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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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`DECLARATION OF RICARDO VALERDI, PH.D.
`IN SUPPORT OF PLAINTIFF ACCELERATION BAY LLC’S
`OPPOSITION TO DEFENDANT ACTIVISION BLIZZARD, INC.’S MOTIONS FOR
`SUMMARY JUDGMENT AND TO EXCLUDE EXPERT OPINIONS UNDER FRE 702
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`
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`C.A. No. 16-453 (RGA)
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`))))))))))))
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`Plaintiff,
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`v.
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`Defendant.
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`
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`Case 1:16-cv-00453-RGA Document 476 Filed 02/23/18 Page 2 of 3 PageID #: 39295
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`I, Ricardo Valerdi, Ph.D., hereby declare as follows:
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`1.
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`I am an Associate Professor in the Systems and Industrial Engineering
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`Department at the University of Arizona, and have been retained by counsel for Plaintiff
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`Acceleration Bay, LLC (“Acceleration Bay”) to serve as an expert witness in the above-
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`captioned action.
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`2.
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`I submit this declaration in support of Acceleration Bay’s Opposition to
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`Defendant Activision Blizzard, Inc.’s Motions for Summary Judgment and to Exclude Expert
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`Opinions (“Opposition”).
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`3.
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`Attached to Acceleration Bay’s Opposition are true and correct copies of my (1)
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`Expert Report Regarding Cost Estimates, dated September 23, 2017 (“Opening Report”), and (2)
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`Errata to my Opening Report, dated October 23, 2017.
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`4.
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`I also understand that Acceleration Bay will submit a copy of its Opposition with
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`hyperlinks linking to complete true and accurate copies of the above reports.
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`5.
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`I incorporate by reference the opinions set forth in my expert reports in the above
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`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 reports for this case are true
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`and accurate based on my personal knowledge and professional experience. My expert reports
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`also accurately reflect 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 my
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`expert reports, as well as on any other issues for which I have submitted or will submit an expert
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`report in this action.
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`- 1 -
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`Case 1:16-cv-00453-RGA Document 476 Filed 02/23/18 Page 3 of 3 PageID #: 39296
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`I declare under penalty of perjury of the laws of the United States that the foregoing is
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`true and correct to the best of my knowledge.
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`Executed this 23rd day of February, 2018.
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`
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`___________________
`Ricardo Valerdi, Ph.D.
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`- 2 -
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