UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________
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`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner
`
`___________________________________
`
`Case: PGR2018-00055
`U.S. Patent No. 9,687,744
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`
`
`DECLARATION OF DAVID CRANE
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 1
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`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner
`
`___________________________________
`
`Case: PGR2018-00055
`U.S. Patent No. 9,687,744
`
`
`
`DECLARATION OF DAVID CRANE
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 1
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`
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`PGR2018-00055
`U.S. Patent No. 9,687,744
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`I. Qualifications & Background.
`1. My name is David Crane, and I reside in California. I am an independent
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`consultant. I am over eighteen years of age, and I would otherwise be competent
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`to testify as to the matters set forth herein if I am called upon to do so.
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`2.
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`I submit this Declaration at the request of GREE, Inc., for consideration by
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`the Patent Trial and Appeal Board in the post-grant review of U.S. Patent No.
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`9,9,687,744 (“the ’659 patent”).
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`3.
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`In forming my opinions, I rely on my knowledge and experience in the field
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`and on documents and information referenced in this Declaration. No part of my
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`compensation in this matter is dependent upon the outcome of this proceeding or
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`any issue in this proceeding.
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`4.
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`I built my first computer – an unbeatable Tic-Tac-Toe computer – at the age
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`of 14, and graduated high school with the ability to program IBM mainframe
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`computers in 3 languages.
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`5.
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`I earned a Bachelor of Science in Electronic Engineering Technology from
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`DeVry Institute of Technology in Phoenix, Arizona (“DeVry”) in 1975. While in
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`college, I was the lead hardware designer and project leader on a fully digital Tic-
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`Tac-Toe playing custom hardware project. This design featured 72 discrete
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`integrated circuits and an innovative display using polarized light to separate light
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`output into Xs and Os. In the same timeframe, I designed the first programmable
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 2
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`electronic drum machine, and a digital clock that never needed setting, designed to
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`receive a time standard over the AC power line.
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`6.
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`I began my professional engineering career at National Semiconductor in
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`1975 developing integrated circuits and working with early analog-to-digital and
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`digital-to-analog converters.
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`7.
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`In 1977, I began my career in the video game industry when I joined Nolan
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`Bushnell’s Atari Inc., (“Atari”), where I designed and developed games that
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`generated approximately $15 million in sales revenues for the company. In 1979, I
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`co-founded Activision, Inc. (“Activision”), the first third-party developer and
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`publisher of video game cartridges.
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`8.
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`Activision grew to over $300 million in value in three years, and is now one
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`of the largest, if not the largest, third party video game publishers in the world,
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`with a market capitalization of over $15 billion. During my tenure at Activision I
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`designed and programmed many hit games with unit sales over 500,000. One such
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`example is the game Pitfall!™ which sold over 3,500,000 copies, and held the #1
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`spot on the Billboard Charts for 64 consecutive weeks. Pitfall!™ generated over
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`$50 million in wholesale revenues and spawned numerous other products including
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`many sequels, toys, and a Saturday morning cartoon.
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`9.
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`After leaving Activision in 1987, I founded a series of small game
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`publishing companies, performing the same two main functions: First become the
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 3
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`company’s hardware expert on a particular game console, then design and program
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`award-winning games. Throughout this process I have developed expertise in over
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`20 video game consoles or systems, including the Atari 2600, Atari 5200, Atari
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`7800, Atari 400, Atari 800, Magnavox Odyssey II, Mattel Intellivision,
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`Colecovision, Apple II, MS-DOS, Commodore C64, Commodore C128, Nintendo
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`NES, Nintendo SNES, Nintendo Game Boy, Nintendo DS, Sega Master System,
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`Sega Genesis, Sega CD, Sony Playstation, Microsoft Xbox, Microsoft Xbox 360,
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`Nokia Series 60 feature phones, LG VX4400, LG VX6000, Apple iPhone, Apple
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`iPod touch, and Apple iPad.
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`10. As game consoles evolved, so did computer programming languages. My
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`expertise includes work in over 20 computer languages: FORTRAN, RPG,
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`COBOL, BASIC; Microprocessor Assembly Languages: 6502, Intel 8080,
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`National Semiconductor PACE 16 bit, National Semiconductor SC/MP 8 bit, GI-
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`1610, Zilog Z80, 65816, Intel 8048, 8086, 80286; Microprocessor Programming
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`Languages: C, C++, Objective C, J2ME, Brew; NEC microcontroller assembly
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`language; Scripting Languages: Lingo, Actionscript, Lua, Javascript, HTML-5;
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`Engineering Languages: SPICE, and VHDL.
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`11. A partial list of the published game titles for which I am responsible for the
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`game design and/or programming includes: Canyon Bomber, Outlaw, Slot
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`Machine, Pitfall!, Pitfall II, Lost Caverns, Freeway, Laser Blast, Fishing Derby,
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 4
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`Dragster, Grand Prix, A Boy and His Blob, The Rescue of Princess Blobette,
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`Ghostbusters, Skateboardin’, Super Skateboardin’, The Activision Decathlon,
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`T*O*Y*S, Transformers, the computer game, David Crane’s Amazing Tennis,
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`Bart Simpson’s Escape from Camp Deadly, CHOMP, Arcade Bowling, Ten Pin
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`Championship Bowling, Stellar Blast, Arcade Hoops, 3 Point Hoops, QB Pass
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`Attack, Field Goal Frenzy, Lotto Letters, Super Swish, Stellar Blast, Mariner
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`Hybrid Infomercial, Lacrosse, Beach Volleyball, Spiderman Climbing game,
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`Miller Seat Salsa, Super Cocoa Man, Break the Rules Hoops, Downfield Strike,
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`Mini Motocross, Robopup Run, Toyota 4runner Challenge, Tyco RC Speed
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`Wrench, Vertical Jam, E.T.’s Adventure, Bubble Yum Home Run Derby, Bubble
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`Yum Bullpen Blast, Gummi Savers Egg Hunt, Foul Shot Shootout, Life Savers
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`Water Park Pinball, Field Goal Challenge, Crème Savers Bowling, Golf Solitaire,
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`Skyworks Lanes Bowling, Carefree on Ice, Gummi Savers Rock-N-Skate, YIPES!
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`Photo Safari, Ice Breakers Slap Shot Shootout, Southpark Pinball, Breath Savers
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`Road Rally, Ford NASCAR racing challenge, MTv Cranks Dirt Bike Game, Ice
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`Breakers Ultimate Bobsled, Breath Savers Billiards, Snackwells Chocolate Factory
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`Pinball, Snowboard Big Air, Skate Rage Inline Skating, Candystand Miniature
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`Golf, Lifesavers Word Challenge, Candystand Open Tennis, Mountain Climbing, 3
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`Point Shootout, Grand Slam Pinball, Nabisco World Team Racing, Soccer
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 5
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`Shootout, LifeSavers Treasure Hunt, Oreo Adventure, LifeSavers Roll-A-ball, Air
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`Crisps Slam Dunk, Fruit Chews BMX, and Postopia Bowling.
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`12.
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`I have received many awards for my work and career. Most recently, I
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`received one of the Academy of Interactive Arts and Sciences lifetime honors: The
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`Pioneer Award, celebrating my foundational and continuing work in the creation
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`and development of the video game business. This singular honor, presented to me
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`in 2010, was the inaugural award in a new category. I was the first to receive this
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`award out of everyone who had ever worked in the video game industry throughout
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`its entire history. Additional awards include Game Designer of the Year (twice),
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`the prestigious 2003 Game Developer Choice Award for contribution to the field,
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`and the Lifetime Achievement Award in Video Games from Classic Gaming Expo.
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`In addition to these personal honors, many of the individual games that I have
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`developed have also received numerous awards.
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`13.
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`I am a regular speaker and/or panelist at video game industry trade events
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`such as the D.I.C.E. Summit (Design, Innovate, Communicate & Entertain), and
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`GDC (Game Developers Conference). I have spoken at gatherings of game
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`business executives (such as at the Pepperdine University Graziadio School of
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`Business and Management), and I am featured annually at the Classic Gaming
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`Expo. I have been profiled in national press publications including Forbes
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 6
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`Magazine and Newsweek, and I have been interviewed by such diverse
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`publications as television’s 20/20 News Magazine and the G4 Television Network.
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`14. My complete academic background and professional experience are set forth
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`in my Curriculum Vitae, a copy of which is attached hereto as Appendix A.
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`15.
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`I relied on the foregoing training, knowledge, and experience in the relevant
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`art in formulating the opinions expressed herein.
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`II. Materials Considered.
`16.
`I have reviewed and considered the following documents in forming the
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`opinions set forth in my declaration:
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`a. The ’744 Patent (filed as Exhibit 1001 by Supercell OY).
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`b. Supercell OY’s Petition for Post-Grant Review of the ’744 Patent.
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`c. Exhibit 1002 – the prosecution history of the ’744 Patent.
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`d. Exhibit 1003 – U.S. Patent No. 9,457,279.
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`e. Exhibit 1004 – the prosecution history of U.S. Patent No. 9,457,279.
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`f. Exhibit 1005 – USPTO Guidance dated December 16, 2014.
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`g. Exhibit 1006 – USPTO Memorandum dated May 19, 2016.
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`h. Exhibit 1007 – USPTO Memorandum dated November 2, 2016.
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`i. Exhibit 1008 – Subject Matter Eligibility Examples of December
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`2016.
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 7
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`III. Legal Standards Applied.
`17.
`I have been informed and understand that a claim in an unexpired patent
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`shall be given its broadest reasonable construction in light of the patent’s
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`specification. I have been informed and understand that claim terms are generally
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`given their ordinary and customary meaning as would be understood by a person of
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`ordinary skill in the art in the context of the entire disclosure.
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`18.
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`I have been informed and understand that an invention is patent-eligible if it
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`claims a new and useful process, machine, manufacture, or composition of matter,
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`but laws of nature, natural phenomena, and abstract ideas are not patentable. I
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`have been informed and understand that the inquiry determine whether or not an
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`invention is patent-eligible has two steps: (1) determine whether the claim is
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`directed to a patent-ineligible abstract idea, and (2) if so, whether the elements of
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`the claim both individually and as an ordered combination transform the nature of
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`the claim in a patent-eligible application of the abstract idea. I have been informed
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`and understand that claims reciting well-understood, routine, conventional activity
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`in the field are insufficient to render the claims patent-eligible, and the question of
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`whether a claim element or combination of elements is well-understood, routine
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`and conventional to a skilled artisan in the relevant field is a question of fact.
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`19.
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`I have been informed and understand that claims have sufficient written
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`description when the disclosure of the application relied upon reasonably conveys
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 8
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`to those skilled in the art that the inventor had possession of the claimed subject
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`matter as of the filing date. I have been informed and understand that this test
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`requires an objective inquiry into the four corners of the specification from the
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`perspective of a person of ordinary skill in the art, and based on that inquiry the
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`specification must describe an invention understandable to that skilled artisan and
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`show that the inventor actually invented the invention claimed.
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`20.
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`I have been informed and understand that a claim must particularly point out
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`and distinctly claim the subject matter. I have been informed and understand that a
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`claim is indefinite when it contains words or phrases whose meaning is unclear. I
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`have been informed and understand that the definiteness requirement is not a
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`demand for unreasonable precision, and the amount of clarity that is required
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`necessarily invokes some standard of reasonable precision in the use of language in
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`the context of the circumstances. I have been informed and understand that
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`whether claims are sufficiently definite is based on the perspective of one of
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`ordinary skill in the art in view of the entire written description and developing
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`prosecution history.
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`IV. Level of Ordinary Skill in the Art.
`21. A person of ordinary skill in the art (“POSA”) would possess at least an
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`associate degree in the field of computer science (or a related discipline, such as
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`computer engineering, to the extent the course of study involved the design and
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 9
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`programming of graphical user interfaces) and at least two years of practical (e.g.,
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`work) experience in the field of video-game programming and interface design. If
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`the POSA did not obtain a formal degree, then they would have at least four years
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`of practical (e.g., work) experience in the field of video-game programming and
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`interface design. In addition, a POSA would have training or experience in game
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`theory and the development of game rules or mechanics.
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`V. Opinions Regarding the ‘744 Patent.
`A. The Technical Problem Described in the ‘744 Patent
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`22. The ‘744 Patent is directed at an improvement in multiplayer online battle
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`games in which players are allowed to, for example, form Guilds and combine the
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`efforts of players in order to execute attacks against their opponents in the game.
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`The Specification correctly identifies that the nature of multiplayer games creates a
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`barrier for new players, specifically:
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`“For a plurality of players to make successive attacks in cooperation
`with each other, the players need to be proficient in the battle game to
`a certain extent, and there is hardly any scene where inexperienced
`players can play active parts. Since it is more advantageous in terms
`of game development to form a group of skilled high-level players,
`inexperienced players are not sufficiently motivated to participate in
`the battle game.” Ex. 1001 at 1:53-60
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 10
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`23. There are many aspects to the barrier/problem—social, behavioral,
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`marketing, and technical. The ‘744 Patent Specification and Claims are directed
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`toward a technical, game-design solution in order to address this problem.
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`24. The technical barrier results from the in-game advantages possessed by
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`veteran players, which allow those players to have a greater ability to be successful
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`in the game. Advantages held by veteran players include his or her experience in
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`playing the game (such as the number of hours or sessions played), but also include
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`the player character’s level, accumulated in-game loot, weapons, and earned in-
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`game skills. It was known in the art at the time of the invention for elements such
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`as player performance statistics and character’s experience points (XP) to be
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`factored into that player’s battle results.
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`25. Solving the technical problems created by this barrier is an important part of
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`the design of a multiplayer game. For any game, design goals include maximizing
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`player accessibility and usability of the game through its interface and the
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`mechanics of the game. The outcome of a battle in a multiplayer game is an
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`element under the control of the game’s designer, and it is reasonable to apply
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`innovations to the game mechanic in order to maximize player accessibility and
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`usability of the game.
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 11
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`B. The Invention Described in the ‘744 Patent is an Inventive Game
`Mechanic for Multiplayer Online Battle Games
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`26. The inventive mechanic of the ‘744 Patent is used in combo attacks to affect
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`the overall outcome of a combo battle based on the difference in proficiency
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`between the players involved in the combo.
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`27. All of the independent claims (Claims 1, 5, and 9) recite specific rules for
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`implementing this mechanic in combo executed in a battle game by a group of
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`characters in a multiplayer, client-server environment.
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`Claim 1: “… controlling, by a processor of the server device, an effect
`of attack by a group, according to a difference in the parameter
`between two characters belonging to the same group…”
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`Claim 5: “…displaying, by the processor, on a display device, an
`effect of attack by a group, wherein the effect is controlled in
`accordance with a difference in a parameter between two characters
`belonging to the same group…”
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`Claim 9: “…wherein the processor is operative to control an effect of
`attack by a group, according to a difference in the parameter between
`two characters belonging to the same group…”
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`28. The “parameter” in the claims is a numeric representation of the player’s
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`proficiency (see below). With a player’s proficiency represented as a numerical
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`value, the outcome of a battle can be affected by the difference in those numerical
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`values.
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 12
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`29. The Patent describes the implementation of this parameter in multiplayer
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`battle games as an improvement over what was known in the art. I do not believe,
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`nor has Petitioner provided evidence in the Petition, that affecting the result of a
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`battle based on the difference in combo players’ proficiency was well-understood,
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`routine, or conventional in multiplayer battle games at the time of the invention.
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`30. The invention solves the technical problem described above by incentivizing
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`players to form a group of varying levels of skill:
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`“…the effect of successive attacks can be increased by successively
`making an attack by a character operated by a player with a high
`degree of proficiency in the battle game and an attack by a character
`operated by a player with a low degree of proficiency in the battle
`game. This creates more scenes where players with low proficiency
`in the battle game can play active parts, making the social game more
`active. In particular, inexperienced players are effectively motivated
`to participate in the game” Ex. 1001 at 6:6-15
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`31. Moreover, while the inexperienced player is motivated to participate in the
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`game, the more experienced player is rewarded with a better outcome when going
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`into battle paired with a less experienced player. Both veteran and novice players
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`benefit from the mechanic.
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 13
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`C. Written Description Analysis - The Specification teaches a POSA how to
`practice the claims.
`1. “parameter”
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`32. The “parameter” disclosed in the Specification is a numeric representation of
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`a given player’s proficiency based on in-game character attributes, including:
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`Level:1 “…the parameter 50 may be a variable indicating the degree
`of proficiency in the battle game. The degree of proficiency represents
`the player’s skill or experience, and so is also referred to as “level”.
`The level of the player increases as the player becomes more
`experienced in the battle game.” Ex. 1001 at 3:47-52
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`Reward: “The reward may be, for instance, an item for increasing the
`character’s offensive power, an item for recovering the character’s
`health points or recovering from damage, or points added as a result
`of damaging an enemy character.” Ex. 1001 at 3:60-63
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`Time elapsed: “the parameter 50 may be a variable indicating the
`time elapsed from the date on which the player participates in the
`battle game.” Ex. 1001 at 3:65-67
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`Offensive / Recovery Ability: “The parameter 50 may be a variable
`that changes as the character’s offensive ability or recovery ability
`changes.” Ex. 1001 at 3:67-4:02
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`1 It was well known in the art at the time of the invention for games to maintain a
`numeric “level” for in-game characters. One goal of a game player was to play a
`game for many hours and/or in specific ways in order to “level-up” his or her
`character.
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 14
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`33. A POSA would understand how to use any or all of these example measures
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`to derive a numerical parameter that represents a player’s proficiency in a game. It
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`would be well within the skill of a POSA to write a game program, for example in
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`an object-oriented or procedure-oriented programming language as described in the
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`‘744 patent (Ex. 1001 at 6:60 – 7:17) that utilizes any or all of these measures as
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`the “parameter” to practice the claimed invention.
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`2. “controlling…”
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`34. The Specification provides particular algorithms in the figures and discloses
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`how the result of a combo attack is controlled by the various inputs, such as
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`difference in parameter, timing of attacks, and number of attacks:
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`Difference in parameter: “Here, the effect of attack by the group 300
`(e.g. the attack by the character 302 on the character 402) is increased
`more when the difference ∆ Pl in the parameter 50 between the two
`characters 301 and 302 is larger.” Ex. 1001 at 5:62-66
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`“Here, the effect of attack by the group 300 (e.g. the attack by the
`character 303 on the character 403) is increased more when the
`difference ∆ P2 in the parameter 50 between the two characters 302
`and 303 is larger.” Ex. 1001 at 5:67-6:04
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`Timing of attacks: “Alternatively, the effect of successive attacks
`may be increased more when the number of successive attacks is
`larger on the condition that the time difference (“t2-tl” or “t3-t2”)
`between attacks successively made by two characters is within a
`predetermined time.” Ex. 1001 at 6:42-46
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 15
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`Number of attacks within a predetermined time: “For instance, the
`effect of successive attacks may be increased more when the number
`of attacks made by any characters in the group 300 within a
`predetermined time from time t1 at which the first attack starts is
`larger.” Ex. 1001 at 6:38-42
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`35. Each of these examples disclosed in the Specification discuss affecting the
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`outcome of an attack in the form of an increase, which is a form of “control”. A
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`POSA would know a negative increase or no change were also possibilities and
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`would know how to implement them.
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`36. Note also that the claims do not require specific values for proficiency; nor
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`do they require a definition of “low proficiency” or “high proficiency”. Neither
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`would a POSA need specific examples of values in the specification to understand
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`how to affect the outcome of an attack based upon these properties.
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`3. “information necessary for a battle game”
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`37. The Specification explains the client-server implementation of an online
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`battle game. In the example given, the information necessary for a battle game,
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`while unique for any specific implementation of a game, is computed at the server
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`with resulting data transmitted from the server for display on the client:
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`Referring to FIG. 2, “The computer program 40 is a program for
`performing game processing in response to requests from the plurality
`of client devices 30, and includes a plurality of software modules that
`are called in a main program and executed. These software modules
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 16
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`are each a subprogram modularized to execute specific processing …
`As one of such modularized subprograms, the computer program 40
`includes a presentation processing module 41 for performing
`presentation processing of the battle game.” Ex. 1001 at 3:29-41
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`Referring to FIG. 3, “The display device 36 provides an image display
`interface for game screens and the like to the player” Ex. 1001 at
`4:49-51
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`38. As noted, which and what types of parameters are necessary to a battle game
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`vary with the game. It is well within a POSA's understanding which parameters
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`are necessary to a specific battle game that he or she is creating that would be sent
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`from the server to the client.
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`4. “displaying…”
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`39. The ‘744 Specification describes an exemplary game display as shown in
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`FIG. 4, including what information gets displayed:
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 17
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`40. The client display device is configured to display a battlefield, player
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`characters, and character combo groupings:
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`“The game screen 200 comprises an event field 201 and a palette 202.
`The event field 201 is a virtual field in which a battle game between
`groups 300 and 400 is developed. Characters 301, 302, and 303
`belonging to the group 300 and characters 401, 402, and 403
`belonging to the other group 400 are displayed in the event field 201.”
`Ex. 1001 at 5:20-25
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`41. The client display device is also configured to display “combo gauges”:
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`“The number of successive attacks is referred to as "combo count",
`and the gauges 501 and 502 displaying the combo counts are each
`referred to as "combo gauge".” Ex. 1001 at 5:20-25
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 18
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`42. The ‘744 Specification provides a clear Written Description of “displaying”
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`and an exemplary game screen, providing the POSA with sufficient disclosure to
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`practice the claims.
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`5. “effect of an attack”
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`43. The Specification discloses at least one example of what is meant by the
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`“effect of an attack”:
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`Referring to FIG. 4: “Each player … attacks the opponent character
`according to the combination of skills, attack values, specific items,
`defense values, and the like…”
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`[Then following the attack]
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` “Damage inflicted on the opponent character and damage inflicted on
`the character of the player are then calculated.” Ex. 1001 at 5:42-44
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`44. The calculation of damage inflicted on opponent and player characters, and
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`the combo counts depicted in the combo gauges as described above, are two
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`examples of how the Specification describes what the “effect of an attack” is and
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`how it might be displayed.
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`D. Claims are Definite
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`45.
`
` As shown above, the ‘744 Specification contains sufficient Written
`
`Description of the terms relied upon in the Claims, providing the POSA with the
`
`necessary disclosure in order to practice the claims. For the same reasons stated
`
`
`
`
`
`Patent Owner GREE, INC. - Exhibit 2002 - Page 19
`
`
`
`above, the disclosures in Specification coupled with the knowledge of one of
`
`ordinary skill in the art sufficiently defines the terms used in the Claims.
`
`1. controlling… an effect of an attack by a group
`
`46. The Specification provides particular algorithms in the figures and discloses
`
`how the result of a combo attack is controlled.
`
`47. The examples cited above discuss affecting the outcome of an attack in the
`
`form of an increase, which is a form of “control”. A POSA would also realize that
`
`a negative increase or no change were possible forms of “control” and would know
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`how to implement them. The Specification also discloses at least one example of
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`what is meant by the “effect of an attack”.
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`48. With the disclosure of both “control” and an “effect of an attack”, there
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`would be no ambiguity in the mind of a POSA as to what the inventor meant by
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`controlling an effect of an attack by a group.
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`2. information necessary for a battle game
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`49. The information necessary to implement a battle game is processed on a
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`server to which massive numbers of players are connected. Information necessary
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`to display on a client device the current state of a battle game is transmitted from
`
`said server to each client device. Which and what types of parameters are
`
`necessary to a battle game vary with the specific implementation of a game, and it
`
`
`
`
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 20
`
`
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`is well within a POSA's understanding which parameters are necessary to send to
`
`the client device for the specific battle game that he or she 1s designing.
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`3. displaying... an effect of attack by a group
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`50.
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`As I explained above, the “744 Specification describes an exemplary game
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`display, which includesthe display of a battlefield, player characters, and character
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`combo groupings. The Specification also discloses at least one example of whatis
`
`meant by the “effect of an attack”—damageinflicted on opponentand player
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`characters.
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`51. With the disclosure of both an exemplary game display and an effect of an
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`attack, there would be no ambiguity in the mind of a POSAasto what the inventor
`
`meant by displaying an effect of an attack by a group.
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`VI.
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`SUMMARY
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`52.
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`[note that my analysis is continuing and that I may modify or supplement
`
`my conclusionsas I receive additional information. I declare under penalty of
`
`perjury that the foregoing Declaration is true and correct.
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`Dated: July 18, 2018
`
`David Crane
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`Patent Owner GREE,INC. - Exhibit 2002 - Page 21
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`Patent Owner GREE, INC. - Exhibit 2002 - Page 21
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