Paper No. __
`Filed: August 13, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`BUNGIE, INC.,
`Petitioner,
`
`v.
`
`WORLDS INC.,
`Patent Owner.
`_____________________________
`
`Case IPR2015-01319
`Patent 8,082,501
`_____________________________
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`MOTION FOR ROUTINE OR ADDITIONAL DISCOVERY
`
`
`Filed: August 13, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`BUNGIE, INC.,
`Petitioner,
`
`v.
`
`WORLDS INC.,
`Patent Owner.
`_____________________________
`
`Case IPR2015-01319
`Patent 8,082,501
`_____________________________
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`MOTION FOR ROUTINE OR ADDITIONAL DISCOVERY
`
`
`
`IPR2015-01319
`Patent 8,082,501
`
`Table of Contents
`
`Page
`
`I.
`
`II.
`
`INTRODUCTION ................................................................................................. 1
`
`BACKGROUND ................................................................................................... 2
`
`III. ANALYSIS ......................................................................................................... 4
`
`A.
`
`B.
`
`PO’s Argument Regarding Routine Discovery is Misplaced ............... 4
`
`PO’s Requested Discovery is Not in the Interest of Justice .................. 5
`
`i.
`
`ii.
`
`PO’s Motion is Based on a False Premise .................................. 6
`
`Requested Financial Discovery is Overly Broad, Unduly
`Burdensome, and Would Not be Useful ..................................... 8
`
`iii. Request for Communications Concerning Legal Reviews
`is Not Narrowly Tailored ............................................................ 9
`
`iv.
`
`Request for Communications Concerning
`Indemnification is Overbroad and Lacks Relevance ................ 10
`
`IV. CONCLUSION ................................................................................................... 10
`
`V. APPENDIX – LIST OF EXHIBITS ........................................................................ 11
`
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`IPR2015-01319
`Patent 8,082,501
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`I.
`
`INTRODUCTION
`
`Pursuant to the Board’s July 30, 2015 Order (Paper 8), Petitioner Bungie,
`
`Inc. (“Bungie”) submits this Opposition to Patent Owner Worlds Inc.’s (“Patent
`
`Owner” or “PO”) Motion for Routine or Additional Discovery (Paper 9).
`
`PO’s motion cites to (1) a Software Publishing and Development Agreement
`
`(“DevPub Agreement”) between Bungie and Activision Publishing, Inc.
`
`(“Activision”), and (2) a 2012 lawsuit between Worlds and Activision
`
`(“Worlds/Activision lawsuit”), but neither support the contention of any unnamed
`
`real party in interest (“RPI”) or otherwise justify the requested discovery. Bungie,
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`the developer of the Destiny videogame, is responsible for defense of intellectual
`
`property claims against Destiny. Nothing in the DevPub Agreement allows any
`
`party other than Bungie to control these IPR proceedings. PO’s arguments in its
`
`motion regarding the DevPub Agreement are based on an erroneous and illogical
`
`reading of that agreement, and fail to support its discovery request.
`
`With regard to the Worlds/Activision lawsuit, that litigation addresses only
`
`third party products having nothing to do with Bungie – Destiny has never been a
`
`“product-at-issue” in that litigation. PO points only to a single letter sent to
`
`Activision’s litigation counsel suggesting Destiny be added, something
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`unsurprisingly never done, given the unrelated nature of Destiny and the late stage
`
`of that litigation. Mere bluster in an unrelated lawsuit against a Bungie business
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`partner cannot trigger a standing bar under § 315(b) as to Bungie.
`
`Neither the DevPub Agreement nor the unrelated Worlds/Activision
`
`litigation changes that Bungie is solely responsible for the cost and control of the
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`IPR2015-01319
`Patent 8,082,501
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`IPRs against PO’s patents. Beyond the erroneous reading of the DevPub
`
`Agreement, PO’s discovery requests are speculative, overly broad and unduly
`
`burdensome, and unlikely to yield any fruitful information. Accordingly, PO’s
`
`request for discovery should be denied.
`
`II. BACKGROUND
`
`PO is a notorious patent assertion entity, known in the videogame industry
`
`for aggressively threatening and asserting through litigation the patents at issue in
`
`the current IPRs. Starting in 2002, PO began working with General Patent
`
`Corporation, which “represents clients in IP enforcement matters and licensing
`
`transactions on a contingency basis.” Ex. 1033. In late 2008, following the
`
`issuance of U.S. Pat. No. 7,181,690, which is a parent to the patent at issue here,
`
`PO sued NCSoft, developer of several popular massively-multiplayer videogames.
`
`Id. Following filing of the suit, the CEO of PO proclaimed that PO intended to sue
`
`any company that made a successful massively-multiplayer videogame. Ex. 1034.
`
`In May 2011, PO spun-off its remaining operations to a wholly-owned subsidiary,
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`retaining its patent portfolio which it indicated it “intends to continue to increase
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`and to more aggressively enforce against alleged infringers.” Ex. 1035 at 8.
`
`On April 4, 2012, PO initiated a lawsuit against Activision alleging the
`
`World of Warcraft and Call of Duty videogame series infringed PO’s patents.
`
`Ex. 2003. Bungie has nothing to do with the World of Warcraft and Call of Duty
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`videogame series, both of which were developed by Activision’s subsidiaries or
`
`corporate affiliates. Ex. 1031 ¶¶ 6-15. PO’s motion cites to a single November 13,
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`2014 letter sent, over a year-and-a-half into litigation, to Activision’s litigation
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`counsel suggesting Destiny be added to the lawsuit. Ex. 2004. Neither Destiny nor
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`any other Bungie product has ever been added to that lawsuit. Indeed, PO recently
`
`filed amended infringement contentions that remain limited to the World of
`
`Warcraft and Call of Duty videogames. Ex. 1036.
`
`Bungie is a private, independent videogame developer in the business of
`
`designing and creating videogames. See, e.g., Ex. 2002 at 7-8. Bungie has
`
`developed numerous videogames since the company was established in 1991,
`
`including the highly successful Halo franchise in conjunction with Microsoft.
`
`Ex. 1032. Activision is a videogame publisher in the business of mass-producing,
`
`marketing, and distributing videogames. See, e.g., Ex. 2002 at 9-10. Activision acts
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`as a publisher both for numerous third party videogame developers as well as for
`
`its own in-house development studios. See, e.g., Ex. 1031 ¶¶ 6-15.
`
`On April 16, 2010, Bungie and Activision entered into the DevPub
`
`Agreement, which provided that the videogame Destiny would be developed by
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`Bungie and published by Activision. Ex. 2002.1 Under the DevPub Agreement,
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`Bungie remains the owner of the Destiny videogame and all other Destiny
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`intellectual property. Id. at 6.
`
`
`1 The Board’s Order states that “Counsel for Petitioner explained that he had
`
`not received a copy of the Bungie-Activision Agreement.” Paper 8 at 2. To be
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`clear, while aware of the agreement, counsel pointed out that PO scheduled a
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`conference call without any notification to Bungie or the Board as to any specific
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`discussion points.
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`The terms of the DevPub Agreement that PO has pointed to are garden-
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`variety contract terms. The DevPub Agreement sets out the parties’ responsibilities
`
`with regard to the development and publishing of Destiny videogames. Id. at 7-10.
`
`Among a list of several items that are to be the joint responsibility of the parties
`
`during development are legal clearance reviews. Id. at 10. The DevPub Agreement
`
`also contains a warranty that “to the best of [Bungie’s] knowledge with respect to
`
`patents” the Destiny videogames “shall not infringe upon or violate the rights of,
`
`nor require the consent of, any other party.” Id. at 19.2 Finally, Bungie agreed to
`
`indemnify against any claims arising out of “any infringement of a third party’s
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`rights in Intellectual Property caused” by a Destiny videogame. Id. at 21. The
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`DevPub Agreement specifies Bungie may “assume the defense” of any such claim.
`
`Id. Destiny was released on September 9, 2014. Ex. 1032.
`
`III. ANALYSIS
`
`A.
`
`PO’s Argument Regarding Routine Discovery is Misplaced
`
`PO’s argument regarding “routine discovery” is not really a request for
`
`discovery, but simply a speculative assertion that an unnamed RPI exists followed
`
`by the conclusion that “Bungie already should have produced this information as
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`‘routine discovery[.]’” Paper 9 at 5-6. However, “[r]outine discovery under 37
`
`C.F.R. § 41.51(b)(1)(iii) is narrowly directed to specific information known to the
`
`
`2 PO’s contention that the warranty requires a “reasonable investigation” is
`
`incorrect. See Paper 9 at 3. A “reasonable investigation” is only required with
`
`respect to trademarks. Ex. 2002 at 19.
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`responding party to be inconsistent with a position advanced by that party in the
`
`proceeding, and not broadly directed to any subject area in general within which
`
`the requesting party hopes to discover such inconsistent information.” Garmin Int'l
`
`Inc. v. Cuozzo Speed Techs. LLC, IPR2012-00001, Paper 26 at 3-4 (PTAB Mar. 5,
`
`2013) (informative) (emphases added). Routine discovery is self-executing.
`
`Blackberry, IPR2013-00126, Paper 15 at 2 (PTAB Aug. 19, 2013).
`
`Bungie’s IPR petitions correctly list Bungie as the sole RPI. The publicly
`
`available DevPub Agreement does not contradict that listing. As such, Bungie
`
`believes that it has already complied with its routine discovery obligations.
`
`B.
`
`PO’s Requested Discovery is Not in the Interest of Justice
`
`PO alternatively contends that its requests are appropriate as “additional
`
`discovery.” Paper 9 at 6-10. A party seeking additional discovery has the burden of
`
`demonstrating that the additional discovery is necessary “in the interest of justice.”
`
`37 C.F.R. § 42.51(b)(2); Garmin, IPR2012-00001, Paper 26 at 6. The Board in
`
`Garmin made clear requests must be narrowly tailored and that “[t]he mere
`
`possibility of finding something useful, and mere allegation that something useful
`
`will be found, are insufficient to demonstrate that the requested discovery is
`
`necessary in the interest of justice.” Id. at 6-7.
`
`PO argues that the requested discovery is necessary to show that Activision
`
`is an unnamed RPI in these IPRs. Paper 9 at 5-6. RPI, however, describes “the
`
`relationship between a party and a proceeding[.]” Aruze Gaming Macau, Ltd. v.
`
`MGT Gaming, Inc., IPR2014-01288, Paper 13 at 11 (PTAB Feb. 20, 2015). Central
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`to any RPI determination is that a party other than the named petitioner was
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`controlling the proceeding before the Board.” Id. Accordingly, for the requested
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`discovery to be necessary in the interest of justice, PO would have to show, beyond
`
`mere speculation, that the requested discovery would be substantively useful in
`
`establishing that Activision controlled or had the ability to control the instant
`
`proceedings. For the reasons discussed below, PO’s requested additional discovery
`
`is not in the interest of justice.
`
`i. PO’s Motion is Based on a False Premise
`
`PO’s motion fails because it is premised on a faulty assumption, namely that
`
`this IPR is a “legal review” under Section 7A.15(j) of the DevPub Agreement. In
`
`order to obtain additional discovery, “[t]he party requesting discovery should
`
`already be in possession of evidence tending to show beyond speculation that in
`
`fact something useful will be uncovered.” Id. at 6. PO incorrectly argues that the
`
`DevPub Agreement is such evidence, and that Section 7A.15(j) of the DevPub
`
`Agreement gave Activision “a contractual opportunity to control and fund the IPR
`
`petitions against Worlds.” Paper No. 9 at 4 (emphasis omitted); see also id. at 10
`
`(“By the very existence of the Agreement and the documents that must exist
`
`according to the Agreement terms . . .”). Because these IPRs are not legal
`
`clearance reviews as provided for in the DevPub Agreement, PO’s motion is
`
`supported by nothing more than speculation and should be denied.
`
`Section 7A.15(j) of the DevPub Agreement provides that Bungie and
`
`Activision will have joint responsibility for standard legal clearance reviews
`
`conducted in the course of the development of Destiny: “Conducting legal reviews
`
`of the Products to ensure that all Intellectual Property and other rights are fully
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`cleared for use.” Ex. 2002 at 10 (emphasis added). This term covers a variety of
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`reviews that might be desired during development, because a videogame can
`
`require legal clearance similar to a television show or film. That might mean, for
`
`example, reviewing the title, script, and visual and audio assets to ensure that any
`
`appropriate rights have been obtained and that they do not infringe any trademarks
`
`or copyrights. See, e.g., id. at 5 (defining intellectual property). PO fails to
`
`demonstrate that these IPRs could fall within the scope of the legal clearance
`
`reviews term. A reasonable reading of the provision requires that they are not, at
`
`least because the subject of these IPRs is PO’s patents, not any Destiny product.
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`These IPRs are not within the scope of the DevPub Agreement.
`
`Indeed, it is apparent from the DevPub Agreement that even legal activity
`
`involving a review of a Destiny product is not necessarily within the scope of the
`
`legal clearance reviews term. To be clear, Bungie could not have any
`
`indemnification obligation under the DevPub Agreement with respect to PO’s
`
`patents, because no complaint has been filed asserting infringement by Destiny.
`
`Nonetheless, under the DevPub Agreement, Bungie is solely responsible for costs
`
`relating to any defense of any third party claim of patent infringement against
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`Destiny, and has the right to assume control of any such defense, which would
`
`encompass both invalidity and noninfringement defenses. Id. at 21. Interpreting
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`Section 7A.15(j) to give Activision the ability to control such defenses, as PO
`
`proposes, is inconsistent with the plain language of the indemnity provision.
`
`Because PO’s motion depends on an illogical and incorrect reading of the
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`DevPub Agreement, PO has failed to provide any evidence tending to show
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`IPR2015-01319
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`beyond speculation that in fact something useful would be uncovered by its
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`requests, and PO’s motion for additional discovery should be denied in toto.
`
`ii. Requested Financial Discovery is Overly Broad, Unduly
`Burdensome, and Would Not be Useful
`
`Beyond PO’s flawed reading of the DevPub Agreement (Paper 9 at 7-8),
`
`PO’s requests for financial documents are overbroad, unduly burdensome, and
`
`would not lead to discovery that is substantively useful. PO has broadly requested
`
`(1) documents identifying the bank accounts from which Bungie made any
`
`payment associated with a “legal review” of PO’s patents, (2) documents
`
`identifying the bank accounts in which Bungie held or deposited development
`
`advances from Activision, (3) documents showing that funds originally received
`
`from Activision were used to pay for, or commingled with funds used to pay for,
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`any “legal review” of PO’s patents. Id. at 1-2. PO’s theory is a fishing expedition.
`
`First, these requests are incredibly overbroad and intrusive. They would
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`require Bungie to search for and produce any financial document, including bank
`
`records, relating to aspects of Bungie’s business having nothing to do with these
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`IPRs. They are hardly “sensible and responsibly tailored according to a genuine
`
`need.” Second, these requests would not lead to discovery that is substantively
`
`useful. PO has not presented any authority for its “commingling” theory of
`
`funding, as it cannot. Activision’s payment of development advances to Bungie
`
`funded the development of the Destiny videogame, not these IPRs. Finally, the
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`Board decision cited by PO does not support such broad discovery. See Hughes
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`Net. Sys., LLC v. Cal.Inst. of Tech., IPR2015-00059, Paper 21 at 4-5 (PTAB May
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`-8-
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`11, 2015) (with respect to financial information, ordering only discovery of “legal
`
`bills demonstrating DISH involvement in the IPR proceedings”). To be clear,
`
`unlike in the present case, in Hughes the patent owner had presented threshold
`
`evidence that showed useful evidence was likely to be found, because the parties at
`
`issue were closely related entities who proclaimed in a related district court case
`
`they would be pursuing IPR’s together. Id. at 1-5.
`
`iii. Request for Communications Concerning Legal Reviews is
`Not Narrowly Tailored
`
`In addition to the incorrect premise that these IPRs are legal clearance
`
`reviews under the DevPub Agreement (Paper 9 at 8-9), PO’s request is not
`
`“sensible and responsibly tailored according to a genuine need.” PO requests any
`
`“[c]ommunications between Bungie and Activision concerning legal review of any
`
`Worlds Patent(s)[.]” Id. at 2. This request is not narrowly tailored to issues relating
`
`to these proceedings, let alone issues relevant to control or funding of these
`
`proceedings. Its scope is even broader than it might seem given PO’s broad
`
`definitions, particularly for “Communications,” “Bungie,” and “Activision.” Ex.
`
`2005 at 2-3. Again, the cases cited by PO do not support such broad discovery.
`
`Hughes, IPR2015-00059, Paper 21 at 5 (with respect to communications, ordering
`
`only discovery of “communications from DISH (not from other entities) related to
`
`drafts and approvals of IPR petitions”); Coalition for Affordable Drugs II LLC v.
`
`NPS Pharms., Inc., IPR2015-00990, Paper 14 at 7 (PTAB July 2, 2015)
`
`(authorizing discovery as to “agreements . . . relating to the control or ability to
`
`control any aspect of the current proceeding by a party not designated” a RPI).
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`IPR2015-01319
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`iv. Request for Communications Concerning Indemnification
`is Overbroad and Lacks Relevance
`
`Again, PO’s request is premised on an erroneous assumption that PO
`
`somehow “triggered” an “obligation to conduct legal reviews” by Bungie. Paper 9
`
`at 9. And again, PO’s request is overbroad, seeking “[c]ommunications between
`
`Bungie and Activision related to Bungie’s indemnification of or obligation to
`
`indemnify Activision based on any of the Worlds Patents(s)[,]” (Paper 9 at 2)
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`which as presented could theoretically cover any communication regarding the
`
`DevPub Agreement over the past six years. See also Ex. 2005 at 2-3 (definitions).
`
`More importantly, PO has failed to explain how any indemnification obligation
`
`with respect to litigation could possibly be relevant to a RPI analysis. The case
`
`cited by PO authorized discovery relevant to determining privity. Arris Grp., Inc.
`
`v. C-Cation Techs., LLC, IPR2014-00746, Paper 15 at 3-4 (PTAB July 24, 2014).
`
`“In contrast to the RPI inquiry, which focuses on a party’s relationship to a
`
`proceeding, the privity inquiry focuses on the relationship between parties.” Aruze
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`Gaming, IPR2014-01288, Paper 13 at 13. PO has not contended that Bungie is
`
`barred as a privy of Activision, because as discussed in detail above, Destiny is not
`
`a subject of the Worlds/Activision lawsuit.
`
`IV. CONCLUSION
`
`PO’s Motion for Routine or Additional Discovery should be denied.
`
`
`
`
`
`Dated: August 13, 2015
`
`
`
`
`
`Respectfully submitted,
`
`/ Michael T. Rosato /
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
`
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`Description
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`IPR2015-01319
`Patent 8,082,501
`V. APPENDIX – LIST OF EXHIBITS
`Exhibit
`No.
`1001 U.S. Patent No. 8,082,501 to Leahy et al.
`1002 Declaration of Michael Zyda, D.Sc.
`1003 Michael Zyda, curriculum vitae
`1004 File History of 11/591,878 to Leahy et al.
`1005 Thomas A. Funkhouser, RING: A Client-Server System for Multi-User
`Virtual Environments, Symposium on Interactive 3D Graphics, 1995,
`at 85-92 and 209.
`
`1006 1995 Symposium on Interactive 3D Graphics, The Association for
`Computing Machinery, Inc. (1995).
`
`1007 Date Stamped Copy of the Excerpt of the Proceedings of the 1995
`Symposium on Interactive 3D Graphics, The Association for
`Computing Machinery, Inc. (1995).
`
`1008 U.S. Patent No. 5,659,691 to Durward
`1009 Worlds’ Opening Claim Construction Brief, Worlds, Inc. v. Activision
`Blizzard, Inc. et al., No. 1:12-cv-10576-DJC (D. Mass Apr. 22,
`2013).
`
`1010 Excerpt, Microsoft Press Computer Dictionary (3rd Ed. 1997).
`Ivan Sutherland Photo Essay – A.M. Turing Award Winner,
`http://amturing.acm.org/photo/sutherland_3467412.cfm#photo_2 (last
`visited May 25, 2015).
`
`1011
`
`1012 DigiBarn Games: Maze War Retrospective,
`http://www.digibarn.com/collections/games/xerox-maze-war/ (last
`visited May 22, 2015).
`
`1013 U.S. Patent No. 4,521,014 to Sitrick
`1014 Douglas B. Smith, et al., An Inexpensive Real-Time Interactive Three-
`Dimensional Flight Simulation System (1987).
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`No.
`1015 Michael Zyda et al., NPSNET: A 3D Visual Simulator for Virtual World
`Exploration and Experience (1991).
`
`Description
`
`1016 James O. Calvin, et al., STOW Realtime Information Transfer and
`Networking System Architecture (1995).
`
`1017 Thomas A. Funkhouser, Adaptive Display Algorithm for Interactive
`Frame Rates During Visualization of Complex Virtual Environments
`(1993).
`
`1018 Symposium, Computer Graphics Proceedings, The Association for
`Computing Machinery, Inc. (1993).
`
`1019 U.S. Patent No. 5,777,621 to Schneider
`1020 U.S. Patent No. 5,021,976 to Wexelblat et al.
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`1021
`1022
`1023
`1024
`1025
`1026
`1027
`1028
`1029
`Intentionally left blank
`1030
`1031 Worlds’ First Amended Complaint for Patent Infringement, Worlds, Inc.
`v. Activision Blizzard, Inc., et al., No. 1:12-cv-10576-DJC (D. Mass
`September 21, 2012).
`1032 Activision Sells in More Than $500 Million of Destiny Worldwide as of
`Day One, Business Wire,
`http://www.businesswire.com/news/home/20140910005318/en/Activi
`sion-Sells-500-Million-Destiny-Worldwide-Day#.VczipWfJDTs (last
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`Description
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`visited August 12, 2015).
`1033 Worlds.com Sues NCSoft for Infringing Key Virtual Worlds Patent,
`Business Wire,
`http://www.businesswire.com/news/home/20081231005197/en/World
`s.com-Sues-NCSoft-Infringing-Key-Virtual-Worlds#.VczjsWfjDTs
`(last visited August 12, 2015).
`1034 Eric Krangel, Worlds.com CEO: We’re ‘Absolutely’ Going To Sue
`Second Life And World Of Warcraft,
`http://www.businessinsider.com/worldscom-ceo-were-absolutely-
`going-to-sue-second-life-and-world-of-warcraft-2009-3 (last visited
`August 10, 2015).
`1035 Worlds Inc. Quarterly Report Pursuant to Section 13 or 15(d) of the
`Securities Exchange Act of 1934 for the Quarterly Period ended
`March 31, 2015 (2015).
`1036 Worlds Inc.’s Sixth Supplemental Disclosure of the Claims Infringed,
`Worlds, Inc. v. Activision Blizzard, Inc., et al., No. 1:12-cv-10576-
`DJC (D. Mass July 27, 2015).
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`CERTIFICATE OF SERVICE
`
`I certify that on August 13, 2015 the foregoing PETITIONER’S
`
`OPPOSITION TO PATENT OWNER’S MOTION FOR ROUTINE OR
`
`ADDITIONAL DISCOVERY and EXHIBITS 1031 through 1036 were served on
`
`the Patent Owner via email at the correspondence addresses of record as follows:
`
`Wayne M. Helge
`whelge@dbjg.com
`
`Donald L. Jackson
`djackson@dbjg.com
`
`Michael R. Casey
`mcasey@dbjg.com
`
`
`
`
`
`Dated: August 13, 2015
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`
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`Respectfully submitted,
`
`/ Michael T. Rosato /
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
`
`
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