Paper No. __
`Filed: June 21, 2018
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner
`____________________
`
`Case PGR2018-00039
`Patent 9,669,308
`____________________
`
`
`
`DECLARATION OF MICHAEL ZYDA
`(EXHIBIT 2001)
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`Gree, Inc.
`Ex. 2001
`Page1
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`Filed: June 21, 2018
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner
`____________________
`
`Case PGR2018-00039
`Patent 9,669,308
`____________________
`
`
`
`DECLARATION OF MICHAEL ZYDA
`(EXHIBIT 2001)
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`Ex. 2001
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` I. MY BACKGROUND
`1. My name is Michael Zyda, and I reside in California. I am an independent
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`consultant. I am not employed by GREE, Inc., have never been an employee of
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`GREE, Inc., and have not otherwise had a professional relationship with GREE,
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`Inc. I am over eighteen years of age, and I would otherwise be competent to testify
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`as to the matters set forth herein if I am called upon to do so.
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`2.
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`I submit this Declaration at the request of GREE, Inc., for consideration by
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`the Patent Trial and Appeal Board (PTAB) in Post-Grant Review (PGR) No.
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`PGR2018-00039 of U.S. Patent No. 9,669,308 (308 Patent). I am being
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`compensated for my work in connection with this Declaration. No part of my
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`compensation in this matter is dependent upon the outcome of this proceeding or
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`any issue in this proceeding.
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`3.
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`In forming my opinions, I rely on my knowledge and experience in the field
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`and on documents and information referenced in this Declaration.
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`4.
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`I began my career in Computer Graphics in 1973 as part of an undergraduate
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`research group, the Senses Bureau, at the University of California, San Diego.
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`5.
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`I earned a Master of Science in Computer and Information Science from the
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`University of Massachusetts in 1978. I was also Teaching Assistant in the
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`Department of Computer and Information Science from September 1976 - August
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`1978.
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`6.
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`I earned a Doctor of Science in Computer Science from Washington
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`University in 1984 based on my Doctoral Thesis entitled "Algorithm Directed
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`Architectures for Real-Time Surface Display Generation." I was also Research
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`Associate/Assistant in the Department of Computer Science from September 1978
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`- March 1983, and August 1983 - January 1984.
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`7.
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`I began my career as a full-time teacher of Computer Science at the Naval
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`Postgraduate School (NPS) in Monterey, California, in February of 1984 as an
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`Assistant Professor in the Department of Computer Science. In July 1990, I was
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`granted tenure. After being granted tenure and until the Fall of 2004, I held a
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`number of Positions in the Computer Science department of NPS, including
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`Academic Associate Chair for the Department of Computer Sciences, Academic
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`Associate Chair for the Modeling, Virtual Environments and Simulation
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`Curriculum, Founding Chair, Modeling, Virtual Environments and Simulation
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`Academic Group, and Professor of Computer Science.
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`8.
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`From November 2000 - November 2004, while a Professor of Computer
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`Science, I was the Founding Director of the MOVES (modeling, virtual
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`environments, and simulation) Institute at NPS. Also at NPS, my NPSNET
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`Research Group built the first networked virtual environment with fully
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`instrumented body suits that played across the Internet. My work on the
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`networking of virtual environments contributed to the development of the IEEE
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`1278.1 standard for distributed interactive simulation. I helped found the
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`subspecialty in modeling and simulation for the United States Navy, the simulation
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`operations functional area (57) for the US Army and the simulation operations area
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`(MOS-9625) for the US Marine Corps.
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`9.
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`Since October 2004, I have been the Founding Director of the University of
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`Southern California (USC) GamePipe Laboratory, and a Professor of Engineering
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`Practice in the USC Department of Computer Science. At USC, I founded the B.S.
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`in Computer Science (Games), the M.S. in Computer Science (Game
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`Development), and the USC Games joint Advanced Games course. That program
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`has been rated #1 by the Princeton Review for eight of the last nine years, and
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`program alumni have shipped games played by over 2.5 billion players (about
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`$100B in revenue).
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`10. As can be seen from the attached Curriculum Vitae (Exhibit A), I have (i)
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`authored numerous publications in the field of video games and especially
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`mobile/online gaming, (ii) numerous National Academy appointments (including a
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`lifetime appointment for "extraordinary service"), (iii) been named as an inventor
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`on numerous video-game related patent applications and patents, (iv) been named
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`to numerous video-game-related Advisory Boards, and (v) acted as an expert
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`witness in numerous video-game-related litigations and PTAB trials.
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` II. MATERIALS I CONSIDERED
`11.
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`I have reviewed and considered the following documents in forming the
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`opinions set forth in this Declaration:
`
`A.
`B.
`C.
`D.
`E.
`F.
`G.
`
`H.
`I.
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`The 308 Patent (filed as Exhibit 1001 by Supercell OY).
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`Supercell OY’s Petition for Post-Grant Review of the 308 Patent.
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`Exhibit 1002 – the prosecution history of the 308 Patent.
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`Exhibit 1003 – the USPTO Memorandum dated May 19, 2016.
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`Exhibit 1004 – the USPTO Memorandum dated November 2, 2016.
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`Exhibit 1005 – the prosecution history of U.S. Patent No. 9,468,849.
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`Exhibit 1006 – Subject Matter Eligibility Examples: Business
`Methods of December 2016.
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`Exhibit 1007 – Microsoft Computer Dictionary, 3 (4th ed. 1999).
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`Exhibits 2002 and 2004 – AMERICAN HERITAGE COLLEGE DICTIONARY
`93 and 479 (3rd ed. 1997).
`
`J.
`Exhibit 2003 – USPTO Memorandum dated April 19, 2018.
`K. Various Pokémon Series Game Manuals (Exhibit B)
`III. MY UNDERSTANDING OF LEGAL STANDARDS
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`A. Claim Construction
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`12.
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`I have been informed and understand that a claim in an unexpired patent
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`shall be given its broadest reasonable interpretation in light of the patent’s
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`specification. I have been informed and understand that claim terms are generally
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`given their plain meaning as would be understood by a person of ordinary skill in
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`the art in the context of the entire disclosure.
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`13.
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`B.
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`Patent-Eligibility for Computer-Related Inventions
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`I have been informed and understand that an invention is patent-eligible
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`under 35 U.S.C. §101 if it claims a new and useful process, machine, manufacture,
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`or composition of matter. But, under judicially-created exceptions to patent
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`eligibility, laws of nature, natural phenomena, and abstract ideas are not patentable.
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`With respect to the abstract idea exception, I have been informed and understand
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`that the inquiry to determine whether or not an invention is patent-eligible has two
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`steps: (1) determine whether the claim is directed to a patent-ineligible abstract
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`idea, and (2) if so, whether the elements of the claim both individually and as an
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`ordered combination transform the nature of the claim into a patent-eligible
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`application of the abstract idea. I have been informed and understand that claim
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`elements reciting well-understood, routine, conventional activity in the field are
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`insufficient to render the claims patent-eligible, and the question of whether a
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`claim element or combination of elements is well-understood, routine and
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`conventional to a skilled artisan in the relevant field is a question of fact.
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`C. Written Description
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`14.
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`I have been informed and understand that claims have sufficient written
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`description under 35 U.S.C. §112(a) when the disclosure of the application relied
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`upon reasonably conveys to those skilled in the art that the inventor had possession
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`of the claimed subject matter as of the filing date. I have been informed and
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`understand that this test requires an objective inquiry into the four corners of the
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`specification from the perspective of a person of ordinary skill in the art, and based
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`on that inquiry, the specification must describe an invention understandable to that
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`skilled artisan and show that the inventor actually invented the invention claimed.
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`D. Definiteness
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`15.
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`I have been informed and understand that a claim must particularly point out
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`and distinctly claim the subject matter. I have been informed and understand that a
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`claim is indefinite under 35 U.S.C. §112(b) when it contains words or phrases
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`whose meaning is unclear. I have been informed and understand that the
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`definiteness requirement is not a demand for unreasonable precision, and the
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`amount of clarity that is required necessarily invokes some standard of reasonable
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`precision in the use of language in the context of the circumstances. I have been
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`informed and understand that whether claims are sufficiently definite is based on
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`the perspective of one of ordinary skill in the art in view of the entire written
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`description and developing prosecution history.
`IV. LEVEL OF ORDINARY SKILL IN THE ART
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`16. A person of ordinary skill in the art ("skilled artisan") of the 308 Patent
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`would possess at least an associate degree in the field of computer science (or a
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`related discipline, such as computer engineering, to the extent the course of study
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`involved the design and programming of video games) and at least two years of
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`practical (e.g., work) experience in the field of video-game design and
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`programming. If the skilled artisan did not obtain a formal degree, then they
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`would have at least four years of practical (e.g., work) experience in the field of
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`video-game design and programming.
`V. CLAIM CONSTRUCTION
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`17. At the time of the invention, and in view of the specification, the skilled
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`artisan would have understood the plain meaning of the term "execute" to be "to
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`put into effect; carry out."
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`18.
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`It is true that, in a strict computer programming sense, the term "execute"
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`means to run a computer program. But the term is not used so narrowly in the 308
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`Patent. In particular, the specification of the 308 Patent is not limited to only
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`describing the running of computer programs. For example, the specification
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`clearly discloses sending instructions from the game server 1 to the communication
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`terminal 2. Exhibit 1001, 14:47-53. The sending of these instructions allows the
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`game server 1 to put the battle into effect. Thus, in the context of the server 1, the
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`skilled artisan would understand that term "execute" in the claims is used more
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`broadly to describe that the game server 1 causes the battle process to happen, i.e.,
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`the executed instructions cause the battle process to be "put into effect." The
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`skilled artisan would also have recognized that when describing the actual
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`performance of an act, the disclosure much more frequently uses the term
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`"perform" rather than "execute." See, e.g., Id. at 8:66-67, 9:18-23, 9:44-45, 10:15-
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`16; 15:31-33, 16:28-30, and 18:51-54.
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`19. For these reasons, nothing in the disclosure of the 308 Patent would have
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`caused the skilled artisan to have understood the term "execute" to have been used
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`more narrowly than in accordance with its plain meaning in the 308 Patent.
`VI. THE INVENTION CLAIMED IN THE 308 PATENT IMPROVES
`THE MOBILE VIDEO GAME SYSTEM AND/OR IMPROVES
`THE TECHNOLOGICAL FIELD OF MOBILE VIDEO GAMES
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`20. The invention described in the 308 Patent and recited in independent claims
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`1, 7, and 8 represents an innovative technological improvement over prior art video
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`game systems.
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`21. One specific technological improvement is the feature of, "when the user has
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`battled with the determined opponent in the past, determining, based on at least one
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`user operation received from the communication terminal, the procedure to be one
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`of the first mode and a second mode for executing the battle with fewer user
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`operations received from the communication terminal than in the first mode,"
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`recited in claims 1, 7, and 8 of the 308 Patent.
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`22. This feature improves the video game system and the technological field of
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`video game design because it provides the user with an option to use the claimed
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`"second mode" (disclosed "auto mode" in the 308 Patent) for executing the battle
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`that requires fewer user inputs than the claimed "first mode" (disclosed "manual
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`mode") for executing the battle. Providing the option of the second mode reduces
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`the time of conducting the battle and reduces the processing load on the system
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`because the system (i) has to act on fewer user inputs when conducting the battle,
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`and (ii) avoids the complex rendering of the manual mode battle screen 9 when
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`conducting the battle. Id. at 1:21-49, 11:63-67, and 17:16-23.
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`23. Based on my experience, at the time of the invention, a skilled artisan would
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`have understood that providing the claimed "second mode" when a user has battled
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`an opponent in the past would beneficially reduce the time of conducting the battle,
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`and reduce the processing load because the processor would (i) have to act on
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`fewer user inputs and (ii) avoid the complex rendering of the manual mode battle
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`screen. When reading the specification of the 308 Patent, the skilled artisan would
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`recognize these improvements as important technological benefits to the overall
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`system and the field of mobile gaming that directly result from providing the
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`claimed "second mode."
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`24.
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`In particular, at the time of the invention, the skilled artisan would have
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`recognized that one problem recognized by the inventors of the 308 Patent in
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`conventional combat-style games is that a user must manually battle each
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`opponent, which requires many user operations for each battle. Id. at 1:41-44.
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`This can become both tedious for the user and an unnecessary draw on system
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`resources, especially when the opponent is an opponent with whom the user has
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`battled with before. Id. at 1:21-49, 11:63-67, and 17:16-23.
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`25. Based on my experience, in network-based video games for communication
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`terminals (e.g., mobile phones), at the time of the invention, the skilled artisan
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`would have understood that it is very important to prevent an unnecessary draw on
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`the resources of the communication terminal and the overall system because
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`unnecessary memory usage and unnecessary processing load increase the time for
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`the system to conduct the battle and unnecessarily decrease battery life of the
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`communication terminal.
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`26. At the time of the invention, the skilled artisan would have further
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`understood how the claimed features result in this benefit at least because the 308
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`Patent describes an example of how the claimed "second mode" achieves these
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`benefits. In the auto mode (claimed "second mode"), the battle is conducted with
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`fewer user operations than in the manual mode by, for example, (i) conducting the
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`battle semi-automatically by omitting a portion of the command selection by the
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`user, or (ii) conducting the battle automatically by omitting all command selection
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`by the user. Id. at 8:38-43. In particular, the auto mode processing unit 13 of the
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`server 1 automatically controls the player character by selecting cards and
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`attacking the opponent in accordance with a predetermined process. Id. at 8:66-
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`9:3. For example, the auto mode processing unit 13 may select only the cards in
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`the user's deck that are of the attack type and attack in order starting with the first
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`enemy character or by prioritizing cards having a long recovery turn. Id. at 9:3-10.
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`When the auto mode processing unit 13 has completed the battle, the server 1
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`provides the results to the user. For example, the server 1 can instruct the
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`communication terminal 2 to display a battle result screen 6 indicating whether the
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`user won or lost and the content of the battle. Id. at 12:1-19, 14:58-60, and 16:34-
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`37. All of this can be done without having to render the more complex and
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`resource-intensive manual mode battle screen 9. Id. at 11:63-67.
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`27. Based on the above, it is my opinion that, at the time of the invention, the
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`skilled artisan would have considered providing the claimed "second mode" when
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`a user has battled an opponent in the past to be a technological improvement over
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`prior art video game systems because it beneficially reduces the time of conducting
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`the battle, and reduces the processing load because the processor would (i) have to
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`act on fewer user inputs and (ii) avoid the complex rendering of the manual mode
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`battle screen.
`VII. AT LEAST INDEPENDENT CLAIMS 1, 7, AND 8
`RECITE FEATURES THAT ARE NOT WELL-
`UNDERSTOOD, ROUTINE, AND CONVENTIONAL
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`28.
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`I have no reason to believe that the skilled artisan would have considered the
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`feature of, "when the user has battled with the determined opponent in the past,
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`determining, based on at least one user operation received from the communication
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`terminal, the procedure to be one of the first mode and a second mode for
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`executing the battle with fewer user operations received from the communication
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`terminal than in the first mode," recited in claims 1, 7, and 8 of the 308 Patent, to
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`have been a well-understood, routine, and conventional feature at the time of the
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`308 Patent's invention for at least the following reasons:
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`29. Neither the 308 Patent specification nor prosecution history identify it as
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`having been a well-understood, routine, and conventional feature.
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`30.
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`I am not aware of any Federal Circuit or Supreme Court decision that
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`describes it as having been a well-understood, routine, and conventional feature.
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`31. The Petitioner did not identify any prior art game system that incorporates
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`such a feature.
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`32. No prior art game system that incorporates such a feature was identified by
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`the examiner during prosecution of the 308 Patent or its family member
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`patents/applications.
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`33.
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`I am not aware of any prior art game system that incorporates such a feature.
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`34. Perhaps the most well-known, turn-based battle video games at the time of
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`the invention—the video games in the well-known Pokémon series—did not
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`include such a feature. In particular, each video game in the Pokémon series from
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`the "Pokémon Red Version" and "Pokémon Blue Version" released for Nintendo's
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`Gameboy in Japan in February of 1996, through the "Pokémon X" and "Pokémon
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`Y" versions released for Nintendo's 3DS worldwide on October 12, 2013, did not
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`include a feature that allowed a user to select a second mode for executing the
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`battle with fewer user operations received from the communication terminal than
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`in the first mode when the user has battled with the determined opponent in the
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`past. See Exhibit B.
`VIII. THE CLAIMS OF THE 308 PATENT DO
`NOT LACK WRITTEN DESCRIPTION
`
`A.
`
`The Disclosure Provides Adequate Written Description
`for Executing the Battle According to the First Mode
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`35. The disclosure of the 308 Patent conveys with reasonable clarity to a skilled
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`artisan that, at the time of the invention, Patent Owner was in possession of the
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`invention reciting executing the battle according to the first mode in at least two
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`different ways.
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`36. First, when the plain meaning of the term "execute" is properly understood
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`to be "to put into effect; carry out," the disclosure clearly describes that the server 1
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`puts the battle into effect with the determined procedure. In particular, by sending
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`an instruction to conduct the battle in manual mode, the game server 1 puts the
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`manual mode (claimed "first mode") into effect. Exhibit 1001, 14:47-53.
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`37. Second, even when "execute" is given the meaning "carry out," the 308
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`Patent also describes an alternative showing that Patent Owner was in possession
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`of the invention reciting "executing the battle with the determined procedure." In
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`particular, the game server 1 can alternatively perform some of the functions of the
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`communication terminal 2. One of the examples provided is the server 1 carrying
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`out the battle with the determined procedure instead of the communication terminal
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`2. Id. at 18:51-63. That is, this portion of the disclosure explains that the battle
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`can be carried out on the server 1 with the resulting game screen being displayed in
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`a web window on the communication terminal 2 based on data generated by the
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`server 1. Id. At the time of the invention, the skilled artisan would have
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`recognized this as a common way for a server to take over some of the processing
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`load from a client device and simply display the results of the processing (e.g.,
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`manual mode battle screen 9) in a web browser window on the communication
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`terminal 2. According to this alternative, only the menus or fixed input interfaces
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`are generated as a native display on the communication terminal 2, but the
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`processing of the battle in manual mode is carried out on the game server 2. Id.
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`B.
`
`The Disclosure Provides Adequate Written Description for
`Determining a Procedure for Executing the Battle Based
`on Whether the User has Battled an Opponent in the Past
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`38. The disclosure of the 308 Patent at the time of the invention would have
`
`conveyed with reasonable clarity to a skilled artisan the Patent Owner was in
`
`possession of the invention including determining a procedure for executing the
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`battle based on whether the user has battled an opponent in the past. In particular,
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`when viewed as a whole, it is clear that the specification describes both (i)
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`embodiments in which the procedure for the battle is based on whether the user has
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`battled an opponent in the past, and (ii) narrower embodiments in which the
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`procedure for the battle is based on whether the user has won against the opponent
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`in the past. In particular, at least four of the "solutions" described in the 308 Patent
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`disclose that the procedure is based on whether the user has battled an opponent in
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`the past. Id. at 2:1-16, 3:44-5, 4: 8-20 and 38-50. This is even more clearly
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`explained in column 17, lines 24-54, of the 308 Patent, which clearly discloses that
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`only whether a user has battled an opponent in the past needs to be considered and
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`that referring to win-loss information is an optional further consideration.
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`39. From these disclosures, the skilled artisan would have understood that the
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`server 1 can refer to the battle history to determine whether the user has battled an
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`opponent and determine a procedure for executing the battle based on whether the
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`user has battled an opponent in the past without referring to any win-loss
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`information. Thus, the 308 Patent at the time of the invention would have
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`conveyed with reasonable clarity to a skilled artisan the Patent Owner was in
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`possession of the invention including determining a procedure for executing the
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`battle based on whether the user has battled an opponent in the past.
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` IX. THE CLAIMS OF THE 308 PATENT ARE NOT INDEFINITE
`A.
`
`The Recited "Executing the Battle with
`the Determined Procedure," is Definite
`40. As explained above, the skilled artisan would have understood "execute" to
`
`mean "to put into effect; carry out." Also, as explained above, the 308 Patent
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`discloses (i) a scenario in which the server 1 "executes" the battle with the
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`determined procedure by putting the battle into effect, and (ii) another scenario in
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`which the server 1 "executes" the battle with the determined procedure by carrying
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`out the battle. Thus, the skilled artisan would have clearly understood from the
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`specification that the "metes and bounds" of the recited "executing the battle with
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`the determined procedure" cover each of these situations.
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`B.
`
`The Recited "When the User has Not Battled
`with the Determined Opponent in the Past,
`Automatically Determining a Procedure for Executing
`the Battle to be a First Mode for Executing the Battle
`Based on at Least One User Operation Received
`from the Communication Terminal," is Definite
`
`41.
`
`It would have been clear to the skilled artisan at the time of the invention
`
`how the claimed process for automatically determining a procedure for executing
`
`the battle to be a first mode can take place based on whether the user has battled
`
`the opponent. As explained above, the disclosure clearly discloses embodiments in
`
`which the procedure for the battle is based on whether the user has battled an
`
`opponent in the past without referring to win-loss information. Based on the
`
`Gree, Inc.
`Ex. 2001
`Page17
`
`
`
`
`disclosure of the 308 Patent, the skilled artisan would have understood that this can
`
`be done by referring to the battle history 112, which indicates which opponents a
`
`PGR2018-00039
`U.S. Patent No. 9,669,308
`
`user has battled in the past. E.g., Id. at 7:59-61, 17:24-47.
`X. CONCLUSION
`
`42.
`
`I declare under penalty of perjury that the foregoing Declaration is true and
`
`correct. Of course, my analysis is continuing and I may modify or supplement my
`
`conclusions as I receive additional information.
`
`Dated: _________
`
`June 20, 2018June 20, 2018
`
`
`
`
`
`Attachments:
`
`Exhibit A: Curriculum Vitae of Michael Zyda
`
`Exhibit B: Pokémon Series Game Manuals
`
`___________________________
`Michael Zyda
`
`
`
`Gree, Inc.
`Ex. 2001
`Page18
`
`
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