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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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`v.
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`Defendant.
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`ACCELERATION BAY LLC,
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`ELECTRONIC ARTS INC.,
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`Plaintiff,
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`v.
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`Defendant.
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`C.A. No. 16-453 (RGA)
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`C.A. No. 16-454 (RGA)
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`C.A. No. 16-455 (RGA)
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`))))))))))))
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`))))))))))
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`)))))))))))
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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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`v.
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`Defendants.
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`DECLARATION OF MICHAEL GOODRICH, PH.D.
`IN SUPPORT OF PLAINTIFF ACCELERATION BAY LLC.’ S
`MOTIONS FOR SUMMARY JUDGMENT
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`Case 1:16-cv-00455-RGA Document 390 Filed 02/02/18 Page 2 of 3 PageID #: 27226
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`I, Michael Goodrich, Ph.D., hereby declare as follows:
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`1.
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`I am a Chancellor’s Professor in the Department of Computer Science at
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`the University of California, Irvine, and have been retained by counsel for Plaintiff Acceleration
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`Bay, LLC (“Acceleration Bay”) to serve as an expert witness in the above-captioned action.
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`2.
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`I submit this declaration in support of Acceleration Bay’s Motions for
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`Summary Judgment.
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`3.
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`Attached to Acceleration Bay’s Motions for Summary Judgment Brief is a
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`true and correct copy of my Expert Report Regarding Validity of U.S. Patent Nos. 6,701,344,
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`6,829,634, 6,714,966, 6,732,147, 6,920,497 and 6,910,069 dated November 13, 2017 (“Expert
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`Report”).
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`4.
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`I also understand that Acceleration Bay will submit a copy of its summary
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`judgment papers with hyperlinks linking to complete true and accurate copies of the above
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`report.
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`5.
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`I incorporate by reference the opinions set forth in my Expert Report in
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`the above referenced matter, and swear to their contents, as if fully set forth herein.
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`6.
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`The statements and opinions set forth in my Expert Report for this case are
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`true and accurate based on my personal knowledge and professional experience. My Expert
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`Report also accurately reflects the facts and circumstances described therein.
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`7.
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`I expect to testify at trial in this action regarding the opinions set forth in
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`my Expert Report, as well as on any other issues for which I have submitted or will submit an
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`expert report in this action.
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`1
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`Case 1:16-cv-00455-RGA Document 390 Filed 02/02/18 Page 3 of 3 PageID #: 27227
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`I declare under penalty of perjury of the laws of the United States that the
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`foregoing is true and correct to the best of my knowledge.
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`Executed this 2nd day of February, 2018.
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`Goodrich, Ph.D
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