`
`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.
`
`ACCELERATION BAY LLC’S MOTION FOR LEAVE TO FILE REPLY
`
`Plaintiff Acceleration Bay LLC respectfully moves the Court for leave to file the attached,
`
`two-page reply (Ex. 1 hereto), in response to Defendant’s Opposition (D.I. 696) to Acceleration
`
`Bay’ Motion for Reconsideration (D.I. 695) (the “Motion”).
`
`The requested relief is sought in order to address three points raised in Defendant’s
`
`Opposition (1) Defendant’s admission that SEER-SEM is a reliable methodology, (2) Defendant’s
`
`characterization of Dr. Valerdi’s inputs to the SEER-SEM model as unreliable, and (3)
`
`Defendant’s characterization of the Federal Circuit’s decision in Prism Techs. LLC v. Sprint
`
`Spectrum LP, 849 F.3d 1360 (Fed. Cir. 2017). A response is required to address Defendant’s
`
`mischaracterizations on each of these issues.
`
`On September 26 and 27, 2019, Delaware counsel for Acceleration Bay contacted
`
`Defendant’s Delaware counsel by telephone and email to discuss this motion. Defendant does not
`
`agree to the relief requested.
`
`
`
`Case 1:16-cv-00453-RGA Document 697 Filed 09/27/19 Page 2 of 2 PageID #: 52360
`
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Philip A. Rovner
`Philip A. Rovner (#3215)
`Jonathan A. Choa (#5319)
`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
`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: September 27, 2019
`6418193
`
`2
`
`
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