ACTIVISION BLIZZARD, INC. and RIOT GAMES, INC., Petitioners

Document Reserved Strunk, William, and White, E.B., The Elements of Style, 2000, at

Deposition Transcript of David Crane, May 24, 2017 Pfaffenberger, Bryan, Webster’s New World Dictionary of Computer Terms, 1997, at 289.

Respectfully submitted,

Case IPR2016-01885 within ten business days of Petitioner's date of service of the objection to evidence (i.e., June 26, 2017).1 Ex. 2007 (Declaration of Kiho Lee) In response to Petitioners' objection to the authenticity of the Evidences A-G listed in Exhibit 2006 of the Patent Owner Response, Patent Owner submits a Supplemental Declaration of Kiho Lee, Ex. 2007 (Supplemental), Mr. Lee declares that "GAT has received various documents including e-mail communications related to the KPA from NHN Entertainment and You Me Patent & Law Firm (hereafter "You Me"), a Korean patent law firm which drafted and filed the KPA.

Hyunseon Kang) of You Me declaring that the "foregoing e-mails and attachments have been stored and maintained as records for the KPA of NHN Corporation in the course of You Me's regularly conducted patent business

Moreover, Ms. Kang of You Me declares that the "foregoing e-mails and attachments have been stored and maintained as records for the KPA of NHN Corporation in the course of You Me's regularly conducted patent business activities for the client."

Moreover, Mr. Lee declares that "GAT has received various documents including e-mail communications related to the KPA from NHN Entertainment and You Me Patent & Law Firm (hereafter "You Me"), a Korean patent law firm which drafted and filed the KPA.

Mr. Lee also declares "GAT has received various documents including e-mail communications related to the KPA from NHN Entertainment and You Me Patent & Law Firm (hereafter "You Me"), a Korean patent law firm which drafted and filed the KPA.

(701, 702, 703) Patent Owner has not demonstrated that Mr. Lee is qualified to render an expert opinion, or otherwise has personal knowledge as a lay witness.

Patent Owner also does not provide support for Mr. Lee’s statement that the “Evidence” discloses one or more claim elements of the ‘743 patent; that any of the “Evidence” shows conception and reduction to practice of the claimed invention as of a particular date; that any of the “Evidence” shows “due diligence” between any two particular dates; or that an expert would rely on the type and extent of information provided to reach such conclusions.

Exhibit 2009 (Geunwoo Choi Email and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Email,” or that the purported authorship, source or date is accurate.

(403) Any purported relevance is outweighed by unfair prejudice, confusion, or the potential to mislead, for the reasons previously discussed.. Exhibit 2011 (Gamvatar Scheme and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Gamvatar Scheme,” or that the purported authorship, source or date is accurate.

(403) Any purported relevance is outweighed by unfair prejudice, confusion, or the potential to mislead, for the reasons previously discussed.. Exhibit 2012 (Zip File Folder and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Zip File Folder,” or that the purported authorship, source or date is accurate.

(701, 702, 703) Patent Owner has not demonstrated that Mr. Lee is qualified to render an expert opinion, or otherwise has personal knowledge as a lay witness.

Patent Owner also does not provide support for Mr. Lee’s statement that the “Evidence” discloses one or more claim elements of the ‘743 patent; that any of the “Evidence” shows conception and reduction to practice of the claimed invention as of a particular date; that any of the “Evidence” shows “due diligence” between any two particular dates; or that an expert would rely on the type and extent of information provided to reach such conclusions.

Exhibit 2009 (Geunwoo Choi Email and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Email,” or that the purported authorship, source or date is accurate.

(403) Any purported relevance is outweighed by unfair prejudice, confusion, or the potential to mislead, for the reasons previously discussed.. Exhibit 2011 (Gamvatar Scheme and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Gamvatar Scheme,” or that the purported authorship, source or date is accurate.

(403) Any purported relevance is outweighed by unfair prejudice, confusion, or the potential to mislead, for the reasons previously discussed.. Exhibit 2012 (Zip File Folder and English Language Translation) (901) Patent Owner has not provided evidence to authenticate this “Zip File Folder,” or that the purported authorship, source or date is accurate.

Here, claim 1 recites use of the compound subject “the plurality of game item functions being combined with the respective layers.” See Strunk, William, and White, E.B., The Elements of Style, 2000, Print (Ex. 2004) at 10 describing “compound subjects qualified by each or every;” contra Decision (Paper 15) § II.A.3, p. 9, “exhaust[ion] in the claims to refer to ‘game item functions.’” The compound subject “the plurality of game item functions being combined with the respective layers” is preceded by the preposition “each of” and succeeded by the singular verb “is exhausted.” See Ex. 2004, p. 10, “Use a singular verb form after each.” To construe otherwise would impermissibly read out the limitation “being combined with the respective layers” from the claim.

Case IPR2016-01885 (2014); see also Wowza Media Sys., LLC v. Adobe Sys., Inc., IPR2013-00054, Paper 16 at 4 (2013) (“Expert testimony that does not disclose the underlying facts or data on which the opinion is based is entitled to little or no weight.”)

“Armor descriptions also contain other important information, including defense value, chance to block an attack (if applicable), current and total durability, and any magical properties.” Ex. 1013, p. 69.

In fact, the D2 Manual expressly discloses a different functionality: “When using ranged weapons, an icon of “crossed arrows” appears on the Play Area whenever your quiver is running low on ammunition.” Ex. 1013, p. 67.

The disclosures of “slots” and “Inventory Panel” in the DAoC Manual do not inherently (i.e., necessarily) require “the avatar comprising multiple layers,” as recited in the claims of the ‘743 Patent.