`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`Playtika Ltd. and Playtika Holding Corp.,
`
`Petitioners,
`
`v.
`
`NEXRF Corp.,
`
`Patent Owner.
`
`U.S. Patent No. 8,747,229
`Filing Date: Dec. 29, 2010
`Issue Date: June 10, 2014
`
`____________________
`
`Case No. IPR2021-00951
`
`
`
`DECLARATION OF STACY A. FRIEDMAN
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`
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`
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`TABLE OF CONTENTS
`
`
`Introduction ...................................................................................................... 1
`I.
`Background and Qualifications ....................................................................... 1
`II.
`III. Summary of Opinions ...................................................................................... 6
`IV. Background and Technology of the ’229 Patent ............................................. 7
`A.
`The ’229 Patent Prosecution History .................................................. 13
`Challenged Claims ......................................................................................... 14
`V.
`VI. Legal Standards ............................................................................................. 18
`VII. Level of Person of Ordinary Skill in the Art ................................................. 23
`VIII. Claim Construction ........................................................................................ 25
`IX. The Challenged Claims are Unpatentable Over the Prior Art ....................... 25
`X. Grounds 1-2: The Joshi Grounds Render Obvious Claims 1, 9, and 17 ....... 27
`A. Overview of Prior Art ......................................................................... 27
`1.
`Joshi........................................................................................... 27
`2.
`Finlayson ................................................................................... 31
`a. Motivation to Combine ................................................... 32
`Independent Claim 1 ........................................................................... 33
`1.
`[1p] “A gaming server system configured to
`communicate with at least one network access device
`communicatively coupled to a network, the gaming
`server system comprising:” ....................................................... 33
`[1a] “a verification system configured to access a
`registration database having a plurality of registration
`data associated with each registered user;” ............................... 35
`
`B.
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`2.
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`ii
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`3.
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`5.
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`6.
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`4.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`[1b] “a memory module configured to store a plurality of
`images corresponding to at least one game outcome that
`are communicated to the at least one network access
`device;” ..................................................................................... 40
`[1c] “a centralized gaming server communicatively
`coupled to each of the at least one network access device,
`the centralized gaming server configured to generate at
`least one random game outcome by random generation at
`the centralized gaming server;” ................................................ 43
`[1d] “a paytable module associated with the centralized
`gaming server, the paytable module configured to
`determine one or more prizes associated with a game
`outcome;” .................................................................................. 45
`[1e] “the centralized gaming server configured to access
`the memory module and communicate the plurality of
`images corresponding to the at least one random game
`outcome to the at least one network access device.” ................ 46
`Independent Claim 9 ........................................................................... 48
`1.
`[9p] “A gaming server system configured to
`communicate with a plurality of network access devices
`that are communicatively coupled to a network, the
`gaming server system comprising:” .......................................... 48
`[9a] “a verification system configured to access a
`registration database having a plurality of registration
`data associated with each registered user, wherein the
`verification system is configured to:” ....................................... 48
`[9b] “receive user identification information associated
`with a player from at least one network access device,
`and” ........................................................................................... 49
`[9c] “verify the player accessing the network access
`device is a registered user by comparing the user
`identification information to the registration data;” ................. 50
`
`C.
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`2.
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`3.
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`4.
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`iii
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`5.
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`7.
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`8.
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`6.
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`U.S. Patent No. 8,747,229
`[9d] “a memory module configured to store a plurality of
`images corresponding to at least one game outcome that
`are communicated to the plurality of network access
`devices;” .................................................................................... 51
`[9e] “a centralized gaming server communicatively
`coupled to each of the plurality of network access
`devices, the centralized gaming server configured to
`generate at least one random game outcome by random
`generation at the centralized gaming server;”........................... 52
`[9f] “a paytable module associated with the centralized
`gaming server, the paytable module configured to
`determine one or more prizes associated with a game
`outcome; and” ........................................................................... 52
`[9g] “the centralized gaming server configured to access
`the memory module and communicate the plurality of
`images corresponding to the at least one random game
`outcome to each network access device.” ................................. 52
`Independent Claim 17 ......................................................................... 53
`1.
`[17p] “A method for generating a game outcome with a
`gaming server system configured to communicate with a
`plurality of network access devices that are
`communicatively coupled to a network, the gaming
`server system comprising:” ....................................................... 53
`[17a] “enabling a verification system to receive user
`identification information from at least one network
`access device;” .......................................................................... 54
`[17b] “verifying with the verification system that the user
`accessing the at least one network access device is a
`registered user by comparing the user identification
`information to registration data stored in a registration
`database;” .................................................................................. 54
`[17c] “generating, with a centralized gaming server
`communicatively coupled to each of the plurality of
`network access devices, at least one random game
`iv
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`D.
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`2.
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`3.
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`4.
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`5.
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`6.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`outcome with random generation at the centralized
`gaming server;” ......................................................................... 54
`[17d] “determining one or more prizes associated with
`the random game outcome with a paytable module
`associated with the centralized gaming server; and” ................ 55
`[17e] “communicating a plurality of images
`corresponding to the at least one random game outcome
`from the centralized gaming server to each network
`access device.” .......................................................................... 55
`XI. Grounds 3-4: The Joshi Agasse Grounds Render Obvious Claims 6, 7,
`14, 15, 22 and 23 ............................................................................................ 55
`A. Overview of Additional Prior Art: Agasse .......................................... 56
`B. Motivation to Combine ....................................................................... 58
`C.
`[Claim 6] “The gaming server system of claim 1, further
`comprising an encoding module configured to convert the
`plurality of images to a format meeting the requirements of
`each network access device.” .............................................................. 62
`[Claim 7] “The gaming server system of claim 1, further
`comprising an encryption module, the encryption module
`configured to encrypt the plurality of images communicated to
`each network access device.” .............................................................. 67
`[Claim 14] “The gaming server system of claim 9, further
`comprising an encoding module configured to convert the
`images to a format meeting the requirements of each network
`access device.” ..................................................................................... 68
`[Claim 15] “The gaming server system of claim 9, further
`comprising an encryption module, the encryption module
`configured to encrypt the plurality of images communicated to
`each network access device.” .............................................................. 68
`[Claim 22] “The method of claim 17, further comprising
`converting the plurality of images to a format meeting the
`
`G.
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`E.
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`F.
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`v
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`requirements of each network access device with an encoding
`module.” .............................................................................................. 68
`[Claim 23] “The method of claim 17, further comprising
`encrypting the plurality of images communicated to each
`network access device with an encryption module.” .......................... 69
`XII. Grounds 5-6: The Joshi Mighdoll Grounds Render Obvious Claims 6,
`14, and 22 ....................................................................................................... 69
`A. Overview of Additional Prior Art: Mighdoll ...................................... 69
`B. Motivation to Combine ....................................................................... 72
`C.
`[Claim 6] “The gaming server system of claim 1, further
`comprising an encoding module configured to convert the
`plurality of images to a format meeting the requirements of
`each network access device.” .............................................................. 75
`[Claim 14] “The gaming server system of claim 9, further
`comprising an encoding module configured to convert the
`images to a format meeting the requirements of each network
`access device.” ..................................................................................... 77
`[Claim 22] “The method of claim 17, further comprising
`converting the plurality of images to a format meeting the
`requirements of each network access device with an encoding
`module.” .............................................................................................. 77
`XIII. Grounds 7-8: The Joshi Dobner Grounds Render Obvious Claims 7,
`15, and 23 ....................................................................................................... 77
`A. Overview of Additional Prior Art: Dobner ......................................... 77
`B. Motivation to Combine ....................................................................... 80
`C.
`[Claim 7] “The gaming server system of claim 1, further
`comprising an encryption module, the encryption module
`configured to encrypt the plurality of images communicated to
`each network access device.” .............................................................. 81
`[Claim 15] “The gaming server system of claim 9, further
`comprising an encryption module, the encryption module
`vi
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`D.
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`D.
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`E.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`configured to encrypt the plurality of images communicated to
`each network access device.” .............................................................. 82
`[Claim 23] “The method of claim 17, further comprising
`encrypting the plurality of images communicated to each
`network access device with an encryption module.” .......................... 82
`XIV. Conclusion ..................................................................................................... 82
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`E.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
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`I.
`
`Introduction
`
`1.
`
`I, Stacy A. Friedman, submit this declaration to state my opinions on
`
`the matters described below.
`
`2.
`
`I have been retained by Playtika Ltd. and Playtika Holding Corp., as
`
`an independent expert in this proceeding before the United States Patent and
`
`Trademark Office.
`
`3.
`
`I understand that this proceeding involves U.S. Patent No. 8,747,229
`
`(“the ’229 patent”), and that I have been asked to provide my opinions as to the
`
`patentability or unpatentability of certain claims of the ’229 patent.
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`4.
`
`This declaration sets forth my opinions, which I have formed in this
`
`proceeding based on my education, training, research, knowledge, and personal
`
`and professional experience; my understanding as an expert in the field; and my
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`study of the evidence.
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`5.
`
`I am being compensated for my time at the rate of $600 per hour. This
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`compensation is not contingent upon the nature of my findings, the presentation of
`
`my findings in testimony, or the outcome of this proceeding.
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`II. Background and Qualifications
`
`6.
`
`I am a professional game designer and casino gaming mathematician, and
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`I am intimately familiar with the issues and technology relating to both digital and
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`physical games. As shown below, I have personally designed, implemented, tested,
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`and analyzed many games, including dozens of single- and multi-player games for both
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`Internet and land-based gaming operators.
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`7.
`
`I am the President of Olympian Gaming, LLC in Lake Oswego, Oregon,
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`a position that I have held since 2001. In that capacity, I have advised clients regarding,
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`among other things, game design and development, casino slot machine and table
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`game mathematics, game software development, network gaming system architecture,
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`and gaming patent infringement and validity. I have over twenty years of professional
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`experience in developing regulated casino games, gaming mathematics, and
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`professional software design expertise. Although I discuss my expert qualifications in
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`more detail below, a recent curriculum vitae which details my educational and
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`professional background is attached as Exhibit 1004.
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`8.
`
`I have been a game player for most of my life, long before my
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`professional entry into the gaming industry, and that continues to this day. I was an
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`avid game player growing up: gin rummy with my father; panguingue, casino, and
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`Rummikub with my grandmother; chess with my grandfather; and various home poker
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`games in high school and college. My earliest recollection of computer games was
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`playing “The Oregon Trail” in grade school on an Apple II computer. During the 1980s
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`I frequented coin-operated video game arcades, and in the mid-to-late 1980s first
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`became familiar with multiplayer online gaming via dial-up modems and text-based
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`adventure games. During middle school and high school, I taught myself software
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`U.S. Patent No. 8,747,229
`programming on a Commodore VIC-20 and an Apple IIgs, the majority of which was
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`for game programs.
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`9.
`
`In 1996, I earned my Bachelor of Arts degree in Computer Science,
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`magna cum laude, from Harvard College, Harvard University, Cambridge,
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`Massachusetts. During college I became familiar with a wider variety of game genres,
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`including RTS or “real time strategy” computer games (specifically Warcraft: Orcs vs.
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`Humans), CCG or “collectible card games” (specifically Magic: The Gathering), and
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`expanded my knowledge of wagering card games to blackjack, baccarat, and casino
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`poker. After college, I became interested in the mathematics of casino games. I taught
`
`myself probability theory—the origins of which are based in wagering games—and
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`began a self-directed study of gaming mathematics, including “advantage play”
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`techniques such as blackjack card counting.
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`10. My professional experience in the casino gaming industry started in 1998,
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`when I joined Silicon Gaming in Palo Alto, California as a game model engineer before
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`it was acquired by International Game Technology (“IGT”). Silicon Gaming designed
`
`and developed interactive video slot machines. As a game model engineer
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`(mathematician), I worked on the designs of video slot games, video keno games, and
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`video card games including video poker and blackjack; helped produce dozens of
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`innovative new games for the Odyssey™ platform; and engaged regulatory agencies
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`to achieve regulatory approval for the mathematics used in the games. In addition, I
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`U.S. Patent No. 8,747,229
`designed and developed game flow and storyboards for new games and game features
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`(behaviors) and developed and shipped over 50 mathematical game models. I also
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`served as a liaison to state regulatory agencies and corrected prior errors in gaming lab
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`submissions, which led to savings of over $50,000 in regulatory fees. I was also
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`responsible for managing the statistical verification and mathematical gameplay
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`testing for Silicon Gaming’s products. In 1999 I invented and analyzed a novel card
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`game for Silicon Gaming’s digital card game portfolio. This game is described in U.S.
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`Patent 6,457,715 and can best be described as “acey-deucy with a discard/draw
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`option.”
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`11.
`
`In 2001, I started an independent casino game design and analysis
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`consultancy, Olympian Gaming LLC. Based on my experience designing, developing,
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`and placing dozens of games in Las Vegas, Reno, and Atlantic City casinos, I advise
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`Internet casino software vendors, new game inventors, and casino game manufacturers
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`in the fields of wagering gameplay design, mathematical analysis, and statistical
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`verification. Most of my earliest clients were online gaming software providers,
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`including WagerWorks, a company that spun out of Silicon Gaming to develop a real-
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`money remote gambling system called WagerWare. WagerWorks was acquired by
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`IGT in 2005. In 2011, I was engaged by DoubleDown Interactive, a social gaming
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`website offering free-to-play slot machine games on its Facebook app, DoubleDown
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`Casino. I designed the mathematics, payouts, and game features for all of
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`DoubleDown's virtual slot machine games. In 2012, IGT bought DoubleDown for
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`$500,000,000. Social gaming applications such as DoubleDown Casino do not earn
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`revenue from wagering. Instead, they follow monetization practices such as
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`microtransactions, in-app purchasing, ad-impression revenue, and subscription-based
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`payments. In the past few years I have been engaged as a game design consultant by
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`several video game studios using similar business models. I have also served as a
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`subject matter expert in many matters related to gaming machines or gaming
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`technology, including over 20 cases involving gaming-related intellectual property.
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`Many of these cases have involved distributed software systems running on networked
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`computers, and in several of these cases I have performed source code reviews. Some
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`of these cases have involved technology related to networked gaming systems,
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`including International Gamco v MGAM (networked lottery systems), Lottotron v
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`Allgames Casinos (remote wagering systems), and Agincourt v. Zynga (social
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`gaming).
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`12. Also through Olympian Gaming, I have invented and applied for patents
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`on over two dozen gaming methods and systems and, together with my patent attorney
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`and frequent co-inventor, control a patent portfolio of approximately forty issued
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`and/or pending patents across several categories of the gaming industry. These
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`innovations include novel table games, electronic wagering games such as slot
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`machine and video poker games, and networked casino management or promotional
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`5
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`systems. Several of these patents describe novel card or tile games in both physical and
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`electronic embodiments, including U.S. Patents 7,651,096 and 8,074,992 (“Bad Beat
`
`Blackjack”), 7,335,099 (“Method for playing wagering games”), 7,708,208 (“Poker
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`game with variable payouts based on probabilities of winning”), and 8,403,737 and
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`8,998,693 (“Royal re-draw video poker side bet”). I performed the game design and
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`mathematical analysis on the games described therein. Olympian Gaming has received
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`regulatory approval for operation of Bad Beat Blackjack in Nevada, Mississippi, and
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`Washington State.
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`13. Based on my experience, training and qualifications, I consider myself to
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`be an expert in the gaming field, with particular expertise in the areas of networked
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`gaming systems as well as in the analysis and implementation of game features in both
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`physical and electronic/computerized embodiments.
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`III. Summary of Opinions
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`14.
`
`I have been asked to provide my opinion on whether certain claims of
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`the ’229 patent are unpatentable over certain prior art references. It is my opinion
`
`that claims 1, 6, 7, 9, 14, 15, 17, 22, and 23 of ’229 patent are unpatentable because
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`they would have been obvious to a person of ordinary skill in the art in view of the
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`prior art.
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`U.S. Patent No. 8,747,229
`IV. Background and Technology of the ’229 Patent
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`15. The ’229 patent is directed to a gaming server system comprising a
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`server configured to generate a random game outcome and to transmit images
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`corresponding to that random game outcome to a network access device, as shown
`
`in FIG. 2 below. See Ex-1001, Claim 1. The claimed gaming server system
`
`comprises (1) a verification system for verifying the identity of a player, (2) a
`
`paytable module for determining a prize associated with the random game
`
`outcome, and (3) a memory module for storing images corresponding to a random
`
`game outcome. See Ex-1001, Claim 1. The dependent claims of the ’229 patent
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`further limit the gaming server system as comprising an encoding module for
`
`converting the images into a format meeting the requirements of the network
`
`access device, and an encryption module for encrypting the images communicated
`
`to the network access device. See Ex-1001, Claims 6 and 7. The specification
`
`states that the network access device may be a computer (FIG. 1a), a set-top box
`
`(FIG. 1b), a wireless device such as a digital phone or a personal digital system
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`(PDA) (FIG. 1c), or slot machine (FIG. 1d), as shown in annotated FIG. 2 below.
`
`Ex-1001, 5:64-6:10.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
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`Ex-1001, FIGS 1a-1d.
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`Ex-1001, FIG. 2 (annotated).
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`
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`16. As shown in FIG. 2 above, the gaming system includes a verification
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`system with a verification server and a registration database. The verification
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`system receives user identification information and security information from a
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`U.S. Patent No. 8,747,229
`network access device to “verif[y] that a user desiring to play the game is a
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`registered player.” Ex-1001, 7:20-21. The user identification information includes
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`“player name, address, user name, password, credit card information, and the date
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`and time of the registration.” Ex-1001, 8:39-42. The security information includes
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`“the MAC ID for biometric input module, the IP address for the server
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`communicating with the registration terminal, and the cryptographic keys
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`associated with the registration terminal.” Ex-1001, 11:56-60. The ’229 patent
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`specification also discloses that the user identification information may be “housed
`
`in a smart card (not shown) that is in communication with the verification system
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`34.” Ex-1001, 7:36-38.
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`17. After a player enters a user ID and a password using a network access
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`device, the server compares the entered data with the data stored in a player
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`registration database. See Ex-1001, 8:36-42. The registration database stores player
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`registration information in fields, as shown in FIGS. 5 and 6 below.
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
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`Ex-1001, FIG 5.
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`
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`Ex-1001, FIG. 6.
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`18.
`
`If the data entered by the player matches the data stored in the
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`registration database, the player is given authorization to access the user account
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`play a game, as shown in FIG. 9 below. See Ex-1001, 8:55-58, 12:45-48.
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`Ex-1001, FIG. 9 (annotated).
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`
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`19. After the verification is complete, the gaming module of the server
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`generates a random number using a random number generator. See Ex-1001, 13:8-
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`13. A paytable module then compares the random number to a paytable to
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`determine a corresponding prize. See Ex-1001, 13:23-26. The server also retrieves
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`images corresponding to the random game outcome from a memory module and
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`transmits them to a network access device. See Ex-1001, 10:21-32.
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`Ex-1001, FIG. 7.
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`
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`20. As stated in the “Description of Related Art” section of the
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`specification, most, if not all, of these elements were well known in the art at the
`
`time of the invention. For example, it states that “[n]etworked interactive gaming
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`in an open networked environment such as the Internet is well-known” and that
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`“[n]etworked interactive gaming using LANs and WANs for progressive slot
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`machines having large jackpots are also well-known.” Ex-1001, 2:36-37, 51-53. It
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`also admits that “[t]o prevent underage gambling[,] prior art systems and methods
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`use passwords, use IDs, credit cards and ‘click-through’ agreements that ask the
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`player to agree to being of legal gambling age by clicking on a button.” Ex-1001,
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`1:64-67. Furthermore, the specification states “[w]ith respect to ensuring that on-
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`line gaming is secure and reliable, prior art systems and methods use various
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`cryptographic techniques such as RSA encryption, digital certificates, or other
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`similar well-known cryptographic methods.” Ex-1001, 2:2-5. The specification
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`also admits that the claimed random number generator and paytable were well
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`known. See Ex-1001, 1:32-42.
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`A. The ’229 Patent Prosecution History
`
`21.
`
`I understand that during the prosecution of the ’229 patent, the
`
`applicant amended the claims from “gaming server” to “centralized gaming server”
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`to clarify that it refers to a server located on the server side, not on the client side.
`
`See Ex-1002, 207 (2/1/2012 Applicant Arguments/Remarks at 8). Furthermore, I
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`understand that to overcome the examiner’s obviousness rejection, the applicant
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`amended independent claim 21 (issued claim 1) to add “the central gaming server
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`configured to access the memory module and communicate the plurality of images
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`corresponding to the at least one game outcome to the valid network access
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`device.” Ex-1002, 160 (10/19/2011 Applicant Arguments/Remarks at 8). I
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`understand that the applicant relied on this amendment to overcome the examiner’s
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`rejection based on prior art, arguing that the cited prior art lacks “the central
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`U.S. Patent No. 8,747,229
`gaming server configured to access the memory module and communicate the
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`plurality of images corresponding to the at least one game outcome to the valid
`
`network access device.” Ex-1002, 209 (2/1/2012 Applicant Arguments/Remarks at
`
`10 (emphasis in original)).
`
`V. Challenged Claims
`
`22. The following claims of the ’229 patent are addressed in this petition.
`
`Element numbers have been added:
`
`Claim 1:
`[1p] A gaming server system configured to communicate
`with at least one network access device communicatively
`coupled to a network, the gaming server system
`comprising:
`[1a] a verification system configured to access a
`registration database having a plurality of registration
`data associated with each registered user;
`[1b] a memory module configured to store a plurality of
`images corresponding to at least one game outcome that
`are communicated to the at least one network access
`device;
`[1c] a centralized gaming server communicatively
`coupled to each of the at least one network access device,
`the centralized gaming server configured to generate at
`least one random game outcome by random generation at
`the centralized gaming server;
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`[1d] a paytable module associated with the centralized
`gaming server, the paytable module configured to
`determine one or more prizes associated with a game
`outcome; and
`[1e] the centralized gaming server configured to access
`the memory module and communicate the plurality of
`images corresponding to the at least one random game
`outcome to the at least one network access device.
`Claim 6:
`[6] The gaming server system of claim 1, further
`comprising an encoding module configured to convert
`the plurality of images to a format meeting the
`requirements of each network access device.
`Claim 7:
`[7] The gaming server system of claim 1, further
`comprising an encryption module, the encryption module
`configured to encrypt the plurality of images
`communicated to each network access device.
`Claim 9:
`[9p] A gaming server system configured to communicate
`with a plurality of network access devices that are
`communicatively coupled to a network, the gaming
`server system comprising:
`[9a] a verification system configured to access a
`registration database having a plurality of registration
`data associated with each registered user, wherein the
`verification system is configured to:
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`[9b] receive user identification information associated
`with a player from at least one network access device,
`and
`[9c] verify the player accessing the network access
`device is a registered user by comparing the user
`identification information to the registration data;
`[9d] a memory module configured to store a plurality of
`images corresponding to at least one game outcome that
`are communicated to the plurality of network access
`devices;
`[9e] a centralized gaming server communicatively
`coupled to each of the plurality of network access
`devices, the centralized gaming server configured to
`generate at least one random game outcome by random
`generation at the centralized gaming server;
`[9f] a paytable module associated with the centralized
`gaming server, the paytable module configured to
`determine one or more prizes associated with a game
`outcome; and
`[9g] the centralized gaming server configured to access
`the memory module and communicate the plurality of
`images corresponding to the at least one random game
`outcome to each network access device.
`Claim 14:
`[14] The gaming server system of claim 9, further
`comprising an encoding module configured to convert
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`the images to a format meeting the requirements of each
`network access device.
`Claim 15:
`[15] The gaming server system of claim 9, further
`comprising an encryption module, the encryption module
`configured to encrypt the plurality of images
`communicated to each network access device.
`Claim 17:
`[17p] A method for generating a game outcome with a
`gaming server system configured to communicate with a
`plurality of network access devices that are
`communicatively coupled to a network, the gaming
`server system comprising:
`[17a] enabling a verification system to receive user
`identification information from at least one network
`access device;
`[17b] verifying with the verification system that the user
`accessing the at least one network access device is a
`registered user by comparing the user identification
`information to registration data stored in a registration
`database;
`[17c] generating, with a centralized gaming server
`communicatively coupled to each of the plurality of
`network access devices, at least one random game
`outcome with random generation at the centralized
`gaming server;
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`Declaration of Stacy Friedman
`U.S. Patent No. 8,747,229
`[17d] determining one or more prizes associated with the
`random game outcome with a paytable module associated
`with the centralized gaming server; and
`[17e] communicating a plurality of images corr