`
`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 ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 1 is September 11, 1987.
`
`As described below, ZyngaPoker processes video signals at a receiver station
`based on at least one information transmission.
`
`ZyngaPoker receives at least one information transmission from a server, such
`as when additional game components are loading and ZyngaPoker receives
`information 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 exam-
`ple, ZyngaPoker 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 indi-
`cates that ZyngaPoker received a control signal that causes additional game
`components to load.
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`ZyngaPoker also receives information content and control signals to provide
`messages to the game user, such as the availability of various resources (en-
`ergy, 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 mes-
`sage to be displayed. The information content may include advertisements
`to purchase products or services, such as to purchase additional resources
`(e.g., Get Chips) or unlock special features. See below:
`
`Continued on next page
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`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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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;
`
`ZyngaPoker generates a benefit datum in response to the first control sig-
`nal by processing subscriber specific data at the receiver station on which
`ZyngaPoker is being played. For example, ZyngaPoker processes subscriber
`specific data (such as a game state stored at the receiver station, which in-
`cludes 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 (e.g., Don’t shy away -
`buy some chips and play!) when the user does not have enough resources to
`complete a certain activity.
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`
`Evidence of Infringement
`
`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;
`
`ZyngaPoker 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, ZyngaPoker delivers information content explaining
`the use of resources. See an example below:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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). ZyngaPoker 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 ZyngaPoker). Such a display button is shown below:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 20
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`ZyngaPoker (Mobile 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.
`
`ZyngaPoker controls the receiver station based on the subscriber input. For
`example, ZyngaPoker may present a payment screen to allow the subscriber
`to pay for the benefit datum.
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 6 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 7 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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 ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 2 is September 11, 1987.
`
`ZyngaPoker 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:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 8 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 9 of 20
`
`Continued on next page
`
`
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`3.
`The method of claim 1
`wherein said subscriber input
`modifies said subscriber specific
`data.
`
`Evidence of Infringement
`Zynga provides ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 3 is September 11, 1987.
`
`ZyngaPoker modifies subscriber specific data (such as a resource counter
`stored in the local game state) when the subscriber input causes those re-
`sources to change. See, for example, below where the purchase of additional
`resources results in an increase of the amount of resources available to the
`user:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 10 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`The method of claim 1,
`4.
`wherein said information con-
`tent comprises a commercial.
`
`Zynga provides ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. The
`priority date for Claim 4 is September 11, 1987.
`
`ZyngaPoker receives information content that includes a commercial for the
`resources.
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 11 of 20
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 20
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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 ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 testing and demonstrating ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 5 is September 11, 1987.
`
`The commercial in Claim 4 is stored locally by ZyngaPoker prior to delivery
`of the commercial. See below:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 13 of 20
`
`
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 14 of 20
`
`Continued on next page
`
`
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`ZyngaPoker (Mobile 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 ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 6 is September 11, 1987.
`
`The commercial in Claim 5 is delivered from storage at the receiver station.
`See below:
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 15 of 20
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`
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`Claim Language
`
`Evidence of Infringement
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 16 of 20
`
`Continued on next page
`
`
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`7.
`The method of claim 6
`wherein said step of delivering is
`performed based on a schedule.
`
`Evidence of Infringement
`Zynga provides ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 testing and demonstrating ZyngaPoker. 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 ZyngaPoker.
`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
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 17 of 20
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`
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`ZyngaPoker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 20
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`ZyngaPoker (Mobile 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 ZyngaPoker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of ZyngaPoker 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 ZyngaPoker. 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 ZyngaPoker.
`The priority date for Claim 9 is September 11, 1987.
`
`ZyngaPoker 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.
`
`Continued on next page
`
`Chart 78 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 19 of 20
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`Claim Language
`
`Evidence of Infringement
`
`Chart 78 – 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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`BubbleSafari (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 BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 1 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 1 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 1 by testing and demonstrating BubbleSafari. Unless indicated oth-
`erwise, 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 BubbleSafari. The
`priority date for Claim 1 is September 11, 1987.
`
`As described below, BubbleSafari processes video signals at a receiver station
`based on at least one information transmission.
`
`BubbleSafari receives at least one information transmission from a server,
`such as when additional game components are loading and BubbleSafari re-
`ceives information content such as advertisements, game graphics, anima-
`tions, and user information and statistics (such as points/levels earned, re-
`sources 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 exam-
`ple, BubbleSafari 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
`BubbleSafari received a control signal that causes additional game compo-
`nents to load.
`
`Continued on next page
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 1 of 24
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 2 of 24
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`BubbleSafari (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`Claim Language
`
`Evidence of Infringement
`BubbleSafari also receives information content and control signals to provide
`messages to the game user, such as the availability of various resources (en-
`ergy, 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 mes-
`sage to be displayed. The information content may include advertisements
`to purchase products or services, such as to purchase additional resources or
`unlock special features (e.g., extra spins). See below:
`
`Continued on next page
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 3 of 24
`
`
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`BubbleSafari (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
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 4 of 24
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`
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`BubbleSafari (Browser-Based 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
`BubbleSafari generates a benefit datum in response to the first control signal
`by processing subscriber specific data at the receiver station on which Bub-
`bleSafari is being played. For example, BubbleSafari processes subscriber
`specific data (such as a game state stored at the receiver station, which in-
`cludes 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
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 5 of 24
`
`
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`BubbleSafari (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
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 6 of 24
`
`
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`BubbleSafari (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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
`BubbleSafari delivers the information content and the benefit datum at an
`output device at the receiver station. The information content and the bene-
`fit datum explain a benefit of acquiring the product or service specific to the
`subscriber. For example, BubbleSafari delivers information content explain-
`ing the use of resources. See an example below, illustrating additional cash
`is needed:
`
`Continued on next page
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 7 of 24
`
`
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`BubbleSafari (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
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 8 of 24
`
`
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`BubbleSafari (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
`
`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). BubbleSafari 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 BubbleSafari). Such a display button (e.g., Buy) is shown
`below:
`
`Continued on next page
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 9 of 24
`
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`BubbleSafari (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.
`
`BubbleSafari controls the receiver station based on the subscriber input. For
`example, BubbleSafari may present a payment screen to allow the subscriber
`to pay for the benefit datum.
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 10 of 24
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`BubbleSafari (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 BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 2 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 2 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 2 by testing and demonstrating BubbleSafari. Unless indicated oth-
`erwise, 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 related documents or testimony for BubbleSafari. The
`priority date for Claim 2 is September 11, 1987.
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 11 of 24
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`BubbleSafari (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`
`Evidence of Infringement
`BubbleSafari stores subscriber specific data at a computer at the receiver sta-
`tion. See, for example, the local storage (e.g., cache) shown below containing
`subscriber specific data:
`
`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 12 of 24
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`Continued on next page
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`BubbleSafari (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 BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 3 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 3 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 3 by testing and demonstrating BubbleSafari. Unless indicated oth-
`erwise, 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 BubbleSafari. The
`priority date for Claim 3 is September 11, 1987.
`
`BubbleSafari modifies subscriber specific data (such as a resource counter
`stored in the local game state) when the subscriber input causes those re-
`sources 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 a display of the number of resources, such as after the re-
`sources are increased after modifying the subscriber specific data:
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 13 of 24
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`BubbleSafari (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 14 of 24
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`BubbleSafari (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 BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 4 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 4 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 4 by testing and demonstrating BubbleSafari. The priority date for
`Claim 4 is September 11, 1987.
`
`BubbleSafari receives information content that includes a commercial (e.g.,
`Add Coins and Cash) for the resources.
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 15 of 24
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`BubbleSafari (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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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 16 of 24
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`BubbleSafari (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 BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 5 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 5 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 5 by testing and demonstrating BubbleSafari. Unless indicated oth-
`erwise, 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 related documents or testimony for BubbleSafari. The
`priority date for Claim 5 is September 11, 1987.
`
`The commercial in Claim 4 is stored locally (e.g., in a cache) by BubbleSafari
`prior to delivery of the commercial. See below:
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 17 of 24
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`
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`BubbleSafari (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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`Chart 2 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 18 of 24
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`BubbleSafari (Browser-Based Game) – Infringement Contentions for U.S. Patent No. 7,797,717
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`Claim Language
`6.
`The method of claim 5,
`wherein said step of deliver-
`ing comprises delivering said
`commercial from storage (e.g.,
`cache) at said receiver station.
`
`Evidence of Infringement
`Zynga provides BubbleSafari as a browser-based game to its users via social
`networking websites and via the Zynga.com website. A user of BubbleSa-
`fari directly infringes Claim 6 by performing the method steps on a personal
`computing device. Zynga indirectly infringes Claim 6 by inducing and con-
`tributing to the direct infringement of its users. Zynga directly infringes
`Claim 6 by testing and demonstrating BubbleSafari. Unless indicated oth-
`erwise, 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 related documents or testimony for BubbleSafari. The
`priority date for Claim 6 is September 11, 1987.
`
`The commercial in Claim 5 is delivered from storage at the receiver station.
`See below:
`
`Continued on next page
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`Chart 2 – Personalized Media Communications, LLC