Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 1 of 14 PageID #: 16158
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ACCELERATION BAY LLC,
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`ACTIVISION BLIZZARD, INC.
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`Plaintiff,
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`Defendant.
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`v.
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`C.A. No. 16-453 (RGA)
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`CONFIDENTIAL—OUTSIDE
`COUNSEL ONLY
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`FILED UNDER SEAL
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`C.A. No. 16-454 (RGA)
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`CONFIDENTIAL—OUTSIDE
`COUNSEL ONLY
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`FILED UNDER SEAL
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`
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`C.A. No. 16-455 (RGA)
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`CONFIDENTIAL—OUTSIDE
`COUNSEL ONLY
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`FILED UNDER SEAL
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`ACCELERATION BAY LLC,
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`ELECTRONIC ARTS INC.,
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`Defendant.
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`ACCELERATION BAY LLC,
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`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
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`Plaintiff,
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`Plaintiff,
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`v.
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`v.
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`Defendants.
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`DEFENDANTS’ RESPONSE TO
`PLAINTIFF’S OBJECTIONS TO SPECIAL MASTER ORDER NO. 3
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`Jack B. Blumenfeld (#1014)
`Stephen J. Kraftschik (#5623)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`skraftschik@mnat.com
`Attorneys for Defendants
`
`
`
`OF COUNSEL:
`Michael A. Tomasulo
`Gino Cheng
`David K. Lin
`Joe S. Netikosol
`WINSTON & STRAWN LLP
`333 South Grand Avenue, 38th Floor
`Los Angeles, CA 90071
`(213) 615-1700
`
`REDACTED
`PUBLIC VERSION
`
`REDACTED
`PUBLIC VERSION
`
`REDACTED
`PUBLIC VERSION
`
`

`

`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 2 of 14 PageID #: 16159
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`
`David P. Enzminger
`WINSTON & STRAWN LLP
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`(650) 858-6500
`
`Dan K. Webb
`Kathleen B. Barry
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601
`(312) 558-5600
`
`Krista M. Enns
`WINSTON & STRAWN LLP
`101 California Street, 35th Floor
`San Francisco, CA 94111
`(415) 591-1000
`
`Michael M. Murray
`WINSTON & STRAWN LLP
`200 Park Avenue,
`New York, NY 10166
`(212) 294-6700
`
`Original Filing Date: June 19, 2017
`Redacted Filing Date: June 26, 2017
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 3 of 14 PageID #: 16160
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`I.
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`INTRODUCTION
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`Acceleration’s objections to the Special Master’s May 19, 2017 Order No. 3 (Ex. A, No.
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`16-453, D.I. 155, the “Order”) is part of a case-long tactic to avoid giving defendants any
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`meaningful information about Plaintiff’s positions. With these objections, Acceleration is seeking
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`to avoid providing basic facts supporting its (1) infringement claims, (2) damages position, (3) the
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`date of the hypothetical negotiation for purposes of determining a reasonable royalty, and (4) its
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`claim that Sony copied and practiced the claimed inventions of the patents. To date, Acceleration
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`has refused to comply with three Special Master’s orders directing them to identify the facts
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`supporting their infringement claims. Last week, Acceleration’s 30(b)(6) witness testified that it
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`knew no facts supporting any claim of infringement, and that all facts are “privileged” because
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`only its counsel has any idea what this case is about. And Acceleration’s counsel acknowledged
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`that he structured the company and patent deal to make sure there were no documents. The
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`information sought by Defendants does not require expert opinion and is not burdensome – they
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`are foundational fact and contention discovery that every patent plaintiff is required to provide
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`early in a case. Allowing Acceleration to deny Defendants all fact discovery into the fundamental
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`aspects of Plaintiff’s case, and giving Defendants notice of Acceleration’s basic positions for the
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`first time in expert discovery is antithetical to the Federal Rules and has greatly prejudiced
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`Defendants’ ability to prepare their defense. Before the close of fact discovery, Acceleration
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`should be required to comply fully with the Order.
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`II.
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`RESPONSES TO PLAINTIFF’S OBJECTIONS
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`The Special Master held multiple hearings on these motions, and the Court should uphold
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`the Special Master’s Orders as follows:
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`1. As to all interrogatories, the objections should be overruled as a preemptive tactic designed
`to prevent the Special Master from issuing further orders.
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`1
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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 4 of 14 PageID #: 16161
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`2.
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`3.
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`4.
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`Interrogatory No. 1: By close of fact discovery, Acceleration should be required to disclose
`all facts underlying all (not just some) of its damages theories. If Acceleration fails to do
`so, it should be precluded from relying on facts that it has not disclosed in its responses.
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`Interrogatory No. 2: Acceleration should be required, in good faith, to identify the date it
`contends is the date of first infringement and the full factual basis for that contention.
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`Interrogatory No. 4: Acceleration should be required to identify all Sony PlayStation
`games that infringe. The Sony license and the number of games under that license is highly
`relevant to the calculation of damages. As Acceleration contends damages of nearly $550
`million for the three Defendants (and for a damages period of around 18 months),
`discovery on this issue is certainly proportional to the needs of this case.1
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`5. Activision Interrogatory Nos. 7 and 9: Acceleration should be ordered to provide complete
`responses as required by the Special Master or be precluded from relying on facts or
`position that it has not disclosed in its responses. Acceleration did not object to the two
`previous orders from the Special Master and has therefore waived its objections. Even if
`the Court considers the objections to the third Special Master order, these objections should
`be overruled as further attempts by Acceleration to obfuscate its infringement theories.
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`A. Acceleration’s Objections Are An Improper Attempt to Foreclose the Special
`Master’s Authority
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`Acceleration states that it will provide additional interrogatory responses, but then objects
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`to the extent Defendants do not believe the answer complies with the Special Master’s Order.
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`These objections should be overruled as an improper attempt to foreclose the authority of the
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`Special Master regarding discovery disputes. Defendants reserve their right to pursue relief before
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`the Special Master for noncompliance with his Orders.
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`B. Acceleration Fails (or Refuses) to Disclose Facts Supporting Each of its Damages
`Theories (Interrogatory No. 1)
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`As the Special Master explains, “Interrogatory No. 1 seeks discovery as to Acceleration’s
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`damages theories and all the facts that Acceleration intends to [rely (sp.)] upon to support each of
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`its theories.” Ex. A, 7; Ex. C, 5; Ex. D, 5, Ex. E, 5. Defendants noted, and the Special Master
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`agreed, that this Court’s decision in In re Cyclobenzaprine has particular relevance to the dispute
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`1 Moreover, in the PTAB proceedings, Acceleration contended that Sony copied and practiced
`the claimed inventions in support of Acceleration’s argument of non-obviousness. Thus,
`Acceleration has admitted both the relevance and lack of burden of providing its position on this
`issue when it serves Acceleration’s need.
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`2
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 5 of 14 PageID #: 16162
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`here. Ex. A, 8. There, the Court explained that “to claim, e.g., lost profits, plaintiffs must have
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`some underlying data” to support such a theory. Ex. F, 3. Similarly, it explained that the plaintiffs
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`“should also have underlying data supporting their other theories of recovery” and that the
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`defendants were entitled to such facts “before [they] are massaged and manipulated by their expert
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`witnesses. Id. The Special Master granted Defendants’ motion without qualification.
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`Although Acceleration claims it has complied with the Special Master’s order, it has not
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`provided supporting facts for a number of its damages theories. It says it will not disclose more.
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`But, per In re Cyclobenzaprine, Acceleration has an “obligation to provide [its] good faith bases
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`for electing [its] theories of recovery.” Ex. F, 3. If Acceleration continues to refuse to do this, it
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`should be held to its interrogatory responses and precluded from relying on other facts.
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`Acceleration’s recent supplements to this interrogatory belie its alleged compliance with
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`the Order. First, Acceleration identifies a number of theories without providing any facts that
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`would support such theories.
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` Ex. G, 8; Ex. H, 8; Ex. I, 8. But Acceleration refers to nothing in
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`support of this number. Similarly, Acceleration contends the
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` Id. Acceleration also identifies
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`five different theories of potential recovery but cites no specific facts in support of each theory. 2
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`Second, Acceleration objects “to the extent … the Order requires further disclosures” and
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`then states that “after fact discovery has been completed, Acceleration Bay will provide reports
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`2 See also Ex. S at 27 (this Court explained that “[w]hen you answer the interrogatory … [y]ou
`actually do need to explain the damages theory without waiting for the expert report. You don't
`need to have the same level of detail, but you ought to have an idea of what the revenue base is
`and the royalty rate and, you know, whatever your Reasonable Royalty theory is.” (Andrews, J).
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`3
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 6 of 14 PageID #: 16163
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`disclosing its damages experts’ opinions.” Ex. B, 4. That is exactly contrary to the holding of In
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`re Cyclobenzaprine, which the Special Master correctly observed requires disclosure of the facts
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`before they are massaged by the experts.
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`Third, Acceleration’s verbose “supplements” say almost nothing and are largely copied
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`directly from the previous responses which were held inadequate. See e.g., Ex. G, 5-6; Ex. H, 5-6;
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`Ex. I, 5-6. Acceleration lists fifteen broad categories of documents that could have relevant
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`information without identifying a single such document. See e.g., Ex. G, 6-7; Ex. H, 6-7; Ex. I, 6-
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`7. It boasts of numerous advantages to the patented technology, but cites to no documents
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`supporting these claims. Ex. G, 7; Ex. H, 7; Ex. I, 7. It contends the Order is “somewhat unclear.”
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`Acceleration’s various attempts at obfuscation were clearly not what the Order intended.
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`C. Acceleration Refuses to Disclose a Hypothetical Negotiation Date and This is
`Acceleration’s Burden to Show (Interrogatory No. 2)
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`Defendants’ Interrogatory No. 2 asks Acceleration to identify what it contends is the
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`hypothetical negotiation date (i.e. date of first alleged infringement) and the factual bases for this
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`contention, which is Acceleration’s burden to establish.3 Defendants pointed out that this
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`disclosure was essential to giving them a full and fair opportunity to rebut the contended date and
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`to conduct discovery surrounding this date (e.g., related to a reasonable royalty at the time). The
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`Special Master agreed, and granted Defendants’ motion without qualification. Ex. A at 9.
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`Acceleration’s plea of compliance flies in the face of both the letter and spirit of the Order.
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`Making no attempt to identify a hypothetical negotiation date, Acceleration contends that
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` Ex. G, 13; Ex. H, 13; Ex. I, 13. Acceleration
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`3 Ex. A, 8; Ex. B, 6; Ex. C, 6; Ex. D, 6.
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`4
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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 7 of 14 PageID #: 16164
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`argues that it would be too burdensome for it to identify any date prior to the service dates.4 But
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`that is not the law. It is obviously absurd to contend that the dates of first infringement are, in all
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`cases, the same dates Acceleration happened to file complaints against three different companies
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`for more than a dozen products. Further, Acceleration has accused several products released prior
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`to the service date of infringement. For example, World of Warcraft was first released in 2004 and
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`the Blizzard downloader Acceleration accuses of infringement was released by 2010.
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`Acceleration’s contention violates well-settled law on the date for a hypothetical
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`negotiation. Hypothetical negotiation dates are routinely identified prior to the service date of a
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`complaint, and prior to even the six year damages period.5 Acceleration should be compelled to
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`provide a good-faith response. As Acceleration has argued the 2017 “versions” of the accused
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`products are infringing (without performing an infringement analysis), it should easily be able to
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`make the same assessment going backward to identify which earlier versions are also infringing
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`and thereby identify what it contends to be the date of first infringement.
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`D. Defendants Seek Relevant Discovery Regarding Sony Products and Acceleration’s
`Damage Claims (Interrogatory No. 4)
`Acceleration initially refused to respond to this interrogatory6 because it was purportedly
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`“unintelligible.” See Ex. K, 7. Defendants pointed out that this was not credible and that
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`Acceleration’s own expert contended that
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`4
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` See id.
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` Ex. J, 12.
` See Wang Laboratories, Inc. v. Toshiba Corp., 993 F.2d 858, 870 (Fed. Cir. 1993) (explaining
`that the reasonable royalty is to be based on rate that would have hypothetically been negotiated
`on the date infringement began even if that date is prior to the date from which the infringer was
`given notice of infringement and even if that initial date precedes that cutoff date that the
`infringer will be liable for damages under the six year limitation period of 35 U.S.C.A. § 286).
`6 Ex. A, 9; Ex. C, 6; Ex. D, 6, Ex. E, 6.
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`5
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 8 of 14 PageID #: 16165
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`(citing Bims Declaration). The Special Master agreed and compelled supplemental responses,
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`finding that “[t]he information as to the Sony Products in interrogatory No. 4 is relevant and a
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`response does not appear to be unnecessarily burdensome.” Ex. A, 9.
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` Ex. G, 15; Ex. H, 15-16; Ex. I, 15. However, Acceleration objects
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`to the Order to the extent it seeks identification of third-party made games playable on Sony
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`products that infringe the Asserted Patents. Ex. B, 6. Acceleration contends that such a response
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`is not relevant and would be unnecessarily burdensome. Id. But identification of all the Sony
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`PlayStation games that infringe is highly relevant to the calculation of an effective royalty rate.7
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`The per-game rate represented by the Sony license changes based on the number of games that are
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`covered under that license. This is also relevant to rebutting secondary considerations of non-
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`obviousness because it goes to the demand for the patented technology. Second, this discovery is
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`certainly proportional to the needs of the case, considering Acceleration’s claim of nearly
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`$550,000,000 in damages for 18 months of sales. Given this, it cannot now argue that further
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`inquiry into its bases for damages is out of bounds.
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`E. Acceleration Refuses To Disclose Facts Supporting Its Infringement Theories
`(Interrogatory Nos. 7 and 9)
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`1. Acceleration has waived its objections.
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`As the Special Master noted, the adequacy of Acceleration’s infringement theories has been
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`the subject of much motion practice over the last two years. Ex. A at 4-5. In April 2016,
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`Defendants sought this information, and the Special Master granted relief in Special Master Order
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`No. 2, ordering Acceleration to supplement its responses to Interrogatory Nos. 7 and 9. Ex. N at 3-
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`4. On March 6, 2017, even though the Scheduling Order stated that discovery continued from the
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`7 As the only license to the Asserted Patents, the Sony license is highly relevant to this case.
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`6
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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 9 of 14 PageID #: 16166
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`prior case, Defendants had to move once again to compel compliance with Special Master Order
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`No. 2. Ex. O. The Special Master granted that order too. Ex. P at 61-62. Acceleration did not file
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`objections to either of those Special Master orders. It simply refused to comply.
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`Acceleration has waived its objections. The Order merely sought to specifically enforce
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`two prior Special Master Orders requiring Acceleration to disclose facts supporting its
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`infringement claims. Defendants have been trying to obtain this information since February 2016.
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`Yet Acceleration now, for the first time, objects to Special Master Order No. 2. Acceleration has
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`dragged this process out until the end of fact discovery, which greatly prejudiced Defendants.8
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`2. Acceleration’s objections are meritless.
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`Again, Acceleration’s objections are an attempt to unilaterally declare its forthcoming
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`responses (they are due the day these responses are due) to be adequate, and to foreclose the
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`authority of the Special Master and to delay providing case critical discovery. In the last two years,
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`Defendants have submitted overwhelming evidence, including the testimony of their expert as well
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`as Acceleration’s own expert, demonstrating the deficiencies of Accelerations infringement
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`contentions. Interrogatory Nos. 7 and 9 seek traditional discovery regarding the basis for
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`Acceleration’s infringement allegations. Acceleration, on the other hand, has engaged in repeated
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`efforts to obfuscate its infringement theories, if it even has any. If Acceleration cannot provide a
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`factual basis for alleging any infringement as requested by Interrogatory Nos. 7 and 9, then it
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`should be precluded from presenting an infringement case. There is no reason for why
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`Acceleration cannot comply with the Order. Acceleration does not provide any proper objections
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`8 Notably, Accelerations’ attempt to obfuscate its lack of any factual basis for these cases extends
`to depositions and claim constructions as well.
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`
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` Ex. Q at 296-298. As discussed in Defendants’ Motion
`to Strike, Acceleration hid its claim construction positions until its opening brief. See Ex. T.
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`7
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 10 of 14 PageID #: 16167
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`for the Court to review. Instead, it raises new objections and illusory reasons to explain why it
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`apparently still cannot identify facts to support an allegation of infringement.
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`First, Acceleration objects because “Acceleration will identify each accused network, but
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`because the accused networks provide the broadcast channels and the accused methods are
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`performed in and by these networks, it is unclear how they can be separately identified.” This is
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`rubbish. Not only is this the first time Acceleration has ever made this argument, it is not
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`supported by any evidence.
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`Ex. L, 201-202. Thus, as Acceleration’s expert agrees, this information is required to show
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`infringement. If Acceleration is really arguing that it cannot do so, then the case should dismissed
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`now. If “it is unclear how they can be separately identified” as the claims require, Acceleration
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`must drop the allegations.9
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`Second, Acceleration objects because “Activision seems to be complaining that
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`Acceleration Bay has not identified by name the specific people playing its game or the particular
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`servers from its pool, a level of specificity not required by the claims or applicable patent law.”
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`Activision made no such argument. The specificity sought is not that of user names or IP
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`addresses, but rather particular computers or processes that Acceleration contends are the
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`participants of each separate network Acceleration alleges infringes. For example, if Acceleration
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`contends Call of Duty’s VOIP network infringes, Acceleration should identify, for example, with
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`9 Acceleration’s argument that it “unclear” how it can state a claim for infringement by
`identifying even one allegedly infringing broadcast channel is an excellent explanation for why
`Activision was compelled to file a Rule 11 motion in this case.
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`8
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 11 of 14 PageID #: 16168
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`respect to the topology patents what it contends (1) are the participants, (2) how many participants
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`there are, (3) which participants are connected, (4) what “m” is, and (5) how flooding occurs. This
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`is basic information required by the explicit limitations of the claims, and Acceleration’s refusal to
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`provide such information at this late stage of discovery is troubling.
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`Acceleration seeks to avoid compliance with the Special Master’s order while preserving
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`all optionality as to its infringement positions by lumping together every computer, game console,
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`server or software process in any way connected with the Accused Games or Activision.
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` Ex. L, 201-202. If Acceleration
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`has a claim to state in this case, it must be able to identify participants of the broadcast channel or
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`there is no claim.10 If there is no claim, the case should be dismissed.
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`Third, Acceleration does not state what its objections are to “the second part of the Order
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`(which relates to Interrogatory 7).” Instead, Acceleration merely states how it plans to ignore what
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`Special Master ordered. The Order plainly requires Acceleration to provide an infringement chart
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`for “each accused method, network and broadcast [channel] [sic].” Not, as Acceleration interprets
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`it, for only each accused network. The claims are directed to broadcast channels and methods as
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`well. Merely identifying a network does not identify the broadcast channel or the method that
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`supposedly infringe each asserted claim.
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`Fourth, Acceleration sets up a straw man by arguing that Activision is asking it to prove
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`infringement or to provide premature expert disclosure. Ex. B, 11. This argument is wrong and
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`was expressly overruled. “These are straightforward interrogatories seeking the basic factual basis
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`for Acceleration’s infringement claims. Acceleration cannot withhold this information during fact
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`10
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` Ex. R at 4.
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`9
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 12 of 14 PageID #: 16169
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`discovery (closing in three months).” Ex. M at 4. The Special Master agreed and issued his Order.
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`Discovery closes in one month, and defendants still do not have this information.
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`Furthermore, Acceleration appears to be suggesting that Rule 26 only requires Acceleration
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`to provide interrogatory responses that put Defendants on notice of Acceleration’s theory of
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`infringement. This is plainly incorrect. Ex. B at 10. The cases Acceleration relies on are
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`inapposite because they involve initial infringement contentions; not interrogatory responses at or
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`near the end of fact discovery. Id. It is unreasonable for Acceleration to think that it can operate
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`under its “notice” standard from the inception of the case until close of fact discovery.11
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`3. Acceleration’s conduct has severely prejudiced Defendants.
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`As stated above and in Activision’s Motion to Compel, Activision has provided to
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`Acceleration everything it needs to supplement its responses. Ex. M at 2. Given that discovery
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`closes in just over a month and the Markman hearing is quickly approaching, Acceleration’s
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`repeated refusal to comply with the Order is extremely prejudicial to Activision, and hinders its
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`ability to defend itself. As noted, the Delaware Courts have issued various sanctions under Fed. R.
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`Civ. P. 37(b)(2)(A) for violation of discovery order. Id. at 12. Accordingly, Activision respectfully
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`requests that the Court confirm the Order and issue appropriate sanctions, as Activision has
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`requested, under Rule 37 as punishment for its delayed tactics and gamesmanship.
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`11 In fact, even under Plaintiff’s (incorrect) notice standard, the Special Master held that Plaintiff
`has failed to meet even that low bar. Ex. A at 5.
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`10
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`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 13 of 14 PageID #: 16170
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`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Stephen J. Kraftschik
`
`Jack B. Blumenfeld (#1014)
`Stephen J. Kraftschik (#5623)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`skraftschik@mnat.com
`
`Attorneys for Defendants
`
`
`
`
`
`OF COUNSEL:
`Michael A. Tomasulo
`Gino Cheng
`David K. Lin
`Joe S. Netikosol
`WINSTON & STRAWN LLP
`333 South Grand Avenue, 38th Floor
`Los Angeles, CA 90071
`(213) 615-1700
`
`David P. Enzminger
`WINSTON & STRAWN LLP
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`(650) 858-6500
`
`Dan K. Webb
`Kathleen B. Barry
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601
`(312) 558-5600
`
`Krista M. Enns
`WINSTON & STRAWN LLP
`101 California Street, 35th Floor
`San Francisco, CA 94111
`(415) 591-1000
`
`Michael M. Murray
`WINSTON & STRAWN LLP
`200 Park Avenue,
`New York, NY 10166
`(212) 294-6700
`
`June 19, 2017
`
`11
`
`

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`Case 1:16-cv-00455-RGA Document 160 Filed 06/26/17 Page 14 of 14 PageID #: 16171
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 26, 2017, I caused the foregoing to be electronically
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`
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`filed with the Clerk of the Court using CM/ECF, which will send notification of such filing to all
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`registered participants.
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`I further certify that I caused copies of the foregoing document to be served on
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`June 26, 2017, upon the following in the manner indicated:
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`Philip A. Rovner, Esquire
`Jonathan A. Choa, Esquire
`POTTER ANDERSON & CORROON LLP
`1313 North Market Street, 6th Floor
`Wilmington, DE 19801
`Attorneys for Plaintiff
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`Paul J. Andre, Esquire
`Lisa Kobialka, Esquire
`James R. Hannah, Esquire
`Hannah Lee, Esquire
`Yuridia Caire, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Attorneys for Plaintiff
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`Aaron M. Frankel, Esquire
`Marcus A. Colucci, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Attorneys for Plaintiff
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`VIA ELECTRONIC MAIL
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`VIA ELECTRONIC MAIL
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`VIA ELECTRONIC MAIL
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`/s/ Stephen J. Kraftschik
`Stephen J. Kraftschik (#5623)
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`