`
`Exhibit B-2 - Preliminary Invalidity Contentions - U.S. Patent No. 10,413,832 to Yoshikawa, et al.
`Based on FarmVille, by Zynga, and “FarmVille for Dummies” by Angela Morales and Kyle Orland, ISBN: 978-1-118-01696-1
`
`The following chart contains Supercell’s Invalidity Contentions demonstrating that FarmVille and “FarmVille for Dummies” anticipates
`and/or renders obvious Claims 1-15 of U.S. Patent No. 10,413,832 under 35 U.S.C. § 102 and 35 U.S.C. § 103, alone or in view of other
`prior art. 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 FarmVille or
`“FarmVille for Dummies,” Supercell reserves the right to argue that such non-anticipated claims are obvious over FarmVille for
`Dummies 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.
`
`
`
`
`
`
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 1 of 42
`
`

`

`’832 Patent Claim 1
`
`[Preamble]
`A game control method
`executed by a game server,
`the method comprising:
`
`
`
`Disclosure from FarmVille
`
`FarmVille discloses game control method executed by a game server:
`FarmVille is a web-based social network video game developed and published by Zynga, and was
`first released for the Facebook platform on June 19, 2009. In addition, an HTML5 version was
`released on October 13, 2011.
`FarmVille for Dummies is a book published by Wily Publishing, Inc. in 2011. The book describes
`how to play FarmVille as it existed at the time.
`“FarmVille is a Web-based farming simulation game produced by a gaming company called
`Zynga. In 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.” P. 7
`“After you install the FarmVille app on your Facebook account (see how in Chapter 2), you start
`with a small, mostly empty farm, which we call the play area. This farm, and the game itself,
`aren’t actually stored permanently on your computer, but exist on “the cloud” of FarmVille
`servers maintained by developer Zynga.” P. 11
`“In contrast to most games on traditional gaming consoles such as the Nintendo Wii or Sony
`PlayStation 3, FarmVille is a Web-based game that you can play without inserting a disc or
`installing any programs to your hard drive. Your farm and the game program required to
`maintain it exist as part of a series of online data centers maintained by FarmVille’s publisher,
`Zynga.” P. 16.
`To the extent this limitation is not explicitly disclosed, 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: Xu, Kamiyama, FFXIV, WoW
`
`2
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 2 of 42
`
`

`

`’832 Patent Claim 1
`
`[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;
`
`
`
`Disclosure from FarmVille
`
`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:
`FarmVille for Dummies describes that a player may obtain bushels as a result of harvests.
`“Receiving money directly for harvesting ripe crops is all well and good, but it’s only a part of
`the benefit you can derive from those crops. By finding and sharing bushels during your harvest,
`and assembling those bushels into sellable crafted goods, you can get rewards including
`experience points (XP), Farm Coins, and, most usefully, fuel for farming vehicles…. Bushels are
`the core of the Farmers Market. Bushels are simply 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.”
`P. 113.
`FarmVille for Dummies further describes that players can share bushels with other players, and/or
`obtain bushels from other players.
`“Bushels are the core of the Farmers Market. Bushels are simply 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.” P. 113.
`“You can also collect bushels that your neighbors are sharing in their market stalls.” P. 115
`“The Get Bushels section of the Farmers Market menu appears, as shown in Figure 7-2. (If you
`leave this section, you can click the Get Bushels tab at the top of the menu to return.) Click the
`up and down arrows on the right side of the menu to see what kinds of bushels are currently
`being offered in your neighbors’ market stalls, as indicated by that neighbor’s picture next to the
`bushel.” P. 115
`
`3
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 3 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`Figure 7-2 of FarmVille for Dummies (reproduced above) shows a plurality of cells, each associated
`with extracted items.
`“The Shop for Bushels section of the Friend’s Market menu appears, as shown in Figure 7-3.
`Note that this menu may actually show multiple crops on offer from the applicable neighbor, not
`just the one you’re looking for.” P. 115.
`
`4
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 4 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`Figure 7-3 of FarmVille for Dummies (reproduced above) shows a plurality of cells, each associated
`with extracted items.
`“After you install the FarmVille app on your Facebook account (see how in Chapter 2), you start
`with a small, mostly empty farm, which we call the play area. This farm, and the game itself,
`aren’t actually stored permanently on your computer, but exist on “the cloud” of FarmVille
`servers maintained by developer Zynga.” P. 11
`In addition, FarmVille for Dummies discloses that a player may also use bushels they have collected.
`An interface for using bushels is illustrated in Figure 7-5 of FarmVille for Dummies.
`
`5
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 5 of 42
`
`

`

`
`
`’832 Patent Claim 1
`
`Disclosure from FarmVille
`“You can use bushels to access temporary bonus effects for your usual planting and harvest
`cycle.” P. 120.
`“Click the Use Bushels tab at the top of the menu. A display of all the bushels currently in your
`inventory appears (refer to Figure 7-5 to see what an inventory looks like). Click the tabs above
`the bushels to filter the list by types of crops, or use the left and right arrows on the side of the
`menu to navigate multiple pages of bushels.” P. 121.
`
`
`As illustrated in Figure 7-5, the interface comprises a plurality of cells each associated with an item.
`A POSITA would have understood that, as the game is executed by a game server, the items
`displayed in the cells of the Farmer’s Market are stored in a memory of the game server, and
`extracted from the memory for display.
`
`6
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 6 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`To the extent this limitation is not explicitly disclosed, 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: Xu, Kamiyama, FFXIV, WoW
`
`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:
`Figures 7-2 and 7-3 of Farmville for Dummies (reproduced below, annotations added) each show a
`sheet comprising a plurality of cells and obtainable item information. As the game is executed by a
`game server, the POSITA would have understood that the interfaces of Figures 7-2 and 7-3 are
`displayed to a player at a user terminal (e.g., the player’s computer, mobile device, etc.) by sending
`information to the player’s user terminal.
`
`[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;
`
`7
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 7 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`# of obtained items
`
`8
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 8 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`# of unobtained items
`
`# of obtained items
`
`In addition, Figure 7-5 also shows obtainable item information.
`
`
`
`9
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 9 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`# of obtained items
`
`
`To the extent this limitation is not explicitly disclosed, 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: Matsuzo, FFXIV, WoW
`
`FarmVille discloses receiving, in the virtual game, a selection request from the user terminal to select
`one cell among the plurality of cells:
`
`10
`
`[Element 1-C]
`receiving, in the virtual game,
`a selection request from the
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 10 of 42
`
`

`

`
`
`’832 Patent Claim 1
`user terminal to select one
`cell among the plurality of
`cells;
`
`Disclosure from FarmVille
`“3. Click the Take One button underneath the bushel you want. You can collect up to three total
`bushels from each neighbor each calendar day.” P. 116
`
`
`In addition, the player may use a bushel.
`“3. Click the green Use button underneath the bushel you want to use. A pop-up notification
`appears.
`4. Click the green Accept button. The bushel is removed from your inventory. Click the red X
`button in the upper-right corner of the Farmers Market menu to return to your farm. A small icon
`
`
`
`11
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 11 of 42
`
`

`

`
`
`’832 Patent Claim 1
`
`Disclosure from FarmVille
`of the bushel appears in the bottom-right corner of the play area, indicating that the bushel’s
`bonus is in effect. This effect lasts for two hours.” P. 121.
`
`
`To the extent this limitation is not explicitly disclosed, 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: Kamiyama, FFXIV, WoW
`
`12
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 12 of 42
`
`

`

`’832 Patent Claim 1
`
`[Element 1-D]
`sending information for
`differentiating, in the virtual
`game, a display of the one
`cell from another cell of the
`plurality of cells in the sheet,
`wherein the differentiating of
`the display of the one cell is
`done in response to the
`selection request to select the
`one cell; and
`
`
`
`Disclosure from FarmVille
`
`FarmVille discloses sending information for differentiating, in the virtual game, a display of the one
`cell from another cell of the plurality of cells in the sheet, wherein the differentiating of the display of
`the one cell is done in response to the selection request to select the one cel:
`FarmVille for Dummies shows a player at a user terminal can select a cell from the plurality of cells
`showing different bushels by clicking the “Take One” button within a particular cell.
`To the extent that FarmVille for Dummies does not explicitly show sending information for
`differentiating a display of the one cell from other cell of the plurality of cells in response to the
`selection request to select the one cell, see “Farmers Market | Market Stall” (hereinafter “Video 1”),
`available at https://www.youtube.com/watch?v=_ZBlcQrmong. Video 1 was published on Youtube
`on July 3, 2010, and depicts operations of FarmVille as they existed at the time.
`As shown at 1:44 of Video 1, prior to the player clicking on the “Take One” button within a market
`stall cell, the “Take One” button has a pale green color:
`
`
`13
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 13 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`However, when the player has moved their cursor over and clicks the “Take One” button, the button
`has a bright green color.
`
`
`14
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 14 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`Furthermore, once the player has taken all of a particular item that they can corresponding to a
`particular cell, the “Take One” button for the cell is greyed out.
`
`15
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 15 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`As such, a POSITA would have understood that a cell associated with an item (e.g., a particular type
`of bushel) and containing the “Take One” button described and illustrated in FarmVille for Dummies
`would be differentiated visually when the cell is selected (e.g., the player clicks the “Take One”
`button in the cell, changing the color of the button from pale green to bright green), and that this
`would involve “sending information for differentiating, in the virtual game, a display of the one cell
`from another cell of the plurality of cells in the sheet, wherein the differentiating of the display of the
`one cell is done in response to the selection request to select the one cell.”
`In addition, see “4.1 How to Make More Bushels in Farmville” (hereinafter “Video 2”), available at
`https://www.youtube.com/watch?v=BVvLVlt-DBA. Video 2 was published on Youtube on May 6,
`2011, and depicts operations of FarmVille as they existed at the time.
`
`16
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 16 of 42
`
`

`

`
`
`’832 Patent Claim 1
`
`Disclosure from FarmVille
`As shown at 0:23 of Video 2, prior to the player clicking on the “Use” button within a cell of the
`“Use Bushels” interface, the “Use” button has a pale green color:
`
`
`When the player selects the “Use” button, the button becomes dark green.
`
`17
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 17 of 42
`
`

`

`’832 Patent Claim 1
`
`Disclosure from FarmVille
`
`
`
`
`To the extent this limitation is not explicitly disclosed, 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: Xu, FFXIV, WoW
`
`FarmVille discloses providing, in the virtual game, an item of the extracted items that is associated
`with the one cell to a user of the user terminal:
`
`18
`
`[Element 1-E]
`providing, in the virtual
`game, an item of the extracted
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 18 of 42
`
`

`

`’832 Patent Claim 1
`items that is associated with
`the one cell to a user of the
`user terminal.
`
`
`
`’832 Patent Claim 2
`
`[Element 2]
`The game control method
`of claim 1, wherein
`
`
`
`Disclosure from FarmVille
`When the player selects a cell in a Farmer’s Market (as illustrated in Figure 7-3), the player receives
`the bushel associated with the selected cell.
`“3. Click the Take One button underneath the bushel you want. You can collect up to three total
`bushels from each neighbor each calendar day.” P. 116
`Also see 1:44 of Video 1, showing the user having an inventory of 1 corn bushel prior to clicking the
`“Take One” button, and an inventory of 2 corn bushels after clicking the “Take One” button.
`In addition, when the player uses a bushel (by clicking on the “Use” button in a cell and clicking an
`“Accept” button of a subsequent pop-up), a bonus associated with the selected bushel is provided to
`the player. In other words, the effect of the bushel is provided to the player.
`“4. Click the green Accept button. The bushel is removed from your inventory. Click the red X
`button in the upper-right corner of the Farmers Market menu to return to your farm. A small icon
`of the bushel appears in the bottom-right corner of the play area, indicating that the bushel’s
`bonus is in effect. This effect lasts for two hours.” P. 121.
`To the extent this limitation is not explicitly disclosed, 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: Kamiyama, FFXIV, WoW
`
`Disclosure from FarmVille
`
`FarmVille discloses that the information for differentiating the display of the one cell includes
`information for differentiating a pattern of the one cell according to the item type of the item
`associated with the one cell:
`
`19
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 19 of 42
`
`

`

`
`
`’832 Patent Claim 2
`the information for
`differentiating the display of
`the one cell includes
`information for differentiating
`a pattern of the one cell
`according to the item type of
`the item associated with the
`one cell.
`
`Disclosure from FarmVille
`As shown in Video 1, the “Take One” button of a cell changes between pale green, bright green, and
`grey, based on user selection of the cell.
`A POSITA would have understood that the differentiating pattern of the one (selected) cell may be
`according to the item type of item associated with the one cell. For example, the “Take One” button
`for cells associated items that are still available for selection are displayed in green, while the “Take
`One” button for cells associated with items no longer available for selection are displayed in grey.
`In addition, see Figure 6-3, reproduced below, showing cells associated with different trees a player
`can obtain. Cells associated with different types of trees (e.g., normal trees versus limited/seasonal
`trees) are displayed with differentiating patterns.
`
`
`To the extent this limitation is not explicitly disclosed, 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
`
`
`
`20
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 20 of 42
`
`

`

`
`
`’832 Patent Claim 2
`
`Disclosure from FarmVille
`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: Xu, FFXIV, WoW
`
`Disclosure from FarmVille
`
`FarmVille discloses that the information sent to the user terminal for displaying the sheet includes
`information of a character to be displayed in each of the plurality of cells, the character indicating a
`rarity value of each item associated with each cell:
`Figure 6-3, reproduced below, showing different trees a player can obtain, which include normal
`trees and limited edition trees:
`
`
`
`’832 Patent Claim 3
`
`[Element 3]
`The game control method
`of claim 1, wherein
`the information sent to the
`user terminal for displaying
`the sheet includes information
`of a character to be displayed
`in each of the plurality of
`cells, the character indicating
`a rarity value of each item
`associated with each cell.
`
`21
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 21 of 42
`
`

`

`’832 Patent Claim 3
`
`Disclosure from FarmVille
`
`
`
`See also Figure 6-9:
`
`
`
`22
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 22 of 42
`
`

`

`’832 Patent Claim 3
`
`Disclosure from FarmVille
`
`
`
`
`See also Figure 7-9, reproduced below, showing Farmer’s Market crafted goods that the player can
`obtain associated with different levels.
`
`
`
`23
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 23 of 42
`
`

`

`’832 Patent Claim 3
`
`Disclosure from FarmVille
`
`
`
`
`To the extent this limitation is not explicitly disclosed, 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: Xu, FFXIV, WoW
`
`
`
`24
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 24 of 42
`
`

`

`’832 Patent Claim 4
`
`[Element 4-A]
`A game server comprising:
`a memory in which each of a
`plurality of cells is associated
`with each of extracted items
`extracted from the memory;
`and
`
`
`
`Disclosure from FarmVille
`
`FarmVille discloses a game server comprising a memory in which each of a plurality of cells is
`associated with each of extracted items extracted from the memory:
`FarmVille for Dummies discloses:
`“FarmVille is a Web-based farming simulation game produced by a gaming company called
`Zynga. In 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.” P. 7
`“After you install the FarmVille app on your Facebook account (see how in Chapter 2), you start
`with a small, mostly empty farm, which we call the play area. This farm, and the game itself,
`aren’t actually stored permanently on your computer, but exist on “the cloud” of FarmVille
`servers maintained by developer Zynga.” P. 11
`“In contrast to most games on traditional gaming consoles such as the Nintendo Wii or Sony
`PlayStation 3, FarmVille is a Web-based game that you can play without inserting a disc or
`installing any programs to your hard drive. Your farm and the game program required to
`maintain it exist as part of a series of online data centers maintained by FarmVille’s publisher,
`Zynga.” P. 16.
`A POSITA would understand that in order for the FarmVille game and player information (e.g., the
`player’s farm) to be stored on FarmVille servers (e.g., a game server), the server would comprise
`memory.
`See also Element 1-A.
`A POSITA would have understood that, as the game is executed by a game server, the items
`displayed in the cells of the Farmer’s Market are stored in a memory of the game server, and
`extracted from the memory for display.
`
`To the extent this limitation is not explicitly disclosed, 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
`
`25
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 25 of 42
`
`

`

`
`
`’832 Patent Claim 4
`
`[Element 4-B]
`a controller configured to
`send 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,
`
`Disclosure from FarmVille
`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: Xu, Kamiyama, FFXIV, WoW
`
`FarmVille discloses a controller configured to send 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:
`A POSITA would have understood that the game server would comprise a processing element, such
`as a controller, for controlling operations of the game.
`See also Element 1-B.
`To the extent this limitation is not explicitly disclosed, 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: Matsuzo, FFXIV, WoW
`
`[Element 4-C]
`receive, in the virtual game, a
`selection request from the
`user terminal to select one
`cell among the plurality of
`cells,
`
`FarmVille discloses the controller configured to receive, in the virtual game, a selection request from
`the user terminal to select one cell among the plurality of cells:
`See Element 1-C.
`To the extent this limitation is not explicitly disclosed, 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
`
`26
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 26 of 42
`
`

`

`
`
`’832 Patent Claim 4
`
`[Element 4-D]
`send information for
`differentiating, in the virtual
`game, a display of the one
`cell from another cell of the
`plurality of cells in the sheet,
`wherein the differentiating of
`the display of the one cell is
`done in response to the
`selection request to select the
`one cell, and
`
`[Element 4-E]
`provide, in the virtual game,
`an item of the extracted items
`that is associated with the one
`cell to a user of the user
`terminal.
`
`Disclosure from FarmVille
`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: Kamiyama, FFXIV, WoW
`
`FarmVille discloses the controller configured to send information for differentiating, in the virtual
`game, a display of the one cell from another cell of the plurality of cells in the sheet, wherein the
`differentiating of the display of the one cell is done in response to the selection request to select the
`one cell:
`See Element 1-D.
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`o