PTAB
IPR2021-00501
Supercell Oy v. GREE Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2021-00501
- Patent #: 10,369,464
- Filed: February 5, 2021
- Petitioner(s): Supercell Oy
- Patent Owner(s): Gree, Inc.
- Challenged Claims: 1-10
2. Patent Overview
- Title: Game Control Method, Server Device, Game System, And Computer-Readable Recording Medium
- Brief Description: The ’464 patent describes a system for managing players in online team battle games. The disclosed method involves disbanding a team determined to be inactive, acknowledging players from that team as waiting for a new team based on their activity status, and creating a new team when certain conditions are met.
3. Grounds for Unpatentability
Ground 1: Obviousness over Core MOBA References - Claims 1-10 are obvious over Lin in view of LoL Game Info and Dota 2 Guide.
- Prior Art Relied Upon: Lin (Application # 2014/0025732), LoL Game Info (archived website information for the game League of Legends), and Dota 2 Guide (a community guide for the game Dota 2).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the combination of references taught all steps of the challenged independent claims. Lin described a user matching system for a Multiplayer Online Battle Arena (MOBA) game and explicitly identified League of Legends (LoL) as its exemplary system, directing a reader to the official LoL website. The LoL Game Info reference, from that website, allegedly disclosed the core claimed functionality. Petitioner asserted that after a game of LoL ends (win or loss), the system automatically disbands the match-made teams, meeting the “disbanding” step. A player wishing to play again must re-enter a matchmaking queue. At this point, the server “acknowledges” the player as a “formation wait player” based on their “activity status,” which in LoL corresponds to a skill-based Elo rating that reflects past performance. Finally, the server “creates” a new group once a “setting condition” is met, which occurs when the matchmaking system finds a sufficient number of players with a similar skill rating (e.g., five per team) to form a competitive match. The Dota 2 Guide was presented as additional evidence that these team formation and lifecycle mechanics were conventional and well-known in the art.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSA), guided by Lin’s express reference to LoL, would combine its teachings with the detailed implementation information available in the LoL Game Info reference from the official website. The motivation would be to build a functional and commercially successful MOBA game by employing the established, proven techniques used by the genre’s most popular titles.
- Expectation of Success: Petitioner contended that a POSA would have a high expectation of success because the combination involved implementing features already proven to work effectively and at a large scale in widely popular online games like LoL and Dota 2.
Ground 2: Obviousness over the Primary Combination and Additional Art for Inactivity Definitions - Claims 1-10 are obvious over Lin and LoL Game Info, further in view of Dota 2 Guide, LoL Patch 3.5 Notes, and/or Win/Loss/Abandon Feedback.
- Prior Art Relied Upon: The primary combination from Ground 1, supplemented with LoL Patch 3.5 Notes (official game patch notes) and Win/Loss/Abandon Feedback (a Dota 2 developer forum entry).
- Core Argument for this Ground:
- Prior Art Mapping: This ground focused on broader interpretations of the claimed “inactive state” limitation, arguing it encompassed player inactivity before a game concludes. The LoL Patch 3.5 Notes disclosed an “AFK Detection” feature where a team was determined to be inactive and was disbanded if a player failed to select a character during the pre-game “Champion Select” phase. This prevented matches from starting with a shorthanded team. Similarly, the Win/Loss/Abandon Feedback forum entry for Dota 2 described that a player was deemed to have abandoned a game (rendering their team inactive) if they were disconnected for more than five minutes. Petitioner asserted these scenarios met the limitation of “disbanding...a group determined to be in an inactive state.” This argument also addressed dependent claims; for instance, a player who is AFK or abandons a game is often penalized with a temporary matchmaking cooldown. In this state, the server compares the player's activity status (bad behavior) and determines not to acknowledge them as a formation wait player, thereby teaching the limitations of claim 3.
- Motivation to Combine: A POSA would combine these features to solve the well-known and highly frustrating problem of AFK players (“leavers”) ruining the game experience for others. Implementing an automated system to detect such inactivity and fairly resolve the match was a known solution to improve player satisfaction and retention, making its inclusion a logical and desirable design choice.
- Expectation of Success: The expectation of success was high, as these AFK-detection and abandonment penalty systems were publicly announced and successfully implemented by the developers of LoL and Dota 2 to address direct and widespread community feedback on these exact issues.
4. Relief Requested
- Petitioner requested the institution of an inter partes review and the cancellation of claims 1-10 of Patent 10,369,464 as unpatentable.
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