`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ACCELERATION BAY LLC,
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`Plaintiff,
`
`v.
`
`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
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`C.A. No. 16-455 (RGA)
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`REDACTED
`PUBLIC VERSION
`Original Filing Date: July 22, 2019
`Redacted Filing Date: July 30, 2019
`
`DECLARATION OF JOE NETIKOSOL
`IN SUPPORT OF TAKE-TWO INTERACTIVE SOFTWARE, INC.,
`ROCKSTAR GAMES, INC., and 2K SPORTS, INC.’S OPENING BRIEF
`IN SUPPORT OF THIER MOTION FOR SUMMARY JUDGMENT
`
`I, Joe Netikosol, declare:
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`1.
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`I am an associate attorney with the law firm Winston & Strawn LLP, counsel of
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`record for Take-Two Interactive Software, Inc., Rockstar Games, Inc., and 2K Sports, Inc.
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`(“Defendants” or “Take-Two”) for the above referenced matter.
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`2.
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`Attached as Exhibit A-8 is a true and correct copy of Take-Two’s Response to
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`Plaintiff’s Common Interrogatory No. 6.
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`3.
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`Attached as Exhibit A-9 is a true and correct copy of Take-Two’s Response to
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`Plaintiff’s Common Interrogatory No. 1.
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`4.
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`Attached as Exhibit A-10 is a true and correct copy of excerpts of Acceleration
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`Bay’s infringement contentions for GTA and NBA 2K, dated July 11, 2017.
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`5.
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`Attached as Exhibit E-10 is an additional excerpt of the true and correct copy of
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`the deposition transcript of Dr. Michael Mitzenmacher.
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`6.
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`Attached as Exhibit E-11 is an additional excerpt of the true and correct copy of
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`the deposition transcript of Dr. Nenad Medvidović.
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`
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`Case 1:16-cv-00455-RGA Document 481 Filed 07/30/19 Page 2 of 4 PageID #: 34278
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`I declare under penalty of perjury that the foregoing is true and correct. Executed this
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`22nd day of July 2019, in Los Angeles, California.
`
`/s/ Joe Netikosol
`Joe Netikosol
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`2
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`
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`Case 1:16-cv-00455-RGA Document 481 Filed 07/30/19 Page 3 of 4 PageID #: 34279
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 30, 2019, I caused the foregoing to be electronically
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`filed with the Clerk of the Court using CM/ECF, which will send notification of such filing to all
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`registered participants.
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`I further certify that I caused copies of the foregoing document to be served
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`on July 30, 2019, upon the following in the manner indicated:
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`Philip A. Rovner, Esquire
`Jonathan A. Choa, Esquire
`POTTER ANDERSON & CORROON LLP
`1313 North Market Street
`Hercules Plaza, 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
`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
`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)
`
`
`
`Case 1:16-cv-00455-RGA Document 481 Filed 07/30/19 Page 4 of 4 PageID #: 34280
`Case 1:16-cv-00455-RGA Document 481 Filed 07/30/19 Page 4 of 4 PagelD #: 34280
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`EXHIBITS A8-10 AND E10-11
`EXHIBITS A8-10 AND E10-11
`REDACTED IN THEIR ENTIRETY
`REDACTED IN THEIR ENTIRETY
`
`
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