UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`The Honorable Rodney Gilstrap
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`
`Civil Action No. 2:19-cv-00413-JRG-RSP
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`
`
`
`
`JURY TRIAL DEMANDED
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`
`§ § § § § § § § § §
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`
`
`GREE, INC.,
`
`
`
`
`v.
`
`
`SUPERCELL OY,
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`EXPERT REPORT OF STACY FRIEDMAN
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`
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`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 1 of 250
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`197. A POSITA would understand that depicting cards in a player’s hand as shown in
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`Baten Kaitos mimicked the real-world arrangement of holding cards in a player’s hand and a
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`“Next” card ready to replace it.
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`VIII. THE ASSERTED CLAIMS OF THE ’177 AND ’362 PATENTS ARE PATENT-
`INELIGIBLE
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`198.
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` In my opinion, the claims of the ’177 patent and the ’362 patent are directed to
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`the abstract idea of organizing a game with different rules for different phases of the game, and
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`rely solely on generic computer components to carry out that abstract idea. They are therefore
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`patent ineligible.
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`A.
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`The Asserted Claims of the ’177 and ’362 Patents are Drawn to An Abstract
`Idea
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`199. The asserted patents describe computer-implemented methods or systems for
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`managing a game, specifically, organizing a computer battle game with different rules for
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`different periods of the game. Both the ’177 and ’362 patents are directed to the abstract idea of
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`managing a game on a computer by setting a different battle condition for at least one of multiple
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`terms of the battle game. See ’177 and ’362 patents (the claims of both patents are described as a
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`virtual battle under which certain rules can be changed and battle conditions vary based on a
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`different term of the battle game). The specification for both patents is identical and describes
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`the claims of both patents as a “game control method, a system, and a non-transitory computer-
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`readable recording and/or storage medium that allow a wide range of players to enjoy a group
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`battle without regard for difference in level, degree of attack strength, or the like and that
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`improve the participation rate in a group battle throughout the set time slot.” ’177 patent, 3, 11.
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`14-20 and ’362 patent, 3:18-24. In other words, the claims cover nothing more than managing a
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`game involving different rules for different periods within the game.
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`200.
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`I understand that the Patent Owner has agreed with the assessment of the claims
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`as directed to managing a game on a computer by setting a different battle condition for at least
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`one of multiple terms of the battle game, having described the ’177 and ’362 patents’ claims as
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`“a virtual battle under which certain rules can be changed and battle conditions vary based on the
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`time slot of the battle game.” Dkt. 34 at 9. Likewise, during prosecution of the application that
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`led to the ’177 patent, Patent Owner described the claimed invention as “also includ[ing] a
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`specific set of rules for operating a game.” ’177 prosecution history at 6/19/2018 Response to
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`Office Action p. 11.
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`201. The shared specification notes several “issues” with prior art “time slot group
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`battle” games, and proposes to change the rules of such games to “improve the participation rate.”
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`The particular rule changes take the form of subdividing the time slot into portions and either (a)
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`giving an advantage to certain players (e.g., beginners or low-level players) in earlier portions, or
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`(b) giving an advantage to players who participate earlier based on their “tallied results.” Both
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`types of rule changes are intended to encourage play in earlier portions of the battle game and to
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`increase the participation rate. As noted below, the claims are broader than “subdividing a time
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`slot into portions” because the claimed “terms” of the battle game are not necessarily subdivisions
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`of a predetermined time slot as described in the specification. Also as noted below, the claims are
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`broader than “time slot group battle” games because the claimed “player” can play the game
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`alone, without interacting with any other player.
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`202.
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`In my opinion, managing a game on a computer by setting a different battle
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`condition for at least one of multiple terms of a battle game is an abstract idea. The ’177 and
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`’362 patents propose to implement this idea using generic and conventional technology behaving
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`in its ordinary and expected manner. The asserted claims provide no inventive concept to
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`transform the abstract idea into something patent eligible.
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`203. The ’177 and ’362 patents claimed concept of managing a game on a computer by
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`setting a different battle condition for at least one of multiple terms of a battle game consists
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`entirely of mental steps that can be carried out by a human, either mentally, using pen and paper,
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`or with real world game pieces, and thus is abstract.
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`204. Consider the well-known trivia game show Jeopardy, in which players compete
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`against each other for monetary rewards, during three rounds that each have a different condition
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`for point values. In the second round of Jeopardy, point values are doubled over those in the first
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`round. In the final round, a player wagers an amount up to their total score from the previous
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`rounds.25 Though a timer is not visible, each round is timed to fit within the allotted broadcast
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`time for each episode, and an audible beeping noise can be heard at the end of the allotted period
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`for each round.
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`205. This real-world analogy reads on each of the claimed steps in each of the
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`independent claims: (1) in the first round or “term” of Jeopardy, the competition between the
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`players is conducted based on conditions for the first term, namely a set of point values, (2) in the
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`second round or “term,” the competition between the players is conducted based on conditions for
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`the second term that are different from those in the first term, namely a set of point values that are
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`doubled as compared to those in the first term, and (3) in the final round (“Final Jeopardy”) or
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`third “term,” the competition between the players is conducted based on conditions for the third
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`term that are different from those in the first and second terms, namely a wager by the players,
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`with the available wager amount dependent upon a player’s total score prior to the final round.
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`This analogy demonstrates that the claimed process is both a well-known mental process which
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`25 https://web.archive.org/web/20140222052504/https://en.wikipedia.org/wiki/Jeopardy!
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`can be accomplished with pen and paper, and a method of organizing human activity – and is
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`therefore abstract.
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`206. Further, many other games such as sports and boardgames demonstrate that the
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`claimed method of managing a game on a computer by setting a different battle condition for at
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`least one of multiple terms of a battle game is merely automation of a manual process, and is
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`therefore abstract.
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`207. Sports matches that include different terms with different conditions applied
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`during those terms include soccer and American football, both of which implement an overtime
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`round when the allotted game time runs out before a winner is declared (e.g., a tie). An overtime
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`round typically has different conditions than the regular game play, such as reduced time, and
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`changed rules as to scoring and ball placement. For example, NFL football games have different
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`rules for the first 28 minutes of each half, the time period after the two-minute warning in each
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`half, and overtime.26
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`208. Similarly, FIFA World Cup soccer games in knock-out rounds had different rules
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`for regular time, extra time, and penalty kicks.27 Likewise, Olympic hockey had 5-v-5 regular
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`time, 4-v-4 overtime, and shoot-out terms.28
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`209. Similarly, baseball may go into additional innings when there is a tie score at the
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`end of the allotted nine innings, however, the conditions for winning in additional innings differ
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`from the regular allotted innings, such that the game ends immediately if the home team gets
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`ahead, even if there have not yet been three outs. Likewise, in hockey and soccer, a tie at the end
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`26 http://static.nfl.com/static/content/public/image/rulebook/pdfs/2013%20-%20Rule%20Book.pdf
`27 https://www.fifa.com/worldcup/news/golden-goal-rule-applied-for-thefirst-
`time-the-world-cup-finals-71652
`28 http://www.nhl.com/ice/m_news.htm?id=513766
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`of an overtime period for a match results in a shootout, with players from each team alternatingly
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`taking penalty shots against the opposing team’s goalie to determine a winner of the game.
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`210. Similarly, boardgames such as Trivial Pursuit features regular game play,
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`followed by changed conditions once a player obtains their final wedge needed, in which instead
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`of selecting their own category of question, the other players select it for that player. Likewise,
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`in Pictionary and Charades, players proceed with a first set of conditions or rules initially during
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`a limited time, and once that expires, the next round of play begins, such as moving to a new
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`phase or a new player’s turn. These examples all show that games with timing aspects (“terms”),
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`and differing rules or conditions for the different terms, have existed in the physical or manual
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`game space long before the effective filing date of the ’177 and ’362 patents. Because the ’177
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`and ’362 patents claim mere automation of such mental or physical processes, it is my opinion
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`that the claimed concept of managing a game on a computer by setting a different battle
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`condition for at least one of multiple terms of a battle game is abstract.
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`211. While using a computer to set a different battle condition for at least one of
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`multiple terms of a battle game may increase how quickly players can move between the terms
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`of a game, the increase in speed is irrelevant. It is my understanding that adding incidental
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`computer functionality to increase the speed or efficiency of a manual process does not confer
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`patent eligibility on an otherwise abstract idea.
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`212. Additionally, the claims recite nothing more than specific game limitations or
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`game rules for managing a game on a computer. For example, each of the independent claims of
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`the ’177 patent recites a battle game control method, system, or computer readable medium for
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`“displaying, on a first field, a plurality of cards selected from a deck which is a stack of virtual
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`cards.” “conducting a battle to a first opponent character … under a first battle condition,”
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`“automatically initiating a second term of the battle game, and during the second term of the
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`battle game continued from the first term, conducting the battle … under a second battle
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`condition,” and “during a third term of the battle game continued from the second term,
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`conducting the battle … under a third battle condition.”29 Similarly, each of the independent
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`claims of the ’362 patent also require similar limitations: “displaying a game screen comprising a
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`first field …, wherein in the first field, a plurality of cards selected from a deck which is a stack
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`of virtual cards are arranged in a horizontal direction,” “during a first term of the battle game, in
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`the second field, under a first battle condition, conducting a battle against a first-term opponent
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`character …, and concluding the first term of the battle game at a predefined end timing based on
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`a start timing of the battle game,” and “starting a second term of the battle game at a predefined
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`start timing based on the start timing of the battle game, and during the second term after the first
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`term, in the second field, under a second battle condition which is different from the first battle
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`condition, conducting a battle against a second-term opponent character …, and concluding the
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`second term of the battle game at a second predefined end timing based on the start timing of the
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`battle game.” All of these limitations are nothing more than steps for managing a game, or game
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`rules, on a general-purpose computer.
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`213. As noted above, the claims are directed to subject matter that is far broader than
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`the disclosure of the specification. The claims do not require subdivided time slots or group
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`battles, and most claims do not require multiple players or player characters. However, the
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`claims all recite different rules or “battle conditions” for different “terms” of the battle.
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`214.
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`I am informed that the Federal Circuit has previously held that patent claims
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`directed to rules of a game are a type of “organizing human activity” and are therefore abstract. I
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`29 Claims 8 and 16 lack recitation of the third term, and claims 16 and 17 recite systems
`programmed to “display,” rather than reciting displaying.
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`am independently aware30 of court decisions relating to prior games including bingo (Planet
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`Bingo, LLC v. VKGS LLC), blackjack (In re Smith), and dice games (In re Marco Guldenaar
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`Holding B.V.), all of which held that rules for playing games are abstract ideas. For example, in
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`In re Smith¸ claims were directed to a variation of blackjack. “The examiner concluded that the
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`claims represented ‘an attempt to claim a new set of rules for playing a card game,’ which
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`‘qualifies as an abstract idea.’ J.A. 102.” In re Smith, 815 F.3d 816, 818 (Fed. Cir. 2016). The
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`court agreed, holding that “the rejected claims, describing a set of rules for a game, are drawn to
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`an abstract idea.” Id. at 819.
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`215. All of the asserted claims in the ’177 and ’362 patents are directed to rules for
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`playing a card game, specifically a card game in which a player selects a card and conducts a
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`battle against an opponent character, and there are different “battle conditions” for different
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`“terms of the battle game.” The applicant explicitly stated during prosecution that “the claimed
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`invention concerns operating the battle game under a specific set of rules” and “the claimed
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`invention also includes a specific set of rules for operating a game which, when viewed as a
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`whole, promote active participation of players with a wide range of levels and enjoyment
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`throughout a group battle.” ’177 prosecution history at 6/19/2018 Response to Office Action p.
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`10-11, emphasis in original.
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`216. Moreover, managing a game is an activity that can be performed by a human, and
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`any person can manage and play a game. Indeed, the physical and mental activities of playing
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`and managing a game based on select games rules occurs regularly amongst groups of people on
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`a daily basis. Such examples include groups of people participating in team sports (e.g.,
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`basketball, soccer, football, etc.) and playing board games by satisfying the objectives and rules
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`30 That is, I was not first informed of these decisions by counsel in this case.
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`of the game. The specification describes a “group vs. group” battle game that is conceptionally
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`no different than groups of real-world people playing a competitive game together, such as
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`participating in team sports like dodge ball, kick ball, soccer or baseball, or playing board games.
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`Thus, the claims are directed to nothing more than managing relationships or transactions
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`between people, social activities, and the human behavior of playing a game.
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`217. Moreover, the claims are not even limited to “group vs. group” battle games, and
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`the intended solution to the problem of uneven participation in a “group battle” game is not
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`present in games that are not group battles. The specification states that “embodiments of the
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`present disclosure have been conceived in light of” the circumstances that (a) the participation
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`rate of group members in a time slot group battle tends to increase in the last half of the time slot,
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`and (b) beginners may be unsuccessful in time slot group battles against experienced players
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`because the beginners do not understand effective attacks. However, the scope of the claims is
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`not limited to games in which those problems are known to exist (or even can exist). For
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`instance, the problem of uneven “participation rate of group members in a time slot group battle”
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`does not exist in a game in which only one player is competing against another, such as boxing.
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`One might envision a beginner soccer player on a team just standing still, not participating in the
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`game while his or her more-experienced teammates run past, but it is not plausible that a fighter
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`in a boxing match would similarly not participate.
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`218. According to my understanding of the claim language, the ’177 and ’362 patents’
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`claims do nothing more than recite a few broadly claimed result-oriented functions: setting a
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`different battle condition for at least one of multiple terms of a battle game, and without any
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`particular mechanism for achieving these functions.
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`219. Therefore, in my opinion, the asserted claims are directed to an abstract idea.
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`B.
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`The Asserted Claims of the ’177 and ’362 Patents Add Nothing Inventive
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`220.
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`It is also my opinion that the asserted claims add nothing inventive. The asserted
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`claims recite only conventional and functional technology components incidental to implementing
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`the claimed game rules. The claims of the ’177 and ’362 patents recite only conventional and
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`functional components incidental to implementing the abstract idea of managing a game on a
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`computer by setting a different battle condition for at least one of multiple terms of a battle game.
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`Therefore, in my opinion, the claims are not inventive.
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`221. The patentee acknowledged the existence of prior computer games in which a
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`player selects a card and conducts a battle against an opponent character. The specification is
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`expressly intended to improve prior art “time slot group battle” games. The patents do not
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`introduce any new technology components to accomplish this improvement to prior games.
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`Rather, the specification teaches that the embodiments are performed with “general-purpose”
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`computer technology. ’177 patent at 3:55-60, 4:14-51.
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`222. The ’177 and ’362 patents require nothing more than generic server components
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`that store data and process operations of the game on a generic computer. The specification
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`explains that the claimed concepts can be performed on generic computing technology, and the
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`claims recite only generic computing components. The specification notes that both the server
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`and client devices “may be configured using a general-purpose communication terminal device.”
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`Id. at 3:58-60, 4:4-7 and ’362 patent at 3:65-67, 4:1-3. The specification notes that
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`“[f]urthermore, the general-purpose communication terminal device constituting the server
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`device 10 or the client device 30 also refers to a desktop computer, a notebook computer, a tablet
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`computer, a laptop computer, and a mobile phone.” ’177 patent at 4:17-20 and ’362 patent at
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`4:14-17. The claims recite only a “game screen,” “game apparatus,” and “computer readable
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`medium.” However, these are generic components that do no more than implement the abstract
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`idea on a computer, or use the computer as a tool to perform an abstract idea. In my opinion,
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`these generic components do not transform the claim into a patent-eligible practical application
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`of the abstract idea.
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`223.
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`In my opinion, the challenged claims are not directed to an improvement in
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`computer technology. Neither the claims nor the specification describe any new technology or
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`process, nor do they describe any improvement to known or existing technologies.
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`224.
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`Instead, the ’177 and ’362 patents describe a concept which may allow player to
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`actively participate in a battle for an entire time period using conventional computer functions
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`and well-known concepts. There is no technology described in the specification or recited in the
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`claims that improves computer functionality. Accordingly, the ’177 and ’362 patents do not
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`address a technical problem or provide a technology-based solution.
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`225. The claims also are not directed to solving a technological problem or challenge
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`particular to computing or the Internet. The only function the system needs to perform to carry
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`out the claimed process is to execute software routines programmed to implement the particular
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`game play rules, e.g., by initiating terms and conducting battles. Computers have always
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`performed the function of executing software routines that implement game play rules since the
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`first computer games were written over 50 years ago.
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`226. Without reciting any technologically novel concepts, the ’177 and ’362 patents
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`claim the generic computer steps of “displaying” a stack of virtual cards and “conducting” battle
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`terms according to various battle term conditions, all on generic computer components. All of
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`these functions are well-known processes that computers are known to perform, and were readily
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`available in games well before the earliest effective priority date, and in my opinion are neither
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`novel nor inventive. Indeed, as I describe in great detail throughout this report, such steps were all
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`well-known concepts in video games well before the priority date of the ’177 and ’362 patents, and
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`reflects a generic function of computers – to process information. Thus, the claimed limitations
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`require nothing more than generic computing components to perform game management steps that
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`are well-known and conventional and do not add anything inventive to the claims.
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`227. Further, the ‘177 and ’362 patents recite rule-based claim elements. The
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`’177 patent recites “displaying, on a first field, a plurality of cards selected from a deck which is
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`a stack of virtual cards.” “conducting a battle to a first opponent character … under a first battle
`
`condition,” “automatically initiating a second term of the battle game, and during the second
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`term of the battle game continued from the first term, conducting the battle … under a second
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`battle condition,” and “during a third term of the battle game continued from the second term,
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`conducting the battle … under a third battle condition.” Similarly, the ’362 patent recites
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`“displaying a game screen comprising a first field …, wherein in the first field, a plurality of
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`cards selected from a deck which is a stack of virtual cards are arranged in a horizontal
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`direction,” “during a first term of the battle game, in the second field, under a first battle
`
`condition, conducting a battle against a first-term opponent character …, and concluding the first
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`term of the battle game at a predefined end timing based on a start timing of the battle game,”
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`and “starting a second term of the battle game at a predefined start timing based on the start
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`timing of the battle game, and during the second term after the first term, in the second field,
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`under a second battle condition which is different from the first battle condition, conducting a
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`battle against a second-term opponent character …, and concluding the second term of the battle
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`game at a second predefined end timing based on the start timing of the battle game.” All of
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`these limitations are nothing more than steps for managing a game, or game rules, on a general-
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`purpose computer.
`
`228. As explained throughout this report, the use of rules for providing rewards in a
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`game – including in video games – was well-known, routine, and conventional long before the
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`earliest possible priority date of the ‘177 and ’362 patents. Providing rules for the provision of
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`virtual assets, including rewards, points, or experience, that users work to obtain in the game is a
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`fundamental aspect of games. Many 1980s-era arcade games had high score lists measured in
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`points that were achieved by defeating aliens or monsters (or ghosts or space boulders). As
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`discussed herein, game shows such as Jeopardy is divided into three periods, with different rules
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`for each period. Well-known board games such as Trivial Pursuit, have different rounds with
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`different rules. In card tournaments, such as Euchre or poker, multiple rounds are played, in
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`which the winner of each round of play advances to a new “table” to play against new opponents.
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`Even team sports such as football, soccer, baseball and hockey have different rules for overtime
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`play. Likewise, video battle games, such as Wartune,31 Arena of Heroes,32 Bloodline Champions
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`(MMOHuts),33 each use similar concepts.
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`229. For example, in Wartune, game play is organized into time periods using a time,
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`and the rules change when a different time period begins. A person of skill in the art would
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`appreciate that the notion of having rules for providing virtual assets was not only well-known,
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`routine, and conventional, but also commonsensical.
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`230. The technique of specifically changing conditions to provide beginner players an
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`advantage was also well-understood, routine, and conventional. As noted above, handicapping
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`beginner players to encourage participation or improve game balance is a well-known aspect of
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`many games and sports, and Supercell itself incorporated a form of beginner handicapping in
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`Clash of Clans prior to the priority date of the asserted patents.
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`31 https://www.youtube.com/watch?v=8AmJJ6SdPqs
`32 https://www.youtube.com/watch?v=6mzqKZGbSHA
`33 https://www.youtube.com/watch?v=3vu70sWL2pA
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`231. Further, the patentee acknowledges that the benefit of the claimed set of rules is
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`not related to any improvement in computer technology but rather “when viewed as a whole,
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`promote[s] active participation of players with a wide range of levels and enjoyment throughout
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`a group battle.” ’177 prosecution history at 6/19/2018 Response to Office Action p. 11.
`
`232.
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`In short, the purported invention relies on using known technologies to modify a
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`known game type using known game balancing techniques. Therefore, in my opinion, the claims
`
`do not add anything inventive to the claimed abstract idea.
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`233. Moreover, the dependent claims further recited limitations that were well-known,
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`routine, and conventional before the earliest possible priority date of the ’177 and ’362 patents.
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`Dependent claims 2 and 9 of the ’177 patent and dependent claims 4 and 9 of the ’362 patent
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`specify that various battle conditions are for providing a reward to the player (e.g., “wherein the
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`third battle condition is a condition for providing a reward to the player,” ’177 patent at 13:33-35
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`(claim 2)), which is merely a more detailed description of the battle rules, and thus does not
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`contribute to patent eligibility.
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`234. Similarly, dependent claims 3 and 10 of the ’177 patent and dependent claims 7,
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`8, 15, 16, 23, and 24 of the ’362 patent recite various further battle condition limit details, or
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`further rules (e.g., “wherein a start timing and an end timing of each of the first term and the
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`second term are predetermined using a start timing of the battle game as a reference,” ’177 patent
`
`at 13:36-40 (claim 3)), which do not contribute to patent eligibility.
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`235. Dependent claims 4, 5, 11, and 12 of the ’177 patent and dependent claims 5, 6,
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`17, 18, and 25 of the ’362 patent add detail regarding “attack strength” and/or “life force”
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`(e.g., wherein an attack strength to the opponent character under the second battle condition is
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`higher than an attack strength to the opponent character under the first battle condition,”
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`81
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`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 14 of 250
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`’177 patent at 13:41-45 (claim 4)). This is another modification of a game rule that does not
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`contribute to patent eligibility.
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`236. Finally, dependent claims 6, 7, and 13 of the ’177 patent and dependent claim 10
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`of the ’362 patent add visual aspects of the display (e.g., “wherein the first field and the second
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`field are included in a game screen,” ’177 patent at 14:32-34 (claim 13) and “maintaining an
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`interface gauge element during the battle game; and dynamically adjusting the interface gauge
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`element,” ’362 patent at 13:66-14:1 (claim 10)), but says nothing about what the element looks
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`like, what it does, or where it is located. In my opinion, such generic visual elements are simply
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`generic visual displays that would have been well-understood, routine, and conventional before
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`the earliest priority date of the asserted patents.
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`237. Nor do any of the ordered combination of these claim limitations in the ’177 and
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`’362 patents transform the claims into a patent-eligible application of the concept of managing
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`and playing games. Each of the claim limitations is limited to generic computer components and
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`well-known game concepts, and the claims as a whole merely recite well-known requirements
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`for managing a game on a computer by setting a different battle condition for at least one of
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`multiple terms of a battle game, which were already known before the earliest effective filing
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`date for both the ’177 and ’362 patents. The claims also do not improve the functionality of a
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`computer or video games, and instead, are directed to the abstract idea of managing a game on a
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`computer by setting a different battle condition for at least one of multiple terms of a battle
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`game, concepts which were well known before the earliest effective filing date for both the ’177
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`and ’362 patents.
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`238. The above additional limitations merely recite steps that can be performed
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`mentally, using pen and paper, or manually with game pieces, and thus add nothing inventive.
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`Even in the context of computerized games, the mere recitation of additional conditions, without
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`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 15 of 250
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`any description of how to implement those conditions, and carried out by generic computer
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`components, do not add to the patent eligibility analysis in my opinion.
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`IX.
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`THE ASSERTED CLAIMS OF THE ’177 AND ’362 PATENTS ARE INVALID
`FOR LACKING WRITTEN DESCRIPTION
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`A.
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`The Asserted Claims of the ’177 Patent Fail to Meet the Written Description
`Requirement
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`239. The specification of the asserted patents discloses that it is directed to solving
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`particular problems with “time slot group battles,” namely that players do not actively participate
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`“throughout the entire time set for the group battle” and that “beginners may [] be unsuccessful”
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`because “a battle may be fought with opponents having vastly dissimilar attack strengths.”
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`’177 patent at 1:66-2:29. The specification states that “beginners may end up passively
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`participating in a group battle. Under these circumstances, is therefore preferable to provide a
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`game that allows players with a wide range of levels to enjoy a time slot group battle without
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`regard for level.” Id. at 2:30-34. The specification further states, “Embodiments of the present
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`disclosure have been conceived in light of these circumstances and provides a game control
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`method, a system, and a non-transitory computer-readable recording medium that allow a wide
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`range of players to enjoy a group battle without regard for difference in level, degree of attack
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`strength, or the like and that, in a group battle limited to a time slot, improve the participation
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`rate throughout the set time slot.” Id. at 2:35-42. The specification further states “circumstances
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`that allow beginners to enjoy the battle can be created by setting the battle conditions to increase
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`the attack strength of low-level characters, which correspond to beginners, and to favor
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`beginners to the game in the first portion of the battle in which the participation rate in the battle
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`is not very high.” Id. at 12:7-12. Thus, a POSITA would understand that the described
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`invention is specifically directed to solving the stated problems (lack of