coins available to the user, in the portion
`to be completed.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 19
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`
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`Zynga Slots (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 Zynga Slots to enable the station to
`deliver complete programming as described and shown above. For example,
`with reference to the figures below, Zynga Slots stores a control signal that
`includes an icon that is operative to cause execution of the computer pro-
`gram. Control instructions, which are part of the stored control signal, are
`also included in the computer program, such as the control instruction to
`“SPIN” (highlighted in the second figure below).
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 19
`
`Continued on next page
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 6 of 19
`
`Continued on next page
`
`
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`Zynga Slots (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 Zynga Slots. See
`figure below for an example of the station delivering complete programming.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 7 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 8 of 19
`
`Continued on next page
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`
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`Zynga Slots (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 Zynga Slots as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Zynga Slots 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 infringes Claim 3 by testing and demonstrating Zynga Slots. 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 Zynga Slots. The priority date for
`Claim 3 is September 11, 1987.
`
`Prestored data designates subscriber data in Zynga Slots. Such prestored
`data is used, for example, to maintain continuity between successive playings
`of Zynga Slots. For example, the prestored subscriber data may include game
`play state, the number of coins available, total earnings, or the user’s last
`win. As one example, when access to the Internet on the mobile device is
`disabled, as in the figure below, the subscriber data, such as the number
`of coins available to the user, is still available because it is prestored. The
`number of coins available to the user is available on the device as prestored
`data, as are other subscriber data.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 9 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 10 of 19
`
`Continued on next page
`
`
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`Zynga Slots (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
`Zynga Slots stores subscriber data so that it can be used in a subsequent
`playing of Zynga Slots as prestored data.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 11 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 19
`
`Continued on next page
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`
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`Zynga Slots (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 Zynga Slots as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Zynga Slots 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 Zynga Slots. The
`priority date for Claim 6 is September 11, 1987.
`
`The portion to be completed in Zynga Slots 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 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 13 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 19
`
`Continued on next page
`
`
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`Zynga Slots (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 Zynga Slots as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Zynga Slots 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 infringes Claim 9 by testing and demonstrating Zynga Slots. 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 Zynga Slots. The priority date for
`Claim 9 is September 11, 1987.
`
`A control signal in Zynga Slots causes a controller of the station to control
`a peripheral device, such as a speaker. The control signals set audio settings
`for Zynga Slots, as shown below.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 15 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 16 of 19
`
`Continued on next page
`
`
`
`Zynga Slots (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 Zynga Slots.
`
`Continued on next page
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 17 of 19
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`
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`Zynga Slots (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 19
`
`Continued on next page
`
`
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`Zynga Slots (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 Zynga Slots as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Zynga Slots 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 Zynga Slots. The
`priority date for Claim 11 is September 11, 1987.
`
`Zynga Slots is made available for play on an ultimate receiver station that is
`a storage device, such as a mobile device.
`
`Chart 56 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 19 of 19
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`
`
`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille directly infringes Claim 1 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 1 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 1 by testing and demonstrating ForestVille. 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 re-
`lated documents or testimony for ForestVille. The priority date for Claim 1
`is September 11, 1987.
`
`ForestVille 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, ForestVille 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 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 2 of 20
`
`Continued on next page
`
`
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`ForestVille (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 ForestVille computer program is operative
`to complete the portion to be completed by, for example, accessing prestored
`data. Execution of the ForestVille 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 se-
`lected datum is placed into the portion to be completed, thereby completing
`the programming. For example, upon accessing prestored data, ForestVille
`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 the type of houses or crops selected, or the orienta-
`tion/layout of graphics, and placing the resulting information, such as the
`houses selected by the user, in the portion to be completed.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 20
`
`
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`ForestVille (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 ForestVille to enable the station to
`deliver complete programming as described and shown above. For example,
`with reference to the figures below, ForestVille stores a control signal that
`includes an icon that is operative to cause execution of the computer pro-
`gram. Control instructions, which are part of the stored control signal, are
`also included in the computer program, such as the control instruction to
`“START” (highlighted in the second figure below).
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 6 of 20
`
`Continued on next page
`
`
`
`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`whereby said station of a par-
`ticular kind is enabled to deliver
`complete programming.
`
`The station is enabled to deliver complete programming of ForestVille. See
`figure below for an example of the station delivering complete programming.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 7 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 8 of 20
`
`
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`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille directly infringes Claim 3 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 3 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 3 by testing and demonstrating ForestVille. 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 re-
`lated documents or testimony for ForestVille. The priority date for Claim 3
`is September 11, 1987.
`
`Prestored data designates subscriber data in ForestVille. Such prestored data
`is used, for example, to maintain continuity between successive playings of
`ForestVille. For example, the prestored subscriber data may include the
`type of houses or crops selected, or the orientation/layout of graphics. As
`one example, when access to the Internet on the mobile device is disabled,
`as in the figure below, the subscriber data, such as the game orientation
`or layout, is still available because it is prestored. The game orientation or
`layout is available on the device as prestored data, as are other subscriber
`data.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 9 of 20
`
`
`
`ForestVille (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 subscriber
`data.
`
`ForestVille stores subscriber data so that it can be used in a subsequent
`playing of ForestVille as prestored data.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 10 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 11 of 20
`
`Continued on next page
`
`
`
`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille 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 ForestVille. 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 ForestVille. The priority date for Claim 4
`is September 11, 1987.
`
`ForestVille uses a control signal that comprises a series of sequentially trans-
`mitted control instructions. For example, one transmitted control instruc-
`tion may cause execution to enable delivery of complete programming of
`ForestVille regarding the planting of crops, while a second transmitted con-
`trol instruction may cause execution to enable delivery of complete program-
`ming of ForestVille regarding the harvesting of the planted crops, along with
`the option to speed up the harvesting process. See the examples shown below.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 13 of 20
`
`Continued on next page
`
`
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`ForestVille (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 plant a crop is always transmitted
`before the control instruction to harvest the crop. Further, the control signal
`also includes information designating a time period, such as the time period
`needed to harvest the crop or the time remaining before harvesting can occur.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 20
`
`
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`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 15 of 20
`
`Continued on next page
`
`
`
`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille 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 ForestVille. The priority
`date for Claim 6 is September 11, 1987.
`
`The portion to be completed in ForestVille includes generally applicable in-
`formation. For example, such generally applicable information includes im-
`ages, sounds, or background layouts that are common to many players and
`that are completed by accessing prestored data. See figure below for examples
`of generally applicable information (examples specified with red boxes):
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 16 of 20
`
`
`
`ForestVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 17 of 20
`
`
`
`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille 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 ForestVille. 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 ForestVille. The priority date for Claim 9
`is September 11, 1987.
`
`A control signal in ForestVille causes a controller of the station to control a
`peripheral device, such as a speaker. The control signals set audio settings
`for ForestVille, as shown below.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 18 of 20
`
`
`
`ForestVille (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 ForestVille.
`
`Continued on next page
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 19 of 20
`
`
`
`ForestVille (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 ForestVille as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ForestVille 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 ForestVille. The
`priority date for Claim 11 is September 11, 1987.
`
`ForestVille is made available for play on an ultimate receiver station that is
`a storage device, such as a mobile device.
`
`Chart 61 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 20 of 20
`
`
`
`Gems 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 Gems with Friends as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of Gems 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 Gems 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 Gems with Friends.
`The priority date for Claim 1 is September 11, 1987.
`
`Gems 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, Gems 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 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 1 of 20
`
`
`
`Gems with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 2 of 20
`
`Continued on next page
`
`
`
`Gems 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 Gems with Friends computer program is
`operative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Gems with Friends computer program en-
`ables 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, Gems with Friends displays the portion to be completed, such as the
`game image displayed at the station, and completes it by selecting and pro-
`cessing datum from the prestored data, such as profile names or game scores,
`and placing the resulting information, such as the user’s score, in the portion
`to be completed.
`
`Continued on next page
`
`Chart 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 3 of 20
`
`
`
`Gems 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 Gems with Friends to enable the
`station to deliver complete programming as described and shown above. For
`example, with reference to the figures below, Gems with Friends stores a con-
`trol signal that includes an icon that is operative to cause execution of the
`computer program. Control instructions, which are part of the stored con-
`trol signal, are also included in the computer program, such as the control
`instruction to “Start a Game!” (highlighted in the second figure below).
`
`Continued on next page
`
`Chart 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 4 of 20
`
`
`
`Gems with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 5 of 20
`
`Continued on next page
`
`
`
`Gems with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 63 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 6 of 20
`
`Continued on next page
`
`
`
`Gems with Friends (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 Gems with
`Friends. See figure below for an example of the station delivering complete
`programming.
`
`Con
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