throbber
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Claim Language
`detecting said first discrete sig-
`nal and said second discrete sig-
`nal in said at least one informa-
`tion transmission;
`
`Evidence of Infringement
`Hanging with Friends detects the first and second discrete signals in the
`information transmission. For example, Hanging with Friends detects a first
`discrete signal containing 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:
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`Continued on next page
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`passing said detected at least
`one first discrete signal and said
`second discrete signal to at least
`one processor;
`
`Evidence of Infringement
`Hanging with Friends passes the detected first and second discrete signals
`to a processor so that they can be processed. For example, Hanging with
`Friends passes a first discrete signal containing information related to the
`placement of a first game element and passes a second discrete signal con-
`taining information related to the placement of a second game element. See
`below:
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`Continued on next page
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Evidence of Infringement
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`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;
`
`Evidence of Infringement
`Hanging with Friends organizes information (the placement of game ele-
`ments) included in the first and second discrete signals to provide an or-
`ganized signal at the receiver station. For example, multiple game elements
`are organized so that they are displayed at organized locations on the back-
`ground image, as shown below:
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`Continued on next page
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Evidence of Infringement
`Hanging with Friends generates an image in response to the organized sig-
`nal (containing 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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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`Hanging with Friends 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 Hanging with
`Friends the user enters her name and other user specific information, such as
`her facebook information, as shown below:
`
`The image generated by Hanging with Friends includes information content
`that is not from the first and second discrete signals, such as locally stored
`user information and the graphical representation of items and background
`images.
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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`outputting said video presenta-
`tion to said user, said video pre-
`sentation comprising, firstly, a
`video image and, secondly, a
`coordinated display using said
`generated image and said video
`image, wherein said at least
`some information content of
`said generated image is dis-
`played.
`
`Evidence of Infringement
`This claim element does not include a “software limitation” under P.R. 3-
`1(g). Hanging with Friends outputs a video presentation to the user that
`includes a video image and a coordinated display using the generated image
`and the video image. For example, Hanging with Friends outputs a coordi-
`nated display using the generated image and video images, such as the rising
`of ashes from the volcano and the movement of lava, where two avatars rep-
`resenting the user and an opponent have been organized according to the
`first and second signals.
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`Continued on next page
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`19. The method of claim 18,
`wherein a receiver specific con-
`trol signal
`is generated based
`on a third discrete signal, said
`method further including the
`step of: selecting said video pre-
`sentation in response to said
`generated receiver specific con-
`trol signal.
`
`Evidence of Infringement
`Zynga provides Hanging with Friends as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of Hanging with Friends directly infringes Claim 19 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 19 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 19 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`19 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 doc-
`uments or testimony for Hanging with Friends. The priority date for Claim
`19 is November 3, 1981.
`
`Hanging with Friends includes a third discrete signal that generates a receiver
`specific control signal. Further, a video presentation is selected in response
`to the generated receiver specific control signal. For example, the screenshot
`below displays an additional element that starts a video presentation, such
`as the “watch” button.
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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Claim Language
`
`Evidence of Infringement
`Once the user clicks on the “watch” button, a video of the opponent’s attempt
`to guess a word is output to the user, as shown below. As another example,
`also output to the user are three icons, representing life lines for the user,
`that slide into their locations.
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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 73 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`22. The method of claim 18,
`further comprising the steps of:
`
`receiving said at least one user
`specific subscriber datum; and
`
`Evidence of Infringement
`Zynga provides Hanging with Friends as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of Hanging with Friends directly infringes Claim 22 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 22 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 22 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`22 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 doc-
`uments or testimony for Hanging with Friends. The priority date for Claim
`22 is November 3, 1981.
`
`The receiver station receives at least one user specific subscriber datum
`through user input or the user specific subscriber datum may be received
`from the Zynga servers. For example, the user can update their sound pref-
`erences.
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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`As another example, the screenshot below shows specific subscriber datum
`that was received from the Zynga servers, such as the current game state of
`the user.
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`As a further example, the screenshot below shows specific subscriber datum
`that was received from the Zynga servers, such as the current game state of
`the user’s friend.
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 79 of 102
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`passing said at least one user
`specific subscriber datum to a
`storage device.
`
`Evidence of Infringement
`The user specific subscriber datum received by user input or from the Zynga
`server is passed to a storage device. This is demonstrated when the program
`is exited and reentered without an Internet connection. The user preferences
`for the sound settings is not reset to default when accessed without an In-
`ternet connection, and instead shows the previously entered user preference,
`as shown below. Thus, the user preferences are stored on a storage device.
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 81 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`Further, user data received from the Zynga servers are stored at the receiver
`station. For example, the screenshot below shows a game without a valid
`connection that shows specific user data is still available, such as the last word
`played by the user, “SHANTY” in this example, and information relating to
`the user’s ongoing game with a friend or opponent.
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 83 of 102
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`Continued on next page
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`

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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`As another example, the Zynga server stores the user’s account information,
`which is validated each time the user logs in.
`
`23. The method of claim 18,
`further including the step of:
`
`Zynga provides Hanging with Friends as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of Hanging with Friends directly infringes Claim 23 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 23 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 23 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`23 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 doc-
`uments or testimony for Hanging with Friends. The priority date for Claim
`23 is November 3, 1981.
`
`contacting a remote station to
`obtain said at least one user spe-
`cific subscriber datum.
`
`Hanging with Friends contacts the Zynga server to obtain at least one specific
`subscriber datum, such as to update user specific subscriber data. As an
`example, the user specific subscriber datum is the game state, as shown
`below.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 85 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`Hanging with Friends also contacts the Zynga server to update advertisement
`information.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 87 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`As another example, Hanging with Friends also contacts the Zynga server to
`update the user’s friend’s game state.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 89 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`24. The method of claim 18,
`wherein a receiver specific con-
`trol signal
`is processed based
`on a third discrete signal, said
`method further including the
`step of outputting said video
`image in response to said re-
`ceiver
`specific control
`signal,
`wherein said coordinated dis-
`play is output based on said re-
`ceiver specific control signal.
`
`Evidence of Infringement
`Zynga provides Hanging with Friends as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of Hanging with Friends directly infringes Claim 24 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 24 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 24 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`24 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 doc-
`uments or testimony for Hanging with Friends. The priority date for Claim
`24 is November 3, 1981.
`
`Hanging with Friends includes a third discrete signal that processes a re-
`ceiver specific control signal. For example, the screenshot below displays an
`additional element that starts the coordinated display, such as the “watch”
`button.
`
`Continued on next page
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 90 of 102
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`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 91 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`Once the user clicks the “watch” button, a video presentation is output to
`the user.
`
`Continued on next page
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`Claim Language
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`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 93 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`The display is output based on the receiver specific control signal, specifically
`the “watch” button.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 95 of 102
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`Continued on next page
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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`28. The method of claim 18,
`wherein said receiver station in-
`cludes a video monitor which
`outputs said video presentation,
`wherein said video presentation
`comprises a series of computer
`generated video display out-
`puts, and wherein by process-
`ing said at least one user spe-
`cific subscriber datum said at
`least one processor delivers said
`generated image at said video
`monitor in one of said series of
`computer generated display out-
`puts, said method further com-
`prising the step of receiving said
`at least one user specific sub-
`scriber datum from a remote
`data source.
`
`Evidence of Infringement
`Zynga provides Hanging with Friends as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of Hanging with Friends directly infringes Claim 28 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 28 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 28 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`28 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 doc-
`uments or testimony for Hanging with Friends. The priority date for Claim
`28 is November 3, 1981.
`
`The receiver station includes a video monitor to output the video presenta-
`tion. The video presentation of Hanging with Friends comprises a series of
`computer generated video display outputs. As an example, shown below is
`a series of screenshots taken during a video presentation which demonstrate
`the series of computer generated video display outputs, which includes user
`specific subscriber datum.
`
`Continued on next page
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 96 of 102
`
`

`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 97 of 102
`
`Continued on next page
`
`

`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 98 of 102
`
`Continued on next page
`
`

`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
`
`Claim Language
`
`Evidence of Infringement
`Hanging with Friends processes the user specific subscriber datum and under
`the direction of Hanging with Friends the processor delivers the generated
`image at the video monitor in one of the series of computer generated display
`outputs. For example, Hanging with Friends receives the user’s game status,
`such as the score, the user’s level, and the locations of graphical elements.
`See below:
`
`Continued on next page
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 99 of 102
`
`

`
`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
`
`Claim Language
`
`Evidence of Infringement
`
`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
`
`Page 100 of 102
`
`Continued on next page

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