`
`The following chart contains Supercell’s Invalidity Contentions demonstrating that Gratuitous Space Battles, Game and Manual1
`anticipates claims 1-16 of U.S. Patent No. 10,335,682 under 35 U.S.C. § 102 or renders the same claims obvious alone or in view of
`other prior art under 35 U.S.C. § 103. Because the Court has yet to issue a claim construction in this case, fact discovery is ongoing,
`and the invalidity of the asserted claims will likely be the subject of expert discovery, these contentions are preliminary only and
`Supercell reserves the right to supplement or modify these contentions in accordance with the agreed patent-disclosure procedures and
`the Docket Control Order in this case. Additionally, and in further consideration of the preliminary stages of the case, Supercell notes
`that the pinpoint citations referenced in this chart are not exhaustive, and Supercell reserves the right to rely on additional citations
`within the reference. Furthermore, citations to any figure, table, or chart are meant to encompass the language describing the
`respective figure, table, or chart, and vice versa.
`
`These charts also incorporate analysis based upon GREE’s apparent interpretation of the asserted claims, as reflected in GREE’s
`infringement contentions to date. Supercell does not agree with GREE’s incomplete, ambiguous, and inadequate application of the
`asserted claims in those contentions. However, as detailed below, such application (to the extent that it can be reasonably ascertained)
`further renders each asserted claim invalid. Supercell further reserves its right to supplement these contentions based on further
`discovery, including any supplemental infringement contentions or any interrogatory response purporting to rebut these invalidity
`contentions provided by GREE.
`
`Additionally, Supercell notes that while certain potential obviousness arguments and combinations may be cited within these charts,
`such recitations are not exhaustive. As such, to the extent that any asserted claims are found not to be anticipated by Gratuitous Space
`Battles, Supercell reserves the right to argue that such non-anticipated claims are obvious over Gratuitous Space Battles alone, in view
`of any of the arguments raised within the charts, in view of any of the other prior art cited in Supercell’s cover pleading, or in view of
`prior art that may later become known to Supercell as part of the discovery process.
`
`
`
`
`1 Gratuitous Space Battles is a video game that was publicly available on or before November 17, 2009. The printed publications cited herein (e.g., Manual for
`Gratuitous Space Battles. Version 1.1; Gratuitous Space Battles - Gameplay How to! (part 1) - TGN available at
`https://www.youtube.com/watch?v=RCHroucekmQ; Gratuitous Space Battles - Gameplay How to! (part 2) - TGN available at
`https://www.youtube.com/watch?v=jMF_HOHxTwI) qualify as prior art to the asserted patent herein as disclosing a prior art system, as a combination of printed
`publications, or both.
`
`1
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 1 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`1 Preamble: A method
`performed by a user
`terminal used by a first
`player, the method
`comprising:
`
`Gratuitous Space Battles
`
`Gratuitous Space Battles discloses a method performed by a user terminal used by a first player, the
`method.
`
`See, e.g., Gratuitous Space Battles at pg. 4:
`
`“‘[S]urvival’ mode missions, which pit you against endless waves of enemies attacking from all
`directions. Skirmish missions can be uploaded as challenges to other players, whereas survival
`missions are strictly single-player affairs.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`“Editing and Adding Ship Designs Right clicking the design icons allows you delete them, but be
`warned that this deletes the design entirely from your PC.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 9:
`
`“Browsing Challenges. The main menu has an option for you to check your challenges. This button
`will connect online to the galactic server, so ensure your firewall will allow this, or be prepared to fix
`it if it doesn’t. We recommend doing this in windowed mode the first time.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“The enemy Admiral may have cruelly taunted you along with the challenge. Accepting a challenge
`downloads the challenger’s fleet formation to your PC, and battle can then be fought just like any
`other mission. The server will keep track of how many attempts you make to beat the challenge,
`before finally doing so.”
`
`2
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 2 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“GSB is relatively demanding for a 2D game. Especially on your video card. You may want to turn
`some options off from the options screen. It’s also likely you might want to switch to windowed
`mode, or change the screen resolution. You can also adjust the volumes here, and similar stuff.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Ensure you have the latest video card drivers for your PC before trying anything else. If in doubt,
`try the demo first. This game uses Microsoft’s DirectX9, which should be already installed on your
`computer. Your video card must support a minimum screen height of 768 pixels. Some smaller
`netbooks do not support this and will not run the game.”
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 9-10:
`
`3
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 3 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`
`
`
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or obvious.
`Moreover, it would have been obvious to one of ordinary skill in the art to modify this reference so as to
`include this claim limitation in light of the knowledge possessed by one of ordinary skill in the art.
`Further, this claim limitation would have been obvious in light of numerous other U.S. patents, U.S.
`patent publications, articles, and products available at the time the asserted patent was filed, and it would
`have been obvious to combine these references to a person of ordinary skill in the art. For example, see
`at least the corresponding claim elements in the respective charts, which are incorporated by reference as
`
`4
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 4 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`1a: transmitting first
`information to a server
`from the user terminal,
`the first information
`identifying a second
`player which is different
`from the first player and
`being designated by the
`first player,
`
`if fully set forth herein: Mastermind, Backyard Monsters, Cho, Farone, Kim, Sword of the Stars,
`Madden 25, FIFA 13, Gratuitous Tank Battles, JP 200.
`
`Gratuitous Space Battles discloses transmitting first information to a server from the user terminal, the
`first information identifying a second player which is different from the first player and being designated
`by the first player.
`
`See, e.g., Gratuitous Space Battles at pg. 4:
`
`“‘[S]urvival’ mode missions, which pit you against endless waves of enemies attacking from all
`directions. Skirmish missions can be uploaded as challenges to other players, whereas survival
`missions are strictly single-player affairs.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`“Editing and Adding Ship Designs Right clicking the design icons allows you delete them, but be
`warned that this deletes the design entirely from your PC.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 9:
`
`“Browsing Challenges. The main menu has an option for you to check your challenges. This button
`will connect online to the galactic server, so ensure your firewall will allow this, or be prepared to fix
`it if it doesn’t. We recommend doing this in windowed mode the first time.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`5
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 5 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`
`
`“The enemy Admiral may have cruelly taunted you along with the challenge. Accepting a challenge
`downloads the challenger’s fleet formation to your PC, and battle can then be fought just like any
`other mission. The server will keep track of how many attempts you make to beat the challenge,
`before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“GSB is relatively demanding for a 2D game. Especially on your video card. You may want to turn
`some options off from the options screen. It’s also likely you might want to switch to windowed
`mode, or change the screen resolution. You can also adjust the volumes here, and similar stuff.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Ensure you have the latest video card drivers for your PC before trying anything else. If in doubt,
`try the demo first. This game uses Microsoft’s DirectX9, which should be already installed on your
`computer. Your video card must support a minimum screen height of 768 pixels. Some smaller
`netbooks do not support this and will not run the game.”
`
`6
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 6 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“The challenges listed can be toggled to be either all challenges, or those that are explicitly sent to
`you by other players. The enemy Admiral may have cruelly taunted you along with the challenge.
`Accepting a challenge downloads the challenger’s fleet formation to your PC, and battle can then be
`fought just like any other mission. The server will keep track of how many attempts you make to beat
`the challenge, before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Online. This screen allows you to enter your registration code and set your username for challenges.
`Your username has to be unique. Do not share your serial number with anyone else, of any species, if
`you do so, it may become disabled by antipiracy measures, and you will no longer be able to
`download or upload challenges, or patch the game. There are two windows of note on this screen.
`The first is where you enter your serial code, the second is where you select the username that you set
`to that code. Obviously at this point the game will connect to the internet, so ensure your firewall will
`not block the game from doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 9-10:
`
`7
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 7 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`
`
`
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or obvious.
`Moreover, it would have been obvious to one of ordinary skill in the art to modify this reference so as to
`include this claim limitation in light of the knowledge possessed by one of ordinary skill in the art.
`Further, this claim limitation would have been obvious in light of numerous other U.S. patents, U.S.
`patent publications, articles, and products available at the time the asserted patent was filed, and it would
`have been obvious to combine these references to a person of ordinary skill in the art. For example, see
`at least the corresponding claim elements in the respective charts, which are incorporated by reference as
`
`8
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 8 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`if fully set forth herein: Mastermind, Cho, Farone, JP 200, Backyard Monsters, Cho, Farone, Kim,
`Madden 25, Gratuitous Tank Battles, Sword of the Stars, FIFA 13.
`
`Gratuitous Space Battles discloses the server receiving second information from another user terminal
`executing a game, the second information being associated with the second player and the second
`information indicating types and positions of at least one of a set of game contents arranged within at
`least a part of a game space.
`
`See, e.g., Gratuitous Space Battles at pg. 1:
`
`1b: the server receiving
`second information from
`another user terminal
`executing a game, the
`second information
`being associated with the
`second player and the
`second information
`indicating types and
`positions of at least one
`of a set of game contents
`arranged within at least a
`part of a game space;
`and
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 2:
`
`
`
`9
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 9 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`(“Ship Design”):
`
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 2:
`
`
`
`10
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 10 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 4:
`
`
`
`11
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 11 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 4:
`
`
`
`
`
`12
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 12 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`(“The Deployment Screen):
`
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`
`
`13
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 13 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`
`
`14
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 14 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`(“The Battle Screen”):
`
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`
`
`“Editing and Adding Ship Designs Right clicking the design icons allows you delete them, but be
`warned that this deletes the design entirely from your PC.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`15
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 15 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`
`
`16
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 16 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 8:
`
`17
`
`
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 17 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 9:
`
`“Browsing Challenges. The main menu has an option for you to check your challenges. This button
`will connect online to the galactic server, so ensure your firewall will allow this, or be prepared to fix
`it if it doesn’t. We recommend doing this in windowed mode the first time.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`
`
`“The enemy Admiral may have cruelly taunted you along with the challenge. Accepting a challenge
`downloads the challenger’s fleet formation to your PC, and battle can then be fought just like any
`other mission. The server will keep track of how many attempts you make to beat the challenge,
`before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`18
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 18 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`“GSB is relatively demanding for a 2D game. Especially on your video card. You may want to turn
`some options off from the options screen. It’s also likely you might want to switch to windowed
`mode, or change the screen resolution. You can also adjust the volumes here, and similar stuff.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Ensure you have the latest video card drivers for your PC before trying anything else. If in doubt,
`try the demo first. This game uses Microsoft’s DirectX9, which should be already installed on your
`computer. Your video card must support a minimum screen height of 768 pixels. Some smaller
`netbooks do not support this and will not run the game.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“The challenges listed can be toggled to be either all challenges, or those that are explicitly sent to
`you by other players. The enemy Admiral may have cruelly taunted you along with the challenge.
`Accepting a challenge downloads the challenger’s fleet formation to your PC, and battle can then be
`fought just like any other mission. The server will keep track of how many attempts you make to beat
`the challenge, before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Online. This screen allows you to enter your registration code and set your username for challenges.
`Your username has to be unique. Do not share your serial number with anyone else, of any species, if
`you do so, it may become disabled by antipiracy measures, and you will no longer be able to
`download or upload challenges, or patch the game. There are two windows of note on this screen.
`The first is where you enter your serial code, the second is where you select the username that you set
`
`19
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 19 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`to that code. Obviously at this point the game will connect to the internet, so ensure your firewall will
`not block the game from doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 2-3:
`
`20
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 20 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 5-6:
`
`
`
`21
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 21 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`
`
`
`
`22
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 22 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`23
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 23 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`See, e.g., https://www.youtube.com/watch?v=jMF_HOHxTwI (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`24
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 24 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`25
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 25 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`26
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 26 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`27
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 27 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`28
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 28 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`29
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 29 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`30
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 30 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`31
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 31 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or obvious.
`Moreover, it would have been obvious to one of ordinary skill in the art to modify this reference so as to
`include this claim limitation in light of the knowledge possessed by one of ordinary skill in the art.
`Further, this claim limitation would have been obvious in light of numerous other U.S. patents, U.S.
`patent publications, articles, and products available at the time the asserted patent was filed, and it would
`have been obvious to combine these references to a person of ordinary skill in the art. For example, see
`at least the corresponding claim elements in the respective charts, which are incorporated by reference as
`if fully set forth herein: Mastermind, Backyard Monsters, Cho, Farone, Kim, Madden 25, Gratuitous
`
`32
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 32 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`1c: receiving, at the user
`terminal, third
`information from the
`server based on the first
`information, the third
`information being
`associated with the
`second player, the third
`information being
`related to the second
`information, and the
`third information being
`used for reproducing the
`types and the positions
`of the at least one of the
`set of game contents
`arranged within the at
`least a part of the game
`space in the user
`terminal.
`
`Tank Battles, Sword of the Stars, JP 200, Legend of Grimrock Dungeon Editor, FIFA 13, Gratuitous
`Space Battle.
`
`Gratuitous Space Battles discloses receiving, at the user terminal, third information from the server
`based on the first information, the third information being associated with the second player, the third
`information being related to the second information, and the third information being used for
`reproducing the types and the positions of the at least one of the set of game contents arranged within the
`at least a part of the game space in the user terminal.
`
`See, e.g., Gratuitous Space Battles at pg. 1:
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 2:
`
`
`
`33
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 33 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 2:
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 2:
`
`34
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 34 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 4:
`
`
`
`35
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 35 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`36
`
`
`
`
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 36 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 5:
`
`
`
`37
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 37 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 6:
`
`
`
`38
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 38 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`
`
`“Editing and Adding Ship Designs Right clicking the design icons allows you delete them, but be
`warned that this deletes the design entirely from your PC.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`39
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 39 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 7:
`
`
`
`40
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 40 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 8:
`
`41
`
`
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 41 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 9:
`
`“Browsing Challenges. The main menu has an option for you to check your challenges. This button
`will connect online to the galactic server, so ensure your firewall will allow this, or be prepared to fix
`it if it doesn’t. We recommend doing this in windowed mode the first time.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“The enemy Admiral may have cruelly taunted you along with the challenge. Accepting a challenge
`downloads the challenger’s fleet formation to your PC, and battle can then be fought just like any
`other mission. The server will keep track of how many attempts you make to beat the challenge,
`before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“GSB is relatively demanding for a 2D game. Especially on your video card. You may want to turn
`some options off from the options screen. It’s also likely you might want to switch to windowed
`mode, or change the screen resolution. You can also adjust the volumes here, and similar stuff.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Ensure you have the latest video card drivers for your PC before trying anything else. If in doubt,
`try the demo first. This game uses Microsoft’s DirectX9, which should be already installed on your
`computer. Your video card must support a minimum screen height of 768 pixels. Some smaller
`netbooks do not support this and will not run the game.”
`
`42
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 42 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“The challenges listed can be toggled to be either all challenges, or those that are explicitly sent to
`you by other players. The enemy Admiral may have cruelly taunted you along with the challenge.
`Accepting a challenge downloads the challenger’s fleet formation to your PC, and battle can then be
`fought just like any other mission. The server will keep track of how many attempts you make to beat
`the challenge, before finally doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pg. 10:
`
`“Online. This screen allows you to enter your registration code and set your username for challenges.
`Your username has to be unique. Do not share your serial number with anyone else, of any species, if
`you do so, it may become disabled by antipiracy measures, and you will no longer be able to
`download or upload challenges, or patch the game. There are two windows of note on this screen.
`The first is where you enter your serial code, the second is where you select the username that you set
`to that code. Obviously at this point the game will connect to the internet, so ensure your firewall will
`not block the game from doing so.”
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 2-3:
`
`43
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 43 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`See, e.g., Gratuitous Space Battles at pgs. 5-6:
`
`
`
`44
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 44 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`
`
`
`
`45
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 45 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`
`
`
`
`46
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 46 of 375
`
`
`
`Exhibit G-7: U.S. Patent No. 10,335,682 to Gratuitous Space Battles, Game and Manual (“Gratuitous Space Battles”)
`
`’682 Patent claim 1
`
`Gratuitous Space Battles
`
`See, e.g., https://www.youtube.com/watch?v=jMF_HOHxTwI (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`See, e.g., https://www.youtube.com/watch?v=RCHroucekmQ (published May 29, 2011) (last accessed
`December 2, 2019):
`
`
`
`47
`
`Patent Owner Gree, In