UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`SIGHTLINE PAYMENTS, LLC,
`
`
`Plaintiff,
`
`
`v.
`
`EVERI HOLDINGS INC., EVERI
`PAYMENTS INC., EVERI GAMES
`HOLDING INC., and EVERI GAMES INC.,
`
`
`Defendants.
`
`
`
`
`
`Case No.: 6:21-cv-01015-ADA
`
`JURY TRIAL REQUESTED
`
`
`
`
`
`
`DEFENDANTS’ PROPOSED CLAIM CONSTRUCTIONS
`
`Defendants Everi Holdings Inc. (“Everi Holdings”), Everi Payments Inc. (“Everi
`
`Payments”), Everi Games Holding Inc. (“Everi Games Holding”), and Everi Games Inc. (“Everi
`
`Games”)(collectively, “Everi” or “Defendants”), by and through counsel of record, Dickinson
`
`Wright PLLC, hereby propose the following preliminary claim constructions for U.S. Patent Nos.
`
`8,708,809 (“the ‘809 Patent”), 8,998,708 (“the ‘708 Patent”), 9,196,123 (“the ‘123 Patent”),
`
`9,466,176 (“the ‘176 Patent”), and 9,785,926 (“the ‘926 Patent”).
`
`Everi may supplement with additional extrinsic evidence based upon Plaintiff’s proposed
`
`constructions and conferences between the parties. Everi also reserves the right to modify,
`
`supplement or amend its claim constructions set forth below, including after receiving Plaintiff’s
`
`proposed claim constructions and the parties’ conferences concerning claim constructions. Everi
`
`also reserves the right to remove claim terms from this list, or add terms to this list based upon
`
`Plaintiff’s claim constructions.
`
`Subject to any agreement of the parties limiting or focusing the subject matter or form of
`
`expert or percipient witness testimony presented in connection with claim construction, Everi may
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`SIGHTLINE PAYMENTS, LLC,
`
`
`Plaintiff,
`
`
`v.
`
`EVERI HOLDINGS INC., EVERI
`PAYMENTS INC., EVERI GAMES
`HOLDING INC., and EVERI GAMES INC.,
`
`
`Defendants.
`
`
`
`
`
`Case No.: 6:21-cv-01015-ADA
`
`JURY TRIAL REQUESTED
`
`
`
`
`
`
`DEFENDANTS’ PROPOSED CLAIM CONSTRUCTIONS
`
`Defendants Everi Holdings Inc. (“Everi Holdings”), Everi Payments Inc. (“Everi
`
`Payments”), Everi Games Holding Inc. (“Everi Games Holding”), and Everi Games Inc. (“Everi
`
`Games”)(collectively, “Everi” or “Defendants”), by and through counsel of record, Dickinson
`
`Wright PLLC, hereby propose the following preliminary claim constructions for U.S. Patent Nos.
`
`8,708,809 (“the ‘809 Patent”), 8,998,708 (“the ‘708 Patent”), 9,196,123 (“the ‘123 Patent”),
`
`9,466,176 (“the ‘176 Patent”), and 9,785,926 (“the ‘926 Patent”).
`
`Everi may supplement with additional extrinsic evidence based upon Plaintiff’s proposed
`
`constructions and conferences between the parties. Everi also reserves the right to modify,
`
`supplement or amend its claim constructions set forth below, including after receiving Plaintiff’s
`
`proposed claim constructions and the parties’ conferences concerning claim constructions. Everi
`
`also reserves the right to remove claim terms from this list, or add terms to this list based upon
`
`Plaintiff’s claim constructions.
`
`Subject to any agreement of the parties limiting or focusing the subject matter or form of
`
`expert or percipient witness testimony presented in connection with claim construction, Everi may
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
`
`rely upon testimony concerning the level and perspective of one skilled in the art at the time of
`
`inventions, the ordinary meaning of claim terms and words used in the patents, and the technology
`
`described in the Patents-in-Suit.
`
`EVERI CLAIM TERMS FOR CONSTRUCTION
`
`
`
`1.
`
`2.
`
`3.
`
`Claim Term/Phrase
`“gaming account”
`‘809 Patent: claim 22
`•
`•
`‘708 Patent: all asserted claims
`(claims 18-20)
`‘123 Patent: all asserted claims
`(claims 1, 8-9, 11, 13)
`‘176 Patent: all asserted claims (1,
`2, 4-5, 7-10, 14-17, 19-20)
`‘926 Patent: all asserted claims
`(claims 1-2, 4-5, 7-10, 12, 14-17,
`19-20)
`
`•
`
`•
`
`•
`
`
`“stored value account”
`
`
`•
`
`•
`
`•
`
`•
`
`•
`
`‘809 Patent: all asserted claims
`(claims 17-20, 22)
`‘708 Patent: all asserted claims
`(claims 18-20)
`‘123 Patent: all asserted claims
`(claims 1, 8-9, 11, 13)
`‘176 Patent: all asserted claims
`(claims 1-2, 4-5, 7-10, 14-17, 19-
`20)
`‘926 Patent: all asserted claims
`(claims 1-2, 4-5, 7-10, 12, 14-17,
`19-20)
`
`
`“stored value payment vehicle”
`
`
`•
`
`•
`
`•
`
`‘809 Patent: all asserted claims
`(claims 17-20, 22)
`‘708 Patent: all asserted claims
`(claims 18-20)
`‘123 Patent: all asserted claims
`(claims 1, 8-9, 11, 13)
`
`Everi’s Proposed Construction
`“any type of financial account (i.e.,
`electronic ledger) or collection of
`financial accounts that are associated with
`a player, and maintained by or on behalf
`of a casino”
`
`“financial account maintained by a
`financial institution”
`
`“physical or virtual payment device used
`to access, and facilitate transactions using,
`funds from the stored value account”
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
`
`Everi’s Proposed Construction
`Plain and ordinary meaning
`
`“a computing system that maintains, and
`processes transactions associated with, the
`stored value account and the stored value
`payment vehicle”
`
`
`“a unique identifier issued by a casino or
`gaming environment to identify a
`particular player”
`
`“information that identifies and
`authenticates a player, including at least a
`player identifier”
`
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`Claim Term/Phrase
`‘transaction facilitator computing system”
`
`
`•
`•
`•
`
`‘123 Patent: claims 8-9, 11, 13
`‘176 Patent: claims 8-10
`‘926 Patent: claims 8-10, 12
`
`
`“issuer processor computing system”
`
`
`‘809 Patent: all asserted claims
`(claims 17-20, 22)
`‘123 Patent: claim 1
`
`
`“player identifier”
`
`
`•
`
`•
`
`•
`
`‘809 Patent: all asserted claims
`(claims 17-20, 22)
`‘123 Patent: claim 1
`
`•
`
`•
`•
`•
`
`•
`•
`•
`
`•
`
`
`“player credentials”
`
`
`‘123 Patent: claim 1
`‘176 Patent: claims 1, 2, 4, 5, 7, 20
`‘926 Patent: claims 1, 2, 4, 5, 7-10,
`12, 20
`
`“player” (Plaintiff’s proposed term)
`
`
`‘809 Patent: claims 17, 20, 22
`‘123 Patent: claims 1, 8, 13
`‘176 Patent: claims 1, 2, 7, 8, 10,
`14, 15, 20
`‘926 Patent: claims 1, 2, 7, 8, 10,
`14, 15, 20
`
`
`“wagering account” (Plaintiff’s proposed
`term)
`
`
`•
`•
`•
`•
`
`‘708 Patent: claim 19
`‘123 Patent: claim 13
`‘176 Patent: claims 2, 10, 15
`‘926 Patent: claims 2, 10, 15
`
`
`
`
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
`
`Dated: March 2, 2022
`
`DICKINSON WRIGHT PLLC
`
`
`/s/ John S. Artz
`
`Christopher E. Hanba (TX Bar No. 24121391)
`Dickinson Wright PLLC
`607 W. 3rd Street, Suite 2500
`Austin, TX 78701
`(512) 582-6889
`Email: CHanba@dickinsonwright.com
`
`John S. Artz
`(Bar No. 68507)
`Dickinson Wright PLLC
`350 S. Main Street, Suite 300
`Ann Arbor, MI 48104
`Telephone:
`(734) 436-7356
`Email: JSArtz@dickinsonwright.com
`
`Attorneys for Defendants
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 2, 2022, a true and correct copy of the foregoing has been
`
`served on all counsel of record via email to the following:
`
`Colby Brian Springer
`cspringer@polsinelli.com
`
`Jonathan R. Spivey
`jspivey@polsinelli.com
`
`Joshua Rayes
`jrayes@polsinelli.com
`
`La Tasha Mabry Snipes
`tsnipes@polsinelli.com
`
`Melenie Van
`MVan@Polsinelli.com
`
`Michael David Pegues
`mpegues@polsinelli.com
`
`
`DATED: March 2, 2022
`
`
`
`
`An employee of Dickinson Wright PLLC
`
`
`
`EVERI EX. 1030
`Everi v. Sightline IPR2022-00696
`
`
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