Cho, et al., “A Flood Routing Method for Data Networks,” Sep. 1997, Proceedings of 1997 International Conference on Information, Communications and Signal Processing, vol.

Komine et al., “A Distributed Restoration Algorithm for Multiple—Link and Node Failures of Transport Networks,” Dec. 1999, IEEE Globecom ’90, Communicaitons: Com mecting the Future, vol.

AZar, et al., “Routing Strategies for Fast Networks,” May 1992 INFOCOM ’92, Eleventh Annual Joint Conference of the IEEE Computer and Communications Societies, vol.

Examples of client/server middleware systems include remote procedure calls (“RPC”), database servers, and the common object request broker architecture (“CORBA”).

In one embodiment, the distance that the edge connection request message travels is established by the portal computer to be approximately twice the estimated diameter of the broadcast channel.

Plaintiff Acceleration Bay LLC (“Plaintiff”), by its undersigned counsel, hereby submits the following disclosures to Defendant Activision Blizzard, Inc. (“Defendant”), pursuant to Section 1(b) of the Court’s Rule 16 Scheduling Order dated October 29, 2015 (the “Scheduling Order”).

These disclosures are based on information now reasonably available to Plaintiff and represent a good faith effort to identify information that Plaintiff reasonably believes to be required in these disclosures.

Plaintiff is continuing to investigate facts, issues, and law relevant to this action and expressly reserves the right to modify, amend, supplement and/or correct the information provided in these disclosures as information becomes available.

Plaintiff will supplement this section to add other games as accused products as the relevant information become available.

Separately and pursuant to Section 1(b) of the Scheduling Order, Plaintiff will produce the file history for each asserted patent.

AZar et al., “Routing Strategies for Fast Networks,” May 1992, INFOCOM ’92, Eleventh Annual Joint Conference of the IEEE Computer and Communications Societies, vol.

* Cho et al., “A Flood Routing Method for Data Networks,” Sep. 1997, Proceedings of 1997 International Conference on Information, Communications, and Signal Processing, vol.

* Komine et al., “A Distributed Restoration Algorithm for Multiple—Link and Node Failures of Transport Networks,” Dec. 199 Global Telecommunications Conference, 1990, and Exhibition, IEEE, vol.

Examples of client/server middleware systems include remote procedure calls (“RPC”), database servers, and the common object request broker architecture (“CORBA”).

In one embodiment, the distance that the edge connection request message travels is established by the portal computer to be approximately twice the estimated diameter of the broadcast channel.

Emphasis is added below to call out at least some of the required actors identified in each independent method claim that Defendant is accused of indirectly infringing.

A method for healing a disconnection of a first computer from a second computer, the computers being connected to a broadcast channel, said broadcast channel being an m-regular graph where m is at least 3, the method comprising: attempting to send a message from the first computer to the second computer; and when the attempt to send the message is unsuccessful, broadcasting from the first computer a connection port search message indicating that the first computer needs a connection; and having a third computer not already connected to said first computer respond to said connection port search message in a manner as to maintain an m-regular graph.

A computer-based, non-routing table based, non-switch based method for adding a participant to a network of participants, each participant being connected to three or more other participants, the method comprising: identifying a pair of participants of the network that are connected wherein a seeking participant contacts a fully connected portal computer, which in turn sends an edge to a number of randomly selected connection request neighboring participants to which the seeking participant is to connect; disconnecting the participants of the identified pair from each other; and the connecting each participant of participants to the seeking participant.

A computer-based, non-switch based method for adding nodes to a graph that is m-regular and m-connected to maintain the graph as m-regular, where m is four or greater, the method comprising: identifying p pairs of nodes of the graph that are connected, where p is one half of m, wherein a seeking node contacts a fully connected portal node, which in turn sends an edge connection request to a number of randomly selected neighboring nodes to which the seeking node is to connect; disconnecting the nodes of each identified pair from each other; and connecting each node of the identified pairs of nodes to the seeking node.

A method in a computer for locating a computer through which to connect to a network, the method comprising: providing an identification of a portal computer or a plurality of portal computers, the portal computer or the plurality of portal computers having a communications port or communications ports with a call-in port being enabled for communications when the portal computer or the plurality of portal computers is in a state to coordinate the connection of a seeking computer to the network, wherein the call-in port is a type of communications port; selecting the communications port or communications ports of the portal computer or the plurality of portal computers and attempting to communicate with the selected communications port or communications ports until communications with the call-in port is successful, wherein a port ordering algorithm is used to identify the call-in port, and wherein the communications ports selected by the port ordering algorithm may be re-ordered; and using the call-in port to request that the portal computer or the plurality of portal computers coordinate the connecting of the seeking computer to the network.

And, in fact, you know, Judge Thynge acknowledged that defendants had raised a, quote, "legitimate concern that their confidential information could be competitively misused in strategically narrowing plaintiffs' patent claims during reexamination.

You know, it's a -- and the Xerox Court sort of moved past that concern by noting that, Well, plaintiffs would undoubtedly seek the broadest coverage possible in reexamination, regardless of their counsel's knowledge of defendants products.

THE COURT: But as a theoretical matter, the post -- the reissue proceeding is slightly riskier for the inadvertent disclosure effecting, you know, being tied in with strategic choices that counsel is making, just because you could expand the scope.

I do think quoting In Re: Deutsche Bank Trust, that strategically amending or surrendering claim scope during prosecution, which is what the case says, is, essentially, competitive decision-making, and there is the risk of an inadvertent disclosure.

So the idea that outside counsel would be driving the filing of a citizen's petitions, I think what they're really -- what they are really talking about, and what they're really concerned about are instances in which there are intentional disclosures of confidential information, and that is already covered by the Protective Order.

DEFENDANTS’ PROPOSED PROVISION: Extremely sensitive “Confidential Material” representing computer code and associated comments and revision histories, formulas, engineering specifications, or schematics that define or otherwise describe in detail the algorithms or structure of software or hardware designs, disclosure of which to another Party or Non-Party would create a substantial risk of serious harm that could not be avoided by less restrictive means.

Every individual who has signed the “Acknowledgement and Agreement To Be Bound By Confidentiality Order” attached as Exhibit A, or who received any Designated Material, agrees to subject himself or herself to the jurisdiction of this Court for the purpose of any proceedings related to performance under, compliance with, or violation of this Order.

In addition, the proposed bar has been raised fairly late in the litigation, and, given the representations about the size of the Plaintiffs law firm, and the exposure of its attorneys to confidential information to date, as well as their experience with the patent and the prior art, the balance of harm does not favor the Defendants.

2.15 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

In addition, any such motion must be accompanied by a competent declaration describing the parties’ efforts to resolve the matter by agreement (i.e., the extent and the content of the meet and confer discussions) and setting forth the reasons advanced by the Designating Party for its refusal to approve the disclosure.

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