WARGAMING GROUP LIMITED and ACTIVISION BLIZZARD, INC., Petitioners,

Pursuant to the Board’s October 24, 2017 Scheduling Order (Paper 16), 37 C.F.R. § 42.70(a), and 35 U.S.C. § 316(a)(10), Petitioners respectfully request oral argument on July 11, 2018.

Petitioners request (without any intent to waive consideration of any issue not requested) one hour for the Petitioners to address the following issues at the oral hearing:  Ground 1: Claims 1–7 are obvious under Levine (Ex. 1004) in view of Dungeons & Dragons Player’s Handbook (Ex. 1005);  No Service on Wargaming.net LLP in the United Kingdom; and  Motion to Exclude Exhibit 2027 (Paper 30).

Petitioners additionally request that the Board provide audio-visual equipment to display demonstrative exhibits, including a projector to be connected to a laptop, and a document camera for displaying documents of record.

77, No. 157, at 48768, Petitioners will contact the Board Trial Division paralegal to discuss this request.

WARGAMING GROUP LIMITED and ACTIVISION BLIZZARD, INC., Petitioners,

Honorable Board: The parties hereby notify the Board that the parties have stipulated to extend certain dates set forth in the Scheduling Order (Paper No. 16), the Notice of Stipulation to Extend Due Dates 1, 2, and 3 dated January 9, 2018 (Paper No. 35), the Notice of Stipulation to Extend Due Date 2 dated April 25, 2018 (Paper No. 45), and the Second Notice of Stipulation to Extend Due Date 2 dated May 7, 2018 (Paper No. 48).

The parties have conferred and reached agreement regarding modification of DUE DATE 2 and here stipulate to the following adjustments to the schedule: Current Date New Agreed Date

May 22, 2018 May 25, 2018 May 21, 2018 Respectfully submitted, /Harper Batts/ Harper Batts, Reg. No. 56,160

In accordance with 37 CFR § 42.8(a)(3), (b)(3) and (b)(4), Game and Technology Co., Ltd. ("Patent Owner ") submits the following Mandatory Notices.

Real Party-In-Interest The real party-in-interest is Game and Technology Co., Ltd., a Korean corporation having its registered office at 701-44, 29, Saujung-ro 74 beon-gil, Gimpo-si, Gyeonggi-do, Republic of Korea.

Related Matters The following judicial and/or administrative matters may affect, or may be affected by, a decision in this Inter Partes Review.

1250 Connecticut Avenue, NW, Suite 700 Washington, D.C. 20036 Tel.

Service Information Service information is as follows, with the postal mailing address being identical to the hand-delivery address:

Commissioner: Game and Technology, Ltd. hereby appoints: Joseph J. Zito, Reg. No. 32,076 Richard A. Castellano, Reg. No. 61,961 as attorneys to represent the undersigned before the United States Patent and Trademark Office in the Inter Partes Review of U.S. Patent 7,682,243.

The undersigned is authorized to sign this Power of Attorney on behalf of Game and Technology, Ltd.

Executed at on the /f^day of May, 2017.

Honorable Board: Petitioner and Patent Owner hereby notify the Board that the parties have stipulated to extend certain dates set forth in the Scheduling Order (Paper No. 16), the Notice of Stipulation to Extend Due Dates 1, 2, and 3 dated January 9, 2018 (Paper No. 35) and the Notice of Stipulation to Extend Due Date 2 dated April 25, 2018 (Paper No. 45).

The parties have conferred and reached agreement regarding modification of DUE DATE 2 and hereby stipulate to the following adjustments to the schedule: Current Date New Agreed Date

May 8, 2018 May 22, 2018 Dated: May 7, 2018 Respectfully submitted, /Harper Batts/ Harper Batts, Reg. No. 56,160 BAKER BOTTS L.L.P.

In accordance with 37 CFR § 42.8(a)(3), (b)(3) and (b)(4), Game and Technology Co., Ltd. ("Patent Owner ") submits the following Mandatory Notices.

Related Matters The following judicial and/or administrative matters may affect, or may be affected by, a decision in this Inter Partes Review.

Game and Technology Co. Ltd v. Blizzard Entertainment, Inc. et al, 2:16-cv- 06499 (C.D.

Activision Blizzard, Inc. v. Game and Technology Co., Ltd., IPR2016-01918 (4) Wargaming Group Limited.

Service Information Service information is as follows, with the postal mailing address being identical to the hand-delivery address:

INVENTORS: Byonng Wook KIM FILED: June 23, 2005 ISSUED: March 23, 2010

Patent Owner Game and Technology Co., Ltd hereby revokes all other powers of attorney previously granted, and appoints the attorneys and practitioners associated with Customer No. 23323 to represent Patent Owner in the above-captioned Inter Parres Review (IPR) and transact all business in the U.S. Patent and Trademark Office connected therewith.

Please address all e-mails and telephone calls to lead and back-up counsel, listed below:

Lead Counsel William 1-1.

The individual signing below has the authority to execute this document on behalf of Patent Owner, Game and Technology Co., Ltd. Signatur : W (C\_’ Printed Name: éflMQOO K!

Patent Owner and Petitioner hereby notify the Board that the parties have stipulated to extend certain dates set forth in the Scheduling Order (Paper No. 16) and the Notice of Stipulation to Extend Due Dates 1, 2, and 3 dated January 9, 2018 (Paper No. 35).

The parties have conferred and reached agreement regarding modification of DUE DATE 2 and hereby stipulate to the following adjustments to the schedule: Original Date New Agreed Date

Respectfully submitted, /John M. Bird/ # 46,027, John M. Bird for

In its Preliminary Response, Patent Owner states that “[a]s attested to in the Witness Statement of Service in Civil Action No. 2:15-cv-01260 by John Frederick Talbot, Mr. Talbot served Mr. Costas A. Joannou, who received service on behalf of Wargaming.net LLP, on December 10, 2015, in London, England.”1 Paper 8 at 4.

Petitioner denies that Wargaming.net LLP was served in the manner described by Mr. Talbot and requests that the Board consider the declaration of Mr. Joannou, which refutes Mr. Talbot’s witness statement.

Mr. Joannou states that there is no record of any courier fees charged to Wargaming.net LLP in December 2015, or the months thereafter, as there would have been if he had received any materials on behalf of Wargaming.net LLP. Id. ¶¶ 6–8.

For the reasons set forth above, Petitioner requests that the Board find that Wargaming.net LLP was not properly served, that inter partes review is not time barred, and that the Board institute inter partes review of the ’243 Patent.

Pursuant to 37 C.F.R. § 42.24(d), the undersigned certifies that the foregoing Reply contains no more than 2 pages and therefore complies with the page limitation specified in the Board’s Order Granting Petitioner’s Request to File a Reply to Patent Owner’s Preliminary Response.

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

Pursuant to 37 C.F.R. § 42.10(b), Petitioner Activision Blizzard, Inc. hereby appoints the following practitioners as their attorneys to transact all business in the United States Patent and Trademark Office associated with the above-captioned inter partes review:

The individual signing below has the authority to execute this document on behalf of Petitioner, Activision Blizzard, Inc.

Counsel for Wargaming Group Limited (“Petitioner”) contacted Game and Technology Co., Ltd.'s (“Patent Owner's”) Counsel by e-mail on July 18, 2017, requesting complete copies of Exhibits 2001 and 2002, including the attachments referred to in the Exhibits.

Patent Owner has provided copies of the attached Exhibit 2001 Supplemental and Ex. 2002 Supplemental to Patent Owner's counsel by e-mail on July 19, 2017.

Respectfully submitted,

Date: July 19, 2017 /John M. Bird/ # 46,027, John M. Bird for

In accordance with 37 C.F.R. § 42.53 and by the agreement of the parties, Petitioner Wargaming Group Limited will take the deposition of Dr. Mark Claypool on March 29, 2018 at 10:00 a.m. at the office of Sughrue Mion PLLC, 2100 Pennsylvania Avenue NW, Suite 800, Washington, DC 20037.

The deposition will be recorded stenographically and may be videotaped.

Respectfully Submitted,

The undersigned certifies that on March 7, 2018, a complete copy of the foregoing Notice of Deposition of Dr. Mark Claypool was served via electronic mail to counsel for the Patent Owner at the email address designated in the Patent Owner’s Mandatory Disclosures:

Pursuant to 37 C.F.R. § 42.24(d), the undersigned certifies that this PATENT OWNER RESPONSE complies with the type-volume limitation of 37 C.F.R. § 42.24(b).

The word count application of the word processing program used to prepare this Petition indicates that the Petition contains 13,733 words, excluding the parts of the brief exempted by 37 C.F.R. § 42.24(b).

Respectfully submitted, /John M. Bird/ # 46,027, John M. Bird for

When the error goes to form rather than substance, as these illustrative defects obviously do, and the proper defendant receives the original process, realizes it is directed at him, and thus is put on notice of the commencement of the action, there is no reason why a United States district court should refuse to permit the amendment of either the process or the return of service.” Accordingly, mere procedural printing error that caused the seal and signature to be missing from the copy of the summons properly served by Mr. Talbot does not render the service ineffective.

Moreover, Petitioner’s own citation to Levine (Ex. 1004) provides a definition of attribute that is inconsistent with the basic “ability” in the context of RPG of the ‘243 Patent and D&D, Player’s Handbook (Ex[1005]): “Such a new character is termed an avatar within the instance of the interactive, multi-user gaming application.

Each avatar can be classified in terms of three definitions: (1) role … (2) attributes—this encapsulates the person or character within the synthetic environment (e.g., hair color, eyes, description, inventory, location, etc.); and (3) name.” Levine (Ex[1004], ¶ 658).

Such a modification would have been counter to the rules of D&D, which were modified based on “collected information from a variety of customer-response outlets including our customer service department … to retool the game from the ground up and incorporate everyone’s suggestions … to improve the game” (Id.)—namely from the perspective actual players of D&D instead of Petitioner’s mere conjecture.

They love to cast their spells from behind strong fighters, to ‘magic up’ rogues and send them out to scout, and to rely on the divine healing of clerics” (Ex[1005],57, “Other Classes”)—are starkly and intentionally different than the roles of the Barbarian, Paladin, Ranger, or Druid.