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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`IGT and IGT CANADA SOLUTIONS ULC,
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`ZYNGA INC.,
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`Defendant.
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`Plaintiffs,
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`v.
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`C.A. No. 6:21-CV-00331-ADA
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`Judge: Honorable Alan D. Albright
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`PLAINTIFFS’ SECOND AMENDED FINAL INFRINGEMENT CONTENTIONS
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`Pursuant to the Court’s Order granting leave to amend (see Dkt. 106), Plaintiffs IGT (“IGT
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`US”) and IGT Canada Solutions ULC (“IGT Canada”) (together, “IGT”) hereby provide these
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`Second Amended Infringement Contentions to Defendant Zynga Inc. (“Zynga”). As attached
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`hereto, these amended contentions supplement and supersede Exhibit C to IGT’s original Final
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`Infringement Contentions, served March 16, 2022. In all other cases, however, IGT incorporates
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`by reference its original Final Infringement Contentions (Exhibit F) and First Amended Final
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`Infringement Contentions (Exhibits A, B, D, and E), served June 23, 2022, including all of IGT’s
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`disclaimers, objections, and reservations of rights as if fully set forth herein.
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`Fact discovery is closed. See Dkt. 97. These contentions are based on the information that
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`has been provided to IGT to date, and IGT expressly reserves the right to revise, amend, and/or
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`supplement these infringement contentions, including after Zynga provides further discovery or
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`any other pertinent information, after receiving new or modified claim constructions from the
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`Court, or for any other reason(s) contemplated by the Federal Rules of Civil Procedure, the Court’s
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`Local Rules and Standing Orders, or otherwise as allowed by the Court. IGT also reserves all
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`rights to rely upon additional information and documents in support of its infringement
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`contentions.
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`Zynga Ex. 1019, p. 1
` Zynga v. IGT
` IPR2022-00199
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`Ex. C: ’089 Patent
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`Claim 28
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`Zynga’s Accused Methods
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`Further, if the claim requirement of “a software authorization agent” as that element appears in the
`claims of the ’089 Patent is found not to be literally infringed, it is infringed under the Doctrine of
`Equivalents. Zynga’s Accused Methods perform the same function as the claimed software
`authorization agent (e.g., they ensure that gaming software transfers an downloads are authorized), in
`the same way (i.e., by referring to a transaction database or other repository of information defining
`authorized software transfers), to achieve the same result (e.g., allowing authorized software transfers
`and rejecting unauthorized software transfers). Any difference between Zynga’s authorization
`components and functions and the claimed “software authorization agent,” if any, is insubstantial.
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`Additionally, if the claim requirement of “gaming software” as that element appears in the claims of
`the ’089 Patent is found not to be literally infringed, it is infringed under the Doctrine of
`Equivalents. Zynga’s Accused Methods perform the same function as the claimed gaming software
`(e.g., they provide requisite game assets, instructions, data, and other procedures relating to
`gameplay), in the same way (i.e., via computer software), to achieve the same result (e.g., playing a
`game on any supported hardware platform). Any difference between Zynga’s cookies, game asserts,
`game state data, or other game-related software components and the claimed “gaming software,” if
`any, is insubstantial.
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`5
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`Zynga Ex. 1019, p. 2
` Zynga v. IGT
` IPR2022-00199
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