Please read to the bottom its written in a specific order.
My years as a PI and Asset locator come Back to me…
The Subpoena is mightier than the sword my friends.
As I have said here is what is possible.
Follow below my bouncing subpoena ball questions.
Obviously some of the questions below would be considered compounded and would need to be inquired upon differently but I am grouping for the readers here.
1. How much did ATVI invest originally with Bungie.
2. Was there future amounts paid to Bungie.
3. Were those amounts deposited into one account or many accounts
and in many which accounts were they deposited into.
4. On what date was a Activision Board member accepted by Bungie to
sit on the Bungie board.
5. What was the board members name Hereafter know as board member
J.Doe or Doe
6. Was this individual Doe the only one elected by Bungie for
Activision.
7. Was the ATVI board member Doe privy to ALL board meetings
8. Were all outside 3rd party lawsuits discussed at board meetings
in front of Doe
9. Did Doe have a Bungie email.
10. Was the Activision letter referring to Destiny shown to all board
members
11. Were minutes of all board meeting recorded by mechanical means
(audio) or written
12. Did Doe have access to any meeting minutes missed
13. Is there a record of board meetings for the prior 10 years
14. Is there a written record or audio for those meeting
15. Did the board direct monies from ATVI into a general account to
clear
16. Did the board direct monies from a general account to a
legal/council account
17. Was a retainer, invoice or any amount written from any account
for the litigation from any of the aforementioned accounts and if
so how much for
18. Was the amount paid shown on corporate tax returns
19. Did Activision pay any amounts directly to Bungie for litigation
in ANY other cases.
20. Did Activision EVER PAY any amount to Bungie for ANY litigation
IN ANY other case or case review
21. Did the board members not Doe direct legal council to institute
the IPR WITH the Doe at the same meeting of the board
22. Did Doe vote on the issue or offer a positive move forward is
warranted recorded at the time or comment on such.
23. Did Doe have an active Bungie email i.e Doe@Bungie.net
24. Can you produce all emails to, from, cc, bcc for Doe
25. Is there an employment file for Doe
26. Does that employment file contain a application for employment
27. Is there a contract for employment between Bungie and Doe
28. Did ATVI or any party on behalf of ATVI legal, employee, patent
ever email Bungie about any question to make sure the IP was free
from litigation such as the case at hand with Worlds
29. If bungie is not privy with ATVI does, has bungie ever send any
emails to ATVI in house or other legal council for ATVI?
Activision
30. Did J. Doe Ever work for ATVI
31. From what date to what date
32. Was Doe ever a board member for ATVI
33. Who did Doe report directly too daily
34. Who did Doe report directly to that was on the ATVI board
35. Did doe have an ATVI Email account
36. How long has or did Doe work with ATVI
37. What was Doe’s duties at the company
38. Was there a memo, letter, board meeting minutes or meeting
whereas Doe’s duties on the Bungie board was discussed and agreed
to.
39. DID DOE EVER REPORT BUNGIE BOARD MEETING ISSUES WITH ANYONE AT
ATVI
40. If Doe did discuss Bungie board meetings with whom did he or she
41. Where those minutes, emails information sent electronically
42. Did Doe ever sit In on any board meeting permanently or temp for
any special meeting
43. Did Doe ever discuss Bungie meetings with ATVI board
44. Was there any emails, memos, letters, discussions from the legal
department to or from anyone with ATVI regarding any IP
litigation on ANY case
45. Was there any emails, memos, letters, discussions from the legal
department to or from anyone with ATVI regarding any IP
litigation regarding the cancelling of the 10 year old contract
with Bungie
46. When Bungie paid its legal retainer, invoices or other legal fee
for each of the last 10 years did any of those payments come from
any account that original or later monies were paid by ATVI were
deposited into
47. If ANY payments from ATVI into a Bungie account was used to pay
legal fees was there any attempt and if so to depurate legal
payments from casual day to day payments to others in a way to
show monies were not co-mingled
48. Was there ever a statement made by J Doe at any board meeting
regarding and LEGAL issues including IP or any other
49. Did bungie ever have any contract, agreement, paper, electronic
document in which parties guiding ATVI and Bungie exist
50. Has an ATVI representative ever discussed in person,
electronically, memo, contract or in any other way using any
instrument human or materially any legal case regarding any 3rd
party not Worlds Inc. at any time during the past 10 years or
during the contract years between ATVI and Bungie.
Lastly
to Bungie at any meeting was it brought to J Doe to EVER during any board meeting or individual meeting, phone call, text, email, memo or other conveyance conduit of information do bring ANY kind of information to Activision to ask a question and to receive feedback on ANY issue during the 10 year contract and if so what was such information
Lastly
to Activision at any meeting was it brought to J Doe to EVER during any board meeting or individual meeting, phone call, text email, memo or other conveyance conduit of information do bring ANY kind of information to Activision to ask a question and to receive feedback on ANY issue during the 10 year contract and if so what was such information
See my friends these are a quick top 50
information subpoena" questions - My Subpoena Duces Tecum would be based upon the information based on the information subpoena.
I brought many an investigation to a complete halt and to a very nicely structured settlement.
This is nothing short of a win for WORLDS i could only hope that Thom alludes to this type of warfare.
FOLKS IF.........IF any 4 of the items in any combination exists or happened its game over. If Bungie who now has no contract and now recently just got a 100 million for a small piece of their company from NETEASE does not need ATVI anymore way decide to either, concede, remove the IPR or settle with a small licence issue to boot - ATVI would LOSE their minds!!!.
Anyway just my opinion with 20 + years of experience
AI
