Worlds Inc (WDDD)

[coolerheadsprevail]

FYI, from another board, it appears Docket entries 119 and 120 have been filed. They do not yet appear on the us.archive.org site yet (http://ia601204.us.archive.org/31/items/gov.uscourts.mad.143034/gov.uscourts.mad.143034.docket.html), but this source has been solid before (he was the same source who first posted 118 on that board, which I immediately brought here), and so I suspect 119 and 120 should show up on the us.archive.org site shortly. But, in the interim, here is what this source posted:

Doc 119
Amended Document (Filed & Entered: 03/04/2014)
Docket Text: AMENDED DOCUMENT by Worlds, Inc.. Amendment to [34] Preliminary Disclosure of the Claims Infringed, Fourth Supplemental. (Caughey, Ryan)

Note: This is a 7-pager so he did not post the content.


Doc 120
Motion for Leave to File (Filed & Entered: 03/04/2014)
Docket Text: MOTION for Leave to File Under Seal Exhibits to DKT 119 Disclosure of Claims Infringed, Fourth Supplemental by Worlds, Inc.(Caughey, Ryan)

WORLDS, INC.,
Plaintiff,
vs.
ACTIVISION BLIZZARD, INC.,
BLIZZARD ENTERTAINMENT, INC. and
ACTIVISION PUBLISHING, INC.,
Defendants.

Civil Action No. 1:12-CV-10576 (DJC)

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-12 through J-12 of Worlds' Fourth Supplemental Disclosure of the Claims Infringed, filed March 4, 2014.1

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.

1 This filing is made pursuant to an agreement by the parties. Call of Duty: Ghosts was released in November 2013. On December 12, 2013, Activision agreed to permit Worlds to inspect source code for Call of Duty: Ghosts and then supplement its infringement contentions. On February 18, 2014, Worlds inspected source code for Call of Duty: Ghosts, and Worlds is submitting its hereby serving and filing its supplemental contentions on March 4, 2014.

WHEREFORE, Worlds respectfully requests that the Court grant its motion for leave to file under seal Exhibits B-12 through J-12 of Worlds' Fourth Supplemental Disclosure of the 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: March 4, 2014 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.

Joel R. Leeman, BBO # 292070
Sunstein Kann Murphy & Timbers LLP

*************

In summary, 119 and 120 is all good news as it is requesting that the newest COD entry into the franchise ("Ghosts") also be added to the suit and eligible for damages/royalties. No guarantee the Court will grant it, but like 118, no harm can come of this as a denial will not take anything away from WDDD but a granting adds more potential $$$ to the pot at the end of the rainbow...