EXHIBIT A

Case 3:22-cv-00686-X Document 25-1 Filed 06/22/22 Page 1 of 4 PageID 633
Independent Claims Asserted in Patent No. 10,188,940

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 supplying user inputs to a 

computer program for controlling the 

computer program...”

Not inventive as it merely describes a 

videogame controller.

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

videogame controller.

“at least one depressible trigger 

mechanism...”

Not inventive as it merely describes a 

videogame controller.

“and a mechanism for manual adjustment of a 

range of motion of the at least one trigger 

mechanism, the mechanism being disposed 

within an internal volume defined by the 

outer case 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.

Claim 2

Element Defendant’s Response

“An apparatus for supplying user inputs to a 

computer program for controlling the 

computer program,...”

Not inventive as it merely describes a 

videogame controller.

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

videogame controller.

“at least one depressible trigger 

mechanism...”

Not inventive as it merely describes a 

videogame controller.

“and a first mechanism for adjusting a first 

end stop position of a range of motion of the 

Either (1) limiting the claim to an adjustable 

mechanism, which Defendant did not 

Case 3:22-cv-00686-X Document 25-1 Filed 06/22/22 Page 2 of 4 PageID 634
at least one depressible trigger mechanism, 

the first mechanism being disposed within an 

internal volume defined by the outer case of 

the apparatus.”

infringe, or (2) encompassing every possible 

trigger stop, and thus subject to Alice.

Claim 4

Element Defendant’s Response

“A game controller for controlling electronic 

games,...”

Not inventive as it merely describes a 

videogame controller.

“including 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 being in 

operational association with electrical 

circuitry contained within the housing, which 

electrical circuitry is controlled by depression 

of the at least one depressible trigger for 

manipulating electrical outputs of the 

electrical circuitry for the controlling 

electronic games...”

Not inventive as it merely describes a 

videogame controller.

“the game controller having a mechanism 

which provides for manual adjustment of a 

depressible range of the at least one 

depressible trigger mechanism.”

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 5

Element Defendant’s Response

“An apparatus for supplying user inputs to a 

computer program for controlling the 

computer program,...”

Not inventive as it merely describes a 

videogame controller.

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

videogame controller.

“at least one depressible trigger 

mechanism,...”

Not inventive as it merely describes a 

videogame controller.

“and a trigger adjustment system that allows 

for manual adjustment of a range of motion of 

the at least one trigger mechanism, the trigger 

adjustment system being disposed within an 

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 25-1 Filed 06/22/22 Page 3 of 4 PageID 635
internal volume defined by the outer case of 

the apparatus.”

Claim 6

Element Defendant’s Response

“An apparatus for supplying user inputs to a 

computer program for controlling the 

computer program,...”

Not inventive as it merely describes a 

videogame controller.

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

videogame controller.

“at least one depressible trigger 

mechanism,...”

Not inventive as it merely describes a 

videogame controller.

“and a stop adjustably positioned to engage 

the at least one depressible trigger 

mechanism, the stop being disposed within an 

internal volume of the outer case.”

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 8

Element Defendant’s Response

“A game controller for controlling electronic 

games,...”

Not inventive as it merely describes a 

videogame controller.

“including 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 being in 

operational association with electrical 

circuitry contained within the housing, which 

electrical circuitry is controlled by depression 

of the at least one depressible trigger for 

manipulating electrical outputs of the 

electrical circuitry for controlling electronic 

games and”

Not inventive as it merely describes a 

videogame controller.

“the game controller having a trigger 

adjustment system that allows for the manual 

adjustment of a depressible range of the at 

least one depressible trigger mechanism.”

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 25-1 Filed 06/22/22 Page 4 of 4 PageID 636