EXHIBIT B

Case 3:22-cv-00686-X Document 25-2 Filed 06/22/22 Page 1 of 4 PageID 637
Independent Claims Asserted in Patent No. 10,596,455

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 resiliently 

biased to a first position...”

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; and...”

Not inventive as it merely describes a 

videogame controller.

“a mechanism for adjustment of a range of 

motion of the at least one 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.

“wherein, the mechanism is configured to be 

inserted into a void behind the inner surface 

of the depressible trigger wherein the void is 

defined by the outer case, and...”

Not inventive as it merely describes a trigger 

stop.

“wherein the mechanism is configured such 

that when the mechanism is inserted, the 

inner surface of the depressible trigger 

Not inventive as it merely describes a trigger 

stop.

Case 3:22-cv-00686-X Document 25-2 Filed 06/22/22 Page 2 of 4 PageID 638
contacts the mechanism to adjust the range of 

motion of the depressible trigger by changing 

a degree of rotation of the depressible 

trigger.”

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 configured to adjust a range of 

motion of a 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.

“wherein the depressible trigger comprises a 

first surface located outside an outer case of 

the apparatus and a second surface opposite 

the first surface, the second surface 

configured to move into a volume defined by 

the outer case when the trigger is 

depressed,...”

Not inventive as it merely describes a trigger 

stop.

“wherein the trigger stop is disposed within 

the volume defined by the outer case of the 

apparatus and in a pathway of the second 

surface of the depressible trigger and,...”

Not inventive as it merely describes a trigger 

stop.

“wherein the trigger stop is configured to 

engage the inner surface of the depressible 

trigger of the apparatus to adjust a range of 

motion of the depressible trigger.”

Not inventive as it merely describes a trigger 

stop.

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.

“at least one depressible trigger at least in part 

exposed relative to the housing,...”

Not inventive as it merely describes a 

videogame controller.

“At least one depressible trigger at least 

partially disposed within the housing 

comprising a first surface configured to be 

Not inventive as it merely describes a trigger 

stop.

Case 3:22-cv-00686-X Document 25-2 Filed 06/22/22 Page 3 of 4 PageID 639
engaged by a user to depress the at least one 

trigger and a second surface opposite the first 

surface, the second surface defining a 

pathway when the at least one trigger is 

depressed;”

“electrical circuitry contained within the 

housing, wherein the at least one depressible 

trigger is in operational association with the 

electrical circuitry such that depression of the 

at least one depressible trigger causes 

electrical outputs of the electrical circuity to 

control operation of the electronic game; and”

Not inventive as it merely describes a 

videogame controller.

“a trigger adjustment system disposed within 

the housing in the pathway of the second 

surface of the at least depressible trigger and 

in communication with the at least one 

depressible trigger, the trigger adjustment 

system configured to adjust a range of 

depressible motion of the at least one 

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 25-2 Filed 06/22/22 Page 4 of 4 PageID 640