Horn (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`The method of claim 1,
`3.
`wherein said prestored data des-
`ignates subscriber data,
`
`Zynga provides Horn as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of Horn 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 Horn. 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 Horn. The priority date for Claim 3 is September 11, 1987.
`
`Continued on next page
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 8 of 13
`
`
`
`Claim Language
`
`Evidence of Infringement
`
`The method of claim 1,
`3.
`wherein said prestored data des-
`ignates subscriber data,
`
`Zynga provides Horn as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of Horn 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 Horn. 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 Horn. The priority date for Claim 3 is September 11, 1987.
`
`Continued on next page
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 8 of 13
`
`
`
`Horn (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`Prestored data designates subscriber data in Horn. Such prestored data
`is used, for example, to maintain continuity between successive playings of
`Horn. For example, the prestored subscriber data may include game play
`state, statistics, or user preferences. 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 statistics or game play state properties, is still available
`because it is prestored. The statistics and game play state properties are
`available on the device as prestored data, as are other subscriber data.
`
`Continued on next page
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 9 of 13
`
`
`
`Horn (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.
`
`Horn stores subscriber data so that it can be used in a subsequent playing of
`Horn as prestored data.
`
`Continued on next page
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 10 of 13
`
`
`
`Horn (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 11 of 13
`
`Continued on next page
`
`
`
`Horn (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 Horn as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`Horn 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 Horn. The priority date for Claim 6
`is September 11, 1987.
`
`The portion to be completed in Horn includes generally applicable informa-
`tion. 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 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 12 of 13
`
`
`
`Horn (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 Horn as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`Horn 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 Horn. The priority date for Claim
`11 is September 11, 1987.
`
`Horn is made available for play on an ultimate receiver station that is a
`storage device, such as a mobile device.
`
`Chart 79 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 13 of 13
`
`
`
`Dream PetHouse (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 Dream PetHouse as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices. A
`user of Dream PetHouse 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 Dream PetHouse.
`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 Dream PetHouse. The priority date
`for Claim 1 is September 11, 1987.
`
`Dream PetHouse is stored on a storage device and includes a computer pro-
`gram and a portion to be completed by accessing prestored data at the sta-
`tion. For example, Dream PetHouse 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 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 1 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 2 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 Dream PetHouse computer program is
`operative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Dream PetHouse 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,
`Dream PetHouse 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
`seed value, and placing the resulting information, such as the pets selected
`by the user or the seed value for the user, in the portion to be completed.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 3 of 22
`
`
`
`Dream PetHouse (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 Dream PetHouse to enable the station
`to deliver complete programming as described and shown above. For exam-
`ple, with reference to the figures below, Dream PetHouse stores a control
`signal that includes an icon that is operative to cause execution of the com-
`puter program. Control instructions, which are part of the stored control
`signal, are also included in the computer program, such as the control in-
`struction to “Start” (highlighted in the second figure below).
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 4 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 5 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 6 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 Dream PetHouse.
`See figure below for an example of the station delivering complete program-
`ming.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 7 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 8 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 Dream PetHouse as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices. A
`user of Dream PetHouse 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 Dream PetHouse.
`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 Dream PetHouse. The priority date
`for Claim 3 is September 11, 1987.
`
`Prestored data designates subscriber data in Dream PetHouse. Such pre-
`stored data is used, for example, to maintain continuity between successive
`playings of Dream PetHouse. For example, the prestored subscriber data
`may include user preferences, a coin value, or a seed value. As an example,
`the subscriber data, such as the pets selected by the user or the seed 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 pets or seed 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 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 9 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 10 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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
`Dream PetHouse stores subscriber data so that it can be used in a subsequent
`playing of Dream PetHouse as prestored data.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 11 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 12 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 PetHouse as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices. A
`user of Dream PetHouse 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
`directly infringes Claim 4 by testing and demonstrating Dream PetHouse.
`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 related documents or testimony for Dream PetHouse. The priority date
`for Claim 4 is September 11, 1987.
`
`Dream PetHouse 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 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 13 of 22
`
`
`
`Dream PetHouse (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 ac-
`cording to a specific order in which the first control instruction to initiate the
`speeding up of the construction of a pethouse is always transmitted before
`the second control instruction to hire a nurse. Further, the control instruc-
`tions also include information designating a time period, such as the time
`period remaining before the construction is completed or before the nurse is
`hired.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 14 of 22
`
`
`
`Dream PetHouse (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 Dream PetHouse as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices. A
`user of Dream PetHouse 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 Dream PetHouse.
`The priority date for Claim 6 is September 11, 1987.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 15 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`The portion to be completed in Dream PetHouse 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 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 16 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 17 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 PetHouse as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices. A
`user of Dream PetHouse 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 Dream PetHouse.
`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 Dream PetHouse. The priority date
`for Claim 9 is September 11, 1987.
`
`A control signal in Dream PetHouse causes a controller of the station to
`control a peripheral device, such as a speaker. The control signals set audio
`settings for Dream PetHouse, as shown below.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 18 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 19 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 Dream PetHouse.
`
`Continued on next page
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 20 of 22
`
`
`
`Dream PetHouse (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 21 of 22
`
`Continued on next page
`
`
`
`Dream PetHouse (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 Dream PetHouse as a “mobile game” to its users playing
`on personal computing devices such as, for example, mobile handheld de-
`vices. A user of Dream PetHouse 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 Pet-
`House. The priority date for Claim 11 is September 11, 1987.
`
`Dream PetHouse is made available for play on an ultimate receiver station
`that is a storage device, such as a mobile device.
`
`Chart 80 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 22 of 22
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