UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Civil Action No. 2:23-cv-471-JRG
`
`JURY TRIAL DEMANDED
`
`)
`)
`)
`)
`)
`)
`)
`)
`
`))
`
`SPORTSCASTR INC.
`(d/b/a PANDA INTERACTIVE),
`
`v.
`
`Plaintiff,
`
`GENIUS SPORTS LTD.,
`
`Defendant.
`
`PLAINTIFFS’ DISCLOSURE OF ASSERTED CLAIMS AND
`PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Plaintiff SportsCastr Inc. (d/b/a PANDA Interactive) (“Plaintiff” or “PANDA”), by and
`
`through its attorneys of record, and pursuant to the Court’s December 13, 2023, Order (Dkt. 9) and
`
`the parties’ agreement, as approved by the Court, to extend the deadlines to comply with P.R. 3-1,
`
`3-2, 3-3, 3-4 (see Dkt. 11), provides the following Disclosure of Asserted Claims and Infringement
`
`Contentions (“Infringement Contentions”), including initial claim charts relating each known
`
`Accused Product of Defendant Genius Sports Ltd. (“Defendant” or “Genius Sports”) to the
`
`asserted claims of U.S. Patent No. 10,805,687 (“the ’687 Patent”), U.S. Patent No. 10,425,697
`
`(“the ’697 Patent”), and U.S. Patent No. 11,039,218 (“the ’218 Patent”) (the ’687, ’697, and ’218
`
`Patents collectively, “the Asserted Patents”). These Infringement Contentions are made solely for
`
`the purpose of this action.
`
`Plaintiff’s investigation regarding infringement and additional potential grounds of
`
`infringement is ongoing. Plaintiff’s Infringement Contentions are therefore based upon
`
`information that Plaintiffs have been able to obtain to date from publicly available sources,
`
`together with its good-faith beliefs regarding the Accused Products and their operation, and is
`
`given without prejudice to Plaintiff’s right to supplement and/or amend these Infringement
`
`1
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`Contentions as additional facts are ascertained, discovery is conducted, analysis is made, research
`
`is completed, and claim language is construed. Discovery in this case has yet to commence, and
`
`Defendant has yet to produce any technical documents, including but not limited to source code,
`
`for the Accused Products, such that Plaintiff anticipates the discovery of technical information
`
`sufficient to show the functionalities of the Accused Products will further support Plaintiff’s
`
`claims. Plaintiff reserves the right to amend and/or supplement these Infringement Contentions as
`
`additional details are made available.
`
`Plaintiff’s Infringement Contentions are based at least in part on Plaintiff’s present
`
`understanding of the meaning and scope of the claims of the Asserted Patents. Plaintiff reserves
`
`the right to supplement and/or amend these Infringement Contentions if its understanding of the
`
`claim scope changes, including any constructions of any term by the Court.
`
`For each Asserted Patent, Plaintiff identifies the following Accused Products of which it is
`
`currently aware. The identification of Accused Products is based on Plaintiff’s research and
`
`analysis to date. Plaintiff reserves the right to add, delete, substitute, or otherwise amend this list
`
`of Accused Products based on discovery or other circumstances, in a manner consistent with the
`
`Federal Rules of Civil Procedures, local rules, and the Court’s orders and procedures.
`
`Accused Products. The Accused Products include, without limitation, the following:
`
`• Genius Sports’ Sportsbook Platform and live streaming services, as well as other
`
`offerings and services that integrate with Genius Sports’ Sportsbook Platform and
`
`live streaming services, including but not limited to the product marketed under the
`
`trade names Multibet, BetVision, GeniusLive, and GeniusLive+, including any
`
`equivalent or substantially similar products.
`
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`Defendant’s Infringement. Based upon currently available information, Plaintiff
`
`identifies the following asserted claims:
`
`•
`
`•
`
`•
`
`The ’687 Patent. Defendant has infringed and is infringing claims 1-9, 19-25, and
`
`27-30, literally and/or under the Doctrine of Equivalents. Defendant has infringed
`
`and is infringing these claims both directly and indirectly (by inducing infringement
`
`pursuant to 35 U.S. Code § 271(b) and/or by contributing to infringement pursuant
`
`to 35 U.S. Code § 271(c)).
`
`The ’697 Patent. Defendant has infringed and is infringing claims 1-9, 19-25, and
`
`27-30, literally and/or under the Doctrine of Equivalents. Defendant has infringed
`
`and is infringing these claims both directly and indirectly (by inducing infringement
`
`pursuant to 35 U.S. Code § 271(b) and/or by contributing to infringement pursuant
`
`to 35 U.S. Code § 271(c)).
`
`The ’218 Patent. Defendant has infringed and is infringing claims 1-30, literally
`
`and/or under the Doctrine of Equivalents. Defendant has infringed and is infringing
`
`these claims both directly and indirectly (by inducing infringement pursuant to 35
`
`U.S. Code § 271(b) and/or by contributing to infringement pursuant to 35 U.S. Code
`
`§ 271(c)).
`
`Based upon currently available information, Plaintiff asserts that Defendant has infringed
`
`and/or continues to infringe the patents and claims as identified and described in the claim charts
`
`for the Accused Products attached as Exhibits 1-3. These exhibits contain illustrative examples of
`
`Defendant’s presently known infringement of the Asserted Claims by evidencing the
`
`correspondence between (i) the elements of the Asserted Claims, and (ii) the corresponding items
`
`of the Accused Products. However, it should be understood that such examples are illustrative in
`
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`nature and not exhaustive, additional materials may evidence infringement, and/or additional bases
`
`of infringement may be present and uncovered during discovery and/or after claim construction.
`
`Each element of each asserted claim is presently alleged to be literally present. However,
`
`to the extent Defendant argues that a limitation is not present, then Defendant still infringes under
`
`the Doctrine of Equivalents. Any differences alleged to exist between any of the Asserted Claims
`
`and any of the Accused Products are insubstantial and therefore each Accused Product also meets
`
`each limitation under the Doctrine of Equivalents as the identified features of the Accused Products
`
`perform substantially the same function in substantially the same way to achieve substantially the
`
`same result as the corresponding claim limitation. Plaintiff reserves the right to supplement and/or
`
`amend these Infringement Contentions as discovery is conducted, Defendant provides any alleged
`
`non-infringement positions, and/or claim construction is completed to further supplement its
`
`allegations under the Doctrine of Equivalents as appropriate.
`
`Defendant directly infringes each of the asserted claims under 35 U.S.C. §271(a) at least
`
`by using, operating, testing, advertising, making, installing, maintaining, distributing, supporting,
`
`providing instructions for, offering to sell, selling and/or otherwise providing services including
`
`the Accused Products—or systems incorporating the Accused Products—within the United States
`
`and/or importing the Accused Products into the United States. Defendant also directly infringes
`
`each of the claims at least by performing, or being responsible for the performance (e.g., the acts
`
`are attributable to it), of each of the claimed steps as set forth in the accompanying charts.
`
`Defendant’s acts of direct infringement are further set forth in accompanying Exhibits 1-3.
`
`Defendant also indirectly infringes the Asserted Claims by inducing infringement pursuant
`
`to 35 U.S. Code § 271(b)). Defendant has had knowledge of each of the asserted patents and of
`
`alleged infringement since at least October 4, 2023 and further has had knowledge of the specific
`
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`
`
`manner by which the Accused Products infringe each patent since at least October 5, 2023 when
`
`Plaintiff filed its Complaint. Defendant knowingly induced one or more third part(ies) (e.g.,
`
`business partners, customers or others), to infringe the Asserted Claims by making the Accused
`
`Products available on its website, widely advertises the Accused Products, providing platforms
`
`and applications that allow partners and users to access the Accused Products, providing
`
`instructions for installing, and providing technical support to users and/or engaging in activities
`
`that aid and abet infringement of the Asserted Patents by end-users within the United States, with
`
`knowledge and intent that performance of such actions will infringe the Asserted Claims.
`
`Defendant committed these acts with knowledge or willful blindness that such induced acts would
`
`constitute infringement of the Asserted Claims at the very least as of the filing of the Complaint in
`
`this matter. Defendant also has had actual or constructive notice of each Asserted Patent since at
`
`least as early as the date Plaintiff provided notice of the corresponding Asserted Patent on its
`
`website. Defendant knew that it infringed the Asserted Patents based on its knowledge of the same.
`
`Alternatively, or additionally, Defendant was willfully blind to the fact that it infringed the
`
`Asserted Patents despite its knowledge of the same, based on, for example, the similarity of the
`
`Accused Products to Plaintiff’s patented products. Defendant’s inducement of infringement by
`
`others is further set forth in each of Exhibits 1-3.
`
`Defendant also indirectly infringes the Asserted Claims by contributing to infringement
`
`pursuant to 35 U.S. Code § 271(c). Each of the Accused Products is a material part of the claims—
`
`and Defendant knew each of the Accused Products is especially made or especially adapted for
`
`use in an infringement of the Asserted Claims. Further, the Accused Products have no substantial
`
`non-infringing uses, as set forth in the exemplary claim charts.
`
`
`
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`
`
`Defendant also contributes to infringement of its customers and end users of the Accused
`
`Products by offering to sell or selling within the United States or importing into the United States
`
`the Accused Products, which are for use in practicing, and under normal operation practice,
`
`methods claimed in the Asserted Patents, constituting a material part of the inventions claimed,
`
`and not a staple article or commodity of commerce suitable for substantial non-infringing uses.
`
`Indeed, the Accused Products and the example functionality have no substantial non-infringing
`
`uses but instead are specifically designed to practice the Asserted Patents. Defendant’s
`
`contributory infringement is further set forth in each of Exhibits 1-3.
`
`Plaintiff reserves the right to supplement and/or amend these Infringement Contentions as
`
`discovery is conducted, Defendant provides any alleged non-infringement positions, and/or claim
`
`construction is completed to further supplement its allegations under 35 U.S. Code § 271(a-c) as
`
`appropriate.
`
`Priority Dates. Plaintiff presently identifies the following priority dates for the Asserted
`
`Patents.
`
`• The ’687 Patent is entitled at least to the earliest priority date listed on the face of
`
`the Patent, specifically, August 5, 2016, corresponding to Provisional Application
`
`No. 62/371,558.
`
`• The ’697 Patent is entitled at least to the earliest priority date listed on the face of
`
`the Patent, specifically, August 5, 2016, corresponding to Provisional Application
`
`No. 62/371,558.
`
`• The ’218 Patent is entitled at least to the earliest priority date listed on the face of
`
`the Patent, specifically, August 5, 2016, corresponding to Provisional Application
`
`No. 62/371,558.
`
`
`
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`
`
`Plaintiff’s investigation and analysis is ongoing, and Plaintiff reserves the right to assert
`
`and rely on an earlier invention date in the event Defendant identifies alleged prior art that is earlier
`
`than the identified priority date corresponding to a date of conception followed by diligence and
`
`reduction to practice of the claimed invention.
`
`Plaintiff’s Practicing Products. As addressed in its Complaint, Plaintiff has implemented
`
`its patented technologies in its video-streaming products including a video-based social network
`
`targeting consumers (SportsCastr) and a B2B software solution designed for major enterprises,
`
`sports media, affiliates, and betting operators (PANDA Studio). Plaintiff’s investigation and
`
`analysis is ongoing, and Plaintiff reserves the right to rely on additional details concerning how
`
`the aforementioned products practice the asserted claims of the Asserted Patents and/or to add,
`
`delete, substitute, or otherwise amend this list of practicing products based on additional
`
`investigation and discovery or other circumstances, in a manner consistent with the Federal Rules
`
`of Civil Procedures, local rules, and the Court’s orders and procedures.
`
`Production of Documents. Simultaneously with this Disclosure, Plaintiff is producing
`
`documents pursuant to P.R. 3.2. Plaintiff reserves the right to supplement this production as
`
`additional investigation and discovery is conducted in the ordinary course of these proceedings.
`
`Further, Plaintiff reserves the right to supplement or revise its Infringement Contentions
`
`and/or charts, including identification of additional asserted claims, based on, for example, new
`
`versions or variations of one or more of the Accused Products that are later discovered.
`
`DATED: January 18, 2024
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`KING & SPALDING LLP
`
`
`By: /s/ Chris Campbell
`Christopher C. Campbell (#444262 DC)
`1700 Pennsylvania Avenue, NW
`Suite 200
`Washington, DC 20006
`(202) 626-5578
`
`7
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`

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`ccampbell@kslaw.com
`
`Matthew D. Wood (#24110548)
`500 West 2nd Street
`Suite 1800
`Austin, TX 78701
`(512) 457-2000
`mwood@kslaw.com
`
`
`
`
`
`
`
`OF COUNSEL:
`
`Britton F. Davis
`KING & SPALDING LLP
`1401 Lawrence Street, Suite 1900
`Denver, CO 80202
`(720) 535-2300
`bfdavis@kslaw.com
`
`Ryan A. Schmid
`KING & SPALDING LLP
`1700 Pennsylvania Avenue, NW
`Suite 200
`Washington, DC 20006
`(202) 626-5578
`rschmid@kslaw.com
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the foregoing document
`
`has been served on January 18, 2024 to all counsel of record below:
`
`jeannie.heffernan@kirkland.com
`james.lomeo@kirkland.com
`
`
`
`/s/ Chris Campbell _____________
`
`
`
`
`8
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`

`Exhibit 1
`
`U.S. PATENT NO. 10,805,687 V/S Genius Sports Ltd.
`
`I.
`
`INTRODUCTION
`
`The chart below demonstrates how Defendant Genius Sports Ltd. (“Defendant” or “Genius Sports”) as well as Defendant’s
`partners, customers, and end users of the products and features discussed below, directly infringe, either literally or under the doctrine
`of equivalents, at least claims 1-9, 19-25, and 27-30of U.S. Patent No. 10,805,687 (“the ’687 Patent”). Defendant and Defendant’s
`partners, customers, and end users directly infringe the identified claims at least by making, using, selling, installing, configuring to
`operate, importing, testing, and/or offering to sell at least Genius Sports’ Sportsbook Platform and live streaming services, as well as
`other offerings and services that integrate with Genius Sports’ Sportsbook Platform and live streaming services, including but not limited
`to the product marketed under the trade names Multibet, BetVision, GeniusLive, and GeniusLive+, including any equivalent or
`substantially similar products (collectively, “the Accused Products”) either alone, and/or when installed and operated as designed and
`intended on a computer system or network, as detailed below.
`Each element of each asserted claim is presently alleged to be literally present. Because discovery has not started and the Asserted
`Claims have not yet been construed, SportsCastr Inc. (d/b/a PANDA Interactive) (“Plaintiff” or “PANDA”) reserves the right to
`supplement its contentions, including with respect to the Doctrine of Equivalents as appropriate. In addition, any of Defendant’s products
`that perform similar functions and/or incorporate or rely on the same or similar functionality (for example, without limitation, any
`predecessor or successor products performing the same functions in the same ways or products which use the same software, plugins,
`or libraries or call the functions underlying the operations identified below) as the Accused Products also infringe in the manner set out
`below.
`
`Defendant directly infringes at least claims 1-9, 19-25, and 27-30 of the ’687 Patent, either literally or under the doctrine of
`equivalents, by making, using, offering to sell and selling the systems described below. Defendant’s partners, customers, and end users
`of its Accused Products and corresponding systems and services directly infringe at least claims 1-9, 19-25, and 27-30 of the ’687 Patent,
`literally or under the doctrine of equivalents, at least by using the Accused Products and corresponding systems and services, as described
`below. For example, Defendant publicizes and markets that it works with partners worldwide in connection with using its Accused
`Products and corresponding systems and services:
`
`
`
`1
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`

`
`
`
`
`See https://geniussports.com/sportsbook/.
`Defendant has actively induced and are actively inducing infringement of at least claims 1-9, 19-25, and 27-30 of the ’687 Patent
`with specific intent to induce infringement, and/or willful blindness to the possibility that its acts induce infringement, in violation of
`35 U.S.C. § 271(b). For example, Defendants encourages and induces customers to use the Genius Sports Platform in a manner that
`infringes claims 1-9, 19-25, and 27-30 of the ’687 Patent at least by offering and providing the software and by engaging in activities
`relating to selling, marketing, advertising, promotion, installation, support, and distribution of the Accused Products.
`Defendant encourages, instructs, directs, and/or requires third parties—including its certified partners and/or customers—to use
`the Accused Products in infringing ways. Defendants further encourages and induces its customers to infringe claims 1-9, 19-25, and
`27-30 of the ’687 Patent: 1) by widely advertising those services, and providing technical support and instructions to users, and 2)
`through activities relating to marketing, advertising, promotion, installation, support, and distribution of the Accused Products, including
`its
`video
`streaming
`software,
`and
`services
`in
`the United States.
`(See PANDA_000055-PANDA_000064,
`https://www.geniussports.com/sportsbook/streaming/.) Further, as the entity that provides installation, implementation, and integration
`of the Accused Products in addition to ensuring the Accused Product remains operational for each customer through ongoing technical
`support, on information and belief, Defendant and/or its partners affirmatively aid and abet each customer’s use of the Accused Products
`in a manner that infringes the ’687 Patent.
`
` 2
`
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`

`
`
`Defendant also contributes to the infringement of its partners, customers, and end-users of the Accused Products by providing
`within the United States or importing into the United States the Accused Products, constituting a material part of the inventions claimed,
`and not a staple article or commodity of commerce suitable for substantial non-infringing uses. Indeed, as shown below, the Accused
`Products have no substantial non-infringing uses because the accused functionality, including the one-to-many socket architecture and
`separate channels for video and event information, is an integral part of the Accused Products and must be performed for the Accused
`Products to perform their intended purpose. These functionalities are continually running when the system is in use and, on information
`and belief, cannot be removed or disabled (or, if they could, the system would no longer suitably function for its intended purpose).
`Moreover, for the same reasons, without the system and components identified below that practice the ’687 Patent, that functionality
`could not be performed. Additionally, the accused functionality, including the one-to-many socket architecture and separate channels
`for video and event information, itself has no substantial non-infringing uses because the components, modules and methods identified
`below are a necessary part of that functionality. For example, without the one-to-many socket architecture, the Accused Products could
`not effectively synchronize the event information across multiple viewers. These functionalities are continually running when the system
`is in use and cannot be removed or disabled (or, if they could, the system would no longer suitably function for its intended purpose).
`Moreover, for the same reasons, without the system and components identified below that practice claimed in the ’687 Patent, that
`functionality could not be performed.
`Indeed, as shown below, the Accused Products have no substantial non-infringing uses because the accused functionality is an
`integral part of the Accused Products and must be performed for the Accused Products to perform their intended purpose. For example,
`at least the functionalities and corresponding modules (whether software and/or hardware) described below have no suitable non-
`infringing use and form a material part of the Accused Products. In other words, when each of the Accused Products operates, the
`functions below are performed. Moreover, when the functionality and modules specifically described below are operated, they perform
`the steps described below. The Accused Products (and the specific modules and functionalities described herein) are designed and
`intended specifically to perform the inventions claimed in the Asserted Claims, and do not have any other purpose. For example, the
`Accused Products and accused functionalities (e.g., the one-to-many architecture) constitute a material part of the inventions claimed
`because such architecture is integral to the system as recited in the claims of the ’687 Patent. None of these products are staple goods—
`they are sophisticated and customized video streaming products, methods, and systems.
`Plaintiff provides the following example claim charts based on currently available information, including through public sources.
`Plaintiff reserves the right to modify, amend, or supplement these claim charts should it become aware of additional information
`regarding the Accused Products and systems, including through discovery, or should one or more claims be construed in a manner
`differently than interpreted herein.
`
` 3
`
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`

`

`In addition to the specific claims charted below, Plaintiff intends to take discovery of the Accused Products related to claims 10-
`18 and 26, which require, inter alia, at least one real-time messaging protocol (RTMP) media server and at least one web real time
`communication (WebRTC) media server. Plaintiff believes that such discovery, including in particular relevant source code, will
`provide facts to show whether the Accused Products infringe one or more of these claims. Plaintiff therefore reserves the right to
`supplement its contentions, including by adding one or more of these claims, as this case progresses.
`
`
`
`II.
`
`CLAIM CHARTS
`1.
`
`Independent Claim 1
`
`See Claim 19, infra.
`
`
`Accused Product
`
`See discussion of Claim Elements [19A] and [19A.1], infra.
`
` 4
`
`
`
`Key Features
`for
`[1.P] A
`system
`first
`providing,
`to
`a
`plurality of viewer client
`devices, a first plurality of
`copies of a first live stream
`of digital content relating
`to a first live sporting
`event, and for providing,
`to a second plurality of
`viewer client devices, a
`second plurality of copies
`of a second live stream of
`digital content relating to
`the first live sporting event
`or a second live sporting
`event,
`the
`system
`comprising:
`[1A] a plurality of media
`sources to:
`[1A.1] receive the first
`live stream of digital
`content and the second
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`

`Accused Product
`
`
`
`See discussion of Claim Element [19A.2], infra.
`
`See discussion of Claim Element [19A.3], infra.
`
`See discussion of Claim Element [19B], infra.
`
` 5
`
`
`
`Key Features
`live stream of digital
`content;
`[1A.2] provide a first
`copy of the first plurality
`of copies to a first viewer
`client device of the first
`plurality of viewer client
`devices via a first video
`Internet communication
`channel between the
`plurality of media sources
`and the first viewer client
`device of the first
`plurality of viewer client
`devices; and
`[1A.3] provide a first
`copy of the second
`plurality of copies to a
`first viewer client device
`of the second plurality of
`viewer client devices via
`a second video Internet
`communication channel
`between the plurality of
`media sources and the
`first viewer client device
`of the second plurality of
`viewer client devices;
`[1B] a control server to
`periodically retrieve, via
`the Internet, first event
`information germane to
`
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`

`

`Accused Product
`
`See discussion of Claim Elements [19C] and [19C.1], infra.
`
`
`
`On information and belief, the Accused Products include at least one socket server to “transmit the first
`event information to at least the first viewer client device of the first plurality of viewer client devices via
`a first event information Internet communication channel between at least one first event socket of the at
`least one socket server and the first viewer client device of the first plurality of viewer devices, wherein
`the at least one first event socket corresponds to the first event information germane to the first live
`sporting event.”
`
`Genius Sports offers a Multibet widget, which can be integrated into the front-end of the sportsbook’s
`platform. An end user using the sportsbook’s platform can request a bet via the widget and the widget
`can thereafter retrieve the data needed to populate the end user’s betslip. This data includes, for example,
`the bet generated by the sportsbook’s trading platform, which is transmitted by Genius Sports back-end
`(e.g., their Pricing Engine) to the Multibet widget. Although the bets are generated dynamically by the
`sportsbook’s platform, the bets are always stored by Genius Sports for re-use.
`
`Key Features
`the first live sporting
`event; and
`[1C] at least one socket
`server communicatively
`coupled to the control
`server to:
`[1C.1] receive from the
`control server at least the
`first event information;
`and
`[1C.2] transmit the first
`event information to at
`least the first viewer
`client device of the first
`plurality of viewer client
`devices via a first event
`information Internet
`communication channel
`between at least one first
`event socket of the at
`least one socket server
`and the first viewer client
`device of the first
`plurality of viewer
`devices, wherein the at
`least one first event
`socket corresponds to the
`first event information
`germane to the first live
`sporting event.
`
`
` 6
`
`
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`

`

`Key Features
`
`Accused Product
`
`
`
`(See, PANDA_000065,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4136337521/Multibet+Front-
`End+Integration.)
`
`
`
`
`
`
`(See, PANDA_000533 at PANDA_000535,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4283664043/Multibet+Sportsbook+Integration
`+V3#Sportsbook-Trading-Platform-Response-to-Multibet-Market-Messages.)
`
`In addition, Genius Sports transmits at least the bet generated by the sportsbook’s trading platform, to
`the Genius widget on client’s device via the Internet.
`
` 7
`
`
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`

`

`Key Features
`
`Accused Product
`
`
`
`
`
`(See, PANDA_000001,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4284776797/Authenticating+User-
`Session+Using+a+Proxy+Service.)
`
`Communication between the Multibet widget and Genius Sport’s back-end is accomplished using Genius
`Sport’s SmartStream integration. SmartStream products are embedded within a webpage via an iframe.
`
` 8
`
`
`
`Sportradar 1019
`Page 16
`
`

`

`Key Features
`
`Accused Product
`
`
`
`(See, PANDA_000065,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4136337521/Multibet+Front-
`End+Integration.)
`
`
`
`
`(See, PANDA_000077,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/56529015/SmartStream+Integrations.)
`
`
`
`
` 9
`
`
`
`Sportradar 1019
`Page 17
`
`

`

`Key Features
`
`Accused Product
`
`
`
`
`
`(See, PANDA_000077-PANDA_000078,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/56529015/SmartStream+Integrations.)
`Genius Sports offers several data-related product offerings to provide sportsbooks various data streams
`(betting data, sports data). In one example, Genius Sports’ platform uses Multibet, which allows end
`users (e.g., bettors) to place same-game parlays during a sports match. Multibet is specifically offered to
`sportsbooks for integration into their trading platform.
`As shown in the screenshots below, Genius Sports transmits the soccer game score, total goals
`over/under, total corners, first goal scorer, player cards, etc.
`
`
`10
`
`Sportradar 1019
`Page 18
`
`

`

`Key Features
`
`Accused Product
`
`
`
`
`(See, PANDA_000111 at PANDA_000112-PANDA_000113,
`https://geniussports.com/sportsbook/betting-data-odds/in-play-multibet/.)
`
`
`
`
`
`11
`
`Sportradar 1019
`Page 19
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`

`

`Key Features
`
`Accused Product
`
`
`
`
`(See, PANDA_000179-PANDA_000180, https://www.geniussports.com/newsroom/genius-sports-
`launches-in-play-multibet-for-the-next-generation-of-same-game-parlay-bets/.)
`
`Genius Sports offers several options to sportsbooks to integrate MultiBet into their trading platform. In
`one example, Genius Sports provides a Multibet API, Sportsbook Integration (V3), and a UI widget to
`facilitate both front-end and back-end integration.
`
`
`
`12
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`Sportradar 1019
`Page 20
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`

`

`Key Features
`
`Accused Product
`During operation, Genius Sport’s Integration Service (provided by Sportsbook Integration (V3))
`transmits various data (fixtures, markets, prices, results) to the sportsbook’s trading platform via an
`Internet connection. Additionally, the Integration Service transmits a message to create a market (bet) in
`the sportsbook’s trading platform. In return, the generated bet is transmitted from the trading platform to
`the Integration Service. In this manner, the sportsbook and Genius Sports services retrieve information
`germane to the first live sporting event via the Internet.
`
`
`
`
`(See, PANDA_000212 at PANDA_000213,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4283664027/Multibet+Back-End+Integration.)
`
`
`
`
`
`
`13
`
`Sportradar 1019
`Page 21
`
`

`

`Key Features
`
`Accused Product
`
`
`
`(See, PANDA_000539,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/34822492/Integration+Schema.)
`
`
`
`
`
`
`14
`
`Sportradar 1019
`Page 22
`
`

`

`Key Features
`
`Accused Product
`
`
`
`(See, PANDA_000209 at PANDA_000210,
`https://geniussports.atlassian.net/wiki/spaces/BID/pages/4284187362/Market+Lifetime.)
`
`
`
`
`
`
`
`
`
`15
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`Sportradar 1019
`Page 23
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`

`

`
`
`2.
`
`Dependent Claim 2
`
`Key Features
`[2.P] The system of claim
`1, wherein:
`
`[2A] the first live stream
`of digital content and the
`second live stream of
`digital content both relate
`to the first live sporting
`event;
`
`Accused Product
`
`See Claim 1, supra.
`
`The Accused Products deliver “thousands of low latency live streams” from top tier football leagues
`across Argentina, Colombia, Iceland and China, as well as dozens of FIBA basketball and FIVB
`volleyball leagues globally. The delivered “live streams” include “the first live stream of digital content
`and the second live stream of digital content both relate to the first live sporting event.”
`
`
`
`
`(See, PANDA_000176-PANDA_000177, https://geniussports.com/newsroom/genius-sports-builds-out-
`official-data-trading-and-live-streaming-partnership-with-tipsport/.)
`
`
`
`
`16
`
`Sportradar 1019
`Page 24
`
`

`

`Key Features
`
`Accused Product
`
`
`
`
`(See, PANDA_000015, https://investors.geniussports.com/news/news-details/2019/Betgenius-
`launches-live-streaming-service-for-sportsbooks/default.aspx.)
`
`As stated below, Genius Sports’ platform pairs “video, captured direct from pitch or courtside … with
`official data and live betting services…”:
`
`
`17
`
`Sportradar 1019
`Page 25
`
`

`

`Key Features
`
`Accused Product
`
`
`
`
`
`(See, PANDA_000015-PANDA_000016, https://investors.geniussports.com/news/news-
`details/2019/Betgenius-launches-live-streaming-service-for-sportsbooks/default.aspx.)
`
`The Accused Products comprise at least one socket server. See discussion of Claim Element 19C, inf