Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 1 of 13 PageID #: 25015
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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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`Plaintiff,
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`v.
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`ACTIVISION BLIZZARD, INC.,
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`Defendant.
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`ACCELERATION BAY LLC,
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`Plaintiff,
`
`v.
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`ELECTRONIC ARTS INC.,
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`Defendant.
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`ACCELERATION BAY LLC,
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`Plaintiff,
`
`v.
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`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC., and 2K
`SPORTS, INC., Delaware Corporations,
`
`Defendants.
`
`)
`)
`)
`) C.A. No. 16-453 (RGA)
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`)
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`)
`)
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`) C.A. No. 16-454 (RGA)
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`)
`)
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`) C.A. No. 16-455 (RGA)
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`NON-PARTY SONY INTERACTIVE ENTERTAINMENT AMERICA LLC.’S
`OPPOSITION TO PLAINTIFF ACCELERATION BAY LLC’S DISCOVERY MOTION
`AND REQUEST FOR A PROTECTIVE ORDER
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`
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`
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`Originally filed under seal on August 30, 2017
`Redacted Public Version filed on September 8, 2017
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`

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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 2 of 13 PageID #: 25016
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`Sony Interactive Entertainment America LLC (“Sony”)1 opposes Plaintiff Acceleration
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`Bay LLC’s (“Acceleration Bay” or “Plaintiff”) request for documents containing highly
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`confidential information of Sony at issue in an August 16, 2017 letter brief (“Plaintiff’s Letter
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`Brief”). Sony is not a party to this action, nor has Sony received a Rule 45 subpoena from any
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`party. Sony has intervened for the limited and sole purpose of protecting its highly confidential
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`financial information.
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`SUMMARY OF ARGUMENT
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`This dispute relates to highly confidential Sony information redacted from four
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`documents produced by defendants Activision Blizzard, Inc. (“Activision”), Electronic Arts Inc.
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`(“EA”), and Take-Two Interactive Software, Inc. (“Take-Two”) (collectively “Defendants”).
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`(See Plaintiff’s Letter Brief at 2, Exs. 1, 5, 8 and 9.) The information consists of the highly
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`confidential terms of three video-game-publisher agreements between Sony and the Defendants.
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`This information is irrelevant to this patent-infringement case between the parties.
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`In its Letter Brief, Plaintiff requested that Defendants “be precluded from relying upon
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`their agreements with Sony” in this action, and requested only in the “alternative” that the
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`redacted Sony agreements be “produced in their entirety and without any redactions.”
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`(Plaintiff’s Letter Brief at 1, 5; see also Proposed Order (D.I. 230-1) at 2.)2 But Plaintiff has
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`since changed its position. Shortly after Plaintiff filed its Letter Brief, the Court granted a
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`motion by Defendants to dismiss all claims related to games used on Sony platforms. (D.I. 237.)
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`But rather than concede that these agreements are even less relevant to this action than before the
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`Court’s dismissal and seek agreement to the primary relief requested in Plaintiff’s Letter Brief,
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`1 Sony Interactive Entertainment America LLC is a successor-in-interest to Sony Computer Entertainment America
`Inc.
`2 Plaintiff’s letter brief attached redacted versions of three publisher agreements between Sony and Defendants, as
`Exhibits 1, 5, 8 and 9. Exhibits 8 and 9 consist of two copies of a single agreement.
`1
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 3 of 13 PageID #: 25017
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`Plaintiff instead has informed Sony and the Special Master that it “is no longer seeking to
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`preclude reliance on the Sony agreements” and is now seeking an order compelling production of
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`the redacted portions of the agreements that relate to the “payments between Defendants and
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`Sony.” (See August 29, 2017 Email from Aaron Frankel to Special Master Terrell.) Defendants
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`are “neither seeking to disclose nor rely on the redacted information.” (Defendants’ Answering
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`Brief in Opposition to Plaintiff’s August 16, 2017 Discovery Motions (“Defendant’s Answering
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`Brief”) at 1.)
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`Plaintiff’s motion to compel production of this confidential payment information should
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`be denied because discovery of this information is not “proportional to the needs of the case” for
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`four reasons: (1) the terms are Sony’s highly confidential trade secrets, (2) production of this
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`information could harm Sony, (3) the information is neither relevant nor necessary to this action,
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`and (4) the purported need for this information does not outweigh the injury that would ensue if
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`it were disclosed.
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`For the same reasons, the Court should grant a protective order to allow Sony’s highly
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`confidential trade-secret information to remain redacted.
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`FACTUAL BACKGROUND
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`Sony is a video-game company that markets and sells video-game consoles. Sony’s
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`video-game console systems have included the original PlayStation® system, PlayStation® 2
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`(“PS2”), the PlayStation® 3 (“PS3”), and the current PlayStation® 4 (“PS4”). These systems are
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`sometimes referred to as video-game “platforms.” (See Declaration of Florian Hunziker
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`(“Hunziker Decl.”), submitted herewith, ¶ 3.)
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`The Defendants—EA, Activision, and Take-Two—are video-game publishers. (Id. at
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`¶ 3.) Each of the Defendants has created and distributed video games for use on various
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`2
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 4 of 13 PageID #: 25018
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`platforms, including Sony’s PS3 and PS4 platforms. The terms under which the Defendants are
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`permitted to publish their respective games for use on Sony platforms are set forth in publisher
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`agreements with Sony. These publisher agreements include, among other matters and terms,
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`highly confidential terms governing the royalties that each Defendant is required to pay Sony
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`under the agreements. (Id.)
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`The information redacted in the Sony publisher agreements attached to Plaintiff’s Letter
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`Brief includes “specific financial terms such as royalty rates.” (Plaintiff’s Letter Brief at 2.)3
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`Sony treats this information as highly confidential trade secrets and considers it extremely
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`important to protect this information from disclosure. One of these agreements is with EA, a
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`second is with Activision and the other two are with Take-Two. All three companies are
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`competitors of each other. (Hunziker Decl. ¶¶ 2, 4.)
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`On August 24, 2017, the Court granted a motion by Defendants to dismiss all claims
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`related to games used on Sony platforms. (D.I. 237.)
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`Sony has conferred in good faith with Plaintiff and Defendants in an effort to resolve the
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`dispute without court action. However, Plaintiff has continued to seek the unredacted production
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`of the payment terms of Sony’s publisher agreements.
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`(Defendant’s Answering Brief at 1.)
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`
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`3 Other highly confidential information is also redacted from these agreements. However, in light of Plaintiff’s
`August 29, 2017 email to the Special Master, Sony understands that Plaintiff is no longer seeking to have that
`information unredacted.
`3
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`

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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 5 of 13 PageID #: 25019
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`ARGUMENT
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`I.
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`PLAINTIFF’S MOTION TO COMPEL SHOULD BE DENIED
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`Plaintiff’s motion to compel the unredacted production of the payment terms of Sony’s
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`publisher agreements with Defendants should be denied because discovery of this information is
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`not “proportional to the needs of the case” for four reasons: (1) the financial terms of the
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`agreements are Sony trade secrets, (2) production of this information might harm Sony, (3) the
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`information is neither relevant nor necessary to this action, and (4) the purported need for this
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`information does not outweigh the injury that would ensue if it were disclosed. See Taro Pharms
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`U.S.A., Inc. v. Perrigo Israel Pharms, Ltd., 2015 WL 7737310, at *1-*2 (Dec. 1, 2015) (setting
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`out standard for determining whether to prohibit production of trade-secret information and
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`denying motion to compel); Fed. R. Civ. P. 26(b)(1).
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`A.
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`The Financial Terms of Sony’s Publisher Agreements Are Sony Trade
`Secrets.
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`There is no dispute that the financial terms redacted in the documents and now sought by
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`Plaintiff are Sony trade secrets. Such financial information is routinely upheld by courts as
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`protectable trade secrets. See Syngenta Crop Protection, LLC v. Willowood USA, LLC, 2016 WL
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`4925099, at *2-*3 (D. Del. Sept. 14, 2016) (sales and revenue information constitute trade
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`secrets); SI Handling Sys., Inc. v. Heisley, 753 F.2d 1244, 1260 (3d Cir. 1985) (costing and
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`pricing information that is not “readily obtainable by anyone in the industry” qualifies for trade
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`secret protection). Sony derives independent economic value from this information not being
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`generally known to, and not being readily ascertainable by proper means by, others who can
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`obtain economic value from its disclosure. See Taro Pharms, 2015 WL 7737310, at *1 (quoting
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`DEL. CODE.ANN. tit 6, § 2001(4)(a), (b)). (See also Hunziker Decl. ¶¶ 5-6 (explaining
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`potential economic harm to Sony if this information were known to Defendants).)
`4
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 6 of 13 PageID #: 25020
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`Sony makes substantial and reasonable efforts to maintain the secrecy of the financial
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`terms of its publisher agreements. (Hunziker Decl. ¶ 7.) For example, in order to shield this
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`information from the public and within the video-game publisher community,
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` (Id.) Moreover, as reflected in the agreements themselves, Sony ensures
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`contractually that each of the Defendants maintains the secrecy of the terms of its respective
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`publishing agreement(s) with Sony. (See id. ¶ 8.)
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`B.
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`Production of the Sony Publisher Agreement Financial Terms Might Harm
`Sony.
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`Disclosure of the financial terms of Sony’s redacted publisher agreements “might be
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`harmful” to Sony, for several reasons. Taro Pharms, 2015 WL 7737310, at *1 (internal
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`quotations omitted). First,
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`Fourth,
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`. Second,
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`Third,
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`(See Hunziker Decl. ¶¶ 3-5); see also Taro Pharms, 2015 WL
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`7737310, at *2 (“Courts generally presume that disclosure to a competitor is more harmful that
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`[sic] disclosure to a noncompetitor.”) (internal quotations omitted); Syngenta, 2016 WL
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`4925099, at *2 (same).
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`
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`5
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 7 of 13 PageID #: 25021
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`
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`(See Hunziker Decl. ¶ 6.)
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`C.
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`The Sony Publisher Agreement Financial Terms Are Not Relevant, Much
`Less Necessary, To This Action.
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`Because Sony protects the financial terms of its publisher agreements as trade secrets and
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`disclosure of the trade secrets might be harmful to Sony, the “burden shifts to the party seeking
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`disclosure to show that the disclosure of the trade secrets is both relevant and necessary.” See
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`Taro Pharms, 2015 WL 7737310, at *1. To satisfy relevance, Plaintiff “must show that the
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`material sought is relevant to the subject matter of the lawsuit.” Id. (internal quotations omitted)
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`In order to satisfy the necessity requirement, Plaintiff “must establish that [the information
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`sought] is reasonably necessary for a fair opportunity to develop and prepare the case for trial.”
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`Id. (internal quotations omitted). “Where proof of either relevance or need is not established,
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`discovery is properly denied.” Am. Standard Inc. v. Pfizer Inc., 828 F.2d 734, 743 (Fed. Cir.
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`1987) (emphasis in original). Plaintiff has not met its burden.
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`Plaintiff’s assertion that the publisher agreement payment terms are “relevant to the
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`reasonable royalty analysis” is unsupported and wrong. (See August 29, 2017 Email from Aaron
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`Frankel to Special Master Terrell.) As a matter of law, the payment terms of the publisher
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`agreements are not relevant to the reasonable royalty analysis in this action because the
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`agreements are not comparable license agreements—i.e., they are not comparable to the
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`hypothetical patent license agreement that the would-be licensor (here, Plaintiff) and the would-
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`be licensees (here, Defendants) would have entered for a license under the patents-in-suit, had
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`the parties negotiated and entered into a patent license on the eve of the alleged infringement).
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`The publisher agreements set forth the terms under which Defendants are permitted to publish
`6
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 8 of 13 PageID #: 25022
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`video games for use on Sony’s video-game platforms, such as Sony’s PS4 console. The
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`publisher agreements are irrelevant to the reasonable royalty determination in this action. See
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`ResQNet.com, Inc. v. Lansa, Inc., 594 F.3d 860, 870 (Fed. Cir. 2010) (Plaintiff’s expert
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`improperly relied upon “rebundling licenses” which “furnished finished software products and
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`source code, as well as services such as training, maintenance, marketing, and upgrades, to other
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`software companies in exchange for ongoing revenue-based royalties” and had no relation to the
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`claimed invention.); see also M2M Sols. LLC v. Enfora, Inc. 167 F. Supp. 3d 665, 675-76 (D.
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`Del. 2016) (“The testimony of a damages expert in a patent suit who relies on non-comparable
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`licenses in reaching his royalty rate should be excluded.”) (internal quotations omitted); Uniloc
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`USA, Inc. v. Microsoft Corp., 632 F.3d 1292, 1317 (Fed. Cir. 2011) (“there must be a basis in
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`fact to associate the royalty rates used in prior licenses to the particular hypothetical negotiation
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`at issue in the case.”).4
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`Plaintiff has not even argued, much less demonstrated, that the Sony publisher agreement
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`financial terms are necessary to this action. Such terms are not relevant to a reasonable royalty
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`analysis. Defendants have confirmed that they do not intend to rely on the redacted information
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`in the publisher agreements with Sony. Discovery of the publisher agreement financial terms
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`4 Sony understands that Plaintiff is no longer seeking the production of the any redacted terms other than the
`payment terms in the Sony publisher agreements with Defendants. Sony therefore does not address Plaintiff’s other
`two relevance arguments – that they provide context and that they are needed to respond to Defendants’ “purported
`implied license defense to Acceleration Bay’s claims for infringement and damages.” Plaintiff’s Letter Brief at 3, 5.
`To the extent Plaintiff is still seeking production of any redacted terms other than the payment terms, the
`information is irrelevant and the redactions are narrow enough in scope that their content is readily apparent and
`they are not necessary to provide context. See Beverage Distribs., Inc. v. Miller Brewing Co., 2010 WL 1727640, at
`*5 (S.D. Ohio April 28, 2010) (“In those cases cited by defendants where redactions were approved, the number of
`redacted documents appeared to be small, and the content of the redactions was readily apparent”); One World
`Foods, Inc. v. Stubb’s Austin Restaurant Co. LC, 2016 WL 8678866, at *4 (W.D. Tex. Dec. 2, 2016) (“Defendants
`focus on how a redacted SPA will make it more difficult to pose questions to witnesses. The Court, however, is not
`concerned with Defendants’ inability to rephrase their questions to witnesses. The pertinent inquiry for discovery is
`relevance.”) (internal citations omitted). Moreover, Plaintiff does not need to respond to Defendants’ “purported
`implied license defense to Acceleration Bay’s claims for infringement and damages” as that defense is no longer
`relevant in light of the Court’s dismissal of Plaintiff’s claims against products for use on Sony platforms.
`7
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 9 of 13 PageID #: 25023
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`should thus be denied. See Am. Standard, 828 F.2d at 743 (“Where proof of either relevance or
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`need is not established, discovery is properly denied.”) (emphasis in original).
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`
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`D.
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`The Injury to Sony Outweighs Any Need for The Publisher Agreement
`Payment Terms.
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`Even if this Court were to find the information was both relevant and necessary (which it
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`is not) the injury to Sony that could result from disclosure in this action—even under a protective
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`order—is sufficient to outweigh Plaintiff’s purported need for the information. See Taro
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`Pharms, 2015 WL 7737310, at *2 (“After the moving party has shown relevancy and need, the
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`court must balance the need for the information against the injury that would ensue if disclosure
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`is ordered.”) (internal quotations and citations omitted).
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`Here, as discussed above, Sony might be harmed by the disclosure of the publisher
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`payment terms. (See Section II; see also Hunziker Decl. ¶¶ 3-6.) Sony is also a non-party to this
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`litigation. Cf. Taro Pharms, 2015 WL 7737310, at *2 (“Also, courts may consider a subpoenaed
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`party’s status as a non-party in the analysis.”).
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`The fact that there is a discovery protective order in place does not render the requested
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`production of Sony’s publisher agreement payment terms risk free or appropriate in this case. As
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`this Court has recognized:
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`What happens with any information disclosed by [non-party] in response to [plaintiff’s]
`subpoena, particularly at trial, is anyone’s guess. Although the protective order allows the
`designation by [non-party] that such information is confidential and limits initial
`disclosure to outside counsel, the parties to this litigation are left with the option of how
`disclosure of such confidential information is handled at trial.
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`Mannington Mills, Inc. v. Armstrong World Indus., Inc., 206 F.R.D. 525, 530–31 (D. Del. 2002).
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`As a non-party, Sony would be relying upon Defendants, Plaintiff, and the Court “‘to maintain
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`the confidentiality designation or to limit public disclosure ... during trial.’” Id. (“Despite
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`[plaintiff’s] arguments to the contrary, ‘it would be divorced from reality to believe that either
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`8
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 10 of 13 PageID #: 25024
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`party here would serve as the champion of its competitor ... to maintain the confidentiality
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`designation or to limit public disclosure ... during trial.’”) (quoting Micro Motion, Inc. v. Kane
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`Steel Co., Inc., 894 F.2d 1318, 1325 (Fed. Cir. 1990)). And, unless the Court seals the
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`courtroom, and Judge Andrews has indicated that he prefers not to do so,
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`
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` See
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`E.I. DuPont de Meours & Co. v. Unifrax I LLC, 14-cv-1250-RGA, D.I. 281 at 12 (D. Del. April
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`28, 2017) (“And, so, you know, I’m not a big fan of closing the courtroom”).
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`
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` (See Hunziker Decl. ¶ 6.)
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`E.
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`The Publisher Agreement Financial Terms Should Remain Redacted.
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`Redaction of Sony’s publisher agreement financial terms is appropriate here and
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`consistent with the revised Federal Rules, which permit only discovery “proportional to the
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`needs of the case.” Fed. R. Civ. P. 26(b)(1). Particularly in light of its irrelevance to the
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`underlying matters, redactions of highly confidential trade-secret information belonging to a non-
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`party properly takes into account “the importance of the issues at stake in the action … the
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`importance of the discovery in resolving the issues, and whether the burden or expense of the
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`proposed discovery outweighs its likely benefit.” Id.; see also XTO Energy, Inc. v. ATD, LLC,
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`2016 WL 1730171, at *16 (D. NM April 1, 2016) (“The 2015 amendment [to Rule 26(b)(1)]
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`made notable deletions and additions, both of which aimed to emphasize the need to make
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`discovery proportional to the needs of the case.”). Moreover, “‘[a]lthough Rule 26(b) applies
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`equally to discovery of nonparties, the fact of nonparty status may be considered by the court in
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 11 of 13 PageID #: 25025
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`weighing the burdens imposed in the circumstances.’” Syngenta, 2016 Wl 4925099, at *2
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`(quoting Katz v. Batavia Marine & Sporting Supplies, Inc., 984 F.2d 422, 424 (Fed. Cir. 1993)).
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`Because any burden associated with the redactions is minimal, and non-party Sony might
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`be harmed by the production of this irrelevant, highly sensitive trade-secret information,
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`redactions of the information that Plaintiff seeks should be allowed. See, e.g., Dutcher v. Bold
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`Films LP, 2017 WL 1901418, *7 (D. Utah May 8, 2017) (“Irrelevant information like financial
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`data, business contracts, and personal emails of celebrities need not be disclosed merely because
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`they appear on a document that contains information that is relevant to this case.”) (emphasis
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`added); One World Foods, Inc. v. Stubb’s Austin Restaurant Co. LC, 2016 WL 8678866, at *4
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`(W.D. Tex. Dec. 2, 2016) (“The pertinent inquiry for discovery is relevance. After reviewing the
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`redacted sections of the SPA in camera, the Court is convinced that the redacted portions contain
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`irrelevant and sensitive personal and commercial information, nearly all of which relate to third
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`parties. …. Therefore, the redactions to the SPA properly withheld sensitive, irrelevant
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`information”).
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`Delaware Display Group LLC v. Lenovo Group Ltd., 2016 WL 720977 (D. Del. Feb. 23,
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`2016) does not compel a different result. There, the court “reluctantly conclude[d] that Plaintiffs
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`must produce unredacted versions of the royalty reports” and found that “[t]he sensitive
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`information [attorney’s fees] is protected from further disclosure by the Protective Order.” Id. at
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`*6. First, there is no indication that plaintiffs in Delaware Display had protected its attorney’s
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`fees as trade secrets. Second, the court “acknowledged that there is a split of authority”
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`regarding redacting irrelevant information but concluded that disallowing redaction was “more
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`persuasive. Since the producing party is ordinarily ‘not harmed by producing irrelevant
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`information or by producing sensitive information which is subject to a protective order,’
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`10
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 12 of 13 PageID #: 25026
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`redactions are unnecessary.” Id. at *6 n.11 (quoting Beverage Distribs., Inc. v. Miller Brewing
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`Co., 2010 WL 1727640, at *4 (S.D. Ohio April 28, 2010)). 5 Here, Sony’s trade-secret
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`information is irrelevant and Sony submits that it could be harmed by the production of this
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`irrelevant sensitive information. (See Hunziker Decl. ¶¶ 5-6.) Redactions are therefore
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`necessary. Because of the injury that would otherwise occur to Sony, good cause exists to limit
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`discovery in this manner.
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`CONCLUSION
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`For all of the foregoing reasons, Sony respectfully requests that the Court deny Plaintiff’s
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`request as to the Sony agreements, grant Sony’s request for a Protective Order and allow Sony’s
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`highly confidential trade secret information to remain redacted.
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`Respectfully Submitted,
`
`/s/ Gregory B. Williams
`Gregory B. Williams (ID# 4195)
`Austen C. Endersby (ID# 5161)
`FOX ROTHSCHILD LLP
`919 N. Market Street
`Suite 300
`Wilmington, DE 19899-2323
`(302) 622-4211
`gwilliams@foxrothschild.com
`aendersby@foxrothschild.com
`
`-and-
`
`Tara D. Elliott (ID# 4483)
`WILMER CUTLER PICKERING HALE AND
`DORR LLP
`
`5 The court in Beverage Distributors Inc. found in camera review of redacted documents to be “impractical”
`because of the “extent of the redactions” – a substantial percentage of the thousands of pages of documents
`produced – and distinguished that scenario from the cases allowing redactions where the court only had to review a
`small number of documents, and “redactions involved a single type of document and one or two discrete categories
`of allegedly irrelevant information.” Beverage Distribs., 2010 WL 1727640 at *3, *5. Here, only three documents
`are at issue and “the content of the redactions [is] readily apparent.” Id. at *5. Accordingly, any burden associated
`with the redactions is minimal.
`11
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`Case 1:16-cv-00453-RGA Document 298 Filed 09/08/17 Page 13 of 13 PageID #: 25027
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`1875 Pennsylvania Avenue, NW
`Washington, DE 20006
`(202) 663-6748
`tara.elliott@wilmerhale.com
`
`Date: August 30, 2017
`
`12
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