Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 1 of 42
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`QUINN EMANUEL URQUHART & SULLIVAN, LLP
` Sean S. Pak (Bar No. 219032)
` seanpak@quinnemanuel.com
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Telephone: (415) 875-6600
`Facsimile: (415) 875-6700
`
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
` Robert M. Schwartz (Bar No. 117166)
` robertschwartz@quinnemanuel.com
` Lance L. Yang (Bar No. 260705)
` lanceyang@quinnemanuel.com
`865 S. Figueroa Street, 10th Floor
`Los Angeles, CA 90017
`Telephone: (213) 443-3000
`Facsimile:
`(213) 443-3100
`
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
` Ron Hagiz (pro hac vice forthcoming)
` ronhagiz@quinnemanuel.com
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Telephone: (212) 849-7000
`Facsimile:
`(212) 849-7100
`
`Attorneys for Plaintiff Skillz Platform Inc.
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SKILLZ PLATFORM INC., a
`Delaware corporation,
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`Plaintiff,
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`v.
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`AVIAGAMES INC., a Delaware
`corporation,
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`Defendant.
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`Case No.:__________
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`COMPLAINT FOR PATENT
`INFRINGEMENT
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`JURY TRIAL DEMANDED
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`Case No.: ___________
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 2 of 42
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`Plaintiff Skillz Platform Inc. (“Skillz” or “Plaintiff”) hereby asserts the
`following claims for patent infringement against Defendant AviaGames Inc.
`(“AviaGames” or “Defendant”), and alleges as follows:
`INTRODUCTION
`1. Most patent infringement cases involve someone who inadvertently
`trespassed on someone else’s invention, followed by a dispute about who got there
`first. This is not one of those cases. Instead, it is a case where Defendant
`AviaGames set out, seemingly from the get-go, to steal Skillz’s highly valuable
`intellectual property in the form of copyrights and patents. This lawsuit focuses on
`two of Skillz’s foundational patents that AviaGames has indisputably infringed.
`2.
`Skillz is a pioneer in competitive mobile gaming, founded on the
`simple belief that people love to compete. In 2012, Skillz developed innovative
`technologies to invent a new kind of mobile gaming platform (the “Skillz
`Platform”). The Skillz Platform facilitates two important things. First, it connects
`millions of players across the country in meaningful, fun, and—most importantly—
`fair competition. Second, it enables thousands of independent mobile game
`developers to transform new and existing games into skill-based competitions that
`have proven extremely profitable for game developers and players alike.
`Leveraging its patented technology and collaborative business model, Skillz now
`hosts billions of casual eSports tournaments for millions of mobile players
`worldwide, offering $100 million in prizes each month.
`3.
`To help game developers enable social competition in their games and
`take advantage of the Skillz Platform, Skillz provides a free Software Development
`Kit (“SDK”) through a portal on its website (the “Developer Portal”). The Skillz
`SDK includes, among other things, built-in, patented functionality that provides
`pseudo-random number generation that developers are required to use when they
`need a random number seed for their game. This feature ensures that players in
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 3 of 42
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`head-to-head competition are playing under identical, yet random, conditions and is
`critical to the fairness of every game played on the Skillz Platform.
`4.
`In 2016, AviaGames met with Skillz and said it was interested in
`building a game for the Skillz Platform. It signed up to become a Skillz customer
`and began receiving additional tools, creative support, market data, and technical
`know-how beyond what Skillz offers free of charge through its Developer Portal.
`Through this supposed “collaboration,” AviaGames gained intimate knowledge of
`the Skillz Platform.
`5.
`AviaGames then created a copycat platform called Pocket7Games and
`used it to launch knockoff versions of some of the most popular games on the Skillz
`Platform. AviaGames even began promoting the Pocket7Games app using
`marketing assets that Skillz provided after AviaGames asked for help promoting the
`only game it did create for the Skillz Platform. That game, which flopped, appears
`to have been a mere decoy designed to facilitate AviaGames’s access to valuable
`information about Skillz’s technology and business.
`6.
`AviaGames then went on to create and release standalone games
`independent of its Pocket7Games app, including games titled “Bingo Clash”,
`“Solitaire Clash”, “21 Gold”, “Explodocube”, and “Tile Blitz”.
`7.
`Through these standalone games and the Pocket7Games platform,
`AviaGames now competes directly with Skillz, as well as the independent
`developers whose games AviaGames has slavishly copied.
`8.
`It may turn out that AviaGames’s infringement was less deliberate than
`it appears—that AviaGames simply absorbed the keys to Skillz’s success and then
`used those keys to its advantage without even knowing it.
`9.
`But something more sinister may have happened. Discovery in this
`case may establish that AviaGames planned from the get-go to merely “pose” as a
`mobile developer interested in launching a game on the Skillz platform, bait Skillz
`into divulging the ins and outs of its technology and business, and use this valuable
`Case No. _____________
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 4 of 42
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`information to deliberately infringe Skillz’s intellectual property and profit from
`Skillz’s innovation and drive.
`10. AviaGames’s internal documents and the depositions of its key
`personnel will tell whether its infringement was innocent or not. AviaGames may
`have intended to deceive Skillz from the moment the parties first met in 2016.
`Under the patent laws of the United States, however, it makes no difference. What
`matters is that AviaGames is profiting from Skillz’s patented technology. And that
`it must stop.
`11. Skillz welcomes fair competition. But Skillz cannot—and will not—
`tolerate theft. Skillz brings this action to protect its innovative technology, and to
`hold AviaGames accountable for its infringement of the patents that teach it.
`THE PARTIES
`12. Skillz is a Delaware corporation with its principal place of business at
`321 NW Glisan Street, Suite 510, Portland, Oregon 97209. Skillz is the owner of
`the intellectual property rights at issue in this action. Skillz’s innovative technology
`has enabled thousands of independent video game developers to create thriving
`businesses developing skill-based video games that provide millions of gamers with
`access to fair, fun, and meaningful competition. Because of Skillz, video gamers
`can now compete and profit from their skill and dedication.
`13. On information and belief, AviaGames is a Delaware corporation with
`a principal place of business at 2586 Wyandotte Street, Unit 2B, Mountain View,
`California 94043. On information and belief, AviaGames markets, offers, and
`distributes applications and services such as the Pocket7Games application and
`standalone game applications throughout the United States, including in this
`District.
`14. Upon information and belief, AviaGames directly and/or indirectly
`develops, designs, manufactures, distributes, markets, offers to sell and/or sells
`infringing products and services in the United States, including in this District, and
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 5 of 42
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`otherwise purposefully directs infringing activities to this District in connection with
`the Pocket7Games application and standalone game applications.
`JURISDICTION & VENUE
`15. This is a civil action for patent infringement arising under the patent
`laws of the United States, 35 U.S.C. § 1 et seq.
`16. This Court has subject-matter jurisdiction over the matters asserted
`herein under 28 U.S.C. §§ 1331 and 1338(a) and 35 U.S.C. §§ 271 et seq.
`17. This Court has personal jurisdiction over AviaGames, in part because
`AviaGames does continuous and systematic business in this District, including by
`providing infringing products and services to the residents of this District that it
`knew would be used within this District, and by soliciting business from the
`residents of this District. For example, AviaGames is subject to personal
`jurisdiction in this Court because, among other reasons, upon information and belief,
`it has a regular and established place of business at its offices in this District,
`including its office in Mountain View, and directly and through agents regularly
`does, solicits and transacts business in the Northern District of California and
`elsewhere in the State of California, including through its website at
`www.pocket7games.com, as well as its Pocket7Games application and standalone
`game applications, all of which are marketed, offered, distributed to, and utilized by
`users of mobile devices in this District and throughout the State of California.
`18.
`In particular, AviaGames has committed and continues to commit acts
`of infringement in violation of 35 U.S.C. § 271, and has made, used, marketed,
`distributed, offered for sale, sold, and/or imported infringing products and services
`in the State of California, including in this District, and engaged in infringing
`conduct within and directed at or from this District. For example, AviaGames has
`purposefully and voluntarily placed the Pocket7Games application and standalone
`game applications into the stream of commerce with the expectation that its
`infringing products and services will be used in this District. The infringing
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 6 of 42
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`Pocket7Games application and standalone game applications have been and
`continue to be distributed to and used in this District. AviaGames’s acts cause
`injury to Skillz, including within this District.
`19. Venue is proper in this District under the provisions of 28 U.S.C.
`§§ 1391 and 1400(b) at least because a substantial part of the events or omissions
`giving rise to the claims occurred in this judicial district, and because AviaGames
`has committed acts of infringement in this District and has a regular and established
`place of business in this District.
`20.
`In particular, on information and belief, AviaGames has a regular and
`established place of business in this District located in Mountain View, California.
`On further information and belief, AviaGames employs engineers and/or other
`personnel within this District, including at its office in Mountain View.1
`INTRADISTRICT ASSIGNMENT
`21. On information and belief, a substantial part of the events giving rise to
`the claims alleged in this Complaint occurred in the County of Santa Clara. For
`purposes of intradistrict assignment under Civil Local Rules 3-2(c) and 3-5(b), this
`Intellectual Property Action will be assigned on a districtwide basis.
`FACTUAL ALLEGATIONS
`SKILLZ’S INNOVATION GIVES BIRTH TO A THRIVING NEW INDUSTRY
`22. Skillz was founded in October 2012 in Boston, Massachusetts.
`23. At that time, despite the popularity of video games in modern society,
`video gamers had limited to no options to compete and profit from their skill and
`dedication in the same way that athletes in many physical sports could. While
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`I.
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`1 For example, www.linkedin.com identifies AviaGames’s founder and CEO,
`Vickie Chen, and AviaGames’s co-founder and VP of Marketing, Ping Wang, as
`being located in Mountain View, California. (See Exs. C & D.) In addition, as of
`the date of this filing, AviaGames’s LinkedIn page includes a job posting for a full-
`time position in the “San Francisco bay area.” (See Ex. E.)
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`athletes in physical sports could earn millions of dollars through competition—not
`to mention recognition, respect, endorsements, and countless other opportunities—
`the technology to afford video gamers similar opportunities hadn’t yet been
`developed. Andrew Paradise and Casey Chafkin founded Skillz to change that.
`Skillz now offers more than $100 million in prizes each month.
`24. Skillz makes a mobile eSports platform. Rather than hoard its
`technology, Skillz opened the platform to third-party game developers to maximize
`the impact and reach of its innovation.
`25. The Skillz Platform helps developers build successful franchises by
`enabling social competition in their games. Not only that, it aligns the interests of
`developers and gamers with respect to user monetization. Whereas traditional
`mobile games monetize user engagement through in-game advertisements or
`purchases, the Skillz Platform allows developers to monetize user engagement
`primarily through prizes and competition. This dynamic generates significantly
`stronger monetization for developers while delivering gaming experiences that
`players trust and love. In turn, Skillz receives a percentage of player entry fees in
`paid contests.
`26. To enable game developers to make their games available on the Skillz
`Platform, Skillz developed a Software Development Kit (“SDK”) that allows
`developers to integrate eSports functionality and social competition into new or
`existing mobile games. Using Skillz’s SDK, which Skillz makes available through a
`portal on its website, game developers can create or modify their own video games
`to be fun, fair, and competitive experiences.
`27. Competitive gaming has proven to improve player retention, enhance
`gameplay, boost app store reviews, increase player engagement, and lengthen
`gameplay sessions—all of which helps game developers better monetize their
`content. Thus, integrating Skillz’s patented technology has proven extremely
`valuable to game developers, in addition to the users that play these games.
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`28. To create the Skillz Platform, Skillz developed several groundbreaking
`technologies, including the two patents that are the subject of this action.
`29. First, to guarantee the fairness and integrity of every competition on the
`Skillz Platform, Skillz developed a technology that allows gameplay to be the same
`for competitors within an online digital game competition, while also allowing
`games to be different across different competitions. By assigning each competition
`a unique match identifier and using pseudo-random number seeds that are
`characterized by that unique match identifier, the elements of each game can be the
`same for the participants in one competition while maintaining the unpredictable
`nature of each game that is critical to competitive gaming. This novel technology
`allows competitions to be skill-based even when the games have random elements
`associated with them, such as the starting hand and deck in a head-to-head game of
`solitaire. Game developers are instructed on how to access this technology through
`the Skillz SDK so that their games can offer head-to-head competitions where
`gamers experience identical, yet still unpredictable, conditions. Skillz has been
`awarded multiple patents relating to this technology, including U.S. Patent No.
`9,649,564 (“the ’564 Patent”).2
`30.
`In addition, to ensure that players could compete for cash in
`compliance with restrictions against cash-based competitions in certain states—and
`that players could be discouraged from cheating given the real-money stakes—
`Skillz developed technology that allows only players in states that allow cash-based
`competitions to play for real money, and creates an electronic record of their in-
`game actions as an anti-cheating measure. By requiring players’ client devices, e.g.,
`mobile phones, to provide GPS information before participating in an online cash-
`based digital game competition, cash-based competitions can be provided to users
`anywhere those competitions are permitted. And, by maintaining electronic records
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`2 The ’564 Patent is attached as Exhibit B.
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`of each competitor’s in-game actions that are also made available to other
`competitors, the possibility of cheating can be effectively minimized. Skillz
`claimed this invention in U.S. Patent No. 9,479,602 (“the ’602 Patent”).3
`31. The ’564 and ’602 Patents are fundamental to the innovation that Skillz
`brought to the mobile gaming industry. Using these technologies, Skillz enables
`video game developers to create skill-based mobile video games for the Skillz
`Platform in which users can compete with one another to earn hundreds, thousands,
`or even millions of dollars.
`II. LED BY SKILLZ, THE “ESPORTS” INDUSTRY EXPLODES
`32. Fueled in part by Skillz’s revolutionizing technology and collaborative
`business model, the eSports industry exploded, and Skillz became one of the fastest
`growing companies in the United States.
`33. Although Skillz did not coin the term “eSports” or invent the concept
`of mobile gaming or competitive video games, Skillz’s technology and drive has
`had an enormous impact on these industries and has helped launch eSports into the
`mainstream. Though Skillz’s impact cannot be quantified in numbers alone, the
`numbers themselves are staggering.
`34. The first Skillz-powered gaming app went live in April 2013. By July
`2014, Skillz had paid out over $1 million in cumulative prize money. By June 2015,
`that number had increased to $10 million. In December 2015, it reached $20
`million.
`35.
`In January 2016, Skillz launched cross-platform multiplayer technology
`allowing Android and iOS users to play in the same competitive video game
`tournaments. That year, Skillz accounted for 46% of all eSports prizes awarded.
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`3 The ’602 Patent is attached as Exhibit A.
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`36.
`In May 2017, Skillz became the first eSports company to appear on
`CNBC’s “Disruptor 50” list after it doubled its revenue run-rate to over $100
`million in eight months.
`37.
`In August 2017, Skillz was named the fastest growing private company
`in America by Inc. magazine, with three-year revenue growth of over 50,000%.
`38. By October 2017, just four years after its founding, Skillz had over
`6,000 independent developers signed up to create games and eSports for the Skillz
`Platform.
`39.
`In November 2017, Skillz launched multi-app chat technology,
`allowing more than 2,500 apps on the Skillz Platform to connect 12 million users
`through chat.
`40. Today, the Skillz Platform has over 40 million registered users and
`hosts an average of over 5 million daily tournaments, including 1.5 million paid
`entry daily tournaments, offering over $100 million in prizes each month.
`41. And, contrary to certain stereotypes about competitive sports and video
`gamers, more than half of Skillz’s 40 million players are women. In 2018, the top
`ten gamers on the Skillz Platform received $8 million in prize money. Seven of
`those competitors were women—including a user named Kmamba1090, who
`received $1,418,508 in prize money that year, and a user named jpark87, an
`engineering student whose $627,191 in prize money helped her pay for college.
`42.
`In the wake of Skillz’s revolutionary advancements, mobile gaming has
`attracted billions of dollars of investment from traditional sports teams and leagues,
`professional athletes, pop stars, private equity, media moguls, Fortune 100
`corporations, and a diverse array of game publishers.
`43. Skillz’s meteoric rise has fueled the growth of an industry whose
`market size already eclipses music, movies, and television.
`44. Yet Skillz is not alone in its success, nor did it set out to be. Skillz’s
`mission today is the same as it has been from the start: to enable independent mobile
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`game developers to create thriving businesses while providing gamers everywhere
`with access to fair, fun, and meaningful competition. By sharing its technology with
`game developers in this collaborative manner, Skillz has created opportunities for
`thousands of independent start-ups. Skillz’s technology provides the tools necessary
`for mom-and-pop development studios to compete with the largest and most
`sophisticated mobile game developers in the world.
`III. AVIAGAMES TEAMS UP WITH SKILLZ TO DEVELOP A GAME FOR THE
`SKILLZ PLATFORM—OR SO IT SAYS
`45.
`In 2016, AviaGames began inquiring about the Skillz Platform.
`46. Without Skillz’s know-how and SDK, developers could spend years
`trying to overhaul their video games into eSport games. The Skillz SDK enables
`developers to achieve that transformation in as little as a single day of development
`work. This technology set is delivered to Skillz’s game development community
`via Skillz’s Developer Portal, which allows developers to monitor, integrate and
`update their games seamlessly.
`47. The ability to transform regular video games into competitive eSports
`has proven extremely valuable to independent game developers, allowing them to
`turn many of their games into revenue sources that reward both developers and users
`alike.
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`48.
`In particular, Skillz’s Tournament Management System (“TMS”)
`drives revenue for game developers by enabling cash tournaments, increasing
`traffic, advertising revenue, and in-app purchases through virtual currency
`tournaments. The Skillz TMS also improves game retention. Competition makes
`games more social as players compete against each other in tournaments. Scores
`become more meaningful as players get rewarded for their skills, which translates
`into more downloads, a higher number of daily active users, and longer gameplay
`sessions.
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`49. While any game developer can make use of Skillz’s SDK by going to
`www.Skillz.com, creating an account on the Skillz Developer Portal, and agreeing
`to Skillz’s Online Developer Terms and Conditions of Service, developers who want
`additional assistance from Skillz can sign up to become a Skillz customer.
`50. AviaGames became a Skillz customer in 2016 so that it could benefit
`from Skillz’s specialized knowledge and expertise.
`51. Shortly thereafter, AviaGames launched its first and only game on the
`Skillz Platform. The game, which was called Number Drop, was not popular with
`users.
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`52. Armed with the knowledge it learned from Skillz, AviaGames then
`launched additional games on platforms that competed against Skillz. These
`additional games copied some of the most popular games that already existed on the
`Skillz Platform.
`53. Around this time, AviaGames also began building its own platform that
`used Skillz’s patented technology. That platform is known today as Pocket7Games.
`The Pocket7Games platform includes several games that are blatant copies of games
`already offered on the Skillz Platform.
`54. AviaGames later released several of these copycat games as standalone
`games, further infringing Skillz’s inventions.
`55. AviaGames’s wrongful appropriation of Skillz’s technology and
`innovation continues to this day, allowing AviaGames to continue profiting off of
`the work of others.
`56. Skillz brings this action to protect its innovative technology, hold
`AviaGames accountable for its unlawful infringement, recoup the damages it has
`suffered—and the profits AviaGames has “earned”—as a result of AviaGames’s
`misconduct.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 13 of 42
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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 9,479,602
`57. Skillz incorporates by reference and re-alleges all of the foregoing
`paragraphs of this Complaint as if fully set forth herein.
`The ’602 Patent
`58. U.S. Patent No. 9,479,602 (“the ’602 Patent”) is entitled “Event
`platform for peer-to-peer digital gaming competition” and was issued on October
`25, 2016. A true and correct copy of the ’602 Patent is attached as Exhibit A.
`59. The ’602 Patent was filed on May 20, 2015, as U.S. Patent Application
`No. 14/717,621.
`60. Skillz is the owner of all rights, title, and interest in and to the ’602
`Patent, with the full and exclusive right to bring suit to enforce the ’602 Patent,
`including the right to recover for past infringement.
`61. The ’602 Patent is valid and enforceable under United States Patent
`Laws.
`62. At the time of the ’602 Patent, it was not common or conventional to
`use a computing system to: (a) receive data identifying a peer-to-peer gaming event
`and comprising a request to register for the peer-to-peer gaming event from a remote
`client, the peer-to-peer event being a geographically restricted peer-to-peer gaming
`competition having a plurality of participants each playing a skill-based digital
`game, (b) associate the client with the peer-to-peer gaming event, (c) receive data
`characterizing a location of the client according to a geolocation system of the
`client, (d) compare the location of the client to a predefined geolocation of the peer-
`to-peer event to determine that the client satisfies a geographical location
`requirement of the peer-to-peer gaming event, and (e) cause provision of a skill-
`based digital game to the client during the peer-to-peer gaming event.
`63. The inventors of the ’602 Patent realized that peer-to-peer gaming
`events in the context of electronic sports (also known as eSports or competitive
`gaming) presented a technological problem because such “events are generally
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 14 of 42
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`organized in an ad hoc manner,” such that “games played by event participants often
`vary in difficulty (and therefore player outcome varies) because the game may
`present a different scenario each time the game is played,” “mak[ing] it challenging
`to determine event competition winners or rankings in a fair manner.” ’602 Patent
`at 1:27-43.
`64. The inventors of the ’602 Patent recognized that, when a remote client
`sought to participate in a peer-to-peer gaming event where the event is
`geographically restricted, receiving a request from that client, associating the client
`with the peer-to-peer gaming event, and receiving data characterizing a location of
`the client according to a geolocation system of the client could facilitate a
`comparison of the client’s location to the peer-to-peer event’s predefined
`geolocation so as to determine that the client satisfies a geographical location
`requirement and only then cause provision of a skill-based digital game to the client
`during the peer-to-peer gaming event. As taught by the ’602 Patent, “[e]vents can
`be location-based so that the event will take place at a specific geographical
`location, and systems are in place to only permit users who are at those geographical
`locations to participate in the event.” ’602 Patent at 7:24-27. For example, peer-to-
`peer gaming events may be geographically restricted where such events involve
`cash games, including skill-based competitions, because different states have
`different laws regulating cash games (including skill-based competitions), making it
`necessary to impose geographic restrictions to comply with local laws and
`regulations.
`65. The ’602 Patent discloses, among other things, an unconventional and
`technological solution to an issue arising specifically in the context of electronic
`sports. The solution implemented by the ’602 Patent provides a specific and
`substantial improvement over prior ad hoc methods used for this purpose, resulting
`in an improved method for facilitating fair, skill-based, geographically restricted
`peer-to-peer gaming events. The ’602 Patent achieves this result by introducing
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`Case 5:21-cv-02436-BLF Document 1 Filed 04/05/21 Page 15 of 42
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`novel elements such as, among other things, receiving data characterizing the
`client’s location according to the client’s geolocation system, wherein the
`geolocation system is a global positioning system (GPS) service or a local position
`system (LPS) utilizing beacons, and comparing that location to a predefined
`geolocation of the peer-to-peer event to determine that the client satisfies the event’s
`geographical location and only then providing the skill-based digital game to the
`client during the peer-to-peer gaming event. This solution is novel because, among
`other things, it makes it harder for users to trick the system to circumvent
`geographical restrictions. For example, if restrictions were based on user profiles, a
`user could falsify his or her address; similarly, if restrictions were based on IP
`addresses, a user could spoof an IP address by using a proxy. Relying on location
`systems that are independent of user input and provide location in real time, such as
`GPS or LPS, makes the geographical restrictions harder to circumvent. This
`technological solution is particularly novel where the peer-to-peer competition
`includes a plurality of participants concurrently playing the skill-based digital game.
`66. The inventors of the ’602 Patent also recognized that cheating was a
`potential problem in peer-to-peer gaming events. As taught by the ’602 Patent,
`“[v]ideo recordings can be streamed live and stored for all game entries which can
`later be verified for authenticity (e.g., anti-cheating).” ’602 Patent at 6:4-7.
`67. The ’602 Patent discloses, among other things, an unconventional and
`technological solution to an issue arising specifically in the context of electronic
`sports. The solution implemented by the ’602 Patent provides a specific and
`substantial improvement over prior anti-cheating methods by generating an
`electronic record of the peer-to-peer gaming event. The ’602 Patent achieves this
`result by introducing novel elements such as, among other things, generating a video
`feed recording in-game actions by capturing an interface display space of the skill-
`based digital game and broadcasting the capture to peer-to-peer gaming platforms of
`one or more additional clients participating in the peer-to-peer event.
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`Case 5:21-cv-02436-BLF Document 1