UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, 

and 

Activision Blizzard, Inc., 

a corporation. 

Docket No. 9412 

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COMPLAINT COUNSEL’S MOTION TO EXTEND FACT DISCOVERY TO ALLOW 

DISCOVERY REGARDING RESPONDENTS’ AGREEMENTS WITH UBISOFT 

ENTERTAINMENT SA AND SONY INTERACTIVE ENTERTAINMENT LLC AND 

REQUEST FOR EXPEDITED RULING 

Complaint Counsel respectfully moves the Court to extend fact discovery in this matter 

for the limited purpose of allowing discovery regarding agreements that Respondents executed 

months after the close of fact discovery with third parties Ubisoft Entertainment SA (“Ubisoft”) 

and Sony Interactive Entertainment LLC (“Sony”). Fact discovery in this matter closed on April 

7, 2023. Respondents executed the Sony and Ubisoft agreements1

 on July 15, 2023, and August 

21, 2023, respectively. According to Respondents, these agreements are procompetitive and 

remedy the anticompetitive effects of the proposed acquisition of Activision Blizzard, Inc. by 

1

 The Ubisoft agreement consists of several complex, interrelated agreements. 

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Microsoft Corp. (the “Proposed Transaction”). Microsoft in fact told the United Kingdom’s 

Competition & Markets Authority (“UK CMA”) that the Ubisoft agreement rendered the 

Proposed Transaction a “substantially different transaction.”2 Complaint Counsel has had no 

opportunity to conduct discovery regarding the Ubisoft agreement or the execution of the Sony 

agreement. 

As further explained in the attached Memorandum, good cause exists for granting 

discovery on the agreements. These agreements require scrutiny so that this Court has a complete 

picture of the facts when it decides this matter. Discovery can be completed without risk of 

delaying the merits hearing, which is currently scheduled to commence twenty-one days after the 

U.S. Court of Appeals for the Ninth Circuit issues its opinion regarding the Commission’s appeal 

of the district court decision denying preliminary relief. Allowing the requested discovery will 

not unfairly prejudice Respondents. Denying discovery of these agreements will, however, 

unfairly prejudice Complaint Counsel and undermine the Court’s ability to adjudicate this 

matter. 

The Court previously granted Complaint Counsel’s and Respondents’ joint request to 

extend the deadline for all parties’ final exhibit lists by one week. See Order, In re Microsoft 

Corp. & Activision Blizzard, Inc., No. 9412 (F.T.C. May 12, 2023). Complaint Counsel has 

received no other timing extensions in this matter. 

Complaint Counsel respectfully requests expedited briefing and disposition of this 

Motion. This Court has previously recognized that, “[p]ursuant to FTC Rule 3.22(d), [it] may 

shorten the time within which a response is due.” In re La. Real Est. Appraisers Bd., No. 9374, 

2

 B. Smith, Microsoft And Activision Blizzard Restructure Proposed Acquisition and Notify Restructured 

Transaction to the UK’s Competition and Markets Authority (Aug. 21, 2023), available at 

https://blogs.microsoft.com/on-the-issues/2023/08/21/microsoft-activision-restructure-acquisition/. 

2 
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2017 WL 3277253 (F.T.C. July 20, 2017); see also Email from D. Gross to A. Bohanon, et al., In 

re Microsoft Corp. & Activision Blizzard, Inc., No. 9412 (F.T.C. June 27, 2023) (Chambers 

Order shortening time to respond). 

A proposed order is attached. 

Dated: October 10, 2023 Respectfully submitted, 

s/ James H. Weingarten 

James H. Weingarten 

Maria Cirincione 

Ethan Gurwitz 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Telephone: (202) 326-3570 

Email: jweingarten@ftc.gov 

Counsel Supporting the Complaint 

3 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, 

and 

Activision Blizzard, Inc., 

a corporation. 

Docket No. 9412 

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[PROPOSED] ORDER 

Upon consideration of Complaint Counsel’s Motion to Extend Fact Discovery to Allow 

Discovery Regarding Respondents’ Agreements with Ubisoft Entertainment SA and Sony 

Interactive Entertainment LLC and Request for Expedited Ruling: 

IT IS HEREBY ORDERED that Complaint Counsel’s motion is GRANTED. 

IT IS FURTHER ORDERED that Complaint Counsel is granted leave to serve requests 

for production of documents and data, interrogatories, notices of depositions, and subpoenas 

duces tecum and ad testificandum for the purpose of taking discovery relevant to the August 21, 

2023 agreements by and among Ubisoft Entertainment SA, Microsoft Corp., and Activision 

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Blizzard, Inc. and the July 15, 2023, agreement between Microsoft Corp. and Sony Interactive 

Entertainment LLC. 

IT IS FURTHER ORDERED that the following deadlines and limits shall apply to the 

discovery authorized herein: 

1. Complaint Counsel shall serve no more than ten requests for production on each 

Respondent; 

2. Complaint Counsel shall serve no more than ten interrogatories on Microsoft 

Corp. and five interrogatories on Activision Blizzard, Inc.; 

3. Following service of discovery, recipients shall meet and confer within two days, 

serve responses and objections within seven days, and complete document production within 21 

days; 

4. The deadline for completing fact discovery shall be eight weeks from the date of 

the entry of this Order. 

SO ORDERED. 

Dated: _________ ____________________ 

D. Michael Chappell 

Chief Administrative Law Judge 

2 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, 

and 

Activision Blizzard, Inc., 

a corporation. 

Docket No. 9412 

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MEMORANDUM IN SUPPORT OF COMPLAINT COUNSEL’S MOTION TO EXTEND 

FACT DISCOVERY TO ALLOW DISCOVERY REGARDING RESPONDENTS’ 

AGREEMENTS WITH UBISOFT ENTERTAINMENT SA AND SONY INTERACTIVE 

ENTERTAINMENT LLC AND REQUEST FOR EXPEDITED BRIEFING 

Months after fact discovery closed in this matter in April 2023, Respondents executed 

agreements with French videogame publisher Ubisoft Entertainment SA (“Ubisoft”) and Sony 

Interactive Entertainment LLC (“Sony”) that will impact American consumers and that 

Respondents assert are procompetitive and remedy the alleged anticompetitive effects of the 

proposed acquisition of Respondent Activision Blizzard, Inc. (“Activision”) by Respondent 

Microsoft Corp. (“Microsoft”) (the “Proposed Transaction”). Microsoft’s July 15, 2023, 

agreement with Sony (the “Sony Agreement”) purports to provide Sony with rights to certain 

1 
Activision content.3

 The August 21, 2023, set of agreements by and among Microsoft, 

Activision, and Ubisoft (collectively, the “Ubisoft Agreement”) purport to transfer to Ubisoft the 

rights to stream Activision content over the cloud—including to United States consumers—if the 

Proposed Transaction closes. Respondent Microsoft has publicly stated that because of the 

Ubisoft Agreement, “its proposed acquisition of Activision Blizzard presents a substantially 

different transaction under UK law than the transaction Microsoft submitted for . . . 

consideration in 2022” and that Complaint Counsel is challenging here.4

 The United Kingdom 

Competition & Markets Authority (“UK CMA”) determined that the Ubisoft Agreement is so 

significant that it required Respondents to start an entirely separate merger notification and 

review process.5  

Complaint Counsel has had no opportunity to conduct discovery regarding the Ubisoft 

Agreement or the execution of the Sony Agreement. In fact, Complaint Counsel first learned 

about the Ubisoft Agreement after Respondents announced its execution and submission to the 

UK CMA. Complaint Counsel is entitled to take—and this Court ought to have the benefit of— 

discovery of Respondents’ agreements with Ubisoft and Sony. 

PROCEDURAL BACKGROUND 

The Complaint in this matter alleges that the Proposed Transaction will give Microsoft 

the ability and incentive to fully or partially foreclose competitors from Activision’s uniquely 

valuable video game content. Compl. ¶ 96-119. As a result, the Proposed Transaction may 

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3 See, e.g., Phil Spencer (Xbox CEO), X, (July 16, 2023), https://twitter.com/XboxP3/status/1680578783718383616. 4

 Brad Smith, Microsoft and Activision Blizzard Restructure Proposed Acquisition and Notify Restructured 

Transaction to the UK’s Competition and Markets Authority, MICROSOFT, (Aug. 21, 2023), 

https://blogs.microsoft.com/on-the-issues/2023/08/21/microsoft-activision-restructure-acquisition/ (emphasis 

added); see also Brad Smith (Microsoft Pres.), X, (Aug. 22, 2023), 

https://twitter.com/BradSmi/status/1693866142702653802. 5 See UK CMA, Microsoft / Activision Blizzard (Ex-cloud Streaming Rights) Merger Inquiry, (Aug. 22, 2023) 

https://www.gov.uk/cma-cases/microsoft-slash-activision-blizzard-ex-cloud-streaming-rights-merger-inquiry. 

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substantially lessen competition in at least one of the following markets: a relatively mature 

market for high-performance video game consoles (or in the alternative, a broader video game 

console market); a market for video game content library subscription services in which 

consumers subscribe to a service offering access to a library of video games; and a relatively 

nascent market in which consumers stream video games over the cloud. Compl. ¶¶ 62; 118-19. 

Pursuant to the Court’s Case Management and Scheduling Order, fact discovery in this 

case closed on April 7, 2023. See Scheduling Order at 2. 

On April 26, 2023, the UK CMA prohibited Respondents from consummating the 

Proposed Transaction based on finding it may be expected to substantially lessen competition in 

the market for cloud gaming services.6 

On June 12, 2023, the Commission filed an action in federal district court to preliminarily 

enjoin the Proposed Transaction after Respondents refused to confirm that they would abide by 

the UK CMA’s orders barring the Proposed Transaction. See Compl. at 2-3 (ECF No. 1), FTC v. 

Microsoft Corp., No. 3:23-cv-2880 (N.D. Cal. June 12, 2023). After a five-day evidentiary 

hearing, the district court denied the FTC’s request for a preliminary injunction. See FTC v. 

Microsoft Corp., No. 3:23-cv-2880, 2023 WL 4443412 (N.D. Cal. July 10, 2023). The 

Commission appealed, and oral argument before the U.S. Court of Appeals for the Ninth Circuit 

is scheduled for December 6, 2023. 

On July 15, 2023, Microsoft and Sony executed the Sony Agreement. 

6

 UK CMA, ANTICIPATED ACQUISITION BY MICROSOFT OF ACTIVISION BLIZZARD, INC. FINAL REPORT (Apr. 26, 

2023), 

https://assets.publishing.service.gov.uk/media/644939aa529eda000c3b0525/Microsoft_Activision_Final_Report_.pd 

f. 

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On July 18, 2023, Respondents agreed to a negotiated extension of the time to 

consummate the Proposed Transaction from July 18 to October 18, 2023.7 

On July 20, 2023, on Respondents’ motion, the FTC Secretary withdrew this matter from 

adjudication pursuant to 16 C.F.R. § 3.26(c). See Order, In re Microsoft Corp. & Activision 

Blizzard, Inc., No. 9412 (July 20, 2023). 

On August 21, 2023, Respondents and Ubisoft executed the Ubisoft Agreement. 

On September 26, 2023, the Commission voted to return this matter to adjudication. See 

Order Returning Matter to Adjudication, In re Microsoft Corp. & Activision Blizzard, Inc., No. 

9412 (Sept. 26, 2023). 

FACTUAL BACKGROUND 

A. The Ubisoft Agreement 

The Ubisoft Agreement is comprised of three separate contracts executed in August 2023 

that together purport to transfer to Ubisoft the rights to sell cloud-streamed versions of Activision 

games in the United States, the United Kingdom, and various other countries outside of the 

European Economic Area if the Proposed Transaction is consummated. 

Complaint Counsel first learned of the Ubisoft Agreement after Respondents publicly 

announced its execution and submission to the UK CMA as part of an effort to remedy the UK 

CMA’s finding that the Proposed Transaction may be expected to result in a substantial lessening 

of competition in the market for the supply of cloud gaming services in the United Kingdom. On 

August 28, after multiple requests, Respondents provided the Ubisoft Agreement to Complaint 

Counsel. The next day, at Complaint Counsel’s request, Respondents’ counsel provided a brief 

overview of the terms of the agreements via videoconference. 

7 See Activision Blizzard, Inc., Current Report at 2 (Form 8-K) (July 19, 2023). 

4 
Complaint Counsel has had no opportunity for discovery regarding the Ubisoft 

Agreement. Before this matter was returned to adjudication, Complaint Counsel asked 

Respondents’ counsel for any business documents about the Ubisoft Agreement, but 

Respondents never responded to this request. Respondents also declined to provide Complaint 

Counsel with copies of information about the Ubisoft Agreement they provided to the UK CMA. 

B. The Sony Agreement 

On July 15, 2023, Microsoft executed an agreement with Sony purporting to offer Call of 

Duty on PlayStation and PlayStation Plus (Sony’s video game subscription service) after the 

close of the Proposed Transaction. { } an offer Microsoft 

made to Sony in December 2022, on which Complaint Counsel diligently sought timely 

discovery. Sony’s CEO testified that the December offer was { 

} After the district court denied preliminary 

relief, and seven months after the close of fact discovery in this matter, Sony nevertheless signed 

the agreement. Complaint Counsel has had no opportunity to take discovery regarding Sony’s 

decision to sign the agreement with Microsoft. 

ARGUMENT 

FTC Rule 3.21(c)(2) permits this Court to extend discovery for good cause, which exists 

when a scheduling order deadline “cannot be met despite the diligence of the party seeking the 

extension.” In re Traffic Jam Events, No. 9395, 2021 WL 3465709, at *1 (F.T.C. July 23, 2021) 

(quoting In re Gemtronics, Inc., No. 9330, 2009 WL 725988, at *1 (F.T.C. Feb. 13, 2009)). 

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 8 Exhibit A, Excerpt of PX3378 at 016-20 (Ryan Hr’g Testimony at 59:10-70:23). 

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Pursuant to Rule 3.21(c)(2), the Court shall consider “any extensions already granted, the length 

of the proceedings to date, the complexity of the issues, and the need to conclude the evidentiary 

hearing and render an initial decision in a timely manner.” This Court also has granted requests 

for additional discovery when the “public interest and the search for the truth are served” by such 

discovery. In re LabMD, Inc., No. 9357, 2014 WL 7183808, at *4 (F.T.C. Dec. 8, 2014). 

Complaint Counsel has good cause for requesting the ability to take discovery of the Ubisoft and 

Sony Agreements, and all of the factors set forth in Rule 3.21(c)(2) support this request. 

First, good cause exists to grant additional time for discovery of the Ubisoft and Sony 

Agreements because the agreements were not executed until months after the close of fact 

discovery. While Complaint Counsel had taken discovery of Microsoft’s offer to Sony and 

Sony’s { } to that offer, Complaint Counsel had no opportunity to take 

discovery about the circumstances surrounding Sony’s decision in July 2023 to accept the offer. 

Moreover, Complaint Counsel had no notice of the Ubisoft Agreement until after it was executed 

in August 2023. Respondents controlled the timing of this agreement, waiting to negotiate and 

execute the Ubisoft Agreement more than eighteen months after announcing the Proposed 

Transaction, seven months after the Commission issued its Administrative Complaint, and over 

three months after the UK CMA concluded that the Proposed Transaction may be expected to 

substantially lessen competition in the cloud streaming market. 

Second, the agreements and their possible effects on American consumers in the relevant 

markets present complex questions of fact that require additional discovery. See In re Pom 

Wonderful LLC & Roll Glob. LLC., No. 9344, 2011 WL 1429882, at *2 (F.T.C. Apr. 5, 2011) 

(granting an extension in part due to the “[t]he complexity of the issues in this case”). For 

example: 

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 The Ubisoft Agreement implicates different payment schemes, including { 

} Complaint Counsel is entitled to discovery of, for example, how these payment schemes 

were determined, whether Ubisoft can profitably offer streamed Activision games based on these 

schemes, and whether other market participants can profitably purchase streamed Activision 

games based on this pricing scheme. 

 Discovery also is required to test Respondents’ assertions that the Ubisoft Agreement 

is procompetitive. For example, under the current pricing terms, Ubisoft must pay Microsoft { 

} This raises doubts about whether it could ever be profitable for Ubisoft to 

license these games to multi-game content subscription service providers that offer streaming. If 

not, the effect may be to foreclose new Activision games from being offered on those services. 

This potential anticompetitive effect, among others, demonstrates why discovery is needed from 

Respondents and Ubisoft, as well as from the multi-game content subscription services providing 

cloud streaming today, including Amazon and Sony. 

 Although Complaint Counsel had no opportunity to take discovery of the Ubisoft 

Agreement and no notice of any potential deal with Respondents, Ubisoft’s ability, incentives, 

and plans to market cloud streaming rights for Activision games are now highly relevant. 

 Relevant discovery also encompasses Respondents’ negotiation to extend the deadline 

for completing the Proposed Transaction from July to October 2023, which provided time for 

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negotiating and executing the Ubisoft Agreement. The Ubisoft Agreement purports to offer 

Activision content broadly across cloud-gaming services, which is in direct conflict with 

Respondents’ arguments that Activision content cannot be supported by cloud streaming. 

Third, all of the other Rule 3.21(c)(2) factors support extending discovery. The 

proceedings to date have progressed efficiently, with the only pause arising from Respondents’ 

motion to withdraw this matter from adjudication. Permitting discovery of the agreements 

presents no risk of delaying the evidentiary hearing. The evidentiary hearing is not set to begin 

until twenty-one days after the Ninth Circuit rules on the Commission’s appeal. Complaint 

Counsel’s request for eight weeks to take the requested discovery will not risk delaying the 

merits hearing or issuance of the Court’s decision. 

Fourth, the “public interest and search for the truth” require discovery on the agreements. 

See LabMD, Inc., 2014 WL 7183808, at *4. These agreements purport to affect millions of 

gamers in the United States. The issue of whether the agreements are sufficient to replace the 

competition lost because of the Proposed Transaction requires additional discovery before it can 

be resolved. Neither Complaint Counsel nor this Court can simply take Respondents’ untested 

word on the alleged procompetitive benefits of the agreements. As the Supreme Court has made 

clear, “all doubts as to the remedy are to be resolved in [the Government’s] favor.” United States 

v. E. I. du Pont de Nemours & Co., 366 U.S. 316, 334 (1961); see also United States v. Aetna 

Inc., 240 F. Supp. 3d 1, 78 (D.D.C. 2017) (“Courts appropriately guard their ability to ascertain 

the actual facts at issue, rather than allow a party to thwart judicial review through its own 

machinations.”). This Court is entitled to ordinary course information and sworn testimony about 

these agreements and their effects. 

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Finally, Respondents cannot plausibly claim any unfair prejudice arising from permitting 

discovery of agreements that they executed long after the close of fact discovery and that they 

are publicly touting as having changed the antitrust analysis of the Proposed Transaction. In fact, 

the lack of discovery unfairly prejudices Complaint Counsel’s ability to analyze the effects of 

these agreements on American consumers. 

CONCLUSION 

For the foregoing reasons, Complaint Counsel respectfully moves the Court to extend the 

fact discovery deadline to permit discovery relevant to the Ubisoft and Sony Agreements. 

Pursuant to FTC Rule 3.22(d), Complaint Counsel respectfully requests expedited briefing and 

disposition of this Motion. 

Dated: October 10, 2023 Respectfully submitted, 

s/ James H. Weingarten 

James H. Weingarten 

Maria Cirincione 

Ethan Gurwitz 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Telephone: (202) 326-3570 

Email: jweingarten@ftc.gov 

Counsel Supporting the Complaint 

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EXHIBIT A 

CONFIDENTIAL – REDACTED IN ENTIRETY 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, 

and 

Activision Blizzard, Inc., 

a corporation. 

Docket No. 9412 

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STATEMENT REGARDING MEET AND CONFER 

Pursuant to the January 4 Scheduling Order and the May 12 Order Granting Joint Motion 

for First Revised Scheduling Order, Complaint Counsel submit this statement in support of their 

Motion to Extend Fact Discovery to Allow Discovery Regarding Respondents’ Agreements with 

Ubisoft Entertainment SA and Sony Interactive Entertainment LLC and Request for Expedited 

Ruling. Complaint Counsel has conferred with Respondents in good faith and attempted to come 

to an agreement on a discovery proposal. On September 27, 2023, Complaint Counsel requested 

Respondents’ position on a proposal to extend fact discovery. Respondents waited five days to 

acknowledge the request and submitted a counterproposal to Complaint Counsel on October 5. 

On October 6, Respondents confirmed by email their unwillingness to agree to a discovery 

1 
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proposal that includes individual depositions and interrogatories. Discussions continued via 

email on October 6 and 9. Complaint Counsel and Respondents reached an impasse regarding 

the appropriate scope of discovery regarding the agreements. 

Dated: October 10, 2023 Respectfully submitted, 

s/ James H. Weingarten 

James H. Weingarten 

Maria Cirincione 

Ethan Gurwitz 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Telephone: (202) 326-3570 

Email: jweingarten@ftc.gov 

Counsel Supporting the Complaint 

2 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, 

and 

Activision Blizzard, Inc., 

a corporation. 

Docket No. 9412 

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DECLARATION OF MARIA CIRINCIONE IN SUPPORT OF COMPLAINT 

COUNSEL’S MOTION TO EXTEND FACT DISCOVERY TO ALLOW DISCOVERY 

REGARDING RESPONDENTS’ AGREEMENTS WITH UBISOFT ENTERTAINMENT 

SA AND SONY INTERACTIVE ENTERTAINMENT LLC AND REQUEST FOR 

EXPEDITED BRIEFING 

My name is Maria Cirincione. I am over eighteen years of age, and I am a citizen of the 

United States. I have personal knowledge of the information contained herein. 

1. I am serving as Complaint Counsel in the above-captioned matter. 

2. I respectfully submit this declaration to provide certain documents that are 

referred to in Complaint Counsel’s Motion to Extend Fact Discovery to Allow Discovery 

Regarding Respondents’ Agreements with Ubisoft Entertainment SA and Sony Interactive 

Entertainment LLC and Request for Expedited Ruling. 

1 
3. Submitted herewith are true and correct copies of the following: 

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Exhibit Description 

A Excerpt of PX3378 at 016-20 (Ryan Hr’g Testimony at 59:10-70:23). 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

Dated: October 10, 2023 Respectfully submitted, 

s/ Maria Cirincione 

2 
CERTIFICATE OF SERVICE 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/10/2023 OSCAR NO 608713 | PAGE Page 20 of 21 * -PUBLIC PUBLIC

 

I hereby certify that on October 10, 2023, I filed the foregoing document electronically using the 

FTC’s E-Filing System, which will send notification of such filing to: 

April Tabor 

Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-113 

Washington, DC 20580 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

 Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

I also certify that I caused the foregoing document to be served via email to: 

Beth Wilkinson 

Rakesh Kilaru 

Alysha Bohanon 

Anastasia Pastan 

Grace Hill 

Sarah Neuman 

Kieran Gostin 

Wilkinson Stekloff LLP 

2001 M Street, NW 

Washington, DC 20036 

(202) 847-4010 

bwilkinson@wilkinsonstekloff.com 

rkilaru@wilkinsonstekloff.com 

abohanon@wilkinsonstekloff.com 

apastan@wilkinsonstekloff.com 

ghill@wilkinsonstekloff.com 

sneuman@wilkinsonstekloff.com 

kgostin@wilkinsonstekloff.com 

Mike Moiseyev 

Megan Granger 

Weil, Gotshal & Manges LLP 

2001 M Street, NW 

Washington, DC 20036 

(202) 682-7235 

michael.moiseyev@weil.com 

Steven Sunshine 

Julia K. York 

Jessica R.Watters 

Skadden, Arps, Slate, Meagher & Flom LLP 

1440 New York Ave, NW 

Washington, DC 20005 

(202) 371-7860 

steve.sunshine@skadden.com 

julia.york@skadden.com 

jessica.watters@skadden.com 

Maria Raptis 

Matthew M. Martino 

Michael Sheerin 

Evan R. Kreiner 

Andrew D. Kabbes 

Bradley J. Pierson 

Skadden, Arps, Slate, Meagher & Flom LLP 

One Manhattan West 

New York, NY 10001 

(212) 735-2425 

maria.raptis@skadden.com 

matthew.martino@skadden.com 

michael.sheerin@skadden.com 

evan.kreiner@skadden.com 

andrew.kabbes@skadden.com 
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megan.granger@weil.com 

Counsel for Microsoft Corporation 

bradley.pierson@skadden.com 

Counsel for Activision Blizzard, Inc. 

By: s/ James H. Weingarten 

James H. Weingarten 

Counsel Supporting the Complaint