`
`E-2
`U.S. PATENT NO. 11,117,056
`
`INFRINGEMENT OF U.S. PATENT NO. 11,117,056 BY PLR’S HOMESCAPES
`
`Plaintiff Flip Phone Games Inc. (“FPG”) contends that PLR Worldwide Sales Limited (“PLR”) makes, uses, sells, offers for sale, and/or
`
`imports into the United States gaming systems, software, and/or methods for controlling devices and games including the Homescapes mobile game,
`
`which acts infringe claims 1 through 16 of U.S. Patent No. 11,117,056, as set forth below. The specific components, systems, and constructs
`
`identified in this chart are for exemplary purposes only and FPG reserves all rights to supplement or amend these disclosures as additional
`
`components, systems, and constructs become known through discovery, as well as after PLR produces documents and source code and/or the Court
`
`construes any terms from the claims of the ’056 patent. PLR induces infringement of the asserted claims by providing instructions or information,
`
`for example on publicly available websites to explain how to use Homescapes in an infringing manner including, inter alia, the PLR website.
`
`See e.g., https://playrix.helpshift.com/hc/en/14-homescapes/
`
`PLR indirectly infringes the ’056 Patent by contributing to the direct infringement by end users by providing Homescapes which is especially
`
`made for use on end-user devices in a manner that infringes and has no substantial non-infringing uses.
`
`
`
`
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`1
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`Playrix Ex. 1009, Page 1 of 40
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`

`

`
`US 11,117,056 to Hartwell, Methods and Systems for Updating In-Game Content
`Compared to: Homescapes
`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`US 11,117,056
`[claim 1, preamble] A
`system for providing
`updated content associated
`with mobile video game to
`a mobile communication
`device, the system
`comprising:
`
`Homescapes by Playrix
`To the extent the preamble is limiting, Homescapes provides a system for updating content associated with the mobile
`video game to a mobile communication device.
`
`https://playrix.helpshift.com/hc/en/14-homescapes/faq/11809-how-often-and-why-do-you-need-to-update-the-game/
`(“We usually release our exciting new updates approximately every 2 months 📆📆”);
`https://playrix.helpshift.com/hc/en/14-homescapes/faq/11810-how-do-i-update-the-game-1670546975/ (“If you still
`don't have access to the update, don't worry. It will become available to you very soon! 🤗🤗 New versions of the game
`are released on different platforms with small delays (sometimes up to several days) ⏰ That happens due to a
`difference in the procedures for checking the update on different platforms. You may need to reinstall the game to get
`the latest available version 😉😉”).
`
`
`Homescapes on the App Store (apple.com) (“Welcome to Homescapes, the most heartwarming game from Playrix's
`Scapes™ series! Solve match-3 puzzles to restore a wonderful mansion on a verdant street. Exciting adventures start
`at the doorstep!
`Beat colorful match-3 levels to renovate and decorate rooms in the mansion, unlocking ever more chapters in the
`exciting family story along the way! What are you waiting for? Make yourself at home!
`The game features:
`● Unique gameplay: help Austin renovate the house by swapping and matching pieces!
`● Interior design: you decide what the house will look like.
`● Exciting match-3 levels: tons of fun, featuring unique boosters and explosive combinations!
`● A huge, beautiful mansion: discover all the secrets it holds!
`● Fantastic characters: watch them live their lives and interact with each other in the in-game social network.
`● A cute pet: meet а naughty and fluffy cat.
`● Invite your Facebook friends to help you create your own cozy atmosphere in the house!”)
`
`
`[1a] a storage medium for Homescapes provides a storage medium for storing in-game video game content. For example, the game is updated
`
`
`
`2
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`Playrix Ex. 1009, Page 2 of 40
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`

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`storing in-game video
`game content;
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`E-2
`U.S. PATENT NO. 11,117,056
`
`frequently with updated game content from the server being stored in a storage medium. Such updates occur when a
`user launches the Homescapes application on a mobile communication device.
`
`
`[1b] a server in
`communication with the
`storage medium; and
`wherein the server is
`configured to:
`receive a request for
`updated content from the
`mobile communication
`device;
`
`
`
`
`
`
`Homescapes is a mobile device game, which is in communication with a game server.
`https://playrix.helpshift.com/hc/en/14-homescapes/faq/1062-system-requirements-1627577130/ (“The minimum
`system requirements for the game are listed below. They may change in the future if program modifications are
`introduced to the game. ��� 1GB of RAM; ��� 500 MB of free space; ��� a stable internet connection.”). Pursuant to
`Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server and client
`side source code or other internal documents and information for the Homescapes game, which is not publicly
`available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses and after
`Playrix produces source code and/or other internal documents and information relevant to this claim element.
`
`Each time the user logs into the game, and at various points throughout gameplay, the Homescapes game connects to
`the server and communicates with it to receive data. As a player progresses through the game, Homescapes
`communicates with the server which is configured to receive requests for updated content from the mobile device.
`
`
`3
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`Playrix Ex. 1009, Page 3 of 40
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`U.S. PATENT NO. 11,117,056
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`The HTTPS traffic between the mobile device and the game server has been captured using the program Fiddler
`Everywhere over a wireless (WiFi) network. When the game application is opened while the game is updating, the
`following screenshots detail the communications sent to/from the mobile device for iOS devices. The server,
`identified here as the Host (homescapes-cdn.playrix.com) is accessed with a URL request and the Get method.
`
`
`
`
`IOS Homescapes – Manifest then updates (Red Box)
`
`Each of these http communications represents a request portion and a response portion. The URLs also indicate that
`they are located in an iOS directory. This indicates that there should also be an Android directory which should be
`different sizes. See Exhibit D-1 where Gardenscapes operates in this manner.
`Homescapes identifies, in response to receiving a request, what in-game video game content to send. As a user
`progresses through Homescapes, the game communicates with the server based on which juncture the user is at in the
`game. The server receives the request from the client regarding what in-game content to send based on where the
`user is in Homescapes.
`
`Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server
`and client side source code or other internal documents and information for the Homescapes game, which is not
`publicly available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses
`and after Playrix produces source code and/or other internal documents and information relevant to this claim
`element.
`In response to receiving a request, the game server pre-selects a message in part based on the model type of mobile
`device it is. For example, on information and belief, the pre-selected message differs based on the model type of the
`mobile communication device. See e.g., analysis of this claim element with respect to Gardenscapes.
`
`
`4
`
`[1c] identify, in response to
`receiving the request, what
`in-game video game
`content to send;
`
`[1d] send a message
`relating to the in-game
`video game content to the
`mobile communication
`
`
`
`Playrix Ex. 1009, Page 4 of 40
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`

`

`
`device in response to
`receiving the request,
`wherein the message is
`pre-selected by the server
`based on a model type
`associated with the mobile
`communication device, a
`service subscription
`associated with the mobile
`communication device, or
`a service provider for the
`service subscription
`associated with the mobile
`communication device; and
`
`[1e] send the in-game
`video game content to the
`mobile communication
`device as the updated
`content for the mobile
`video game.
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server
`and client side source code or other internal documents and information for the Homescapes game, which is not
`publicly available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses
`and after Playrix produces source code and/or other internal documents and information relevant to this claim
`element.
`
`
`
`
`
`
`
`
`
`
`The in-game video game content is sent to the mobile device from the server. As one non-limiting example below,
`when the user reaches a certain threshold in Homescapes the server sends in-game video game content. Pursuant to
`Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server and client
`side source code or other internal documents and information for the Homescapes game, which is not publicly
`available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses and after
`Playrix produces source code and/or other internal documents and information relevant to this claim element.
`
`
`
`
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`5
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`Playrix Ex. 1009, Page 5 of 40
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`

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`E-2
`U.S. PATENT NO. 11,117,056
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`In-game video
`game content
`
`
`
`
`
`FPG incorporates by reference its analysis of Claim 1.
`
`The server provides updated content comprising of promotional content.
`
`
`[Claim 2] The system of
`claim 1, wherein the
`updated content comprises
`promotional content.
`
`
`
`
`
`6
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`Playrix Ex. 1009, Page 6 of 40
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`

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`U.S. PATENT NO. 11,117,056
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`Hidden
`promotional
`content
`
`[Claim 3] The system of
`claim 2, wherein the
`promotional content
`comprises localized
`promotional content based
`on a location of the mobile
`communication device.
`
`
`
`
`
`FPG incorporates by reference its analysis of Claims 1 and 2.
`
`Homescapes provides a system wherein the promotional content comprises localized promotional content based on a
`location of the mobile communication device. Pursuant to Paragraph 3(a)(i) of the Discovery Order, further
`verification of this feature requires review of the server and client side source code or other internal documents and
`information for the Homescapes game, which is not publicly available to FPG. As such, FPG reserves the right to
`supplement these contentions as discovery progresses and after Playrix produces source code and/or other internal
`documents and information relevant to this claim element.
`
`
`Homescapes offers promotional content that is localized to the local language of the user’s location. On information
`and belief, Homescapes is localized to default to the location of the mobile communication device and can then be
`changed manually. https://playrix.helpshift.com/hc/en/14-homescapes/faq/4117-changing-the-language-in-the-game/.
`
`
`
`7
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`Playrix Ex. 1009, Page 7 of 40
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`

`

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`E-2
`U.S. PATENT NO. 11,117,056
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`
`Homescapes distributes promotions “on a random and automatic basis, and they depend on many things such as your
`current game progress, location and so on.” https://playrix.helpshift.com/hc/en/14-homescapes/faq/5657-why-don-t-
`i-have-a-special-offer-but-my-friend-does/?l=en.
`
`
`Homescapes makes URL calls that include localization such as the URL https://cdn.playrix.com/online-
`settings/Homescapes/production/ios/country/US.json. This indicates that Homescapes localizes the game application
`to the content delivery network by country, such as the US, as seen in the following screenshot.
`
`
`
`
`8
`
`Playrix Ex. 1009, Page 8 of 40
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`

`

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`E-2
`U.S. PATENT NO. 11,117,056
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`
`
`IOS – Homescapes – Localized URL (Red Box)
`
`On information and belief, Android devices operate in a similar manner to IOS devices and have URL calls to an
`android directory. See e.g., analysis of this claim element with respect to Gardenscapes.
`FPG incorporates by reference its analysis of Claim 1.
`
`Homescapes identifies what in-game video game content to send based on a model type associated with the mobile
`communication device. See e.g., analysis of this claim element with respect to Gardenscapes.
`
`Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server
`and client side source code or other internal documents and information for the Homescapes game, which is not
`publicly available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses
`and after Playrix produces source code and/or other internal documents and information relevant to this claim
`element.
`
`
`
`
`
`
`FPG incorporates by reference its analysis of Claim 1.
`
`On information and belief, Homescapes’s server is configured to send information to the mobile communication
`device regarding the in-game placement location of the in-game videogame content. For example, when a user
`reaches a certain juncture in Homescapes, Homescapes communicates with its server to provide an in-game
`placement location (ie. the billboard, below) where a user may travel to in-game within the Homescapes universe to
`obtain the video game content.
`
`
`9
`
`[Claim 4] The system of
`claim 1, wherein
`identifying what in-game
`video game content to send
`is based on a model type
`associated with the mobile
`communication device, a
`service subscription
`associated with the mobile
`communications device, a
`service provider for the
`service subscription
`associated with the mobile
`communication device, or
`a location of the mobile
`communications device.
`[Claim 5] The system of
`claim 1, wherein the server
`is further configured to
`send information to the
`mobile communication
`device regarding the in-
`game placement location of
`the in-game video game
`content.
`
`
`
`Playrix Ex. 1009, Page 9 of 40
`
`

`

`E-2
`U.S. PATENT NO. 11,117,056
`
`© Mummini
`
`
`
`
`
`10
`
`
`
`
`
`Finchen50
`© Sachsengirls
`
`
`
`
`
`Playrix Ex. 1009, Page 10 of 40
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`

`

`
`
`
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`E-2
`U.S. PATENT NO. 11,117,056
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`[Claim 6] The system of
`claim 1, wherein the server
`is further configured to
`check whether the mobile
`communication device
`should receive the updated
`content before sending the
`updated content to the
`mobile communication
`device.
`[Claim 7] The system of
`claim 1, wherein the server
`is further configured to
`track the distribution of
`updated content.
`
`
`
`
`FPG incorporates by reference its analysis of Claim 1.
`
`On information and belief, Homescapes is configured to check whether the mobile communication device should
`receive the updated content before sending the updated content to the mobile communication device. Paragraph
`3(a)(i) of the Discovery Order, further verification of this feature requires review of the server and client side source
`code or other internal documents and information for the Homescapes game, which is not publicly available to FPG.
`As such, FPG reserves the right to supplement these contentions as discovery progresses and after Playrix produces
`source code and/or other internal documents and information relevant to this claim element.
`
`
`
`FPG incorporates by reference its analysis of Claim 1.
`
`On information and belief, the Homescapes server tracks the distribution of updated content. Pursuant to Paragraph
`3(a)(i) of the Discovery Order, further verification of this feature requires review of the server and client side source
`code or other internal documents and information for the Homescapes game, which is not publicly available to FPG.
`
`11
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`Playrix Ex. 1009, Page 11 of 40
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`

`

`
`
`[Claim 8] The system of
`claim 1, wherein the server
`is further configured to
`check for availability of
`bandwidth before sending
`the updated content to the
`mobile communication
`device.
`
`[Claim 9 -preamble] A
`method for providing
`updated content associated
`with a mobile video game
`to a mobile communication
`device, the method
`comprising:
`[9a] storing, on a storage
`medium, pre-selected in-
`game video game content
`for use in a video game;
`
`[9b] receiving, at a server,
`a request from the mobile
`communication device for
`updated content from the
`mobile communication
`device;
`[9c] identifying, by the
`server in response to
`receiving the request, what
`
`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`As such, FPG reserves the right to supplement these contentions as discovery progresses and after Playrix produces
`source code and/or other internal documents and information relevant to this claim element.
`FPG incorporates by reference its analysis of Claim 1.
`
`
`On information and belief, Homescapes checks for availability of bandwidth before sending the updated content to
`the mobile communication device. Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this
`feature requires review of the server and client side source code or other internal documents and information for the
`Homescapes game, which is not publicly available to FPG. As such, FPG reserves the right to supplement these
`contentions as discovery progresses and after Playrix produces source code and/or other internal documents and
`information relevant to this claim element.
`See Preamble Claim 1.
`
`Homescapes provides a storage medium for storing in-game video game content. Pursuant to Paragraph 3(a)(i) of
`the Discovery Order, further verification of this feature requires review of the server and client side source code or
`other internal documents and information for the Homescapes game, which is not publicly available to FPG. As such,
`FPG reserves the right to supplement these contentions as discovery progresses and after Playrix produces source
`code and/or other internal documents and information relevant to this claim element.
`
`See Claim 1b.
`
`See Claim 1c.
`
`12
`
`Playrix Ex. 1009, Page 12 of 40
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`

`

`
`pre-selected in-game video
`game content to send;
`[9d] sending a message
`relating to the in-game
`video game content from
`the server to the mobile
`communication device in
`response to receiving the
`request, wherein the
`message is pre-selected by
`the server based on a
`model type associated with
`the mobile communication
`device, a service
`subscription associated
`with the mobile
`communication device, or
`a service provider for the
`service subscription
`associated with the mobile
`communication device; and
`[9e] sending, from the
`server, the pre-selected in-
`game video game content
`to the mobile
`communication device as
`the updated content for the
`mobile video game.
`[Claim 10] The method of
`claim 9, wherein the
`updated content is
`promotional content.
`[Claim 11] The method of
`
`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`See Claim 1d.
`
`See Claim 1e.
`
`See Claim 2.
`
`FPG incorporates by reference its analysis of Claims 9 and 10.
`
`13
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`Playrix Ex. 1009, Page 13 of 40
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`

`

`
`claim 10, wherein the
`promotional content is
`localized promotional
`content based on a location
`of the mobile
`communication device.
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`
`Homescapes provides a method wherein the promotional content is localized promotional content based on a location
`of the mobile communication device. Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of
`this feature requires review of the server and client side source code or other internal documents and information for
`the Homescapes game, which is not publicly available to FPG. As such, FPG reserves the right to supplement these
`contentions as discovery progresses and after Playrix produces source code and/or other internal documents and
`information relevant to this claim element.
`
`
`Homescapes offers promotional content that is localized to the local language of the user’s location. On information
`and belief, Homescapes is localized to default to the location of the mobile communication device and can then be
`changed manually. https://playrix.helpshift.com/hc/en/14-homescapes/faq/4117-changing-the-language-in-the-game/.
`
`
`
`
`
`
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`14
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`Playrix Ex. 1009, Page 14 of 40
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`

`

`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`Homescapes distributes promotions “on a random and automatic basis, and they depend on many things such as your
`current game progress, location and so on.” https://playrix.helpshift.com/hc/en/14-homescapes/faq/5657-why-don-t-
`i-have-a-special-offer-but-my-friend-does/?l=en.
`
`
`Homescapes makes URL calls that include localization such as the URL https://cdn.playrix.com/online-
`settings/Homescapes/production/ios/country/US.json. This indicates that Homescapes localizes the game application
`to the content delivery network by country, such as the US, as seen in the following screenshot.
`
`
`
`
`IOS – Homescapes – Localized URL (Red Box)
`
`On information and belief, Android devices operate in a similar manner to IOS devices and have URL calls to an
`android directory. See e.g., analysis of this claim element with respect to Gardenscapes.
`Homescapes provides a method to identify what in-game video game content to send based on a model type
`associated with the mobile communication device and a location of the mobile communications device. On
`information and belief, in response to receiving a request, the game server pre-selects a message in part based on the
`model type of mobile device it is. Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this
`feature requires review of the server and client side source code or other internal documents and information for the
`Homescapes game, which is not publicly available to FPG. As such, FPG reserves the right to supplement these
`contentions as discovery progresses and after Playrix produces source code and/or other internal documents and
`information relevant to this claim element.
`
`
`Homescapes offers promotional content that is localized to the local language of the user’s location. On information
`and belief, Homescapes is localized to default to the location of the mobile communication device and can then be
`changed manually. https://playrix.helpshift.com/hc/en/14-homescapes/faq/4117-changing-the-language-in-the-game/.
`
`15
`
`[Claim 12] The method of
`claim 9, wherein
`identifying what in-game
`video game content to send
`is based on a model type
`associated with the mobile
`communication device, a
`service subscription
`associated with the mobile
`communications device, a
`service provider for the
`service subscription
`associated with the mobile
`communication device, or
`a location of the mobile
`communications device.
`
`
`
`Playrix Ex. 1009, Page 15 of 40
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`

`

`
`
`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`
`Homescapes distributes promotions “on a random and automatic basis, and they depend on many things such as your
`current game progress, location and so on.” https://playrix.helpshift.com/hc/en/14-homescapes/faq/5657-why-don-t-
`i-have-a-special-offer-but-my-friend-does/?l=en.
`
`
`Homescapes makes URL calls that include localization such as the URL https://cdn.playrix.com/online-
`settings/Homescapes/production/ios/country/US.json. This indicates that Homescapes localizes the game application
`to the content delivery network by country, such as the US, as seen in the following screenshot.
`
`
`
`
`16
`
`Playrix Ex. 1009, Page 16 of 40
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`

`

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`E-2
`U.S. PATENT NO. 11,117,056
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`[Claim 13] The method of
`claim 9, further comprising
`sending information from
`the server to the mobile
`communication device
`regarding the in-game
`placement location of in-
`game video game content.
`
`
`
`IOS – Homescapes – Localized URL (Red Box)
`
`On information and belief, Android devices operate in a similar manner to IOS devices and have URL calls to an
`android directory. See e.g., analysis of this claim element with respect to Gardenscapes.
`
`FPG incorporates by reference its analysis of Claim 9.
`
`On information and belief, Homescapes’s comprises a method for sending information from the server to the mobile
`communication device regarding the in-game placement location of in-game video game content. For example,
`when a user reaches a certain juncture in Homescapes, Homescapes communicates with its server to provide an in-
`game placement location (ie. the billboard, below) where a user may travel to in-game within the Homescapes
`universe to obtain the video game content. Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification
`of this feature requires review of the server and client side source code or other internal documents and information
`for the Homescapes game, which is not publicly available to FPG. As such, FPG reserves the right to supplement
`these contentions as discovery progresses and after Playrix produces source code and/or other internal documents and
`information relevant to this claim element.
`
`
`
`
`
`17
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`Playrix Ex. 1009, Page 17 of 40
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`

`

`E-2
`U.S. PATENT NO. 11,117,056
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`© Mummini
`
`
`
`
`
`
`
`
`
`Sian
`111/400 Pe
`
`oe-es—_
`
`Finchen50
`© Sachsengirls
`
`
`
`
`
`18
`
`Playrix Ex. 1009, Page 18 of 40
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`
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`U.S. PATENT NO. 11,117,056
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`[Claim 14] The method of
`claim 9, further comprising
`checking whether the
`mobile communication
`device should receive the
`updated content before
`sending the updated
`content to the mobile
`communication device.
`
`[Claim 15] The method of
`claim 9, further comprising
`tracking the distribution of
`updated content at the
`server.
`
`
`
`
`
`
`FPG incorporates by reference its analysis of Claim 9.
`
`On information and belief, Homescapes further comprises checking whether the mobile communication device
`should receive the updated content before sending the updated content to the mobile communication device. Pursuant
`to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server and
`client side source code or other internal documents and information for the Homescapes game, which is not publicly
`available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses and after
`Playrix produces source code and/or other internal documents and information relevant to this claim element.
`
`
`FPG incorporates by reference its analysis of Claim 9.
`
`On information and belief, Homescapes further comprises tracking the distribution of updated content at the server.
`Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server
`and client side source code or other internal documents and information for the Homescapes game, which is not
`
`19
`
`Playrix Ex. 1009, Page 19 of 40
`
`

`

`
`
`[Claim 16] The method of
`claim 9, wherein the server
`checks for availability of
`bandwidth before sending
`the updated content to the
`mobile communication
`device.
`
`
`
`
`
`E-2
`U.S. PATENT NO. 11,117,056
`
`publicly available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses
`and after Playrix produces source code and/or other internal documents and information relevant to this claim
`element.
`FPG incorporates by reference its analysis of Claim 9.
`
`On information and belief, Homescapes further comprises tracking the distribution of updated content at the server.
`Pursuant to Paragraph 3(a)(i) of the Discovery Order, further verification of this feature requires review of the server
`and client side source code or other internal documents and information for the Homescapes game, which is not
`publicly available to FPG. As such, FPG reserves the right to supplement these contentions as discovery progresses
`and after Playrix produces source code and/or other internal documents and information relevant to this claim
`element.
`
`20
`
`Playrix Ex. 1009, Page 20 of 40
`
`

`

`
`
`E-3
`U.S. PATENT NO. 11,117,056
`
`INFRINGEMENT OF U.S. PATENT NO. 11,117,056 BY PLR’S TOWNSHIP
`
`Plaintiff Flip Phone Games Inc. (“FPG”) contends that PLR Worldwide Sales Limited (“PLR”) makes, uses, sells, offers for
`
`sale, and/or imports into the United States gaming systems, software, and/or methods for controlling devices and games including the
`
`Township mobile game, which acts infringe claims 1 through 16 of U.S. Patent No. 11,117,056, as set forth below. The specific
`
`components, systems, and constructs identified in this chart are for exemplary purposes only and FPG reserves all rights to supplement
`
`or amend these disclosures as additional components, systems, and constructs become known through discovery, as well as after PLR
`
`produces documents and source code and/or the Court construes any terms from the claims of the ’056 patent. PLR induces
`
`infringement of the asserted claims by providing instructions or information, for example on publicly available websites to explain
`
`how to use Township in an infringing manner including, inter alia, the PLR website.
`
`See e.g., https://playrix.helpshift.com/hc/en/3-township/
`
`PLR indirectly infringes the ’056 Patent by contributing to the direct infringement by end users by providing Township which
`
`is especially made for use on end-user devices in a manner that infringes and has no substantial non-infringing uses.
`
`
`
`
`
`
`
`1
`
`Playrix Ex. 1009, Page 21 of 40
`
`

`

`
`U.S. 11,117,056 to Hartwell, Methods and Systems for Updating In-Game Content
`Compared to: Township1
`
`
`U.S. 11,117,056
`[claim 1, preamble]
`A system for
`providing updated
`content associated
`with mobile video
`game to a mobile
`communication
`device, the system
`comprising:
`
`[1a] a storage
`medium for storing
`in-game video game
`content;
`
`E-3
`U.S. PATENT NO. 11,117,056
`
`Township by Playrix
`To the extent the preamble is limiting, Township provides a system for updating content associated with the
`mobile video game to a mobile communication device.
`
`https://apps.apple.com/us/app/township/id638689075 (“Township is a unique blend of city building and farming!
`Build your dream town! Harvest crops, process them at your facilities, and sell goods to develop your town. Trade
`with distant islands. Open restaurants, cinemas and other community buildings to give life in your town special
`flavor. Explore the mine to get resources and find ancient artifacts. Run your own zoo and collect animals from
`around the world.
`Are you ready to build your dream? Let’s get started!
`Township features:
`● Different buildings and decorations you can use to create your dream town● Various crops to grow and later
`process at your factories
`● Fun, charismatic townspeople with orders you need to fill
`● Your town's mine packed with ancient artifacts to discover and collect
`● Exotic goods brought from the islands
`● A zoo to build where you can even breed animals
`● Famous landmarks you can use to decorate your town, like the Statue of Liberty, Big Ben, and many more!
`● Play with your Facebook and Game Center friends or make new friends in the game community! Township is
`free to play, though some in-game items can also be purchased for real money. If you don't want to use this
`option, simply turn it off in your device's ‘Restrictions’ menu.”)
`Township provides a storage medium for storing in-game video game content. For example, the game is updated
`frequently with updated game content from the server being stored in a storage medium. Such updates occur
`when a user launches the Township application on a mobile communication device.
`
`
`
`1 Township on the App Store (apple.com) (“Build your dream town! Develop your town's infrastructure, harvest crops, discover
`artifacts in the mines, and establish a trading system!.”)
`
`
`
`2
`
`Playrix Ex. 1009, Page 22 of 40
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`

`

`E-3
`U.S. PATENT NO. 11,117,056
`
`[1b] a server in
`communication with
`the storage medium;
`and wherein the
`server is configured
`to:
`receive a request for
`updated content from
`the mobile
`communication
`device;
`
`
`
`
`Township is a mobile device game, which is in communication with a game server. See, e.g,
`https://playrix.helpshift.com/hc/en/3-township/faq/19-progress-transfer/ (You can transfer your game progress
`from your old device to your new one by connecting the new game to the same Facebook account you used for
`the first device: 1. Install the game from the App Store, Google Play, or the Amazon App Store on the new
`device. 2. Connect the newly installed game to the same Facebook account you used for the old device. 3. A
`window telling you to download the saved game from our server will pop up. 4. Select Yes and type
`