`
`Exhibit B-8 - Preliminary Invalidity Contentions - U.S. Patent No. 9,561,439 to Oono
`Based on U.S. Patent App. Pub. No. 2013/0190094 to Ronen et al. (“Ronen”)
`
`The following chart contains Supercell’s Invalidity Contentions demonstrating that Ronen anticipates Claims 1-7 of U.S. Patent No.
`9,561,439 under 35 U.S.C. § 102 or renders the same claims obvious alone or in view of other prior art under 35 U.S.C. § 103. Because
`the Court has yet to issue a claim construction in this case, fact discovery is ongoing, and the invalidity of the asserted claims will likely
`be the subject of expert discovery, these contentions are preliminary only and Supercell reserves the right to supplement or modify these
`contentions in accordance with the agreed patent-disclosure procedures and the Docket Control Order in this case. Additionally, and in
`further consideration of the preliminary stages of the case, Supercell notes that the pinpoint citations referenced in this chart are not
`exhaustive, and Supercell reserves the right to rely on additional citations within the reference. Furthermore, citations to any figure,
`table, or chart are meant to encompass the language describing the respective figure, table, or chart, and vice versa.
`
`These charts also incorporate analysis based upon GREE’s apparent interpretation of the asserted claims, as reflected in GREE’s
`infringement contentions to date. Supercell does not agree with GREE’s incomplete, ambiguous, and inadequate application of the
`asserted claims in those contentions. However, as detailed below, such application (to the extent that it can be reasonably ascertained)
`further renders each asserted claim invalid. Supercell further reserves its right to supplement these contentions based on further
`discovery, including any supplemental infringement contentions or any interrogatory response purporting to rebut these invalidity
`contentions provided by GREE.
`
`Additionally, Supercell notes that while certain potential obviousness arguments and combinations may be cited within these charts,
`such recitations are not exhaustive. As such, to the extent that any asserted claims are found not to be anticipated by Ronen, Supercell
`reserves the right to argue that such non-anticipated claims are obvious over Ronen 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 2007 - Page 1 of 23
`
`

`

`’439 Patent Claim 1
`
`[Preamble]
`A game control method
`carried out by a game control
`device for providing a game
`to a plurality of
`communication terminals
`respectively used by a
`plurality of users, the game
`control device
`communicating with the
`plurality of communication
`terminals over a
`communication network and
`having a storage unit for
`storing information for each
`of the plurality of users, the
`method comprising the steps
`of:
`
`[Element 1-A]
`(a) grouping the plurality of
`users into one or more
`groups;
`
`
`
`Disclosure from Ronen
`
`Ronen discloses a game control method carried out by a game control device for providing a game to
`a plurality of communication terminals respectively used by a plurality of users, the game control
`device communicating with the plurality of communication terminals over a communication network
`and having a storage unit for storing information for each of the plurality of users.
`
`“As illustrated in this figure, the system 100 includes a server 120 that is connected to a plurality of
`clients 110 via a network 140 (e.g., the Internet, a local area network (LAN), intranet or other
`network). Clients 110 connect to the server 120 via the network 140 to play the game 125. Clients
`110 may connect to the server 120 using any type of wired or wireless connection.” ¶ [0032]
`“As the user plays the game 125, all data associated with the user's gaming session may be recorded
`by the user's client 110 and stored on the server 120.” ¶ [0037]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Ronen discloses (a) grouping the plurality of users into one or more groups.
`
`“After a game 125 has been initialized, a team 115 comprising at least two players is created (block
`610). The operations related block 610 may be implemented by the team controller 310 described
`above. During the creation of a team 115, roles may be assigned to specific players. A role may
`include a set of parameters, functions, features, abilities, etc. which are not available to other players
`
`2
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 2 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-B]
`(b) storing a correspondence
`between the plurality of users
`and the one or more groups in
`the storage unit;
`
`
`
`Disclosure from Ronen
`participating in the game 115. Referring back to the example provided above with respect to FIG. 11,
`three players may be assigned different roles (i.e., an army commander, an air force commander and
`a naval commander), and each of the roles may be associated with a distinct subset of functionalities
`and attributes (e.g., only the air force commander can attack with planes, and only the naval
`commander can move in water).” ¶ [0087]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Ronen discloses (b) storing a correspondence between the plurality of users and the one or more
`groups in the storage unit.
`
`“When adding or removing users from a team 115, the team controller 310 may associate or
`disassociate a user profile 353 with an instance of a team profile 354 stored in the gaming database
`350. The team profile 354 may store all data related to a team (e.g., team members, games being
`played by the team, etc.) Likewise, when editing an existing member of a team 115, the team
`controller 310 may modify the team profile 354 and/or user's profile 353 stored in the gaming
`database 350.” ¶ [0056]
`
`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
`
`3
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 3 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-C]
`(c) transmitting information
`over the communication
`network to initiate a group
`event in which a first plurality
`of users forming a first group
`cooperatively participate in
`the game;
`
`
`
`Disclosure from Ronen
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Ronen discloses (c) transmitting information over the communication network to initiate a group
`event in which a first plurality of users forming a first group cooperatively participate in the game.
`
`“Amongst other functions, the socializer 340 may be configured to: (1) transmit invitations (e.g., a
`player can invite other players or non-players to start a game, complete a tasks or engage in some
`type of gaming activity); (2) post information on the wall of a user in a social forum (e.g., “click here
`to play” or “send virtual good”); (3) send gifts or virtual goods to a friend or group of friends; (4)
`send notifications to players or teams (e.g., indicating a new call for action or indicating that
`information was posted on the user's wall); or (5) provide a ticker function which provides a short
`textual notification about gaming activities. The socializer 340 may be configured to provide
`additional means of communicating as well.” ¶ [0085]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`4
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 4 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-D]
`(d) storing a parameter value
`for each of the plurality of
`users, wherein the parameter
`value for a respective user is
`increased as the respective
`user makes progress in the
`group event;
`
`
`
`Disclosure from Ronen
`
`Ronen discloses (d) storing a parameter value for each of the plurality of users, wherein the
`parameter value for a respective user is increased as the respective user makes progress in the group
`event.
`
`”Virtual goods can be acquired in various ways including, but not limited to, using virtual currency,
`using real money in a game store, receiving a gift from friend, requesting a gift and receiving a
`positive reply, completing a task or mission, picking up or activating objects which randomly appear
`when playing the game, jointly purchasing a virtual good, obtaining an achievement or trophy in
`game, virtually betting on an item with another team or user, or by responding to a wall post in a
`social forum. Virtual goods can be obtained in other ways as well.” ¶ [0074]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`[Element 1-E]
`(e) monitoring progress of the
`group event and updating the
`parameter value for each of
`the first plurality of users in
`accordance with the progress
`
`Ronen discloses (e) monitoring progress of the group event and updating the parameter value for
`each of the first plurality of users in accordance with the progress of the first group in the group
`event.
`
`“Virtual goods can be acquired in various ways including, but not limited to, using virtual currency,
`using real money in a game store, receiving a gift from friend, requesting a gift and receiving a
`positive reply, completing a task or mission, picking up or activating objects which randomly appear
`
`5
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 5 of 23
`
`

`

`’439 Patent Claim 1
`of the first group in the group
`event;
`
`
`
`Disclosure from Ronen
`when playing the game, jointly purchasing a virtual good, obtaining an achievement or trophy in
`game, virtually betting on an item with another team or user, or by responding to a wall post in a
`social forum. Virtual goods can be obtained in other ways as well.” ¶ [0074]
`
`“As the user plays the game 125, all data associated with the user's gaming session may be recorded
`by the user's client 110 and stored on the server 120. When other users (e.g., teammates) play the
`game 125, the recorded data may be retrieved and utilized to generate and display ghosting features
`on the gaming canvas displayed to other team members. Amongst other things, the ghosting features
`may indicate gaming activities engaged in by the user. The ghosting features be utilized by the other
`team members in various ways (e.g., to complete tasks, obtain objects or earn accolades). ¶ [0037]
`“The data recorded and stored for a user's session may include data associated with a variety of
`different gaming activities. As used herein, a “gaming activity” generally refers to any type of action
`or activity the user engages in within the confines of the game 125. For example, a gaming activity
`may represent the situation where a user progresses to a new level in a game 125, engages in battle
`with an opponent, unlocks an achievement, completes a task or sub-task assigned to the user, utilizes
`a virtual good or item in the inventory, or any other activity in which the user engages in while
`playing the game 125.” ¶ [0038]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`6
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 6 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-F]
`(f) providing at least one of a
`plurality of game pieces to
`each of the first plurality of
`users in the group event,
`based on the parameter value
`for the corresponding user,
`wherein the plurality of game
`pieces are required to obtain a
`game item;
`
`
`
`Disclosure from Ronen
`
`Ronen discloses (f) providing at least one of a plurality of game pieces to each of the first plurality of
`users in the group event, based on the parameter value for the corresponding user, wherein the
`plurality of game pieces are required to obtain a game item.
`
`“A plurality of clients 110 may collaboratively play the game 125 together as a virtual team 115.
`Users that are part of a virtual team 115 may work together or cooperate to complete tasks, missions
`or achievements. In addition, virtual teams 115 may share an inventory (e.g., weapons or health
`elixirs), and exercise joint ownership over virtual goods (e.g., can buy, sell, upgrade or use items in
`the inventory). While each user can still have individual tasks or achievements, users are part of a
`larger team-based gameplay progression.” ¶ [0034]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`[Element 1-G]
`(g) storing allocation
`information indicating which
`game piece has been provided
`to which user, in the storage
`unit;
`
`Ronen discloses (g) storing allocation information indicating which game piece has been provided to
`which user, in the storage unit.
`
`“A plurality of clients 110 may collaboratively play the game 125 together as a virtual team 115.
`Users that are part of a virtual team 115 may work together or cooperate to complete tasks, missions
`or achievements. In addition, virtual teams 115 may share an inventory (e.g., weapons or health
`elixirs), and exercise joint ownership over virtual goods (e.g., can buy, sell, upgrade or use items in
`
`7
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 7 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-H]
`(h) determining whether all
`the required game pieces have
`been provided to the first
`plurality of users, based on
`the allocation information;
`and
`
`
`
`Disclosure from Ronen
`the inventory). While each user can still have individual tasks or achievements, users are part of a
`larger team-based gameplay progression.” ¶ [0034]
`“As the user engages in gaming activities while playing the game 125, the client 110 for each user
`records all associated information and transmits this information for storage on a server 120. The
`gaming activity information being stored on the server 120 may be used to update the canvas 352,
`joint inventory, tasks or other game data 351 associated with the game 125.” ¶ [0097]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang , Bethke, Kane, Kobayashi, Forsaken World.
`
`Ronen discloses (h) determining whether all the required game pieces have been provided to the first
`plurality of users, based on the allocation information.
`
`“A team task represents a task that is completed by the actions of two or more players. A team task
`may be divided into sub-tasks that are completed by different team members. The team tasks can be
`can be comprised of a regular group of sub-tasks that can be achieved together. For example, any
`player can contribute to any of the sub-tasks relating to gathering five logs, retrieving a pipe and
`sending a gift.” ¶ [0080]
`“When saving information related to a user's session to the database 130, a variety of different
`parameters may be saved with each activity including time stamps, information indicating the type of
`activity that took place (e.g., opened a crate, opened a door or added a building), specific parameters
`associated with the activity (e.g., an identification number for a door that was opened), movement
`
`8
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 8 of 23
`
`

`

`’439 Patent Claim 1
`
`[Element 1-I]
`(i) allocating in a memory,
`the game item to the first
`group or at least one of the
`first plurality of users, when it
`is determined that all the
`required game pieces have
`been provided within a
`predetermined period of time
`during which the group event
`is taking place.
`
`
`
`Disclosure from Ronen
`data (e.g., vectors and locations), information indicating the speed of an activity or player, outcomes
`related to the data (e.g., whether a trophy was achieved or whether a new level was attained), current
`location of the player or activity, game specific data (e.g., pertaining to a task or level), or objects
`used in performing the activity (e.g., a club or car).” ¶ [0039]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang , Bethke, Kane, Kobayashi, Forsaken World.
`
`Ronen discloses (i) allocating in a memory, the game item to the first group or at least one of the first
`plurality of users, when it is determined that all the required game pieces have been provided within a
`predetermined period of time during which the group event is taking place.
`
`“As a user plays the game 125, everything that the user does may be recorded, including all gaming
`activities engaged in the user, and the information associated with each recorded session may be
`stored on the server database 130 (although the client 110 may temporarily save this data locally
`before transmission to the server 120). When saving information related to a user's session to the
`database 130, a variety of different parameters may be saved with each activity including time
`stamps, information indicating the type of activity that took place (e.g., opened a crate, opened a door
`or added a building), specific parameters associated with the activity (e.g., an identification number
`for a door that was opened), movement data (e.g., vectors and locations), information indicating the
`speed of an activity or player, outcomes related to the data (e.g., whether a trophy was achieved or
`
`9
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 9 of 23
`
`

`

`
`
`Disclosure from Ronen
`whether a new level was attained), current location of the player or activity, game specific data (e.g.,
`pertaining to a task or level), or objects used in performing the activity (e.g., a club or car).” ¶ [0039]
`
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Disclosure from Ronen
`
`Ronen discloses that different game pieces are respectively provided to the first plurality of users.
`
` A
`
` team task represents a task that is completed by the actions of two or more players. A team task
`may be divided into sub-tasks that are completed by different team members. The team tasks can be
`can be comprised of a regular group of sub-tasks that can be achieved together. For example, any
`player can contribute to any of the sub-tasks relating to gathering five logs, retrieving a pipe and
`sending a gift. ¶ [0080]
`
`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.
`
`10
`
`’439 Patent Claim 1
`
`
`
`’439 Patent Claim 2
`
`[Element 2]
`The game control method
`according to claim 1, wherein
`in step (f), different game
`pieces are respectively
`provided to the first plurality
`of users.
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 10 of 23
`
`

`

`
`
`’439 Patent Claim 2
`
`Disclosure from Ronen
`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: World of Warcraft, Warhammer Online, Guild
`Wars 2, Englman, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`
`
`’439 Patent Claim 3
`
`[Element 3]
`The game control method
`according to claim 1,
`further comprising the step of
`(j) deleting the allocation
`information from the storage
`unit when the predetermined
`period of time has elapsed.
`
`Disclosure from Ronen
`
`Ronen discloses (j) deleting the allocation information from the storage unit when the predetermined
`period of time has elapsed.
`
`“Specifically, the inventory manager 325 may include functionality permitting each of the users to
`add objects to the joint inventory 1420. Once an object is added to the inventory 1420, the object is
`commonly owned by all players on the team 115, and each player can utilize the object as he or she
`pleases. The inventory manager 325 may also include functions for removing objects from the joint
`inventory 1420. An object may be removed from the joint inventory 1420 in a variety of different
`situations, such as when the object has been used by a player or in response to explicit designation
`from a player to discard the object.” ¶ [0136]
`
`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
`
`11
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 11 of 23
`
`

`

`
`
`’439 Patent Claim 3
`
`Disclosure from Ronen
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online,
`Englman, Bethke, Kane, Kobayashi.
`
`’439 Patent Claim 4
`
`[Element 4]
`The game control method
`according to claim 3, further
`comprising the step of
`(k) periodically causing an
`event to occur for providing
`one of the plurality of game
`pieces to a user, wherein
`in step (f), one of the plurality
`of game pieces is provided to
`one of the first plurality of
`users in the event.
`
`Disclosure from Ronen
`
`Ronen discloses (k) periodically causing an event to occur for providing one of the plurality of game
`pieces to a user, wherein in step (f), one of the plurality of game pieces is provided to one of the first
`plurality of users in the event.
`
`“Virtual goods can be acquired in various ways including, but not limited to, using virtual currency,
`using real money in a game store, receiving a gift from friend, requesting a gift and receiving a
`positive reply, completing a task or mission, picking up or activating objects which randomly appear
`when playing the game, jointly purchasing a virtual good, obtaining an achievement or trophy in
`game, virtually betting on an item with another team or user, or by responding to a wall post in a
`social forum. Virtual goods can be obtained in other ways as well.” ¶ [0074]
`
`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: World of Warcraft, Guild Wars 2, Englman,
`Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`
`
`
`
`12
`
`Patent Owner Gree, Inc.
`Exhibit 2007 - Page 12 of 23
`
`

`

`’439 Patent Claim 5
`
`[Element 5]
`The game control method
`according to claim 1, further
`comprising the steps of:
`(l) storing a ranking point for
`the first group when it is
`determined that all the
`required game pieces have
`been provided; and
`(m) storing a reward for the
`first plurality of users in
`accordance with a total value
`of ranking points for the first
`group during a predetermined
`period of time.
`
`
`
`Disclosure from Ronen
`
`Ronen discloses (l) storing a ranking point for the first group when it is determined that all the
`required game pieces have been provided; and (m) storing a reward for the first plurality of users in
`accordance with a total value of ranking points for the first group during a predetermined period of
`time.
`
`“The data recorded and stored for a user's session may include data associated with a variety of
`different gaming activities. As used herein, a “gaming activity” generally refers to any type of action
`or activity the user engages in within the confines of the game 125. For example, a gaming activity
`may represent the situation where a user progresses to a new level in a game 125, engages in battle
`with an opponent, unlocks an achievement, completes a task or sub-task assigned to the user, utilizes
`a v