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`GREE, INC.,
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`v.
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`SUPERCELL OY,
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`The Honorable Rodney Gilstrap
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`Civil Action No. 2:19-cv-00071-JRG-RSP
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`JURY TRIAL DEMANDED
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`§§§§§§§§§§
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`Plaintiff,
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`Defendant.
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`EXPERT REPORT OF MARK CLAYPOOL, PH.D.
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`RESTRICTED – ATTORNEYS’ EYES ONLY
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`Patent Owner Gree, Inc.
`Exhibit 2009 - Page 1 of 4
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`2.
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`Mastermind
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`112. Mastermind combines a post titled “Mastermind’s In-Game Builder Idea (with
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`LOADS of pictures!)” and a post titled “Mastermind’s In-Game Builder Post” both made on
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`September 11, 2013 to a community forum for Clash of Clans by a user using the name
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`“Mastermind.” I will refer collectively to these forum posts as “Mastermind” or “Mastermind’s
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`In-Game Builder Idea.” The forum was hosted by Supercell and the postings made thereon were
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`publicly available on the Internet. Mastermind would thus would have been available to the
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`public prior to the effective filing date of the ‘594 patent. I understand the version of the posts I
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`reviewed faithfully represents the posts as they existed before the effective filing date of the ‘594
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`patent. Mastermind’s In-Game Builder Post was archived by the Internet Archive on September
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`15, 2013. Mastermind at 10, 12. I further understand that the author of the posts has
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`authenticated the images shown in the archive of the post on Internet Archive. I understand that
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`34
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`REDACTED
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`Patent Owner Gree, Inc.
`Exhibit 2009 - Page 2 of 4
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`164.
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`In addition, it is my opinion that a diligent, skilled researcher engaged in a
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`reasonable search for prior art would not have found Mastermind as a prior art reference even
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`with the benefit of GREE’s infringement contentions before the filing of the Petition for Post-
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`Grant Review. A diligent, skilled researcher would not spend time sifting through the
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`suggestions provided on Internet message boards, as they would normally not include useful or
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`sufficiently detailed suggestions.
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`58
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`REDACTED
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`REDACTED
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`Patent Owner Gree, Inc.
`Exhibit 2009 - Page 3 of 4
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`or information produced by the parties in this litigation, information set forth in any
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`supplemental reports or declarations submitted by either party, and the Court’s construction of
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`the patent claim terms.
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`247.
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`If called to testify, I will as needed explain the principles and terminology referred
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`to in this report, as well as the materials referenced herein. I also expect that I will illustrate my
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`testimony through the use of demonstrative exhibits, as needed.
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`92
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`Patent Owner Gree, Inc.
`Exhibit 2009 - Page 4 of 4
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