EXHIBIT C

Case 3:22-cv-00686-X Document 25-3 Filed 06/22/22 Page 1 of 4 PageID 641
Independent Claims Asserted in Patent No. 11,185,766

Specification

Summary of Invention Defendant’s Response

“The present invention seeks to improve upon 

or at least mitigate some of the problems 

associated with controllers of the prior art by 

providing a game controller which includes 

an adjustable trigger system that has a 

mechanism to allow the end user to control or 

recalibrate the maximum and/or minimum 

trigger positions.”

Either (1) limiting the claims to an adjustable 

mechanism, which Defendant did not 

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

Claim 1

Element Defendant’s Response

“An apparatus for providing a user input to a

computer program for controlling the

computer program, the apparatus

comprising...”

Not inventive as it merely describes a 

videogame controller.

“an outer case,...” Not inventive as it merely describes a 

videogame controller.

“At least one depressible trigger pivotally 

mounted to the apparatus and biased to a 

resting position when the depressible trigger 

is not activated,”

Not inventive as it merely describes a 

videogame controller.

“the depressible trigger having an outer 

surface configured for engagement during 

operation and extending outside the outer 

case, and an inner surface opposite the outer 

surface, wherein the inner surface defines a 

travel path in response to an activation of the 

depressible trigger, and...”

Not inventive as it merely describes a trigger 

stop.

“A mechanism extending from a plane 

different from the plane of the travel path into 

a void behind the inner surface of the 

depressible trigger, wherein the void is 

defined by the outer case, the mechanism 

configured to adjust a length of the travel path 

of the depressible trigger.”

Either (1) limiting the claim to an adjustable 

mechanism, which Defendant did not 

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

Case 3:22-cv-00686-X Document 25-3 Filed 06/22/22 Page 2 of 4 PageID 642
Claim 12

Element Defendant’s Response

“A trigger stop for use in an apparatus for 

supplying user inputs to a computer program 

for controlling the computer program, the 

trigger stop comprising:...”

Not inventive as it merely describes a trigger 

stop.

“a stop mechanism configured to adjust a 

range of motion of a depressible trigger of the 

apparatus,...”

Either (1) limiting the claim to an adjustable 

mechanism, which Defendant did not 

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

“wherein the depressible trigger comprises: A 

first surface located outside an outer case of 

the apparatus, the first surface configured to 

provide an engagement surface for the user to 

activate the depressible trigger, and”

Not inventive as it merely describes a 

videogame controller.

“a second surface opposite the first surface, 

the second surface configured to define a 

pathway in a volume defined by the outer 

case when the trigger is activated, wherein the 

stop mechanism is disposed within the 

volume defined by the outer case of the 

apparatus, and...”

Not inventive as it merely describes a trigger 

stop.

“wherein the stop mechanism extends into the 

pathway of the second surface along plane 

different from the plane of the pathway to 

adjust the range of motion of the depressible 

trigger.”

Either (1) limiting the claim to an adjustable 

mechanism, which Defendant did not 

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

Claim 17

Element Defendant’s Response

“A game controller for controlling an 

electronic game, the game controller 

comprising:”

Not inventive as it merely describes a 

videogame controller.

“a housing,...” Not inventive as it merely describes a 

videogame controller.

“a pivoting trigger at least partially disposed 

within the housing, the trigger comprising a 

first surface configured to be engaged by a 

user to depress the trigger and a second 

surface opposite the first surface, the second 

Not inventive as it merely describes a trigger 

stop.

Case 3:22-cv-00686-X Document 25-3 Filed 06/22/22 Page 3 of 4 PageID 643
surface defining a pathway when the trigger 

is depressed...”

“electrical circuitry contained within the 

housing, wherein the trigger is in operational 

association with the electrical circuitry such 

that depression of the trigger causes electrical 

outputs of the electrical circuitry to control 

operation of the electronic game; and...”

Not inventive as it merely describes a 

videogame controller.

“a trigger stop disposed within the housing in 

the pathway of the second surface of the 

trigger, the trigger stop disposed along plane 

different from the plane of the pathway, the 

trigger stop configured to change a range of 

depressible motion of the trigger.”

Either (1) limiting the claim to an adjustable 

mechanism, which Defendant did not 

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

Case 3:22-cv-00686-X Document 25-3 Filed 06/22/22 Page 4 of 4 PageID 644