Worlds Inc (WDDD)

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3150592v1/013049
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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Civil Action No. 1:12-CV-10576 (DJC)
JURY TRIAL DEMANDED
WORLDS, INC.’S MOTION TO TRANSFER VENUE
Pursuant to 28 U.S.C. § 1404(a), Plaintiff Worlds, Inc. (“Worlds”) moves to transfer venue
to the Central District of California. In support of this Motion, Worlds is contemporaneously
filing: (1) Memorandum in Support of Worlds, Inc.’s Motion to Transfer Venue; (2) Declaration
of Ryan V. Caughey in Support of Worlds, Inc.’s Motion to Transfer Venue (and exhibits thereto);
and (3) Declaration of Thom Kidrin in Support of Worlds, Inc.’s Motion to Transfer Venue.
For the reasons set forth in the accompanying Memorandum and supporting materials,
Worlds respectfully requests that this Court issue an order transferring this case in its entirety to
the U.S. District Court for the Central District of California.
REQUEST FOR ORAL ARGUMENT
Pursuant to Local Rule 7.1(d), Worlds respectfully requests oral argument to aid in resolution
of this Motion.
Case 1:12-cv-10576-DJC Document 131 Filed 05/02/14 Page 1 of 3
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3150592v1/013049
RULE 7.1 CERTIFICATION
Pursuant to Local Rule 7.1(a)(2), Worlds hereby certifies that counsel for Worlds has
conferred with counsel for Defendants about the subjects raised in this Motion, and Defendants
are opposed to transferring venue.
Dated: May 2, 2013 Respectfully submitted,
Worlds, Inc.
By its attorneys,
By: /s/ Ryan V. Caughey________
Max L. Tribble (admitted pro hac vice)
[e-mail]
Chanler Langham (pro hac vice pending)
[e-mail]
Ryan Caughey (admitted pro hac vice)
[e-mail]
SUSMAN GODFREY L.L.P.
1000 Louisiana Street, Suite 5100
Houston, Texas 77002
Telephone: [phone]
Facsimile: [phone]
Joel R. Leeman (BBO # 292070)
[e-mail]
SUNSTEIN KANN MURPHY & TIMBERS LLP
125 Summer Street
Boston, MA 02110-1618
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Worlds, Inc.
Case 1:12-cv-10576-DJC Document 131 Filed 05/02/14 Page 2 of 3
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3150592v1/013049
CERTIFICATE OF SERVICE
I certify that on the above date, this document and supporting materials identified above
were filed through the ECF system and thereupon 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 131 Filed 05/02/14 Page 3 of 3