Exhibit B to the Complaint

1

U.S. Patent No. 9,300,723 v. Activision Publishing, Inc.

Claims 22, 24, 29, 30.

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 1 of 54 PageID #: 21
Exhibit B to the Complaint

2

1. Claim Chart

Claim Analysis

[22.P] A 

method of 

transferring a 

media file from 

a wireless

mobile device 

to a media 

system over a 

communication 

network, the 

media system 

including a 

security 

measure, 

comprising:

Activision Publishing, Inc. (“Company”) performs and/or induces others to perform a method of transferring a media 

file from a wireless mobile device to a media system over a communication network, the media system including a 

security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Company provides Call of Duty: Modern Warfare III, an internet-based game featuring Voice Chat

in which the player and his friends communicate with each other. Call of Duty: Modern Warfare III is accessible on 

both PC and laptop, with the game installed on both the player's PC or laptop (“media system”) and his friend’s PC or 

laptop (“wireless mobile device”). The player’s PC or laptop receives voice chats (“media file”) from his friend’s PC 

or laptop through a network connection (“communication network”). To communicate through voice chat, both the 

player and his friend need to log in (“security measure”) to the Call of Duty account.

Source: https://www.callofduty.com/

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 2 of 54 PageID #: 22
Exhibit B to the Complaint

3

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 3 of 54 PageID #: 23
Exhibit B to the Complaint

4

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:30 (annotated)

media system

click on 

social

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 4 of 54 PageID #: 24
Exhibit B to the Complaint

5

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:33 (annotated)

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:36 (annotated)

media system 

click on add 

friends

player enter 

friend’s Activision 

ID and custom 

message to send 

friend request

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 5 of 54 PageID #: 25
Exhibit B to the Complaint

6

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17 (annotated)

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 6 of 54 PageID #: 26
Exhibit B to the Complaint

7

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 7 of 54 PageID #: 27
Exhibit B to the Complaint

8

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

wireless mobile 

device transfers 

media file

media 

system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 8 of 54 PageID #: 28
Exhibit B to the Complaint

9

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 9 of 54 PageID #: 29
Exhibit B to the Complaint

10

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Source: 

https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt

(annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

security 

measure of 

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 10 of 54 PageID #: 30
Exhibit B to the Complaint

11

[22.1] 

disposing the 

media system 

in an accessible 

relation to at

least one 

interactive 

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said

at least one 

interactive 

computer 

network, 

wherein the

wireless 

mobile device 

within said 

wireless range,

wherein said 

wireless 

mobile device 

is detectable by 

said

media system,

Company performs and/or induces others to perform the step of disposing the media system in an accessible relation 

to at least one interactive computer network that has a wireless range structured to permit authorized access to said at 

least one interactive computer network, wherein the wireless mobile device within said wireless range, wherein said 

wireless mobile device is detectable by said media system.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, Call of Duty: Modern Warfare is accessible on both PC and laptop, with the game installed on the player's 

PC or laptop (“media system”). Players engage in communication with their friends through the Voice Chat feature. 

When a player utilizes Voice Chat, their voice chats are transmitted from their PC or laptop to the friend’s PC or laptop 

via a wireless internet connection (“interactive computer network”). Given that players need to connect to a wireless 

internet connection for both playing the game and engaging in voice chat communication, it is apparent that the player's 

PC or laptop maintains an accessible relationship with the interactive computer network. 

Further, the player logs in to the router by entering its login credentials (“authorized access”) on its PC or laptop for 

establishing a wireless internet connection (“interactive computer network”). As wireless routers inherently possess a 

specified range, therefore, it is apparent to a person having ordinary skill in the art that a wireless range is structured to 

permit authorized access to at least one interactive computer network.

Furthermore, the player adds his friends to his friend list so that he can communicate with them through voice chat. 

Subsequently, during gameplay, the friend’s PC or laptop (“wireless mobile device”) transmits voice chats to the 

player’s PC or laptop (“media system”) through the established wireless internet connection. Given that wireless routers 

have a defined range and the player's PC or laptop connects to it before initiating an internet connection, it follows that 

the player's PC or laptop communicates with its friend’s PC or laptop. Therefore, upon information and belief, the 

friend’s PC or laptop is disposed within said wireless range and it is detectable by the player’s PC or laptop.

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 11 of 54 PageID #: 31
Exhibit B to the Complaint

12

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:30 (annotated)

media system

click on 

social

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 12 of 54 PageID #: 32
Exhibit B to the Complaint

13

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:33 (annotated)

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:36 (annotated)

player click on 

add friends

player enter 

friend’s Activision 

ID and custom 

message to send 

friend request

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 13 of 54 PageID #: 33
Exhibit B to the Complaint

14

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 14 of 54 PageID #: 34
Exhibit B to the Complaint

15

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii (annotated)

interactive 

computer 

network

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 15 of 54 PageID #: 35
Exhibit B to the Complaint

16

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 16 of 54 PageID #: 36
Exhibit B to the Complaint

17

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[22.2] initially 

disposing at 

least one digital 

media file on 

the

wireless 

mobile device, 

said media 

system being 

structured to 

detect said 

wireless 

mobile device 

disposed

within said 

wireless range,

Company performs and/or induces others to perform the step of initially disposing at least one digital media file on the 

wireless mobile device, said media system being structured to detect said wireless mobile device disposed within said 

wireless range.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, both player’s PC or laptop and his friend’s PC or laptop communicate with each other using voice chat. 

The friend’s PC or laptop ("wireless mobile device") records (“initially disposed”) the voice chats (“digital media file”). 

Therefore, it would be apparent to a person having ordinary skill in the art that the player’s PC or laptop (“media 

system”) is structured to detect its friend’s PC or laptop (“wireless mobile device”). Since, both player and his friend’s 

PC or laptop devices are connected to the wireless router having a defined range therefore, upon information and belief, 

the friend’s PC or laptop is disposed within said wireless range.

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

digital 

media file

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 17 of 54 PageID #: 37
Exhibit B to the Complaint

18

Source: https://support.activision.com/articles/call-of-duty-voice-chat-moderation

Source: https://gamerant.com/call-of-duty-modern-warfare-3-ai-voice-chat-moderation/

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 18 of 54 PageID #: 38
Exhibit B to the Complaint

19

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 19 of 54 PageID #: 39
Exhibit B to the Complaint

20

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

(annotated)

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 20 of 54 PageID #: 40
Exhibit B to the Complaint

21

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:30 (annotated)

media system

click on 

social

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 21 of 54 PageID #: 41
Exhibit B to the Complaint

22

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:33 (annotated)

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:36 (annotated)

player click on 

add friends

player enter 

friend’s Activision 

ID and custom 

message to send 

friend request

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 22 of 54 PageID #: 42
Exhibit B to the Complaint

23

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[22.3] 

structuring a 

communication 

link to dispose 

said media

system and said 

wireless 

mobile device 

in a 

communicative relation 

with one 

another via said 

at least one

interactive 

computer 

network,

Company performs and/or induces others to perform the step of structuring a communication link to dispose said media 

system and said wireless mobile device in a communicative relation with one another via said at least one interactive 

computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, once connected to the wireless internet, the player initiates the login process to their Activision account 

using their PC or laptop (“media system”). This involves entering login credentials such as email and password through 

the wireless internet connection (“one interactive computer network”). Further, the player adds his friend so that he can 

communicate with them through voice chat. Consequently, this procedure establishes a communication channel 

(“structuring a communication link”) between the player's PC or laptop and the friend’s PC or laptop (“wireless mobile 

device”).

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 23 of 54 PageID #: 43
Exhibit B to the Complaint

24

Source: 

https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt

(annotated)

player login to 

player’s 

platform

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 24 of 54 PageID #: 44
Exhibit B to the Complaint

25

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17 (annotated)

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 25 of 54 PageID #: 45
Exhibit B to the Complaint

26

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

wireless 

mobile 

device 

sends media 

file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 26 of 54 PageID #: 46
Exhibit B to the Complaint

27

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

wireless mobile 

device sends 

media file

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 27 of 54 PageID #: 47
Exhibit B to the Complaint

28

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

(annotated)

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 28 of 54 PageID #: 48
Exhibit B to the Complaint

29

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[22.4] initiating 

said 

communication 

link by said 

media system,

Company performs and/or induces others to perform the step of initiating said communication link by said media 

system.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the player adds its friend so that he can communicate with them through voice chat. Consequently, this 

procedure establishes a communication channel between the player's PC or laptop and the friend’s PC or laptop 

(“initiating said communication link by said media system”).

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 29 of 54 PageID #: 49
Exhibit B to the Complaint

30

Source: 

https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt

(annotated)

player login to 

player’s 

platform

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 30 of 54 PageID #: 50
Exhibit B to the Complaint

31

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:30 (annotated)

media system

click on 

social

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 31 of 54 PageID #: 51
Exhibit B to the Complaint

32

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:33 (annotated)

Source: https://www.youtube.com/watch?v=3-6htQc3-bQ at 0:36 (annotated)

player click on 

add friends

player enter 

friend’s Activision 

ID to add friend

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 32 of 54 PageID #: 52
Exhibit B to the Complaint

33

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

media file

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 33 of 54 PageID #: 53
Exhibit B to the Complaint

34

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

(annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[22.5] 

transmitting by 

said wireless 

mobile device 

to the media

system said at 

least one digital 

media file 

therebetween

via said 

communication 

link, and

Company performs and/or induces others to perform the step of transmitting by said wireless mobile device to the 

media system said at least one digital media file therebetween via said communication link.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, both the player and his friend communicate with each other using voice chat during gameplay. The 

friend’s PC or laptop ("wireless mobile device") sends the voice chat (“digital media file”) to the player’s PC or laptop 

(“media system”).

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 34 of 54 PageID #: 54
Exhibit B to the Complaint

35

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

digital 

media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 35 of 54 PageID #: 55
Exhibit B to the Complaint

36

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

digital 

media file

media system

wireless mobile 

device

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 36 of 54 PageID #: 56
Exhibit B to the Complaint

37

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[22.6] wherein 

said 

communication 

link is 

structured to 

bypass

the security 

measure of the 

Company performs and/or induces others to perform the step of wherein said communication link is structured to bypass 

the security measure of the media system for a limited permissible use of the communication link by the wireless mobile 

device for only transferring the at least one digital media file to, and displaying the at least one digital media file on, 

the media system.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the player’s PC or laptop ("media system") and the friend’s PC or laptop initially requires to enter login 

credentials such as username and a password ("security measure") for login into Activision server. The server does not 

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 37 of 54 PageID #: 57
Exhibit B to the Complaint

38

media system 

for a limited

permissible use 

of the 

communication 

link by the wire

less mobile 

device for only 

transferring the 

at least one

digital media 

file to, and 

displaying the 

at least one

digital media 

file on, the 

media system.

require both player and his friend to input the email and password ("security measure") every time they communicate. 

Instead, the email and password input are necessary during the initial connection process, and thereafter, both player 

and his friend’s PC or laptop automatically exchanges data without requiring users to re-enter the email and password 

("bypass at least one media terminal security measure"). Therefore, upon information and belief, the communication 

link is structured to bypass at least one media terminal security measure. Furthermore, the friend’s PC or laptop utilizes 

the communication channel exclusively for transmitting the voice chats to the player’s PC or laptop (“bypass the 

security measure of the media system for a limited permissible use of the communication link by the wireless mobile 

device for only transferring the at least one digital media file”).

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 38 of 54 PageID #: 58
Exhibit B to the Complaint

39

Source: 

https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt

(annotated)

security 

measure of 

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 39 of 54 PageID #: 59
Exhibit B to the Complaint

40

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17 (annotated)

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 40 of 54 PageID #: 60
Exhibit B to the Complaint

41

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

digital 

media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 41 of 54 PageID #: 61
Exhibit B to the Complaint

42

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[24] The 

method of 

claim 22, 

wherein the 

transmission of 

the at least one 

digital media 

file from the 

wireless 

mobile

device to the 

media system 

Company performs and/or induces others to perform the step of transmission of the at least one digital media file from 

the wireless mobile device to the media system completely bypasses the security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the player’s PC or laptop ("media system") and the friend’s PC or laptop (“wireless mobile device”) are 

not required to input the email and password ("security measure") every time they communicate. Instead, the email and 

password input are necessary during the initial connection process, and thereafter, the platforms automatically exchange 

data without requiring users to re-enter the email and password. The friend’s PC or laptop transmits the voice chats to 

the player’s PC or laptop (“bypass the security measure”). Therefore, upon information and belief, the channel created 

between the player’s PC or laptop and the friend’s PC or laptop bypass the security measure.

digital media file

transfers and 

displays on the 

media system

media 

system

wireless mobile 

device

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 42 of 54 PageID #: 62
Exhibit B to the Complaint

43

completely 

bypasses the 

security 

measure.

Source: 

https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt

(annotated)

security 

measure of 

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 43 of 54 PageID #: 63
Exhibit B to the Complaint

44

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17 (annotated)

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 44 of 54 PageID #: 64
Exhibit B to the Complaint

45

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

digital 

media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 45 of 54 PageID #: 65
Exhibit B to the Complaint

46

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[27] The 

method of 

claim 22, 

wherein the 

communication 

link is at least 

one of a peerto-peer 

connection, 

bluetooth 

connection, 

Company performs and/or induces others to perform the step of the communication link is at least one of a peer-topeer connection, bluetooth connection, and a WiFi connection.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the friend’s PC or laptop transmits the voice chats to the player’s PC or laptop using the wireless internet 

connection (“WiFi connection”).

digital media file

transfers to the 

media system

media 

system

wireless mobile 

device

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 46 of 54 PageID #: 66
Exhibit B to the Complaint

47

and a WiFi 

connection.

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 47 of 54 PageID #: 67
Exhibit B to the Complaint

48

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 48 of 54 PageID #: 68
Exhibit B to the Complaint

49

Source: https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[29] The 

method of 

claim 22, 

further 

comprising 

presenting the 

at least one 

digital media 

file on a 

display.

Company performs and/or induces others to perform the step of presenting the at least one digital media file on a 

display.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the player’s PC or laptop plays and displays (“presenting”) the received voice chats (“digital media file”).

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

presenting the at 

least one digital 

media file on the 

media system

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 49 of 54 PageID #: 69
Exhibit B to the Complaint

50

Source: https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[30] The 

method of 

claim 22, 

wherein the at 

least one digital 

media file is 

provided by the 

wireless 

mobile device.

Company performs and/or induces others to perform the step of at least one digital media file is provided by the wireless 

mobile device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the friend’s PC or laptop (“wireless mobile device") transmits the voice chats (“at least one digital media 

file”) to the player’s PC or laptop.

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 50 of 54 PageID #: 70
Exhibit B to the Complaint

51

Source: https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-gettingstarted-guide

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:17 (annotated)

wireless mobile 

device

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 51 of 54 PageID #: 71
Exhibit B to the Complaint

52

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 0:30 (annotated)

digital 

media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 52 of 54 PageID #: 72
Exhibit B to the Complaint

53

Source: https://www.youtube.com/watch?v=FQNQUfAFVuE at 1:26 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

wireless mobile 

device transfers 

digital media file

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 53 of 54 PageID #: 73
Exhibit B to the Complaint

54

2. List of References

1. https://www.callofduty.com/, last accessed on December 22, 2023.

2. https://support.activision.com/modern-warfare-iii/articles/pc-system-requirements-for-modern-warfare-iii, last accessed on 

December 22, 2023.

3. https://support.activision.com/modern-warfare-iii/articles/connecting-to-modern-warfare-iii, last accessed on December 22, 

2023.

4. https://www.callofduty.com/guides/getting-started/call-of-duty-modern-warfare-iii-play-guides-getting-started-guide, last 

accessed on December 22, 2023.

5. https://support.activision.com/articles/call-of-duty-voice-chat-moderation, last accessed on December 22, 2023.

6. https://profile.callofduty.com/cod/login?redirectUrl=https%3A%2F%2Fwww.callofduty.com%2F&promo=jpt, last accessed 

on December 22, 2023.

7. https://www.youtube.com/watch?v=FQNQUfAFVuE, last accessed on December 22, 2023.

Case 2:24-cv-00043-JRG-RSP Document 1-2 Filed 01/24/24 Page 54 of 54 PageID #: 74