UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ZYNGA INC.,
`
` PETITIONER,
`
` V.
`
` PATENT OWNER,
`
` PATENT OWNER.
`
` _______________________________
`
` U.S. PATENT NO. 7,168,089
`
` CASE NO. IPR2022-00199
`
` ZOOM VIDEOCONFERENCE DEPOSITION
`
` CRAIG E. WILLS, Ph.D.
`
` MONDAY, NOVEMBER 14, 2022
`
`JOB NO. 5565042
`
`REPORTED BY: DAYNA HESTER, C.S.R. 9970
`
`Veritext Legal Solutions
`866 299-5127
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`Zynga Ex. 1018, p. 1
` Zynga v. IGT
` IPR2022-00199
`
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ZYNGA INC.,
`
` PETITIONER,
`
` V.
`
` PATENT OWNER,
`
` PATENT OWNER.
`
` _______________________________
`
` U.S. PATENT NO. 7,168,089
`
` CASE NO. IPR2022-00199
`
` ZOOM VIDEOCONFERENCE DEPOSITION
`
` CRAIG E. WILLS, Ph.D.
`
` MONDAY, NOVEMBER 14, 2022
`
`JOB NO. 5565042
`
`REPORTED BY: DAYNA HESTER, C.S.R. 9970
`
`Veritext Legal Solutions
`866 299-5127
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`Zynga Ex. 1018, p. 1
` Zynga v. IGT
` IPR2022-00199
`
`
`
`ZOOM VIDEOCONFERENCE DEPOSITION OF CRAIG E. WILLS,
`PH.D., TAKEN ON BEHALF OF PETITIONER ZYNGA INC., AT
`9:32 A.M., EASTERN STANDARD TIME, MONDAY,
`NOVEMBER 14, 2022, WITH THE WITNESS, COUNSEL, AND COURT
`REPORTER APPEARING REMOTELY VIA ZOOM VIDEOCONFERENCE,
`BEFORE DAYNA HESTER, C.S.R. NO. 9970.
`
`APPEARANCES OF COUNSEL:
`FOR PETITIONER:
` ORRICK, HERRINGTON & SUTCLIFFE LLP
` BY: K. PATRICK HERMAN, ESQ.
` (PRESENT VIA ZOOM VIDEOCONFERENCE)
` 51 WEST 52ND STREET
` NEW YORK, NEW YORK 10019
` (212) 506-3596
` PHERMAN@ORRICK.COM
`
`FOR PATENT OWNER:
`
` BAKER & HOSTETLER LLP
` BY: ROBERT L. HAILS, JR., ESQ.
` (PRESENT VIA ZOOM VIDEOCONFERENCE)
` 1050 CONNECTICUT AVENUE, NW, SUITE 1100
` WASHINGTON, D.C. 20036
` (202) 861-1692
` RHAILS@BAKERLAW.COM
`
` BAKER & HOSTETLER LLP
` BY: JEFFREY W. LESOVITZ, ESQ.
` (PRESENT VIA ZOOM VIDEOCONFERENCE)
` 1735 MARKET STREET, SUITE 3300
` PHILADELPHIA, PENNSYLVANIA 19103-7501
` (215) 568-3100
` JLESOVITZ@BAKERLAW.COM
`
` -- APPEARANCES CONTINUED ON NEXT PAGE --
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`Zynga Ex. 1018, p. 2
` Zynga v. IGT
` IPR2022-00199
`
`
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`A P P E A R A N C E S O F C O U N S E L ( C O N T I N U E D ) :
`
`F O R P A T E N T O W N E R ( C O N T I N U E D ) :
`
` B A K E R & H O S T E T L E R L L P
`
` B Y : S C O T T A . S K I L E S , E S Q .
`
` ( P R E S E N T V I A Z O O M V I D E O C O N F E R E N C E )
`
` 3 1 2 W A L N U T S T R E E T , S U I T E 3 2 0 0
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` C I N C I N N A T I , O H I O 4 5 2 0 2
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` ( 5 1 3 ) 9 2 9 - 3 4 0 0
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` S S K I L E S @ B A K E R L A W . C O M
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`Zynga Ex. 1018, p. 3
` Zynga v. IGT
` IPR2022-00199
`
`
`
` I N D E X
`
`DEPONENT EXAMINATION PAGE
`
`CRAIG E. WILLS, PH.D.
`
` BY MR. HERMAN 6
`
` BY MR. HAILS 83
`
` QUESTIONS INSTRUCTED BY COUNSEL NOT TO ANSWER
`
` (NONE.)
`
` E X H I B I T S
`
`EXHIBIT NO. PAGE DESCRIPTION
`
`EXHIBIT 1001 20 FILE TITLED "EX 1001 - US7168089.PDF"
`
`EXHIBIT 1013 40 FILE TITLED "EX 1013 - US7931533 TO
`
` LEMAY.PDF"
`
`EXHIBIT 1020 57 FILE TITLED "EX 1020 - WILLS,
`
` CHARACTERISTICS OF MOBILE WEB CONTENT.PDF"
`
`EXHIBIT 1021 63 FILE TITLED "EX 1021 - WILLS, EXPERIENCE
`
` WITH WEBWARE.PDF"
`
`EXHIBIT 1023 67 FILE TITLED "EX 1023 - GAME.PDF"
`
`EXHIBIT 1024 67 FILE TITLED "EX 1024 - GAME 2.PDF"
`
`EXHIBIT 2031 9 FILE TITLED "EX 2031 - WILLS
`
` DECLARATION.PDF"
`
`EXHIBIT 2032 9 FILE TITLED "EX 2032 - WILLS CV.PDF"
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`Page 4
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`Zynga Ex. 1018, p. 4
` Zynga v. IGT
` IPR2022-00199
`
`
`
` ZOOM VIDEOCONFERENCE
`
` MONDAY, NOVEMBER 14, 2022
`
` 9:32 A.M., EASTERN STANDARD TIME
`
` THE REPORTER: Good morning.
`
` Pursuant to Federal Rules of Civil Procedure, I
`
`am obligated to state the following as a read-on:
`
` My name is Dayna Hester. I am the court
`
`reporter. I am contracted with the firm Veritext Legal
`
`Solutions located in Los Angeles, California.
`
` We are going on the record at 9:31 a.m. East
`
`Coast time on November 14, 2022.
`
` This is the remote video appearance deposition
`
`of CRAIG E. WILLS, Ph.D., taken by counsel for
`
`Petitioner in the matter of Zynga Inc. versus Patent
`
`Owner, filed in United States Patent and Trademark
`
`Office, before the Patent Trial and Appeal Board. Case
`
`Number IPR2022-00199.
`
` All participants attending remotely, would you
`
`please state your appearance and affiliations for the
`
`record beginning with the noticing attorney.
`
` MR. HERMAN: Good morning.
`
` This is Patrick Herman from Orrick Herrington &
`
`Sutcliffe here on behalf of Petitioner Zynga.
`
` MR. HAILS: Good morning.
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` Zynga v. IGT
` IPR2022-00199
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` This is Bob Hails from Baker Hostetler on
`
`behalf of Patent Owner.
`
` THE REPORTER: And we have Jeffrey Lesovitz on
`
`the line and Scott Skiles.
`
` Okay. Mr. Wills, please raise your right hand.
`
` THE WITNESS: [Witness did as requested].
`
` THE REPORTER: Do you affirm the testimony you
`
`are about to give in the cause now pending will be the
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`truth, the whole truth, and nothing but the truth?
`
` THE WITNESS: I do.
`
` THE REPORTER: Thank you.
`
` THE WITNESS: It is "Wills," Dayna.
`
`When you -- initially you made it "Willis," but there
`
`you made it "Wills." So sorry.
`
` CRAIG E. WILLS, Ph.D.
`
` having been first duly sworn, was examined
`
` and testified as follows:
`
` EXAMINATION
`
`BY MR. HERMAN:
`
` Q. Good morning, Dr. Wills.
`
` A. Good morning.
`
` Q. You have been deposed before; correct?
`
` A. I have.
`
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`Zynga Ex. 1018, p. 6
` Zynga v. IGT
` IPR2022-00199
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` Q. So despite your prior experience, I'm going to
`
`spend a moment this morning going through a view basic
`
`ground rules to make sure we're on the same page.
`
` The first, as you have seen and heard, there is
`
`a court reporter here today. And because of that, it's
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`important that you respond verbally so that the reporter
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`can record your testimony.
`
` Is that okay?
`
` A. Yes.
`
` Q. And it is also important that we not talk over
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`each other so that we have a clear record. And I'll do
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`my best to wait for you to finish answering before
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`asking another question, and I also ask that you wait
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`until I am done with my question before answering.
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` And it's also important not to interject in the
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`middle of a question with an -- like, an "okay" or
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`another kind of verbal utterance.
`
` Is that okay?
`
` A. Yes.
`
` Q. Next, you are entitled to a question that you
`
`understand. So if anything I ask during the day today
`
`is unclear, please feel free to ask for a clarification.
`
`Otherwise, I'll assume we are on the same page.
`
` Is that okay?
`
` A. That is okay.
`
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`Zynga Ex. 1018, p. 7
` Zynga v. IGT
` IPR2022-00199
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` Q. And next, I ask that you not look at anything
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`during your deposition besides the documents that I give
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`you. And that if you do look at anything, I ask that
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`you tell me.
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` The one exception to that is, as we noted
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`before, you have a physical copy -- a clean physical
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`copy of your declaration, and you are free to refer to
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`that.
`
` I just ask that you let me know when you are
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`doing so.
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` Is that okay?
`
` A. Yes. That's fine. I mean -- and just to be --
`
`just to be clear, I do have clean copies of, you know,
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`other documents, exhibits related, you know.
`
` Q. So if at any point during the deposition you
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`refer to one of those, I ask that you just let -- let me
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`know that you are doing so.
`
` Is that okay?
`
` A. Very good. Yes.
`
` Q. And next, I ask that you don't have any side
`
`conversations during the course of the deposition or use
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`technology like your phone or your computer to engage in
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`communication with anyone during the deposition.
`
` Is that okay?
`
` A. That is -- that is clear. Yes.
`
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`Zynga Ex. 1018, p. 8
` Zynga v. IGT
` IPR2022-00199
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` Q. Now, is there anything that would prevent or
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`interfere with your testimony today?
`
` A. Not that I am aware of. No.
`
` Q. Okay. So I have put three previously marked
`
`exhibits into the "Marked Exhibit" folder. And one of
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`those is Exhibit 2031. Can you find that for me.
`
` (Exhibit 2031, a previously marked
`
` document, is attached for reference.)
`
` THE WITNESS: 2031. Let's see, that -- that
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`appears to be my declaration.
`
`BY MR. HERMAN:
`
` Q. So Exhibit 2031 is the declaration that you
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`authored in this proceeding, which is IPR2022-00199; is
`
`that right?
`
` A. I do have that, and I do see the three -- the
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`three documents there.
`
` Q. Okay. And Exhibit 2032, that is a copy of your
`
`CV that you attached to your declaration; is that right?
`
` (Exhibit 2032, a previously marked
`
` document, is attached for reference.)
`
` THE WITNESS: Let me -- indeed -- indeed, it
`
`is. Yes.
`
`BY MR. HERMAN:
`
` Q. Okay. And if you can go back to Exhibit 2031,
`
`that's your declaration.
`
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`Zynga Ex. 1018, p. 9
` Zynga v. IGT
` IPR2022-00199
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` And I would like you to turn to Page 78 and, in
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`particular, Paragraph 143 on that page.
`
` A. Sorry. I am going to look at the hardcopy
`
`here.
`
` Paragraph 143?
`
` Q. Yes. Paragraph 143, Page 78.
`
` A. Yes.
`
` Q. So the second sentence of that paragraph reads
`
`[as read]:
`
` "A POSITA that reads claims 28 and 84
`
` expects that the games can be run on the
`
` second gaming device once the gaming software
`
` is transferred."
`
` Do you see that?
`
` A. I do.
`
` Q. So what do you mean when you use the word "run"
`
`in that sentence?
`
` A. From a standpoint, I would say "run" is
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`equivalent to execute.
`
` Q. So would it be fair to say that it is the
`
`computer or device on which the gaming software is
`
`present that runs the game?
`
` Is that true?
`
` A. Yes. That, in this the case, it is the second
`
`gaming device that is running the game -- gaming
`
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`Page 10
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`Zynga Ex. 1018, p. 10
` Zynga v. IGT
` IPR2022-00199
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`software.
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` Q. And running the game is different from playing
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`the game; right? It's the player who plays the game,
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`and it's the device that runs the game; true?
`
` A. Yes. The player at the -- at the device is
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`playing the game.
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` Q. And it is your opinion that the software that
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`is transferred from the first to the second gaming
`
`devices of claims 28 and 84 must be what actually runs
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`the game on the second gaming device.
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` Is that true?
`
` A. It is -- it is my opinion that the software
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`transferred from the first to the second gaming device
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`contributes to running the game on the second device.
`
`Yes.
`
` Q. So it's not just enough for the game to be
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`playable on the second device with the game's code
`
`executed somewhere else.
`
` Is that true?
`
` A. Are we -- is this in the context of the
`
`'089 patent that you are asking this question?
`
` Q. In the context of the claims --
`
` A. Claims --
`
` Q. -- claims 28 and 84 of the '089 patent?
`
` A. Okay. I'm sorry. Can you ask that again. I'm
`
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`Zynga Ex. 1018, p. 11
` Zynga v. IGT
` IPR2022-00199
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`just -- I wanted to clarify the point. I'm sorry.
`
`Please ask that question again.
`
` Q. Okay. So is not enough, in your opinion, for
`
`the game to be playable on the second gaming device with
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`the game's code being executed somewhere else?
`
` A. By "not enough," you mean not enough relative
`
`to claims 28 and 84 here?
`
` Q. That's right. Yes.
`
` A. Well -- and certainly claim 28 does talk about
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`gaming software which runs on the gaming machine or the
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`gaming device here.
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` Q. So in your view, whatever is transferred to the
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`second gaming device in the context of the claims must
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`be what actually runs the game, as opposed to just
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`allowing it to be played by the player using that second
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`gaming device?
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` A. Certainly what is transferred contributes to
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`that gaming software that is run on, in this case, the
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`second gaming device.
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` Q. And by "contributes," you don't mean just
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`contributes to making the game able to be played.
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`Contributes to actually running the game on the second
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`gaming device; true?
`
` A. Then -- yes, in running the game on the second
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`device, what is transferred is part of that software
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`Zynga Ex. 1018, p. 12
` Zynga v. IGT
` IPR2022-00199
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`that -- and used by that software that runs. Yes.
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` Q. Now, so going back to this Paragraph 143 on
`
`Page 78, you cite to both -- well, you cite to claim 28;
`
`is that right?
`
` A. Yes. I believe I excerpt here from claim 28.
`
` Q. And that's -- you see, there is a cite that
`
`says, "See, for example, claim 28," and there's a
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`parenthetical, that's the excerpt you are referring to?
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` A. Yes.
`
` Q. Okay. And in that excerpt, you characterize
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`the claim as [as read]:
`
` "(Reciting a 'transfer [of] gaming
`
` software to a second gaming device,' 'wherein
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` the gaming software is for' uses (a)-(e),
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` which are run 'on a gaming machine.'"
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` Do you see that?
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` A. I do.
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` Q. So you are stating here that the claims require
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`gaming software that is, quote, "run on a gaming
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`machine"; is that right?
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` A. That is what I am saying there is -- is part of
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`claim 28, yes.
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` Q. And it's that understanding of claim 28 that
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`led you to conclude that the HTML files transferred by
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`Goldberg system are not the claimed downloaded gaming
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`Zynga Ex. 1018, p. 13
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`software.
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` Is that fair?
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` A. In my report here, I cite a -- a number of
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`reasons for that -- for that opinion. But, certainly,
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`this is -- what we have here in Paragraph 143 is -- is
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`part of that.
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` Q. All right. So the fact that the claims require
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`gaming software run on a gaming machine is part of the
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`basis of your opinion; correct?
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` A. Yes. I would say that is fair. It is part of
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`my -- the basis of my opinion.
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` Q. Okay. Now, can you turn to Page 81 and, in
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`particular, about the middle of Paragraph 149 on that
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`page.
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` Let me know when you are there.
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` A. [Witness complies].
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` Yes. I am -- I am there here on my hard copy.
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` Q. Okay. So in Paragraph 149, you start with
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`two definition quotes.
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` Do you see that?
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` A. I start with [as read]:
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` "Goldberg's...aligns with ordinary
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` understandings of HTML at the time of the
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` invention."
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` Yes.
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`Zynga Ex. 1018, p. 14
` Zynga v. IGT
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` Q. And then there is two, what appear to be,
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`quotes of definitions; correct?
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` A. There are, yes.
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` Q. Then immediately below that there's a sentence
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`that reads [as read]:
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` "A POSITA would recognize that, even after
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` the web pages are received by Internet client
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` nodes 318, the Internet clients nodes 318 are
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` incapable of running a game."
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` Do you see that?
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` A. I do see that sentence, yes.
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` Q. All right. So, again, here you are using the
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`word "running"; is that right?
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` A. I am certainly using the word "running."
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` Q. And this, again, refers to execution on the
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`Internet client nodes; is that right?
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` A. Yes. I think that that is a -- a "running" and
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`"executing" would be synonymous here, yes.
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` Q. So this is you, again, expressing your view
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`that the claims require that the second gaming device be
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`the device that engages in the running of a game.
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` Is that true?
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` A. The running of the software of -- the running
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`of the gaming software. Yes.
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` Q. So in Goldberg, players can play a game on the
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`Page 15
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`Zynga Ex. 1018, p. 15
` Zynga v. IGT
` IPR2022-00199
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`Internet client nodes 318; correct?
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` A. Yes. Players play -- play the game from a --
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`from the end device. Yes.
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` Q. All right. And there is software on that
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`player's end device that allows the players to play that
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`game; correct?
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` A. Yes. There is browsing software -- browser
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`software there that -- as disclosed by Goldberg, that
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`allows that playing to happen.
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` Q. Okay. But the underlying logic that
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`essentially controls the game flow or the game progress,
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`that logic is running on the casino servers in Goldberg;
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`correct?
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` A. I believe that logic -- I would characterize it
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`that -- at the -- at the servers -- I think -- Goldberg
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`calls it the -- in Figure 3, calls it "website" where
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`that logic is.
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` Q. But it's not on the Internet client nodes.
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`It's on the website, the logic, in Goldberg; is that
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`right?
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` A. Correct. In Goldberg it is at the website, and
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`it is not at the client device.
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` Q. Okay. So when you say that -- when you use the
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`word "running" here in Paragraph 149, what you believe
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`the claims require is that logic actually be running on
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`Zynga Ex. 1018, p. 16
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`the Internet client nodes.
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` Is that true?
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` A. That the -- that the gaming software needs to
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`be running here on the Internet client nodes.
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` Q. All right. So the portion of the gaming
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`software that determines the game flow, in your view
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`that needs to be running on the internet client nodes;
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`correct?
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` A. Yes. That's part of the gaming software that
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`we're looking at in terms of -- is that -- that that
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`software is not executing on the gaming device.
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` Q. Now, if you could turn to Page 89 and, in
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`particular, Paragraph 162.
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` A. 162. What I see starts with something from
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`Mr. Crane.
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` Q. That's right.
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` A. Okay.
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` Q. And there's also a sentence in that paragraph
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`that begins with the word "first." If you can find that
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`for me.
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` A. Pardon?
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` Q. There is a sentence that begins with the word
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`"first."
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` A. Yes. I do see.
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` Q. And that goes on to read [as read]:
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`Zynga Ex. 1018, p. 17
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` "In Goldberg's system, the web pages are
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` neither run nor installed on the Internet
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` client nodes 318."
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` Do you see that?
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` A. I do see that sentence. Yes.
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` Q. So in that sentence you use both the words
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`"run" and then "installed"; correct?
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` A. I do.
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` Q. In your view, do they need to be, one,
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`installed; and, two, run on the second gaming device to
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`be gaming software, as that term is used in claims 28
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`and 84?
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` A. They -- they use both the word "run" and
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`"installed." So neither run. So those web pages are
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`not executing on the client device. And neither are
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`those web pages installed; in other words, do they have
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`a long-term presence on the Internet client nodes.
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` Q. And you believe that something can only be
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`gaming software if it is both, one, executed; and it's,
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`two, installed on the second gaming device; true?
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` A. No. I'm simply making the point that
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`neither -- neither of those conditions are true in
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`Goldberg's system.
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` Q. So my question is does that matter? So if it's
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`not required by the claims, it doesn't matter. In your
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`Zynga Ex. 1018, p. 18
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`view, does it -- are those two things required by the
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`claims?
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` A. Well, certainly the -- going back to claim 28,
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`that -- that software is run on the -- the gaming
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`software is run on the client node. We have established
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`that that is true. Okay.
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` In this particular case, I -- I'm adding a
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`parenthetical remark that -- where in this case those --
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`those web pages are not -- are not installed in
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`Goldberg's system.
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` Q. So my question is, is that a requirement of the
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`claims? Does the claims require that the gaming
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`software that is downloaded to the second gaming device
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`be installed on the second gaming device?
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` A. I don't -- the claims do not specifically talk
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`about claims 28 and 84 of the '089 patent. They do not
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`specifically talk about installing on the Internet
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`client nodes.
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` Q. Okay. So whether or not the gaming software
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`is -- can be considered installed or not, it is not, in
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`your view, something that is required or something that
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`can distinguish the claims from the prior art; correct?
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` A. Certainly the claim that -- the claim language
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`in claim 28 is that they -- that the gaming software
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`needs to run on the Internet client nodes.
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`Zynga Ex. 1018, p. 19
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` Q. So the gaming software only needs to run, in
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`your view, in the Internet -- or on the second gaming
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`device. It does not necessarily need to be installed;
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`true?
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` A. It is not installed on the -- on Goldberg's
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`system, but the claim -- claim 28 does not explicitly
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`address the notion of whether or not software is
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`installed.
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` Q. So now I would like you to look at
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`Exhibit 1001.
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` Do you have a copy of that?
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` (Exhibit 1001, a previously marked
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` document, is attached for reference.)
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` THE WITNESS: I think I do. Let me see.
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` So we have the '089 -- '089 patent here. Okay.
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`BY MR. HERMAN:
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` Q. So Exhibit 1001 is the '089 patent at issue in
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`this proceeding; correct?
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` A. Yes. Yes, it is.
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` Q. Do --
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` A. I do have a hard copy of it.
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` Q. And you are free to look at that, if you would
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`prefer.
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` A. Okay.
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` Q. And you reviewed the '089 patent in crafting
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`Zynga Ex. 1018, p. 20
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`your declaration in this case; correct?
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` A. Yes.
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` Q. And you reviewed both the claims and the
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`specifications in arriving at your opinions?
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` A. Yes, I did.
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` Q. And you are generally familiar with the
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`claims -- at least the claims that are at issue in this
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`proceeding and the specification?
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` A. Yes.
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` Q. Now, I would like you to turn to claim 28, if
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`you could, for me. And if it helps, that claim is found
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`on Page 41 of Exhibit 1001.
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` A. Yes. Column 43.
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` Q. Now, that claim 28 does not use the word "run";
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`correct?
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` A. I do not see the word "run." No.
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` Q. Now, the claim includes a final clause that
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`begins with the word "Wherein."
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` Do you see that?
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` A. Yes. I do see that on the clause.
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` Q. And that clause begins by reading [as read]:
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` "Wherein the gaming software is for at
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` least one of a) a game of chance played on a
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` gaming machine [comma], b) a bonus game of
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` chance played on a gaming machine...."
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`Page 21
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`Zynga Ex. 1018, p. 21
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` Do you see that?
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` A. I do.
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` Q. So what I just read there uses the word
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`"played"; is that right?
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` A. It does use the word "played."
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` Q. And it does not use the word "run"; correct?
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` A. The claim does not use the word "run" there.
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` Q. And I believe you testified previously that it
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`is the player that plays the game; correct?
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` A. A player does play the game from the gaming
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`machine, yes.
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` Q. Now, if you could turn back to Exhibit 2031.
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`That is your declaration.
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` A. Yep.
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` Q. And I would like you to turn to Page 21 and, in
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`particular, Paragraph 43.
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` A. 21. Page 21, Paragraph 43, [as read]:
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` "Goldberg discloses that..."?
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` Q. Yes.
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` That paragraph goes on to read [as read]:
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` "As a game unfolds, the blackjack
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` driver 26 fields player requests received
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` from an Internet client node 318, and it
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` generates new game representations that are
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` sent to the Internet client node 318 in
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`Zynga Ex. 1018, p. 22
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` response."
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` You see that?
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` A. I do.
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` Q. Now, those new game representations that are
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`sent to the Internet client node 318, those are in
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`Goldberg HTML pages; correct?
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` A. Yes. That is my understanding that these
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`representations are HTML pages sent to the client
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`devices.
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` Q. Now, if you'll turn to Page 28 and, in
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`particular, Paragraph 53.
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` A. [Witness complies].
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` Okay. Beginning "The dub-dub-dub server."
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` Q. That's right.
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` A. Sorry. That was my abbreviation -- my
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`abbreviation for it.
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` Q. And I think by "dub-dub-dub" you meant WWW; is
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`that correct?
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` A. I'm sorry. I did, indeed. There was a
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`Worldwide Web Conference that I was involved with, and
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`we would call it the "dub-dub-dub conference." So...
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` Q. So there is a block quote in that Paragraph 53,
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`and below that block quote there is a sentence that
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`reads [as read]:
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` "The CGI scripts 348 generate outputs
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`Zynga Ex. 1018, p. 23
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` representing new game configurations as they
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` are developed by the blackjack driver 26."
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` Do you see that?
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` A. I do see that.
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` Q. Now, the CGI scripts 348, those are running on
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`Goldberg's website or web server or casino server, or
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`whatever you want to refer to that entity; right?
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` A. They -- yes. According to the figures, they
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`are part of the website. Yes. The CGI scripts.
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` Q. Those "new game configurations" that you are
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`referring to here in Paragraph 53, those are the same
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`thing as the new game representations that we talked
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`about a second ago in Paragraph 43, the HTML pages that
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`are output; correct?
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` A. Yes. That is my understanding.
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` Q. And those output HTML pages are meant for and
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`eventually sent to the client devices; correct?
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` A. Yes. That is my understanding that in Goldberg
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`those are sent to the -- those HTML pages are sent to
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`the client device.
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` Q. And those HTML pages include new game
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`configurations or new game representations; correct?
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` A. They contain whatever is generated by the
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`CGI scripts.
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` Q. And what is generated is a representation or
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`Zynga Ex. 1018, p. 24
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`configuration of the game; correct?
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` A. A configuration of the current -- current --
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`the current game, yes.
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` Q. Now, if you turn to Page 62 of your declaration
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`and, in particular, Paragraph 116.
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` A. Paragraph -- Paragraph 116 begins on Page 61?
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` Q. Yes. But I would like to direct your attention
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`to that paragraph --
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` A. No. That's fine. I just want to make sure I'm
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`with you.
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` Q. All right. So at the top of the Page 62, it's
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`a continuation of Paragraph 116, which starts on the
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`previous page; is that right?
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` A. Uh-huh. Yes.
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` Q. And at the top of Page 62, there's a sentence
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`that reads [as read]:
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` "Both the HTML web pages and the ad viewer
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` program 812 must be provided to an Internet
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` client node 318 to provide the gaming
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` functionality and the advertisement supported
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` service that Goldberg describes."
`
` Do you see that?
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` A. I do see that.
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` Q. So one of the things that you are saying here
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`are that the HTML pages need to be provided to the
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`Internet client nodes 318 to provide gaming
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`functionality; correct?
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` A. Yes. To -- to display the gaming
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`representation that we talked about, yes.
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` Q. And the player at that Internet client node 318
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`cannot play a game at the Internet client node unless
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`those HTML pages are sent to the Internet client node;
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`correct?
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` A. Right. The -- the player at the client device
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`plays the game by viewing the content of the -- of the
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`page that is sent and selecting some sort of input
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`available on that page.
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` Q. So receipt of those HTML pages is a necessary
`
`requirement for the player to actually play the game at
`
`the Internet client node; correct?
`
` A. Yes. The browser on their -- on their node.
`
` Q. Now, can you turn to Page 55 for me.
`
` A. Page --
`
` Q. And, in particular, Paragraph 106.
`
` A. Yes.
`
` Q. And here the paragraph reads [as read]:
`
` "Goldberg discloses that web site 308
`
` transmits HTML pages to Internet client
`
` nodes 308 as blackjack games are played on
`
` the blackjack game controller 14. These web
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 26
`
`Zynga Ex. 1018, p. 26
` Zynga v. IGT
` IPR2022-00199
`
`
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`2
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