This presumption may be rebutted when a patentee, acting as a lexicographer, sets forth an alternate definition of a term in the specification with reasonable clarity, deliberateness, and precision.

Each of the independent claims recites “wherein said sync point information is a ratio of which changes in said ability of pilot are applied to said ability of unit.” Petitioner’s proposed construction of “information indicating a relationship” ignores this express requirement of the claim, and it is also unreasonably broad in view of the ’243 patent’s disclosure that “sync point 304 is information indicating a numeric relationship between a

The maximum attacking power addition value ATPMAX represents an upper limit under which the attacking power addition value ATP is increased according to the combat count BT which is the number of times combat is waged when the player character is outfitted with said weapon item.

Although these passages may describe updating limits on unit abilities after a battle, Petitioner does not explain how coefficient y, the alleged “sync point information,” is used in this process.

As such, we are not persuaded the record before us establishes a reasonable likelihood that Petitioner would prevail on its assertions that dependent claims 2–5 and 8 would have been obvious as alleged in the Petition.

ACTIVISION BLIZZARD, INC. and RIOT GAMES, INC.,1 Petitioners,

1 Activision Blizzard, Inc. is listed as the sole Petitioner in Case IPR2016- 01918, whereas Activision Blizzard, Inc. and Riot Games, Inc. are listed as joint Petitioner entities in Cases IPR2016-01880 and IPR2016-01885.

Patent Owner represents that Petitioners do not oppose the motions.

Under these circumstances, it is ORDERED that the Motion to Withdraw filed by Patent Owner’s counsel of record in each of the above-captioned proceedings is granted; FURTHER ORDERED that Richard S. Meyer, Hae-Chan Park, and Yeasun Yoon are permitted to withdraw as counsel in each of these proceedings.

Patent Owner: William Mandir Peter Park John Bird Christopher Bezak Fadi Kiblawi

For more information, please consult the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756 (Aug. 14, 2012), which is available on the Board Web site at http://www.uspto.gov/PTAB.

Patent Owner is advised of the requirement to submit mandatory notice information under 37 C.F.R. § 42.8(a)(2) within 21 days of service of the petition.

The parties are advised that under 37 C.F.R. § 42.10(c), recognition of counsel pro hac vice requires a showing of good cause.

Joseph Zito Luiz Felipe Correa de Oliveira 1250 Connecticut Ave. NW, Suite 200 Washington, D.C. 20036 Richard B. Vaught 111 West Saint John Street Suite 500 San Jose, CA 95113 H.C. Park & Associates, PLC 1894 Preston White Drive Reston, VA 20191 Case IPR2016-01918 Patent 7,682,243

If the parties actually engage in alternative dispute resolution, the PTAB would be interested to learn what mechanism (e.g., arbitration, mediation, etc.) was used and the general result.

The Board has previously held that inadvertent omission of original foreign-language patent documents in an Inter Partes Review petition constitutes correctable clerical error under 37 C.F.R. § 42.104(c).

at 3 (granting a Motion to Correct Clerical Error to submit two inadvertently omitted exhibits) (PTAB Nov. 6, 2015) (Paper 12); see also Syntroleum Corp. v. Neste Oil Oyj, IPR2013-00178, slip op.

Likewise, the failure to include the original Japanese-language version of Kurosawa with its translation as Exhibit 1010 was both unintentional and inadvertent.

Petitioner only became aware of these two clerical mistakes when the Patent Owner raised this issue for the first time in its Preliminary Response.

Furthermore, Petitioner produced the Japanese-language versions of both Matsui and Kurosawa to Patent Owner in the related district court litigation between the parties.

Patent Owner desires new counsel in the above-captioned inter partes review proceeding.

In addition, Patent Owner 's new counsel has read and intends to comply with the Office Patent Trail Practice Guide and the Board's Rules of Practice for Trials, as set forth in Part 42 of the Code of Federal Regulations.

A Substitute Power of Attorney for Patent Owner's new counsel was submitted on November 30, 2016.

In identifying and designating new counsel who are ready and able to take over the representation, reasonable steps have been taken to "avoid foreseeable prejudice to the rights of the client, including giving due notice to his or her client, [and] allowing time for employment of another practitioner."

In addition, a decision on whether to institute this inter partes review has not yet issued, and no extensions of time will be needed upon grant of this Motion.

For terms not specifically listed and construed below, and in the absence (to date) of arguments from GAT concerning claim construction, Petitioner interprets them, for the purposes of this IPR only, in accordance with their plain and ordinary meaning.

This combination would have also improved the methods, systems, and computer readable media taught by Matsui by allowing players to bolster the capabilities of a unit, based on corresponding accomplishments of the pilot.

It would have been obvious to a POSITA to combine the leveling up disclosures of Kurosawa with the disclosures of Matsui, so that the methods, systems, and computer readable media taught by Matsui included the element “pilot information database further includes level information of said pilot and said unit.” (Id.) Each of these references is in the field of video gaming and related technology, and describes a role-playing game with in-game player characters and items or units associated with said in-game player characters.

Matsui further teaches multiplying the sync point information SK by the numerical value coefficient λ, and then adding the result to the unit ability ATPMAX, as required by this claim limitation.

For the purposes of this proceeding, Petitioner respectfully suggests that a POSITA would likely understand that the broadest reasonable interpretation of the term “biorhythm information” would include at least one element of information about the pilot’s health, strength, endurance, or life force.

Patent Owner Patent No. 7,682,243 Filing Date: June 23, 2005 Issue Date: March 23, 2010 Title: METHOD FOR PROVIDING ONLINE GAME WHICH CHANGES

1001 U.S. Patent No. 7,682,243 1002 Declaration of David Crane 1003 1004 Certified Translation of Japanese Unexamined Patent Application Publication JP2000-135372 (“Matsui”) Warlords Battlecry III Manual English (Enlight Interactive, Inc., 2004) (“Battlecry Manual”) 1005 “WBC3 Heroes Creation” file (“Battlecry Heroes Table”) 1006 “WBC3 Spells” file (“Battlecry Spells Table”) 1007 “WBC3 Units” file (“Battlecry Units Table”) 1008 1009 1010 1011 1012 1013 1014 1015 Pictures of Purchased Warlords Battlecry III Game, including CD-

Wayback Machine screenshot showing the Warlords Battlecry Website as of June 5, 2004 Certified Translation of Japanese Unexamined Patent Application Publication JP2002-200350 (“Kurosawa”) Declaration of J. Garretson Declaration of T. Chaney Declaration of P. Shah Corrected Ex. 1003 — JP2000-135372 Corrected Ex. 1010 — JP2002-200350

Dated: February 9, 2017 Respectfully submitted, By: /John D. Garretson/ John D. Garretson Reg. No. 39,681 Shook, Hardy & Bacon L.L.P. 2555 Grand Blvd.