Case 1:15-cv-00311-RGA Document 142 Filed 05/27/16 Page 1 of 3 PageID #: 4089
`
`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 DAMAGES DISCOVERY
`
`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 to provide the following discovery
`
`within ten (10) days: (1) gross and net revenues, costs, expenses, and profits for U.S. and foreign
`
`

`

`Case 1:15-cv-00311-RGA Document 142 Filed 05/27/16 Page 2 of 3 PageID #: 4090
`
`sales broken down by country (all Defendants); (2) disclosure of revenues from the sale of
`
`accused products including online distribution platforms, bundled sales and tokens and
`
`supplemental responses to Common Interrogatory No. 7, which seeks information related to such
`
`revenues (all Defendants); (3) supplemental responses to Common Interrogatory No. 6 regarding
`
`the geographical locations where the components of accused products are manufactured,
`
`developed, and tested (all Defendants); (4) unredacted patent license agreements that relate to the
`
`accused products or Defendants’ multi-player networks (Take-Two only); (5) sales forecasts and
`
`billings information (all Defendants); and (6) financial information in generally accepted
`
`accounting principles (GAAP) format (Activision only).
`
`The grounds for this motion are set forth in Acceleration Bay’s letter brief, 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). A telephonic hearing on this motion is scheduled for June 8, 2016 at 1:00 p.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 142 Filed 05/27/16 Page 3 of 3 PageID #: 4091
`
`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
`Hannah Lee
`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: May 27, 2016
`1225044
`
`3
`
`

Accessing this document will incur an additional charge of $.

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

Accept $ Charge

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.

We are unable to display this document.

PTO Denying Access

Refresh this Document
Go to the Docket