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They can, have and will
WATCH VPOR POP NEXT WEEK AFTER 2014 NUMBERS - JUST SAYIN - DO YOUR OWN DD
WHY R U HERE?
Number crunching>
assuming 4b shares issued
Price per share $0.002 = Market Cap of $8,000,000
Revenues expected Q4 2014: $1M
Revenues expected 2015: $10-15M
Profit expected 2015: $2M
At price per share of $0.01 market cap would be $40M with 4b shares issued and with a profit of $2M the P/E would be 20
I believe we will have way less than 4b shares issued even after all debt is paid or converted. More realistic IMO is 3b shares issued.
They derive revenues from two different markets: e cigarettes and internet advertising software with the bulk of revenue at the moment from the latter I believe.
I expect Q1 2015 to show revenues of $3-5M and at that point would expect the stock to go to 2 cents/share
Just my 2 cents (pun intended) - do your own DD!
reh
If these guys would issue all authorized shares and the stock went to a penny the market cap would be only $45M. If we expect them to have revenues north of $10M this year that price is not unreasonable. I would like to see how the revenue is between VGR Media and Vapor products. On VGR it looks to me to be very high profit so most revenues would be pure margin. If they got $10M revenue from VGR alone and all shares were issued a penny stock price would represent a P/E of less than 10 which is very reasonable.
My conclusion is that based upon my DD this stock could easily go beyond a penny but just a penny from here is 6-7 return on investment. I guess the Q1 filing expected mid-May will tell the tale.
REH
ps - Do your own DD
another lawsuit against activision:
Acceleration Bay Claims 'Call of Duty' and 'World of Warcraft' Violate Six Patents
March 13, 2015 - GamePolitics Staff
Acceleration Bay LLC has sued Activision Blizzard Inc. claiming that two of the company's biggest franchises violate six of the patents it holds (Civil Action No. 1:15-cv-00228-UNA). We do not have access to the filings or exhibits as of this writing. Acceleration Bay appears to a patent holding company and does not produce any products or services with these patents, according to what we found on its web site. Activision Blizzard has not issued a public statement about the case.
The games mentioned in the patent infringement case that allegedly violate Acceleration Bay's patents include World of Warcraft and the Call of Duty series.
The case was filed in the Delaware District Court in Wilmington, Delaware. A judge has not been assigned to the case.
We will have more on this story as it develops.
http://www.gamepolitics.com/2015/03/13/acceleration-bay-claims-call-duty-and-world-warcraft-violate-six-patents#.VQcbJyvF8RA
while we wait, here's news of a legal nature conserning Activision:
http://abcnews.go.com/US/wireStory/judge-eyes-275m-settlement-activision-shareholder-suit-29395830
buying opportunity imo but lets not have Hudson make too much so I am fine with the price dropping while they dump
Hudson still doing everything they can to hurt the company so if there is any agreement with them as far as price then maybe Worlds can do something. I doubt it so we will see dumping by Hudson until they are out.
JMHO
REH
All i see are "certain volume restrictions". It does NOT say anything about price restrictions. One should assume Hudson will sell all they can until empty. They are not in it for the long run, they dump and move on to the next gullible victim who will take their toxic deal out of desperation - that's their MO.
reh
link to that agreement please. all i see is this with no details:
http://www.otcmarkets.com/edgar/GetFilingHtml?FilingID=10425011
reh
HAVE NOT SEEN THAT IN WRITING BUT MIGHT HAVE MISSED IT. I WOULD NOT TRUST THEM TO EVEN IF THEY SIGNED ONTO IT
HUDSON WON'T STOP UNTIL THEY ARE EMPTY
i forget, did we see that in writing?
also, don't trust those guys anyway
Hudson keeps on dumping. Why companies deal with these gangsters is beyond me.
That's the MO of these types of firms, they just want to cash in and find the next victim. They ruin companies and shareholders but don't care one bit - no wonder they get in trouble with the SEC but they seem to still get away with it. Let them sell - the damage was doing a deal with them in the first place, easy search will tell anyone they are crooks.
Simply that the Judge agrees that Worlds can add new games from Activision to the suit. Will have no impact on the Markman but on the trial as there are more products who will be claimed infringe Worlds patents.
02/25/2015 151 Judge Denise J. Casper: ELECTRONIC ORDER entered granting 150 Motion for Leave to File Exhibits B-13 through J-13 of World's Fifth Supplemental Disclosure of the Claim Infringed filed 2/9/15; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Hourihan, Lisa) (Entered: 02/25/2015)
Got them
i'll grab 1M shares at 0.003 now
where do you get your "facts"? "Zero revenue"? Go do some due diligence before you speak and then make an informed decision.
nuff said
REH
NOTE DISCLOSURE
FACE VALUE ACCRUED INTEREST
Investment Firm: $150,000 Note issued on May 22, 2014, a corporation loaned the Company $150,000 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
150,000
4,307
Investment Firm: $6,000 Note issued on November 22, 2011. A corporation loaned the Company $6,000 in exchange for a Promissory Note bearing interest at 10%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
6,000
1,715
Investment Firm: $50,000 Note issued on March 12, 2014. This corporation loaned the Company $50,000 in exchange for a Promissory Note bearing interest at 10%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
50,000
2,767
Investment Firm: $150,000 including $4,882.19 Renewal Fee, Note issued on March 18, 2014. This corporation loaned the Company $150,000 in exchange for a Promissory Note bearing interest at 18%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
154,882
15,714
Investment Firm: $11,027.10 Note issued on February 7, 2014. This corporation loaned the Company $11,027.10 in exchange for a Promissory Note bearing interest at 18%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
11,027
4,980
Investment Firm: $40,000 Note issued on April 30, 2014. This corporation loaned the Company $40,000 in exchange for a Promissory Note bearing interest at 18%. The Lender and is allowed to convert the promissory note into Company common shares, based on which, Lender converted on January 28, 2014 $9,000 of the note . The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
31,000
9,020
13
Investment Firm: On April 29, 2014 Notes issued: $21,739.13, $364,130.43, $434,782.61 and $521,739.00. This corporation loaned the Company $1,342,391.17 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
1,342,391
45,310
Investment Firm: $20,000.00 Note issued on August 15, 2011. A corporation loaned the Company $20,000 in exchange for a Promissory Note bearing interest at 5%. The Lender is allowed to convert the promissory note into Company common shares, based on which the Note's buyer, Subsequently the note transferred to a non-affiliated second investment firm, which has converted $7,720.58. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014
12,279
1,921
Investment Firm: $150,000.00 funded $75,000 on July 1, 2014 and $75,000 on September 3, 2014. Note issued on May 28, 2014. This corporation agreed to loan the Company $521,739.00 over time in exchange for a Promissory Note bearing no interest for the first three months. The Lender is allowed to convert the promissory note into Company common shares. No accrued interest payable due to the grace period already mentioned. Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014
150,000
2,910
Private Investor: $40,000.00 Note issued on June 1, 2012. This individual loaned the Company $40,000 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares, The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
40,000
7,461
Investment Firm: $60,000 Note issued on May 28, 2014. This corporation loaned the Company $60,000 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
60,000
1,644
Investment Firm: $150,000 Note issued on May 22, 2014. This corporation loaned the Company $150,000 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
150,000
4,307
14
Private Investor: $50,000.00 Note issued on December 5, 2011. This individual loaned the Company $50,000 in exchange for a Promissory Note bearing interest at 8%. In May, 2012, $28,000 was paid on the Note. The Lender is allowed to convert the promissory note into Company common shares, The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
22,000
8,947
Investment Firm: $5,000 Note issued on January 18, 2013, $5,000 Note issued on February 4, 2013, $1,500 Note issued on August 14, 2013; $15,000 Note issued on May 21, 2012, $7,000 Note issued on May 30, 2012, $20,000 Note issued on July 24, 2012, $17,000 Note issued on October 10, 2013, $13,000 Note issued on January 16, 2013, $6,000 Note issued on July 24, 2012, $20,000 Note issued on March 6, 2014 and $10,000 Note issued on August 9, 2012 . This corporation loaned the Company $112,500 in exchange for a Promissory Note bearing interest at 18%. The Lender is allowed to convert the promissory note into Company common shares, based on which converted $20,384.34 from Face Value and $67,615.66 from Accrued Interests. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
91,966
11,258
Investment Firm: $8,877 Note issued on June 25, 2012. This individual loaned the Company $8,877 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares, The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
8,877
1,609
Investment Firm: $100,000 Note issued on May 29, 2014. This corporation loaned the Company $95,000 in exchange for a Promissory Note bearing interest at 8%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet was as of September 30, 2014.
100,000
2,718
Investment Firm $75,000 Note issued on August 29 and 30, 2012. This corporation loaned the Company $75,000 in exchange for a Promissory Note bearing interest at 18%, $1,500 is pending for funding. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $24.043 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
73,500
27,184
15
Investment Firm $250,000 Note: on June 24, 2014. Funded $50,000 on July 1, 2014, this entity loaned the Company $250,000 in exchange for a Promissory Note bearing interest at 12% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $1,495.89 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
50,000
1,496
Investment Firm $555,000 Note: on June 27, 2014 and funded $200,000 on July 2, 2014 this entity loaned the Company $225,000 in exchange for a Promissory Note bearing interest at 10% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $4,931.51 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
200,000
4,932
Investment Firm $100,000 Note: on July 17, 2014 this entity loaned the Company $100,000 in exchange for a Promissory Note bearing interest at 12% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $2,465.75 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
100,000
2,466
Investment Firm $110,000 Note: on July 18, 2014 this entity loaned the Company $110,000 in exchange for a Promissory Note bearing interest at 8% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $1,748.11 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
110,000
1,784
Investment Firm $110,000 Note: on July 29, 2014 this entity loaned the Company $110,000 in exchange for a Promissory Note bearing interest at 8% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $1,518.90 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
110,000
1,519
Investment Firm $105,000 Note: on August 22, 2014 this entity loaned the Company $105,000 in exchange for a Promissory Note bearing interest at 10% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $1,121.92 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
105,000
1,122
Investment Firm $80,000 Note: on April 20, 2014 this entity loaned the Company $80,000 in exchange for a Promissory Note bearing interest at 18% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $7,425.28 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
80,000
7,425
16
Individual $69,000 Note: on May 1, 2014 this entity loaned the Company $69,000 in exchange for a Promissory Note bearing interest at 18% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $6,267.09 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
69,000
6,267
Investment Firm $250,000 Note: on April 24, 2014 this entity loaned the Company $250,000 in exchange for a Promissory Note bearing interest at 18% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $20,386.54 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
250,000
20,387
Private Investor $44,000.00 Note issued on November 15 and December 20, 2012, an individual loaned the Company $44,000 000 in exchange for a Promissory Note bearing interest at 18%. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $12,692 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
44,000
14,278
Investment Firm $11,500 Note: on May 23, 2013 this entity loaned the Company $11,500 in exchange for a Promissory Note bearing interest at 18% for a term of one year renewable. The Lender is allowed to convert the promissory note into Company common shares. The accrued interest payable balance on this note was $2,317 as of September 30, 2014, and is included in the Convertible Promissory Notes – Accrued Interest Section of the Company’s balance sheet.
11,500
2,847
TOTAL:
3,583,423
218,290
All of the above notes are uncollateralized.
As a result of the above, the balance of the notes payable is $4,488,423 face value as of September 30, 2014 and funds pending $905,000 making a net of $ 3,583,423, and the accrued interest thereon is $218,290 as September 30, 2014.
AGREED, WOULD HELP TO GET UPDATED DATA ON OTC MARKETS, especially on float BUT HERE'S FROM LAST FILING:
Common Stock, $0.001 par value 429,827,024 shares issued & outstanding on November 13, 2014
Series A Preferred Stock, $0.001 par value, 1,000,000 shares issued & outstanding on November 13, 2014
Series B Preferred Stock, $0.001 par value, 250,000 shares issued & outstanding on November 13, 2014
Preferred stock, $0.001 par value, 15,000,000 shares authorized,
1,250,000 and 1,000,000 issued and outstanding at September 30, 2014 and December 31, 2013, respectively
Common stock, $0.001 par value, 1,000,000,000 shares authorized,
On October 28, 2014 the Company amended its Articles of Incorporation to increase the total quantity of authorized common stock to 2,500,000,000 shares
Any and all shares of Series B Preferred Stock shall be restricted from any conversion into shares of Common Stock by any holder thereof for a period of eighteen (18) months from the date of their issuance.
On March 31, 2014, the Company issued 7,000,000 shares of its restricted common stock - if there is 12 month restriction on these then legend could be removed end of next month
On October 1, 2014, the Company issued 5,000,000 shares of restricted common stock to a consulting firm per the terms and conditions of a specific consulting agreement for services with such party.
REH
Authorized is 2b but not issued. Float data not available but i would venture to guess that less than 50% of the outstanding is in the float, i.e. the remainder is restricted (12 months on OTC Pink and also VERY hard to place with brokers after legend removal).
Market Value1 $1,246,498 a/o Feb 19, 2015
Shares Outstanding 429,827,024 a/o Nov 13, 2014
Float Not Available
Authorized Shares 2,000,000,000 a/o Jan 15, 2014
Par Value No Par Value
REH
VPOR: STRONG BUY IMHO
Market cap as of yesterday about $1.25M
$1.3 mill revenue in Q3 last year.
Year end financials coming out around end of March I expect.
They could do $10-12M this year in revenue
Should be profitable
$1M+ cash plus assets of $2-2.5M (but also $3.6M in convertible notes payable)
Debt should be gone
This stock could easily go to a penny and beyond IMHO
REH
I AM SIMPLY LOOKING AT THE NUMBERS AND COMPARING TO THE CAP AND NOT AT PASSED FACTS. BASED UPON THAT I LIKE THE POTENTIAL. T/A DOESN'T AGREE BUT I REALLY DON'T CARE. AS OPPOSED TO MANY SUB-PENNY'S THERE'S SUBSTANCE IN THIS OPERATION AT THIS POINT IMHO
REH
Market cap as of yesterday about $1.25M
$1.3 mill revenue in Q3 last year.
Year end financials coming out around end of March I expect.
They could do $10-12M this year in revenue
Should be profitable
$1M+ cash plus assets of $2-2.5M (but also $3.6M in convertible notes payable)
Debt should be gone
This stock could easily go to a penny and beyond IMHO
REH
http://www.secinfo.com/$/SEC/Filings.asp?Type=3%2F4%2F5%2F144%2FU-12%2A&Label=Insider+Trading+Reports&Since=2
You can retrieve reporting forms from the SEC's EDGAR database or the SEC Info Insider Trading Reports. Form 14A is the proxy statement in which you will find a list of directors and officers and the number of shares they each own. There is also a list of beneficial owners, or people or entities owning more than 5% of a company's stock.
The other relevant forms are 13D and 13G for disclosure of outside beneficial ownership, and Forms 3, 4 and 5 for disclosure of insider beneficial ownership. Insiders with more than 10% of the voting power file Forms 3, 4 or 5, and outsiders owning more than 5% file schedule 13D or its amendment form 13F.
Hudson Bay:
At The SEC — A Focus on Short Selling
The SEC is focusing attention on trading illegal short selling, announcing twenty-three actions new actions centered on the prohibited trading practice. At the same time the Commission’s National Exam Program issued a Risk Alert on illegal short selling.
Each of the actions announced is based on Rule 105 of Regulation M. That Rule generally prohibits short selling an equity security during a restricted period. That period is five business days before a public offering. The strict liability Rule is designed to avoid depressing the offering price for a security.
Twenty-two of the actions announced were settled. A broad spectrum of entities were involved in the proceedings. They included Blackthorn Investment Group, D.E. Shaw & Co., Deerfield Management Company, Hudson Bay Capital Management, Southpoint Capital Advisors and the Ontario Teachers’ Pension Plan Board.
Each of the settling firms agreed to pay disgorgement, prejudgment interest and a penalty. The largest amount of disgorgement was paid by JGP Global Gestao de Recursos at $2,537,114.00. The smallest amount was paid by Credentia Group at $4,091.00.
Penalties ranged from a high of $679,950.00 paid by Manikay Partners on disgorgement of $1,657,000.00 to a low of $65,000 paid by eight firms: Claritas Investments Ltd, which disgorged $73,883; Credentia Group which paid the smallest amount of disgorgement; Merus Capital Partners which disgorged $8,402.00; PEAK6 Capital Management which disgorged $58,321.00; Philadelphia Financial Management of San Francisco which disgorged $137,524.38; Soundpoint Advisors which disgorged $346,568.00; Talkot Capital which disgorged $17,640 and Western Standard which disgorged $44,980.00.
When and when the actions were filed was not disclosed. The one case identified did not settle and was filed earlier this month. In the Matter of G-2 Trading LLC, Adm. Proc. File No. 3-15494 (Corrected Order Filed Sept. 16, 2013).
These actions are not the first brought by the Commission alleging violations of Regulation M, Rule 105. Since the adoption of the Rule the agency has brought a number of cases under it. Earlier this year, for example, the Commission filed proceedings based on the Rule. See, e.g, In the Matter of UBS O’Connor, LLC, Adm. Proc. File No. 3-15437 ( Filed June 13, 2013); In the Matter of Ardsley Advisory Partners, Adm. Proc. File No. 3-15199 (Filed February 5, 2013). This is the first time, however, that the Commission has announced a large group of Regulation M, Rule 105 actions together.
Program: Celesq and West Legal Ed present: Financial Fraud: Avoiding the Path of the New SEC Investigative Priority, online on September 25, 2013 at 12:00 p.m. EST (here).
new filing yesterday number 2:
3518703v1/013049
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
WORLDS, INC.,
Plaintiff,
vs.
ACTIVISION BLIZZARD, INC.,
BLIZZARD ENTERTAINMENT, INC. and
ACTIVISION PUBLISHING, INC.,
Defendants.
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)
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)
)
)
)
)
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Civil Action No. 1:12-CV-10576 (DJC)
JURY TRIAL DEMANDED
WORLDS’ MOTION FOR LEAVE TO FILE UNDER SEAL
Pursuant to Local Rule 7.2 and Section 12 of the Stipulated Protective Order entered by
the Court in this action on December 26, 2012 (Dkt. No. 49) (the “Protective Order”), Plaintiff
Worlds, Inc. (“Worlds”) hereby moves for leave to file under seal Exhibits B-13 through J-13 of
Worlds’ Fifth Supplemental Disclosure of the Claims Infringed, filed February 9, 2015.
In support of its motion, Worlds states that the foregoing includes information that
Worlds has identified and designated as “HIGHLY RESTRICTED—CONFIDENTIAL
SOURCE CODE” pursuant to the terms of the Protective Order. The sealed exhibits include
non-public, proprietary, confidential, and commercially-sensitive information and computer
source code relating to this litigation, and public access to this information will harm Worlds’
competitive positions. Worlds will provide unsealed versions of its sealed materials to the Court
and to Defendants’ counsel, subject to the terms of the Protective Order.
WHEREFORE, Worlds respectfully requests that the Court grant its motion for leave to
file under seal Exhibits B-13 through J-13 of Worlds’ Fifth Supplemental Disclosure of the
Case 1:12-cv-10576-DJC Document 150 Filed 02/09/15 Page 1 of 23518703v1/013049 2
Claims Infringed. Should the Court deny this Motion to Seal, Worlds respectfully requests that
the Court return the filings rather than placing it in the public file.
Dated: February 9, 2015 WORLDS, INC.
By its attorneys,
/s/ Ryan V. Caughey_____________________
Max L. Tribble
Brian D. Melton
Chanler Langham
Ryan V. Caughey
SUSMAN GODFREY L.L.P.
1000 Louisiana, Suite 5100
Houston, TX 77002-5096
Telephone: (713) 651-9366
mtribble@susmangodfrey.com
bmelton@susmangodfrey.com
clangham@susmangodfrey.com
rcaughey@susmangodfrey.com
Joel R. Leeman, BBO # 292070
Sunstein Kann Murphy & Timbers LLP
125 Summer Street
Boston, MA 02110-1618
Telephone: (617) 443-9292
jleeman@sunsteinlaw.com
CERTIFICATE OF SERVICE
I certify that a true copy of the above document was filed through the Court’s ECF
system on the above date and will be sent electronically to the registered participants as
identified on the Notice of Electronic Filing (NEF).
/s/ Ryan V. Caughey
Ryan V. Caughey
Case 1:12-cv-10576-DJC Document 150 Filed 02/09/15 Page 2 of 2
new filing yesterday number 1:
3518702v1/013049
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
WORLDS, INC.,
Plaintiff,
v.
ACTIVISION BLIZZARD, INC., BLIZZARD
ENTERTAINMENT, INC., and ACTIVISION
PUBLISHING, INC.,
Defendants.
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Civil Action No. 1:12-CV-10576 (DJC)
JURY TRIAL DEMANDED
WORLDS INC.’S FIFTH SUPPLEMENTAL
DISCLOSURE OF THE CLAIMS INFRINGED
Worlds Inc. (“Worlds”) provides the following fifth supplemental disclosure of the
claims infringed. The purpose of this supplemental disclosure is to add Call of Duty: Advanced
Warfare as an accused product and submit corresponding infringement disclosures for each of
the patents-in-suit.1
Defendants recently released Call of Duty: Advanced Warfare, in late 2014.
Worlds also supplements its disclosure to add the recently released World of Warcraft: Warlords
of Draenor — Defendants’ recent expansion pack to World of Warcraft — as an accused
product. Because Defendants have stipulated that World of Warcraft: Warlords of Draenor
functions materially the same (for purposes of infringement) as the versions covered by the prior
World of Warcraft infringement disclosures, Worlds is not submitting supplemental World of
Warcraft infringement charts at this time.
The infringement charts for Call of Duty: Advanced Warfare are attached as Exhibits B-
13, D-14, F-13, H-13, and J-13, which are numbered sequentially with the other accused Call of
1 This filing is made pursuant to an agreement by the parties. Call of Duty: Advanced Warfare was released in Late
2014. Defendants agreed to permit Worlds to inspect source code for Call of Duty: Advanced Warfare and then
supplement its infringement contentions accordingly. On January 7 and 8, 2015, Worlds inspected source code for
Call of Duty: Advanced Warfare, and Worlds is hereby serving and filing its supplemental disclosures.
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 1 of 73518702v1/013049 -2-
Duty titles. Worlds has not attached or modified the previously served and filed infringement
disclosures. Therefore, the previously served and filed infringement disclosures remain
operative, along with the supplemental infringement disclosures for Call of Duty: Advanced
Warfare.
Worlds’ statements herein are based on publicly available information and the computer
source code and documentation that Defendants have provided. Discovery is ongoing, and
certain documentation and information may not yet be available to Worlds that is fundamental to
its infringement claims. In particular, Worlds has not yet deposed officers or employees of any
defendant concerning the operation, functionality and integration, packaging, or terminology of
their respective products. Accordingly, Worlds reserves the right to amend its infringement
disclosures in light of further discovery, and also in light of the Court’s Markman order.
With publicly available data, it is occasionally difficult to identify Defendants’ infringing
products by name. However, Defendants have given Worlds information regarding the titles in
the Call of Duty and World of Warcraft franchises. Therefore, Worlds’ identification is based on
Defendants’ representations. If additional titles in the Call of Duty or World of Warcraft
franchises are identified during discovery (or if additional versions of previously identified titles
are discovered), Worlds reserves the right to add those versions to this lawsuit.
Based on the information provided by Defendants, the infringing products in the Call of
Duty franchise include the following games and all versions thereof, across all non-mobile
platforms (including PC, Mac, PlayStation 2, PlayStation 3, PlayStation 4, Xbox, Xbox 360,
Xbox One, Wii, and Wii-U)2
: Call of Duty; Call of Duty: United Offensive (expansion pack);
Call of Duty 2; Call of Duty 2: Big Red One; Call of Duty 3; Call of Duty 4: Modern Warfare;
Call of Duty 4: Modern Warfare “Reflex Edition”; Call of Duty: World at War; Call of Duty:
2 Worlds does not allege that any mobile versions of Call of Duty or World of Warcraft are infringing
products.
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 2 of 73518702v1/013049 -3-
Modern Warfare 2; Call of Duty: Black Ops; Call of Duty: Modern Warfare 3; Call of Duty:
Ghosts; and Call of Duty: Advanced Warfare. The infringing products in the World of Warcraft
franchise include the following games and all versions thereof, across all platforms: World of
Warcraft; World of Warcraft: Burning Crusade (expansion set); World of Warcraft: Wrath of the
Litch King (expansion set); World of Warcraft: Cataclysm (expansion set); World of Warcraft:
Mists of Pandaria (expansion set); World of Warcraft: Warlords of Draenor (expansion set).
Collectively, these titles in the Call of Duty and World of Warcraft franchises compose the
Accused Products.
In Worlds’ First Requests for Production, served August 29, 2012, Worlds requested that
defendants produce and make available for inspection source code for all versions and iterations
of all titles in the Call of Duty and World of Warcraft franchises (i.e., the accused products
specified above). Worlds’ statements herein are based on the source code that defendants have
made available in response to those requests for production. Defendants have repeatedly
purported to make available for inspection “source code relating to the Accused Products that is
sufficient to show the operation of the accused product(s) or method(s) that Worlds identified in
its preliminary infringement disclosure.” See, e.g., Activision’s Second Supplemental Noninfringement
Contentions at 6 (Dkt. No. 52). To the extent Defendants make additional source
code available for inspection — or to the extent Defendants’ tendered source code does not
include code for all World of Warcraft and Call of Duty titles and products, or to the extent
Defendants’ release or market new World of Warcraft or Call of Duty titles during the pendency
of this lawsuit — Worlds may supplement these contentions or seek other relief from the court.
Furthermore, Worlds expressly reserves the right to supplement, augment, or alter its responses
herein based on additional information obtained through discovery or other means concerning
defendants’ respective products and services.
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 3 of 73518702v1/013049 -4-
Worlds incorporates the allegations set forth in its Original and First Amended
Complaints as if fully set forth herein, as well as in its Original and Supplemental Disclosures of
Claims Infringed. Subject to the above limitations and reservations of right, Worlds makes the
following additional disclosures:
Worlds claims that each element of each asserted claim is directly infringed by
Defendants. If for any reason the Accused Products are not found to directly meet each element
of an asserted claim, Worlds alleges that Defendants are contributing to the infringement of such
claim or inducing its infringement by others because the accused functionalities have no
substantial non-infringing use, and because Defendants are aware that they are inducing the
direct infringement by its users and customers of the Accused Products. Worlds recognizes that
whether Defendants’ infringement is direct or indirect may depend on the Court’s claim
construction rulings. Once the Court construes the claims at issue, Worlds will designate which
of such claims are infringed only indirectly, if any.
Moreover, Worlds claims that each element of each asserted claim is present literally in
the Accused Products. To the extent any claim construction results in the Accused Products
falling outside the literal scope of any asserted claim, Worlds reserves the right to contend that
the Accused Products still infringe under the doctrine of equivalents. Once the Court construes
the claims at issue, Worlds will designate which of such claims are only infringed under the
doctrine of equivalents.
Based on information presently available to it, Worlds asserts that defendants infringe at
least the following claims of U.S. Patent No. 7,181,690 by their manufacture, sale, offer for sale,
and use of their Call of Duty and World of Warcraft products having the accused functionality as
more fully set forth in Exhibits A and B-1 through B-13: claims 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,
12, 13, 14, 15, 16, 17, 18, 19, and 20.
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 4 of 73518702v1/013049 -5-
Based on information presently available to it, Worlds asserts that defendants infringe at
least the following claims of U.S. Patent No. 7,493,558 by their manufacture, sale, offer for sale,
and use of their Call of Duty and World of Warcraft products having the accused functionality as
more fully set forth in Exhibits C and D-1 through D-13: claims 4, 5, 6, 7, 8, and 9.
Based on information presently available to it, Worlds asserts that defendants infringe at
least the following claim of U.S. Patent No. 7,945,856 by their manufacture, sale, offer for sale,
and use of their Call of Duty and World of Warcraft products having the accused functionality as
more fully set forth in Exhibits E and F-1 through F-13: claim 1.
Based on information presently available to it, Worlds asserts that defendants infringe at
least the following claims of U.S. Patent No. 8,082,501 by their manufacture, sale, offer for sale,
and use of their Call of Duty and World of Warcraft products having the accused functionality as
more fully set forth in Exhibits G and H-1 through H-13: claims 1, 2, 3, 4, 5, 6, 7 (World of
Warcraft only), 8, 10, 12, 14, 15, and 16 (World of Warcraft only).
Based on information presently available to it, Worlds asserts that defendants infringe at
least the following claims of U.S. Patent No. 8,145,998 by their manufacture, sale, offer for sale,
and use of their Call of Duty and World of Warcraft products having the accused functionality as
more fully set forth in Exhibits I and J-1 through J-13: claims 1, 2, 3, 7, 8, 11, 12, 13, 14, 15, 16,
17 (World of Warcraft only), 18, 19, and 20.
At this time, Worlds knows of no specific limitations of the asserted claims where
infringement depends on equivalents. Worlds alleges that if there are any differences between the
claim elements in the aforementioned claims and the accused systems or methods, the
differences are insubstantial and infringement would exist under the doctrine of equivalents.
Worlds expressly reserves the right to augment and supplement this disclosure after further
discovery from defendants and/or depending on this Court’s interpretation of the asserted claims.
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 5 of 73518702v1/013049 -6-
DATED: February 9, 2015 Respectfully submitted,
WORLDS, INC.
By its attorneys,
/s/ Ryan V. Caughey
Max L. Tribble (admitted pro hac vice)
Brian D. Melton (admitted pro hac vice)
Chanler Langham (admitted pro hac vice)
Ryan Caughey (admitted pro hac vice)
SUSMAN GODFREY L.L.P.
1000 Louisiana, Suite 5100
Houston, TX 77002-5096
Telephone: (713) 651-9366
Facsimile: (713) 654-6666
mtribble@susmangodfrey.com
bmelton@susmangodfrey.com
clangham@susmangodfrey.com
rcaughey@susmangodfrey.com
Joel R. Leeman (BBO # 292070)
SUNSTEIN KANN MURPHY
& TIMBERS LLP
125 Summer Street
Boston, MA 02110-1618
Telephone: (617) 443-9292
Facsimile: (617) 443-0004
jleeman@sunsteinlaw.com
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 6 of 73518702v1/013049 -7-
Certificate of Service
I hereby certify that a true copy of the above document was served upon Defendants’
counsel of record by CM/ECF and email on February 9, 2015.
/s/ Ryan V. Caughey
Ryan V. Caughey
Case 1:12-cv-10576-DJC Document 149 Filed 02/09/15 Page 7 of 7
$WDDD - STRONG BUY
The decision in TEVA is powerful and points out that the CAFC made an error regarding factual findings - read the decision here: http://www.supremecourt.gov/opinions/14pdf/13-854_o7jp.pdf
This would be good news should WDDD end up in the same situation but in the meantime this comes down to the Markman soon to be released and Casper's judgement on indefiniteness on the many claims.
REH
sounds good. I concentrate pretty much on tech stocks and my list is from high to low risk.
I am now following
My list:
WRAP, WDDD, OMCM, GOOGL and BABA
RR
NO NEWS
1:12-cv-10576-DJC Worlds, Inc. v. Activision Blizzard, Inc. et al
Denise J. Casper, presiding
Date filed: 03/30/2012
Date of last filing: 10/03/2014