`
`K R A M E R L E V I N N A F T A L I S & F R A N K E L L L P
`
`PAUL ANDRE
`PARTNER
`PHONE (650) 752-1710
`PANDRE@KRAMERLEVIN.COM
`
`February 19, 2016
`
`The Honorable Richard G. Andrews
`United States District Court
`For the District of Delaware
`844 North King Street
`Wilmington, DE 19801
`
`Re:
`
`Acceleration Bay LLC. v. Activision Blizzard, Inc., Civil Action
`No. 15-228-RGA; Acceleration Bay LLC. v. Electronic Arts Inc.,
`Civil Action No. 15-282-RGA; Acceleration Bay LLC. v. Take-
`Two Interactive Software, Inc. et al. Civil Action No. 15-311-RGA
`
`Dear Judge Andrews:
`
`Subsequent to the February 12, 2016 discovery conference in the above-referenced
`actions, Kramer Levin Naftalis & Frankel LLP has been retained by Hamilton Capital XXI LLC
`(“Hamilton Capital”) to respond to Defendants’ subpoenas in these matters.
`
`During the discovery conference, the Court asked Hamilton Capital to inform it of any
`independent objections to the production of the loan agreement between Acceleration Bay and
`Hamilton Capital. Hamilton Capital hereby notifies the Court that it objects to the production of
`the loan agreement on the same grounds asserted by Acceleration Bay, including that the loan
`agreement is not relevant to any claim or defense in these cases. See C.A. 15-cv-282-RGA, D.I.
`80 at 2-3. Notwithstanding and without waiver of these objections and objections to any further
`discovery by Defendants, Hamilton Capital will not seek to disturb the Court’s ruling that
`Acceleration Bay will only produce the loan agreement in the Court-approved redacted form.
`
`Respectfully,
`
`/s/ Paul Andre
`
`Paul Andre
`
`cc:
`
`All Counsel of Record (Via ECF Filing, Electronic Mail)
`
`990 MARSH ROAD MENLO PARK CA 94025-1949 PHONE 650.752.1700 FAX 650.752.1800
`1177 AVENUE OF THE AMERICAS NEW YORK NY 10036-2714 PHONE 212.715.9100 FAX 212.715.8000
`47 AVENUE HOCHE 75008 PARIS FRANCE PHONE (33-1) 44 09 46 00 FAX (33-1) 44 09 46 01
`WWW.KRAMERLEVIN.COM
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