Exhibit C — Gibson Guitar’s Chart Breaking Down Alleged ‘Guitar Hero’ Infringement

When Activision filed suit against Gibson Guitar Corporation on March 11, the game-maker included a nine-page chart that breaks down how “Guitar Hero” allegedly does infringe on a 1999 patent.

Why would Activision include that?

Probably because the company feels that the chart does not make a convincing argument.

The Gibson Patent Vs “Guitar Hero” comparison chart was included in a February 18 letter sent by Gibson’s lawyer to Activision’s legal team and is now part of Activision’s filing. It breaks down the patent vs. game comparison, line by line.

TheĀ  chart has a lot of this:


What do you think? Do all the arguments in the chart hold up? Judge for yourself.

The full point-by-point breakdown, in nine-page chart form, follows below.

(The chart that follows includes excerpts of Gibson’s 5000-word Patent No. 5,990,405. If you want to compare the full version of the patent — including diagrams of Gibson’s patent — to the claims below, then take a look at the official document on file with the U.S. government.)