UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`The Honorable Rodney Gilstrap
`
`
`Civil Action No. 2:19-cv-00310-JRG-RSP
`
`
`
`
`
`JURY TRIAL DEMANDED
`
`
`§ § § § § § § § § §
`
`
`
`GREE, INC.,
`
`
`
`
`v.
`
`
`SUPERCELL OY,
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`EXPERT REPORT OF STACY FRIEDMAN
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 1 of 53
`
`

`

`
`
`2.
`
`FarmVille by Zynga Inc.
`
`211. FarmVille (hereinafter “FarmVille”) is an agriculture-simulation browser-based
`
`social network game, that was developed and published by Zynga in 2009. The objective of the
`
`game is to cultivate a thriving farm, and to do so, users can plant and harvest crops and trees, as
`
`well as care for farm animals, such as milking cows and collecting eggs from chickens. Trees,
`
`crops and animals are obtained by, for example, buying them or receiving them as gifts. The
`
`user plays the game through a web browser, the game program being stored at maintained by an
`
`online game server.
`
`212. The FarmVille game was available on the social network website Facebook as of
`
`200954 and continues to be available on Facebook. The Farmville game was also available for
`
`download as a mobile app for the iPhone, iPod Touch, and iPad during a brief period in 2010.
`
`Farmville was not considered by the examiners at the Patent Office during prosecution of the
`
`’708 or ’832 patents. Because the earliest possible priority date of the ’708 and ’832 patents
`
`patent is June 21, 2012, the Farmville game is prior art to these patents.
`
`213. The FarmVille game was publicly available in the US at the time of the effective
`
`filing date of the ’708 or ’832 patents. For example, the authors of FarmVille for Dummies
`
`(referenced below) are based in the US.55 I also personally observed my wife playing FarmVille
`
`in the United States in the 2010 timeframe, therefore I was personally aware that FarmVille was
`
`publicly available in the United States.
`
`
`
`54 See https://web.archive.org/web/20090722110640/https:/www.facebook.com/FarmVille/.
`
`55 https://www.linkedin.com/in/kyleorland/; https://www.linkedin.com/in/angela-s-morales-
`4a806b23/; http://fandomania.com/interview-angela-morales-aka-farmgoddess-of-farmville-
`freak/.
`
`102
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 2 of 53
`
`

`

`
`
`214. Farmville is also described by numerous references, including game manuals,
`
`videos, and websites that were publicly available before June 21, 2012. I have reviewed these
`
`references and they are described below. It is my opinion that each of these references anticipate
`
`the claims, or alternatively each render the claims obvious, alone or in combination with the
`
`other references relating to FarmVille. It would have been obvious to combine these references
`
`as they all relate to the original FarmVille game prior to March 2011.5657
`
`215. A book titled “FarmVille for Dummies” (hereinafter “FVD”) is an instructional
`
`guidebook describing in detail the features and general functionality of the social network game
`
`FarmVille. FarmVille for Dummies was published in 2011 by Wiley Publishing, Inc., roughly
`
`one year before the effective filing date of the ’708 and ’832 patents. Accordingly, the
`
`FarmVille for Dummies is prior art to the patents-in-suit.
`
`216. A video titled “Farmers-Market | Market Stall” (hereinafter “FarmVille Video 1),
`
`available at https://www.youtube.com/watch?v=_ZBlcQrmong, depicts specific gameplay
`
`features of FarmVille at that time. The account that posted FarmVille Video 1 is
`
`“VecinosFarmville.” The VecinosFarmville account has four videos relating to FarmVille, all
`
`posted in 2010. As of October 6, 2020, FarmVille Video 1 has 1,668 views. A search for
`
`“Farmville Market Stall” in the youtube search engine pulls up the Farmville Video 1 as the 11th
`
`result. Farmville Video 1 was published on July 2, 2010 and is therefore prior art to the patents-
`
`in-suit.
`
`
`
`56 I understand that there are multiple “FarmVille” games. For example, in March 2011, a game
`called FarmVille English Countryside was released. https://www.zynga.com/games/farmville/.
`A sequel game called FarmVille 2 was released in September 2012.
`
`57 https://www.zynga.com/games/farmville/.
`
`103
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 3 of 53
`
`

`

`
`
`217. Another video titled “Farmville Mystery game” (hereinafter “FarmVille Video 2),
`
`available at https://www.youtube.com/watch?v=clUWH4cp_jA, depicts specific gameplay features
`
`of FarmVille at that time. The account that posted FarmVille Video 2 is “SuperXOneX.” The
`
`SuperXOneX account has six videos relating to FarmVille, all posted between 2010 and 2012. As
`
`of October 30, 2020, FarmVille Video 1 has 9,983 views. A search for “Farmville Mystery Game”
`
`in the YouTube search engine pulls up the Farmville Video 2 as the first result. Farmville Video 1
`
`was published on August 15, 2010 and is therefore prior art to the patents-in-suit.
`
`218. FVD describes that FarmVille is a social networking game comprised of network
`
`game servers, communications, and storage that provides a social game for users to play on their
`
`devices to cultivate a virtual farm and collect helpful virtual in-game items to advance the game.
`
`FVD at 29-32. More specifically, FarmVille is a game that “take[s] advantage . . . of social
`
`networking framework to encourage interaction with other players. Socializing with other players
`
`by visiting their farms, sharing gifts, and participating in cooperative jobs . . . This focus on social
`
`interaction puts FarmVille at the forefront of a new trend called social gaming.” Id. at 9.
`
`219. FVD notes that “[i]n contrast to many computer games that you have to buy on a
`
`disc, anyone with an Internet connection and a Facebook account can load FarmVille in his or
`
`her Web browser and play for free in an instant. The ease of access is one of the reasons
`
`FarmVille has become so popular.” FVD at 7. The game may be installed as an app “on your
`
`Facebook account . . . and the game itself, [isn’t] actually stored permanently on your computer,
`
`but exist on ‘the cloud’ on FarmVille servers.” Id. at 11. In other words, FarmVille’s social
`
`gaming service is configured to synchronize a player’s game and inventory data with the latest
`
`version stored on the server. Id. at 11, 32. To “play FarmVille, you need to make sure that your
`
`browser has JavaScript enabled [which] lets your browser talk to the FarmVille servers and keep
`
`104
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 4 of 53
`
`

`

`
`
`the farm that you see on your screen synced with the version stored in the Internet ‘cloud’ of
`
`online servers.” Id. at 16-17.
`
`220. FVD describes that the basic concept of the FarmVille game is to “manage your
`
`virtual farm by planting, growing, and harvesting virtual crops; tending livestock and trees;
`
`constructing buildings such as barns and chicken coops; and buying and selling goods made on
`
`the farm.” FVD at 7. During the course of gameplay, players may be able to acquire and amass
`
`many different in-game items. Id. at 9. For example, the player earns in-game currency used to
`
`“purchase the seeds you need to grow crops or any of the other items that drive the FarmVille
`
`economy.” Id. at 76. Planted crops and trees can be harvested by the player to earn more in-
`
`game currency (Farm Coins). See id. Players may acquire items through an in-game FarmVille
`
`Market store, exchange items with other players through a Farmers Market, craft new items from
`
`crops and other resources, earn items as rewards (e.g., completing certain tasks, playing a
`
`Mystery Game, etc.), and/or the like. See, e.g., id. at 75-76, 113, 122-125, 169-170, 175-176.
`
`221. FVD describes various interfaces in FarmVille where a player may view, select,
`
`and/or acquire various types of items. Many of these interfaces display a sheet of cells, where
`
`each cell is associated with a respective item, and may include a graphic corresponding to the
`
`item and/or additional information concerning the item. See, e.g., FVD at 42, 93, 113-115, 120-
`
`121, 187-188. For example, FVD describes a “Farmers Market” within the game where the
`
`player can share and collect “bushels,” which are “a special type of item that you can use to
`
`improve your harvests, share with friends to collect bonuses, or collect to help craft goods.” Id.
`
`at 113. When the player finds “bushels through a harvest, you can also share copies of those
`
`bushel in your market stall.” Id. at 115. The player may also acquire bushels shared by their
`
`neighbors (e.g., Facebook friends of the player who are also players of FarmVille). Id. Figure 7-
`
`105
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 5 of 53
`
`

`

`
`
`2 shows a “Get Bushels” interface of the Farmers Market, where the player can view which
`
`bushels that their neighbors are sharing in their markets stalls in the Farmers Market. Id.
`
`
`
`222. The player may select the market stall of a neighbor to view which bushels the
`
`neighbor has made available for sharing, an example of which is shown in Figure 7-3. Id. The
`
`displayed interface may be a sheet of multiple cells corresponding “multiple crops on offer from
`
`the applicable neighbor,” as well as additional information indicating how many of each type of
`
`bushel the player currently has in their inventory, how many additional bushels they can obtain
`
`from the neighbor’s market stall, etc. See id., Figure 7-3. The player may select a desired bushel
`
`(e.g., by clicking on the “Take One” button displayed in the cell corresponding to the desired
`
`bushel below the image of the bushel) to collect one of the bushel, and may “collect up to three
`
`total bushes from each neighbor each calendar day.” Id.
`
`106
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 6 of 53
`
`

`

`
`
`
`
`223. The player may also access a “Use Bushels” interface in the Farmers Market that
`
`allows the player to view bushels currently in their inventory, and use bushels in order to be
`
`provided with “temporary bonus effects for your usual planting and harvest cycle.” Id. at 120,
`
`Figure 7-5. The illustrated interface displays a sheet of cells corresponding to bushels currently
`
`in the player’s inventory, and indicates how many of each type of bushel the player currently
`
`possesses. Id. at 121. The interface further indicates that the player “can store only 100 bushels
`
`in your inventory at a time,” and shows how many total bushels the player has acquired. Id. at
`
`117. The player may elect to use a bushel to be provided the bushel’s special effects for two
`
`hours, and/or share the bushel with other players (e.g., by clicking the “Use” button or the
`
`“Share” button, respectively). Id. at 121.
`
`107
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 7 of 53
`
`

`

`
`
`
`
`224. FVD describes that FarmVille Market within the game that functions as a shop
`
`where the player may speed “FarmVille currency on necessary purchases: the seeds, vehicles,
`
`fuel, and other essential items for running and expanding your farm.” Id. at 93. The market
`
`menu displays “various product sections” and sheets of cells coresponding to item listings, each
`
`item listing containing “the item’s name, a small picture of the item, the time until harvest, and
`
`the item’s cost, which is displayed in either Farm Coins or Farm Cash, depending on the item.
`
`Many item listings also contain additional information about that purchase, such as the item’s
`
`selling price and the number of experience points (XP) you earn with your purchase.” Id. at 94;
`
`see also Figure 6-1 (reproduced below). The interface may display different backgrounds for
`
`different types of items (e.g., limited time items, Winter Holiday items, etc.). Id.
`
`108
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 8 of 53
`
`

`

`
`
`
`
`225.
`
`In addition to items related to planting and harvesting crops, the player may also
`
`acquire items such as decorations and clothing to customize the appearance of their farm and/or
`
`their farmer avatar. See id. at 42, 99. For example, the player of FarmVille may customize the
`
`appearance of their “farmer avatar” using a “Customize My Farmer” menu, where the player
`
`may equip their farmer avatar with various clothing items, including clothing items from their
`
`inventory, as well as clothing items purchasable from the FarmVille Market. Id. at 42; Figure 3-
`
`6 (reproduced below). As shown in Figure 3-6, available clothing items may be displayed in
`
`respective cells. When the player selects a particular clothing item (e.g., using the “Use” and/or
`
`the “Try On” buttons), the game may provide the selected clothing item to be equipped on the
`
`displayed farmer avatar. The displayed interface visually differentiates the cells of items the
`
`player has selected for wearing by their farmer avatar, relative to cells of other items not worn by
`
`the player’s farmer avatar.
`
`109
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 9 of 53
`
`

`

`
`
`
`
`226. The player of FarmVille may, while playing the game, “amass their own
`
`collections of all sorts of decorations, vehicles, animals, and other items.” Id. at 187. In
`
`addition, the player may acquire collectible items, which are “a special class of items meant
`
`specifically for collecting.” Id. The player may view their acquired collectibles via a
`
`Collections interface. Id. In addition, for certain collections (e.g., limited-time collections), the
`
`player can elect to purchase specific items missing from their collection, in order to complete
`
`their collection. Id. at 189. For example, Figure 11-5 of FVD (reproduced below) shows a
`
`Collections interface where the player may view their Collections (each displayed as a respective
`
`row of item cells) and purchase additional items to complete their collection. Id. at 188.
`
`110
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 10 of 53
`
`

`

`
`
`
`
`227.
`
`In addition, FVD shows that the information pertaining to the acquirable items
`
`associated with the displayed cells may be displayed in different formats or at different positions.
`
`For example, the rarity value of an item (e.g., “Uncommon”, “Common”, or “Rare”) may be
`
`displayed below an image of the item as show in Figure 11-5 above, or as shown in Figure 10-3
`
`(reproduced below) be displayed above the image of the item, and within a same border as the
`
`image of the item. FVD at 175.
`
`111
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 11 of 53
`
`

`

`
`
`
`
`228. FarmVille implements a user interface that allow users to see their virtual items
`
`and to send them as gifts to other users. Id. at 30, Figure 3-1. The user interface includes a
`
`“Gifting page” that allows a player to “select free gifts to send to your farming neighbors” and a
`
`“My Neighbors page” to select the neighbor to receive the gift. Id. at 30-31, 33, Figures 3-2, 3-3.
`
`FarmVille’s “Gifting Page” with item selection and transfer options is shown below in Figure 3-2:
`
`
`
`112
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 12 of 53
`
`

`

`
`
`229. Additionally, users may collect all the gifts received from other players in a gift
`
`inventory box, otherwise known as a Gift Box. FarmVille for Dummies at 68-69. Through the
`
`Gift Box, a user can manage the inventory of gifts. An example of the Gift Box is provided
`
`below:
`
`(https://farmville.wonderhowto.com/news/re-gifting-0120426/)
`
`
`230.
`
`It is my understanding that Zynga has not yet authorized me to review source
`
`code related to FarmVille. I reserve the right to supplement my report should such code be made
`
`
`
`available.
`
`3.
`
`U.S. Patent No. 8,663,014 to Xu
`
`231.
`
`I have reviewed U.S. Patent No. 8,663,014 (“Xu”), entitled “Apparatus and
`
`Method with Physical Location Check-in that Triggers a Status Change in a Virtual Game.” The
`
`application for Xu was filed on January 17, 2012 and claims priority to U.S. Provisional
`
`Application 61/438,118 filed on January 31, 2011. Xu was not considered by the examiners at
`
`113
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 13 of 53
`
`

`

`
`
`I.
`
`INVALIDITY OF THE ’832 PATENT
`
`1.
`
`FarmVille Invalidates the Asserted Claims of the ’832 Patent
`
`328.
`
`In my opinion, FarmVille, in view of the knowledge of a person of ordinary skill,
`
`and other references such as Xu, discloses each and every element of asserted claims 1-15 of the
`
`’832 patent.
`
`a.
`
`Element 1-pre: A game control method executed by a game
`server, the method comprising…
`
`329. FarmVille is an agriculture-simulation browser-based social network game, where
`
`the user plays the game through a web browser, the game program being stored at maintained by
`
`an online game server. For example, FVD describes FarmVille as “a Web based farming
`
`simulation game” existing “on ‘the cloud’ of FarmVille servers maintained by developer Zynga.”
`
`FVD at 7; 11. The “game program required to maintain [the game] exist as part of a series of
`
`online data centers maintained by FarmVille’s publisher, Zynga,” and to play FarmVille, the
`
`player’s browser “talk[s] to the FarmVille servers and keep[s] the farm that you see on your
`
`screen synced with the version stored in the Internet ‘cloud’ of online servers.” Id. at 16-17.
`
`Additionally, to access FarmVille via Facebook, FVD teaches that a user may “[i]nstall the
`
`FarmVille App” by “set[ting] up your Facebook account” and going to
`
`“http:://apps.facebook.com/onthefarm” and “log[ging] in to your Facebook account” in which
`
`then “FarmVille should load automatically.” Id. at 22-23. FVD describes specific instructions
`
`for playing directly from the website Farmville.com by going to “the FarmVille site at
`
`http://www.farmville.com[.]” Id. FarmVille may also be played on a user’s mobile using the
`
`“mobile FarmVille app for the iPhone, iPod Touch, and iPad.” Id. at 27.
`
`330. A POSITA would have understood that the “online data centers”/“online servers”
`
`described in FVD corresponds to a game server. The POSITA would further have understood
`
`168
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 14 of 53
`
`

`

`
`
`that game control methods for operating the game would be executed by the server, in order to
`
`generate game information that is communicated to the web browser on the user’s computer.
`
`b.
`
`Element 1-A: associating, in a memory of the game server,
`each of a plurality of cells with each of extracted items
`extracted from the memory
`
`331. FarmVille discloses associating, in a memory of the game server, each of a
`
`plurality of cells with each of extracted items extracted from the memory, under the Court’s (and
`
`GREE’s proposed) claim construction. For example, in FarmVille, the player is able to acquire
`
`various items within the game, such as crops, animals, trees, buildings, decorations, etc. FVD
`
`discloses that a player’s farm within FarmVille is stored on the “FarmVille servers.” FVD at 11.
`
`The POSITA would have understood that the player’s farm stored on the server would include
`
`data concerning a “current status” of their farm, including player attributes, facilities the player
`
`has built, items the player has acquired, neighboring players to the player’s farm, etc. See, e.g.,
`
`FVD at 2, 42, 153, 226. The POSITA would have thus understood that the items within the
`
`FarmVille game would be stored in a memory of the game server.
`
`332.
`
`In addition, FarmVille discloses a variety of different interfaces used in the game
`
`that comprise a plurality of cells associated with items. The POSITA would have understood
`
`that because the game program of FarmVille is stored and maintained by the online game server,
`
`information for generating any of the interfaces used in the game would be stored and
`
`maintained by the server. The POSITA would have understood that in order to display an
`
`interface showing a plurality of cells, data corresponding to the interface to be displayed
`
`(comprising the plurality of cells) would be stored in the memory, and comprise associations
`
`with items extracted from the memory that are associated with the cells.
`
`169
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 15 of 53
`
`

`

`
`
`333. The Court has interpreted the element to mean “associating… each of a plurality
`
`of cells with each item of a plurality of extracted items,” or that “each cell is associated with
`
`each item.” Claim Construction Order at 25.
`
`334. Under the Court’s construction, a person of ordinary skill would recognize that
`
`various interfaces in FarmVille include a plurality of cells where each cell is associated with
`
`each of extracted items extracted from a memory of the server. For example, FarmVille includes
`
`a Mystery Game through which the user may acquire limited-edition items. See FVD at 175.
`
`Figure 10-3 of FVD (reproduced below) shows an interface of the Mystery Game. The Mystery
`
`Game is a “simple, interactive balloon-popping game,” which the user plays by pointing a dart at
`
`a desired balloon, and clicking on the balloon. Id. at 175-176. When the user clicks on a
`
`balloon, a “random limited-edition item is added to your Gift Box.” Id. The POSITA would
`
`have understood the balloons of the Mystery Game interface to correspond to “cells.”
`
`
`
`335. The random items that the user can receive through the Mystery Game are
`
`selected from a limited set of items. For example, the FarmVille Wiki describes that FarmVille
`
`implemented different versions of the mini-game over different times that gave users items from
`
`different sets of limited-edition items. See Mystery Game, FarmVille Wiki, June 18, 2012
`
`Revision (available at https://farmville.fandom.com/wiki/Mystery_Game?oldid=234234). For
`
`170
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 16 of 53
`
`

`

`
`
`example, the FarmVille wiki shows that “Mystery Game 28” (screenshot below), which ran
`
`between December 12, 2010 and December 19, 2010, provided players limited-edition items
`
`from a particular set, and that other mystery games that ran at different times provided items
`
`from different sets.
`
`336. The POSITA would have understood that because the user may, responsive to
`
`selecting a displayed cell/balloon, receive a random limited-edition item of the set of items
`
`associated with the current Mystery Game (e.g., Mystery Game 28, or another version of the
`
`
`
`171
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 17 of 53
`
`

`

`
`
`Mystery Game), each of the plurality of cells/balloons may be associated with “each of extracted
`
`items extracted from the memory” of the set of items.73
`
`337.
`
`In addition, though the Court has construed the element “associating, in a memory
`
`of the game server, each of a plurality of cells with each of extracted items extracted from the
`
`memory” to mean that each cell is associated with each item, GREE appears to argue on the
`
`basis that the element means that each of the plurality of cells is associated with one
`
`corresponding item. See, e.g., GREE Inc.’s Amended Disclosure of Asserted Claims and
`
`Infringement Contentions. FarmVille contains many interfaces that satisfy GREE’s
`
`interpretation of the element, as FarmVille describes many interfaces that display a plurality of
`
`cells, each cell associated with a respective item, and where the player may be provided the item
`
`corresponding to a cell responsive to a request to select the cell.
`
`338. For example, FarmVille describes interfaces where a player can obtain bushels, “a
`
`special type of item that [the player] can use to improve [their] harvests, share with friends to
`
`collect bonuses, or collect to help craft goods,” from other players. FVD at 113. The player may
`
`access a “Farmers Market” and be presented with a “Shop for Bushels” menu upon selecting a
`
`
`
`73 The POSITA would have understood that having the server predetermine an item to be
`provided associated with each cell of a displayed interface (and sending such information as part
`of the initial instructions to display the interface) and having the server determine which item to
`provide only after a selection request is received (e.g., in response to the selection request) are
`obvious alternative ways for the server to determine an item to be provided to the user based on
`the selection request. In addition, the POSITA would have known that it would be desirable,
`especially in games that involve the provision of hidden or “mystery” items, for the server to
`determine the item only after the selection request is received, to prevent possible cheating by the
`user, e.g., analyzing data received from the server to find out which specific item will be
`provided for a given cell without actually selecting the cell. In cases where the server does not
`determine the specific item to provide until after a selection request is received, each of the cells
`can potentially provide any of the plurality of items, and as such would each be associated with
`each of the plurality of items.
`
`172
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 18 of 53
`
`

`

`
`
`market stall of a particular neighbor, as shown in Figure 7-3 (reproduced below), which includes
`
`a plurality of cells, each associated with a respective item/bushel. FVD at 115-116.
`
`
`
`339.
`
`In FarmVille, the player may also acquire collectible items, which are viewable
`
`from a “Collectibles menu” within the game. FVD at 187-189. FVD discusses that some
`
`collections are “Limited Time” collections, and that players who are missing items from a
`
`limited time collection may buy the items through the Collections interface, as shown in Figure
`
`11-5 of FVD (reproduced below, annotations added). Id. As shown in Figure 11-5 of FVD, the
`
`Collections interface comprises a plurality of cells, each cell associated with a collectible item
`
`that is part of a particular collection (under GREE’s contention).
`
`173
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 19 of 53
`
`

`

`
`
`
`
`340. FVD further discloses that each player of FarmVille may customize a
`
`personalized farmer avatar, using a “Customize My Farmer” menu. FVD at 42. At this menu,
`
`the player may equip their farmer avatar with various clothing items, including items from their
`
`inventory, or items purchasable from the FarmVille Market. FVD at 42; Figure 3-6 (reproduced
`
`below). Figure 3-6 shows the “Customize My Farmer” interface as having a plurality of cells,
`
`each associated with a clothing item.
`
`174
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 20 of 53
`
`

`

`
`
`
`
`341.
`
`In addition to interfaces comprising a plurality of cells where a user can get items,
`
`FarmVille contains interfaces with a plurality of cells where the user uses or consumes items.
`
`For example, the player may also access a “Use Bushels” interface in the Farmers Market that
`
`allows the player to view bushels currently in their inventory, and use bushels in order to be
`
`provided with “temporary bonus effects for your usual planting and harvest cycle.” FVD at 120,
`
`Figure 7-5. The illustrated interface displays a sheet of cells corresponding to bushels currently
`
`in the player’s inventory, and indicates how many of each type of bushel the player currently
`
`possesses. Id. at 121. The player may elect to use a bushel to be provided the bushel’s special
`
`effects for two hours, and/or share the bushel with other players (e.g., by clicking the “Use”
`
`button or the “Share” button, respectively). Id.
`
`175
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 21 of 53
`
`

`

`
`
`
`
`342. The POSITA would have understood that because the game program and data for
`
`the player’s farm are stored on the game’s online servers, the items associated with the cells of
`
`the displayed interfaces would be “extracted from the memory” of the game server. In addition,
`
`because the game program is maintained by the online game server, and the player plays the
`
`game via a web browser, it would have been obvious to the POSITA that any information
`
`specifying interfaces to be displayed in the game (and/or instructions for displaying such
`
`interfaces, e.g., information indicating which items correspond to which cells to be displayed)
`
`would be stored as part of the game program on the server. The POSITA would thus have
`
`understood that to generate any of the above-described interfaces for display would involve
`
`“associating, in a memory of the game server, each of a plurality of cells” of the interface “with
`
`each of extracted items extracted from the memory”. For example, in the “Shop for Bushels”
`
`interface illustrated in Figure 7-3, the POSITA would have understood when the player selects
`
`which neighbor’s market stall they wish to view, the game would extract, from the memory,
`
`information corresponding to items that the neighbor player has designated for sharing, and
`
`176
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 22 of 53
`
`

`

`
`
`associate each item with a respective cell, so that information for each item can be displayed in
`
`its respective cell of the interface to be displayed to the player.
`
`c.
`
`Element 1-B: sending information to a user terminal for
`displaying, in a virtual game, a sheet comprising the plurality
`of cells and obtainable item information, the obtainable item
`information comprising at least one of (i) a total number of
`items for each item type, (ii) a number of obtained items and
`(iii) a number of un-obtained items;
`
`343. FarmVille discloses sending information to a user terminal for displaying, in a
`
`virtual game, a sheet comprising the plurality of cells and obtainable item information, the
`
`obtainable item information comprising at least one of (i) a total number of items for each item
`
`type, (ii) a number of obtained items and (iii) a number of un-obtained items, under at least the
`
`Court’s “plain and ordinary meaning” claim construction. As FarmVille is a browser-based
`
`game, the POSITA would have understood that the game server would send information to the
`
`player’s user terminal to allow the player’s terminal to display (through their web browser) the
`
`various interfaces of the game, which would include, as discussed above, interfaces displaying a
`
`sheet comprising the plurality of cells. In addition, these interfaces also display obtainable item
`
`information.
`
`344. For example, FarmVille includes various interfaces that the game may display to
`
`allow the player to view, select, and/or acquire items, where the interfaces include a displayed
`
`sheet comprising a plurality of cells each associated with a respective item. See, e.g., FVD at
`
`Figure 3-6 (“Customize My Farmer”), Figure 7-3 (“Shop for Bushels”), Figure 11-5
`
`(“Collections”). In addition, these interfaces may display obtainable item information. For
`
`example, Figure 7-3 illustrates the “Shop for Bushels” interface displaying a sheet of cells (each
`
`corresponding to a respective bushel) and obtainable item information comprising a number of
`
`177
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 23 of 53
`
`

`

`
`
`obtained items (e.g., “Your inventory” for each bushel type) and a number of unobtained items
`
`(e.g., “Purchases remaining”). FVD at 115-116.
`
`
`
`345. The Collections interface illustrated in Figure 11-5 also displays a sheet of cells
`
`(e.g., three rows of six cells) and obtainable item information comprising a total number of items
`
`for each item type (“number to the right of the slash under each limited-time collectible
`
`indicat[ing] how many of that collectible you need to acquire before storing the collection”) and
`
`a number of obtained items (“the number to the left indicates how many you have found thus
`
`far”). FVD at 189. For example, the Collections interface of Figure 11-5 displays that the player
`
`has obtained 2 acorns, and needs 10 acorns to complete the “Autumn Collection.” A POSITA
`
`would have understood that the player may (e.g., by selecting the “Buy” button for the acorn
`
`item) buy up to 8 additional acorns to complete that item for their collection. See FVD at 189.
`
`178
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 24 of 53
`
`

`

`
`
`
`
`346. The “Mystery Game” interface of FarmVille (e.g., as illustrated in Figure 10-3 of
`
`FVD) also displays a sheet of cells (e.g., five rows of five balloons) and obtainable item
`
`information comprising a number of obtained items and a number of unobtained items. For
`
`example, as shown in Figure 10-3 of FVD, a row of rectangles is displayed below the plurality of
`
`balloons/cells and indicate a number of different items of the set of items associated with the
`
`Mystery Game the player has obtained by popping the balloons. When the player fir