`
`September25, 2020
`
`VIA EMAIL AND OVERNIGHT DELIVERY SERVICE
`
`Mr. Frank D. Gibeau
`CEO
`Zynga Inc.
`699 Eighth Street
`San Francisco, CA 94103
`
`INFRINGEMENT NOTICE — SERVER-BASED GAMING (“SBG") PATENTS
`
`Dear Mr. Gibeau:
`
`IGT, the global leader in gaming technology, has invested significant research and development
`resources addressing and solving numeroustechnological issues associated with server-based
`gaming. This work hasled to the developmentof a sizable patent portfolio consisting of over 80
`worldwide patents covering fundamental technology necessary for implementing a server-based
`gaming systemthatis reliable, efficient, and secure.
`
`IGT attempted to discuss the value of its SBG patent portfolio in a friendly manner without putting
`Zynga on formal notice of patent infringement.
`IGT acceded to Zynga’s demandsby providing a
`representative list of IGT’s SBG patents with the expectation that the parties would meet to
`discusstheir value and applicability in good faith. Unfortunately, Zynga has rebuffed all attempts
`to discuss the SBG patents through delaying tactics and outright dismissal of IGT’s patents.
`
`As we have been unable to engage Zyngain constructive dialog, IGT regretfully places Zynga on
`notice of infringing one or more claims of the following SBG patents:
`
`1. US Patent No. 7,168,089 entitled Secured virtual network in a gaming environmentis
`practiced by at least Zynga Poker.
`
`2. US Patent No. 7,303,473 entitled Network gaming system is practiced by at least Zynga’s
`“Hit It Rich” slots.
`
`3. US Patent No. 8,221,241 entitled Gaming involving devices in multiple locations is
`practiced by the Zynga Live feature found in Zynga Poker, as well as the Invite Neighbors
`feature found in Farmville 2.
`
`4. US Patent No. 9,129,489 entitled Remote gaming method where venue's system suggests
`different games to remote player using a mobile gaming deviceis practiced by the Loyalty
`Loungefeature found in Zynga’s Wizard of Ozslots.
`
`5. US Patent No. 9,295,908 entitled Systems and methods for remote gaming using game
`recommenderis practiced by at least Zynga’s Wizard of Oz slots.
`
`IGT EXHIBIT 2023
`Zynga v. IGT, IPR2022-00199
`
`
`
`Zynga Inc,
`September 25, 2020
`Page # 2
`
`IGT would prefer to resolve this matter through good faith business discussions and avoid any
`unnecessary distractions resulting from a failure to do so. We respectfully request that you
`appoint a senior memberof your business organization to lead these discussions with your
`General Counsel. Please let us know by October 9, 2020 if Zynga has any desire to finda
`business resolution to this matter.
`
`Respectfully,
`
`Oh.
`
`Renato Ascoli
`CEO, Global Gaming
`
`Enrico Drago, Senior Vice President
`Christopher Spears, General Counsel
`Stephen Calogero, Deputy General Counsel
`
`Zynga
`Phuong Phillips, General Counsel (via email only)
`Mercedes Hobson, IP Counsel (via email only)
`
`
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