`
`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`Philip A. Rovner
`Partner
`Attorney at Law
`provner@potteranderson.com
`302 984-6140 Direct Phone
`302 658-1192 Firm Fax
`
`February 5, 2020
`
`BY CM/ECF & HAND DELIVERY
`
`The Honorable Richard G. Andrews
`U.S. District Court for the District of Delaware
`U.S. Courthouse
`844 North King Street
`Wilmington, DE 19801
`
`Re:
`
`Acceleration Bay LLC v. Take-Two Interactive Software, Inc.,
`C.A. No. 16-455-RGA (D. Del.)
`
`Dear Judge Andrews:
`
`Further to the Court’s request during yesterday’s hearing, Acceleration Bay is asserting
`the following patents and claims against the Take-Two Defendants:
`
`
`
`
`
`
`
`
`
`
`
`6,701,344, Claims: 12, 13, 14, and 15;
`
`6,714,966, Claims: 12 and 13;
`
`6,920,497, Claims: 9 and 16;
`
`6,732,147, Claim: 1; and
`
`6,910,069, Claims: 1 and 11.
`
`Acceleration Bay asserts literal infringement for all elements of the asserted claims.
`Acceleration Bay further asserts, in the alternative, that the Take-Two Defendants infringe the
`following claim elements under the Doctrine of Equivalents:
`
`’344 Patent
`
` Claim 12: processor; at least 3 neighbors; originating participant sends data to the
`other participants by sending the data through each of its connections to its neighbor
`participants and wherein each participant sends data that it receives from a neighbor
`participant to its other neighbor participants; m-regular; non-complete; broadcast
`channel;
`
`
`
`Case 1:16-cv-00455-RGA Document 489 Filed 02/05/20 Page 2 of 3 PageID #: 34310
`The Honorable Richard G. Andrews
`February 5, 2020
`Page 2
`
` Claim 13: distributed game; broadcast channel; provide game information; at least 3
`neighbors; originating participant sends data to the other participants by sending the
`data through each of its connections to its neighbor participants and wherein each
`participant sends data that it receives from a neighbor participant to its neighbor
`participants; m-regular; non-complete; identify broadcast channel for game of
`interest; connecting to the identified broadcast channel;
`
` Claim 14: accessing web server that maps game to broadcast channel;
`
` Claim 15: broadcast channel formed by at least 3 other computers;
`
`’966 Patent
`
` Claim 12: network; computer network at least 3 neighbor participants; relaying; m-
`regular; incomplete; broadcast channel for a topic of interest;
`
` Claim 13: information delivery service; plurality of broadcast channels; each
`broadcast channel provides information to plurality of participants; at least 3
`neighbors; relaying; m-regular; non-complete; identifying a broadcast channel;
`connecting to identified broadcast channel;
`
`’497 Patent
`
` Claim 9: locate call-in port; identifying portal computer having dynamically selected
`call-in port; repeatedly trying to establish connection; port ordering algorithm;
`reordering communications port;
`
`’147 Patent
`
` Claim 1: m-regular; disconnect message; connection port search; third computer
`being one of the neighbors on said list of neighbors;
`
`’069 Patent
`
` Claim 1: m-regular; identifying a pair of participants; contact a portal computer; edge
`connection request; disconnecting participants of the identified pair; connecting
`participants of the identified pair.
`
`
`
`Case 1:16-cv-00455-RGA Document 489 Filed 02/05/20 Page 3 of 3 PageID #: 34311
`The Honorable Richard G. Andrews
`February 5, 2020
`Page 3
`
`Should Your Honor have any further questions, counsel is available at the Court’s
`convenience.
`
`Respectfully,
`
`/s/ Philip A. Rovner
`
`Philip A. Rovner (#3215)
`
`PAR/mas/6566551
`cc: All Counsel of Record
`
`
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