FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 1 of 97 * PUBLIC *; 

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UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation; 

Docket No. 9412 

and 

Activision Blizzard, Inc. 

a corporation. 

RESPONDENT MICROSOFT CORP.’S OPPOSITION TO NON-PARTY SONY 

INTERACTIVE ENTERTAINMENT LLC’S MOTION TO QUASH OR LIMIT 

SUBPOENA DUCES TECUM 

Sony Interactive Entertainment LLC (“SIE”) is at the heart of this case. SIE has unleashed its 

executives and high-priced economists to petition the Commission, as well as regulators around the 

world, to block the transaction. At minimum, SIE has: (1) submitted advocacy opposing the deal, 

; (2) sent its executives, 

, to make presentations to regulators; (3) 

; and (4) hired economists to develop qualitative and 

quantitative analyses and . 

SIE’s campaign has worked. The Commission’s theory of harm relies almost exclusively on 

the facially implausible claim that the acquisition is anticompetitive because Respondent Microsoft 

Corp. (“Microsoft”) will withhold from SIE a single game (Call of Duty) produced by Respondent 

Activision Blizzard King (“Activision”). Compl. ¶ 1. Indeed, the Commission’s Complaint 

references SIE and its products more than sixty times, and describes SIE as Microsoft’s only 

competitor in a gerrymandered “High-Performance Console” market. Id. ¶¶ 1–2, 28, 63–72. 

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Despite leading the charge to stop the transaction, SIE claims it should not be required to 

produce documents on the very topics it has put at issue. SIE has submitted a declaration asserting 

that 

Ex. A ¶¶ 24, 33. Yet SIE will not produce documents from Lin Tao, SIE’s 

Chief Financial Officer, so that Microsoft can test . SIE likewise 

refuses to produce documents from Hideaki Nishino, Senior Vice President of Platform Experience, 

who oversees SIE’s hardware business, even though SIE asserts that 

Ex. A ¶ 37. 

And SIE will not agree to produce a single document from its Senior Director of Competition and 

Regulatory Affairs, Greg McCurdy, 

. 

SIE does not contest these custodians’ relevance, resting instead on assertions of burden. 

Given SIE’s central role, that purported burden does not warrant a motion to quash. SIE is not just 

any other third party; it is a first party among third parties. Nonetheless, Microsoft has attempted to 

assuage SIE’s concerns. Microsoft has allowed SIE to use Technology Assisted Review (“TAR”), 

which means that SIE does not need to manually review most documents for responsiveness. And 

Microsoft has made compromises to decrease SIE’s privilege review, such as limiting the McCurdy 

review to external communications. 

Several weeks have passed since Microsoft served the Subpoena on January 12, 2023, at the 

start of discovery. Any claim that SIE is unable to produce documents in a timely manner is a problem 

of SIE’s own making. SIE’s motion to quash should be denied, and SIE should be required to produce 

all non-privileged, responsive documents by March 13, 2023, to leave time for depositions before 

fact discovery closes on April 7, 2023. 

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ARGUMENT 

I. SIE should produce documents from the contested custodians 

A. Lin Tao and Hideaki Nishino 

There is no basis for SIE’s refusal to allow discovery of Tao and Nishino, both of whom 

possess information essential to issues SIE has introduced into this case. 

As CFO, Tao is the key custodian with information about SIE’s financial health and plans. 

Her documents are central to Respondents’ ability to test SIE’s assertions that 

. Ex. A ¶¶ 24, 33. They are also important to assess SIE’s 

economists’ assertions, including claims that: 

 Ex. B at 3, 4, 14, 20 (emphases added). 

Nishino is the head of SIE’s hardware business, another topic of central importance. Among 

other things, SIE asserts that the acquisition

 Ex. A ¶ 37; see also id. ¶ 11. 

SIE asserts in a single sentence that Microsoft reneged on its agreement to drop these 

custodians. Not so. Throughout negotiations, Microsoft made clear that (1) all thirteen of its initially 

proposed custodians are relevant, Ex. C; and (2) any agreement on custodians was contingent on SIE 

agreeing to other conditions, which SIE refused to accept, Ex. D. 

Rather than challenging these custodians’ relevance, SIE asserts that producing their 

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 SIE Ex. B ¶ 11 (emphasis added). Nor does SIE authority for its 

suggestion that the existence of foreign-language documents precludes discovery. 

documents would be unduly burdensome. But “[p]arties resisting discovery of relevant information 

carry a heavy burden of showing why discovery should be denied.” In re Polypore Int’l, 2008 FTC 

LEXIS 155, at *16 (Nov. 14, 2008); see also In re Phoebe Putney Health Sys., 2013 FTC LEXIS 82, 

at *11–12 (May 30, 2013) (applying Polypore requirement in third-party context, and denying motion 

to quash); In re Intel Corp., 2010 WL 2143904, at *2 (F.T.C. May 19, 2010) (same). SIE has failed 

to satisfy that requirement. SIE says nothing about the burden associated with Nishino. And while 

SIE claims that an “analysis of Ms. Tao’s documents revealed that a high percentage are in Japanese,” 

SIE Mot. at 6, that claim is unsupported by any evidence. Indeed, the supporting declaration cited by 

SIE

B. Greg McCurdy 

E.g., Ex. E; Ex. F. 

SIE Ex. F ¶¶ 3–5. 

By definition, most, if not all, of those communications are not privileged. 

Rather than addressing relevance, SIE relies on blanket assertions of privilege and the 

purported burden of reviewing McCurdy’s files because he is a lawyer. But, according to his job 

posting, McCurdy is also responsible for SIE’s public policy engagement. Ex. G (“Partnering with 

SIE Government Affairs on SIE’s public policy initiatives with respect to competition and other 

regulatory issues”). Being an attorney does not immunize McCurdy from discovery, especially when 

he is also acting in a public policy role. See In re Rail Freight Fuel Surcharge Antitrust Litig., 2009 

WL 3443563, at *9–10 (D.D.C. Oct. 23, 2009) (requiring production of in-house attorney’s 

4 
 

 

 

 

 

 

 

 

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documents). And SIE has failed to make a specific showing why each of the withheld 

communications is privileged. 

SIE’s burden arguments ring particularly hollow given Microsoft’s agreement to limit review 

of McCurdy’s files to external communications. In Forth v. Walgreen Co., the plaintiff sought to 

compel a third-party to produce documents from an in-house attorney. 2020 WL 4569501 (D.R.I. 

Aug. 7, 2020). In granting that motion, the Court explained that “[t]he usual burden of combing the 

production set for privilege is largely eliminated by [p]laintiffs’ agreement to add search terms . . . so 

that only third-party communications . . . will be turned up by the searches.” Id. at *3; see also Le v. 

Zuffa, LLC, No. 2:15-cv-01045 (D. Nev. Dec. 8, 2015) (ECF 207) (burden of privilege review limited 

by search methodology). The same is true here. 

C. Predecessor Custodians 

As is customary, Microsoft asks that SIE produce documents from custodial predecessors 

where custodians have not been in their roles for the entire relevant time period. In response, SIE 

speculates that other custodians provide adequate coverage for the missing predecessors because 

some of those other custodians supervised, or reported to, the predecessors. But there is no reason to 

assume that a supervisor, who covers a significantly broader portfolio, will have identical documents 

to her subordinates. SIE, for example, has refused to provide a predecessor custodian for Christian 

Svensson, who manages SIE’s relationship with Activision, even though Svensson has only been in 

his position since 2021. That relationship is of the upmost importance here, and SIE has not supported 

its assertion that Svensson’s manager would have the same documents as Svensson’s predecessor. 

II. SIE’s motion to quash several individual requests should be denied 

A. Requests 22–25, 28–29 

These Requests all seek data, not documents, about the performance of SIE’s gaming 

business. This data is essential to testing SIE’s claim that the acquisition . 

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See supra Part I.A. SIE’s only objection to these requests is the proposed timeframe of 2012 through 

the last full month prior to the production of data. SIE Mot. at 7. But SIE has not explained why 

pulling and producing data from its central files, without any need for responsiveness or privilege 

review, would be unduly burdensome. SIE should produce the requested data. 

B. Requests 14(d) and 19 

Requests 14(d) and 19 are in dispute only to the extent that Microsoft seeks a targeted pull of 

specific documents—valuations, board documents, and regulatory submissions—related to SIE’s 

cloud-gaming acquisitions of Gaikai in 2012 and OnLive in 2015. Ex. H; Ex. I. Cloud gaming 

allows gamers to stream games without downloading the games to a device. The Commission alleges 

that cloud-gaming services comprise a relevant market and Microsoft will foreclose cloud-streaming 

services from licensing Activision’s content. Compl. ¶¶ 83–91, 98. Providing targeted information 

about SIE’s own cloud-gaming efforts is relevant to assessing the viability of that claim and is not 

unduly burdensome. 

C. Request 3 

Microsoft seeks drafts of that . SIE claims, without support, that there 

are no non-privileged drafts. Mot. at 8. That is not a proper way to raise privilege. SIE must produce 

responsive, non-privileged information and provide a log. 

D. Request 13 

Microsoft seeks performance reviews for SIE custodians, where such reviews are otherwise 

responsive to the Subpoena. Ex. J. Contrary to SIE’s assertions, Microsoft is not seeking to 

embarrass SIE’s leadership; it seeks to understand the metrics on which SIE’s executives and business 

are evaluated. 

The cases SIE cites do not hold that performance reviews are immune from production. 

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Instead, they show this question turns on fact-specific relevance analyses, and the decisions go both 

ways. See, e.g., Harris v. Bechtel Marine Propulsion Corp., 2022 WL 3754736, at *4 (D. Idaho Aug. 

30, 2022) (requiring production of personnel files). Given Microsoft’s limitation that it only seeks 

performance reviews containing information otherwise responsive to the Subpoena, SIE cannot claim 

the requested documents are irrelevant. 

E. Request 35 

Request 35 seeks executed copies of content-licensing agreements between SIE and thirdparty gaming publishers. 

These contracts are relevant. Among other things, Microsoft is aware that PlayStation 

requires many third-party publishers to agree to exclusivity provisions, including preventing the 

publishers from putting their games on Xbox’s multi-game subscription service. But Microsoft does 

not fully understand the extent of SIE’s arrangements or how they impact the industry’s 

competitiveness. Given exclusivity’s centrality to the Commission’s Complaint, see, e.g., Compl. 

¶¶ 9, 12, 51, 53, Microsoft needs this information for its defense. 

SIE claims this Request is unduly burdensome because 

. SIE Ex. E ¶ 4. 

Ex. K. SIE knows the names of its third-party publishers and can create 

keyword searches to isolate the relevant contracts. 

Finally, SIE notes these agreements contain sensitive business information. But “[t]he fact 

that discovery might result in the disclosure of sensitive competitive information is not a basis for 

denying such discovery” where there is a protective order. In re Lab. Corp. of Am., 2011 FTC LEXIS 

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22, at *5 (Feb. 17, 2011). 

III. SIE has buried additional unsupported motions to quash in its exhibits 

Buried in its voluminous 23-page Exhibit H, SIE asks the Court to quash several additional 

document requests. Not only is this an end-run around the Rules of Practice, 16 C.F.R. § 3.22(c), SIE 

has failed to provide support for the relief requested. That is enough to deny SIE’s requests, but 

Microsoft nonetheless addresses the most significant issues raised by SIE. 

A. Request 1 

SIE has not only made submissions to the Commission challenging this transaction; it has 

made submissions to regulators worldwide. Microsoft requests that SIE produce documents that SIE 

submitted to these regulatory authorities in connection with this transaction. SIE has refused, 

agreeing only to produce submissions to the European Commission and United Kingdom’s 

Competition and Markets Authority, based on claims of burden. But SIE has not explained why 

producing the materials it voluntarily submitted to regulators—a production requiring no custodial 

searches and no privilege review—is disproportionately burdensome. 

B. Request 7 

Contrary to the allegation that Microsoft will make Call of Duty exclusive to Xbox, since 

announcing the deal, Microsoft has repeatedly offered to enter into an agreement to license Call of 

Duty to SIE—first for five years and then for ten, an unheard-of duration in the industry. SIE has 

refused. Microsoft seeks documents about these negotiations, including SIE’s internal consideration 

of Microsoft’s offers and why it has refused them. SIE again attempts to rely on unsupported and 

untestable privilege claims. SIE Ex. H at 11. That is insufficient for SIE to avoid discovery on this 

relevant topic. 

C. Request 14(f) 

This Request seeks information about SIE’s investment in virtual reality technology for its 

8 
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. See supra Part I.A. Nor can it refuse discovery based on commercial 

sensitivity where there is a protective order. In re Lab. Corp., 2011 FTC LEXIS 22, at *5. 

console, which SIE executives have highlighted as a strategic imperative and “a giant leap forward 

in the way we play games.” Ex. L at 6; see also Ex. M at 20. SIE asks the Court to quash this Request 

because the information it seeks is purportedly irrelevant and commercially sensitive. SIE is wrong. 

SIE cannot claim information about its hardware investments is irrelevant when 

CONCLUSION 

SIE’s motion should be denied, and SIE should produce the requested documents by March 

13, 2023. 

9 
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Dated: February 13, 2023 Respectfully submitted, 

By: /s/ Kieran Gostin 

Beth Wilkinson 

Rakesh N. Kilaru 

Kieran Gostin 

Grace L. Hill 

Anastasia M. Pastan 

Sarah E. Neuman 

Wilkinson Stekloff LLP 

2001 M Street NW, 10th Floor 

Washington, DC 20036 

Telephone: (202) 847-4000 

Fax: (202) 847-4005 

bwilkinson@wilkinsonstekloff.com 

rkilaru@wilkinsonstekloff.com 

kgostin@wilkinsonstekloff.com 

ghill@wilkinsonstekloff.com 

apastan@wilkinsonstekloff.com 

sneuman@wilkinsonstekloff.com 

Michael Moiseyev 

Megan A. Granger 

Weil Gotshal & Manges LLP 

2001 M Street NW 

Suite 600 

Washington, DC 20036 

(202) 682-7026 

michael.moiseyev@weil.com 

megan.granger@weil.com

 Counsel for Microsoft Corp. 

10 
 

 

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______________________________________ 

PUBLIC 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation; 

Docket No. 9412 

and 

Activision Blizzard, Inc. 

a corporation. 

[PROPOSED] ORDER DENYING SONY INTERACTIVE ENTERTAINMENT LLC’S 

MOTION TO QUASH OR LIMIT SUBPOENA DUCES TECUM 

Upon consideration of Non-Party Sony Interactive Entertainment LLC’s (“SIE’s”) 

Motion to Quash or Limit Respondent Microsoft’s Corp.’s (“Microsoft’s”) Subpoena duces 

tecum and Microsoft’s opposition thereto, it is HEREBY 

ORDERED that SIE’s motion is DENIED. SIE shall complete production in response to 

Microsoft’s Subpoena by March 13, 2023, with rolling productions to begin as soon as feasible. 

ORDERED: 

D. Michael Chappell 

Chief Administrative Law Judge 

Date: February ___, 2023 

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CERTIFICATE OF SERVICE 

I hereby certify that on February 13, 2023, I caused a true and correct copy of the 

foregoing to be filed electronically using the FTC’s E-Filing System and served the following 

via email: 

April Tabor 

Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm H-113 

Washington, DC 20580 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm H-110 

Washington, DC 20580 

I also certify that I caused the forgoing document to be served via email to: 

James H. Weingarten (jweingarten@ftc.gov) 

James Abell (jabell@ftc.gov) 

Cem Akleman (cakleman@ftc.gov) 

Taylor Alexander (talexander@ftc.gov) 

J. Alexander Ansaldo (jansaldo@ftc.gov) 

Peggy Bayer Femenella (pbayerfemenella@ftc.gov) 

Michael T. Blevins (mblevins@ftc.gov) 

Amanda L. Butler (abutler2@ftc.gov) 

Nicole Callan (ncallan@ftc.gov) 

Maria Cirincione (mcirincione@ftc.gov) 

Kassandra DiPietro (kdipietro@ftc.gov) 

Jennifer Fleury (jfleury@ftc.gov) 

Michael A. Franchak (mfranchak@ftc.gov) 

James Gossmann (jgossmann@ftc.gov) 

Ethan Gurwitz (egurwitz@ftc.gov) 

Meredith Levert (mlevert@ftc.gov) 

David E. Morris (dmorris1@ftc.gov) 

Merrick Pastore (mpastore@ftc.gov) 

Stephen Santulli (ssantulli@ftc.gov) 

Edmund Saw (esaw@ftc.gov) 

U.S. Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Washington, DC 20580 

Telephone: (202) 326-3570 

12 
 

 

 

 

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Counsel Supporting the Complaint 

D. Bruce Hoffman (bhoffman@cgsh.com) 

Leah Brannon (lbrannon@cgsh.com) 

Carl Lawrence Malm (lmalm@cgsh.com) 

Isabel Tuz (ituz@cgsh.com) 

Everett K. Coraor (ecoraor@cgsh.com) 

Cleary Gottlieb Steen & Hamilton LLP 

2112 Pennsylvania Avenue, N.W. 

Washington, D.C. 20037 

Telephone: (202) 974-1500 

Counsel for Non-Party Sony Interactive Entertainment LLC 

Steven C. Sunshine (steve.sunshine@skadden.com) 

Julia K. York (julia.york@skadden.com) 

Jessica R. Watters (jessica.watters@skadden.com) 

Skadden, Arps, Slate, Meagher & Flom LLP 

1440 New York Avenue, N.W. 

Washington, D.C. 20005 

Telephone: (202) 271-7860 

Maria A. Raptis (maria.raptis@skadden.com) 

Michael J. Sheerin (michael.sheerin@skadden.com) 

Matthew M. Martino (matthew.martino@skadden.com) 

Evan R. Kreiner (evan.kreiner@skadden.com 

Andrew D. Kabbes (andrew.kabbes@skadden.com) 

Bradley J. Pierson (bradley.pierson@skadden.com) 

Skadden, Arps, Slate, Meagher & Flom LLP 

One Manhattan West 

New York, NY 10001 

Telephone: (212) 735-2425 

Counsel for Activision Blizzard, Inc. 

/s/ Kieran Gostin 

Kieran Gostin 

Counsel for Microsoft Corp. 

13 
EXHIBIT A 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT A 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT B 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT B 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT C 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT C 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT D 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT D 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT E 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT E 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT F 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT F 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT G

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EXHIBIT *
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1/16/23, 12:19 PM Senior Director, Competition & Regulatory Affairs Job in Washington, DC at PlayStation Global | JobSearcher 

https://jobsearcher.com/j/senior-director-competition-regulatory-affairs-at-playstation-global-in-washington-dc-rvW8V97 1/5 

Senior Director, Competition & Regulatory Affairs 

PlayStation Global Washington, DC 

Starting at $250 

Show Short Description 

Stand out and contact PlayStation Global directly

Senior Director, Competition & Regulatory Counsel 

San Mateo, CA OR Washington, D.C. 

As Senior Director, Competition & Regulatory Counsel, you will be the primary competition and regulatory counsel for the Sony Interactive 

Entertainment (SIE) business worldwide. 

You will be responsible for leading SIE’s efforts to comply with competition laws globally and for managing and supervising regulatory investigations 

and proceedings worldwide, including interfacing with governmental and regulatory agencies on a broad range of issues, including competition, 

consumer protection, product safety, packaging, and labeling, and directing overall case and matter strategy. 

You will also be responsible for providing advice on competition laws to SIE business teams and training the business on regulatory requirements. 

You will report to the Vice President, Intellectual Property & Litigation and be a senior level member of SIE’s global legal leadership team. 

You will be expected to coordinate activities across SIE’s business, corporate and legal functions globally. 

The position will be based in San Mateo, California or Washington, DC. 

Providing legal guidance to executives across multiple areas of the SIE business on applicable competition laws and regulatory investigations and 

proceedings. 

Formulating and implementing appropriate internal processes to ensure global compliance with competition laws and regulatory obligations. 

Representing SIE’s interests before competition authorities and other regulatory agencies around the world. 

Selecting and managing outside counsel to represent SIE’s interests before regulatory agencies. 

Performing periodic risk assessments under competition laws for different areas of the SIE business. 

Providing in-person and virtual trainings to the business on competition laws and regulatory requirements. 

Partnering with SIE Government Affairs on SIE’s public policy initiatives with respect to competition and other regulatory issues. 

At least 15 years of experience as a practicing attorney primarily in the area of competition and other litigation and regulatory matters, preferably 

with a mix of in-house and outside counsel experience. 

Substantial experience in advising sophisticated companies regarding the activities of United States and foreign regulatory agencies, including 

advising on matters involving competition authorities. 

Substantial experience advising clients responding to subpoenas, CIDs, and interview requests from competition authorities and other regulatory 

agencies. 

A strong understanding of competition law and principles, and the ability to efØciently review, interpret, and analyze complex legal information. 

Outstanding oral, written, and interpersonal communication skills. 

Ability to work cross-functionally with multiple stakeholders, including legal, government affairs, PR, economists and business teams. 

Strong judgment and decision-making skills. 

Data driven mindset and ability to identify and recommend the best course of action even in ambiguous situations. 

A keen working understanding of policy-making processes and government relations. 

A global mindset with the demonstrated ability to work across geographic boundaries to implement worldwide business and policy strategies. 

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EXHIBIT H

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EXHIBIT +
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 27 of 97 * PUBLIC *; 

Sony Computer Entertainment to Acquire 

Gaikai Inc., a Leading Interactive Cloud 

Gaming Company 

SCE to Build a Cloud Service Bringing Gaikai's Cloud Based-Streaming 

Technologies into Its Network Business 

NEWS PROVIDED BY 

Sony Computer Entertainment 

Jul 02, 2012, 02:30 ET 

TOKYO, July 2, 2012 /PRNewswire/ -- Sony Computer Entertainment (SCE) today announced 

that it entered into a definitive agreement on June 30, 2012 (Japan Time) to acquire Gaikai 

Inc., the world's leading interactive cloud-based gaming company, for approximately USD 

380 million. Through the acquisition, SCE will establish a new cloud service, ensuring that it 

continues to provide users with truly innovative and immersive interactive entertainment 

experiences. 

"By combining Gaikai's resources including its technological strength and engineering talent 

with SCE's extensive game platform knowledge and experience, SCE will provide users with 

unparalleled cloud entertainment experiences," said Andrew House, President and Group 

CEO of Sony Computer Entertainment Inc. "SCE will deliver a world-class cloud-streaming 

service that allows users to instantly enjoy a broad array of content ranging from immersive 

core games with rich graphics to casual content anytime, anywhere on a variety of internetconnected devices." 

"SCE has built an incredible brand with PlayStation and has earned the respect of countless 

millions of gamers worldwide," said David Perry, CEO of Gaikai Inc. "We're honored to be able 

to help SCE rapidly harness the power of the interactive cloud and to continue to grow their
ecosystem, to empower developers with new capabilities, to dramatically improve the reach 

of exciting content and to bring breathtaking new experiences to users worldwide." 

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Established in 2008 and headquartered in Aliso Viejo, California, Gaikai has developed the 

highest quality, fastest interactive cloud-streaming platform in the world that enables the 

streaming of quality games to a wide variety of devices via the internet. With this acquisition, 

SCE will establish a cloud service and expand its network business by taking full advantage of 

Gaikai's revolutionary technology and infrastructure including data centers servicing dozens 

of countries and key partners around the world. 

The transaction is subject to certain regulatory approvals and customary closing conditions. 

SCE will continue to aggressively expand a new world of entertainment through the 

introduction of innovative technologies and the delivery of amazing experiences. 

About Sony Computer Entertainment Inc. 

Recognized as the global leader and company responsible for the progression of consumerbased computer entertainment, Sony Computer Entertainment Inc. (SCEI) manufactures, 

distributes, develop and markets the PlayStation®2 (PS2®) computer entertainment system, 

the PSP® (PlayStation®Portable) handheld entertainment system, the PlayStation®3 (PS3®) 

computer entertainment system and the PlayStation®Vita (PS Vita) portable entertainment 

system. SCEI has revolutionized home entertainment since they launched PlayStation in 

1994. PS2® further enhances the PlayStation legacy as the core of home networked 

entertainment. PSP® is a handheld entertainment system that allows users to enjoy 3D 

games with high-quality full-motion video and high-fidelity stereo audio. PS3® is an 

advanced computer system, incorporating the powerful Cell Broadband Engine and RSX 

processors. PS Vita is an ultimate portable entertainment system that offers a revolutionary 

combination of rich gaming and social connectivity within a real world context. SCEI also 

delivers the PlayStation® experience to open operating systems through PlayStation®Mobile, 

a cross device platform. Headquartered in Tokyo, Japan, SCEI, along with its affiliated 

companies, Sony Computer Entertainment America LLC., and Sony Computer Entertainment 

Europe Ltd., and its division companies, Sony Computer Entertainment Japan and Sony 


Computer Entertainment Asia develops, publishes, markets and distributes hardware and 

software, and manages the third party licensing programs for these platforms in the 

respective markets worldwide. 

PlayStation, PS3, PS2 and PSP are registered trademarks or trademarks of Sony Computer 

Entertainment Inc. 

All other trademarks are property of their respective owners. 

SOURCE Sony Computer Entertainment

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 29 of 97 * PUBLIC *; 

Computer Entertainment Asia develops, publishes, markets and distributes hardware and 

software, and manages the third party licensing programs for these platforms in the 

respective markets worldwide. 

PlayStation, PS3, PS2 and PSP are registered trademarks or trademarks of Sony Computer 

Entertainment Inc. 

All other trademarks are property of their respective owners. 

SOURCE Sony Computer Entertainment 


EXHIBIT I

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EXHIBIT ,
The Verge Menu - 

ENTERTAINMENT 

How Sony bought, and 

squandered, the future of gaming 

PlayStation Now had the keys to the cloud gaming kingdom, but Sony 

barely stuck a toe in the door 

By SEAN HOLLISTER 

Photography by VJERAN PAVIC 

Dec 5, 2019, 8:00 AM EST 

{1 O Comments 

y f @2

Menu

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Menu

ENTERTAINMENT

How Sony bought, and

squandered, the future of gaming

PlayStation Now had the keys to the cloud gaming kingdom, but Sony

barely stuck a toe in the door

By SEAN HOLLISTER

Photography by VJERAN PAVIC

Dec 5, 2019, 8:00 AM EST 

0 Comments 
part of / 

PlayStation 25th anniversary issue 

top me if you’ve heard this one before: a video game 

platform that lets you play games with the press of a button, 

no need for discs or downloads. Tap on a YouTube ad for a game, and you're instantly playing in your web browser. Experience 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 32 of 97 * PUBLIC *; 

part of /

PlayStation 25th anniversary issue

S top me if you’ve heard this one before: a video game

platform that lets you play games with the press of a button,

no need for discs or downloads. Tap on a YouTube ad for a

game, and you’re instantly playing in your web browser. Experience
greatest games on your ancient laptop, phone, or

, s to remote servers instead of having to buy a console or

the latest and g

tablet,thanks t

the latest and greatest games on your ancient laptop, phone, or

tablet, thanks to remote servers instead of having to buy a console or

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build a powerful gaming PC. Fire up a game on the TV,then

seamlessly pick it up on your mobile device. Stuck in a game? Ask a

friend to take over your controller from across the internet.

If that sounds like the lofty pitch for Google’s Stadia cloud gaming service, you’ve

been paying attention. But every single one of those things was promised years ago

by a startup named Gaikai — a startup that Sony bought in 2012 for $380 million. At

the time, Sony gave every indication that it would harness the full potential of a

PlayStation cloud. It even bought Gaikai’s closest competitor, OnLive, in 2015 and

launched a service called PlayStation Now that finally hit 1 million subscribers this

October. But half a decade later,the company has barely tapped into cloud gaming’s

promise, and competitors like Google seem poised to attract the gamers that Sony

failed to convert.

I doubt it’s a coincidence that Google and Gaikai’s pitches sound so similar. As

Gaikai co-founder, CEO, and former PlayStation Now chief David Perry pointed out

to me in an interview on the day Stadia debuted, Google gaming boss Phil Harrison

used to sit on Gaikai’s advisory board. Jack Buser, Stadia’s head of business

development, used to run Sony’s PlayStation Now. Heck, a clean-shaven Sundar

Pichai was the one who first introduced how Gaikai could stream games natively in

the Chrome web browser,three years before he became Google’s CEO.

Related /

Google Stadia review: the best of cloud gaming is still just a beta

The world is waiting for Google Stadia to flop

Mind you, Google is already having plenty of trouble meeting the lofty goals it

cribbed from Gaikai, breaking many of the promises it made before launch. But how

did Sony let Google become the front-runner in cloud gaming to begin with, after

having the better part of a decade to freely build it out?

Let’s take a quick trip back to February 2013 when Sony introduced the PlayStation

4 and revealed evealed Gaikai’s aikai s newfound ewfound role in the whole thing.When Perry strode erry strode
nted a vision of a PlayStation Network like we’

you instantly try any game before you buy

onstage, he presen

one that would let

d never seen before,

t y it. His words:

With the Gaikai cloud technology, our goal is to make free exploration possible for

virtually any PlayStation 4 game in the PlayStation Store. Imagine you’re in the store,

checking out the latest titles and you see something that catches your eye: no

problem. You can simply press the X button to hop in and start playing the game.

Now in the past, not all games were available, and the ones that were had to be kind

of the ‘lite’ version, where they’d been edited down so they could be downloaded

reasonably quickly. With Gaikai and the PlayStation Store, you’ll be able to instantly

experience anything that you want. I’ve always liked that concept of try it for free,

share it if you like it, and pay only for the games you fall in love with.

It’s easy to forget this was Gaikai’s pitch from the start: instant free demos of games

you can try before you buy, using practically any device you own.

I got an exclusive first look at Gaikai in December 2010, and I’ll never forget what

Perry asked me afterward: not whether the streaming quality was good, but if I’d

experienced enough to figure out whether the game was worth buying. That was

why Gaikai originally streamed games from YouTube and Facebook ads — they

were legitimately ads! — though Gaikai was also willing to let publishers stand up

their own servers and set their own pricing if gamers wanted to turn those ads into

game time.

onstage, he presented a vision of a PlayStation Network like we’d never seen before,

one that would let you instantly try any game before you buy it. His words:

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When I visited Gaikai’s headquarters in June 2012, I was amazed by how many

endpoints Gaikai had already built. Both LG and Samsung TVs were slated to feature

’s headquarters in June 2012, I was amazed by how many

y built. Both LG and Samsung TVs were slated to feature

When I visited Gai

endpoints Gaikai h

ikai

had already

the service. It worked with an off-the-shelf ff h h lf Android tablet. Best Buy and Walmart

had live game demos you could play on their websites, and you could share demos

on Facebook with your friends and relatives they could play right inside the social

network if you liked.

But Perry says most of that went out the window when he cashed Sony’s check.

“After Sony acquired Gaikai, we went quiet. I stopped giving speeches, I stopped

pushing this as the future of the industry ... We withdrew from all the deals,” he

relates.

Though Perry says he’s loyal to Sony for buying Gaikai and eventually building a

service with 1 million subscribers instead of just “shoving it somewhere in a drawer,”

he says his personal opinion is that Sony didn’t really understand what to do with

Gaikai, and the company started by trying to shoehorn Gaikai’s tech into a way to

sell its own hardware.

“Sony acquired something that they thought would be a good idea to buy because

they could feel the momentum, and I don’t think at the time it was clear to them

which business they were in,” Perry says. “If you are in charge of PlayStation, are you

in the hardware business or are you in the gameplay business? I don’t think that was

clear. Because if you’re in the hardware business,this isn’t very interesting. If you’re

the guys building hardware, and someone starts talking about the cloud, it’s just like,

‘Meh, we’ve got work to do.’”
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And “meh” was definitely how I felt when Sony’s PlayStation Now cloud gaming

service debuted. When an open beta launched in late 2014, it was ridiculed as the

antiquated Blockbuster of video games: a service where you’d have to rent each PS3

title — and only PS3 titles — for more than you’d pay to buy a used disc at

GameStop. It felt like an expensive way to cover for the fact that the PS4 wasn’t

backwards compatible with PS3 games.

Sony later added a $20-a-month subscription service for a selection of lessdesirable games alongside the rentals (it eventually ditched rentals altogether), and

it expanded support to the PS3, PS Vita, PlayStation TV, a handful of Sony TVs and

Blu-ray players, and even a few Samsung smart TVs.

But it took until late 2016 for Sony to finally let you play PlayStation games on a PC,

and it was mid-2017 before it added a back catalog of current-gen PS4 titles instead

of exclusively older games. And it was tough luck if you wanted to play those PS4
games on your S

platform, save PC

ony handheld or smart TV because Sony

and PS4, along the way. It was only

ditched every ot

ny

her

, y this October that Sony finally

dropped d the price of PlayStation l S i Now to a more reasonable $60 a year and deigned

to add a few flagship games like God of War and Uncharted 4. But even those $20

“greatest hits” games will only be available to stream through January 2nd, 2020.

Even though Sony has finally stopped trying to use its PS4 Remote Play app to sell

Sony smartphones, and it opened it up to iPhone and Android gamers (years after

shutting down a perfectly good hack),there’s no parallel PlayStation Now mobile

app in sight. Sony completely ceded the Gaikai / OnLive era idea of delivering cloud

games directly to phones. That’s where Microsoft’s xCloud is now striking first and

where Google and early Gaikai partner Nvidia may also have an opportunity.

There are reasons why Sony took it slow with Gaikai — they’re just unfortunate

reasons — like how Sony’s initial PlayStation Now service relied on having actual

PS3 hardware in the data center for every single player. That capped Sony’s physical

and economic ability to expand the service as quickly as it might have liked. Or how

the company wound up diverting its attention to VR.

“VR took all the air in the room for a while.”

“Cloud gaming is working. We’ve demonstrated it. We’re sort of waiting for things to

get better and have more power in the cloud, faster internet speeds, all the rest of it

... And then VR comes out, and VR took all the air in the room for a while,” says

Perry. He also points out that Sony never put much marketing behind PS Now or ran

a real ad until last month. Sony also never wound up offering a bundle with its other

subscription services like PlayStation Plus and PlayStation Vue, for that matter.

When I ask Perry what happened to the key part of his original vision — the idea

that PS4 players would be able to instantly sample games for free — he admits that

Sony never actually tried.

“It was something I was passionate about, but I don’t think it had the support of

others,” says Perry, adding that he found it wasn’t necessarily compatible with “the

harsh reality reality of business.” business. One example: example: he spoke to a publisher ublisher who told him,

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games on your Sony handheld or smart TV because Sony ditched every other

platform, save PC and PS4, along the way. It was only this October that Sony finally
“David, we don’t want anyone to play our game.” When Perry asked why, he says they

replied: “Because the trailer does a better job of convincing them our game is good.

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 38 of 97 * PUBLIC *; 

want anyone to play

the trailer does a better j

our game.” When Perry asked why, he says they

job of conv

“David, we don’t w

replied: “Because t j incing them our game is good.

The game isn’t very good to be honest, but the trailer makes it look good.” It was a

clarifying moment.

“We don’t want anyone to play our game.”

Even so, Perry says he believes gamers would “have to be insane not to sign up” for

PlayStation Now at the new lower price, as long as they spend a lot of time gaming.

“The amount of games you’re getting for the money is absurd.” But he also believes

that Sony, Google, and other prospective cloud gaming providers need to stop trying

to stick existing gaming components into their servers and convince publishers to

build and share their best games instead of just a back catalog of titles. “They have

to decide that this is the future.”

Perry’s somewhat worried that cloud gaming will adopt the same pattern we’re

seeing with other streaming media today, where Disney and HBO and Apple and

many more are all standing up their own video delivery services to compete with

Netflix for our attention. “When things get out of control, you end up with multiple

streaming services. And you want to watch Harry Potter, and you don’t know where

it is,” he says. Sony had seven unchallenged years to convince publishers, but now

Google, Electronic Arts, Ubisoft, Microsoft, Nintendo, Amazon, Verizon, Walmart,

Nvidia, and others are all testing the waters for their own possible cloud gaming

subscriptions.
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None of this is to say Sony wasted those seven years or made the wrong decisions.

The PlayStation 4 wound up becoming a phenomenal success. It’s the second bestselling console of all time having shipped over 102 million units, handily winning

this console generation. PlayStation VR is also one of the best-selling console

accessories ever, even if VR hasn’t taken off quite yet. And Sony did need to make

some hard choices during the past decade to turn around its foundering business.

This is the decade Sony decided it was no longer an electronics company, chopping

off pieces of itself to survive.

Some of Gaikai’s know-how might have even been responsible for that success. In

2012, Gaikai showed me a demo where you could start playing a game while the rest

of it downloads in the background — something that became a core feature of the

PlayStation 4. Share Play, a feature that lets you see a friend’s screen from over the

internet and then take over the controls, also eventually shipped. And even if Sony
front runner in cloud gaming, buying Gaikai and OnLive early on

Wh I i i f h fi i i I h d i Pl S i N i ’

of patents on the tech.

doesn’t become a

means it has a lot

doesn’t become a front-runner in cloud gaming, buying Gaikai and OnLive early on

means it has a lot of patents on the tech.

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When I try it again for the first time in years, I have to admit PlayStation Now isn’t

bad. I’m streaming God of War on my Windows desktop at a fairly lackluster 720p

resolution, but with nary a hitch. There’s no way I’d spend $10 a month or $60 a year

for that experience — not when I can own those same games permanently for $10 or

less per disc — but I would pay if Sony gave me the latest games there. Better yet, I’d

pay to get games that aren’t even possible on console, with hundreds or thousands

of simultaneous players, incredibly advanced physics simulations, and AI-voiced

NPCs that don’t just repeat the same pre-programmed lines of dialogue. It’s just not

clear whether Sony has any intent to deliver those things — and now it’ll have to

fight its own ideas in the hands of much wealthier adversaries like Google. All we

know for now is that the PlayStation 5 is coming, and Sony has a vague interest in

maximizing the “off-console opportunity” of cloud gaming as well.

In 2014, Perry claimed that Sony had “fully greenlit” a project where Gaikai would

help build “the fastest global network ever made” to let gamers play like never

before. That may still be the plan, but Sony’s going to need some help. That may be

why it struck a cloud gaming partnership with Microsoft this May,teaming up with

its chief rival.

Sony was one of the few companies that believed in cloud gaming enough to spend

big in 2012, just as it was one of the few that believed in VR. But that wasn’t enough

to make Sony a leader.

Related /

Microsoft and Sony are teaming up for the future of gaming

0 COMMENTS
EXHIBIT J 

[This entire exhibit is subject to the Protective Order]

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EXHIBIT J 

[This entire exhibit is subject to the Protective Order] 
EXHIBIT K

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EXHIBIT K
 

INSIDER REVIEWS 0. 

> 

00 

■ 

■ 

■ 

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HOME TECH 

Is PS5 backward compatible? Yes, more than 4,000 PS4 

games work on the next-gen console — here's what to 

know 

By Dave Johnson Dec 9, 2021, 5:44 PM 

With very few exceptions, the PS5 is backward compatible with PS4 games. YELIM LEE/AFP via Getty Images 

The PS5 is largely backward compatible with PS4 games, with more than 4,000 

available titles. 

There are only about a half-dozen known PS4 games that are incompatible with 

the PS5. 

There are some limitations; for example, the Share menu can't be displayed on the 
PS5 when playing a PS4 game. 

A new game console like the PlayStation 5 is a substantial investment, so ideally you 

can extend its value by continuing to play older PS4 games on it. If you are wondering 

if your existing library of PS4 games will work on your new PSS, you're in for some 

good news: It's a qualified "yes." 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 44 of 97 * PUBLIC *; 

tions; f xample, the Shar e display 

PS5 when playing a PS4 game. 

A new game console like the PlayStation 5 is a substantial investment, so ideally you 

can extend its value by continuing to play older PS4 games on it. If you are wondering 

if your existing library of PS4 games will work on your new PS5, you're in for some 

good news: It's a qualiDed "yes." 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 45 of 97 * PUBLIC *; 

The PS5 is backward compatible with PS4, to an extent 

An overwhelming majority of PS4 game titles will play on a PS5 console. That's about 

4,000 games, so with rare exception, your existing game collection will play Dne 

(though you should be sure your PS5 has all available updates installed before trying 

to play PS4 games). Sony also advises that you should verify the core game works 

properly on the PS5 before purchasing or installing any add-ons for the game. 

In fact, some PS4 games may see an overall improvement when played on the PS5. 

Select games can take advantage of the PS5's Game Boost feature, which allows the 

game to run at a higher frame rate. Games that run better on PS5 thanks to Game 

Boost include Assassin's Creed Odyssey, Crysis Remastered, God of War, Ratchet & 

Clank, Rocket League, Shadow of the Tomb Raider, and others. 

If you enjoy PlayStation VR, you'll be pleased to learn that PS VR titles are included in 

the list of compatible games. Playing VR games on a PS5 requires a PS VR headset, 

PlayStation Camera for PS4, and a PlayStation Camera adaptor, and the games 

perform best when you use a DualShock 4 controller. 
Specific PS4 on PS5 limitations 

The list of PS4 games which are known to be incompatible with the PSS is quite short. 

At this time, these are the only games to avoid: 

e Afro Samurai 2: Revenge of Kuma Volume One 

e TT Isle of Man — Ride on the Edge 2 

e Just Deal With It! 

e Robinson: The Journey 

e We Sing 

e Hitman Go: Definitive Edition 

Shadwen 

Even though most other games will run on the PS5, the gaming experience might not

• 

• 

• 

• 

• 

• 

• 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 46 of 97 * PUBLIC *; 

SpeciRc PS4 on PS5 limitations 

The list of PS4 games which are known to be incompatible with the PS5 is quite short. 

At this time, these are the only games to avoid: 

Afro Samurai 2: Revenge of Kuma Volume One 

TT Isle of Man – Ride on the Edge 2 

Just Deal With It! 

Robinson: The Journey 

We Sing 

Hitman Go: DeDnitive Edition 

Shadwen 

Even though most other games will run on the PS5, the gaming experience might not 
,) 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 47 of 97 * PUBLIC *; 

always be 100% seamless. Some features or functionalities that were available on the 

PS4 might not work when you play the game on the PS5. For example, the Share 

menu can't be displayed on the PS5 when playing a PS4 game. You can take 

screenshots by pressing the Create button on your DualSense controller, however. 

Likewise, some PS4 games can't record video at 3840 x 2160 even if you start 

recording at that setting — you will only get a resolution of 1920 x 1080. 

Note: PS5 backward compatibility is not extended to PS3, PS2, or PS1 games. 

Dave Johnson 

Freelance Writer 

Dave Johnson is a technology journalist who writes about consumer tech and how the 

industry is transforming the speculative world of science fiction into modern-day real life. 

Dave grew up in New Jersey before entering the Air Force to operate satellites, teach...

Read more 

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EXHIBIT /
i i i

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PlayStation.Blog

February 22, 2022 

F i rst l ook : th e h ea d set d es i g n fo r P l ayStati o n VR2 

374 0 2,419 

The inspiration behind the latest VR hardware design. 

Hideaki Nishino (https://blog.playstation.com/author/hnishino/) 

Senior Vice President, Platform Experience, SIE 

Today, I am especially pleased to reveal the stunning new design of our next generation VR 

headset, PlayStation VR2, together with an updated and Ŵnal design image of our PlayStation 

VR2 Sense controller. 

You’ll notice the PS VR2 headset has a similar shape as the PS VR2 Sense controller, taking on a 

matching “orb” look. The circular orb shape represents the 360-degree view that players feel 

when they enter the virtual reality world, so this shape captures it nicely. 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 51 of 97 * PUBLIC *; 

(https://live.staticŵickr.com/65535/51897391159_f7b9795a07_k.jpg) 

The design of the PS VR2 headset was also inspired by the look of the PS5 family of products. 

When our design team created the PS5 console, they also had the next generation VR headset 

in mind so you’ll notice some similarities in the look and feel. The PS5 console has ŵat edges as 

it is meant to be displayed on a ŵat surface, while there was more emphasis on adding 

roundness to the design of PS VR2 headset since it is meant to have constant human contact, 

similar to the rounded edges of the DualSense controller and Pulse 3D headset. 

Our goal is to create a headset that will not only become an attractive part of your living room 

decor, but will also keep you immersed in your game world, to the point where you almost 

forget you are using a headset or controller. That’s why we paid very close attention to the 

ergonomics of the headset and conducted extensive testing to ensure a comfortable feel for a 

variety of head sizes. We already had a lot of positive feedback on the ergonomics of the Ŵrst PS 

VR headset by carefully balancing the headset weight and having a simple headband that can 

be adjustable, so we kept the same concept for the PS VR2 headset. Other features such as the 

headset’s adjustable scope that places the scope area closer or further away from the face and 

placement of the stereo headphone jack also remain the same, so players will be familiar with it. 

(https://live.staticŵickr.com/65535/51897391199_64d60b890e_k.jpg) 

For the PS VR2 headset, we took comfort a few steps further by adding new features such as a 

lens adjustment dial, so users have an additional option to match the lens distance between 

their eyes to optimize their view. We also created a slimmer design with a slight weight 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 52 of 97 * PUBLIC *; 

reduction – even with the new added features such as the new built-in motor for the headset 

feedback. It was quite a challenge to create a slimmer design with new features added to 

improve upon our Ŵrst headset, but our design and engineering teams proved this could be 

possible when we saw the Ŵnal design! 

Additionally, we’ve integrated a new vent design for the PS VR2 headset that we think users will 

enjoy. Yujin Morisawa, Senior Art Director at SIE led the headset design of PS VR2 and explains 

why this is his absolute favorite part of the design: 

“When I started to work on the design for 

the PlayStation VR2 headset, one of the 

areas I wanted to focus on Ŵrst was the idea 

of creating a vent in the headset to let air 

out, similar to the vents on the PS5 console 

that allows airŵow. Our engineers came up 

with this idea as a good way to allow 

ventilation and avoid having the lens fog up 

while players are immersed in their VR 

games. I worked on many design concepts 

to achieve this, and in the Ŵnal design, you 

can see there is a little space in between the 

top and front surface of the scope that 

contains the integrated ventilation. I am 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 53 of 97 * PUBLIC *; 

really proud of how this turned out and the 

positive feedback I have gotten so far. I hope 

our PlayStation fans will also agree, and I 

can’t wait for them to try it out.”

– Yujin Morisawa, Senior Art Director, SIE 

Another treat we wanted to share – similar to the thousands of tiny PlayStation symbols we 

added to the design of the PS5 console and DualSense controller, we also included tiny 

PlayStation symbols to the front and back bands of the PS VR2 headset to add a comfortable 

feel for players to enjoy. 

When PS VR2 launches, it’ll take a giant leap forward in the way we play games in virtual reality.

There are plenty of exciting new features 

(https://blog.playstation.com/2022/01/04/playstation-vr2-and-playstation-vr2-sensecontroller-the-next-generation-of-vr-gaming-on-ps5/) to look forward to in the PS VR2 system, 

including stunning visual Ŵdelity in 4K HDR and state-of-art graphical rendering, enhanced 

tracking such as inside-out camera tracking, new PlayStation VR2 Sense Technology features 

such as headset feedback, and the new, intuitive PS VR2 Sense controller that creates an 

incredibly deep feeling of immersion. Additionally, the PS VR2 system comes in a simple, single 

cord set up so you can connect to your games immediately. PS VR2 development kits are 

already in the hands of game creators, and we are excited for what they’ll come up with to truly 

make virtual reality a remarkable experience for gamers. We look forward to sharing more 

details with you about PS VR2. Stay tuned! 
ps vr2 (https://blog.playstation.com/tag/ps-vr2/) 

ps vr2 sense controller (https://blog.playstation.com/tag/ps-vr2-sense-controller/) 

PSVR2 (https://blog.playstation. 

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-yt2%2F La ystat on Ht at4eF lon Odesign%s20for%20PlayStation%20VR2) 

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374

ps vr2 (https://blog.playstation.com/tag/ps-vr2/) 

ps vr2 sense controller (https://blog.playstation.com/tag/ps-vr2-sense-controller/) 

PSVR2 (https://blog.playstation.com/tag/psvr2/) 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 55 of 97 * PUBLIC *; 

EXHIBIT 0
Game & Network Services Segment 

Senior Executive Vice President 

Sony Group Corporation 

President and CEO, Sony Interactive Entertainment LLC 

Representative Director and President, Sony Interactive Entertainment Inc. 

Jim Ryan

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 56 of 97 * PUBLIC *; 

Game & Network Services Segment 

Senior Executive Vice President 

Sony Group Corporation 

President and CEO, Sony Interactive Entertainment LLC 

Representative Director and President, Sony Interactive Entertainment Inc. 

Jim Ryan 
G&NS Segment 

PlayStation: The Road to Profitable Transformation 

 Less. Bk Psa 

Thriving © Building Maintaining Core Business Our Biggest Our Longest 

Ever Platform Ever Tail 

 

 . . f N {A 2. PlayStationVR2 = BA: 

owerTul NCW 

Growth Vectors C.° wargwvare > ai BUNGIE 48/ZON fe SHOW 

, MOBILE BEYOND 

CONSOLE 

 

3. 

Transformative 

Sony Group (ol | F] elele-1alelal 

©2022 CTMG. All Rights Reserved. © 2022 MARVEL Sony Group Corporation | 2

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 57 of 97 * PUBLIC *; 

G&NS Segment 

PlayStation: The Road to Profitable Transformation 

1. 

Thriving 

Core Business 

2. 

Powerful New 

Growth Vectors 

3. 

Transformative 

Sony Group 

Collaboration 

Building 

Our Biggest 

Ever Platform 

Maintaining 

Our Longest 

Ever Tail 

COMMERCIAL PORTFOLIO AUDIENCE 

PC MOBILE BEYOND 

CONSOLE 

©2022 CTMG. All Rights Reserved. © 2022 MARVEL Sony Group Corporation | 2 
G&NS Segment 

FY21: Record Earnings in a Transition Year 

 

Net Sales 

(Billions, ¥Yen) 

94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 1 12 13 14 15 16 7 18 19 20 21 FY 

PlayStation. —jJ PlayStation.2 = ss. BS PSA. SS. 

Operating Income Ea 

(Billions, ¥Yen) 

Figures before FY20 are based on US GAAP and figures for FY21 are based on IFRS Sony Group Corporation | 3

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 58 of 97 * PUBLIC *; 

G&NS Segment 

FY21: Record Earnings in a Transition Year 

Net Sales 

(Billions, ¥Yen) 

2,740 

1,044 661 1,017

94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20 21 

FY 

Operating Income 

346 

(Billions, ¥Yen) 

-51 -232 -19 

Figures before FY20 are based on US GAAP and figures for FY21 are based on IFRS Sony Group Corporation | 3 
Biss. 

Building Our 

Biggest Platform 

Ever 

Unprecedented 

PY =Tn ake lare| 

Si icolavem =1e-1ale| 

Category 

Growth 

Highest 

Engagement 

Ever 

 

G&NS Segment 

Take caret le) (<3 

Game Lineup 

BE-Ye dilate Maps) 

Supply Issue 

Sony Group Corporation | 4

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 59 of 97 * PUBLIC *; 

G&NS Segment 

Building Our 

Biggest Platform 

Ever 

Unprecedented 

Demand 

Strong Brand 

Incredible 

Game Lineup 

Category 

Growth 

Highest 

Engagement 

Ever 

Tackling PS5 

Supply Issue 

Sony Group Corporation | 4 
 

ex

Sou

Platf

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 60 of 97 * PUBLIC *; 

G&NS Segment 

PS5 – Unprecedented Demand 

Sell-Through Time of 80K HW 

Purchase Interest in PlayStation Console Units at US Retailers 

(One Year After Each Console’s Launch Year, North America Only) (End of 1st Full FY for PS5 vs. End of 1st Full FY for PS4) 

November 2021 

55%

expressed interest 

in PS5 

US retailer events sold PS5s at 

a rate of nearly 1,000 units per minute* 

er events sold P 

80K 

UNITS 

IN 82

MINUTES 

November 2014 

PS4 units in the US were selling at 6 per minute, 

at the same stage in product lifecycle 

pressed interest 

80K IN 9 

UNITS DAYS 

rce: NielsenIQ - BASES 

orm Volumetric, 2014 and 2021 *Across 3 different leading U.S. retailer events Sony Group Corporation | 5 

28%

in PS4 

No 

2

exp 

in 

Sourc 

Platfo 
 

 

 

G&NS Segment 

Unprecedented China Demand 

Week 72 Sell-Through Active Console Volume Ranking Average Cumulative PS Plus Subs 

After Global Launch (As of March 2022) Spend Per Active Device: Week 72 After Global Launch 

Week 72 After Global Launch 

= a | 1 9. || 

WLZ 2. e@ “ff 1 10. Ie 

20 = " oo = $69.81 89.9K 

(Free Supply) 

sa 1. 

 

 

 

 

~“ 

 

oy £0) 4 

(Constrained Supply) 

Sony Group Corporation | 6

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 61 of 97 * PUBLIC *; 

r

(C

Unprecedented China Demand 

G&NS Segment 

Week 72 Sell-Through 

After Global Launch 

Active Console Volume Ranking 

(As of March 2022) 

1. 5. 9. 

Average Cumulative 

Spend Per Active Device: 

Week 72 After Global Launch 

PS Plus Subs 

Week 72 After Global Launch 

250K 

(F ee Supply) (Free S 

2. 

3. 

4. 

6. 

7. 

8. 

10. 

11. $69.81 89.9K 

1. 5. 9. 

670K 

(C onstrained Supply)

2. 

3. 

4. 

6. 

7. 

8. 

10. 

11. 

$223.34 295.7K 

Sony Group Corporation | 6 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 62 of 97 * PUBLIC *; 

G&NS Segment 

Gaming Category Growth 

WW Gaming Industry Size by Platform* Console Industry Size by Revenue Type* 

($BIL USD) ($BIL USD) 

$74 

CAGR 4% $71 $70 CAGR 5% $67 $64 $287 $275 $266 Subscription $254 $240 

MOBILE Digital 

Add-on 

CAGR 6% 

Digital 

Console Software 

Physical PC Console Software 

$10 

$18 

$9 

$9 

$21 

$13 

$20 

$10 

$8 

$20 

$15 

$24 

$10 

$7 

$18 

$14 

$23 

$9 

$7 

$17 

$150 

$46 

$71 

$159 

$47 

$70 

$166 

$47 

$74 

$8 

$15 

$9 

$11 

$21 

$131 

$45 

$64 

$141 

$46 

$67 

CAGR 1% 

Console 

Hardware 

CY21 CY22 (E) CY23 (E) CY24 (E) CY25 (E) CAGR 4% CY21 CY22 (E) CY23 (E) CY24 (E) CY25 (E) 

CONSOLE 

45% 

MARKET PS4

SHARE 50%+ 

PS5 Target** 

*Source: Projections from IDG Consulting, 2022_Q1 **Internal SIE PS5 target Sony Group Corporation | 7 
G&NS Segment 

The Strongest Gaming Brand 

PlayStation in Top Global Brands Brand Momentum vs. Rest of Category 

PS5 Launch peak #7 PlayStation 

4 Rising to No. 7 from No. 9 YOY 

1 

 

a 3. 4, 5. 

& é Q PELOTON (Spotify _ezansse- ys 

android 

6. 8. 9 10 

® ste. £4: D NN ® Instant Cot “23° fitbit TE USAA EBD Evid F eyrs F Ey1s OM pyi9 A E19 A py19 AF pyr9 OW 6420 W 20 A 90 07 70 O% Ey pyri OF? pyri 03 pyri O* 

 

—e®PlayStation -®-BrandB ® BrandC 

Source: 2022 Prophet Brand relevance index report Source : SIE Global Brand Tracker Sony Group Corporation | 8

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 63 of 97 * PUBLIC *; 

G&NS Segment 

The Strongest Gaming Brand 

PlayStation in Top Global Brands Brand Momentum vs. Rest of Category 

#7 PlayStation 

PS5 Launch peak 

Rising to No. 7 from No. 9 YOY 

63 62 63 62 61 60 62 61 

64 

68 

73 71 

67 65 66 67 

58 57 57 

46 45 45 44 43 42 43 44 44 

48 49 48 

46 46 47 

49 

56 54 54 55 

53 54 54 55 56 56 55 55 55 

1. 2. 3. 4. 5. 

6. 7. 8. 9. 10. 

PlayStation Brand B Brand C 

Source: 2022 Prophet Brand relevance index report Source : SIE Global Brand Tracker Sony Group Corporation | 8 
G&NS Segment 

PlayStation Games Have Never Been Better 

Incredible Content 

 

SHDER ERMAN © 

PLAYSTATION 

 

fey ReETURNAL [7 Honizoh 

Ge, 2 SHOW? 

onal [| “"DEATHLOOP" Gensiin 

 

 og Oey jINBAZK Q FIFA 

GHOSTWIRE tT O K ¥Y 0 

Ratings Source: Metacritic as of May 4, 2022 

...With the Best Yet to Come 

SRNR 

HOGWARTS FERSPOKEN. 

AVATAR — FINAL FANTAST.AV : FRONTIERS « PANDORA:

 

*

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 64 of 97 * PUBLIC *; 

G&NS Segment 

PlayStation Games Have Never Been Better 

Incredible Content ...With the Best Yet to Come 

Ratings Source: Metacritic as of May 4, 2022 Sony Group Corporation | 9 

PLAYSTATION 

STUDIOS 

TITLES 

THIRD 

PARTY 

TITLES 

* 

© 2022 MARVEL 
G&NS Segment 

PS5: Highest Engagement Ever... 

Metrics (March 2015) (March 2022) (March 2022) 

Gameplay Attach (%) 

(Gameplay MAU/Platform MAU) 92% 87% 

Gameplay DAU/MAU 

(Avg. Gameplay DAU/Gameplay MAU) 39% 38% 

MAU Retention Rate 86% 82% 

Monthly Gameplay Hours/User 44.1 39.7 

Paid Plus Subs Attach (%) 

(Paid Plus Subs/Active Consoles in 12 months) 33% 61% 

LTD Store Transactions Attach (%) 

(Paid Store Transacting Accounts1

/Active Users) 36% 34% 

LTD Game Transactions Attach (%) 

(Paid Game Transacting Accounts2/Active Users) 67% 47% 

94% 

46% 

88% 

50.0 

82% 

62% 

71% 

 

94%

46%

88%

50.0

82%

62%

71%

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 65 of 97 * PUBLIC *; 

1 Store transactions include digital full game and add-on transactions from conformed spend. Platform is defined by target content type or transaction device type 2 Game transactions include digital full game, physical full game, and add-on transactions from conformed spend. Platform is defined by target content type or transaction device type Sony Group Corporation | 10 
G&NS Segment 

...And Game Monetization is Stronger 

PS5 Game Spend: 15% Higher Than PS4 

——- 

SUBSCRIPTION 

Mi ADD-ON 

ME OFULL GAME 

PSA. SS. 

(Nov-13 to Mar-15) (Nov-20 to Mar-22) 

Average Game Spend Per Connected Device (USD) 

Sony Group Corporation | 11

-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 66 of 97 * PUBLIC *; 

G&NS Segment 

...And Game Monetization is Stronger 

PS5 Game Spend: 15% Higher Than PS4 

SUBSCRIPTION 

ADD-ON 

FULL GAME 

(Nov-13 to Mar-15) (Nov-20 to Mar-22) 

-21% 

+247% 

+21% 

+15% 

Average Game Spend Per Connected Device (USD) 

Sony Group Corporation | 11 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 67 of 97 * PUBLIC *; 

G&NS Segment 

PS5 Supply Issues: A Top Priority 

Year 3 is 

expected to 

close the gap 

PS5 outsold PS4 

in Year 1 

PS5 undersold 

PS4 in Year 2 due 

to supply 

constraint 

Year 4 onwards, 

PS5 is expected to 

overtake again 

YR1 YR2 YR3 YR4 YR5 

Cumulative Sell-In 

PS4 PS5 

Short-Term Risks 

• COVID-19 impact for parts inventory (e.g., 

Shanghai) 

• Russia impact for logistics and potential 

parts inventory 

Mitigation Measures In Progress 

• Sourcing multiple suppliers for greater 

agility in unstable market conditions 

• Ongoing logistical negotiations to maintain 

optimal PS5 delivery routes 

Sony Group Corporation | 12 
G&NS Segment 

ms 

Maintaining Our 

Longest Ever Tail 

 -_S <1. Ongoing Retain Post-COVID-19 

PVAVANSY EK) Digital Shift 

Continue Loyal Subscriber Base 

Free-to-Play and ARPU Growth 

Growth Opportunities 

 

Sony Group Corporation | 13

- -

-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 68 of 97 * PUBLIC *; 

G&NS Segment 

Maintaining Our 

Longest Ever Tail 

Ongoing 

AAA Slate 

Retain Post COVID-19 

Digital Shift 

Loyal Subscriber Base 

and ARPU Growth 

Opportunities 

Continue 

Free to Play 

Growth 

Sony Group Corporation | 13 
Retain Post-COVID-19 Digital Shift 

G&NS Segment 

PS4 REMAINS KEY DRIVER OF PS STORE REVENUE 

COVID-19 Accelerated Strong 

Digital Shift in PS4 Spend 

20% 27% 34% El 39%, 

48% 

0, 60% 66% 

71% 

80% TEL) 68% El 61%, 

52% 

0, 40% 34% 

23% 

FY13, FY14~—sFY15-—s FY16 FY17, —sFY18 

MDisc @ Digital 

PS Store Revenue % by Console 

 

FY21 

Sony Group Corporation | 14

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 69 of 97 * PUBLIC *; 

G&NS Segment 

Retain Post-COVID-19 Digital Shift 

PS4 REMAINS KEY DRIVER OF PS STORE REVENUE 

COVID-19 Accelerated Strong 

Digital Shift in PS4 Spend 

PS Store Revenue % by Console 

65% 

Sony Group Corporation | 14 

FY21 

80% 

20% 

73% 68% 61% 

52% 

40% 

27% 34% 39% 

48% 

60% 

34% 

23% 20% 

66% 

77% 80% 

FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 

Disc Digital 
G&NS Segment 

Free to Play: A Significant Share of PS4 Spend 

Gx FY21 

% of PS4 

PlayStation 

Store Spend 

(5%) FY16 

; Genshin Call of Duty Apex Rocket 

Key Titles } Fortnite | Impact | Warzone | Legends League 

 

Sony Group Corporation | 15

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 70 of 97 * PUBLIC *; 

G&NS Segment 

Free to Play: A Significant Share of PS4 Spend 

% of PS4 

PlayStation 

Store Spend 

5% FY16 

FY21 25%+ 

Key Titles Fortnite Genshin 

Impact 

Call of Duty 

Warzone 

Apex 

Legends 

Rocket 

League 

Sony Group Corporation | 15 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 71 of 97 * PUBLIC *; 

G&NS Segment 

PlayStation Plus on PS4: Sustained Performance 

Primary Reasons Why People Subscribe % of Total Subs Base (March 2022) 

36% 

Online 

Multiplayer 

13% 

Cloud 

Storage for 

21% 30% 

Game Saves 

Game 

Discounts 

and Offers 

Monthly 

Free Games 

Overall PS4 Plus Subscriber Satisfaction 

72% satisfied 

21% 18% 33% 

80% 

70% 

60% 

50% 

1 2 3 4 5 6 7 8 9 10 - Extremely Satisfied FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 

* COVID-19 & Fall Guys drove unprecedented engagement in FY20 Sony Group Corporation | 16 

69% 

PS4 Renewal Rate 
G&NS Segment 

PS4 vs. PS3: Much Stronger Late Life Cycle 

MAU 

March 2015 

(Final Month 

 

of FY14, 2" Year of PS4) 

36.1M 

users 

 

Pra. March 2022 

(Final Month of FY21, 2"4 Year of PS5) 

Stoo 

 

Average Annual Spend Per 

Active Console* 

FY 2014 

 

(24 Year of PS4) 

$68 

FY 2021 

 

(24 Year of PS5) 

*Excluding the spend on console itself and on second-hand discs Sony Group Corporation | 17

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 72 of 97 * PUBLIC *; 

7 

G&NS Segment 

PS4 vs. PS3: Much Stronger Late Life Cycle 

MAU 

March 2015 

(Final Month of FY14, 2nd Year of PS4) 

36.1M 

users 

March 2022 

(Final Month of FY21, 2nd Year of PS5) 

84.0M 

users 

Average Annual Spend Per 

Active Console* 

FY 2014 

(2nd Year of PS4) 

$68 

FY 2021 

(2nd Year of PS5) 

$151 

*Excluding the spend on console itself and on second-hand discs Sony Group Corporation | 17 
G&NS Segment 

I 

N ew G rowth Commercial exe) auce) [[o) Audience 

Vectors Expansion Expansion Expansion 

 

Sony Group Corporation | 18

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 73 of 97 * PUBLIC *; 

G&NS Segment 

New Growth 

Vectors 

Commercial 

Expansion 

Audience 

Expansion 

Portfolio 

Expansion 

Sony Group Corporation | 18 
G&NS Segment 

New Growth Vectors 

NEY 

PlayStation 

Plus 

Commercial 

Expansion 

PlayStation 

Direct 

exe) auce) ite) (OJarere)i ate) l= der-lareliate Live 

Expansion M&A Our IP Services 

PANU Tel (ale=) Mobile StenvZeyare| Expansion (olarsre) (= 

Sony Group Corporation | 19

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 74 of 97 * PUBLIC *; 

G&NS Segment 

New Growth Vectors 

Commercial 

Expansion 

1. 

New 

PlayStation 

Plus 

2. 

PlayStation 

Direct 

3. 

PS VR2 

Launch 

Portfolio 

Expansion 

4. 

Ongoing 

M&A 

5. 

Expanding 

Our IP 

6. 

Live 

Services 

Audience 

Expansion 

7. 

PC 

8. 

Mobile 

9. 

Beyond 

Console 

Sony Group Corporation | 19 
G&NS Segment 

New Growth Vectors 

NEY 

PlayStation 

Plus 

Commercial maeeNasitclalelal 

Expansion Direct 

 

 

 

 

 

 

 

Sony Group Corporation | 20

1 2 3

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 75 of 97 * PUBLIC *; 

G&NS Segment 

New Growth Vectors 

Commercial 

Expansion 

1. 

New 

PlayStation 

Plus 

2. 

PlayStation 

Direct 

3. 

PS VR2 

Launch 

Portfolio 

Expansion 

4. 

Ongoing 

M&A 

5. 

Expanding 

Our IP 

6. 

Live 

Services 

Audience 

Expansion 

7. 

PC 

8. 

Mobile 

9. 

Beyond 

Console 

Sony Group Corporation | 20 
G&NS Segment 

1. New PlayStation Plus 

A New Service Proposition - Combining the best of both: 

4A ; . a PlayStation.Plus ano > PlayStation Now 

TIER 1: ESSENTIAL TIER 2: EXTRA TIER 3: PREMIUM 

* CLOUD STREAMING 

SAME AS PLUS TODAY CATALOGUE OF 400+ IN MAJOR MARKETS PS4 & PS5 GAMES ON DAY 1 » TRY BEFORE YOU BUY 

¢ CLASSIC GAMES 

 

To improve customer experience, grow our subscriber base and enhance monetization 

OFFER BETTER IMPROVE RETENTION GROW THE BASE CONSUMER VALUE >50M IN FY22 UNS Sa Stall 

 

Sony Group Corporation | 21

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 76 of 97 * PUBLIC *; 

G&NS Segment 

1. New PlayStation Plus 

A New Service Proposition - Combining the best of both: 

AND

TIER 1: ESSENTIAL TIER 2: EXTRA TIER 3: PREMIUM 

SAME AS PLUS TODAY CATALOGUE OF 400+ 

PS4 & PS5 GAMES ON DAY 1 

• CLOUD STREAMING 

IN MAJOR MARKETS 

• TRY BEFORE YOU BUY 

• CLASSIC GAMES 

To improve customer experience, grow our subscriber base and enhance monetization 

GROW THE BASE 

>50M IN FY22 IMPROVE RETENTION INCREASE ARPU OFFER BETTER 

CONSUMER VALUE 

Sony Group Corporation | 21 
G&NS Segment 

2. PlayStation Direct: Continued Growth 

PlayStation Direct's Revenue Future uture E European E Expansion Projected to Triple inFY ‘22 ga cp 

Expected in Early Calendar Year 2023 

Iberia, Italy, Austria 

 

 

 LU ISYAN 

$458M 

$228M $30M 

$9M 

FY19 FY20 FY21 FY22 (E) 

FY21 Unique Customers: 1.3M 

 

 FY22 Unique Customers (Projected): 3.6M 

Sony Group Corporation | 22

SPAIN

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 77 of 97 * PUBLIC *; 

G&NS Segment 

2. PlayStation Direct: Continued Growth 

PlayStation Direct's Revenue Future European Expansion Projected to Triple in FY ‘22 $1.5B 

Expected in Early Calendar Year 2023 

Iberia, Italy, Austria 

$1.13B 

Europe 

$367M 

UK NETHERLANDS

BELGIUM

GERMANY LUXEMBOURG

FRANCE ITALY

AUSTRIA

SPAIN

PORTUGAL

Europe 

USA 

$458M 

9 

$428M 

$9M 

$228M $30M 

FY19 FY20 FY21 FY22 (E) 

FY21 Unique Customers: 1.3M 

FY22 Unique Customers (Projected): 3.6M 

Sony Group Corporation | 22 
G&NS Segment 

3. PS VR2: New Levels of Immersion 

NEW ENHANCED SENSORY CONTROLS 

FEATURES TRACKING 

FOVEATED EXPANDED 

RENDERING FIELD OF VIEW 

CALL OF THE MOUNTAIN 

(oy a} al=xemn Ko most 1140 =) [ale] (= mee) com KOmTian] ©) IIAasr=180] ©) 20+ major first-party and third-party titles confirmed 

and improve ease-of-use for PS VR2 at launch 

Sony Group Corporation | 23 

 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 78 of 97 * PUBLIC *; 

G&NS Segment 

3. PS VR2: New Levels of Immersion 

Enhanced Resolution and Tracking New controller with great ergonomics, 

haptic feedback and adaptive triggers 

Tracking 

Connect to PS5 with a single cord to simplify setup 

and improve ease-of-use 

20+ major first-party and third-party titles confirmed 

for PS VR2 at launch 

Sony Group Corporation | 23 
G&NS Segment 

 

Portfolio Expansion 

 

exe) auce) ite) (OJarere)i ate) l= der-lareliate Live 

Expansion M&A Our IP Services 

 

 

 

Sony Group Corporation | 24

4 5 6

7 8 9

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 79 of 97 * PUBLIC *; 

G&NS Segment 

Portfolio Expansion 

Commercial 

Expansion 

1. 

New 

PlayStation 

Plus 

2. 

PlayStation 

Direct 

3. 

PS VR2 

Launch 

Portfolio 

Expansion 

4. 

Ongoing 

M&A 

5. 

Expanding 

Our IP 

6. 

Live 

Services 

Audience 

Expansion 

7. 

PC 

8. 

Mobile 

9. 

Beyond 

Console 

Sony Group Corporation | 24 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 80 of 97 * PUBLIC *; 

G&NS Segment 

4. Ongoing M&A Activities: FY21 to Date 

May 3, 2021 Investment Communication Platform San Francisco, CA -

Announcement Date Company Type Description Location #FTE1 

June 29, 2021 Full 

Acquisition 

July 1, 2021 Full 

Acquisition 

September 8, 2021 Full 

Acquisition 

September 30, 2021 Full 

Acquisition 

November 4, 2021 Investment 

December 10, 2021 Full 

Acquisition 

January 31, 2022 2 Full 

Acquisition 

March 21, 2022 Full 

Acquisition 

May 3, 2022 Investment 

1: Full-time employees (FTE) at time of acquisition. Investments will not include FTE. 

2: The acquisition is subject to certain closing conditions, including regulatory approvals. 

Console Game Developer 

PC Focused Porting 

Developer 

Game Developer 

(Console, PC, Mobile, VR) 

Console Game Developer 

Indie Game Developer & 

Publisher 

Game Developer 

(Console, PC, Mobile) 

Live Services Developer & 

Publisher 

Live Services Developer 

Backend-as-a-Service 

Helsinki, Finland 80 

Utrecht, The 

Netherlands 55 

Liverpool, UK 265 

Austin, TX 69 

Austin, TX -

Seattle, WA 45 

Bellevue, WA 826 

Montreal, Canada 61 

Seattle, WA -

Sony Group Corporation | 25 
 

 Sony Interactive Entertainment

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 81 of 97 * PUBLIC *; 

G&NS Segment 

4. Ongoing M&A Activities: Bungie Synergies 

Bungie to SIE Integration Plan 

Preparation for integration underway and will 

be mobilized once deal is closed 

Live Services Expertise to PlayStation Studios 

Help Build SIE Live Services Center of Excellence 

Live Services Business Operations to Platform Business 

SIE to Bungie 

Leverage Scale of SIE Publishing & Platform 

(Marketing, Global Business Operations) 

PlayStation Studios Central Services 

G&A Support 

(Legal, Finance, Accounting, HR) 

Expected closing of Bungie acquisition to be completed in Q3 FY22 Sony Group Corporation | 26 
G&NS Segment 

5. Expanding Our IP: Increasing New IP Investment 

 

PlayStation Studios Investment by IP Type 

 

STUDIOS 

FY19 FY22 (E) FY25 (E) 

 

MeExisting mNew 

Sony Group Corporation | 27

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 82 of 97 * PUBLIC *; 

G&NS Segment 

5. Expanding Our IP: Increasing New IP Investment 

PlayStation Studios Investment by IP Type 

23% 

77% 

34% 

66% 

50% 

50% 

FY19 FY22 (E) FY25 (E) 

Existing New 

Sony Group Corporation | 27 
G&NS Segment 

5. Expanding Our IP: Leverage Beyond Gaming 

Broaden Franchise Monetize Our Most Beloved Franchises Give Existing Fans M 

Awareness Beyond the Gaming Category NN VEN Asmixoll tate retort) 

ore 

 — a 

 

 

 

©2022 CTMG. All Rights Reserved. 

 

Sony Group Corporation | 28

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 83 of 97 * PUBLIC *; 

G&NS Segment 

5. Expanding Our IP: Leverage Beyond Gaming 

Monetize Our Most Beloved Franchises 

Beyond the Gaming Category 

Give Existing Fans More 

Ways to Engage 

Broaden Franchise 

Awareness 

Movies Retail TV Series 

©2022 CTMG. All Rights Reserved. Sony Group Corporation | 28 
G&NS Segment 

6. Live Services: Invest to Capture Category Growth 

Projected Gaming Category Growth* PS5 Investment by Business Model** 

$23B 

$9B 

$7B 

$24B 

$10B 

$7B 

$15B 

$9B 

$11B 

$18B 

$9B 

$9B 

$20B 

$10B 

$8B 

Digital 

Add-on 

51% 

49% 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 84 of 97 * PUBLIC *; 

45% 

55% 

Digital 

Console Live 12%

Software Service

Physical Traditional 

Console 

Software 

88% 

CY21 

(Actual) 

CY22 (E) CY23 (E) CY24 (E) CY25 (E) FY19 (Actual) FY22 (E) FY25 (E) 

*Source: Projections from IDG Consulting, 2022 Q1 

**Source: PlayStation Studios internal projections Sony Group Corporation | 29 
G&NS Segment 

6. Live Services: Grow First-Party 

Monetization & Portfolio Diversity 

Projected Number of SIE Live 

Service Franchises by Year 

(Cumulative) 

A More Diverse First-Party Portfolio 

 

 

Single-Player Game Catalog Live Services Game Catalog 

GoD@ EQWAR ieaeeh 

RAGNAROK ~~ FoRBIDDEN WEST” 

BEE SOON | | ecu THE 

THELASTOFUS }9© UNCHARTED PART Il 

RETURNAL. & H@ST 

DEATH — 

STRAN DING FY21 FY22 FY23 FY24 FY25 

(Actual) 

Sony Group Corporation | 30

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 85 of 97 * PUBLIC *; 

G&NS Segment 

6. Live Services: Grow First-Party 

Monetization & Portfolio Diversity 

Projected Number of SIE Live A More Diverse First-Party Portfolio Service Franchises by Year 

(Cumulative) 12 

Single-Player Game Catalog Live Services Game Catalog 

10 

6 

1 

3 

FY21 

(Actual) 

FY22 FY23 FY24 FY25 

Sony Group Corporation | 30 
G&NS Segment 

 

Audience Expansion 

 

 

 

 

 

Audience Stenzel are! 

Expansion Mobile (olarsre) (= 

 

Sony Group Corporation | 31

1 2 3

4 5 6

7 8 9

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 86 of 97 * PUBLIC *; 

G&NS Segment 

Audience Expansion 

Commercial 

Expansion 

1. 

New 

PlayStation 

Plus 

2. 

PlayStation 

Direct 

3. 

PS VR2 

Launch 

Portfolio 

Expansion 

4. 

Ongoing 

M&A 

5. 

Expanding 

Our IP 

6. 

Live 

Services 

Audience 

Expansion 

7. 

PC 

8. 

Mobile 

9. 

Beyond 

Console 

Sony Group Corporation | 31 
G&NS Segment 

7. Exponential Growth to be Sustained by PC Titles Beyond FY22 

Significant YOY Growth 

PC Net Sales $ (In millions) 

$300 

Release Date Release Date Release Date 

Aug 7, 2020 May 18, 2021 Jan 14, 2022 

$80 . . $35 LTD Unit Sales* LTD Unit Sales* LTD Unit Sales* 2,398K 852k 971k | 

FY20 FY21 FY22 (E) 

LTD Revenue* LTD Revenue* LTD Revenue* 

$60M $22.7M $26.2M 

Ratings Source: Metacritic as of May 4, 2022 

*As of March 2022 Sony Group Corporation | 32

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 87 of 97 * PUBLIC *; 

* * * 

G&NS Segment 

7. Exponential Growth to be Sustained by PC Titles Beyond FY22 

Significant YOY Growth 

PC Net Sales $ 

(In millionsك

$300 

Release Date Release Date Release Date 

Aug 7, 2020 May 18, 2021 Jan 14, 2022 

$80 

$35 LTD Unit Sales* LTD Unit Sales* LTD Unit Sales* 

2,398K 852k 971k 

+ 

FY20 FY21 FY22 (E) 

LTD Revenue* LTD Revenue* LTD Revenue* 

$60M $22.7M $26.2M 

Ratings Source: Metacritic as of May 4, 2022 

*As of March 2022 Sony Group Corporation | 32 
 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 88 of 97 * PUBLIC *; 

G&NS Segment 

8. Mobile Strategy: Aggressive Growth Plans 

Leverage partnerships to build leading mobile development and 

publishing capabilities within SIE 

Co-development of top 

IP with industry leaders 

• Partner with respected, 

established and successful mobile 

developers 

• Extend our franchises to more 

players and regions 

• Remain faithful to the values of 

PlayStation Studios 

• Acquire credibility, visibility, and 

learnings 

Establishing network of 

internal studios and projects 

• Internal studios build mobile expertise 

• Strategic partnerships with boutique 

teams 

• Publish external games that fit within 

broader PlayStation Studios portfolio 

• Expand to cross-platform where 

relevant 

Building world-class 

centralized publishing team 

and tools 

• Leadership talent from top mobile 

companies 

• Best practices, processes, and tools 

optimized for cross-studio learning 

• Build publishing operation in parallel 

to production 

Sony Group Corporation | 33 
Releases by Platform 

G&NS Segment 

Evolving Shape of First-Party Portfolio 

Significant Growth of PC and Mobile Within Our Portfolio 

foo" 90% a 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

 

FY 2019 FY 2022 (E) FY 2025 (E) 

MPSS M@PS4+PS5 — PS4 HPC Mobile 

Sony Group Corporation | 34

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 89 of 97 * PUBLIC *; 

G&NS Segment 

Evolving Shape of First-Party Portfolio 

Significant Growth of PC and Mobile Within Our Portfolio 

100% 

FY 2019 FY 2022 (E) FY 2025 (E) 

PS5 PS4+PS5 PS4 PC Mobile 

Sony Group Corporation | 34 

Releases by Platform 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 
G&NS Segment 

9. Console and Beyond 

<i> 

yWug-lakiie)gaatslarela 

from PlayStation’s current 

(fo) alsxe) (=bxe =) al dalem-] 0) 0) gel-lea| 

to a future where 

large elements 

ro) mol U) melo) anvanlelavinva-y.dn-vale| 'oX=Zo)alemaial=mae) alte) (= 

PC & 

Mobile 

PS Plus 

More Platforms 

| Virtual Reality | Cloud | Metaverse 

Better Experiences 

Store PlayStation 

Direct 

Discord Integration 

Sony Group Corporation | 35

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 90 of 97 * PUBLIC *; 

G&NS Segment 

9. Console and Beyond 

A transformation 

from PlayStation’s current 

console-centric approach 

to a future where 

large elements 

of our community extend 

beyond the console 

Virtual 

Reality 

PC & 

Mobile Cloud Metaverse 

More Platforms 

Better Experiences 

PS Plus PlayStation 

Direct 

Discord Store

Integration 

Sony Group Corporation | 35 
G&NS Segment 

SONY The Importance of Group Collaboration 

Sony Group Corporation | 36

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 91 of 97 * PUBLIC *; 

G&NS Segment 

The Importance of Group Collaboration 

Sony Group Corporation | 36 
G&NS Segment 

Transformative Sony Group Collaboration 

\Z SONY < Bess. X Bravia i209 

Perfect for Yc iw BRAVIA XR 

PlayStation’5 RY ys 

Sales and Marketing . 7 cae 

BRAVIA XR (eo) |F-) ofole-hileya) ~ ae = Sound coming from the action 

 

kheowcs 

.| LEARN MORE > 

= @ crunchyroll a. : P 2» pi 

 

 

son SONY Amplify IP ; ka PLAYSTATION PLUS Content Syneraies eS EMI & Distributi VIDEO \ au PASS F eidaleleidtolal SONY 4 \s ee | OF US: ,_ einer : 

Pe a... —— : ee Ac ck Reserved Relevancy 

a “DEATHLOOP" 

7) NANISOV BEER REN Mules MorsLes

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 92 of 97 * PUBLIC *; 

G&NS Segment 

Transformative Sony Group Collaboration 

Sales and Marketing 

Collaboration 

Amplify IP 

Synergies 

Content 

Distribution 

Build Brand 

Relevancy 

©2022 CTMG. All Rights Reserved. 
 

 

 

 

 

Source : SIE Global Platform Experience Tracker (Breakthrough)

PlayStation registration information (IDG)

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 93 of 97 * PUBLIC *; 

G&NS Segment 

ESG Initiatives: SIE is Turning Intention into Actions 

ENVIRONMENT 

•Our Community: 

५ Players submit 377 ocean & 

forest game creations in 

Dreams – shown at UN COP26 

५ SIE has invested in 633,000 

trees to be planted around to 

world, linked to player 

activations in game, in support 

of United Nations Play4Forests 1 

million trees goal 

•Our Services: 

- Our PS Plus cloud streaming 

service has achieved 78% 

renewable electricity & carbon 

neutrality (2020 baseline) 

•Our Products: 

- 10% of the plastic we used to 

manufacture PS game boxes 

was recycled from postindustrial waste in FY21 

SOCIETY 

•Our Community: 

- More than 17,000 PlayStation 

products such as consoles and 

games were donated to Child’s 

Play for distribution in their 

global network of 185 

hospitals 

•Our Products and Services: 

- 60 million free games 

redeemed as part of our “Play 

At Home” initiative during the 

COVID19 pandemic 

•Our Workforce: 

५ Employees donated $3.3 

million towards more than 

2,300 different causes, 

including match-funding by our 

PlayStation Cares program 

($273,000 was towards causes 

aiding the Ukraine crisis) 

GOVERNANCE 

•Our Community: 

- PlayStation Career Pathways 

Program created offering 

technology & gaming scholarships, 

mentorships & internships to 

underrepresented groups; starting 

with MLB & Jackie Robinson 

Foundation partnership 

•Our Products and Services: 

- PlayStation.com accessibility 

destination launched covering 

features available on our consoles 

& PlayStation Studios games 

- PlayStation 5 accessibility enhanced 

adding six screen reader 

languages (total now 15) & mono 

audio headphones option 

•Our Workforce: 

५ Achieved top score & awarded as 

one of the Best Places To Work for 

LGBTQ+ & Disability Inclusion by 

both HRC & Disability:IN 

Sony Group Corporation | 38 
G&NS Segment 

PlayStation: The Road to Profitable Transformation 

1. 

Thriving 

Core Business y 8 | 

a ful N COMMERCIAL 740) 50 @) M1@) AUDIENCE 

bhatt TANI (0) \ EXPANSION EXPANSION 

Growth Vectors 

3. SON Y 

Transformative | 

Sony Grou i 4% Sony — “panel | ED reece, ) (@o} | Flexo) e-1aleyal SONY eiénmr amwdnts PICTURES 

 

 

Sony Group Corporation | 39

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 94 of 97 * PUBLIC *; 

G&NS Segment 

PlayStation: The Road to Profitable Transformation 

COMMERCIAL 

EXPANSION 

PORTFOLIO 

EXPANSION 

AUDIENCE 

EXPANSION 

1. 

Thriving 

Core Business 

2. 

Powerful New 

Growth Vectors 

3. 

Transformative 

Sony Group 

Collaboration 

Sony Group Corporation | 39 
G&NS Segment 

Sony 

Interactive 

Entertainment 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 95 of 97 * PUBLIC *; 

G&NS Segment 

Sony Group Corporation | 40 
SONY 

SONY is a registered trademark of Sony Group Corporation 

Names of Sony products and services are the registered trademarks and/or trademarks of Sony Group Corporation or its Group companies 

Other company names and product names are registered trademarks and/or trademarks of the respective companies

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 96 of 97 * PUBLIC *; 

SONY is a registered trademark of Sony Group Corporation. 

Names of Sony products and services are the registered trademarks and/or trademarks of Sony Group Corporation or its Group companies. 

Other company names and product names are registered trademarks and/or trademarks of the respective companies. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/13/2023 | Document No. 606911 | PAGE Page 97 of 97 * PUBLIC *; 

Cautionary Statement 

Statements made in this presentation with respect to Sony’s current plans, estimates, strategies and beliefs and other statements that are not historical facts are forward-looking statements about the future performance of Sony. Forward-looking 

statements include, but are not limited to, those statements using words such as “believe,” “expect,” “plans,” “strategy,” “prospects,” “forecast,” “estimate,” “project,” “anticipate,” “aim,” “intend,” “seek,” “may,” “might,” “could” or “should,” and words of 

similar meaning in connection with a discussion of future operations, financial performance, events or conditions. From time to time, oral or written forward-looking statements may also be included in other materials released to the public. These 

statements are based on management’s assumptions, judgments and beliefs in light of the information currently available to it. Sony cautions investors that a number of important risks and uncertainties could cause actual results to differ materially 

from those discussed in the forward-looking statements, and therefore investors should not place undue reliance on them. Sony adopted International Financial Reporting Standards (IFRS) starting in the three months ended June 30, 2021, in lieu of the 

previously applied generally accepted accounting principles in the United States (U.S. GAAP). Investors also should not rely on any obligation of Sony to update or revise any forward-looking statements, whether as a result of new information, future 

events or otherwise. Sony disclaims any such obligation. Risks and uncertainties that might affect Sony include, but are not limited to: 

(i) Sony’s ability to maintain product quality and customer satisfaction with its products and services; 

(ii) Sony’s ability to continue to design and develop and win acceptance of, as well as achieve sufficient cost reductions for, its products and services, including image sensors, game and network platforms, smartphones and televisions, which are 

offered in highly competitive markets characterized by severe price competition and continual new product and service introductions, rapid development in technology and subjective and changing customer preferences; 

(iii) Sony’s ability to implement successful hardware, software, and content integration strategies, and to develop and implement successful sales and distribution strategies in light of new technologies and distribution platforms; 

(iv) the effectiveness of Sony’s strategies and their execution, including but not limited to the success of Sony’s acquisitions, joint ventures, investments, capital expenditures, restructurings and other strategic initiatives; 

(v) changes in laws, regulations and government policies in the markets in which Sony and its third-party suppliers, service providers and business partners operate, including those related to taxation, as well as growing consumer focus on 

corporate social responsibility; 

(vi) Sony’s continued ability to identify the products, services and market trends with significant growth potential, to devote sufficient resources to research and development, to prioritize investments and capital expenditures correctly and to 

recoup its investments and capital expenditures, including those required for technology development and product capacity; 

(vii) Sony’s reliance on external business partners, including for the procurement of parts, components, software and network services for its products or services, the manufacturing, marketing and distribution of its products, and its other business 

operations; 

(viii) the global economic and political environment in which Sony operates and the economic and political conditions in Sony’s markets, particularly levels of consumer spending; 

(ix) Sony’s ability to meet operational and liquidity needs as a result of significant volatility and disruption in the global financial markets or a ratings downgrade; 

(x) Sony’s ability to forecast demands, manage timely procurement and control inventories; 

(xi) foreign exchange rates, particularly between the yen and the U.S. dollar, the euro and other currencies in which Sony makes significant sales and incurs production costs, or in which Sony’s assets, liabilities and operating results are 

denominated; 

(xii) Sony’s ability to recruit, retain and maintain productive relations with highly skilled personnel; 

(xiii) Sony’s ability to prevent unauthorized use or theft of intellectual property rights, to obtain or renew licenses relating to intellectual property rights and to defend itself against claims that its products or services infringe the intellectual property 

rights owned by others; 

(xiv) the impact of changes in interest rates and unfavorable conditions or developments (including market fluctuations or volatility) in the Japanese equity markets on the revenue and operating income of the Financial Services segment; 

(xv) shifts in customer demand for financial services such as life insurance and Sony’s ability to conduct successful asset liability management in the Financial Services segment; 

(xvi) risks related to catastrophic disasters, geopolitical conflicts, pandemic disease or similar events; 

(xvii) the ability of Sony, its third-party service providers or business partners to anticipate and manage cybersecurity risk, including the risk of unauthorized access to Sony’s business information and the personally identifiable information of its 

employees and customers, potential business disruptions or financial losses; and 

(xviii) the outcome of pending and/or future legal and/or regulatory proceedings. 

Risks and uncertainties also include the impact of any future events with material adverse impact. The continued impact of COVID-19 and developments relating to the situation in Ukraine and Russia could heighten many of the risks and uncertainties 

noted above. Important information regarding risks and uncertainties is also set forth in Sony’s most recent Form 20-F, which is on file with the U.S. Securities and Exchange Commission.