Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`The following chart contains Supercell’s Invalidity Contentions demonstrating that Mastermind’s In-Game Builder Post1 anticipates
`claims 1-18 of U.S. Patent No. 10,398,978 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 Mastermind,
`Supercell reserves the right to argue that such non-anticipated claims are obvious over Mastermind 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 Mastermind is a video game that was publicly available on or before September 11, 2013. The printed publications cited herein (e.g., Mastermind, Mastermind
`Declaration; Pocket Gamer available at
`https://web.archive.org/web/20130502020345/http:/www.pocketgamer.co.uk/r/iPhone/Clash+of+Clans/review.asp?c=47309, 148; Apps available at
`https://web.archive.org/web/20130520190542/http:/www.148apps.com/reviews/clash-clans-review/; Gamezebo available at
`https://web.archive.org/web/20130501012448/http:/www.gamezebo.com/games/clash-clans/review; GSM Arena available at
`https://web.archive.org/web/20130513063213/http://www.gsmarena.com/apple_iphone_3gs-2826.php; Gameplay 3 available at
`https://www.youtube.com/watch?v=AIYLcHgA-Hw) 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 2006 - Page 1 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`
`
`
`
`
`
`’978 Patent claim 1
`
`1 Preamble: A method
`performed by a portable
`electronic device, the method
`comprising:
`
`Mastermind
`
`Mastermind discloses a method performed by a portable electronic device, the method.
`
`See, e.g., 148Apps:
`
`
`
`See, e.g., Gamezebo:
`
`
`
`“Clash of Clans is thus a simple game, but that's more of a strength than a weakness. It's simple
`enough to provide quick, painless matches on an iPhone in an idle moment, and there are
`enough different units to choose from in the battle mode to make playing against other players
`endlessly rewarding. Best of all, the option to fight against NPC goblins gives Clash of Clans a
`small edge over similar strategy games that rely almost entirely on player-versus-player
`combat.”
`
`
`
`See, e.g., GSM Arena (showing features of iPhone 3 gs):
`
`2
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 2 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Pocket Gamer:
`
`
`
`See, e.g., Pocket Gamer:
`
`
`
`
`
`“Clash of Clans hit the App Store in its full 1.7 release on June 13th 2012, after spending some
`time in closed beta.”
`
`
`
`3
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 3 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`To the extent GREE claims that the claimed functionality is not sufficiently disclosed in
`Mastermind, it is further shown through operation of the Clash of Clans game (e.g., version
`4.120), which will be made available to GREE for inspection. To the extent this limitation is not
`explicitly disclosed by this combination, 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, Sword of the Stars.
`
`Mastermind discloses executing a game by arranging, based on a command received from a first
`player, a plurality of game contents within a game space, the game contents including at least
`game contents for defending from an attack initiated by a second player.
`
`See, e.g., 148Apps:
`
`“Clash of Clans puts players in charge of their own village/township/whatever it is clans hang
`out in and tasks them with not only expanding their colony but attacking and defending against
`others.”
`
`
`
`See, e.g., Gameplay 3 at 0:08.:
`
`1a: executing a game by
`arranging, based on a
`command received from a first
`player, a plurality of game
`contents within a game space,
`the game contents including at
`least game contents for
`defending from an attack
`initiated by a second player;
`
`4
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 4 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Gamezebo:
`
`
`
`“Clash of Clans is thus a simple game, but that's more of a strength than a weakness. It's simple
`enough to provide quick, painless matches on an iPhone in an idle moment, and there are
`enough different units to choose from in the battle mode to make playing against other players
`endlessly rewarding. Best of all, the option to fight against NPC goblins gives Clash of Clans a
`small edge over similar strategy games that rely almost entirely on player-versus-player
`combat.”
`
`
`
`5
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 5 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Gamezebo:
`
`“You could be forgiven for thinking that Clash of Clans was a modded reskin of the recently
`released Galaxy Life: Pocket Adventures. While they differ in visual styles, both games center
`on building up a base in a persistent online environment and then defending it from other
`players. Feeling feisty? You can attack other players as well.”
`
`
`
`See, e.g., Mastermind at 1:
`
`“Currently, the way to build a base is to move everything you have over to the side/edges of the
`base and then start moving things back in a new formation.”
`
`
`
`See, e.g., Mastermind at 2:
`
`6
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 6 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`(showing game contents within a game space)
`
`
`
`See, e.g., Mastermind at 2-3:
`
`
`
`“Let’s get started, back with the original image:
`
`As you can see on the right side of this image, a new button was adde
`
`Touching this button leads to a brand new page with 2 option
`
`Builder and Layouts. Even though this thread has a lot of new things added to the game, I'll try
`to keep it as simple and easy to understand as possible. On this page, you can either click
`
`7
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 7 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`Builder or Layouts. Builder will take you to the actual Base Builder where you can design a
`new base, and Layouts is where your previously made Base Designs are saved (and where you
`can switch from one base design to another in a matter of seconds). Extra points for what game
`the scrolls on the Layout button was taken from [smiley image] For now, let's focus on the
`Builder and select that option:” s:
`
`d:
`
`
`
`
`8
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 8 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`
`
`9
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 9 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Mastermind at 3:
`
`“On this page, you can either click Builder or Layouts. Builder will take you to the actual Base
`Builder where you can design a new base, and Layouts is where your previously made Base
`Designs are saved (and where you can switch from one base design to another in a matter of
`seconds). Extra points for what game the scrolls on the Layout button was taken from [smiley
`image] For now, let's focus on the Builder and select that option:”
`
`
`
`See, e.g., Mastermind at 4:
`
`
`
`10
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 10 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`“This part of the new UI is the heart of the Base Builder. Like stated above, I've made it to look
`like an Attack you would make on any base. But instead of troops, base items are in their place.
`Everything in this window is pretty self explanatory: it includes the picture of the item and how
`many items there are. In this instance, there are five Level 10 Cannons you can place. As you
`may notice, there are 2 different Archer Towers. That simply means they are different levels (as
`shown in the picture).”
`
`
`
`See, e.g., Mastermind at 4:
`
`“This window/picture is the main focus of this thread. This is the In-Game Base Builder! When
`thinking of different ideas of how to make the Base Builder, I liked this idea best. The user
`interface and set-up looks a lot like an Attack screen, so the user would feel fairly comfortable
`with the familiarity of it's design. The other option I was thinking of going with was one like on
`ClashofClansBuilder.com, but instead of the completely top-down view, I decided to go with
`this one. As you can see, there are many new features and buttons that I will explain very
`clearly for you all. The base is completely open, allowing the user to have free reign of placing
`objects. This feature alone is the reason I want the idea (whether my version or another) in the
`game badly.”
`
`
`
`See, e.g., Mastermind at 4:
`
`
`
`11
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 11 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 5:
`
`
`
`See, e.g., Mastermind at 5:
`
`
`
`“I will show an example of what it will look like later (as far as not using every item), but as
`each item is placed, the meters go up. Walls count for both Walls and Total.”
`
`12
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 12 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`
`
`
`
`
`
`“As shown in this picture, we are currently on the ALL tab (as shown by the + icon being
`highlighted on the lowerright) and we've selected the Town Hall. Once clicked, the Town Hall
`pops up on the main screen.”
`
`
`
`See, e.g., Mastermind at 6:
`
`13
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 13 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`“This screenshot exemplifies what happens if you click off and set the Town Hall (or any item)
`in place. As shown in the 2 screenshots above, the Total Bar moves up 1. Again, every item
`needs to be set in place before a base can be saved. Also, the info screen, Send Back Button,
`and white highlight around the Town Hall Button disappear.”
`
`
`
`
`
`See, e.g., Mastermind at 6:
`
` “As shown in this picture, we are currently on the ALL tab (as shown by the + icon being
`highlighted on the lower-right) and we've selected the Town Hall. Once clicked, the Town Hall
`pops up on the main screen. Several things happen when an item is clicked:
`
`14
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 14 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`The Town Hall button is highlighted, showing it is in use. The number went from a white x1 of
`quantity to a grayed out x0, meaning no more Town Halls are able to be placed. The
`background turned from a bright blue color to a dull magenta, signifying more visually that
`there are no other Town Halls to be placed. All this stuff is pretty explanatory, I'm just trying to
`be ultra clear
`
`“This screenshot exemplifies what happens if you click off and set the Town Hall (or any item)
`in place. As shown in the 2 screenshots above, the Total Bar moves up 1. Again, every item
`needs to be set in place before a base can be saved. Also, the info screen, Send Back Button,
`and white highlight around the Town Hall Button disappear.”.”
`
`
`15
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 15 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 7:
`
`
`“Let's click on the WALLS button on the lower-right and start placing some walls!”
`
`“This ANCHOR Button appears next to the SEND BACK Button, and is only seen when a wall
`is selected and in-use. It is an on/off button and when on, the current wall becomes an anchor.
`You can then stretch out connecting walls by dragging in any direction!”
`
`
`
`
`
`See, e.g., Mastermind at 9:
`
`16
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 16 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 9:
`
`
`
`17
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 17 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 9:
`
`
`
` “We click on the Defense Category Button and place a Cannon (which shows its radius).
`Again, I'll show how the Orange Minus Button at the top-right relates to this later.
`
` I
`
` had other photos showing each piece being placed, but let’s speed up the process.”
`
`
`
`See, e.g., Mastermind at 9:
`
`“We click on the Defense Category Button and place a Cannon (which shows its radius).
`Again, I'll show how the Orange Minus Button at the top-right relates to this later.
`
`18
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 18 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
` I
`
` had other photos showing each piece being placed, but let’s speed up the process.”
`
`
`
`See, e.g., Mastermind at 10:
`
`“Saving Your Design
`
`Now let's go ahead and save our base design as a Layout
`
`Click the Green Check Button at the top-right.” !
`
`
`
`
`
`
`See, e.g., Mastermind at 10:
`
`“This is another feature many players have been wanting for awhile: a way to see how well
`their base is covered (with the radii) and where enemy attackers can spawn on their base. Not
`only does the Orange Minus Button minimize the user interface, but adds this new feature as
`well.”
`
`
`
`See, e.g., Mastermind at 10:
`
`“This is another feature many players have been wanting for awhile: a way to see how well
`their base is covered (with the radii) and where enemy attackers can spawn on their base. Not
`
`19
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 19 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`only does the Orange Minus Button minimize the user interface, but adds this new feature as
`well.”
`
`
`
`See, e.g., Mastermind at 11:
`
`
`
`See, e.g., Mastermind at 11:
`
`
`
`“I'll fast forward the process and quickly create a base that uses EVERY item I have
`purchased.”
`
`
`
`20
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 20 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Mastermind at 12:
`
`“With everything complete, we can now click the Green Check Button once again and actually
`save our base as a Layout!”
`
`
`
`
`See, e.g., Mastermind at 14:
`
`
`
`“Clicking a Layout will prompt you with a few choices:
`
` •
`
`
`
` Use This Layout
`
`21
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 21 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`• Rename Layout
`
`
`Choosing the Use This Layout option will automatically switch your base to whatever design
`you select! (Assuming no obstacles are in the way, I'll talk about that in 2 paragraphs).”
`
`
`
`See, e.g., Pocket Gamer:
`
`“Clash of Clans hit the App Store in its full 1.7 release on June 13th 2012, after spending some
`time in closed beta.”
`
`
`
`See, e.g., Pocket Gamer:
`
`“Clans asks you to build a village and populate it with everything the warring tribe you're
`leading might need. A town hall for leadership, a gold mine for money, an army camp to hold
`your warriors, an Elixir collector to gather up this additional resource from the ether - pretty
`soon you've got plenty of architectural work to be getting on with.”
`
`
`
`See, e.g., Pocket Gamer:
`
`“This, of course, is all training for when you first get raided by another real-life player. The
`first time you see your base wiped out, you'll watch the replay to see how it happened, rebuild,
`
`22
`
` •
`
` •
`
` Share Layout
`
` Delete Layout
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 22 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`and perhaps shore up certain areas of your base. Then it's time to train troops and go show them
`who's boss.”
`
`
`
`To the extent GREE claims that the claimed functionality is not sufficiently disclosed in
`Mastermind, it is further shown through operation of the Clash of Clans game (e.g., version
`4.120), which will be made available to GREE for inspection. To the extent this limitation is not
`explicitly disclosed by this combination, 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, JP 200, FIFA 13, Madden 25, Gratuitous Tank Battles, Gratuitous Space
`Battle, Supreme Commander, Legend of Grimrock Dungeon Editor, Madden 25, FIFA 13, Sword
`of the Stars.
`
`Mastermind discloses receiving a command to create a template from the first player.
`
`See, e.g., Mastermind at 1:
`
`“Currently, the way to build a base is to move everything you have over to the side/edges of the
`base and then start moving things back in a new formation.”
`
`
`
`See, e.g., Mastermind at 2-3:
`
`23
`
`1b: receiving a command to
`create a template from the first
`player;
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 23 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`“Let’s get started, back with the original image:
`
`As you can see on the right side of this image, a new button was adde
`
`Touching this button leads to a brand new page with 2 option
`
`Builder and Layouts. Even though this thread has a lot of new things added to the game, I'll try
`to keep it as simple and easy to understand as possible. On this page, you can either click
`Builder or Layouts. Builder will take you to the actual Base Builder where you can design a
`new base, and Layouts is where your previously made Base Designs are saved (and where you
`can switch from one base design to another in a matter of seconds). Extra points for what game
`the scrolls on the Layout button was taken from [smiley image] For now, let's focus on the
`Builder and select that option:” s:
`
`d:
`
`
`
`
`24
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 24 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`
`
`25
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 25 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Mastermind at 4:
`
`“This window/picture is the main focus of this thread. This is the In-Game Base Builder! When
`thinking of different ideas of how to make the Base Builder, I liked this idea best. The user
`interface and set-up looks a lot like an Attack screen, so the user would feel fairly comfortable
`with the familiarity of it's design. The other option I was thinking of going with was one like on
`ClashofClansBuilder.com, but instead of the completely top-down view, I decided to go with
`this one. As you can see, there are many new features and buttons that I will explain very
`clearly for you all. The base is completely open, allowing the user to have free reign of placing
`objects. This feature alone is the reason I want the idea (whether my version or another) in the
`game badly.”
`
`
`
`See, e.g., Mastermind at 5:
`
`26
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 26 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 6:
`
`
`
` “As shown in this picture, we are currently on the ALL tab (as shown by the + icon being
`highlighted on the lower-right) and we've selected the Town Hall. Once clicked, the Town Hall
`pops up on the main screen. Several things happen when an item is clicked:
`
`The Town Hall button is highlighted, showing it is in use. The number went from a white x1 of
`quantity to a grayed out x0, meaning no more Town Halls are able to be placed. The
`background turned from a bright blue color to a dull magenta, signifying more visually that
`there are no other Town Halls to be placed. All this stuff is pretty explanatory, I'm just trying to
`be ultra clear
`
`27
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 27 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`“This screenshot exemplifies what happens if you click off and set the Town Hall (or any item)
`in place. As shown in the 2 screenshots above, the Total Bar moves up 1. Again, every item
`needs to be set in place before a base can be saved. Also, the info screen, Send Back Button,
`and white highlight around the Town Hall Button disappear.”.”
`
`
`
`
`
`
`See, e.g., Mastermind at 9:
`
`28
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 28 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 9:
`
`
`
`29
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 29 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 9:
`
`
`
`“We click on the Defense Category Button and place a Cannon (which shows its radius).
`Again, I'll show how the Orange Minus Button at the top-right relates to this later.
`
` I
`
` had other photos showing each piece being placed, but let’s speed up the process.”
`
`
`
`See, e.g., Mastermind at 10:
`
`“Saving Your Design
`
`
`30
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 30 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`Now let's go ahead and save our base design as a Layout
`
`Click the Green Check Button at the top-right.” !
`
`
`
`
`
`
`See, e.g., Mastermind at 10:
`
`“This is another feature many players have been wanting for awhile: a way to see how well
`their base is covered (with the radii) and where enemy attackers can spawn on their base. Not
`only does the Orange Minus Button minimize the user interface, but adds this new feature as
`well.”
`
`
`
`See, e.g., Mastermind at 12:
`
`“With everything complete, we can now click the Green Check Button once again and actually
`save our base as a Layout!”
`
`31
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 31 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`
`
`See, e.g., Mastermind at 12:
`
`
`
`“Layouts
`
`Although most of this thread has been about the Base Builder aspect, the Layout feature is
`easily as important in my eyes. Once the base design is complete, this is the screen you will be
`taken to.”
`
`
`
`32
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 32 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Mastermind at 12:
`
`
`
`See, e.g., Mastermind at 12:
`
`
`
`“With everything complete, we can now click the Green Check Button once again and actually
`save our base as a Layout!
`
`Click OKAY to save your design as a Layout.”
`
`
`
`See, e.g., Mastermind at 12:
`
`33
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 33 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`See, e.g., Mastermind at 12-13:
`
`
`
`“As we can see, we already have 2 previous base designs saved and 2 spaces empty. Right after
`clicking the Green Check Button to save our design, our only option is to save the design or
`exit out (at the top-right). If we choose to save our design in Layout 1 or Layout 2, an option
`will appear allowing us to either Overwrite the previous design or cancel.
`
`But let's choose the Empty area at the bottom-left.”
`
`
`
`34
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 34 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`See, e.g., Mastermind at 13:
`
`“Once chosen, our new base design is saved as Layout 3!”
`
`
`
`See, e.g., Mastermind at 13:
`
`
`
`See, e.g., Mastermind at 14:
`
`
`
`“Clicking a Layout will prompt you with a few choices:
`
` •
`
` Use This Layout
`
`35
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 35 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
` •
`
` •
`
` •
`
` Rename Layout
`
` Share Layout
`
` Delete Layout
`
`
`Choosing the Use This Layout option will automatically switch your base to whatever design
`you select! (Assuming no obstacles are in the way, I'll talk about that in 2 paragraphs).”
`
`
`
`See, e.g., Mastermind at 14:
`
`36
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 36 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`
`
`
`
`To the extent GREE claims that the claimed functionality is not sufficiently disclosed in
`Mastermind, it is further shown through operation of the Clash of Clans game (e.g., version
`4.120), which will be made available to GREE for inspection. To the extent this limitation is not
`explicitly disclosed by this combination, 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,
`
`37
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 37 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
`which are incorporated by reference as if fully set forth herein: Mastermind, Backyard Monsters,
`Farone, Kim, Cho, JP 200, Madden 25, FIFA 13, Gratuitous Tank Battles, Gratuitous Space
`Battle, Legend of Grimrock Dungeon Editor.
`
`Mastermind discloses creating, responsive to the received command to create the template, a
`plurality of templates defining the plurality of game contents and respective positions of the
`plurality of game contents within the game space.
`
`See, e.g., Mastermind at 5:
`
`1c: creating, responsive to the
`received command to create
`the template, a plurality of
`templates defining the plurality
`of game contents and
`respective positions of the
`plurality of game contents
`within the game space;
`
`
`
`See, e.g., Mastermind at 6:
`
`38
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 38 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Patent claim 1
`
`Mastermind
`
` “As shown in this picture, we are currently on the ALL tab (as shown by the + icon being
`highlighted on the lower-right) and we've selected the Town Hall. Once clicked, the Town Hall
`pops up on the main screen. Several things happen when an item is clicked:
`
`The Town Hall button is highlighted, showing it is in use. The number went from a white x1 of
`quantity to a grayed out x0, meaning no more Town Halls are able to be placed. The
`background turned from a bright blue color to a dull magenta, signifying more visually that
`there are no other Town Halls to be placed. All this stuff is pretty explanatory, I'm just trying to
`be ultra clear
`
`“This screenshot exemplifies what happens if you click off and set the Town Hall (or any item)
`in place. As shown in the 2 screenshots above, the Total Bar moves up 1. Again, every item
`needs to be set in place before a base can be saved. Also, the info screen, Send Back Button,
`and white highlight around the Town Hall Button disappear.”.”
`
`39
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 39 of 448
`
`

`

`Exhibit I-13: U.S. Patent No. 10,398,978 to Mastermind’s In-Game Builder Post (“Mastermind”)
`
`’978 Pa