IPR2013-00156, No. 1002 Exhibit - Zynga Ex 1002 Part 1 of 8 PMC Infringement Contentions (P.T.A.B. Feb. 22, 2013)

CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`CityVille directly infringes Claim 1 by performing the method steps on a per-
`sonal 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 CityVille. 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 CityVille. The priority date for Claim 1 is September 11,
`1987.
`
`CityVille 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, CityVille 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 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 20
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`

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`CityVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 20
`
`Continued on next page
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`

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`CityVille (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 CityVille computer program is operative
`to complete the portion to be completed by, for example, accessing prestored
`data. Execution of the CityVille 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, CityVille
`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 name for the city, the type of houses or
`crops selected, or the orientation/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 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 20
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`

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`CityVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 20
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`

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`CityVille (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 CityVille to enable the station to
`deliver complete programming as described and shown above. For example,
`with reference to the ﬁgures below, CityVille stores a control signal that in-
`cludes 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 “Hire
`Luisa!” (highlighted in the second ﬁgure below).
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 20
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`

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`CityVille (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 CityVille. See
`ﬁgure below for an example of the station delivering complete programming.
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 7 of 20
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`

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`CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`CityVille directly infringes Claim 3 by performing the method steps on a per-
`sonal 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 CityVille. 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 CityVille. The priority date for Claim 3 is September 11,
`1987.
`
`Prestored data designates subscriber data in CityVille. Such prestored data
`is used, for example, to maintain continuity between successive playings of
`CityVille. For example, the prestored subscriber data may include the name
`for the city, 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 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 9 of 20
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`

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`CityVille (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.
`
`CityVille stores subscriber data so that it can be used in a subsequent playing
`of CityVille as prestored data.
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 10 of 20
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`

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`CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`CityVille directly infringes Claim 4 by performing the method steps on a per-
`sonal 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 CityVille. 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 CityVille. The priority date for Claim 4 is September 11,
`1987.
`
`CityVille 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 CityVille
`regarding the planting of crops, while a second transmitted control instruc-
`tion may cause execution to enable delivery of complete programming of
`CityVille regarding the harvesting of the planted crops, along with the op-
`tion to speed up the harvesting process. See the examples shown below.
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 20
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`

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`CityVille (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 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 20
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`

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`CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user
`of CityVille 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 in-
`fringes Claim 6 by testing and demonstrating CityVille. The priority date
`for Claim 6 is September 11, 1987.
`
`The portion to be completed in CityVille 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 for examples of
`generally applicable information (examples speciﬁed with red boxes):
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 16 of 20
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`

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`CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`CityVille directly infringes Claim 9 by performing the method steps on a per-
`sonal 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 CityVille. 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 CityVille. The priority date for Claim 9 is September 11,
`1987.
`
`A control signal in CityVille causes a controller of the station to control a
`peripheral device, such as a speaker. The control signals set audio settings
`for CityVille, as shown below.
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 20
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`

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`CityVille (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 CityVille.
`
`Continued on next page
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 19 of 20
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`

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`CityVille (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 CityVille as a “mobile game” to its users playing on personal
`computing devices such as, for example, mobile handheld devices. A user of
`CityVille 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 in-
`fringes Claim 11 by testing and demonstrating CityVille. The priority date
`for Claim 11 is September 11, 1987.
`
`CityVille is made available for play on an ultimate receiver station that is a
`storage device, such as a mobile device.
`
`Chart 11 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 20 of 20
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`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Holidaytown 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 Holidaytown. 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 Holidaytown. The priority date for
`Claim 1 is September 11, 1987.
`
`Holidaytown 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, Holidaytown 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 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 20
`
`

`
`Holidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 2 of 20
`
`Continued on next page
`
`

`
`Holidaytown (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 Holidaytown computer program is op-
`erative to complete the portion to be completed by, for example, accessing
`prestored data. Execution of the Holidaytown 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,
`Holidaytown 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 name for the city, the type of houses or
`crops selected, or the orientation/layout of graphics, and placing the result-
`ing information, such as the houses selected by the user, in the portion to be
`completed.
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 3 of 20
`
`

`
`Holidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,860,131
`
`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 20
`
`

`
`Holidaytown (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 Holidaytown to enable the station to
`deliver complete programming as described and shown above. For example,
`with reference to the ﬁgures below, Holidaytown 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 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 20
`
`

`
`Holidaytown (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 Holidaytown. See
`ﬁgure below for an example of the station delivering complete programming.
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 7 of 20
`
`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Holidaytown 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 Holidaytown. 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 Holidaytown. The priority date for
`Claim 3 is September 11, 1987.
`
`Prestored data designates subscriber data in Holidaytown. Such prestored
`data is used, for example, to maintain continuity between successive play-
`ings of Holidaytown. For example, the prestored subscriber data may include
`the name for the city, the type of houses or crops selected, or the orienta-
`tion/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 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 9 of 20
`
`

`
`Holidaytown (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.
`
`Holidaytown stores subscriber data so that it can be used in a subsequent
`playing of Holidaytown as prestored data.
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 10 of 20
`
`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Holidaytown 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 Holidaytown. 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 Holidaytown. The priority date for
`Claim 4 is September 11, 1987.
`
`Holidaytown 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 Holiday-
`town regarding the planting of crops, while a second transmitted control
`instruction may cause execution to enable delivery of complete programming
`of Holidaytown 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 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 12 of 20
`
`

`
`Holidaytown (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 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 14 of 20
`
`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of Holidaytown 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 Holidaytown. The
`priority date for Claim 6 is September 11, 1987.
`
`The portion to be completed in Holidaytown 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 for
`examples of generally applicable information (examples speciﬁed with red
`boxes):
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 16 of 20
`
`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Holidaytown 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 Holidaytown. 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 Holidaytown. The priority date for
`Claim 9 is September 11, 1987.
`
`A control signal in Holidaytown causes a controller of the station to control
`a peripheral device, such as a speaker. The control signals set audio settings
`for Holidaytown, as shown below.
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 18 of 20
`
`

`
`Holidaytown (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 Holidaytown.
`
`Continued on next page
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 19 of 20
`
`

`
`Holidaytown (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 Holidaytown as a “mobile game” to its users playing on
`personal computing devices such as, for example, mobile handheld devices.
`A user of Holidaytown 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 Holidaytown. The
`priority date for Claim 11 is September 11, 1987.
`
`Holidaytown is made available for play on an ultimate receiver station that
`is a storage device, such as a mobile device.
`
`Chart 14 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 20 of 20
`
`

`
`Dream Zoo (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 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 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 Dream Zoo. 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 Rule

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