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No. 17 JOINDER by Activision Blizzard Inc., joining in 11 Motion to Dismiss

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 17 (D.Del. Jun. 1, 2015)
Plaintiff has filed three substantially identical complaints against different defendants in this Court.
On May 4, 2015, Defendant Activision Blizzard, Inc. (“Activision”) moved to dismiss plaintiff’s induced infringement claims in this action.
Thereafter, on May 13, 2015, the Federal Circuit issued its opinion in Akamai Technologies, Inc. v. Limelight Networks, Inc., No. 2009- 1372, 2015 WL 2216261 (Fed. Cir. May 13, 2015), concerning the requirements for a claim of joint infringement.
Activision hereby joins in and incorporates by reference Electronic Arts’s motion to dismiss Plaintiff’s claims of joint infringement and its Opening Brief in support thereof.
Specifically, Activision seeks dismissal of Counts III, VI and VIII of Plaintiff’s Amended Complaint, asserting that Activision infringes the method claims of U.S. Patent Nos. 6,732,147, 6,910,069 and 6,920,497 based on a theory of joint infringement.
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No. 15 ANSWERING BRIEF in Opposition re 11 MOTION to Dismiss filed by Acceleration Bay LLC.Reply ...

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 15 (D.Del. May. 21, 2015)
Motion to Dismiss (Demurrer)
Activision’s motion should be denied because Acceleration Bay plausibly pleads that Activision’s customers, users and developers are each singledirect infringers who have been induced by Activision to perform “all the steps of the method claims.” D.I.
In opposing Activision’s motion to dismiss, Acceleration Bay is entitled to have all factual allegations in the Complaint deemed as true and viewed in the most favorable light.
2012) (“The court is not prepared to engage in a claim construction exercise at this stage of the proceedings, with no context whatsoever provided by discovery or a motion practice.”);Internet Media Corp. v. Hearst Newspapers, LLC, Civ.
In finding that post-filing knowledge of patents is sufficient for inducement claims as of the date of the complaint, this Courtopined that “the fundamental purpose of asserting indirect infringement” is “to ensure that the patentee can recover full compensation for any damages suffered as a result of infringement.” Id.
This Court further stated that “[t]he fact that Walker Digital would be prohibited from collecting damages related to indirect infringement for any pre-knowledge (e.g., pre-filing) conduct is the only substantive consequence of allowing allegations such as those at bar to go forward.” Id.
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No. 13 Disclosure Statement pursuant to Rule 7.1: identifying Other Affiliate ASAC II LP for Activision ...

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 13 (D.Del. May. 4, 2015)
Pursuant to Federal Rule of Civil Procedure 7.1, Defendant Activision|Blizzard, Inc. states that it is a publicly traded corporation and that ASAC II LP is the beneficial owner of more than 10% of its common stock.
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No. 12

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 12 (D.Del. May. 4, 2015)

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7 Power of Attorney: Power of Attorney

Document IPR2016-00726, No. 7 Power of Attorney - Power of Attorney (P.T.A.B. Apr. 1, 2016)

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8 Notice: Related Matters

Document IPR2016-00726, No. 8 Notice - Related Matters (P.T.A.B. Apr. 1, 2016)

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No. 6

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 6 (D.Del. Mar. 23, 2015)

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5 Notice: Petitioners Updated Exhibit List as of 3 15 2016

Document IPR2016-00726, No. 5 Notice - Petitioners Updated Exhibit List as of 3 15 2016 (P.T.A.B. Mar. 15, 2016)

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3 Notice: Petitioners Updated Mandatory Notices 03 15 2016

Document IPR2016-00726, No. 3 Notice - Petitioners Updated Mandatory Notices 03 15 2016 (P.T.A.B. Mar. 15, 2016)

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4 Notice: Petitioners Revised Certificate of Service

Document IPR2016-00726, No. 4 Notice - Petitioners Revised Certificate of Service (P.T.A.B. Mar. 15, 2016)

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No. 5

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 5 (D.Del. Mar. 12, 2015)

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No. 2

Document Acceleration Bay LLC v. Activision Blizzard Inc., 1:15-cv-00228, No. 2 (D.Del. Mar. 11, 2015)

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1 Power of Attorney: Power of Attorney

Document IPR2016-00726, No. 1 Power of Attorney - Power of Attorney (P.T.A.B. Mar. 12, 2016)

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1046 Exhibit: Exhibit 1046 Letterr from Rovner to Andrews

Document IPR2017-01600, No. 1046-68 Exhibit - Exhibit 1046 Letterr from Rovner to Andrews (P.T.A.B. Nov. 27, 2017)

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1045 Exhibit: Exhibit 1045 Memorandum re Standing

Document IPR2017-01600, No. 1045-67 Exhibit - Exhibit 1045 Memorandum re Standing (P.T.A.B. Nov. 27, 2017)

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