`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-453 (RGA)
`
`REDACTED -
`PUBLIC VERSION
`
`DECLARATION OF MAXWELL MCGRAW IN SUPPORT OF
`ACTIVISION BLIZZARD, INC.’S REPLY BRIEF IN SUPPORT OF
`MOTION TO STRIKE EXPERT REPORT OF RUSSELL PARR
`
`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
`
`David P. Enzminger
`Louis L. Campbell
`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
`
`Attorneys for Defendant
`
`OF COUNSEL:
`
`B. Trent Webb
`Aaron Hankel
`John Garretson
`Tanya Chaney
`Jordan T. Bergsten
`Maxwell C. McGraw
`SHOOK, HARDY & BACON LLP
`2555 Ground Boulevard
`Kansas City, MO 64108
`(816) 474-6550
`
`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
`
`Original Filing Date: April 19, 2019
`Redacted Filing Date: May 1, 2019
`
`
`
`Case 1:16-cv-00453-RGA Document 687 Filed 05/01/19 Page 2 of 3 PageID #: 52277
`
`I, Maxwell C. McGraw, hereby declare as follows:
`
`1.
`
` I am an attorney with the law firm of Shook, Hardy & Bacon LLP, 2555 Grand
`
`Boulevard, Kansas City, Missouri 64108. Shook, Hardy & Bacon LLP is counsel for Defendant
`
`Activision Blizzard, Inc. (“Activision”) in the instant action. I am admitted to the bar of the
`
`State of Missouri and have been admitted in this case pro hac vice.
`
`2.
`
`I make this Declaration in support of Activision’s reply in support of its motion to
`
`strike expert report of Russell Parr. I am familiar with the facts contained and documents
`
`described in the same.
`
`3.
`
`Attached as Exhibit 1 is a true and correct excerpt of the Expert Report of Russell
`
`L. Parr, dated December 7, 2018.
`
`4.
`
`Attached as Exhibit 2 is a true and correct excerpt of the Expert Report of
`
`Christine S. Meyer, Ph.D., dated September 25, 2017, designated “CONFIDENTIAL –
`
`OUTSIDE COUNSEL ONLY”.
`
`5.
`
`Attached as Exhibit 3 is a true and correct excerpt of the First Supplemental
`
`Expert Report of Catharine M. Lawton, dated January 25, 2019, designated “CONFIDENTIAL”.
`
`6.
`
` Attached as Exhibit 4 is a true and correct excerpt of the Rebuttal Expert Report
`
`of Catharine M. Lawton, dated November 13, 2017, designated “CONFIDENTIAL – OUTSIDE
`
`COUNSEL ONLY”.
`
`I declare under penalty of perjury that the foregoing is true and correct
`
`
`Dated: April 19, 2019
`
`
`
`
`Declaration of Maxwell C. McGraw
`
`By: /s/ _________________________
`Maxwell C. McGraw
`
`
`
`
`
`(1 of 2)
`
`
`
`Case 1:16-cv-00453-RGA Document 687 Filed 05/01/19 Page 3 of 3 PageID #: 52278
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 1, 2019, I caused the foregoing to be electronically
`
`filed with the Clerk of the Court using CM/ECF, which will send notification of such filing to all
`
`registered participants.
`
`I further certify that I caused copies of the foregoing document to be served on May
`
`1, 2019, upon the following in the manner indicated:
`
`Philip A. Rovner, Esquire
`Jonathan A. Choa, Esquire
`POTTER ANDERSON & CORROON LLP
`1313 North Market Street, 6th Floor
`Wilmington, DE 19801
`Attorneys for Plaintiff
`
`Paul J. Andre, Esquire
`Lisa Kobialka, Esquire
`James R. Hannah, Esquire
`Hannah Lee, Esquire
`Yuridia Caire, Esquire
`Greg Proctor, Esquire
`Michael H. Lee, Esquire
`William Hannah, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Attorneys for Plaintiff
`
`Aaron M. Frankel, Esquire
`Marcus A. Colucci, Esquire
`Cristina Martinez, Esquire
`Shannon H. Hedvat, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Attorneys for Plaintiff
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`/s/ Stephen J. Kraftschik
`_______________________________
`Stephen J. Kraftschik (#5623)
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
