Vampire Wars (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
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`Vampire Wars (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Vampire Wars (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 Vampire Wars as a browser-based game to its users via social
`networking websites. A user of Vampire Wars directly infringes Claim 9 by
`performing the method steps on a personal computing device. Zynga indi-
`rectly infringes Claim 9 by inducing and contributing to the direct infringe-
`ment of its users. Zynga directly infringes Claim 9 by testing and demon-
`strating Vampire Wars. 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 related documents
`or testimony for Vampire Wars. The priority date for Claim 9 is September
`11, 1987.
`
`Vampire Wars selects commercials from a plurality of commercials based on
`subscriber specific data such as the level of the subscriber and the content
`already obtained by the subscriber. For example, the commercials may be
`displayed to purchase more resources based on the subscriber having insuffi-
`cient resources to complete an action.
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`Continued on next page
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`Vampire Wars (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 64 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Words with Friends (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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends 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 Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 1 is September 11, 1987.
`
`As described below, Words with Friends processes video signals at a receiver
`station based on at least one information transmission.
`
`Words with Friends receives at least one information transmission from a
`server, such as when additional game components are loading and Words with
`Friends receives information content such as advertisements, game graphics,
`animations, and user information and statistics (such as points/levels earned,
`resources accumulated, 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 example,
`Words with Friends 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
`Words with Friends 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
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`Evidence of Infringement
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`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`
`Evidence of Infringement
`Words with Friends also receives information content and control signals
`to provide messages 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 purchase products or services, such as to purchase
`additional resources or unlock special features. See below:
`
`Continued on next page
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`Page 3 of 23
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`Claim Language
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`Evidence of Infringement
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`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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
`Words with Friends generates a benefit datum in response to the first control
`signal by processing subscriber specific data at the receiver station on which
`Words with Friends is being played. For example, Words with Friends pro-
`cesses 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 exam-
`ple of such a benefit datum is an offer to purchase additional resources (e.g.,
`Words Tokens) when the user does not have enough resources to complete a
`certain activity.
`
`Continued on next page
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`Page 5 of 23
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`Claim Language
`
`Evidence of Infringement
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`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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
`Words with Friends 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, Words with Friends delivers information
`content explaining the use of resources. See an example below:
`
`Continued on next page
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`Page 7 of 23
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`Claim Language
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`Evidence of Infringement
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`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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). Words with Friends 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 Words with Friends). Such a display button is shown
`below:
`
`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`controlling said receiver station
`based on said subscriber input.
`
`Words with Friends controls the receiver station based on the subscriber
`input. For example, Words with Friends may present a payment screen to
`allow the subscriber to pay for the benefit datum.
`
`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends directly infringes Claim 2 by performing the method steps on
`a personal computing device. Zynga indirectly infringes Claim 2 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 2 by testing and demonstrating Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 2 is September 11, 1987.
`
`Continued on next page
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`Page 11 of 23
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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`Words with Friends 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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`Words with Friends (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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends 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 Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 3 is September 11, 1987.
`
`Words with Friends 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 amount of resources available to the subscriber,
`which changes based on purchases made by the subscriber:
`
`Continued on next page
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`

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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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 Words with Friends as a browser-based game to its users
`via social networking websites and via the Zynga.com website. A user of
`Words with Friends 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 Words with Friends.
`The priority date for Claim 4 is September 11, 1987.
`
`Words with Friends receives information content that includes a commercial
`for the resources.
`
`Continued on next page
`
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`Page 15 of 23
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`

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`Words with Friends (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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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends directly infringes Claim 5 by performing the method steps on
`a personal computing device. Zynga indirectly infringes Claim 5 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 5 by testing and demonstrating Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 5 is September 11, 1987.
`
`The commercial in Claim 4 is stored locally by Words with Friends prior to
`delivery of the commercial. See below:
`
`Continued on next page
`
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`Page 17 of 23
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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`The method of claim 5,
`6.
`wherein said step of delivering
`comprises delivering said com-
`mercial from storage at said re-
`ceiver station.
`
`Zynga provides Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends 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 Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 6 is September 11, 1987.
`
`Continued on next page
`
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`Page 18 of 23
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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`The commercial in Claim 5 is delivered from storage at the receiver station.
`See below:
`
`Continued on next page
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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends directly infringes Claim 7 by performing the method steps on
`a personal computing device. Zynga indirectly infringes Claim 7 by induc-
`ing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 7 by testing and demonstrating Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. 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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`

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`Words with Friends (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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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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 Words with Friends as a browser-based game to its users via
`social networking websites and via the Zynga.com website. A user of Words
`with Friends 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 Words with Friends. 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 fol-
`lowing the production of source code, source code documentation, flowcharts,
`and/or other source code related documents or testimony for Words with
`Friends. The priority date for Claim 9 is September 11, 1987.
`
`Words with Friends selects commercials from a plurality of commercials based
`on subscriber specific data such as the level of the subscriber and the content
`already obtained by the subscriber (e.g., number of resources available).
`
`Continued on next page
`
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`Page 22 of 23
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`

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`Words with Friends (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 66 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 23 of 23
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`

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`Words with Friends (Mobile 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 Words with Friends as a “mobile game” to its users playing
`on personal computing devices such as, for example, mobile handheld de-
`vices. A user of Words 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 Words with
`Friends. Unless indicated otherwise, each element in Claim 1 includes a “soft-
`ware 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 documen-
`tation, flowcharts, and/or other source code related documents or testimony
`for Words with Friends. The priority date for Claim 1 is September 11, 1987.
`
`As described below, Words with Friends processes video signals at a receiver
`station based on at least one information transmission.
`
`Words with Friends receives at least one information transmission from a
`server, such as when additional game components are loading and Words with
`Friends receives information content such as advertisements, game graphics,
`animations, and user information and statistics (such as points/levels earned,
`resources accumulated, 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 example,
`Words with Friends 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 screen indicates that
`Words with Friends received a control signal that causes additional game
`components to load.
`
`Continued on next page
`
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`Page 1 of 26
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`

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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 26
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`Continued on next page
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`

`
`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`
`Evidence of Infringement
`Words with Friends also receives information content and control signals
`to provide messages 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 (e.g., store button) to purchase products or services, such as
`to purchase additional resources or unlock special features. See below:
`
`Continued on next page
`
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`Page 3 of 26
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`

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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 26
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`Continued on next page
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`

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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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
`Words with Friends generates a benefit datum in response to the first control
`signal by processing subscriber specific data at the receiver station on which
`Words with Friends is being played. For example, Words with Friends pro-
`cesses 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 exam-
`ple of such a benefit datum is a description of the benefit of purchasing a
`particular product or service (e.g., puchasing additional Word-O-Meters).
`
`Continued on next page
`
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`Page 5 of 26
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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
`Words with Friends 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, Words with Friends delivers information
`content explaining the use of resources. See an example below:
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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). Words with Friends 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 Words with Friends). Such a display button is shown
`below:
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 10 of 26
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`controlling said receiver station
`based on said subscriber input.
`
`Evidence of Infringement
`Words with Friends controls the receiver station based on the subscriber
`input. For example, Words with Friends may present a payment screen to
`allow the subscriber to pay for the benefit datum.
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 26
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`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.
`
`Evidence of Infringement
`Zynga provides Words with Friends as a “mobile game” to its users playing
`on personal computing devices such as, for example, mobile handheld de-
`vices. A user of Words with Friends 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 testing and demonstrating Words with
`Friends. Unless indicated otherwise, each element in Claim 2 includes a “soft-
`ware 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 documen-
`tation, flowcharts, and/or other source code related documents or testimony
`for Words with Friends. The priority date for Claim 2 is September 11, 1987.
`
`Words with Friends stores subscriber specific data at a computer at the
`receiver station. See, for example, the local storage (e.g., device memory)
`shown below containing subscriber specific data:
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`Words with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
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`Evidence of Infringement
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`Chart 69 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 14 of 26
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`Words with Friends (Mobile 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 Words with Friends as a “mobile game” to its users playing
`on personal computing devices such as, for example, mobile handheld de-
`vices. A user of Words with Friends 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 Words with
`Friends. Unless indicated otherwise, each element in Claim 3 includes a “soft-
`ware 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 documen-
`tation, flowcharts, and/or other source code related documents or testimony
`for Words with Friends. The priority date for Claim 3 is September 11, 1987.
`
`Words with Friends 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
`display below illustrates whether Word-O-Meters are available for use, which
`changes based on purchases by the subcriber:
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`Page 15 of 26
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`Words wi