Worlds Inc (WDDD)

[Savy Investors]

New Pacer Document - 02/23/2021

Case 1:12-cv-10576-DJC Document 332 Filed 02/23/21 Page 1 of 4

IN THE 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


DEFENDANTS’ NOTICE OF SUPPLEMENTAL PROCEEDINGS IN SUPPORT OF DEFENDANTS ’ MOTION FOR SUMMARY JUDGMENT UNDER 35 U.S.C. § 101
Defendants Activision Blizzard, Inc., Blizzard Entertainment, Inc., and Activision Publishing, Inc. (collectively, “Activision” or “Defendants”), file this Notice of Supplemental Authority to bring to the Court’s attention material that is relevant to Defendants’ Motion for Summary Judgment under 35 U.S.C. § 101 (Dkt. 272), which is pending before the Court and on which the Court heard argument on July 22, 2020.
On September 20, 2019, Worlds filed a lawsuit against Linden Research, Inc. d/b/a Linden Lab, asserting infringement of U.S. Patent No. 7,181,690—which is asserted in this case. Dkt. 295 at 1. On November 13, 2020, the Linden Research court held a Markman hearing. See No. 1:19-cv-01773, Dkt. 55 (D. Del.). In connection with those Markman proceedings, Worlds submitted a technology tutorial (attached hereto as Exhibit A), a copy of which Worlds first produced to Defendants on February 17, 2021 after multiple requests from Defendants.
In that technology tutorial, Worlds states that the “roadcast (client server) architecture was not enough of an improvement” because “[t]he Virtual Space can still become over-crowded.”

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Case 1:12-cv-10576-DJC Document 332 Filed 02/23/21 Page 2 of 4

Ex. A at 0869-0870 (emphasis added). Worlds further states that filtering was “Worlds’ Solution ” to this problem. Id. at 0874 (“Worlds’ Solution: Server-Side and Client-Side Filtering ” (emphasis added)). Worlds also included the below slide, which illustrates and compares broadcast (i.e., no filtering) with Worlds’s alleged invention (i.e., “[f]iltering [c]apabilities).


Ex. A at 0880. These statements Worlds made and illustrations it provided in its technology tutorial in connection with the Linden Research matter run counter to its arguments in opposition to Defendants’ motion for summary judgment under 35 U.S.C. § 101, including that the claims are not directed to filtering and that there is no real-world analogue. Compare Ex. A, with, e.g., Dkt. 276 at 6 (arguing that Activision ’s argument that “the asserted claims are directed to the abstract idea of ‘filtering’ … is wrong”); id. at 12 ( “Activision argues that ‘each claim is directed to the abstract idea of filtering position information in a computer network, i.e., crowd control.’ … Activision also asserts that ‘the very notion of filtering to process information or resolve crowd control problems is a basic method of organizing human activity that is well-known,’ … and that ‘the fundamental concept of filtering people to maintain crowds below a maximum capacity … has been known and used to effectively manage human behaviors and interactions.’ … But as

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Case 1:12-cv-10576-DJC Document 332 Filed 02/23/21 Page 3 of 4

already explained above, there is no real-world comparison to Worlds patented invention.”); Dkt. 287 at 26:16-27:13.

Dated: February 23, 2021 Respectfully submitted,
By: /s/ Sonal N. Mehta
Sonal N. Mehta (pro hac vice)
[e-mail]
WILMER CUTLER PICKERING HALE AND DORR LLP
2600 El Camino Real
Suite 400
Palo Alto, CA 94306
Tel.: [phone]
Fax: [phone]
Kevin S. Prussia (BBO# 666813) [e-mail]
Claire M. Specht (BBO# 687952) [e-mail]
Scott Bertulli (BBO# 690958)
[e-mail]
WILMER CUTLER PICKERING HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel.: [phone]
Fax: [phone]
Attorneys for Defendants Activision Blizzard, Inc., Blizzard Entertainment, Inc., and
Activision Publishing, Inc.


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Case 1:12-cv-10576-DJC Document 332 Filed 02/23/21 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that the foregoing document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) this 23rd day of February, 2021.
By: /s/ Sonal N. Mehta
Sonal N. Mehta