throbber
Filed on behalf of Supercell Oy
`
`By:
`BRIAN M. HOFFMAN, Reg. No. 39,713
`JENNIFER R. BUSH, Reg. No. 50,784
`GREGORY A. HOPEWELL Reg. No. 66,012
`MICHAEL J. SACKSTEDER
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.5200
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`SUPERCELL OY,
`Petitioner,
`
`v.
`
`GREE, Inc.,
`Patent Owner.
`_____________
`
`DECLARATION OF ANTTI TAKALA REGARDING CLASH OF CLANS
`VERSION 4.120
`
`Supercell
`Exhibit 1010
`Page 1
`
`

`

`I, Antti Takala, hereby declare and state as follows:
`
`INTRODUCTION AND QUALIFICATIONS
`
`I.
`Clash of Clans Version 4.120
`
`1.
`
`I am a game programmer at Supercell Oy (“Supercell”). I have personal
`
`knowledge of the matters set forth in this declaration and, if called upon to do so,
`
`could and would testify competently as to the matters set forth herein. I was directly
`
`involved in the development of Clash of Clans and particularly version 4.120 of
`
`Supercell’s Clash of Clans video game.
`
`2.
`
`I am familiar with the operation and gameplay features of Clash of
`
`Clans as available in Clash of Clans version 4.120.
`
`3. Clash of Clans is an online, mobile video game developed by Supercell.
`
`4. Clash of Clans was first published on the App Store and available to
`
`iOS devices on August 2, 2012. Version 4.120 of Clash of Clans was available for
`
`download on iOS devices through the App Store on August 28, 2013.
`
`5.
`
`I am also familiar with the process of submitting version 4.120 of Clash
`
`of Clans for inclusion in the App Store and its release to the public. I am familiar
`
`with the source code for version 4.120 of Clash of Clans and the executable file
`
`“magic.exe,” which was used by the developers of Clash of Clans to test the features
`
`and operations of Clash of Clans version 4.120 on a personal computer.
`
`Supercell
`Exhibit 1010
`Page 2
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`

`

`6.
`
`Supercell submitted to Apple, Inc. the file containing Clash of Clans
`
`version 4.120 through the iTunes Connect System on August 22, 2013, which was
`
`then made available for download through iOS devices on the App Store on August
`
`28, 2013.
`
`7.
`
`The program submitted to Apple for distribution to iOS devices is
`
`specifically designed for the App Store and cannot be installed by a user on a device
`
`or computer outside of Apple’s system.
`
`8.
`
`The file “magic.exe” is an executable application file containing the
`
`program that runs Clash of Clans version 4.120 on an IBM PC-compatible personal
`
`computer. This file is used by Supercell developers to test and see how the game
`
`Clash of Clans and its features in version 4.120 operate. It is referred to as the
`
`“developer build” of version 4.120 of Clash of Clans.
`
`9.
`
`The magic.exe program file was created based on the same source code
`
`that was used to create the iOS build of Clash of Clans version 4.120. The features
`
`and gameplay shown in the developer build are identical to the program submitted to
`
`Apple and released on August 28, 2013 and available for download and execution by
`
`iOS devices, except that the developer build simulates the touch screen capabilities of
`
`the application played on mobile devices by allowing input using a mouse and cursor,
`
`where the application available to players has a touchscreen interface, and the
`
`Supercell
`Exhibit 1010
`Page 3
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`

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`developer build contains an offline game mode and a “Debug Menu,” which are tools
`
`used by developers to test the game and its features.
`
`10. The file containing Clash of Clans version 4.120, which was available
`
`to players through the App Store, runs on devices that communicate with a server via
`
`a network, and exchange data with the server in order to perform the various
`
`functions within the game.
`
`Gameplay
`
`11. The discussion of gameplay features of Clash of Clans 4.120 is based on
`
`my personal knowledge of Clash of Clans version 4.120. The figures below are
`
`screenshots taken from the developer build file of Clash of Clans version 4.120 and
`
`are included in this declaration to illustrate my personal knowledge of the operation
`
`of version 4.120 of Clash of Clans. The screenshots below are consistent with my
`
`personal knowledge of the operation of version 4.120 of Clash of Clans and are used
`
`to illustrate that knowledge. The gameplay and features shown in these screenshots
`
`accurately reflect the gameplay available to players operating version 4.120 of Clash
`
`of Clans on iOS devices as available on August 27, 2013.
`
`12.
`
`In Clash of Clans, players build a cartoon-style medieval village
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`comprised of a town hall, fortifications, and buildings for amassing an army and
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`accruing resources such as elixir and gold. Players use their accrued resources to
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`build and upgrade the components of their village and strength of their army. Players
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`Supercell
`Exhibit 1010
`Page 4
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`

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`use their armies to attack the villages of other players. During an attack, a player
`
`seeks to steal “loot” (i.e. gold and elixir resources) stored by the opposing player.
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`Further, if a player completes a successful attack, he or she is awarded trophies,
`
`which improve the player’s in-game ranking. Similarly, a player’s village may be
`
`attacked by other players, where the other player will seek to steal loot stored in the
`
`village and earn trophies through a successful attack.
`
`13. Clash of Clans is played by a player executing the Clash of Clans
`
`application on a device, such as an iPhone or other iOS device, in communication
`
`with a gameplay server via the Internet.
`
`14. The gameplay server maintains data about each player and coordinates
`
`gameplay between the players. As part of this function, a gameplay server maintains
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`information about each player’s village, attacks made by players, messages between
`
`players, and facilitates matchmaking between players. The gameplay server
`
`exchanges data with iOS devices running the application that communicate with it
`
`via a network. The devices, in turn, exchange data with the server in order to
`
`perform the various functions within the game
`
`Play Area and Game Objects
`
`15. Fig. 1 shows a player’s home village screen showing the player’s
`
`village.
`
`Supercell
`Exhibit 1010
`Page 5
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`

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`Fig. 1
`
`
`
`16. As shown in Fig. 1, the village includes various gameplay objects
`
`placed in a play area. In the village shown above there is a central “Town Hall”
`
`object, gold “Wall” objects, various defensive towers including two “Archer
`
`Towers,” two “Cannons,” a “Mortar” and an “Air Defense.” Other gameplay objects
`
`include a resource collectors and storage containers and objects to train and store
`
`“Troops.”
`
`17. As shown above, the play area is made up of a grid of individual tiles on
`
`which the gameplay objects may be placed. The unoccupied tiles in the play area
`
`alternate dark and light colors. The different gameplay objects include different
`
`Supercell
`Exhibit 1010
`Page 6
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`

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`types of objects, such as buildings (e.g., town hall, cannons, archer towers, etc.),
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`walls, traps (e.g., bombs and springs), and obstacles.
`
`Fig. 2
`
`
`
`18. Fig 2 illustrates a “Tree” obstacle object in the village. The “Tree”
`
`obstacle shown above occupies a 3x3 space on the gameplay area grid. Other
`
`obstacle objects include stones, rocks, mushrooms, and other obstructions. These
`
`obstacles cannot be moved by the player and they prevent a player from placing other
`
`game objects at the location of the obstacle. Obstacles can only be removed from the
`
`village by a player spending resources to remove them. Over time, the obstacles
`
`objects are added to the village by the game at locations that are not occupied by
`
`other objects.
`
`Supercell
`Exhibit 1010
`Page 7
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`

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`19. Surrounding the play area grid is a border area in which buildings may
`
`not be placed, but where the game may place obstacles and where opposing players
`
`may drop troops during an attack.
`
`20. Figs. 3A-D show the border area surrounding the play area grid. As
`
`shown in the figures below, the play area is a square shape comprising a grid of light
`
`and dark green squares. The corners of this grid are displayed in each figure, and the
`
`border between the play area grid and the border area is shown with a light brown
`
`line. Fig. 3A shows the west corner of the play area grid, Fig. 3B shows the north
`
`corner, Fig 3C shows the east corner, and Fig. 3D shows the south corner. The area
`
`outside the play area grid is comprised of a level of thicker grass, then an area
`
`resembling a forest or a rocky beach and water.
`
`Fig. 3A
`
`
`
`Supercell
`Exhibit 1010
`Page 8
`
`

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`(UNdates
`
`Fig. 3B
`
`
`
`
`
`i
`
`Fig. 3C
`
`Supercell
`Exhibit 1010
`Page 9
`
`

`

`
`
`Placing and Moving Game Objects
`
`Fig. 3D
`
`21. One object of the game is for a player to protect his or her “Town Hall”
`
`building and resource storage containers by arranging game objects in a player’s
`
`village in a strategic manner. The arrangement of the objects affects how the village
`
`defends against attacks from other players.
`
`22. To move game objects in the game, such as defensive buildings (e.g.
`
`cannons, archer towers, mortars), walls, the town hall, and resource buildings to
`
`different locations in the play area, users interact with the touchscreen display of the
`
`iOS device to select and move the object with the touchscreen interface. The user
`
`moves game objects by tapping on the game object and dragging that object across
`
`Supercell
`Exhibit 1010
`Page 10
`
`

`

`the screen to a new desired location. As noted above, the developer build emulates
`
`the touchscreen interface through a mouse and cursor. To move an object using the
`
`developer build, the user selects the object by hovering the cursor over the object,
`
`clicking on the object, and dragging it across the screen to a new location.
`
`23. Fig. 4 shows the selection of a “cannon” object by a single tap on the
`
`cannon.
`
`
`
`Fig. 4
`24. Fig. 4 shows the movement of a “cannon” object to a new location by
`
`the user dragging the object across the play area. As shown in this Fig. 5, the cannon
`
`occupies a 3x3 tile area of the game area.
`
`Supercell
`Exhibit 1010
`Page 11
`
`

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`Fig. 5
`
`
`
`25. Players can add game objects to the game area. The additional objects
`
`may improve the player’s ability to grow an army, defend the village against attacks,
`
`or earn and store resources. To add these additional objects to the village, a player
`
`selects the “Shop” icon (shown above in Fig. 5), which brings the user to the “Shop”
`
`interface as shown in Fig. 6.
`
`Supercell
`Exhibit 1010
`Page 12
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`

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`Fig. 6
`
`
`
`26.
`
`In the Shop, as shown in Fig. 6, the player is shown an interface to
`
`select the type of object (“Resources,” “Decorations,” “Army,” or “Defenses”) he or
`
`she would like to add to the village. A player may also purchase “Treasure,” which
`
`allows a user to increase stored resources or “Shield” time, which blocks other users
`
`from attacking the village.
`
`27.
`
`If the user selects “Defenses” from the Shop, the user will be shown the
`
`“Defenses” interface, which displays individual buildings, which the player may
`
`select to place in the village, if the player has sufficient stored resources and has
`
`progressed far enough in the game. Fig. 7 shows the interface for selecting a defense
`
`building.
`
`Supercell
`Exhibit 1010
`Page 13
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`

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`Fig. 7
`
`
`
`28.
`
`If the player selects the “Cannon” object from the Defenses interface,
`
`the village screen will be displayed and the player will need to select a location in the
`
`village to place the game object (the cannon) as shown in Fig. 8. The player
`
`confirms the purchase of the object from the shop and the location of the object in the
`
`village by selecting the green checkmark icon.
`
`Supercell
`Exhibit 1010
`Page 14
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`

`

`Fig. 8
`
`29. After a player places or moves a game object, the Clash of Clans
`
`application executing on the player’s device updates the gameplay server with the
`
`positions of gameplay objects in the player’s village. The update occurs by the
`
`iOS device sending data over a network to the game play server, which processes
`
`the data and updates user information accordingly.
`
`Attacked by Other Players
`
`30.
`
`31.
`
`The player’s village may be attacked by other players.
`
`Fig. 9A-C shows an example attack on the player’s base by a computer
`
`opponent during the game tutorial. When attacked, the defensive structures of the
`
`player’s village defend against attacking units of the other player by firing at the
`
`Supercell
`Exhibit 1010
`Page 15
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`

`

`attacking units. In this example, a cannon in the player’s base defends against two
`
`enemy goblins. In the same way as shown in Figs. 9A-C, the player’s village defends
`
`against other players’ units. In Fig. 9A two “goblin” troops, shown as the two green
`
`characters, are attacking the player’s village. To defend against the attack of these
`
`troops, the cannon of the village fires at the goblins. Fig. 9A shows the goblins
`
`attacking and a cannon ball in midflight shooting at one of the goblins.
`
`Fig. 9A
`
`
`
`32. Fig. 9B shows the effect of the cannon shooting the goblin. After the
`
`cannon ball hits the goblin its “health points” decrease. This reduction in health
`
`Supercell
`Exhibit 1010
`Page 16
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`

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`points is illustrated by the green bar above the character becoming smaller after each
`
`hit from a cannon ball.
`
`Fig. 9B
`
`
`
`33. Fig. 9C shows that the cannon continues to shoot at the goblin until it is
`
`destroyed. As the cannon continues to inflict damage its health points bar continues
`
`to be reduced. Since the goblin’s health is low, it health points bar turns from green
`
`to red.
`
`Supercell
`Exhibit 1010
`Page 17
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`

`

`Fig. 9C
`
`
`
`34. Once the cannon shots reduce the health points of the goblin to zero, the
`
`goblin dies, as is shown by the cartoon ghost and gravestone on the play area in Fig.
`
`9D. If any enemy troops remain, the cannon will fire at them to defend the village.
`
`Supercell
`Exhibit 1010
`Page 18
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`

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`Fig. 9D
`
`
`
`Attacking a Village
`
`35. A player may also build units (or “troops”) in the player’s army and use
`
`these troops to attack another player’s village. To do so, a player selects the
`
`“Barracks” building from the village and chooses to “Train Troops” from the icons
`
`shown at the bottom of the screen, as shown in Fig. 10.
`
`Supercell
`Exhibit 1010
`Page 19
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`

`

`Fig. 10
`
`
`
`36. As shown below in FIG. 11, the player is then shown several different
`
`troop types, which the player may “Train” by spending a predetermined amount of
`
`elixir. Training troops makes them available for use in a battle against another
`
`player’s village.
`
`Supercell
`Exhibit 1010
`Page 20
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`

`

`Fig. 11
`
`
`
`37. When attacking a village, the attacking player places or “deploy” troops
`
`on opposing player’s village area. Once dropped, the troops will automatically attack
`
`the defending village in accordance with rules set for that type of troop.
`
`38. Fig. 12 shows an example village and attack from the game tutorial. In
`
`this example, five “Wizard” troops are deployed against the enemy base by selecting
`
`the troops from the inventory shown at the bottom of the screen, then tapping an
`
`empty area on the village of the opposing player
`
`Supercell
`Exhibit 1010
`Page 21
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`

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`Fig. 12
`39. Fig. 13, below, shows deployed units attacking the village. The
`
`Wizards troops each attack the nearest buildings of the opposing player’s village.
`
`
`
`Fig. 13
`
`
`
`Supercell
`Exhibit 1010
`Page 22
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`

`

`Attacking Other Players
`
`40. To attack another player’s village, the player selects the “Attack!” icon
`
`(Fig. 14) from the lower left corner of the home village screen.
`
`
`
`Fig. 14
`
`41. After the player selects “Attack,” the player is shown an interface
`
`allowing the player to select to either attack another player’s base (“Find a Match”)
`
`or complete a single player mission (“Single Player”).
`
`
`
`Supercell
`Exhibit 1010
`Page 23
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`

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`Fig. 15
`
`42. When a player selects “Find a Match,” the game server searches for a
`
`village of another player to attack. The server searches from among players who are
`
`not online and selects a village of another player with a similar number of trophies as
`
`the attacking player.
`
`43. To make a match and facilitate an attack, the game server stores
`
`information about the arrangement and configuration of other players’ villages.
`
`When the game server selects a match for a player, the game server sends
`
`information about the defending player’s village to the attacking player’s device for
`
`display. That information includes the layout of the defending village, the status of
`
`the objects in the defending village, and any resources that may be available for
`
`looting in the defending village.
`
`44. Fig. 16 shows an example attack on a player’s village. Because the
`
`developer build is not connected to a network, the example attack shown is on the
`
`player’s own village. In the Clash of Clans version 4.120 which was available to the
`
`public, another player’s base would be attacked by the player in the same manner.
`
`45.
`
`In the example attack shown in Fig. 16, the attacking player has
`
`deployed several troops, including several archers and giants, at the northwest portion
`
`of the village. The deployed troops are attacking the village according to a
`
`predetermined set of rules. The archers are attacking the nearest buildings of the
`
`Supercell
`Exhibit 1010
`Page 24
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`

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`village, while the giants move to attack the nearest defensive buildings (e.g. archer
`
`towners or cannons).
`
`
`
`Player Data & Gameplay server
`
`Fig. 16
`
`46. The gameplay server maintains information about each player of Clash
`
`of Clans. Each player has an associated unique identifier stored by the gameplay
`
`server to uniquely identify the player.
`
`47. The gameplay server stores information about each player’s village in
`
`association with the unique identifier for that player.
`
`48. The information associated with each player includes one or more
`
`devices associated with the player’s village. A player may access his or her account
`
`Supercell
`Exhibit 1010
`Page 25
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`

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`from multiple, different devices. Fig. 17 shows an interface in the Clash of Clans
`
`application instructing users that logging into a Game Center account permits play
`
`with multiple iOS devices. Fig. 18 shows another interface in the Clash of Clans
`
`application interface for linking a new device to a player’s account without a Game
`
`Center account.
`
`
`
`FIG. 17
`
`Supercell
`Exhibit 1010
`Page 26
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`
`
`Fig. 18
`49. Players may also receive an informational message (“New device was
`
`linked to your village.”) when a new device is associated with the player’s village as
`
`shown in Fig. 19.
`
`Supercell
`Exhibit 1010
`Page 27
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`

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`
`
`Fig. 19
`50. The gameplay server stores and maintains information about a player’s
`
`village, including the location of game objects (i.e. buildings, walls, resource
`
`collectors, obstacles) within the village and any related status of these game objects.
`
`A portion of the “starting home” data file, which is the information regarding the
`
`initial layout of a player’s village, is reproduced below as Fig. 20. The file shows the
`
`information regarding the “buildings” in the village along with their levels and
`
`locations. The “data” is the ID of the object. For example, building “data” 1000001
`
`is the Town Hall building. The location of the building object is further shown with
`
`stored x-y coordinates. The file also includes stored “obstacles.” This is the same
`
`initial data for all players, and the format stays the same as the game progresses.
`
`Supercell
`Exhibit 1010
`Page 28
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`
`
`Fig. 20
`
`51. When a player opens the Clash of Clans application, the game server
`
`communicates the village information to the client application. During gameplay, the
`
`village information is stored in a transitory manner by the Clash of Clans application.
`
`Supercell
`Exhibit 1010
`Page 29
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`

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`When a village is modified during gameplay (e.g., game objects are added, moved,
`
`upgraded, etc.), the village information is updated and stored at the player’s device in
`
`a similar format, and the Clash of Clans application sends the modification to the
`
`gameplay server, which updates the village information stored at the gameplay
`
`server. When a player links a device (e.g., a second device) to the player’s account,
`
`the game server sends the stored village information associated with that account to
`
`the linked device.
`
`52. When the Clash of Clans application is executed on a device linked to a
`
`player’s account, the device communicates with the game server to receive the
`
`village information associated with the account. When a village is modified on one
`
`linked device, that modification is communicated to the game play server. When the
`
`second device launches the Clash of Clans application, it loads the modified
`
`information from the server and is thus synchronized with another linked device. In
`
`this way, game state information for the village is shared between the multiple linked
`
`devices.
`
`Replay
`
`53. A player may wish to watch attacks that have previously occurred
`
`against his village. To do so, the player selects the envelope icon from the left side of
`
`the home village screen.
`
`Supercell
`Exhibit 1010
`Page 30
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`
`
`Fig. 21
`
`54. As shown in Fig. 22, the player will then be shown a “Defense Log,”
`
`which displays information about attacks on the player’s village by other players,
`
`including the type of troop used in the attack and the percentage damage on the
`
`village the attack inflicted.
`
`Fig. 22
`
`
`
`55. The player may also replay prior attacks he has completed against other
`
`users. The player can select the “Attack Log” tab from the interface above to review
`
`Supercell
`Exhibit 1010
`Page 31
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`such attacks. Fig. 23 shows the Attack Log, which displays information about the
`
`attack by the player made on other players’ villages.
`
`Fig. 23
`
`
`
`56. When the player selects the “Replay” icon in either the Attack Log or
`
`the Defense Log, the corresponding attack or defense is shown to the player.
`
`Clans
`
`57. Players may join groups of players called “clans.” A clan is a group of
`
`players who may play the game together and may chat with one another in the game.
`
`Players may also request troops for a player’s army from other players in the same
`
`Supercell
`Exhibit 1010
`Page 32
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`clan. Likewise, players may donate troops to another player’s army. Fig. 24 shows
`
`an example list of clan members
`
`Fig. 24
`
`
`
`58. A player may view the village layout of members of his or her clan by
`
`tapping on the user’s name in the “View Clan” interface. As shown below in Fig. 25,
`
`the player will then be shown several icons including a “Visit” button. If the player
`
`selects “Visit,” the player will be shown the layout of the clan member’s village.
`
`Supercell
`Exhibit 1010
`Page 33
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`Fig. 25
`
`
`
`59. Players may also chat with the other members of the clan. To do so the
`
`player selects the tab icon shown on the left side of the screen, which is shown on the
`
`left side of the home village screen. The tab icon is shown below in Fig. 26.
`
`
`
`Fig. 26
`
`Supercell
`Exhibit 1010
`Page 34
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`60. The player then enters the clan chat, shown in Fig. 27. In the clan chat
`
`members can post messages that are seen by the members of the clan in the chat. The
`
`game server stores the chat log for the clan and communicates the chat log
`
`information to each player by exchanging data with the players’ device via a
`
`network.
`
`Fig. 27
`
`
`
`61. Players can also share replays of different attacks and defensive battles
`
`with clan members through the clan chat. To do so, the user selects the “Share
`
`Replay” icon (Fig. 28) from his or her Defense Log of Attack Log (as shown in Figs.
`
`21 and 22).
`
`Supercell
`Exhibit 1010
`Page 35
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`
`
`Fig. 28
`
`62. After the player selects the “Share Replay” icon, the player is allowed to
`
`add a comment, as shown in Fig. 29. The player then presses “Send” and the
`
`comment along with a link to the replay of the video is posted to the clan chat, as
`
`shown above in Fig. 27.
`
`Fig. 29
`
`
`
`63. When a player selects the “Replay” button from the clan chat, the
`
`application requests the replay from the game server which then communicates to the
`
`application the information of the attack or defense including the location and status
`
`Supercell
`Exhibit 1010
`Page 36
`
`

`

`of the village building layout and the information about the attack troops. The replay
`
`will then show the attack or defense as it occurred in the original.
`
`Credits
`
`64. A player may view the credits for this game version by selecting the
`
`settings icon (the gears icon) shown on the right side of the village home screen (e.g.,
`
`Fig. 1) and then selecting the “About” button from the Settings interface, shown
`
`above in Fig. 17.
`
`65. The Credits, partially shown in Fig. 30A-C show that this is version
`
`4.120 of Clash of Clans and that I am a contributor to the version.
`
`Fig. 30A
`
`
`
`Supercell
`Exhibit 1010
`Page 37
`
`

`

`TaNeli DksaMa
`Riku Rikala
`MaRtiN ScHjeleR
`PetRi StYRMaN
`Ville SUUR•Uski
`TDMMi SuviNeN
`ANtti Takala
`Veli VaiNiD
`
`
`
`
`
`Fig. 30B
`
`
`ClasH of ClaNs TM 4.120.0
`COpvRigHt 2012 SupeRcell Ltd. All RigHt5 ReseRved.
`us PateNt PeNdiNg
`All use of tHis softwaRe is subject to TeRMS aNd
`CoNditioNs aNd PRivacv Policv at
`www.supeRcell.Net.
`FDR suppoRt CONtact
`clasHof claNs. feedback@supeRcell.Net.
`
`
`Fig. 30C
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct. I
`
`declare that all statements made herein of my knowledge are true, and that all
`
`statements made on information and belief are believed to be true, and that these
`
`Supercell
`Exhibit 1010
`Page 38
`
`

`

`statements were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18
`
`of the United States Code.
`
`Executed this '-.'i-~ day ofFebruary 2020.
`
`Antti Takala
`
`Supercell
`Exhibit 1010
`Page 39
`
`

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