Declaration of Sandeep Chatterjee, Ph.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZYNGA INC.
`Petitioner
`
`v.
`
`IGT,
`Patent Owner
`
`U.S. Patent No. 8,266,212
`Issue Date: September 11, 2012
`
`Title: Game Talk Service Bus
`
`DECLARATION OF SANDEEP CHATTERJEE, PH.D.
`
`Zynga Ex. 1003, p. 1
` Zynga v. IGT
` IPR2022-00368
`
`

`

`Table of Contents
`
`Page
`
`I.
`
`II.
`III.
`
`IV.
`
`V.
`
`INTRODUCTION AND QUALIFICATIONS .............................................. 1
`A.
`Qualifications and Experience ............................................................. 1
`B. Materials Considered ............................................................................ 6
`PERSON OF ORDINARY SKILL IN THE ART ......................................... 8
`STATEMENT OF LEGAL PRINCIPLES ................................................... 10
`A.
`Obviousness ........................................................................................ 10
`B.
`Claim Construction............................................................................. 11
`THE ’212 PATENT ...................................................................................... 13
`A.
`Overview of the Specification ............................................................ 13
`B.
`Prosecution History ............................................................................ 15
`C.
`The Challenged Claims ...................................................................... 16
`APPLICATION OF THE PRIOR ART TO ASSERTED CLAIMS ........... 20
`A.
`Brief Summary of Prior Art ............................................................... 21
`B.
`Analysis of Ground 1 ......................................................................... 26
`1.
`Claim 24 ................................................................................... 27
`2.
`Claim 25 ................................................................................... 67
`3.
`Claim 26 ................................................................................... 68
`4.
`Claim 27 ................................................................................... 69
`5.
`Claim 28 ................................................................................... 71
`6.
`Claim 29 ................................................................................... 75
`7.
`Claim 30 ................................................................................... 77
`8.
`Claim 31 ................................................................................... 79
`9.
`Claim 32 ................................................................................... 88
`10. Claim 33 ................................................................................... 89
`11. Claim 34 ................................................................................... 89
`12. Claim 35 ................................................................................... 90
`-i-
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`Table of Contents
`(continued)
`
`Page
`
`13. Claim 36 ................................................................................... 94
`14. Claim 37 ................................................................................... 95
`15. Motivations to Combine the Prior Art ..................................... 96
`VI. NO SECONDARY CONSIDERATIONS OF NON-OBVIOUSNESS .... 109
`VII. CONCLUSION ........................................................................................... 111
`
`-ii-
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`

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`Declaration of Sandeep Chatterjee, Ph.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`I, Sandeep Chatterjee, Ph.D., declare as follows:
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`A.
`Qualifications and Experience
`1.
`I am the Chief Executive Officer of Experantis LLC, a technology
`
`consulting company. Previously, I was the Executive Vice President and Chief
`
`Technology Officer of SourceTrace Systems, Inc., a technology and services
`
`company enabling the delivery of secure remote electronic services over landline
`
`and wireless telecommunications networks.
`
`2.
`
`I received my bachelor’s degree in Electrical Engineering and
`
`Computer Science from the University of California, Berkeley in 1995. I received
`
`my master’s degree in Computer Science from the Massachusetts Institute of
`
`Technology (MIT) in 1997, and my doctorate in Computer Science from MIT in
`
`2001. I received a certificate of completion for an executive education program on
`
`global leadership from Harvard University in 2011. My doctoral dissertation at MIT,
`
`entitled “Composable System Resources for Networked Systems,” which involved
`
`networked client architectures and systems, was selected as one of the top inventions
`
`in the history of MIT’s Laboratory for Computer Science. This invention is
`
`showcased in a time capsule at the Museum of Science in Boston, Massachusetts.
`
`3.
`
`In 2011, I was named a Young Global Leader. This honor, bestowed
`
`each year by the World Economic Forum, recognizes and acknowledges the top
`
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`leaders—all below the age of 40—from around the world for their professional
`
`accomplishments, commitment to society, and potential to contribute to shaping the
`
`future of the world. In 2016, I was appointed to the World Economic Forum’s expert
`
`network as an expert in technology and innovation.
`
`4.
`
`I was part of the Expert Group that developed the JSR-00172 J2ME
`
`(Java 2 Platform, Micro Edition) Web Services Specification, the worldwide
`
`standard for mobile Web services. I am the co-author, with James Webber, of the
`
`book “Developing Enterprise Web Services: An Architect’s Guide” (published by
`
`Prentice-Hall in 2004). This book discusses games, such as Chess, within the
`
`context of web-based and web services-based systems. This book has been adopted
`
`by over 100 universities and colleges around the world and has been translated or
`
`reprinted in numerous countries around the world.
`
`5.
`
`I have been developing computer hardware and software systems for
`
`over twenty years. At MIT, as part of my doctoral dissertation work, I architected
`
`and developed computer hardware and software modules that were capable of
`
`communicating with and transmitting information to other systems and modules to
`
`which they were connected. Both the hardware and software modules used special
`
`types of interfaces that allowed different modules to use the functionalities and
`
`capabilities provided by each module. For example, a computing module could be
`
`2
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`connected to a television or Liquid Crystal Display (LCD) module to process
`
`information and display text and images onto the LCD. A wireless network module
`
`could then be connected to the computing module and the LCD module to add
`
`wireless network functionality. As I explained above, my doctoral dissertation thesis
`
`was selected as one of the top inventions in the history of MIT’s Laboratory for
`
`Computer Science, and it is preserved and showcased at the Museum of Science in
`
`Boston, Massachusetts.
`
`6.
`
`From 1997,
`
`I was also
`
`the Entrepreneur-in-Residence at
`
`FidelityCAPITAL, the venture capital arm of Fidelity Investments. In 1999, I spun-
`
`out the technology underlying my doctoral dissertation work at MIT and founded
`
`and served as President and Chief Technology Officer (CTO) of Satora Networks,
`
`which developed tools and technologies for building appliances and services for the
`
`Internet using wireless and other technologies to extend it beyond the desktop.
`
`7.
`
`In 2001, I joined Bluestone Software’s Mobile Middleware Labs as a
`
`Senior Engineering developing applications and systems infrastructure for enterprise
`
`Java/J2EE, Web services, and enterprise mobile solutions. After the completion of
`
`Hewlett-Packard’s (“HP”) acquisition of Bluestone, I became a Senior Member of
`
`the Technical Staff at HP’s Middleware Division. I was responsible for architecting
`
`and developing the company’s next-generation Web services platform for enterprise
`
`3
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`as well as mobile environments, known as the Web Services Mediator. I also worked
`
`with HP’s worldwide software operations to add extensions into the Java 2
`
`Enterprise Edition (J2EE) application server to easily support mobile applications
`
`and content, as well as flexible integration with other software systems using the
`
`eXtensible Markup Language (XML) and web services technologies.
`
`8.
`
`After leaving HP and through a contract between HP and the United
`
`States Agency for International Development (USAID), I led the development of a
`
`software system that enabled customers to use their mobile handsets to connect with
`
`the core banking systems of banks and other financial institutions, and perform
`
`transactions without having to travel to bank branches. One version of this solution
`
`utilized wireless point-of-sale (POS) terminals and smart cards to authenticate and
`
`authorize transactions. This was one of the first mobile banking solutions in the
`
`world.
`
`9.
`
`Later, after SourceTrace Systems’ acquisition of this technology and
`
`business, I led the expansion of this solution into multiple countries and into multiple
`
`industries. Banks and other financial services companies utilized this technology to
`
`make their tellers more efficient, to provide self-service kiosks within branches, and
`
`to provide remote access to banking services through roaming banking agents.
`
`10. Additionally,
`
`through SourceTrace’s
`
`licensing agreement with
`
`4
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`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`Telefonica, one of the largest cellular and telecommunications companies in the
`
`world, modified versions of this technology solution were deployed in various other
`
`industries, including logistics and asset management. For example, SourceTrace’s
`
`logistics technology solution enabled trucking companies to use mobile apps running
`
`on the mobile phones of truck drivers to schedule pick-up and delivery jobs, and to
`
`track the real-time status of each job as well as the current location of the truck. As
`
`a specific example, a set of jobs to pick-up and deliver various agricultural
`
`commodities from different farms could be assigned to a truck driver. Based on the
`
`dispatch instructions, including the location of each farm and the amount and type
`
`of agricultural commodity that was to be picked up, the truck driver would pick-up
`
`the commodities from each assigned location, and ultimately deliver all of
`
`commodities to one or more agricultural processing facilities. These technology
`
`solutions also supported different types of location-based services that enhanced the
`
`security and traceability of the system.
`
`11.
`
`12.
`
`I have attached a more detailed list of my qualifications as Exhibit A.
`
`Experantis is being compensated for my time working on this matter at
`
`my standard hourly rate plus expenses. Neither Experantis nor I have any personal
`
`or financial stake or interest in the outcome of the present proceeding, and the
`
`compensation is not dependent on the outcome of this IPR and in no way affects the
`
`5
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`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`substance of my statements in this Declaration.
`
`B. Materials Considered
`13.
` I have considered information from various sources in forming my
`
`opinions. Besides drawing from almost two decades of research and development
`
`work in the area of distributed computing systems, including securing these systems,
`
`I also have reviewed the documents and references as cited herein, including those
`
`identified in the following table:
`
`Exhibit Description
`1001 U.S. Patent No. 8,266,212 to Brunet de Courssou
`
`1002 File History of U.S. Patent No. 8,266,212 to Brunet de Courssou
`1003 Declaration of Sandeep Chatterjee, Ph.D.
`1004 U.S. Patent Application Publication No. 2001/0044339 to Cordero, et
`al.
`
`1005 U.S. Patent No. 5,187,787 to Skeen et al.
`
`1006 Nov. 10, 2021, IGT’s Responsive Claim Construction brief, IGT et al.
`v. Zynga Inc., Case No. 6:21-cv-00331-ADA (W.D. Tex.)
`
`1007 Sept. 27, 2021 Scheduling Order from IGT et al. v. Zynga Inc., Case
`No. 6:21-cv-00331-ADA (W.D. Tex.)
`
`1008
`
`June 30, 2021 Cover Pleading for Patent Owner’s Preliminary
`Infringement Contentions
`
`1009 Exhibit F to June 30, 2021 Patent Owner’s Preliminary Infringement
`Contentions
`
`6
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`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`1010 Derek Beyer, C# COM+ PROGRAMMING (2001)
`
`1011 Bill Brogden, SOAP PROGRAMMING WITH JAVA (2002)
`
`1012 Michi Henning and Steve Vinoski, ADVANCED CORBA PROGRAMMING
`WITH C++ (1999)
`
`1013 C. Liebig, M. Cilia, M. Betz, A. Buchmann, A publish/subscribe
`CORBA Persistent State Service Prototype (2000)
`
`1014 Microsoft Corp., Biz Talk Framework 2.0 Draft: Document and
`Message Specification (June 2000)
`
`1015 Mark Nadelson and Tom Hagan, C++ OBJECTS FOR MAKING UNIX &
`WINNT TALK (2000)
`
`1016 Brian Oki et al., The Information Bus – An Architecture for Extensible
`Distributed Systems, Proceedings of the Fourteenth ACM Symposium
`on Operating Systems Principles December 5-8, 1993
`
`1017 Vijay Machiraju et al., Service-Oriented Research Opportunities in the
`World of Appliances
`
`1018 Brian E. Travis, XML AND SOAP PROGRAMMING FOR BIZTALK
`SERVERS (2000)
`
`1019 Chad Darby et al., BEGINNING JAVA NETWORKING (2001)
`
`1020 Quotron Expects Board to Reject Citicorp Bid, New York Times,
`March 28, 1986
`
`1021 Kenneth P. Birman, BUILDING SECURE AND RELIABLE NETWORK
`APPLICATIONS (1995)
`
`1022 Patrick Eugster et al., Distributed Asynchronous Collections:
`Abstractions for Publish/Subscribe Interaction, ECOOP 2000 –
`Object-Oriented Programming, 14th European Conference, June 12-16,
`2000
`
`7
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`1023
`
`IEEE AUTHORITATIVE DICTIONARY OF IEEE STANDARDS TERMS (7th
`ed., 2000)
`
`1024 Sandeep Chatterjee and James Webber, DEVELOPING ENTERPRISE WEB
`SERVICES, AN ARCHITECT’S GUIDE (2004)
`
`1025 Microsoft Corp., MICROSOFT COMPUTER DICTIONARY, 5th ed., (May 1,
`2002)
`
`1026 XML-RPC.com, SIMPLE CROSS-PLATFORM DISTRIBUTED COMPUTING,
`BASED ON THE STANDARDS OF THE INTERNET (1998)
`
`14.
`
`I have reviewed the Petition in detail and agree with both its analysis
`
`and conclusions.
`
`II.
`
`PERSON OF ORDINARY SKILL IN THE ART
`15.
`I understand that an assessment of claims of the ’212 patent should be
`
`undertaken from the perspective of a person of ordinary skill in the art as of the
`
`earliest claimed priority date, which I understand is November 23, 2001. I have also
`
`been advised that the Patent Owner may not be to establish the November 23, 2001
`
`priority date for the patent claims at issue and that the priority date may instead be
`
`April 10, 2002 or August 21, 2007. If either of those priority dates were to apply
`
`instead, that change would not change the opinions I have expressed in this
`
`declaration. I have also been advised that to determine the appropriate level of a
`
`person having ordinary skill in the art, the following factors may be considered: (1)
`
`the types of problems encountered by those working in the field and prior art
`
`8
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`solutions thereto; (2) the sophistication of the technology in question, and the
`
`rapidity with which innovations occur in the field; (3) the educational level of active
`
`workers in the field; and (4) the educational level of the inventor.
`
`16.
`
`The ’212 patent states that “[e]mbodiments of the present invention
`
`relate generally to the field of pay computer-controlled games and entertainment
`
`devices, including both games of skills and games of chance. More particularly,
`
`embodiments of the present invention relate the field of methods, systems and
`
`devices for the automated monitoring and control of a large number of clusters of
`
`such pay gaming and entertainment devices.” Ex. 1001, 1:20-27. In my opinion, a
`
`person of ordinary skill in the art as of November 2001 would have possessed at
`
`least a bachelor’s degree in computer science or a related field with at least two years
`
`of industry or research experience in the fields of networking or network-based
`
`systems or applications, such as client-server and web-based systems, in the context
`
`of gaming or an equivalent level of skill, knowledge, and experience.. A person
`
`could also have qualified as a person of ordinary skill in the art with some
`
`combination of (1) more formal education (such as a Master of Science degree) and
`
`less technical experience or (2) less formal education and more technical or
`
`professional experience in the fields listed above.
`
`17. My opinions regarding the level of ordinary skill in the art are based
`
`9
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`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`on, among other things, my over 20 years of experience in computer science, my
`
`understanding of the basic qualifications that would be relevant to an engineer or
`
`scientist tasked with investigating methods and systems in the relevant area, and my
`
`familiarity with the backgrounds of colleagues, co-workers, and employees, both
`
`past and present.
`
`18. Although my qualifications and experience exceed those of the
`
`hypothetical person having ordinary skill in the art defined above, my analysis and
`
`opinions regarding the ’212 patent have been based on the perspective of a person
`
`of ordinary skill in the art as of November 2001.
`
`III.
`
`STATEMENT OF LEGAL PRINCIPLES
`A.
`Obviousness
`19.
`I understand that the prior art may render a patent claim obvious. I
`
`understand that two or more pieces of prior art that each disclose fewer than all
`
`elements of a patent claim may nevertheless be combined to render a patent claim
`
`obvious if the combination of the prior art collectively discloses all elements of the
`
`claim. I also understand that establishing obviousness requires a showing that one
`
`of ordinary skill in the art would have and could have combined the references with
`
`a reasonable expectation of success.
`
`20.
`
`I understand that the obviousness analysis must focus on the knowledge
`
`available to one of ordinary skill in the art at the time the claimed invention was
`
`10
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`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`made in order to avoid impermissible hindsight. I have also been informed that the
`
`framework for determining obviousness involves considering the following factors:
`
`(i) the scope and content of the prior art; (ii) the differences between the prior art
`
`and the claimed matter; (iii) the level of ordinary skill in the art; and (iv) any
`
`objective evidence of non-obviousness.
`
`21.
`
`I understand that a combination is improper when one of ordinary skill
`
`in the art, upon reading a reference, would be discouraged from following the path
`
`set out in the reference. I understand this standard may be met when a reference
`
`criticizes, discredits, or otherwise discourages modifying the reference to arrive at
`
`the claimed invention.
`
`B.
`22.
`
`Claim Construction
`I understand that under the legal principles, claim terms are generally
`
`given their ordinary and customary meaning, which is the meaning that the term
`
`would have to a person of ordinary skill in the art in question at the time of the
`
`invention, i.e., as of the effective filing date of the patent application. I further
`
`understand that the person of ordinary skill in the art is deemed to read the claim
`
`term not only in the context of the particular claim in which a claim term appears,
`
`but in the context of the entire patent, including the specification.
`
`23.
`
`I am informed by counsel that the patent specification, under the legal
`
`11
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`principles, has been described as the single best guide to the meaning of a claim
`
`term, and is thus highly relevant to the interpretation of claim terms. And I
`
`understand for terms that do not have a customary meaning within the art, the
`
`specification usually supplies the best context of understanding the meaning of those
`
`terms.
`
`24.
`
`I am further informed by counsel that other claims of the patent in
`
`question, both asserted and unasserted, can be valuable sources of information as to
`
`the meaning of a claim term. Because the claim terms are normally used consistently
`
`throughout the patent, the usage of a term in one claim can often illuminate the
`
`meaning of the same term in other claims. Differences among claims can also be a
`
`useful guide in understanding the meaning of particular claim terms.
`
`25.
`
`I understand that the prosecution history can further inform the meaning
`
`of the claim language by demonstrating how the inventors understood the invention
`
`and whether the inventors limited the invention in the course of prosecution, making
`
`the claim scope narrower than it otherwise would be. Extrinsic evidence may also
`
`be consulted in construing the claim terms, such as my expert testimony.
`
`26.
`
`I have been informed by counsel that, in Inter Partes Review (IPR)
`
`proceedings, a claim of a patent shall be construed using the same claim construction
`
`standard that would be used to construe the claim in a civil action under 35 U.S.C.
`
`12
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`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`§ 282(b) (the “Phillips” claim construction standard), including construing the claim
`
`in accordance with the ordinary and customary meaning of such claim as understood
`
`by one of ordinary skill in the art and the prosecution history pertaining to the patent.
`
`27.
`
`I have applied the “Phillips” claim construction standard for purposes
`
`of interpreting the claims in this proceeding, to the extent they require an explicit
`
`construction. The description of the legal principles set forth above thus provides
`
`my understanding of the “Phillips” standard as provided to me by counsel.
`
`IV. THE ’212 PATENT
`A.
`Overview of the Specification
`28.
`The ’212 patent is titled “Game Talk Service Bus.” The patent
`
`discloses a distributed gaming system “allowing gaming machines, servers,
`
`workstations, mobile PCs, handheld devices and automatic telling machines to talk
`
`together over a network.” Ex. 1001, Abstract.
`
`29.
`
` The patent describes that it “provides a publish-and-subscribe message
`
`bus” over a public or private network via a “game service bus.” Id., Abstract. The
`
`service bus “allows participating communicating end points to publish services or
`
`subscribe to services in a simple and standardized high level fashion.” Id. This
`
`“service bus” may be based on various known technologies, such as “SOAP, RPC,
`
`Microsoft Remoting, CORBA, RSS and/or Microsoft WCF
`
`(Windows
`
`Communication Foundation of .NET Framework 3.0).” Id., 14:65-15:3. The ’212
`
`13
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`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`patent explains that the participating communicating end points “may talk together
`
`in a peer-fashion,” which is “well suited for multiplayer gaming” in a complex and
`
`diverse distributed casino gaming environment. Id., Abstract.
`
`30.
`
` The ’212 patent further describes “device[s] that [are] connected as
`
`part of a computer network” as “nodes.” Id., 14:49-50. A node may “publish” to
`
`“one or a plurality of subscribers” various “services,” including a “progressive
`
`Jackpot service” or “printing service” or “music content” or “video content” over
`
`the network. Id., 15:27-42, 15:51-65, 23:56-67, 25:2-7. Each “node” may serve as
`
`one or more service publishers and simultaneously as one or more service
`
`subscribers. Id., 24:56-60, Fig. 24.
`
`31.
`
`The ’212 patent further discloses a flexible server-client configuration
`
`especially suitable for mobile gaming. Id., 23:17-19. The patent describes that a
`
`central server or a gaming machine may include “high-level software application
`
`modules” like a “business engine,” “video/entertainment/games engine,” or
`
`“authentication engine.” Id., 18:51-56, 19:7-18, 20:42-46. The patent describes the
`
`advantages of the flexible “modular architecture” as “avoid[ing] modifying high-
`
`level software modules,” “accelerat[ing] development time” and “reduc[ing]
`
`development cost” because the high-level software modules may be reused without
`
`modifications. Id., 19:7-18, 26:18-22, 26:61-64.
`
`14
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` IPR2022-00368
`
`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`B.
`32.
`
`Prosecution History
`In connection with preparing this Declaration, I have reviewed the file
`
`history of the ’212 patent. Ex. 1002. I discuss only portions of the file history herein
`
`but reserve the right to rely on any other portion of the file history for my opinions.
`
`33.
`
` The application for the ’212 patent was filed as US11/842,147 on
`
`August 21, 2007. Ex. 1001, Cover. The ’212 patent is a continuation-in-part of
`
`US10/120,635, filed on April 10, 2002 and issued as U.S. Patent No. 7,297,062. Id.
`
`The ’212 patent claims priority to provisional application No. 60/332,593, which
`
`was filed November 23, 2001. Id.
`
`34.
`
`In the first office action, dated June 8, 2011, the Examiner rejected the
`
`as-filed claims as obvious over U.S. Patent No. 5,674,128 to Holch (“Holch”) and
`
`U.S. Patent No. 5,762,552 (“Vuong.”) Ex. 1002, pp. 830-837.
`
`35.
`
`In response on October 3, 2011, Applicant argued that “there is no
`
`teaching or suggestion in the applied combination of references of any steps of
`
`publishing or subscribing, by any gaming machine, for any purpose.” Id., p. 899.
`
`Applicant argued that Holch merely discusses “a process whereby an account server
`
`requests a player’s account number and PIN and causes the gaming machine to
`
`display a selection of video games if both are valid and correspond to one another
`
`and terminates the session if not.” Id., p. 893. Applicant also argued that Vuong did
`
`15
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` IPR2022-00368
`
`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`not cure this deficiency with its teaching of a system for remote real-time interactive
`
`gambling. Id., p. 896.
`
`36. On May 2, 2012, the Examiner rejected claim 25 and 27 as obvious
`
`over Holch and Vuong. Id., pp. 938-39. The Examiner objected to claim 26 as
`
`depending on a rejected base claim but would be allowable if written in independent
`
`form. Id., p. 940.
`
`37. On July 12, 2012, the applicant cancelled claim 25, rewrote claim 26 in
`
`independent form (corresponding to issued claim 22), and amended claim 27 to
`
`depend from claim 26. Id., pp. 958-59.
`
`38. On July 18, 2012, the Examiner responded with a notice of allowance.
`
`Id., p. 974.
`
`C.
`39.
`
`The Challenged Claims
`This Declaration addresses Claims 24-37 of the ’212 patent. I have
`
`reproduced the Challenged Claims below, and divided up the limitations using
`
`bracketed notations (e.g., “[1],” “[2],” etc.) to facilitate identification of the
`
`limitations in my analysis below:
`
`24.[p] A method for distributed gaming over a
`communication bus, comprising:
`
`[1] providing a first gaming machine and coupling the
`first gaming machine to the communication bus;
`
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` IPR2022-00368
`
`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`[2] publishing, by the first gaming machine, a first
`high-level function over the communication bus;
`
`[3] providing a node coupled to the communication
`bus;
`
`[4] receiving, from the node, a request to subscribe to
`the published first high-level function;
`
`[5] accepting the subscription request;
`
`[6] initiating a gaming session on the first gaming
`machine, and
`
`[7] responsive to updates occurring during the gaming
`session, providing call backs, by the first gaming machine,
`the call backs returning a result of the execution of the first
`high-level function to the node over the communication
`bus.
`
`25. The method of claim 24, wherein the receiving
`step is carried out with the node including a second
`gaming machine.
`
`26. The method of claim 24, wherein the receiving
`step is carried out with the node including at least one
`of an entertainment machine, a payment verification
`unit, a specialized device, an IP enabled device, a
`server, a server farm, a computer device, and an
`automatic teller machine.
`
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` IPR2022-00368
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`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`27. The method of claim 24, wherein the high-level
`function includes at least one of a business function, an
`audit function, an authentication function, a biometric
`identification
`function,
`a
`graphics
`rendering
`computation function, and an outcome determination
`function.
`
`28. he method of claim 24, further comprising a step
`of receiving, from the node, a request that the first
`gaming machine executes the high-level function.
`
`29. The method of claim 24, further comprising a
`step of the first gaming machine performing a call back
`upon receiving the request to consume or execute the
`high-level function.
`
`30. The method of claim 24, wherein the second
`providing step is further carried out with the node being
`configured to selectively publish, subscribe, provide,
`execute and request that the first gaming machine
`execute the high level function.
`
`31.[p] A method for distributed gaming over a
`communication bus, comprising:
`
`[1] providing a first node and coupling the first node to
`the communication bus;
`
`[2] publishing, by the first node, a high-level function
`over the communication bus;
`
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`

`

`Declaration of Sandeep Chatterjee, Ph.D. in Support
`of Petition for Inter Partes Review of
`U.S. Patent No. 8,266,212
`
`[3] providing a first gaming machine coupled to the
`communication bus;
`
`[4] receiving, from the first gaming machine, a request
`to subscribe to the published high-level function;
`
`[5] accepting the subscription request;
`
`[6] initiating a gaming session on the first gaining
`machine, and
`
`[7] responsive to updates occurring during the gaming
`session, providing call backs