Zynga Poker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`executing processor instructions
`to process said remotely origi-
`nated data and said user spe-
`cific data at said video appara-
`tus in order to generate said lo-
`cally generated image, said lo-
`cally generated image including
`at least some information con-
`tent that does not include any
`information from said remote
`video source and said remote
`data source;
`
`Zynga Poker executes processor instructions to process the remotely orig-
`inated data and the user specific data at the video apparatus to generate
`locally generated game images. The locally generated image includes at
`least some information content that does not include any information from
`a remote video source and a remote data source. For example, the locally
`generated image of Zynga Poker shown below includes graphical elements,
`such as the background and the images of the cards or icons that come from
`local storage.
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Additionally, Zynga Poker displays locally generated images that include
`information such as sound settings and notification settings, etc. This infor-
`mation comes from local storage. See, for example, below:
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`Evidence of Infringement
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`receiving, at said audio receiver,
`audio which describes informa-
`tion displayed in said video pre-
`sentation;
`
`This claim element does not include a “software limitation” under P.R. 3-
`1(g). The audio receiver receives audio that describes information displayed
`in the video game presentation. For example, Zynga Poker has audio settings
`(as shown below) where music and sound effects are set. Those sound effects
`and music are stored at the mobile device and are received by the audio
`receiver when they are played during game play as sound effects and video
`presentation music. These sound effects and music describe information dis-
`played in the video game presentation.
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`Continued on next page
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`simultaneously displaying said
`locally generated image and said
`image received from said re-
`mote video source at said video
`output device, wherein said at
`least some information content
`of said locally generated image
`is displayed;
`
`Zynga Poker simultaneously displays the locally generated image and the
`image received from the remote video source at the video output device. As
`an example, the locally generated image includes graphical elements that are
`stored locally, such as the background and game icons, while simultaniously
`displaying an image recieved from a remote video source, such as friend
`information or opponent information.
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`As another example, the locally generated image includes the user name,
`selected character, game statistics, profile picture, user preferences, and/or
`other game graphics that come from local storage. These images are dis-
`played simultaneously with an image received from a remote video source
`when Zynga Poker also displays remote game information and data. For
`example, locally generated images are displayed simultaneously with infor-
`mation received from a remote source. See below, where remotely received
`images are circled in red and local images include, for example, the header
`image or the Zynga icon:
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`Continued on next page
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`Evidence of Infringement
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`Further, the game state is recieved from the remote video source by the
`video output device, such as the placement of graphical elements for friend
`information, etc.
`
`Additionally, remote images, such as friend photos are displayed along with
`locally stored graphics.
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`and outputting said audio at
`said video apparatus before
`ceasing to display said locally
`generated video image.
`
`This claim element does not include a “software limitation” under P.R. 3-
`1(g). Zynga Poker outputs the audio at the video apparatus before ceasing
`receives audio to display the locally generated images. For example, during
`gameplay, sound effects play simultaneously with the video game display,
`which includes the display of locally generated video game images such as user
`specific information overlaid on background graphical displays. For example,
`in the screenshot below audio is output comprising bells ringing, chips being
`stacked, and cards being flipped.
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Zynga Poker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`18. A method of outputting a
`video presentation at a receiver
`station, said method comprising
`the steps of:
`
`Evidence of Infringement
`Zynga provides Zynga Poker as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Zynga Poker directly infringes Claim 18 by performing the method
`steps on a personal computing device. Zynga indirectly infringes Claim 18 by
`inducing and contributing to the direct infringement of its users. Zynga di-
`rectly infringes Claim 18 by testing and demonstrating Zynga Poker. Unless
`indicated otherwise, each element in Claim 18 includes a “software limita-
`tion” under P.R. 3-1(g). Additional evidence of infringement may be sup-
`plied as needed in accordance with the Local Rules and the Docket Con-
`trol Order following the production of source code, source code documenta-
`tion, flowcharts, and/or other source code related documents or testimony
`for Zynga Poker. The priority date for Claim 18 is November 3, 1981.
`
`Zynga Poker outputs a video presentation at a receiver station. See screen
`shots of example video presentations below:
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`Continued on next page
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`receiving at least one informa-
`tion transmission at said re-
`ceiver
`station,
`said at
`least
`one
`information transmission
`including a first discrete signal
`and a second discrete signal;
`
`Zynga Poker receives at least one information transmission at the receiver
`station that includes a first discrete signal and a second discrete signal. For
`example, Zynga Poker receives the game status information, which includes
`game information such as information related to the placement of a first game
`item (a first discrete signal) and information related to the placement of a
`second game item (a second discrete signal). As a second example, Zynga
`Poker receives data related to other users, such as a the placement of a first
`game item (a first discrete signal) and information related to the placement
`of a second game item (a second discrete signal).
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`Continued on next page
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`Continued on next page
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`Evidence of Infringement
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`detecting said first discrete sig-
`nal and said second discrete sig-
`nal in said at least one informa-
`tion transmission;
`
`Zynga Poker detects the first and second discrete signals in the information
`transmission. For example, Zynga Poker detects a first discrete signal con-
`taining information related to the placement of a game item and detects a
`second discrete signal information related to the placement of a second game
`item. See below:
`
`Continued on next page
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`passing said detected at least
`one first discrete signal and said
`second discrete signal to at least
`one processor;
`
`Zynga Poker passes the detected first and second discrete signals to a proces-
`sor so that they can be processed. For example, Zynga Poker passes a first
`discrete signal containing information related to the placement of a first game
`element and passes a second discrete signal containing information related to
`the placement of a second game element. See below:
`
`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`organizing information included
`in said at least one first dis-
`crete signal with information in-
`cluded in said second discrete
`signal to provide an organized
`signal at said receiver station;
`
`Zynga Poker organizes information (the placement of game elements) in-
`cluded in the first and second discrete signals to provide an organized signal
`at the receiver station. For example, multiple game elements are organized
`so that they are displayed at organized locations on the background image,
`as shown below:
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Zynga Poker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Evidence of Infringement
`Zynga Poker generates an image in response to the organized signal (contain-
`ing information related to the placement of game elements, for example) by
`processing at least one user specific subscriber datum such as a user name,
`user account, or user preferences. See below:
`
`Claim Language
`generating an image in response
`to said organized signal by pro-
`cessing at least one user spe-
`cific subscriber datum, said at
`least one user specific subscriber
`datum being stored at said re-
`ceiver station prior to said step
`of organizing and based on in-
`formation supplied by a user of
`said receiver station, said gen-
`erated image including at least
`some information content that
`does not include any informa-
`tion from said discrete signals;
`and
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Zynga Poker (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
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`Evidence of Infringement
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`Zynga Poker stores the user specific subscriber datum (such as a user name,
`user account, or user preference) at the receiver station prior to the step
`of organizing and based on information supplied by a user of the receiver
`station. For example, when the user first signs up for Zynga Poker the user
`enters his name and other user specific information, such as his facebook
`information, as shown below:
`
`Continued on next page
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`Chart 77 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 40 of 67
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