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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`Zynga, Inc.,
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`Petitioner,
`
`v.
`
`IGT,
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`Patent Owner
`
`
`
`
`U.S. Patent No. 7,168,089
`
`
`Case No.: IPR2022-00199
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`
`DECLARATION OF CRAIG WILLS, Ph.D
`
`Exhibit 2031
`
`
`IGT EXHIBIT 2031
`Zynga v. IGT, IPR2022-00199
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`

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`Declaration of Craig Wills
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`
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`Ex. 2031
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`I.
`
`IV.
`V.
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 1
`A. Qualifications ........................................................................................ 1
`B.
`Scope of Review .................................................................................... 2
`II. Materials Considered ....................................................................................... 3
`III. The Applicable Law ........................................................................................ 4
`A. General Patent Law ............................................................................... 4
`B.
`Level of Ordinary Skill in the Art ......................................................... 4
`C.
`Principles of Claim Construction .......................................................... 5
`D. Obviousness ........................................................................................... 7
`Introduction to the ‘089 Patent ...................................................................... 10
`Introduction to the Applied Prior Art ............................................................ 14
`A. Goldberg .............................................................................................. 15
`B.
`Olden ................................................................................................... 38
`C.
`D’Souza ............................................................................................... 46
`VI. Claim Constructions ...................................................................................... 49
`VII. Level of Skill in the Art ................................................................................. 50
`VIII. Analysis ......................................................................................................... 54
`A. Mr. Crane’s Reasoning on Motivation to Combine Issues
`Overlooks Important Countervailing Teachings in the Prior Art. ...... 54
`1.
`A POSITA would recognize no motivation to alter
`functionality of the Goldberg HTML files to transfer
`gameplay functionality to a client device. ................................ 55
`The premise on which Mr. Crane proposes to integrate
`Olden’s teachings with Goldberg’s system is fatally flawed.... 63
`Defining entitlements by application functions, as disclosed
`by Olden, runs at cross purposes to Goldberg’s validation
`scheme. ...................................................................................... 71
`
`2.
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`3.
`
`i
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`

`

`C.
`
`B.
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`Even if a POSITA were to integrate Olden’s teachings with
`Goldberg’s system, it would not result in a transfer of
`gaming software to a client device. .......................................... 74
`A POSITA Would Not Recognize Goldberg’s Web Pages as
`“Gaming Software.” ............................................................................ 78
`The Prior Art Fails to Teach Processing the Requests and
`Authorization Messaging as Claimed. ................................................ 96
`D. A POSITA has no Motivation to Combine Goldberg with D’Souza
`and Would Have No Expectation of Success in Doing So. ................ 99
`IX. Declaration in Lieu of Oath ......................................................................... 104
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`4.
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`ii
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`Declaration of Craig Wills
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`Ex. 2031
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`
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`I, Craig Wills, declare as follows:
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`I.
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`
`INTRODUCTION
`I have been retained by Patent Owner, IGT (“Petitioner” or “IGT”), to
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`investigate and opine on certain issues relating to Zynga Inc.’s Petition For Inter
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`Partes Review of U.S. Patent No. 8,795,064 B2, Case No. IPR2022-00200, which
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`challenges validity of claims 28-29, 31-33, 47-50, 84-86, 90-92, and 99-100 of U.S.
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`Patent No. 7,168,089 (“the ’089 patent”).
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`
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`I am being compensated at my usual consulting rate of $400 per hour for my
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`technical analysis in this matter. My compensation is not contingent upon the results
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`of my work.
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`A. Qualifications
` My teaching and research span many areas of computer science, including
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`Internet application performance, distributed computing, networking, and Web
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`privacy. My work has been published in refereed journals and presented at top
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`research conferences. Network gaming has been part of my work on Internet
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`performance and Web privacy. I am a named inventor on eight patents. My work
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`has been cited in popular press venues such as the New York Times, Wall Street
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`Journal, USA Today, Los Angeles Times, San Jose Mercury News, Atlanta Journal-
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`Constitution, InformationWeek, and National Public Radio Science Friday.
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`1
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`Declaration of Craig Wills
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`Ex. 2031
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`
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`I received my B.S. in computer science from University of Nebraska (1982)
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`as well as my M.S. (1984) and Ph.D. (1988) in computer science from Purdue
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`University. I am currently a Professor and the former Head of the Computer Science
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`Department at Worcester Polytechnic Institute (“WPI”). Before my appointment at
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`WPI, I worked at AT&T Bell Laboratories where my work focused on the design
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`and development of an automation tool for network management applications. Since
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`starting at WPI, I have had visiting positions with Cisco Systems, Inc., where I
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`worked with the Network Management Technology Group, and at the School of
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`Mathematical and Computing Sciences at Victoria University of Wellington.
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` My curriculum vitae, which is Ex. 2032, contains a more detailed description
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`of my background.
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`B.
`Scope of Review
`As indicated, I have been tasked to review a petition for inter partes review
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`filed by Zynga, Inc. (“Petitioner” or “Zynga”) relating to the Challenged Claims of
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`the ’089 Patent. I understand that the ’089 Patent is involved in litigation between
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`IGT and Zynga. I have not undertaken a review of other claims from the ’089Patent
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`in developing this declaration.
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`
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`I understand that, in this inter partes review, Zynga asserts that the Challenge
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`Claims are invalid over prior art on the following Grounds:
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`Declaration of Craig Wills
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`Ex. 2031
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`Ground 1: Claims 28-29, 31-33, 47-48, 84-86, 90-92, and 99-100
`purportedly are obvious over Goldberg and Olden.
`Ground 2: Claims 49 and 50 purportedly are obvious over
`Goldberg and Olden in further view of D’Souza.
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`See Petition, paper 1, at 7 (herein “Pet.”). As explained herein, it is my opinion that
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`the Challenged Claims are not obvious for the reasons asserted in Zynga’s Petition.
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`II. MATERIALS CONSIDERED
`I considered the materials referenced in this declaration when developing my
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`opinions, including the following:
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` Zynga Inc.’s Petition for Inter Partes Review of U.S. Patent No.
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`7,168,089, IPR2022-00199, paper 1, and exhibits thereto;
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` Patent Owner’s Preliminary Response, IPR2022-00199, paper 6, and
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`exhibits thereto;
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` Decision Granting Institution of Inter Partes Review 35 U.S.C. § 314,
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`IPR2022-00199, paper 11;
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` Freedman, The Computer Glossary, p. 192, AMACOM (1998) (Ex.
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`2035); and
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` Webster’s New World Computer Dictionary, 10th ed., p. 177, Wiley
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`Publishing (2003), (Ex. 2036).
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`3
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`Declaration of Craig Wills
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`Ex. 2031
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`III. THE APPLICABLE LAW
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`I am not an attorney, and I am not providing any expert opinions on the law.
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`However, I have been advised of certain basic legal principles applicable to my
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`analysis in this report, and I have applied those principles in forming my opinions.
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`Those principles are provided below:
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`A. General Patent Law
`I understand that determining the validity of a patent requires a two-step
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`
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`analysis. First, the meaning and scope of the patent claims are construed, and
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`second, the construed claims are compared to the prior art.
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`
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`I understand that, in the context of an inter partes review, the prior art may
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`comprise patents or printed publications. I also understand that a “printed
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`publication” is a publication sufficiently accessible to the public interested in the art
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`and depends upon dissemination and accessibility.
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`B.
`Level of Ordinary Skill in the Art
`I understand there is a concept in patent law known as the “person having
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`
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`ordinary skill in the art” (“POSITA,” for short). I understand that this concept refers
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`to a person who is trained in the relevant technical field of a patent without
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`possessing extraordinary or otherwise exceptional skill. I further understand that
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`factors such as the educational level of those working in the field, the sophistication
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`of the technology, the types of problems encountered in the art, prior art solutions to
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`those problems, and the speed at which innovations are made may help establish the
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`level of skill in the art. I understand the level of skill of the persons of ordinary skill
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`is to be assessed at the time of the claimed invention.
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`C.
`Principles of Claim Construction
`I understand that, to construe the meaning of a claim term, a court will first
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`
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`look to the claim language itself and its usage in context with other claim terms. I
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`understand that courts will defer to the ordinary and customary meaning that the
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`terms would have to a POSITA at the time of the alleged invention.
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`
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`I also understand that a court will look to intrinsic evidence if the meaning of
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`the term to a person having ordinary skill in the art at the time of the alleged
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`invention is not apparent. I have been informed that this intrinsic evidence includes
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`the context of the words in the claim, the specification of the patent, and the
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`prosecution history of the patent. In fact, I understand that the specification is
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`considered the single best guide to the meaning of a disputed term. I understand
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`that, while the specification is to be used to interpret terms presented in a claim, it is
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`impermissible to import limitations from the specification into a claim.
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` Also, I have been informed that a patentee can become their own
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`“lexicographer” by defining terms within the patent however they wish, as long as
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`Declaration of Craig Wills
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`Ex. 2031
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`they do so explicitly. For evidence that the patentee intended to become their own
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`lexicographer, I understand that the court may look to the intrinsic evidence.
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`
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`I understand that the prosecution history is an important source of intrinsic
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`evidence and generally relevant to the proper interpretation of a claim. For example,
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`I have been informed that the prosecution history can provide additional context that,
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`in addition to the written description, is helpful in interpreting the claims. Further, I
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`have been informed that prosecution history is useful in determining what the
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`patentee believed they originally were claiming, and whether the patentee has
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`narrowed a potential claim construction in an amendment or argument to distinguish
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`the claims over the prior art. Thus, I understand prosecution history is relevant in
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`claim construction.
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`
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`If the meaning of a term is clear from the claim language and the intrinsic
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`evidence, I understand that the claim construction must stop there. I have been
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`informed that only if the meaning of the asserted claims cannot be determined after
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`assessing the intrinsic evidence, may extrinsic evidence be considered. I have been
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`informed that such extrinsic evidence may include expert testimony, dictionaries,
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`and well-known treatises. Even if extrinsic evidence is considered, the claim
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`construction may not be inconsistent with the construction mandated by the intrinsic
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`evidence.
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`Declaration of Craig Wills
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`Ex. 2031
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`I understand that, when a dependent claim recites elements that are comprised
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`by an element of an independent claim, the element that appears in the independent
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`claim has a scope broad enough to encompass the elements of the dependent claim.
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`D. Obviousness
`It is my understanding that, to prove that a claim is invalid for obviousness
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`
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`under 35 U.S.C. § 103 (the pre-America Invents Act version), the challenger of its
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`validity must prove that, for example, two or more prior art references in
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`combination disclose, expressly or inherently, every claim limitation and also that
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`the claim, as a whole, would have been obvious to a person of ordinary skill in the
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`art at the time the alleged invention was made.
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`
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`It is my understanding that the relevant standard for obviousness under 35
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`U.S.C. § 103(a) is as follows:
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`A patent may not be obtained though the invention is not identically
`disclosed or described as set forth in section 102, if the differences
`between the subject matter sought to be patented and the prior art are
`such that the subject matter as a whole would have been obvious at the
`time the invention was made to a person having ordinary skill in the art
`to which said subject matter pertains. Patentability shall not be
`negatived by the manner in which the invention was made.
`In determining whether or not a patented invention would have been obvious,
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`
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`I understand that the following so-called “Graham” factual inquiries must be made:
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`(1) the scope and content of the prior art; (2) the differences between the prior art
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`and the claims at issue; (3) the level of ordinary skill in the pertinent art at the time
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`the alleged invention was made; and (4) any secondary considerations, including
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`commercial success, long felt but unsolved needs, failure of others, etc.
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`I understand that a patent composed of several elements is not proved obvious
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`merely by demonstrating that each of its elements was independently known in the
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`prior art. Most, if not all, inventions rely on building blocks of prior art. The
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`challenger of a patent’s validity must prove that, at the time of the claimed invention,
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`there was a reason that would have prompted a person having ordinary skill in the
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`field of the invention to combine the known elements in a way the claimed invention
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`does, taking into account such factors as:
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`a. whether the claimed invention was merely the predictable result of
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`using prior art elements according to their known function(s);
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`b. whether the claimed invention amounted to nothing more than using a
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`known technique to improve similar devices or methods in the same
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`way;
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`c. whether the claimed invention provides an obvious solution to a known
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`problem in the relevant field;
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`d. whether the prior art teaches or suggests the desirability of combining
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`elements claimed in the invention;
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`Declaration of Craig Wills
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`e. whether the prior art teaches away from combining elements in the
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`claimed invention;
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`f. whether it would have been obvious to try the combinations of
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`elements, such as when there is a design need or market pressure to
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`solve a problem and there are a finite number of identified, predictable
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`solutions; and
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`g. whether the change resulted more from design incentives or other
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`market forces.
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` To find the invention obvious in light of a prior art combination, the prior art
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`combination must have provided a reasonable expectation of success.
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`
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`I further understand that it is not permissible to use hindsight in assessing
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`whether a claimed invention is obvious. Rather, I understand that, to assess
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`obviousness, one places oneself in the shoes of a person having ordinary skill in the
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`relevant field of technology at the time the alleged invention was made who is trying
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`to address the issues or solve the problems faced by the inventor, considering only
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`what was known at the time of the invention and ignoring current knowledge of the
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`inventions.
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`Declaration of Craig Wills
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`Ex. 2031
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` Regarding the fourth step in the four-step process for assessing obviousness
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`(the so-called Graham inquiries), specifically the step involving “objective
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`considerations,” I have been told that some of the factors that may be considered are
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`those of copying, a long felt but unsolved need, failure of others, commercial
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`success, unexpected results created by the claimed invention, unexpected properties
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`of the claimed invention, licenses showing industry respect for the invention, and
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`skepticism of skilled artisans before the invention was made.
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`IV.
`INTRODUCTION TO THE ‘089 PATENT
` The ’089 Patent is directed to managing downloads of gaming software
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`among gaming machines in which a software authorization agent authorizes and
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`monitors transfers:
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`A disclosed gaming machine may securely communicate with devices
`over a public network such as the Internet. … The secure
`communication methods may be used to transfer gaming software and
`gaming information between two gaming devices, such as between a
`game server and a gaming machine. For regulatory and tracking
`purposes, the transfer of gaming software between the two gaming
`devices may be authorized and monitored by a software authorization
`agent.
`Ex. 1001, Abstract.
`
` The ’089 Patent states that electronic download of gaming software allows
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`gaming machines to be reconfigured quickly as game popularity changes:
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`Another desire within the gaming industry is to electronically download
`gaming software from one or more remote locations to a gaming
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`Declaration of Craig Wills
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`Ex. 2031
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`machine. The capability to electronically download gaming software
`is desirable because it may enable gaming machines to be quickly
`reconfigured to account for changes in popularity of various games
`played on the gaming machines and it may simplify software
`maintenance issues on the gaming machine such as gaming software
`updates. … [I]t would be desirable to provide gaming software
`downloading methods for gaming machines that allow gaming software
`to be transferred electronically to the gaming machines from a remote
`location in a secure manner that satisfies regulatory requirements of the
`gaming jurisdiction where the gaming machine is located.
`Id. col. 4:1-24. Gaming software components may be executed on a gaming
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`machine to play, for example, a game of chance. Id. col. 25:38-39.
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` The ’089 Patent discloses a software distribution network that includes
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`gaming machines 54-59 (blue), gaming software content providers 51, 52 (yellow),
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`gaming software distributors 58, 60 (green), and a software authorization agent 50
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`(red):
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`’089 Patent (Ex. 1001), FIG. 8 (annotated)
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`
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`11
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`Declaration of Craig Wills
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`Ex. 2031
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`’089 Patent (Ex. 1001), FIG. 9 (annotated)
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`
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`The ‘089 Patent describes operation of the system in cols. 24:27-31:57. I provide a
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`high-level summary of these components below.
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` The gaming software content providers 51, 52 maintain various gaming
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`software titles that can be downloaded to other devices:
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`A gaming software content provider, such as 51 and 52, may maintain
`a plurality of gaming software titles, versions of gaming software titles
`and gaming software components that may be requested by another
`gaming device for an electronic download. The gaming software
`content provider may download gaming software to various customers
`after the customer has entered a licensing agreement with the content
`provider. Some details of obtaining game licenses for operating gaming
`software on a gaming machine have been described above with respect
`to FIGS. 6 and 7.
`Id. col. 25:27-37.
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`Ex. 2031
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` The gaming software distributors 53, 60 may operate at casinos or other
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`establishments, and may store licensed gaming software for transfer to the gaming
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`machines.
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`The gaming software distributors, such as 53 and 60, may be gaming
`devices, such as game servers, that are maintained by a gaming entity
`such as a casino. For instance, game server 53 may be operated by a
`first casino and game server 60 may be operated by a second casino.
`The game servers may store gaming software that has been licensed to
`the gaming entity from one or more gaming software providers such as
`51 and 52. …
`The game servers operated by a gaming entity may be used to provide
`gaming software to a plurality of gaming machines. For instance, game
`server 53 may be used to provide gaming software to gaming machine
`54, 55, 56 and game server 60 may be used to provide gaming software
`to gaming machines 57, 58 and 59.
`Id. col. 26:31-50.
`
` The gaming machines 55-59 download gaming software from appropriate
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`software distributors 53, 60:
`
`[G]ame server 53 may be used to provide gaming software to gaming
`machine 54, 55, 56 and game server 60 may be used to provide gaming
`software to gaming machines 57, 58 and 59. In one embodiment, the
`game servers may be programmed to download gaming software in
`response to a software request on a gaming machine. For instance, a
`game player playing a game on a gaming machine, such as 55, may
`request to play a particular game of chance on the gaming machine 55
`which is downloaded to the gaming machine from the game server 53.
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`Id.
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`Declaration of Craig Wills
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`Ex. 2031
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` The software authorization agent 50 manages download of gaming software
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`to gaming machines 55-59.
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`In the present invention, gaming software may be transferred between
`various gaming devices, in a gaming software distribution network 90,
`after receiving authorization from a gaming software authorization
`agent 50. … In general, the gaming software authorization agent 50
`approves all gaming software transactions between two gaming devices
`in the gaming software distribution network and stores a record of the
`gaming software transactions.
`Id. col. 24:27-42.
`
` The ’089 Patent discloses that, when a transfer of gaming software is to occur
`
`between a gaming software distributor 53 and another gaming device, a transfer
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`request is made to the software authorization agent 50:
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`[T]he gaming software distributor 53, which may be a game server
`maintained by a casino, may contact the software authorization agent
`50 to request a transfer of gaming software from the gaming software
`provider 51 to the gaming distributor 53. The gaming distributor may
`also contact the software authorization agent to request a transfer of
`gaming software from the gaming software provider 51 to another
`gaming device such as gaming machine.
`Id. col. 28:37-47. “The software authorization agent 50 may approve or deny the
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`request.” When the request is approved, the gaming software distributor 53 “may
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`forward the gaming software to the gaming machine 55.” Id. col. 29:59-66.
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`V.
`
`INTRODUCTION TO THE APPLIED PRIOR ART
` Petitioner adopted a prior art date of December 2000 for purposes of this IPR.
`
`Pet. at 6 (“for purposes of this petition only it has been assumed that the claims have
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`a filing date of December 2000.”). Below, I describe the prior art’s disclosure as it
`
`would have been understood by a POSITA in December 2000.
`
`A. Goldberg
` Goldberg discloses an advertisement-supported gaming system where players
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`may play games asynchronously from each other:
`
`The present invention is a game playing method and apparatus for
`automating games such as blackjack, poker, craps, roulette, baccarat
`and pai gow, wherein players may play continuously and
`asynchronously, and information related to advertised items can be
`exchanged between players and advertisers.
`Ex. 1004, Abstract.
`
` Goldberg discloses an embodiment intended for “use[] within a blackjack
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`gaming establishment such as a casino” (id., col 6:32-45 (describing FIG. 1)) and
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`other embodiments intended “to play blackjack on the Internet” (id., col 6:49-67
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`(describing FIGS. 3, 6, and 8)).
`
` Goldberg’s casino-implemented system is shown in FIG. 1:
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`Declaration of Craig Wills
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`Ex. 2031
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`Goldberg (Ex. 1001), FIG. 1 (annotated)
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`
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`In this embodiment, a blackjack gaming controller 14 (yellow) communicates
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`with one or more gaming stations (orange) via a communication interface:
`
`[T]he embodiment of FIG. 1 presents an architecture for the present
`invention for use on, for example, a local network within a casino,
`wherein low cost gaming stations may be utilized. Accordingly, the
`blackjack gaming system 10 includes a blackjack game controller 14
`electronically connected to one or more potentially remote gaming
`stations 18 so that for each gaming station a player may play blackjack.
`In the blackjack gaming system 10, the blackjack game controller 14
`functions substantially as a dealer would in a manually operated
`blackjack game and each gaming station 18 provides a blackjack player
`with an electronic representation of a blackjack game wherein it may
`appear that the player (i.e., user) at the gaming station 18 is the only
`player playing against the dealer (i.e., "head-to-head" against the
`blackjack game controller 14).
`Id. col. 7:6-20.
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`Declaration of Craig Wills
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`Ex. 2031
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`In the Internet applications (FIGS. 3, 6 & 8), Goldberg’s system has the same
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`basic architecture as the casino embodiment, where blackjack gaming controllers 14
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`(yellow) communicate with Internet client nodes 318 (orange):
`
`
`Goldberg (Ex. 1004), FIG. 3 (annotated)
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`Declaration of Craig Wills
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`Ex. 2031
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`Goldberg (Ex. 1004), FIG. 6 (annotated)
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`Goldberg (Ex. 1004), FIG. 8 (annotated)
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`Declaration of Craig Wills
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`Ex. 2031
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`In each Internet embodiment, the blackjack game controller 14 is placed on a web
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`site 308 that is separate from the Internet client nodes 318 (orange) where the players
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`are located.
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` Goldberg discloses that the architecture of the blackjack game controller 14,
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`when used in the Internet embodiment, is essentially the same as when it is used in
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`the casino embodiment:
`
`FIG. 3 presents a second embodiment of the blackjack gaming system
`of the present invention. In this embodiment, the blackjack game
`controller 14 is substantially the same as described hereinabove [in FIG.
`1]
`Id. col. 14:29-32..
`
`[I]n FIGS. 6A and 6B, there is a game/advertisement controller 604 for
`providing substantially the same functionality as the blackjack game
`controller 14 (FIG. 3) except that games other than blackjack may also
`be played (such as poker, craps, pai gow and roulette).
`Id. col. 21:41-46.
`
`Referring now to an alternative embodiment of the present invention
`presented in FIG. 8, wherein the game/advertisement web site 308
`coordinates with a third party Internet access service provider 810 (or
`interactive cable television provider) for providing Internet 324 (cable
`television) access to users on a reduced cost or free basis once a user
`has registered with the web server 340 (cable television provider).
`Id. col. 28:44-51.
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`In all cases, the blackjack game controller 14 (yellow) contains program
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`modules that play blackjack games:
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` a blackjack driver 26,
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` a wager and accounting modules 30,
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` a blackjack player evaluator module 34 (blue),
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` a card generator module 38 (brown),
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` a house blackjack playing module 42 (green), and
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` a blackjack hand evaluator 46 (red).
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`As explained below, these modules provide total control over the games that are
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`played on the Goldberg system.
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` The blackjack driver 26 coordinates operation of the blackjack game
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`controller 14. It manages communication with the web site’s communication
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`interface, and, ultimately, the Internet client nodes 318. Goldberg states:
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`A blackjack driver 26 exchanges data with the gaming station interface
`22. The blackjack driver 26 substantially coordinates the operation of
`the blackjack game controller 14. In particular, the following
`capabilities are substantially provided by the blackjack driver 26:
`(1.1) identifies each player requesting to play blackjack at one of the
`gaming stations 18;
`(1.2) creates internal data structures for communication with other
`modules of the blackjack game controller 14 regarding each blackjack
`game being played; in particular, blackjack gaming data objects or
`records are (re)instantiated with each player request, such data objects
`providing sufficient information for the blackjack game controller 14
`to properly respond to each received player request;
`(1.3) determines the output of the blackjack game controller 14 to each
`of the active gaming stations 18;
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`(1.4) distributes blackjack gaming data between other modules of the
`blackjack game controller 14; and
`(1.5) provides card representations to gaming stations 18.
`In performing the above tasks, the blackjack driver 26 communicates
`with a blackjack player registration and playing status database 28.
`Id. col. 7:45-67.
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` Goldberg discloses that, as a game unfolds, the blackjack driver 26 fields
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`player requests received from an Internet client node 318, and it generates new game
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`representations that are sent to the Internet client node 318 in response. Goldberg
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`states:
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`the
`in step 430
`Upon receiving a blackjack player request,
`communication interface 22 queues the request and subsequently
`transmits the request to the blackjack driver 26.
`Id. col. 16:14-17.
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` Player requests may request, for example, to play in a new tournament, to play
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`in a new non-tournament game, or to receive a new card in an already-started game:
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`[I]n step 424, the controller 14 waits for a (next) blackjack player input,
`such inputs being, for example, requests to enter a new blackjack
`tournament, requests to commence a new blackjack game within a
`tournament, requests to process a blackjack game play request, a
`request for information regarding the players account, and a request for
`help information (such as how to play blackjack).
`Id. col. 16:7-13. The blackjack driver 26 determines what request is made in a new
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`player request and coordinates with other modules to execute these requests.
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` Goldberg discloses that the wager and accounting module 30 enforces
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`financial limits and performs wagering accounting:
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`[T]he wager accounting module provides the following capabilities:
`(3.1) determines various wagering limit parameters for the next one or
`more blackjack games to be played (e.g., the wagering limit per game
`and the total wagering limit per player); and
`(3.2) performs wagering accounting for each player's wins and losses.
`Thus, the wager accounting module 30 is instrumental in initializing a
`new blackjack game in that this module receives and maintains
`financial information related to each currently active player at a gaming
`station 18. Thus, the wager accounting module 30 has a communication
`data channel with the blackjack player registration and playing status
`database 28 so that the wager accounting module 30 may retrieve
`information for determining whether the player has, for example,
`sufficient financial resources to cover potential wagering losses. Of
`course, to provide waging evaluation information to other controller 14
`modules, the wager accounting module 30 receives identifying
`information from each such module requesting an evaluation.
`Id. col. 8:28-49.
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` Goldberg discloses that the blackjack player evaluator module 34 (blue)
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`determines the options that are available to player as a blackjack game is played and
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`responds to player request within the game:
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`The blackjack driver 26 also communicates with a blackjack player
`evaluator 34. The blackjack player evaluator 34 receives, from each
`player (via instantiations of blackjack gaming data objects from the
`blackjack driver 26), all blackjack player requests except the data from
`each player indicating an amount to be wagered. Thus, the blackjack
`player evaluator 34:
`(4.1) determines each player's options during blackjack games; and
`(4.2) responds to player requests for hits or to, for example, split pairs.
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`Thus, the blackjack player evaluator 34 enforces the gaming
`establishment rules related to pl