`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`MICROSOFT CORP.
`Petitioner,
`
`v.
`
`WORLDS INC.
`Patent Owner
`IPR2021-00277 (Patent No. 8,082,501)
`
`
`
`Declaration of Michael Allen
`
`
`
`
`
`
`
`
`
`
`
`
`1
`
`MS 1026
`
`
`
`Inter Parres Review of US. Patent No. 8,082,501
`
`Declaration of Michael Allen
`
`1, Michael Allen, declare:
`
`1.
`
`I am an Assistant General Counsel at Microsoft Corporation
`
`(“Microsoft”).
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review (“IPR”) proceeding. Unless otherwise stated, the facts stated
`
`in this Declaration are based on my personal knowledge or based on corporate
`
`knowledge.
`
`2.
`
`Among other things, I am responsible for overseeing indemnification
`
`claims made against Microsoft based on alleged patent infringement and my team
`
`maintains records concerning indemnity requests to Microsoft.
`
`3.
`
`In preparation of this declaration, I was made aware that Worlds Inc.
`
`filed a Complaint on March 30, 2012 against Activision Blizzard, Inc., Blizzard
`
`Entertainment, Inc., and Activision Publishing, Inc. (collectively “Activision”).
`
`See Worlds Inc. v. Activision Blizzard, Inc., Blizzard Entertainment, Inc., and
`
`Activisz'on Publishing, Inc., 1-12-cv—10576 (D. Ma. 2012).
`
`I am unaware ofany
`
`claims for indemnification by Activision against Microsoft related to this litigation,
`
`and a search of our records on indemnity requests returns no claims for
`
`indemnification by Activision against Microsoft related to this litigation.
`
`4.
`
`In preparation of this declaration, I was also made aware that, in 2015,
`
`Bungie, Inc. (“Bungie”) prepared and filed a petition for inter partes review
`
`(“IPR”) against US. Patent No. 8,082,501 (“the ’501 patent”).
`
`I am unaware of
`
`Ix.)
`
`
`
`Inter Par/es Review ofU.S. Patent No. 8.082.501
`
`Declaration of Michael Allen
`
`any claims for indemnification by Bungie against Microsoft related to either the
`
`above-noted Activision litigation or Bungie’s IPR petition, and a search of our
`
`records on indemnity requests returns no claims for indemnification by Bungie
`
`against Microsoft related to either the above-noted Activision litigation or
`
`Bungie’s IPR petition.
`
`5.
`
`I am also unaware of any control or funding by Microsoft of the
`
`above—noted Activision litigation or Bungie’s IPR petition, and a search performed
`
`at my direction of Microsoft litigation activity revealed no record of Microsoft
`
`controlling or funding the defense of the above-noted Activision litigation or
`
`Bungie’s IPR petition.
`
`6.
`
`In preparation of this declaration, I was also made aware that Worlds
`
`Inc. filed a Complaint on September 25, 2020 against Microsoft Corporation. See
`
`Worlds Inc. v. Microsoft Corporation, 6:20-cv-872 (W.D. Tex. 2020). After a
`
`reasonable investigation into Microsoft’s litigation activity related to that case, I
`
`have not identified any evidence that Microsoft sought indemnification from either
`
`Bungie or Activision related to the Worlds litigation against Microsoft, or that
`
`either Bungie or Activision controlled or funded the Worlds litigation against
`
`Microsoft. Additionally, my investigation did not identify any evidence that either
`
`Bungie or Activision controlled or funded the IPR petition that is being filed by
`
`Microsoft against Worlds.
`
`
`
`Inter Partes Review of US. Patent No. 8,082,501
`
`Declaration of Michael Allen
`
`7.
`
`I declare that all statements made herein of my own knowledge are
`
`true, and that all statements made on information and belief are believed to be true,
`
`and that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`Dated: November 20, 2020 W W
`
`
`
`Michael Allen
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
