PTAB

IPR2016-00634

Electronic Arts Inc v. White Knuckle Gaming LLC

Title: Method And System For Increased Realism In Video Games
Brief Description: The ’575 patent discloses systems and methods for enhancing realism in sports video games. It addresses the problem of game parameters being fixed at the time of production, which quickly become outdated. The invention connects a video game machine to a remote data server via a network to download and store updated parameters, such as character performance statistics and visual attributes, to reflect the real-time performance and changing conditions of real-life athletes and teams during a sports season.

Prior Art Relied Upon: Madden 2000 Manual, Madden 2000 Card, Madden 2000 Updates, Playoff Week 1 Update, and Super Bowl Update (collectively, "Madden References").
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the Madden References, which describe the commercially available Madden NFL 2000 video game, taught a complete system for updating game characters. The game included characters with specific performance parameters (e.g., throwing accuracy, speed). The Madden 2000 Updates website, accessible via the internet, functioned as a data server offering downloadable updates throughout the 2000 NFL season. These updates contained "adjusted rosters and player abilities" based on the actual on-field performance of NFL athletes during playoff games. Users could download these updates to their PC (the video game machine) and load them into the game, which would change character performance to more closely simulate their real-life counterparts' current abilities.
- Motivation to Combine: The references were all official documentation and software updates for a single product, intended by their publisher to be used together to provide the full, intended user experience.
- Expectation of Success: Because these features were part of a functioning, commercially successful product, a person of ordinary skill in the art (POSA) would have had a very high and certain expectation of success.

Prior Art Relied Upon: The Madden References and FIFA 2001 News (a collection of archived web pages for the FIFA 2001 video game).
Core Argument for this Ground:
- Prior Art Mapping: This ground was asserted against dependent claims requiring updates to visual aspects, automatic downloading, and application to soccer games. Petitioner contended that FIFA 2001 News explicitly taught updating visual game parameters to reflect real-life changes during a season, such as adding new sponsor logos to player jerseys, altering stadium advertising boards, and changing the appearance of field turf. Furthermore, FIFA 2001 News disclosed an architecture where the game could "automatically connect" to a server to download and install these updates, teaching the automatic functionality recited in claim 7.
- Motivation to Combine: A POSA would combine the known visual and automatic update features from a similar sports game (FIFA) with another (Madden) to enhance realism and improve user convenience. This was presented as a predictable design choice driven by market demand for more immersive and up-to-date gaming experiences, with no technological barrier to applying the same update mechanism to different types of parameters or sports.

Prior Art Relied Upon: Swanberg (Application # 2002/0155893).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Swanberg alone rendered many claims obvious by disclosing a complete, analogous system. Swanberg described an electronic trading card game where a physical smart card stored player statistics. A user's local computer could connect to a remote game server via the internet to download updated statistics for the card. These updates were made on a "regular, frequent basis" to reflect the current, actual performance of real-life athletes. When playing the game, the in-game character's performance was dictated by these updated stats. This system of a remote server updating local game data based on real-world athletic events during a season taught the core inventive concept of the ’575 patent.
Additional Grounds: Petitioner asserted an additional obviousness challenge over Swanberg in view of Hines (Application # 2003/0234787). This ground targeted claims specific to basketball games and statistics (e.g., claims 13, 18-20, 32-35) by arguing a POSA would predictably combine Swanberg's general updating framework with the specific real-time basketball statistics (e.g., points scored, free-throws, rebounds) disclosed by Hines to create a realistic basketball simulation.

Petitioner proposed a specific construction for the term "the at least weekly transmissions" as recited in claims 24 and 25. For claim 25, which also recites that "updated transmissions are carried out at least daily," Petitioner argued that the only available antecedent basis for the phrase was the "daily" transmissions. Consequently, Petitioner contended that in the context of claim 25, "the at least weekly transmissions" should be construed to mean "the at least daily transmissions" to resolve the ambiguity.

Petitioner requested the institution of an inter partes review for claims 1-35 of the ’575 patent and the subsequent cancellation of all challenged claims as unpatentable under 35 U.S.C. §103.