blizzard – Patent Arcade

May

2020

Blizzard Takes New Stance on Custom Game IP

Following the release of the remastered edition of Blizzard Entertainment’s classic real-time strategy game “Warcraft 3” as “Warcraft 3: Reforged,” Blizzard also updated its Custom Game Acceptable Use Policy. There were two notable changes to this policy that has caused a reaction among long-time fans of the franchise.

The new policy bans any custom games that use copyright material. This is not an unusual requirement in games which permit users to submit in-game modifications, but fans have reacted negatively to the change given the history of Warcraft 3. Originally, Warcraft 3’s map editor was heralded as revolutionary, as it allowed users to creative complex and breathtaking scenarios using the Warcraft 3 engine. Warcraft 3’s map editor also allowed users to modify the textures of the game, and users quickly began to add content from their favorite franchises, such as Super Mario, Dragon Ball Z, and Lord of the Rings. While Blizzard’s approach to protect itself from intellectual property infringement liability is not surprising, it is notable that when Warcraft 3: Reforged was announced at Blizzcon a few years ago, it was announced that all custom maps compatible with the original game (that is, Warcraft 3) would be playable in the remastered version of the game (that is, in Warcraft 3: Reforged). In practice, users’ experiences have been quite different: any users that dare play maps comprising content from other franchises (e.g., Nintendo games) is swiftly banned, even if those maps had previously been playable in Warcraft 3.

Furthermore, the much larger issue that has drawn the ire of Blizzard fans online has been the change to Blizzard’s policy detailing the ownership of custom games in the Warcraft 3: Reforged engine. According to the new policy, all custom games created in Warcraft 3: Reforged belong to Blizzard, not the creators. In the same vein, Blizzard has stated that they own an instant and total copyright ownership of all custom games created in Warcraft 3: Reforged. While this move is also unsurprising, it does mark a distinct shift from Blizzard’s more relaxed attitude with respect to original Warcraft 3 custom games.

The latter policy change may be the direct result of the overwhelming success of the Defense of the Ancients custom games in Warcraft 3, which later became the wildly successful stand-alone MOBA games Dota 2 and League of Legends. Because Blizzard did not maintain a property right over the original Defense of the Ancients custom games, competing developers Valve and Riot Games both made monumental profits from these games while Blizzard was left with nothing. Going forward, it appears Blizzard does not want to lose out on the battle for new and hugely profitable game designs that emerge using their tools.

While it does not appear any new legal issues will emerge from this change, it will be fascinating to see how video game companies adjust to the new IPs their games create and how they can try to monetize the inventions they helped make possible.

Sep

2019

Dynamic and Nonliteral Elements Win Protection in Blizzard Copyright Suit

MDY Industries, LLC v. Blizzard Entertainment, Inc. and Vivendi Games, Inc.
629 F.3d 928 (9th Cir. 2010)

For those who followed our series of posts on this case, here is our final write-up and combination of analysis into a full write-up.

The case between MDY and Blizzard focused on the video game World of Warcraft (WoW). World of Warcraft is Blizzard’s incredibly popular massively multiplayer online role-playing game (MMORPG). In this game players must complete various quests such as collecting materials or defeating monsters. Through the completion of these in-game tasks a player’s character is able to gain experience and new skills and abilities. MDY and its creator Michael Donnelly, created a software bot called Glider which plays World of Warcraft for its users. This allowed Glider owners to progress their World of Warcraft characters while they were unattended.

In a suit filed with the U.S. District Court for the District of Arizona, MDY sought a declaratory judgment that the Glider bot did not infringe upon Blizzard’s rights. In response Blizzard counterclaimed and third-party complained seven claims:

Tortious interference with contract;
Contributory copyright infringement;
Vicarious copyright infringement;
Violation of the Digital Millennium Copyright Act (DMCA);
Trademark infringement;
Unfair competition; and
Unjust enrichment

On July 14, 2008, Judge Campbell for the U.S. District Court granted and denied in part the parties’ motions for summary judgment. Summary judgment was granted in favor of Blizzard with regard to MDY’s liability for tortious interference, contributory copyright infringement, and vicarious copyright infringement. On the other hand, the Court granted summary judgment in favor of MDY on part of the DMCA claim and on the unfair competition claim.

In its analysis of Blizzard’s contributory copyright infringement claims, the Court first looked at whether purchasers of World of Warcraft were legal “owners” of the client software. Under 17 U.S.C. § 117, owners of computer programs are allowed to create copies or adaptations of the computer program if it is an essential step towards utilization of the program. In the end the Court agreed with Blizzard’s arguments that World of Warcraft purchasers were only licensees of the game. As such players would be required to make use of the game within the scope of the End User License Agreement (EULA). In the EULA Blizzard specifically prohibits “the use of bots or third-party software to modify the WoW experience.”

The District Court further held that the ban on botting was related to Blizzard’s copyright interest and thus any users of Glider were infringing Blizzard’s copyright when they played World of Warcraft in violation of their limited license. Because MDY encouraged and profited from this infringement they could be found secondarily liable for this infringement.

A DMCA violation also occurred where the Glider program circumvented Blizzard’s anti-cheat program Warden. Warden is a security application that controls access to the game.

On December 14, 2010, MDY appealed this judgment to the Ninth Circuit Court of Appeals. In the Court’s ruling, the summary judgment against MDY for contributory copyright infringement was reversed. The Court stated, “for a licensee’s violation of a contract to constitute copyright infringement, there must be a nexus between the condition and the licensor’s exclusive rights of copyright. Here WoW players do not commit copyright infringement by using Glider in violation of the [terms of use].”

This analysis was based on a Federal Circuit case, Chamberlain v. Skylink, 381 F.3d 1178 (Fed. Cir. 2004), which stated there must be a nexus between access and the copyright infringement at issue. As such the Ninth Circuit declined to follow Chamberlain and upheld the judgment that MDY violated the provisions of the DMCA which prohibit the trafficking in copyright circumvention technologies. This was specifically applied to the dynamic nonliteral elements of World of Warcraft. Players already had access to the literal elements of WoW when it was copied to their hard drives. However, the nonliteral and dynamic elements can only be experienced live on the game’s servers and this access is controlled by the Warden program. As such, MDY was found in violation of the DMCA in this manner and the permanent injunction against MDY to prevent future DMCA § 1201(a) violations was affirmed. Blizzard was unable to prevail on their § 1201(b)(1) claim though as they could not prove that Warden “effectively protects a right” of Blizzard under the Copyright Act.

Finally, the summary judgment for tortious contract interference was vacated and remanded to the district court for further consideration because the law standard when viewing all the facts was not met as there were outstanding issues of material fact.

In an attempt for further rehearing of the case MDY attempted to assert Glider was an “independently created computer program” which would exempt it from § 1201(a). However, because this issue was not raised at the district court or presented in the parties’ briefs on appeal the Court declines to hear it. Thus, the motion for panel rehearing was denied and no further petition for rehearing will be entertained by the Court.

This case notably extended copyright protection to the dynamic nonliteral elements of a computer program while also declining to require a nexus between potential DMCA violations and copyright infringement. Previously, running a computer program on a device copied the program to a user’s RAM which similarly removed some of the copyright owner’s protection in the program. However, in copyright of the dynamic nonliteral elements, Blizzard was able to retain control and rights over World of Warcraft despite the literal elements being copied to a user’s device upon use.

Jul

2019

Heroes Charge into Copyright Battle

Blizzard Entertainment, Inc. and Valve Corporation v. Lilith Games (Shanghai) Co. Ltd. and uCool, Inc.,
United States District Court of the Northern District of California, 2018
Case No, 15-cv-04084-CRB

Video game developers Blizzard Entertainment, Inc. and Valve Corporation sued Lilith Games Co. Ltd and uCool, Inc. for copyright infringement under 17 U.S.C. § 101 in a complaint filed September 8, 2015. The case was brought in the United States District Court for the Northern District of California.

Blizzard and Valve are the developers of well-known video games such as World of Warcraft, Starcraft, Diablo, and Dota 2. They allege that Lilith and uCool’s mobile games impermissibly copied the characters, “settings, terrain, background art, and other assets” from Plaintiffs’ video game franchises.

uCool, acting for itself and not Lilith, moved to dismiss Plaintiffs’ Second Claim for Relief, as that was the sole claim against uCool, or alternatively moves for a more definitive statement. Initially, in a decision issued on December 8, 2015, the Court granted uCool’s motion to dismiss with leave to amend.

The Plaintiffs allege that the mobile video games created by Lilith and uCool, “DotA Legends” and “Heroes Charge,” infringe on Plaintiff’s copyrights in the Warcraft Works. In their complaint the Plaintiffs did not expressly specify any allegedly infringing settings, terrain, or art, but they do assert that “almost every one of the hero characters available in the Lilith Games,” which were then copied as well by uCool, are “two-dimensional version[s] of a character either from one of Blizzard’s games” or from Dota 2. Plaintiffs also allege that many of the characters in “Heroes Charge” are substantially similar to Blizzard and Valve’s characters.

In their complaint for relief, Plaintiffs requested that the Court grant, preliminary and permanent injunctions, “monetary relief … including actual damages and/or Defendants’ profits, or statutory damages for copyright infringement and willful copyright infringement under 17 U.S.C. § 504,” and attorneys’ fees.

The District Court first addressed the question of standing. To establish a claim for copyright infringement a plaintiff must plausibly plead two elements: 1) ownership of a valid copyright, and 2) copying of constituent parts of the work that are original. While Lilith and uCool alleged the Plaintiffs lack standing because one or the other might own the specific copyright at issue, the Court concluded that all asserted works are owned by Blizzard or Valve. Similarly, the Plaintiffs identified many allegedly infringed copyrights.

As for the copyrightability of Plaintiffs’ characters, ordinary characters are not generally entitled to copyright protection. The Ninth Circuit has held that “copyright protection is available only ‘for characters that are especially distinctive.’” This standard can be met by showing “sufficiently delineated” and display “consistent, widely identifiable traits.” Generally, the scenes-à-faire doctrine excludes from copyright protection “stock characters and plots in dramatic works.” This doctrine has further been extended to standard or common features in many different works including works generated by computers.

However, in this case Plaintiffs only alleged conclusory statements that their characters were distinctive. The Court did not accept these conclusory allegations because of this lack of specificity as to which elements were distinctive of each character. As such, Plaintiffs failed to meet their burden of alleging copyright ownership in the characters from Warcraft.

Similarly, Plaintiffs widespread allegations against uCool failed to fully provide notice to uCool and the Court as to which “Heroes Charge” characters infringe which characters from Blizzard or Valve’s games. The Court states that Plaintiffs should have provided representative samples of infringed content and plead infringement and ownership with a sufficient level of detail. Without these samples the Court decided it was unable to evaluate the plausibility of Blizzard and Valve’s allegations.

Following the Second Amended Complaint on March 8, 2018, the Court Granted in Part and Denied in Part Lilith’s motion to dismiss with leave to amend and also denied uCool’s motion to dismiss.

The Second Amended Complaint provided much more specific examples of infringed characters in Lilith’s games. Specifically, Lilith’s game “Soul Hunters” which is essentially a newer version of “Dota Legends,” contains a character that could plausibly be seen as infringing on Blizzard’s character “Illidan Stormrage.” As such, with regard to Warcraft characters, Blizzard is able to plausibly allege infringement. However, the Court ruled that the Second Amended Complaint failed to state a plausible claim that “Soul Hunters” infringes Blizzard’s Diablo and Starcraft video games. Thus, those two claims are dismissed with regard to “Soul Hunters” but are still maintained for Lilith’s other games.

In addition, uCool’s motion to dismiss with regard to the Second Amended Complaint was denied. The new complain provided a number of specific and representative examples of infringement with regard to the game “Heroes Charge.” Blizzard’s characters of “Leoric the Skeleton King” and the “Terran Marine” provided concrete examples of characters that were copied into “Heroes Charge.” It is further alleged that uCool had access to Blizzard’s new game “Heroes of the Storm” which provided examples for the characters that were then copied. While uCool argues the game “Heroes of the Storm” was not released until 2015, Blizzard was able to show that test versions of the game were widely available beforehand and thus uCool had access to the allegedly infringed work.

This case has been notable for the developments with regard to copyright in characters in video games. The standard of pleading that the District Court adopts from the Ninth Circuit has been reaffirmed and thus specific and concrete examples of infringement are needed to avoid dismissal of a claim for relief. Even characters such as “Leoric” that typically could fall into a scenes-à-faire defense were able to be copyrighted given specific examples of features that help to delineate the character and increase its level of recognition.

Following the Second Amended Complaint, Lilith filed a response on March 27, 2018. In this response Lilith alleged sixteen affirmative defenses to the alleged copyright infringement. Following this response Blizzard then filed motions to dismiss with prejudice (meaning they cannot refile the case) all claims against uCool and subsequently Lilith as well. While there was no public announcement, the likely result of these filings signify a settlement was reached between all parties involved in the dispute. As is the case in many of these disputes the settlement tempers some of the impact of any potential precedent derived from the many filings in this case. However, valuable lessons regarding copyright in video game characters can be derived from the Second Amended Complain and provide a suggested framework for efficient pleading on this issue in the future.

Nov

2018

Blizzard Entertainment v. Blizzard Sports Center

Blizzard Entertainment, Inc. v. Blizzard Sports Center, Inc., et al
Central District of California
Civil Docket: 8:17-cv-01001-JVS-DFM
Filed 06/09/2017
Decided 11/02/2018

On November 2, 2018, the U.S. District Court of the Central District of California granted Blizzard Entertainment’s motion for default judgment for trademark infringement against Blizzard Sports Center. Blizzard Entertainment (Blizzard) filed the lawsuit against Blizzard Sports Center (BSC) in June of 2017. The district court found there was a likelihood of confusion due to the similarity of the names, the closely related products, and the close geographic proximity of the two companies. The court granted Blizzard an injunction and attorney’s fees.

To succeed with a claim for trademark infringement, a plaintiff must show there is a likelihood consumers will be confused about the source of the two marks. “Blizzard Entertainment” and “Blizzard Sports Center” are very similar marks because both contain the word “Blizzard.” The similarity of marks is not determinative for likelihood of confusion; there are plenty of companies with the same name in different industries. Blizzard primarily sells video games, but it is heavily involved in e-sports. The court felt that e-sports was related enough to physical sports that confusion could arise. Also, BCS’s sports facility is located within a couple of miles of Blizzard’s Irvine, California campus. The close geographic proximity of the two companies weighed heavily against BCS because a consumer might think Blizzard owned the facility. Blizzard also provided evidence of actual consumer confusion.

(Source Google Maps)

A factor in the court’s analysis was BCS’s behavior during the trial. BCS refused to cooperate during the discovery period of litigation and failed to comply with a court order to find new counsel. BCS’s original counsel withdrew around the time the court ordered the company to produce documents. As a corporation, BCS cannot appear before the court Pro Se, so the district court ordered the company to find new lawyers. For whatever reason, BCS did not obtain new counsel which forced the court to find it in default. In the opinion for default judgment, the court mentions several times BCS’s noncompliance. BCS’s behavior does not prove or disprove the trademark infringement claims, but it did not help BCS.

BCS could try to appeal the district court’s decision, but that may not happen considering the company’s actions leading up to the default judgment. We suspect that, based on BCS’s physical proximity to Blizzard and BCS’s lack of any real attempt to try to defend itself in this case, BCS either was trying to benefit from the BLIZZARD mark, or BCS might otherwise have had unclean hands in this matter. We doubt they will pursue this further, but if BCS does appeal, we will provide updates as warranted.

Jul

2018

Striking from the Shadows

Infernal Technology, LLC et al v. Crytek GmbH

United States District Court for the Eastern District of Texas

Docket No. 2-18-cv-00284, filed July 10, 2018

On July 10, 2018, Infernal Technology and Terminal Reality (Infernal) filed a lawsuit in the Eastern District of Texas alleging that Crytek GmbH (Crytek) infringed upon U.S. Patent Nos. 6,362,822 (the ‘822 Patent) and 7,061,488 (the ‘488 Patent). The two patents relate to lighting and shadowing methods in computer graphic simulations.

Image from the ‘822 Patent, Fig. 2.

Claim 1 of the ‘822 Patent reads:

A shadow rendering method for use in a computer system, the method comprising the steps of:

providing observer data of a simulated multi-dimensional scene;

providing lighting data associated with a plurality of simulated light sources arranged to illuminate said scene, said lighting data including light image data;

for each of said plurality of light sources, comparing at least a portion of said observer data with at least a portion of said light data to determine if a modeled point within storing at least a portion of said light image data associated with said point and said light source in a light accumulation buffer; and then

combining at least a portion of said light accumulation buffer with said observer data; and

displaying resulting image data to a computer screen. (‘822 patent, col 12, lines 4-21).

Infernal claims that Crytek’s utilization of video game engine “CryEngine” allegedly infringes the asserted patents. According to the Complaint, Crytek used the allegedly infringing game engine to develop the Crysis series, Warface, Ryse: Son of Rome, The Climb, and Robinson: The Journey.

Typically, the next step for a defendant in this situation is to petition the Patent Trial and Appeal Board (PTAB) for an Inter Partes Review (IPR), but the ‘822 and ‘488 Patents have already survived an IPR because of earlier litigation. In 2015, Infernal sued Electronic Arts for patent infringement. EA responded by petitioning the PTAB for an IPR; however, the PTAB found the ‘822 and ‘488 Patents to be “Not Unpatentable.” EA settled the lawsuit after the PTAB’s decision. Crytek can still petition for an IPR of the asserted patents, but will likely have to use different prior art that the art used by EA or provide a good reason why the Board got it wrong the first time around.

If this seems like deja vu that is because Infernal filed complaints similar to the Crytek Complaint against Microsoft in April and against Activision Blizzard in May. To read our blog post on the Microsoft case click here. We will continue to monitor all three of these cases and provide updates when possible.

May

2018

Case Update: GAT v. Activision Blizzard et al.

Game and Technology v. Activision Blizzard et al., C.D. Cal.,
Case No. 2:16-cv-06499-MLH-SK, Filed August 29, 2016

On March 14, 2018, the Patent Trial and Appeal Board (PTAB) invalidated U.S. Patent No. 8,253,743 (the ‘743 Patent), which Game and Technology (GAT) owns and asserted in this lawsuit. Activision Blizzard, Riot Games, and Valve had petitioned for Inter Partes Review of the ‘743 Patent in response to litigation we had reported on earlier. The ‘743 Patent is related to the layering of items on a character avatar in a video game.

FIG. 5 shows avatars (gamvatars) having a game item function according to an embodiment of the present invention, and it exemplifies gamvatars 530 and 540 generated by combining an avatar 510 which wears clothes purchased at the avatar shop 430 and a game item 520 purchased at the item shop 440. The gamvatar 530 shows the avatar 510 but is arranged in the background layer. As described above, it is possible for the avatar 510 to wear the item 520 or not wear the item 520 depending on the user’s setting. (‘743 patent, col. 6, lines 33-44).

The PTAB found that the ‘743 Patent would have been obvious based on the combined teachings of a Diablo II manual and a 2005 publication of U.S. patent application 2005/0127015 A1 filed August 19, 2004. GAT filed an appeal to the United States Court of Appeals for the Federal Circuit on May 16, 2018.

Earlier, we had reported on Activision Blizzard and Wargaming filing a petition for IPR on another asserted patent, U.S. Patent No. 7,682,243 (the ‘243 Patent). The petition was granted but the PTAB has not yet issued a final written decision in that matter. The Central District of California granted a stay on the original lawsuit until the IPR and the appeals process for the ‘243 and ‘743 Patents have concluded.

In the original lawsuit, GAT claimed the defendants infringed upon three patents. Indeed, Activision had sought an IPR on the third patent, U.S. Patent No. 8,035,649 (the ‘649 Patent). But on February 28, 2017, the PTAB denied instituting a review of the ‘649 Patent. Then, on May 17, 2018, both sides jointly asked the District Court to drop all claims relating to the ‘649 Patent, which the court granted four days later.

As of this writing, the Central District of California case remains stayed until the PTAB and the Federal Circuit determine the validity of the ‘743 and ‘243 Patents, while the claims relating to the ‘649 Patent have been dismissed. We will continue to track any new developments.

May

2018

PTAB Institutes Inter Partes Review of Group Messaging Patent

On May 15, 2018, the Patent Trial and Appeal Board (the “PTAB”) instituted two Inter Partes Review (“IPR”) proceedings against U.S. 5,822,523 (the “’523 Patent”). The ’523 Patent generally relates to group messaging in interactive applications. The petitioner is Riot Games, Inc. (“Riot Games”), maker of popular titles like League of Legends The patent owner is Paltalk Holdings, Inc. (“Paltalk”). From 2006-2009, the ’523 Patent was asserted by Paltalk in patent infringement cases against Microsoft, Sony, Activision Blizzard, NCsoft, Jagex, and Turbine Inc., among others.

Claim 1 of the ’523 Patent reads:

1. A method for providing group messages to a plurality of host computers connected over a unicast wide area communication network, comprising the steps of:

providing a group messaging server coupled to said network, said server communicating with said plurality of host computers using said unicast network and maintaining a list of message groups, each message group containing at least one host computer;

sending, by a plurality of host computers belonging to a first message group, messages to said server via said unicast
network, said messages containing a payload portion and a portion for identifying said first message group;

aggregating, by said server in a time interval determined in accordance with a predefined criterion, said payload portions of said messages to create an aggregated payload;

forming an aggregated message using said aggregated payload; and

transmitting, by said server via said unicast network, said aggregated message to a recipient host computer belonging to said first message group.

Both Riot Games and Paltalk agree that the ’523 Patent expired. While it might seem strange for Riot Games to attack the validity of an expired patent, a patent owner may sue for damages that were incurred when their now-expired patent was valid, though they cannot recover damages that were incurred more than six years prior to the filing of the lawsuit. As it appears that the ’523 Patent expired in 2016, Paltalk could potentially file patent infringement lawsuits up until around 2022, but only for damages that they incurred prior to 2016, and only so long as their damages were in the six years before they filed the lawsuits. For example, if Paltalk sued a game company for patent infringement on Jan. 1, 2021, they could recover damages from Jan. 1, 2015, up until the date the ’523 Patent expired in 2016.

Nov

2017

Blizzard files Inter Partes Review re: World of Warcraft Mounts, Citing Dungeons and Dragons

On November 6, 2017, Activision Blizzard, Inc. (“Blizzard”) filed a petition for inter partes review (“IPR”) against Game and Technology Co. Ltd. (“GAT”). Blizzard is challenging claims 1-7 of U.S. Patent No. 7,682,243 (the “’243 Patent”). The same claims in the same patent were challenged by Wargaming Group Ltd. (“Wargaming”) in IPR2017-01082, which Blizzard plans to join.

Activision’s IPR petition is responsive to a lawsuit that GAT brought against Blizzard in the Eastern District of Texas on July 9, 2015 (No. 2:15-CV-1257, now 2:16-CV-6499 in the C.D. Cal.). In that case, GAT has asserted that Blizzard’s World of Warcraft infringes three patents: the ’243 Patent, U.S. Patent No. 8,253,743, and U.S. Patent No. 8,035,649. In separate suits, GAT has sued Wargaming, Valve Corporation, and Riot Games, Inc.

The ’243 Patent generally relates to a “pilot” and a “unit associated with the pilot,” such as a player character and an animal mount. Claim 1 of the ’243 Patent reads:

1. An online game providing method for providing a pilot and a unit associated with the pilot at an online game, the method comprising the steps of:

controlling an online game such that a player can manipulate a pilot and a unit associated with said pilot, said pilot being a game character operated by a player, said pilot representing the player, said unit being a virtual object controlled by the player;

maintaining a unit information database, the unit information database recording unit information on said unit, in which the unit information includes ability of said unit and sync point information;

maintaining a pilot information database, the pilot information database recording pilot information on said pilot, in which the pilot information includes a unit identifier indicating said unit associated with said pilot, ability of said pilot and the ability of said unit associated with said pilot;

receiving a request for update on first pilot ability information of a first pilot;

searching for unit identifier information associated with the first pilot by referring to the pilot information database;

searching for sync point information associated with the searched unit identifier information by referring to the unit information database; and

updating and recording the first pilot ability information and unit ability information associated therewith in accordance with the searched sync point information such that said ability of unit is changed proportionally to changes in ability of the pilot by referring to said sync point,

wherein said sync point information is a ratio of which changes in said ability of pilot are applied to said ability of unit, and said steps of searching for unit identifier information and of searching for sync point information are performed by a processor.

Blizzard argues that the ’243 Patent’s “alleged novelty” relates to the “sync point,” bolded above. Per Blizzard’s petition, the ’243 Patent is anticipated because the Dungeons and Dragons Player’s Handbook Core Rulebook I v. 3.5 (“D&D 3.5”) discloses “player characters with animals whose abilities are synchronized based on ratio relationships, so that increases to the character’s abilities are applied proportionally to the animal’s abilities.” For instance, D&D 3.5 allegedly discloses that a druid’s animal companion’s abilities increase corresponding to the class level of the druid.

More information on the Inter Partes Review process is available here.

Blizzard Takes New Stance on Custom Game IP

Dynamic and Nonliteral Elements Win Protection in Blizzard Copyright Suit

Heroes Charge into Copyright Battle

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