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`Claim Language
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`Evidence of Infringement
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`Evidence of Infringement
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`passing said detected at least
`one first discrete signal and said
`second discrete signal to at least
`one processor;
`
`CityVille Hollidaytown passes the detected first and second discrete signals
`to a processor so that they can be processed. For example, CityVille Holl-
`idaytown 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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`Claim Language
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`Evidence of Infringement
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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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`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;
`
`CityVille Hollidaytown organizes information (the placement of game ele-
`ments) included in the first and second discrete signals to provide an orga-
`nized 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:
`
`Continued on next page
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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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`Claim Language
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`Evidence of Infringement
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`Continued on next page
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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Evidence of Infringement
`CityVille Hollidaytown 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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`Continued on next page
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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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`Claim Language
`
`Evidence of Infringement
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`CityVille Hollidaytown stores the user specific subscriber datum (such as a
`user name, user account, or user preferences) 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 CityVille
`Hollidaytown the user enters her name and other user specific information,
`such as her Facebook information, as shown below:
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`The image generated by CityVille Hollidaytown 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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`Continued on next page
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`Claim Language
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`Evidence of Infringement
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`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.
`
`This claim element does not include a “software limitation” under P.R. 3-1(g).
`CityVille Hollidaytown 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, CityVille Hollidaytown outputs a coordinated
`display using the generated image and video images such as movement of
`people through the city, where two homes have been organized according to
`the first and second signals.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`Continued on next page
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`CityVille Hollidaytown (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 CityVille Hollidaytown as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of CityVille Hollidaytown 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
`CityVille Hollidaytown. 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 documents
`or testimony for CityVille Hollidaytown. The priority date for Claim 19 is
`November 3, 1981.
`
`CityVille Hollidaytown includes a third discrete signal that generates a re-
`ceiver 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 the video presen-
`tation, such as the build button.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`Once the user clicks on the build button, a video of a rising lightning bolt
`and a falling star is output to the user, as shown below.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
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`Continued on next page
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`CityVille Hollidaytown (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 CityVille Hollidaytown as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of CityVille Hollidaytown 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
`CityVille Hollidaytown. 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 documents
`or testimony for CityVille Hollidaytown. 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.
`
`Continued on next page
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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
`
`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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`passing said at least one user
`specific subscriber datum to a
`storage device.
`
`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, 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
`
`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 con-
`nection that shows specific user data is still available, such as the placement
`of houses in the town.
`
`Continued on next page
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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.
`
`Continued on next page
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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`23. The method of claim 18,
`further including the step of:
`
`Evidence of Infringement
`Zynga provides CityVille Hollidaytown as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of CityVille Hollidaytown 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
`CityVille Hollidaytown. 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 documents
`or testimony for CityVille Hollidaytown. 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.
`
`CityVille Hollidaytown contacts the Zynga server to obtain at least one spe-
`cific 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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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`
`CityVille Hollidaytown also contacts the Zynga server to update advertise-
`ment information.
`
`Continued on next page
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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`
`As another example, CityVille Hollidaytown 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
`
`Continued on next page
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`CityVille Hollidaytown (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 CityVille Hollidaytown as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of CityVille Hollidaytown 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
`CityVille Hollidaytown. 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 documents
`or testimony for CityVille Hollidaytown. The priority date for Claim 24 is
`November 3, 1981.
`
`CityVille Hollidaytown 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 build
`button, which is represented by a picture of a hammer.
`
`Continued on next page
`
`Chart 15 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`CityVille Hollidaytown (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 button, a video presentation is output to the user.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`The display is output based on the receiver specific control signal, specifically
`the build button.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`CityVille Hollidaytown (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 sta-
`tion includes a video monitor
`that outputs said video presen-
`tation, wherein said video pre-
`sentation comprises a series of
`computer generated video dis-
`play outputs, and wherein by
`processing said at least one user
`specific subscriber datum said
`at least one processor delivers
`said generated image at said
`video monitor in one of said se-
`ries of computer generated dis-
`play outputs, said method fur-
`ther comprising the step of re-
`ceiving said at least one user
`specific subscriber datum from
`a remote data source.
`
`Evidence of Infringement
`Zynga provides CityVille Hollidaytown as a “mobile game” to its users play-
`ing on personal computing devices such as, for example, mobile handheld
`devices. A user of CityVille Hollidaytown 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
`CityVille Hollidaytown. 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 documents
`or testimony for CityVille Hollidaytown. 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 CityVille Hollidaytown comprises a series of
`computer generated video display outputs. As an example, shown below is
`a series of screenshots taken during a video presentation that demonstrate
`the series of computer generated video display outputs, which includes user
`specific subscriber datum.
`
`Continued on next page
`
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`Claim Language
`
`Evidence of Infringement
`
`Continued on next page
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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`
`CityVille Hollidaytown processes the user specific subscriber datum and un-
`der the direction of CityVille Hollidaytown the processor delivers the gener-
`ated image at the video monitor in one of the series of computer generated
`display outputs. For example, CityVille Hollidaytown receives the user’s
`game status, such as the score, the user’s level, instructions to continue to
`play, and locations of graphical elements. See below:
`
`Continued on next page
`
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`CityVille Hollidaytown (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`
`CityVille Hollidaytown receives the user specific subscriber datum from a
`remote data source. See the screenshot below showing that a connection
`with the Zynga servers is required to play CityVille Hollidaytown.
`
`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Chart 15 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
`
`Claim Language
`17. A method for receiving
`and processing remotely orig-
`inated and user specific data
`for use with a video appara-
`tus, said video apparatus having
`an audio receiver and a video
`output device for displaying a
`video presentation comprising a
`locally generated image and an
`image received from a remote
`video source, said method com-
`prising the steps of
`
`Evidence of Infringement
`Zynga provides Dream Zoo as a “mobile game” to its users playing on per-
`sonal computing devices such as, for example, mobile handheld devices. A
`user of Dream Zoo directly infringes Claim 17 by performing the method steps
`on a personal computing device. Zynga indirectly infringes Claim 17 by in-
`ducing and contributing to the direct infringement of its users. Zynga directly
`infringes Claim 17 by testing and demonstrating Dream Zoo. Unless indi-
`cated otherwise, each element in Claim 17 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 Dream Zoo.
`The priority date for Claim 17 is November 3, 1981.
`
`Dream Zoo receives and processes remotely originated and user specific data
`for use with a video apparatus, such as a mobile device, having an audio
`receiver and a video output device. For example, Dream Zoo receives data
`from the Zynga servers that is processed with user specific data, such as
`user name or a user game state. Dream Zoo displays a video presentation
`comprising a locally generated image and an image received from a remote
`video source. For example, the screenshot below shows a video presentation
`(the Dream Zoo screen) comprising a locally generated image (combination
`of background and graphical elements) and an image received from a remote
`video source (friend picture).
`
`Continued on next page
`
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`Dream Zoo (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
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`As a second example, the screenshot below illustrates a video presentation
`comprising an image received from a remote video source, such as a photo
`of a friend. The combination of the background and graphical elements is a
`locally generated image.
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`Continued on next page
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`As a third example, the screenshot below shows a video presentation (the
`Dream Zoo screen) comprising a locally generated image (combination of
`background and graphical elements) and images received from a remote video
`source (advertisements).
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`Dream Zoo information is stored on the user’s device, as shown below.
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`Continued on next page
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`Chart 18 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Further, as shown below, Dream Zoo must receive remotely originated data.
`
`receiving said user specific data
`at said video apparatus, said
`user specific data being specific
`to a user of said video appara-
`tus;
`
`Dream Zoo receives user specific data at the video apparatus that is specific
`to the user of the video apparatus. This user specific data includes the current
`state of the game, and other user specific data. For example, when loading,
`Dream Zoo communicates with the Zynga game servers to validate a user,
`check for messages specific to the user, and update the user’s game state,
`among other user specific configurations and values. As a second example,
`user specific data may be received by the video apparatus directly from the
`user.
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`Further, Zynga uses the information collected from the user to send user spe-
`cific information for a personalized game experience, and Dream Zoo receives
`that user specific data:
`
`Source: http://company.zynga.com/about/privacy-center/privacy-policy
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`As another example of receiving user specific data, Dream Zoo receives user
`specific data, such as user name or sound preferences, directly from the user
`at the video apparatus through user input, or Dream Zoo, at the video ap-
`paratus, may receive user specific information, such as the user’s game state,
`personalized messages, or targeted advertisements, from the Zynga servers.
`The sound settings are on by default but can be turned off by the user, as
`shown below, which is another example of Dream Zoo receiving user specific
`data.
`
`As an additional example, Dream Zoo at the video apparatus receives user
`information such as a profile image of the user.
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`Continued on next page
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`Further, the user specific data is specific to a user of the video apparatus,
`being based on user name, user profile, user account, user activity and status,
`user preferences, game status and user contact information. For example,
`Dream Zoo receives data about friends playing the game, news applicable to
`the user, personalized advertisements, user preferences, user’s game status,
`user’s friends’ game status, and personalized messages to the user. See, for
`example, below:
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`Continued on next page
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`Continued on next page
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`Dream Zoo also receives status and information that is data specific to a
`user at the video apparatus. Such data includes, for example, user profile
`information, pending messages and goals, game statistics, friend information
`and user account. See below:
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`Continued on next page
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`Continued on next page
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`contacting a remote data source
`after said step of receiving said
`user specific data;
`
`After receiving user specific data, Dream Zoo contacts a remote data source.
`For example, after the user specific data is received and displayed, Dream Zoo
`contacts a game server to update games. See, for example, the screenshot
`below showing a remote data source being contacted by Dream Zoo.
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`Continued on next page
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`After Dream Zoo receives user specific data, Dream Zoo also contacts a Zynga
`game server with an updated game status. For example, if the Internet is
`disconnected during gameplay, an error message is displayed, which shows
`that Dream Zoo attempts to contact a remote data source after receiving
`user specific data.
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`Continued on next page
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`receiving from said remote data
`source based on said step of con-
`tacting said remotely originated
`data to serve as a basis for dis-
`playing said video presentation;
`
`Based on the contacting step, Dream Zoo receives remotely originated game
`data from the remote data source to serve as a basis for displaying the video
`game presentation. For example, Dream Zoo receives remotely originated
`game data such as specific game status, game statistics, positions of graphical
`elements, and instructions to continue play from the remote data source. See
`below:
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`Continued on next page
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`Continued on next page
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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;
`
`Dream Zoo executes processor instructions to process the remotely originated
`data and the user specific data at the video apparatus to generate locally
`generated gam