`
`Claim Language
`
`Evidence of Infringement
`
`The method of claim 1,
`4.
`wherein said information con-
`tent comprises a commercial.
`
`Zynga provides ChefVille as a browser-based game to its users via social
`networking websites. A user of ChefVille directly infringes Claim 4 by per-
`forming 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
`ChefVille. The priority date for Claim 4 is September 11, 1987.
`
`ChefVille receives information content that includes a commercial (e.g., Add
`Cash and Coins) for the resources.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`Continued on next page
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`Claim Language
`claim
`5.
`The method of
`4, wherein said commercial
`is
`stored at said receiver station
`prior to said step of delivering.
`
`Evidence of Infringement
`Zynga provides ChefVille as a browser-based game to its users via social
`networking websites. A user of ChefVille directly infringes Claim 5 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 5 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 5 by testing and demonstrat-
`ing ChefVille. Unless indicated otherwise, each element in Claim 5 includes
`a “software limitation” under P.R. 3-1(g). Additional evidence of infringe-
`ment 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 ChefVille. The priority date for Claim 5 is September 11, 1987.
`
`The commercial in Claim 4 is stored locally (e.g., in a cache) by ChefVille
`prior to delivery of the commercial. See below:
`
`Continued on next page
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`Page 12 of 20
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Page 13 of 20
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`Claim Language
`6.
`The method of claim 5,
`wherein said step of delivering
`comprises delivering said com-
`mercial from storage at said re-
`ceiver station.
`
`Evidence of Infringement
`Zynga provides ChefVille as a browser-based game to its users via social
`networking websites. A user of ChefVille directly infringes Claim 6 by per-
`forming 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 demonstrat-
`ing ChefVille. Unless indicated otherwise, each element in Claim 6 includes
`a “software limitation” under P.R. 3-1(g). Additional evidence of infringe-
`ment 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 ChefVille. The priority date for Claim 6 is September 11, 1987.
`
`The commercial in Claim 5 is delivered from storage (e.g., cache) at the
`receiver station. See below:
`
`Continued on next page
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`Page 14 of 20
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Claim Language
`7.
`The method of claim 6
`wherein said step of delivering is
`performed based on a schedule.
`
`Evidence of Infringement
`Zynga provides ChefVille as a browser-based game to its users via social
`networking websites. A user of ChefVille directly infringes Claim 7 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 7 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 7 by testing and demonstrat-
`ing ChefVille. Unless indicated otherwise, each element in Claim 7 includes
`a “software limitation” under P.R. 3-1(g). Additional evidence of infringe-
`ment 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 ChefVille. The priority date for Claim 7 is September 11, 1987.
`
`Zynga delivers commercials based on a schedule. For example, certain pur-
`chase options for resources may include sale or bonus items if a purchase is
`made at a certain time. The two displays below illustrate two different deals
`offered to the subscriber at different times.
`
`Continued on next page
`
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`Page 16 of 20
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Page 17 of 20
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Page 18 of 20
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`Claim Language
`9.
`The method of claim 4,
`wherein said commercial is se-
`lected from a plurality of com-
`mercials based on said sub-
`scriber specific data.
`
`Evidence of Infringement
`Zynga provides ChefVille as a browser-based game to its users via social
`networking websites. A user of ChefVille directly infringes Claim 9 by per-
`forming 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 demonstrat-
`ing ChefVille. Unless indicated otherwise, each element in Claim 9 includes
`a “software limitation” under P.R. 3-1(g). Additional evidence of infringe-
`ment 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 ChefVille. The priority date for Claim 9 is September 11, 1987.
`
`ChefVille selects commercials from a plurality of commercials based on sub-
`scriber specific data such as the level of the subscriber and the content already
`obtained by the subscriber. For example, an advertisement may be dispa-
`lyed for more coins when the subscriber specific data illustrates the subscriber
`does not have enough coins for a particular action.
`
`Continued on next page
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`Page 19 of 20
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`Claim Language
`
`Evidence of Infringement
`
`Chart 8 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 20 of 20
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`
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`1. A method of processing video
`signals at a receiver
`station
`based on at least one informa-
`tion transmission, the method
`comprising the steps of:
`
`receiving information content
`and a first control signal in said
`at least one information trans-
`mission at said receiver sta-
`tion, said information content
`describing at least one of a prod-
`uct and a service;
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille 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 test-
`ing and demonstrating CityVille. Unless indicated otherwise, 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 CityVille. The priority date for Claim 1 is
`September 11, 1987.
`
`As described below, CityVille processes video signals at a receiver station
`based on at least one information transmission.
`
`CityVille receives at least one information transmission from a server, such
`as when additional game components are loading and CityVille receives in-
`formation content such as advertisements, game graphics, animations, and
`user information and statistics (such as points/levels earned, resources ac-
`cumulated, prizes earned, purchases, and/or preferences). The information
`content describes a product or a service.
`
`The information transmission also includes a first control signal. For ex-
`ample, CityVille receives a first control signal that causes additional game
`components to load and to compute the user statistics to be displayed on the
`game interface. For example, as shown below, a loading bar indicates that
`CityVille received a control signal that causes additional game components
`to load.
`
`Continued on next page
`
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`Page 1 of 23
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`Claim Language
`
`Evidence of Infringement
`
`CityVille also receives information content and control signals to provide mes-
`sages to the game user, such as the availability of various resources (energy,
`coins, chips, for example) available during game play, to remind the user to
`play other games, to respond to requests from other users, and to accept or
`give gifts to other game users. The information content is the content of the
`message, and the first control signal is the signal that causes the message to
`be displayed. The information content may include advertisements to pur-
`chase products or services, such as to purchase additional resources (e.g.,
`coins and cash) or unlock special features. See below:
`
`Continued on next page
`
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`Page 2 of 23
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Page 3 of 23
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`Claim Language
`generating a benefit datum in
`response to said first control
`signal by processing subscriber
`specific data at said receiver sta-
`tion;
`
`Evidence of Infringement
`CityVille generates a benefit datum in response to the first control signal by
`processing subscriber specific data at the receiver station on which CityVille
`is being played. For example, CityVille processes subscriber specific data
`(such as a game state stored at the receiver station, which includes an amount
`of various resources the subscriber has accumulated) at the receiver station to
`generate a benefit datum. An example of such a benefit datum is an offer to
`purchase additional resources when the user does not have enough resources
`to complete a certain activity.
`
`Continued on next page
`
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`Page 4 of 23
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 5 of 23
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`
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`Claim Language
`delivering said information con-
`tent and said benefit datum at
`an output device at said receiver
`station, wherein said informa-
`tion content and said benefit da-
`tum explain a benefit of acquir-
`ing said product or service spe-
`cific to said subscriber;
`
`Evidence of Infringement
`CityVille delivers the information content and the benefit datum at an output
`device at the receiver station. The information content and the benefit datum
`explain a benefit of acquiring the product or service specific to the subscriber.
`For example, CityVille delivers information content explaining the use of
`resources to purchase or unlock the item the subscriber requested to purchase
`but does not have sufficient resources to purchase. See an example below:
`
`Continued on next page
`
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`Page 6 of 23
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 7 of 23
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`Claim Language
`receiving a subscriber input at
`said receiver station after said
`step of delivering; and
`
`Evidence of Infringement
`This claim element does not include a “software limitation” under P.R. 3-
`1(g). CityVille receives a subscriber input at the receiver station after the
`delivering step. Such an input includes, for example, a click or clicks detected
`on display buttons such as Buy, Skip, Okay, Accept, Continue, Proceed to
`Send, Place Now, Play, or Share (and other similar buttons on the display
`while playing CityVille). Such a display button (e.g., buy) is shown below:
`
`Continued on next page
`
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`Page 8 of 23
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`Claim Language
`
`Evidence of Infringement
`
`controlling said receiver station
`based on said subscriber input.
`
`CityVille controls the receiver station based on the subscriber input. For
`example, CityVille may present a payment screen to allow the subscriber to
`pay for the benefit datum.
`
`Continued on next page
`
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`Claim Language
`
`Evidence of Infringement
`
`2. The method of claim 1, fur-
`ther comprising the step of stor-
`ing said subscriber specific data
`at a computer at said receiver
`station.
`
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille directly
`infringes Claim 2 by performing the method steps on a personal computing
`device. Zynga indirectly infringes Claim 2 by inducing and contributing to
`the direct infringement of its users. Zynga directly infringes Claim 2 by test-
`ing and demonstrating CityVille. Unless indicated otherwise, each element
`in Claim 2 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 CityVille. The priority date for Claim 2 is
`September 11, 1987.
`
`Continued on next page
`
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`Page 10 of 23
`
`
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`
`Evidence of Infringement
`CityVille stores subscriber specific data at a computer at the receiver station.
`See, for example, the local storage shown below containing subscriber specific
`data:
`
`Continued on next page
`
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`3.
`The method of claim 1
`wherein said subscriber input
`modifies said subscriber specific
`data.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille 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 test-
`ing and demonstrating CityVille. Unless indicated otherwise, 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 CityVille. The priority date for Claim 3 is
`September 11, 1987.
`
`CityVille modifies subscriber specific data (such as a resource counter stored
`in the local game state) when the subscriber input causes those resources
`to change. For example, the purchase of additional resources results in an
`increase of the amount of resources available to the user. The screen below
`illustrates the number resources available to a subscriber, which changes
`based on purchases made by the subscriber:
`
`Continued on next page
`
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`Page 12 of 23
`
`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 13 of 23
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`Claim Language
`4.
`The method of claim 1,
`wherein said information con-
`tent comprises a commercial.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille 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 test-
`ing and demonstrating CityVille. The priority date for Claim 4 is September
`11, 1987.
`
`CityVille receives information content that includes a commercial for the
`resources.
`
`Continued on next page
`
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`Page 14 of 23
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`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 15 of 23
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`Claim Language
`claim
`5.
`The method of
`4, wherein said commercial
`is
`stored at said receiver station
`prior to said step of delivering.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille directly
`infringes Claim 5 by performing the method steps on a personal computing
`device. Zynga indirectly infringes Claim 5 by inducing and contributing to
`the direct infringement of its users. Zynga directly infringes Claim 5 by test-
`ing and demonstrating CityVille. Unless indicated otherwise, each element
`in Claim 5 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 CityVille. The priority date for Claim 5 is
`September 11, 1987.
`
`The commercial in Claim 4 is stored locally (e.g., in a cache) by CityVille
`prior to delivery of the commercial. See below:
`
`Continued on next page
`
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`Page 16 of 23
`
`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 17 of 23
`
`
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`6.
`The method of claim 5,
`wherein said step of delivering
`comprises delivering said com-
`mercial from storage at said re-
`ceiver station.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. 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 infringes Claim 6 by test-
`ing and demonstrating CityVille. Unless indicated otherwise, each element
`in Claim 6 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 CityVille. The priority date for Claim 6 is
`September 11, 1987.
`
`The commercial in Claim 5 is delivered from storage (e.g., cache) at the
`receiver station. See below:
`
`Continued on next page
`
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`Page 18 of 23
`
`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 19 of 23
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`Claim Language
`7.
`The method of claim 6
`wherein said step of delivering is
`performed based on a schedule.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille directly
`infringes Claim 7 by performing the method steps on a personal computing
`device. Zynga indirectly infringes Claim 7 by inducing and contributing to
`the direct infringement of its users. Zynga directly infringes Claim 7 by test-
`ing and demonstrating CityVille. Unless indicated otherwise, each element
`in Claim 7 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 CityVille. The priority date for Claim 7 is
`September 11, 1987.
`
`Zynga delivers commercials based on a schedule. For example, certain pur-
`chase options for resources may include sale or bonus items if a purchase is
`made at a certain time.
`
`Continued on next page
`
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`Page 20 of 23
`
`
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
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`Page 21 of 23
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`CityVille (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`9.
`The method of claim 4,
`wherein said commercial is se-
`lected from a plurality of com-
`mercials based on said sub-
`scriber specific data.
`
`Evidence of Infringement
`Zynga provides CityVille as a browser-based game to its users via social net-
`working websites and via the Zynga.com website. A user of CityVille 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 test-
`ing and demonstrating CityVille. Unless indicated otherwise, 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 CityVille. The priority date for Claim 9 is
`September 11, 1987.
`
`CityVille selects commercials from a plurality of commercials based on sub-
`scriber specific data such as the level of the subscriber and the content already
`obtained by the subscriber. For example, shown below is an advertisement
`to the subscriber based on subscriber specific data that the subscriber does
`not have sufficient resources to purchase a requested item:
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Page 23 of 23
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`CityVille (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`1. A method of processing video
`signals at a receiver
`station
`based on at least one informa-
`tion transmission, the method
`comprising the steps of:
`
`receiving information content
`and a first control signal in said
`at least one information trans-
`mission at said receiver sta-
`tion, said information content
`describing at least one of a prod-
`uct and a service;
`
`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 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 CityVille. Unless indicated
`otherwise, 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 follow-
`ing 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.
`
`As described below, CityVille processes video signals at a receiver station
`based on at least one information transmission.
`
`CityVille receives at least one information transmission from a server, such
`as when additional game components are loading and CityVille receives in-
`formation content such as advertisements, game graphics, animations, and
`user information and statistics (such as points/levels earned, resources ac-
`cumulated, prizes earned, purchases, and/or preferences). The information
`content describes a product or a service.
`
`The information transmission also includes a first control signal. For ex-
`ample, CityVille receives a first control signal that causes additional game
`components to load and to compute the user statistics to be displayed on
`the game interface. For example, as shown below, a loading bar (e.g., spin-
`ning wait signal) indicates that CityVille received a control signal that causes
`additional game components to load.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`CityVille also receives information content and control signals to provide mes-
`sages to the game user, such as the availability of various resources (energy,
`coins, chips, for example) available during game play, to remind the user to
`play other games, to respond to requests from other users, and to accept or
`give gifts to other game users. The information content is the content of the
`message, and the first control signal is the signal that causes the message to
`be displayed. The information content may include advertisements to pur-
`chase products or services, such as to purchase additional resources or unlock
`special features. See below:
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`generating a benefit datum in
`response to said first control
`signal by processing subscriber
`specific data at said receiver sta-
`tion;
`
`CityVille generates a benefit datum in response to the first control signal by
`processing subscriber specific data at the receiver station on which CityVille
`is being played. For example, CityVille processes subscriber specific data
`(such as a game state stored at the receiver station, which includes an amount
`of various resources the subscriber has accumulated) at the receiver station to
`generate a benefit datum. An example of such a benefit datum is an offer to
`purchase additional resources when the user does not have enough resources
`to complete a certain activity.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`delivering said information con-
`tent and said benefit datum at
`an output device at said receiver
`station, wherein said informa-
`tion content and said benefit da-
`tum explain a benefit of acquir-
`ing said product or service spe-
`cific to said subscriber;
`
`CityVille delivers the information content and the benefit datum at an output
`device at the receiver station. The information content and the benefit datum
`explain a benefit of acquiring the product or service specific to the subscriber.
`For example, CityVille delivers information content explaining the use of
`resources. See an example below:
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`receiving a subscriber input at
`said receiver station after said
`step of delivering; and
`
`This claim element does not include a “software limitation” under P.R. 3-
`1(g). CityVille receives a subscriber input at the receiver station after the
`delivering step. Such an input includes, for example, a click or clicks detected
`on display buttons such as Buy, Skip, Okay, Accept, Continue, Proceed to
`Send, Place Now, Play, or Share (and other similar buttons on the display
`while playing CityVille). Such a display button (e.g., the buttons showing
`the U.S. Dollar amount) is shown below:
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`controlling said receiver station
`based on said subscriber input.
`
`CityVille controls the receiver stati