throbber
Case 1:15-cv-00311-RGA Document 114 Filed 04/05/16 Page 1 of 3 PageID #: 3469
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 15-228 (RGA)
`
`C.A. No. 15-282 (RGA)
`
`C.A. No. 15-311 (RGA)
`
`)))))))))
`
`))))))))) )))))))))))
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.,
`
`Defendant.
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ELECTRONIC ARTS INC.,
`
`Defendant.
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
`
`Defendants.
`
`PLAINTIFF ACCELERATION BAY LLC’S MOTION TO COMPEL DEPOSITIONS,
`SUBSTANTIVE RESPONSES TO COMMON INTERROGATORY
`NUMBERS 10 AND 11 AND PRODUCTION OF SOURCE CODE
`
`Pursuant to the Court’s Order Appointing Special Master (D.I. 94 in C.A. No. 15-228-
`
`RGA) (“Order”), Plaintiff Acceleration Bay LLC, (“Acceleration Bay”) hereby moves for an
`
`order compelling Defendants in the above captioned actions (1) to provide within seven days a
`
`list of deposition witnesses for each of the accused products and a schedule of the dates they are
`
`

`

`Case 1:15-cv-00311-RGA Document 114 Filed 04/05/16 Page 2 of 3 PageID #: 3470
`
`available for deposition, so that technical depositions can proceed without any further delay; and
`
`(2) to provide substantive responses to Acceleration Bay’s Common Interrogatory Nos. 10 and
`
`11. Acceleration Bay also moves for a finding that Common Interrogatory Nos. 10 and 11 count
`
`as only one interrogatory each against Acceleration Bay’s total allowed Common Interrogatories
`
`under the Scheduling Order (D.I. 34 in C.A. No. 15-228-RGA). Finally, Acceleration Bay
`
`moves for an order compelling Defendant Electronic Arts Inc. to offer for inspection within
`
`seven days the source code for the accused product Plants vs. Zombies: Garden Warfare 2.
`
`The grounds for this motion are set forth in the Parties’ letter briefs, copies of which will
`
`be provided to the Special Master pursuant to Paragraph 3 of the Order and the Special Master
`
`Order Relating to Procedures for Resolving Discovery Motions (D.I. 113 in C.A. No. 15-228-
`
`RGA). An in-person hearing on this motion is scheduled for April 14, 2016 at 11:00 a.m.
`
`Pursuant to D. Del. LR 7.1.1, Acceleration Bay states that it has made reasonable effort to
`
`reach agreement with Defendants on the matters set forth in this motion and has been informed
`
`that Defendants oppose the relief sought.
`
`2
`
`

`

`Case 1:15-cv-00311-RGA Document 114 Filed 04/05/16 Page 3 of 3 PageID #: 3471
`
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Philip A. Rovner
`Philip A. Rovner (#3215)
`Jonathan A. Choa (#5319)
`Hercules Plaza
`P.O. Box 951
`Wilmington, DE 19899
`(302) 984-6000
`provner@potteranderson.com
`jchoa@potteranderson.com
`
`Attorneys for Plaintiff Acceleration Bay LLC
`
`OF COUNSEL:
`
`Paul J. Andre
`Lisa Kobialka
`James R. Hannah
`KRAMER LEVIN NAFTALIS &
`FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`(650) 752-1700
`
`Aaron M. Frankel
`KRAMER LEVIN NAFTALIS &
`FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`(212) 715-9100
`
`Dated: April 5, 2016
`1220541
`
`3
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket