`Case 2:22-cv-00209-GW-MRW Document 46-16 Filed 03/28/22 Page1of3 Page ID #:1080
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`EXHIBIT 15
`EXHIBIT 15
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`Case 2:22-cv-00209-GW-MRW Document 46-16 Filed 03/28/22 Page 2 of 3 Page ID #:1081
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`Mark A. Lemley
`415-376-6404 (direct)
`415-362-6666 (main)
`mlemley@durietangri.com
`
`
`
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`January 5, 2022
`
`VIA EMAIL
`
`Apple Legal
`Apple, Inc.
`One Apple Park Way
`Cupertino, CA 95014
`AppStoreNotice@apple.com
`
`Re: APP89955
`
`Dear Apple App Store:
`
`We are counsel to Garena International I Private Ltd., Garena Online Private Ltd. (now known as Moco
`Studios Private Limited), and Sea Ltd. (collectively, “Garena”).
`
`We write in response to your email dated December 23, 2021 wherein you informed Garena that
`Krafton, Inc. (“Krafton”) had alleged that Garena’s applications Garena Free Fire – New Age (Apple ID
`1300146617) and Garena Free Fire MAX (Apple ID 1480516829) infringe Krafton’s intellectual
`property rights, in particular, its copyright. Garena denies Krafton’s allegations and will be disputing
`them in the appropriate forum.
`
`In any event, it is a matter of public record that Garena and PUBG Corp. (which merged with Krafton in
`2020 and assumed PUBG Corp.’s contractual obligations), previously litigated in arbitration the validity
`of a settlement agreement concerning PUBG’s (now Krafton’s) purported copyright claims. See the
`Singapore Court of Appeal’s reported judgment in PUBG Corp v Garena International I Pte Ltd and
`others [2020] 2 SLR 379, Civil Appeal No. 184 of 2019 (May 19, 2020), a copy of which is enclosed to
`this letter.
`
`As stated in the Court of Appeal’s judgment, the settlement agreement provides for “any dispute,
`controversy, claim or difference of any kind” arising in connection with the settlement agreement to be
`resolved by arbitration. The other details of the referenced settlement agreement are confidential, but
`Krafton is aware of its existence and terms. Krafton is also aware that after the arbitration, PUBG Corp.
`discontinued the High Court proceedings referred to above. Krafton has chosen not to disclose any of
`these matters to Apple in filing this notification.
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`Case 2:22-cv-00209-GW-MRW Document 46-16 Filed 03/28/22 Page 3 of 3 Page ID #:1082
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`January 5, 2022
`Page 2
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`To the extent there is any remaining dispute, we fully expect that arbitration will resolve the dispute in
`Garena’s favor.
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`Please direct any further questions or concerns to us. All of Garena’s rights are reserved.
`
`Very truly yours,
`
`
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`Mark A. Lemley
`
`MAL:co
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`cc:
`
`
`Yunji Yang (romel1945@bluehole.net)
`Sean Anderson (sranderson@winston.com)
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