`
`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`Philip A. Rovner
`Partner
`provner@potteranderson.com
`(302) 984-6140 Direct Phone
`(302) 658-1192 Fax
`
`February 15, 2017
`
`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. Activision Blizzard, Inc. et al.
`D. Del., C.A. No. 16-453-RGA, 16-454-RGA, 16-455-RGA
`
`Dear Judge Andrews:
`
`Further to Section G of the parties’ Proposed Scheduling Order (D.I. 46), Plaintiff
`Acceleration Bay submits the attached proposed Protective Order. The parties have agreed on all
`but one term of the proposed Protective Order: if the prosecution bar should exclude previously
`filed inter partes review proceedings in which the deadline has already passed to amend
`claims. This disputed provision is underlined in Section 10.7 of the proposed Protective Order.
`
`Acceleration Bay proposes that the parties present this limited issue to the Court during
`Friday’s Rule 16 conference. Defendants propose that the issue be presented to the Special
`Master for resolution.
`
`Respectfully,
`/s/ Philip A. Rovner
`Philip A. Rovner (#3215)
`
`All Counsel of Record (Via ECF Filing, Electronic Mail)
`cc:
`Attachment
`
`
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