`
`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
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`Supercell
`Exhibit 1010
`Page 1
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`
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`I, Antti Takala, hereby declare and state as follows:
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`INTRODUCTION AND QUALIFICATIONS
`
`I.
`Clash of Clans Version 4.120
`
`1.
`
`I am a game programmer at Supercell Oy (“Supercell”). I have personal
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`knowledge of the matters set forth in this declaration and, if called upon to do so,
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`could and would testify competently as to the matters set forth herein. I was directly
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`involved in the development of Clash of Clans and particularly version 4.120 of
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`Supercell’s Clash of Clans video game.
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`2.
`
`I am familiar with the operation and gameplay features of Clash of
`
`Clans as available in Clash of Clans version 4.120.
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`3. Clash of Clans is an online, mobile video game developed by Supercell.
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`4. Clash of Clans was first published on the App Store and available to
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`iOS devices on August 2, 2012. Version 4.120 of Clash of Clans was available for
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`download on iOS devices through the App Store on August 28, 2013.
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`5.
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`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
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`with the source code for version 4.120 of Clash of Clans and the executable file
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`“magic.exe,” which was used by the developers of Clash of Clans to test the features
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`and operations of Clash of Clans version 4.120 on a personal computer.
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`Supercell
`Exhibit 1010
`Page 2
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`6.
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`Supercell submitted to Apple, Inc. the file containing Clash of Clans
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`version 4.120 through the iTunes Connect System on August 22, 2013, which was
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`then made available for download through iOS devices on the App Store on August
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`28, 2013.
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`7.
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`The program submitted to Apple for distribution to iOS devices is
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`specifically designed for the App Store and cannot be installed by a user on a device
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`or computer outside of Apple’s system.
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`8.
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`The file “magic.exe” is an executable application file containing the
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`program that runs Clash of Clans version 4.120 on an IBM PC-compatible personal
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`computer. This file is used by Supercell developers to test and see how the game
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`Clash of Clans and its features in version 4.120 operate. It is referred to as the
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`“developer build” of version 4.120 of Clash of Clans.
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`9.
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`The magic.exe program file was created based on the same source code
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`that was used to create the iOS build of Clash of Clans version 4.120. The features
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`and gameplay shown in the developer build are identical to the program submitted to
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`Apple and released on August 28, 2013 and available for download and execution by
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`iOS devices, except that the developer build simulates the touch screen capabilities of
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`the application played on mobile devices by allowing input using a mouse and cursor,
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`where the application available to players has a touchscreen interface, and the
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`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
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`used by developers to test the game and its features.
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`10. The file containing Clash of Clans version 4.120, which was available
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`to players through the App Store, runs on devices that communicate with a server via
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`a network, and exchange data with the server in order to perform the various
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`functions within the game.
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`Gameplay
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`11. The discussion of gameplay features of Clash of Clans 4.120 is based on
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`my personal knowledge of Clash of Clans version 4.120. The figures below are
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`screenshots taken from the developer build file of Clash of Clans version 4.120 and
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`are included in this declaration to illustrate my personal knowledge of the operation
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`of version 4.120 of Clash of Clans. The screenshots below are consistent with my
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`personal knowledge of the operation of version 4.120 of Clash of Clans and are used
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`to illustrate that knowledge. The gameplay and features shown in these screenshots
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`accurately reflect the gameplay available to players operating version 4.120 of Clash
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`of Clans on iOS devices as available on August 27, 2013.
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`12.
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`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
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`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,
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`which improve the player’s in-game ranking. Similarly, a player’s village may be
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`attacked by other players, where the other player will seek to steal loot stored in the
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`village and earn trophies through a successful attack.
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`13. Clash of Clans is played by a player executing the Clash of Clans
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`application on a device, such as an iPhone or other iOS device, in communication
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`with a gameplay server via the Internet.
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`14. The gameplay server maintains data about each player and coordinates
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`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
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`players, and facilitates matchmaking between players. The gameplay server
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`exchanges data with iOS devices running the application that communicate with it
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`via a network. The devices, in turn, exchange data with the server in order to
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`perform the various functions within the game
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`Play Area and Game Objects
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`15. Fig. 1 shows a player’s home village screen showing the player’s
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`village.
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`Supercell
`Exhibit 1010
`Page 5
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`
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`Fig. 1
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`
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`16. As shown in Fig. 1, the village includes various gameplay objects
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`placed in a play area. In the village shown above there is a central “Town Hall”
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`object, gold “Wall” objects, various defensive towers including two “Archer
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`Towers,” two “Cannons,” a “Mortar” and an “Air Defense.” Other gameplay objects
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`include a resource collectors and storage containers and objects to train and store
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`“Troops.”
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`17. As shown above, the play area is made up of a grid of individual tiles on
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`which the gameplay objects may be placed. The unoccupied tiles in the play area
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`alternate dark and light colors. The different gameplay objects include different
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`Supercell
`Exhibit 1010
`Page 6
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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.
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`Fig. 2
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`
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`18. Fig 2 illustrates a “Tree” obstacle object in the village. The “Tree”
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`obstacle shown above occupies a 3x3 space on the gameplay area grid. Other
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`obstacle objects include stones, rocks, mushrooms, and other obstructions. These
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`obstacles cannot be moved by the player and they prevent a player from placing other
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`game objects at the location of the obstacle. Obstacles can only be removed from the
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`village by a player spending resources to remove them. Over time, the obstacles
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`objects are added to the village by the game at locations that are not occupied by
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`other objects.
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`Supercell
`Exhibit 1010
`Page 7
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`19. Surrounding the play area grid is a border area in which buildings may
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`not be placed, but where the game may place obstacles and where opposing players
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`may drop troops during an attack.
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`20. Figs. 3A-D show the border area surrounding the play area grid. As
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`shown in the figures below, the play area is a square shape comprising a grid of light
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`and dark green squares. The corners of this grid are displayed in each figure, and the
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`border between the play area grid and the border area is shown with a light brown
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`line. Fig. 3A shows the west corner of the play area grid, Fig. 3B shows the north
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`corner, Fig 3C shows the east corner, and Fig. 3D shows the south corner. The area
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`outside the play area grid is comprised of a level of thicker grass, then an area
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`resembling a forest or a rocky beach and water.
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`Fig. 3A
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`
`
`Supercell
`Exhibit 1010
`Page 8
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`(UNdates
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`Fig. 3B
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`
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`
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`i
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`Fig. 3C
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`Supercell
`Exhibit 1010
`Page 9
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`Placing and Moving Game Objects
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`Fig. 3D
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`21. One object of the game is for a player to protect his or her “Town Hall”
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`building and resource storage containers by arranging game objects in a player’s
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`village in a strategic manner. The arrangement of the objects affects how the village
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`defends against attacks from other players.
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`22. To move game objects in the game, such as defensive buildings (e.g.
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`cannons, archer towers, mortars), walls, the town hall, and resource buildings to
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`different locations in the play area, users interact with the touchscreen display of the
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`iOS device to select and move the object with the touchscreen interface. The user
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`moves game objects by tapping on the game object and dragging that object across
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`Supercell
`Exhibit 1010
`Page 10
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`
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`the screen to a new desired location. As noted above, the developer build emulates
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`the touchscreen interface through a mouse and cursor. To move an object using the
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`developer build, the user selects the object by hovering the cursor over the object,
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`clicking on the object, and dragging it across the screen to a new location.
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`23. Fig. 4 shows the selection of a “cannon” object by a single tap on the
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`cannon.
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`
`
`Fig. 4
`24. Fig. 4 shows the movement of a “cannon” object to a new location by
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`the user dragging the object across the play area. As shown in this Fig. 5, the cannon
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`occupies a 3x3 tile area of the game area.
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`Supercell
`Exhibit 1010
`Page 11
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`
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`Fig. 5
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`
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`25. Players can add game objects to the game area. The additional objects
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`may improve the player’s ability to grow an army, defend the village against attacks,
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`or earn and store resources. To add these additional objects to the village, a player
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`selects the “Shop” icon (shown above in Fig. 5), which brings the user to the “Shop”
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`interface as shown in Fig. 6.
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`Supercell
`Exhibit 1010
`Page 12
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`
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`Fig. 6
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`
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`26.
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`In the Shop, as shown in Fig. 6, the player is shown an interface to
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`select the type of object (“Resources,” “Decorations,” “Army,” or “Defenses”) he or
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`she would like to add to the village. A player may also purchase “Treasure,” which
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`allows a user to increase stored resources or “Shield” time, which blocks other users
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`from attacking the village.
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`27.
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`If the user selects “Defenses” from the Shop, the user will be shown the
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`“Defenses” interface, which displays individual buildings, which the player may
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`select to place in the village, if the player has sufficient stored resources and has
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`progressed far enough in the game. Fig. 7 shows the interface for selecting a defense
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`building.
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`Supercell
`Exhibit 1010
`Page 13
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`
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`Fig. 7
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`
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`28.
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`If the player selects the “Cannon” object from the Defenses interface,
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`the village screen will be displayed and the player will need to select a location in the
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`village to place the game object (the cannon) as shown in Fig. 8. The player
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`confirms the purchase of the object from the shop and the location of the object in the
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`village by selecting the green checkmark icon.
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`Supercell
`Exhibit 1010
`Page 14
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`
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`Fig. 8
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`29. After a player places or moves a game object, the Clash of Clans
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`application executing on the player’s device updates the gameplay server with the
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`positions of gameplay objects in the player’s village. The update occurs by the
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`iOS device sending data over a network to the game play server, which processes
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`the data and updates user information accordingly.
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`Attacked by Other Players
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`30.
`
`31.
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`The player’s village may be attacked by other players.
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`Fig. 9A-C shows an example attack on the player’s base by a computer
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`opponent during the game tutorial. When attacked, the defensive structures of the
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`player’s village defend against attacking units of the other player by firing at the
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`Supercell
`Exhibit 1010
`Page 15
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`
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`attacking units. In this example, a cannon in the player’s base defends against two
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`enemy goblins. In the same way as shown in Figs. 9A-C, the player’s village defends
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`against other players’ units. In Fig. 9A two “goblin” troops, shown as the two green
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`characters, are attacking the player’s village. To defend against the attack of these
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`troops, the cannon of the village fires at the goblins. Fig. 9A shows the goblins
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`attacking and a cannon ball in midflight shooting at one of the goblins.
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`Fig. 9A
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`
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`32. Fig. 9B shows the effect of the cannon shooting the goblin. After the
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`cannon ball hits the goblin its “health points” decrease. This reduction in health
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`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
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`hit from a cannon ball.
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`Fig. 9B
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`
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`33. Fig. 9C shows that the cannon continues to shoot at the goblin until it is
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`destroyed. As the cannon continues to inflict damage its health points bar continues
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`to be reduced. Since the goblin’s health is low, it health points bar turns from green
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`to red.
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`Supercell
`Exhibit 1010
`Page 17
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`
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`Fig. 9C
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`
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`34. Once the cannon shots reduce the health points of the goblin to zero, the
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`goblin dies, as is shown by the cartoon ghost and gravestone on the play area in Fig.
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`9D. If any enemy troops remain, the cannon will fire at them to defend the village.
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`Supercell
`Exhibit 1010
`Page 18
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`
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`Fig. 9D
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`
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`Attacking a Village
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`35. A player may also build units (or “troops”) in the player’s army and use
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`these troops to attack another player’s village. To do so, a player selects the
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`“Barracks” building from the village and chooses to “Train Troops” from the icons
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`shown at the bottom of the screen, as shown in Fig. 10.
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`Supercell
`Exhibit 1010
`Page 19
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`
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`Fig. 10
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`
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`36. As shown below in FIG. 11, the player is then shown several different
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`troop types, which the player may “Train” by spending a predetermined amount of
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`elixir. Training troops makes them available for use in a battle against another
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`player’s village.
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`Supercell
`Exhibit 1010
`Page 20
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`
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`Fig. 11
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`
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`37. When attacking a village, the attacking player places or “deploy” troops
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`on opposing player’s village area. Once dropped, the troops will automatically attack
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`the defending village in accordance with rules set for that type of troop.
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`38. Fig. 12 shows an example village and attack from the game tutorial. In
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`this example, five “Wizard” troops are deployed against the enemy base by selecting
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`the troops from the inventory shown at the bottom of the screen, then tapping an
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`empty area on the village of the opposing player
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`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
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`Wizards troops each attack the nearest buildings of the opposing player’s village.
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`
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`Fig. 13
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`
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`Supercell
`Exhibit 1010
`Page 22
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`
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`Attacking Other Players
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`40. To attack another player’s village, the player selects the “Attack!” icon
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`(Fig. 14) from the lower left corner of the home village screen.
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`
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`Fig. 14
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`41. After the player selects “Attack,” the player is shown an interface
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`allowing the player to select to either attack another player’s base (“Find a Match”)
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`or complete a single player mission (“Single Player”).
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`
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`Supercell
`Exhibit 1010
`Page 23
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`
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`Fig. 15
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`42. When a player selects “Find a Match,” the game server searches for a
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`village of another player to attack. The server searches from among players who are
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`not online and selects a village of another player with a similar number of trophies as
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`the attacking player.
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`43. To make a match and facilitate an attack, the game server stores
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`information about the arrangement and configuration of other players’ villages.
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`When the game server selects a match for a player, the game server sends
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`information about the defending player’s village to the attacking player’s device for
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`display. That information includes the layout of the defending village, the status of
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`the objects in the defending village, and any resources that may be available for
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`looting in the defending village.
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`44. Fig. 16 shows an example attack on a player’s village. Because the
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`developer build is not connected to a network, the example attack shown is on the
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`player’s own village. In the Clash of Clans version 4.120 which was available to the
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`public, another player’s base would be attacked by the player in the same manner.
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`45.
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`In the example attack shown in Fig. 16, the attacking player has
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`deployed several troops, including several archers and giants, at the northwest portion
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`of the village. The deployed troops are attacking the village according to a
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`predetermined set of rules. The archers are attacking the nearest buildings of the
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`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
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`towners or cannons).
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`
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`Player Data & Gameplay server
`
`Fig. 16
`
`46. The gameplay server maintains information about each player of Clash
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`of Clans. Each player has an associated unique identifier stored by the gameplay
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`server to uniquely identify the player.
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`47. The gameplay server stores information about each player’s village in
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`association with the unique identifier for that player.
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`48. The information associated with each player includes one or more
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`devices associated with the player’s village. A player may access his or her account
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`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
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`application instructing users that logging into a Game Center account permits play
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`with multiple iOS devices. Fig. 18 shows another interface in the Clash of Clans
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`application interface for linking a new device to a player’s account without a Game
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`Center account.
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`
`
`FIG. 17
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`Supercell
`Exhibit 1010
`Page 26
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`
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`Fig. 18
`49. Players may also receive an informational message (“New device was
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`linked to your village.”) when a new device is associated with the player’s village as
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`shown in Fig. 19.
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`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
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`village, including the location of game objects (i.e. buildings, walls, resource
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`collectors, obstacles) within the village and any related status of these game objects.
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`A portion of the “starting home” data file, which is the information regarding the
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`initial layout of a player’s village, is reproduced below as Fig. 20. The file shows the
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`information regarding the “buildings” in the village along with their levels and
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`locations. The “data” is the ID of the object. For example, building “data” 1000001
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`is the Town Hall building. The location of the building object is further shown with
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`stored x-y coordinates. The file also includes stored “obstacles.” This is the same
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`initial data for all players, and the format stays the same as the game progresses.
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`Supercell
`Exhibit 1010
`Page 28
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`Fig. 20
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`51. When a player opens the Clash of Clans application, the game server
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`communicates the village information to the client application. During gameplay, the
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`village information is stored in a transitory manner by the Clash of Clans application.
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`Supercell
`Exhibit 1010
`Page 29
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`When a village is modified during gameplay (e.g., game objects are added, moved,
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`upgraded, etc.), the village information is updated and stored at the player’s device in
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`a similar format, and the Clash of Clans application sends the modification to the
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`gameplay server, which updates the village information stored at the gameplay
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`server. When a player links a device (e.g., a second device) to the player’s account,
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`the game server sends the stored village information associated with that account to
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`the linked device.
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`52. When the Clash of Clans application is executed on a device linked to a
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`player’s account, the device communicates with the game server to receive the
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`village information associated with the account. When a village is modified on one
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`linked device, that modification is communicated to the game play server. When the
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`second device launches the Clash of Clans application, it loads the modified
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`information from the server and is thus synchronized with another linked device. In
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`this way, game state information for the village is shared between the multiple linked
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`devices.
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`Replay
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`53. A player may wish to watch attacks that have previously occurred
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`against his village. To do so, the player selects the envelope icon from the left side of
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`the home village screen.
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`Supercell
`Exhibit 1010
`Page 30
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`Fig. 21
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`54. As shown in Fig. 22, the player will then be shown a “Defense Log,”
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`which displays information about attacks on the player’s village by other players,
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`including the type of troop used in the attack and the percentage damage on the
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`village the attack inflicted.
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`Fig. 22
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`
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`55. The player may also replay prior attacks he has completed against other
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`users. The player can select the “Attack Log” tab from the interface above to review
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`Supercell
`Exhibit 1010
`Page 31
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`such attacks. Fig. 23 shows the Attack Log, which displays information about the
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`attack by the player made on other players’ villages.
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`Fig. 23
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`
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`56. When the player selects the “Replay” icon in either the Attack Log or
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`the Defense Log, the corresponding attack or defense is shown to the player.
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`Clans
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`57. Players may join groups of players called “clans.” A clan is a group of
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`players who may play the game together and may chat with one another in the game.
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`Players may also request troops for a player’s army from other players in the same
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`Supercell
`Exhibit 1010
`Page 32
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`
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`clan. Likewise, players may donate troops to another player’s army. Fig. 24 shows
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`an example list of clan members
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`Fig. 24
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`
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`58. A player may view the village layout of members of his or her clan by
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`tapping on the user’s name in the “View Clan” interface. As shown below in Fig. 25,
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`the player will then be shown several icons including a “Visit” button. If the player
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`selects “Visit,” the player will be shown the layout of the clan member’s village.
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`Supercell
`Exhibit 1010
`Page 33
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`
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`Fig. 25
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`
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`59. Players may also chat with the other members of the clan. To do so the
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`player selects the tab icon shown on the left side of the screen, which is shown on the
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`left side of the home village screen. The tab icon is shown below in Fig. 26.
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`
`
`Fig. 26
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`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
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`members can post messages that are seen by the members of the clan in the chat. The
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`game server stores the chat log for the clan and communicates the chat log
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`information to each player by exchanging data with the players’ device via a
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`network.
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`Fig. 27
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`
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`61. Players can also share replays of different attacks and defensive battles
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`with clan members through the clan chat. To do so, the user selects the “Share
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`Replay” icon (Fig. 28) from his or her Defense Log of Attack Log (as shown in Figs.
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`21 and 22).
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`Supercell
`Exhibit 1010
`Page 35
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`Fig. 28
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`62. After the player selects the “Share Replay” icon, the player is allowed to
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`add a comment, as shown in Fig. 29. The player then presses “Send” and the
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`comment along with a link to the replay of the video is posted to the clan chat, as
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`shown above in Fig. 27.
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`Fig. 29
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`
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`63. When a player selects the “Replay” button from the clan chat, the
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`application requests the replay from the game server which then communicates to the
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`application the information of the attack or defense including the location and status
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`Supercell
`Exhibit 1010
`Page 36
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`of the village building layout and the information about the attack troops. The replay
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`will then show the attack or defense as it occurred in the original.
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`Credits
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`64. A player may view the credits for this game version by selecting the
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`settings icon (the gears icon) shown on the right side of the village home screen (e.g.,
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`Fig. 1) and then selecting the “About” button from the Settings interface, shown
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`above in Fig. 17.
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`65. The Credits, partially shown in Fig. 30A-C show that this is version
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`4.120 of Clash of Clans and that I am a contributor to the version.
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`Fig. 30A
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`
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`Supercell
`Exhibit 1010
`Page 37
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`TaNeli DksaMa
`Riku Rikala
`MaRtiN ScHjeleR
`PetRi StYRMaN
`Ville SUUR•Uski
`TDMMi SuviNeN
`ANtti Takala
`Veli VaiNiD
`
`
`
`
`
`Fig. 30B
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`
`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
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`
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`I declare under penalty of perjury that the foregoing is true and correct. I
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`declare that all statements made herein of my knowledge are true, and that all
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`statements made on information and belief are believed to be true, and that these
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`Supercell
`Exhibit 1010
`Page 38
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`
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`statements were made with the knowledge that willful false statements and the like so
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`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18
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`of the United States Code.
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`Executed this '-.'i-~ day ofFebruary 2020.
`
`Antti Takala
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`Supercell
`Exhibit 1010
`Page 39
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`