Worlds Inc (WDDD)

[rolvram]

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.
)
)
)
)
)
)
)
)
)
)
)
)
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: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Joel R. Leeman, BBO # 292070
Sunstein Kann Murphy & Timbers LLP
125 Summer Street
Boston, MA 02110-1618
Telephone: [phone]
[e-mail]
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