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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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`Plaintiff,
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`v.
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`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
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`Defendants.
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`C.A. No. 16-455-RGA
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`[PROPOSED] ORDER
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`WHEREAS, the Special Master having considered Plaintiff Acceleration Bay LLC’s
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`(“Acceleration Bay”) Motion to Compel and the related briefing and oral argument thereto;
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`IT IS HEREBY ORDERED this ___ day of ________________, 2018, that Acceleration
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`Bay’s Motion is hereby GRANTED.
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`Within five business days of this order, Take-Two shall produce, in Excel format, the
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`total number of unique users worldwide of the accused NBA2K products, for the timeframe of
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`April 2015 through the present, including: (i) the total number of unique users for NBA 2K15
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`and 2K16, (ii) the total number of unique users of the different modes, (iii) the break-down of
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`how many unique users are participating in a particular mode, i.e. one player, two to four
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`players, more than four players, and (iv) the breakdown of these players participating in the
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`United States as well as the rest of the world
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`____________________________________
` Special Master Allen M. Terrell, Jr.
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`5603652
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