`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 16-453 (RGA)
`
`
`
`))))))))
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.
`
`Defendant.
`
`DECLARATION OF YURIDIA CAIRE IN SUPPORT OF
`PLAINTIFF ACCELERATION BAY LLC’S OPPOSITION TO
`ACTIVISION’S OBJECTIONS TO ACCELERATION BAY’S DAMAGES PROFFER
`
`Philip A. Rovner (#3215)
`Jonathan A. Choa (#5319)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza
`P.O. Box 951
`Wilmington, DE 19899
`(302) 984-6000
`provner@potteranderson.com
`jchoa@potteranderson.com
`
`Attorneys for Plaintiff
`Acceleration Bay LLC
`
`OF COUNSEL:
`
`Paul J. Andre
`Lisa Kobialka
`James Hannah
`Yuridia Caire
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`(650) 752-1700
`
`Aaron M. Frankel
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`(212) 715-9100
`
`Dated: April 5, 2019
`
`PUBLIC VERSION
`
`Public version dated: April 12, 2019
`
`
`
`Case 1:16-cv-00453-RGA Document 670 Filed 04/12/19 Page 2 of 3 PageID #: 51928
`
`I, Yuridia Caire, declare as follows:
`
`1.
`
`I am an attorney with the law firm Kramer Levin Naftalis & Frankel LLP, counsel
`
`of record for Acceleration Bay LLC (“Acceleration Bay”) for the above referenced matter. I
`
`have personal knowledge of the facts stated herein and can testify competently to those facts. I
`
`make this declaration in support of Plaintiff Acceleration Bay LLC’s Opposition to Activision’s
`
`Objections to Acceleration Bay’s Damages Proffer.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Supplement to
`
`Expert Report of Russell Parr, served on March 19, 2019.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of a screenshot taken from
`
`Call of Duty Team Deathmatch, bearing Bates number AB-AB 002486.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of a screenshot taken from
`
`Call of Duty Moshpit mode, bearing Bates number AB-AB 002484.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of a screenshot taken from
`
`Call of Duty Gun Game, bearing Bates number AB-AB 002487.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of pages 184-185 from the
`
`transcript of the deposition of John Kirk, taken on May 18, 2017.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts from a World
`
`of Warcraft document, bearing Bates numbers ATVI0030440–41.
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of pages 105-106 and 109
`
`from the transcript of the deposition of Ricardo Valerdi, taken on December 21, 2017.
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of pages 7-10 and 62-63
`
`from the transcript of the deposition of Catharine Mary Lawton, taken on January 25, 2018.
`
`
`
`Case 1:16-cv-00453-RGA Document 670 Filed 04/12/19 Page 3 of 3 PageID #: 51929
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of the July 2002 business
`
`plan from Panthesis Incorporated, bearing Bates numbers HOLT 002332–59.
`
`11.
`
`Attached hereto as Exhibit 10 is a true and corrected copy of page 490 from the
`
`transcript of the deposition of Fred B. Holt, taken on July 26, 2017.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of pages 162-163 from
`
`the transcript of the deposition of Fred B. Holt, taken on May 31, 2017.
`
`13.
`
`Attached hereto as Exhibit 12 is a true and correct copy of pages 22-23 from the
`
`transcript of proceedings held on January 10, 2017.
`
`14.
`
`Attached hereto as Exhibit 13 is a true and correct copy of page 38 from the
`
`transcript of the deposition of Natasha Radovsky, taken on May 4, 2017.
`
`I declare under penalty of perjury of the United States of America that the foregoing is
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`true and correct. Executed on April 5, 2019, in El Paso, Texas.
`
`By: /s/ Yuridia Caire
`Yuridia Caire
`
`6144803
`
`2
`
`
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