Hanging with Friends (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 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 17 by per-
`forming the method steps on a personal computing device. Zynga indirectly
`infringes Claim 17 by inducing and contributing to the direct infringement
`of its users. Zynga directly infringes Claim 17 by testing and demonstrating
`Hanging with Friends. Unless indicated 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 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
`17 is November 3, 1981.
`
`Hanging with Friends 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, Hanging with
`Friends receives data from the Zynga servers which is processed with user
`specific data, such as user name or a user game state. Hanging with Friends
`displays a video presentation comprising a locally generated image and an im-
`age received from a remote video source. For example, the screenshot below
`demonstrates a video presentation (the Hanging with Friends screen) com-
`prising a locally generated image (combination of background and graphical
`elements) and an image received from a remote video source (friend picture).
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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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`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
`
`Evidence of Infringement
`As a second example, the screenshot below illustrates a video presentation
`comprising an image received from a remote video source, such as a profile
`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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`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
`
`Evidence of Infringement
`As a third example, the screenshot below shows a video presentation (the
`Hanging with Friends screen) comprising a locally generated image (combi-
`nation of background and graphical elements) and images received from a
`remote video source (advertisements).
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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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`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 information is stored on the user’s device, as shown
`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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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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`Page 8 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
`
`Evidence of Infringement
`Further, as shown below, Hanging with Friends must receive remotely origi-
`nated data.
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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 10 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
`receiving said user specific data
`at said video apparatus, said
`user specific data being specific
`to a user of said video appara-
`tus;
`
`Evidence of Infringement
`Hanging with Friends 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, Hanging with Friends 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 recieved by the video apparatus
`directly from the user.
`
`Hanging with Friends receives user specific data. For example, Zynga uses
`the information collected from the user to send the user specific information
`for a personalized game experience, and Hanging with Friends receives the
`user specific data:
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`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`
`Source: http://company.zynga.com/about/privacy-center/privacy-policy
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`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`As another example of receiving user specific data, Hanging with Friends
`receives user specific data, such as user name or sound preferences, directly
`from the user at the video apparatus through user input, or Hanging with
`Friends, at the video apparatus, may recieve user specific information, such
`as the user’s game state, personalized messages, or targeted advertisements,
`from the Zynga servers. The sound settings are at the maximum setting by
`default but can be modified by the user, as shown below, which is another
`example of Hanging with Friends receiving user specific data.
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`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 14 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 an additional example, Hanging with Friends at the video apparatus re-
`ceives user information such as a profile image of the user.
`
`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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`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
`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,
`Hanging with Friends 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:
`
`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 18 of 102
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`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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`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 receives status and information that is data specific
`to a user at the video apparatus. Such data includes, for example, user profile
`information, messages about friends, game statistics, friend information and
`user account. 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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`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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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`contacting a remote data source
`after said step of receiving said
`user specific data;
`
`Evidence of Infringement
`After receiving user specific data, Hanging with Friends contacts a remote
`data source. For example, after the user specific data is received and dis-
`played, Hanging with Friends contacts a game server to update games. See,
`for example, the screenshot below showing a remote data source being con-
`tacted by Hanging with Friends.
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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 24 of 102
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`Continued on next page
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`Claim Language
`
`Evidence of Infringement
`After Hanging with Friends receives user specific data, Hanging with Friends
`also contacts a Zynga game server with an updated game status. For ex-
`ample, if the Internet is disconnected during gameplay, an error message is
`displayed, which shows that Hanging with Friends attempts to contact a
`remote data source after receiving user specific data.
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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 26 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
`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;
`
`Evidence of Infringement
`Based on the contacting step, Hanging with Friends receives remotely origi-
`nated game data from the remote data source to serve as a basis for displaying
`the video game presentation. For example, Hanging with Friends receives re-
`motely 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:
`
`Continued on next page
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`Claim Language
`
`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 28 of 102
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`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 29 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
`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;
`
`Evidence of Infringement
`Hanging with Friends executes processor instructions to process the remotely
`originated 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 Hanging with Friends shown below includes graphical
`elements such as the background and the images of the avatars that come
`from local storage.
`
`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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`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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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`
`Evidence of Infringement
`Additionally, Hanging with Friends displays locally generated images that
`include information such as sound settings and notification settings, etc. This
`information comes from local storage. See, for example, below:
`
`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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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`receiving, at said audio receiver,
`audio which describes informa-
`tion displayed in said video pre-
`sentation;
`
`Evidence of Infringement
`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, Hanging with Friends 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
`displayed in the video game presentation.
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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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`Hanging with Friends (Mobile Game) – Infringement Contentions for U.S. Patent No. 7,734,251
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`Claim Language
`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;
`
`Evidence of Infringement
`Hanging with Friends simultaneously displays the locally generated image
`and the image received from the remote video source at the video output de-
`vice. As an example, the locally generated image includes graphical elements
`that are stored locally, such as the background and avatar graphics, while
`simultaniously displaying an image recieved from a remote video source, such
`as friend information or opponent information.
`
`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 38 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, 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 Hanging with Friends also displays remote game information and data.
`For example, locally generated images are displayed simultaneously with in-
`formation 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:
`
`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
`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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`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
`and outputting said audio at
`said video apparatus before
`ceasing to display said locally
`generated video image.
`
`Evidence of Infringement
`This claim element does not include a “software limitation” under P.R. 3-1(g).
`Hanging with Friends 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 running water and drum
`playing.
`
`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 44 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
`18. A method of outputting a
`video presentation at a receiver
`station, said method comprising
`the steps of:
`
`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 18 by per-
`forming 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 directly infringes Claim 18 by testing and demonstrating
`Hanging with Friends. Unless indicated otherwise, each element in Claim
`18 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
`18 is November 3, 1981.
`
`Hanging with Friends outputs a video presentation at a receiver station. See
`screen shots of example video presentations 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 46 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
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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
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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
`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;
`
`Evidence of Infringement
`Hanging with Friends receives at least one information transmission at the
`receiver station that includes a first discrete signal and a second discrete
`signal. For example, Hanging with Friends receives the game status infor-
`mation, which includes game information such as information related to the
`placement of a first game item (a first discrete signal) and information re-
`lated to the placement of a second game item (a second discrete signal). As
`a second example, Hanging with Friends receives data related to other users,
`such as a the placement of a first game item (a first discrete signal) and in-
`formation related to the placement of a second game item (a second discrete
`signal).
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`Page 49 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
`
`Evidence of Infringement
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`Chart 31 – Personalized Media Communications, LLC v. Zynga, Inc. (2:12-cv-68)
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