"The Apple iPod iTunes Anti-Trust Litigation"
REDACTION to 345 Redacted Document Plaintiffs' Reply in Support of Their Motion for Additional Discovery Pursuant to Rule 56(f) by Melanie Tucker. (Sweeney, Bonny) (Filed on 4/26/2010)
13 (Additional counsel appear on signature page.) 14 15 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 16 17 SAN JOSE DIVISION Ts 20 hi) Document Relates To: ) PLAINTIFFS'ADDITIONALOF THEIR MOTION FOR REPLY IN SUPPORT ALL ACTIONS. ) DISCOVERY PURSUANT TO RULE 56(f) 19 ) 21 ) 22 23 18 LITIGATION ) THE APPLE IPOD ITUNES ANTI-TRUST ) Lead Case No. C-05-00037-JW(HRL) ) CLASS ACTION Judge: Date: Time: Location: Hon. James Ware May 10,2010 9:00 am 8, 4th Floor 24 25 REDACTED 26 27 28 520779_1 1 Plaintiffs submit this reply memorandum in support of their motion for additional discovery 2 pursuant to Federal Rules of Civil Procedure, Rule 56(f). 3 I. SUPREME COURT AND NINTH CIRCUIT PRECEDENT FAVOR ADDITIONAL DISCOVERY 4 '''Federal Rule of Civil Procedure 56(f) provides a device for litigants to avoid summary 5 judgment when they have not had sufficient time to develop affirmative evidence.'" Burlington N. 6 Santa Fe R. Co. v. Assiniboine & Sioux Tribes of the Fort Peck Reservation, 323 F.3d 767, 773 (9th 7 Cir. 2003) (quoting United States v. Kitsap Physicians Serv., 314 F.3d 995, 1000 (9th Cir. 2002)). 8 Apple asks this Court to ignore the intended purpose of Rule 56(f) and grant its alternative motion 9 for summary judgment without affording Plaintiffs the opportunity to complete discovery bearing 10 directly on Apple's motion. 1 11 While Rule 56(f) is permissive in nature, "the Supreme Court has restated the rule as 12 requiring, rather than merely permitting, discovery 'where the nonmoving party has not had the 13 opportunity to discover information that is essential to its opposition.'" Metaboltfe Int'l. Inc. v. 14 Wornick, 264 F.3d 832,846 (9th Cir. 2001) (emphasis added) (quoting Anderson v. Liberty Lobby. 15 Inc., 477 U.S. 242 n.5 (1986)). Denial ofa Rule 56(f) motion "is especially inappropriate where the 16 material sought is also the subject of outstanding discovery requests." VISA Int'l Servs. Ass'n v. 17 Bankcard Holders of Am., 784 F.2d 1472,1475 (9th Cir. 1986). 18 Accordingly, where, as here, the party seeking Rule 56(f) discovery has: (l) specifically 19 identified the necessary discovery; (2) demonstrated that such discovery is essential to oppose a 20 21 Plaintiffs have not sought to apply "a more lenient standard" under Rule 56(f) as Apple claims. See Apple's Reply in Support of Motion to Dismiss or, Alternatively, for Summary 22 Judgment ("Apple's Reply") at 13. Despite Apple's attempts to distinguish the standards set forth in Barovich Assocs., Inc. v. Aura Sys., Inc., No. 96-55779, 1998 WL 10747 (9th Cir. Jan. 8, 1998), 23 Barovich is consistent with the law followed by the Ninth Circuit today. See id., at *2 (requiring 24 plaintiffto identify the information sought with "specificity" and demonstrate "that the discovery sought exists"). While a party seeking discovery pursuant to Rule 56(f) must "make clear what 25 information is sought and how it would preclude summary judgment," Garrett v. San Francisco, 818 F.2d 1515, 1518 (9th Cir. 1987), the information need only be "'potentially favorable.'" Clark v. 26 Cap.1475 ("The courts which have denied F.3d 1162, 1178 (9th Cir.for lack seesufficient showing to at Credit & Collection Servs., Inc., 460 a Rule 56(f) application 2006); of also VISA, 784 F.2d 27 supporttfurther discovery appearwashaveobject so where it was clear that the evidence sought was to the done of pure speculation."). almos certainly nonexistent or 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -1- 1 summary judgment motion; and (3) the discovery needed is responsive to outstanding discovery 2 requests, the request should be granted. 3 II. 4 5 PLAINTIFFS HAVE DILIGENTLY PURSUED THE DISCOVERY THAT IS ESSENTIAL TO THEIR OPPOSITION Most of the discovery Plaintiffs seek in order to adequately respond to Apple's motion for summary judgment is responsive to requests served prior to Apple's filing. While this action has 6 been pending for over four years, it was not until October of2009 that Plaintiffs received Apple's 7 first substantive production of merits-related discovery. Declaration of Paula M. Roach Pursuant to 8 Rule 56(f) of the Federal Rules of Civil Procedure in Support of Plaintiffs' Opposition to Apple's 9 Motion to Dismiss or, Alternatively, For Summary Judgment ("Roach Decl."), ~l 1. These 10 documents relate to Plaintiffs' Rule 30(b)(6) deposition notice and related document requests 11 concerning Apple's use of software and firmware updates. Id., ~~10, 11. Through these requests, 12 Plaintiffs sought discovery related to Apple's use of iTunes software and iPod firmware updates. 13 Apple's policies and procedures concerning such updates, the genesis of each update, and the 14 unintended and intended effects of each update. See id., Ex. B. 15 Contrary to Apple's counsel's representations, the parties initially agreed that Apple would 16 produce a subset of documents responsive to the Rule 30(b)(6) requests. Roach Decl., ~10; Cf 17 Declaration of David C. Kiernan in Support of Apple's Reply in Support of Motion to Dismiss or, 18 Alternatively, for Summary Judgment ("Kiernan Decl."), ~2. This subset was intended to allow 19 Plaintiffs to evaluate what other relevant, responsive information was likely available. Plaintiffs did 20 not agree that this was all Apple had to produce. See id., ~2. Instead, Plaintiffs expressly reserved 21 their rights on two separate occasions to seek full discovery of the documents identified in their 22 30(b )(6) notice once Apple's production ofthe subset was complete. See Declaration of Thomas R. 23 Merrick in Support of Plaintiffs' Request for Additional Discovery Pursuant to Rule 56(f), filed 24 concurrently ("Merrick Decl."), Ex. A at 1; id., Ex. B; Roach Decl., ~10. 25 In total, Apple has produced just over 1,000 documents as part of the initial subset of 26 responsive documents. Kiernan Decl., ~2. On March 22, 2010 - the day Plaintiffs' opposition to 27 Apple's motion for summary judgment was due - Apple produced what it represented was the last 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -2- 1 production related to the subset of requests. Id., ~17. However, just a few days ago, on April 22, 2 Apple produced an additional 147 pages of documents responsive to the Rule 30(b)(6) requests. 3 Merrick Decl., ~6. It is unclear when Apple's Rule 30(b)(6) related production will be completed. 4 As discussed more fully below, Plaintiffs have reviewed Apple's production to date and requested 5 additional documents responsive to the requests that directly relate to the factual issues in dispute. 6 Merrick Decl., ~7. 7 Additionally, most ofthe other relevant information was requested by Plaintiffs on December 8 28, 2009. See Roach Decl., ~13. Plaintiffs sought discovery related to, inter alia, Apple's 9 negotiations and contracts with the record labels, Apple's business relationships with Hewlett 10 Packard and Motorola, and Apple's response to RealNetworks. Id., ~~18-24. However, after the 11 Court decertified the plaintiff class in December of 2009, Apple took the position that merits 12 discovery was no longer open and refused, for two months, to produce discovery responsive to these 13 requests. See Roach Decl., ~14. Even after the Court reiterated that discovery was open (see Dkt. 14 No. 324 at 2), Apple made no effort to produce information responsive to these requests until 15 Plaintiffs specified which categories of information were immediately necessary to respond to 16 Apple's motion for summary judgment. Merrick Decl., ~4. Thus, it was by no fault of Plaintiffs that 17 discovery on these issues has been delayed. 18 In fact it was not until April 5, 2010, that Apple began producing documents responsive to 19 Plaintiffs' second set of requests. Id., ~8. Apple produced nine additional amendments to the 20 original contracts with the major labels and on April 8, 2010, produced two contracts with Motorola. 21 Id. Although Apple has agreed to produce the discovery responsive to Plaintiffs' remaining requests 22 as laid out in their supporting Rule 56(f) declaration (see Roach Decl., ~15), it has yet to do so. 23 Plaintiffs have met and conferred with Apple concerning the remaining requests and Apple has 24 promised production would be complete by the end of May. Merrick Decl., ~5. 25 Accordingly, Plaintiffs have been diligent in seeking discovery and should be permitted to 26 obtain the requested discovery in order to respond fully to Apple's motion. 27 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -3- 1 III. PLAINTIFFS HAVE SPECIFIED THE INFORMATION ESSENTIAL TO THEIR OPPOSITION 2 In their Rule 56(f) request and supporting declaration, Plaintiffs specifically identified 3 precisely what information is necessary to oppose Apple's motion and, as discussed above, even 4 sought most of this information prior to Apple's filing. However, Apple now asks that this Court 5 rule on its summary judgment motion without providing Plaintiffs with the necessary discovery 6 requested. See Apple's Reply at 12-13. 7 In its motion for summary judgment, Apple argues that the software and firmware "updates" 8 that disabled the interoperability developed by RealNetworks and potentially other competitors were 9 not anti-competitive. This argument rests on five factual premises: (l) Apple issued the relevant 10 updates in response to illegal "hacks"; (2) the record labels required Apple to issue these updates; (3) 11 the updates just "happened" to disable Harmony; (4) Apple's updates were product improvements; 12 and (5) Apple would have had to disclose secretive and potentially harmful information to 13 RealNetworks to keep Harmony going. See Apple's Motion to Dismiss or, Alternatively, for 14 Summary Judgment ("Apple's Motion") at 1 0-16. Plaintiffs have demonstrated that they are entitled 15 to discovery on all of these factual premises in order to adequately oppose Apple's motion. See 16 Roach Decl., ~4; Plaintiffs' Memorandum in Opposition to Apple's Motion to Dismiss or, 17 Alternatively, for Summary Judgment ("Opposition") at 23. 18 A. 19 Apple's Claim that It Issued the Relevant Updates in Response to Illegal "Hacks" 20 Apple claims that it issued the relevant updates in response to "hacks," or illegal reverse 21 engineering, to FairPlay that violated of the Digital Management Copyright Act ("DMCA"). 22 Apple's Motion at 1 O. However, whether the programs violated the DMCA is itself a factual issue 23 for which Plaintiffs require discovery to adequately respond. For example, as Plaintiffs explained in 24 their Opposition, such reverse engineering does not violate the DMCA where it enables 25 interoperability. Opposition at 17. If the "hacks" were intended for this purpose, then Apple's 26 contention that they were illegal would not stand. Thus, Plaintiffs are entitled to discovery to 27 determine "whether the alleged software programs intended to create interoperability violated the 28 DMCA." Roach Decl., ~~4, 26. 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -4- 1 In order to determine how the programs worked and, thus, whether they indeed violated the 2 DMCA or were, for example, intended to create interoperability, Plaintiffs have requested that Apple 3 produce source code and other technical information concerning the manner in which Apple updated 4 FairPlay to stop the "hacks." Merrick Decl., ~7. Plaintiffs requested these documents in their 5 original Rule 30(b)(6) requests served in April 2009. Apple has stated at this time that it is not 6 willing to produce this information, but the parties continue to meet and confer on the issue. Ąd. 7 Plaintiffs may be required to move to compeL. 8 B. Apple's Claim that the Record Labels Required Apple to Issue the Relevant Updates 9 Apple also claims that the record labels required Apple to issue the relevant updates. In 10 December of 2009, Plaintiffs sought complete production concerning communications with all 11 record labels to determine which, if any, aspects of the updates were required by the labels and 12 which were created on Apple's own accord. See Roach Decl., ~~18, 19. If 13 this information reveals that Apple issued the relevant updates (or relevant portions of the updates) on its own and not 14 pursuant to any contractual requirements with the labels, then Apple's factual contention will be 15 rebutted. See Opposition at 11. Apple has produced additional contracts with the major record 16 labels, but no additional communications. Merrick Decl., ~8. Plaintiffs are entitled to complete 17 discovery on this issue before the Court makes a dispositive ruling. 18 Moreover, Apple has yet to produce contracts and negotiations with content providers other 19 than the major labels (i.e., Sony, BMG, EMI, Universal and Warner), which documents were also 20 requested by Plaintiffs in December of2009. Roach Decl., ~19. Apple claims that these contracts 21 and communications are irrelevant because Apple had a contractual obligation to the other labels to 22 update FairPlay. Apple Reply at 5. However, Apple issued updates to FairPlay for all music sold on 23 iTS and not just the music sold by Sony, BMG, EMI, Universal and Warner. If the contracts and 24 communications with the other content providers reveal that Apple was not required to have any 25 DRM on the music files sold by the content providers in the first place, and thus was not required to 26 update the DRM, then this would rebut Apple's contention that it was required to update the DRM 27 on all music. See Roach Decl., ~19. Accordingly, Plaintiffs are entitled to this information. 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -5- 1 2 3 Apple's Motion at 11. To 4 rebut this contention, Plaintiffs need discovery concerning the different technical aspects of the 5 6 7 8 9 10 Thus, discovery on all of these facets is necessary. 11 Plaintiffs sought this discovery in April, 2009 in conjunction with their Rule 30(b)(6) 12 document requests. See Roach Decl., ~1 O. 13 14 Accordingly, Plaintiffs 15 have requested, pursuant to their Rule 30(b)( 6) document requests, information concerning Apple's 16 understanding of how Harmony works technically; specifications, design documents and diagrams 17 regarding those changes in FairPlay that broke Harmony; documents that describe the relationship 18 between iTunes software updates and iPod firmware updates; documents that indicate how certain of 19 Apple's observations concerning Harmony affected the FairPlay redesign; source code related to 20 iTunes software updates 4.6 and 4.7; and source code related to iTunes software updates (other than 21 4.6 and 4.7) and iPod firmware updates that addressed "hacks." See Merrick Decl., ~7, id., Ex. C; 22 see also Roach Decl., ~~4, 26. 23 The parties met and conferred on these requests on April 22, 2010. Merrick Decl., ~7. 24 Apple's counsel stated that it may be willing to produce some technical information related to the 25 FairPlay redesign in iTunes 4.7. Id. Plaintiffs requested a greater scope of documents and have 26 proposed this production to Apple. Id. If Apple does not agree to production, Plaintiffs will need to 27 move to compel as this information is necessary to adequately oppose Apple's Motion. 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -6- 1 2 3 4 5 6 7 8 9 10 11 12 13 Nonetheless, Plaintiffs are entitled to this discovery before the Court can decide whether a 14 factual dispute exists. 15 D. Apple's Claim that the Updates Were Product Improvements 16 Apple also asserts that the updates were product improvements. Apple's Motion at 13-14; 17 Apple's Reply at 7. In support, Apple contends that the updates helped ensure that Apple remained 18 in compliance with its contractual obligations to the labels. Id.; Apple's Motion at 13. First, this 19 contention presumes that the updates were only issued in response to the record labels' requests to 20 stop "hacks." As Plaintiffs' evidence in their Opposition indicates, the record labels did not require 21 Apple to issue updates to address Harmony. See Opposition at 11. Thus, if the updates targeted 22 Harmony, at least in part, then Apple's contention that the updates were product improvements will 23 be rebutted. Accordingly, Plaintiffs are entitled to discovery on this issue sought in conjunction with 24 Plaintiffs' Rule 30(b)(6) document requests. See Roach Decl., ~26. 25 Additionally, as discussed above and in Plaintiffs' Rule 56(f) motion, Plaintiffs sought 26 production of Apple's communications and contracts with the record labels in December of2009. 27 See Roach Decl., ~~18, 19. If this discovery reveals that the record labels did not communicate to 28 Apple that other relevant software updates were required, then Apple's contention will be rebutted. 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -7- 1 Moreover, Apple has not provided any evidence to support its contention that Harmony made 2 FairPlay less secure. See Opposition at 12. If discovery concerning the technical aspects of 3 Harmony and FairPlay contradict Apple's contentions then Apple's Motion must be denied. Ąd. 4 Plaintiffs are entitled to this discovery - requested in conjunction with their Rule 30(b)( 6) requests- 5 before the Court can determine if a factual dispute exists. See Merrick Decl., ~7. 6 7 E. Apple's Claim that It Would Have Had to Disclose Secret and Potentially Harmful Information to RealNetworks Finally, Apple claims that Harmony could only continue to work if Apple disclosed highly 8 confidential information to RealNetworks that was potentially harmful to Apple. Apple's Motion at 9 14; Apple's Reply at 8. As Plaintiffs previously stated, discovery concerning Apple's business 10 relationships with Hewlett Packard and Motorola are necessary because such discovery will reveal 11 information concerning the type of information Apple shared with competitors and the level of 12 cooperation required. See Opposition at 13; Roach Decl., ~~20, 26. 13 Indeed, Apple's belated production of documents responsive to Plaintiffs' December 2009 14 requests, has revealed additional information that supports Plaintiffs' position. For example, Apple's 15 contracts with Motorola, produced by Apple just a few weeks ago, on April 8, 2010, suggest two 16 things: (l) Apple was engaged in cooperative agreements with competitors that encouraged use of 17 Apple's products; and (2) the level of cooperation Apple claims would be necessary to keep 18 RealNetworks going is grossly overstated. See Merrick Decl., ~9. 19 20 21 22 Accordingly, Plaintiffs are entitled to full 23 discovery on this issue. 24 IV. CONCLUSION 25 For the reasons stated above and in Plaintiffs' request for Rule 56(f) discovery and 26 supporting declaration, if the Court is inclined to hear Apple's Motion for summary judgment at this 27 28 520779 1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) -8- 1 time, then the Court should permit Plaintiffs to obtain additional discovery pursuant to Rule 56(f) in 2 order to adequately oppose Apple's Motion. 3 DATED: April 26, 2010 4 5 Respectfully submitted, 6 7 8 ROBBINS GELLER RUDMAN DOWDLLP & JOHN 1. STOIA, JR. BONNY E. SWEENEY THOMAS R. MERRICK PAULA M. ROACH 9 10 s/ Bonny E. Sweeney BONNY E. SWEENEY 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: 619/231-1058 11 619/231-7423 (fax) 12 13 14 15 THE KA TRIEL LAW FIRM ROY A. KA TRIEL 1101 30th Street, N.W., Suite 500 Washington, DC 20007 Telephone: 202/625-4342 202/330-5593 (fax) 16 17 18 Co-Lead Counsel for Plaintiffs BONNETT, FAIRBOURN, FRIEDMAN & BALINT, P.e. 19 20 21 ANDREW S. FRIEDMAN FRANCIS 1. BALINT, JR. ELAINE A. RYAN TODD D. CARPENTER 2901 N. Central Avenue, Suite 1000 Phoenix, AZ 85012 Telephone: 602/274-1100 602/274-1199 (fax) BRAUN LAW GROUP, P.e. 22 23 MICHAEL D. BRAUN 24 25 12304 Santa Monica Blvd., Suite 109 Los Angeles, CA 90025 Telephone: 310/442-7755 310/442-7756 (fax) 26 27 28 MURRA Y, FRANK & SAILER LLP BRIAN P. MURRAY JACQUELINE SAILER 275 Madison Avenue, Suite 801 New York, NY 10016 -9- 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) 1 Telephone: 212/682-1818 212/682-1892 (fax) 2 3 GLANCY BINKOW & GOLDBERG LLP MICHAEL GOLDBERG 1801 Avenue of the Stars, Suite 311 4 5 Los Angeles, CA 90067 Telephone: 310/201-9150 310/201-9160 (fax) 6 7 8 Additional Counsel for Plaintiffs 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 520779_1 PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL) - 10- CERTIFICATE OF SERVICE I hereby certify that on April 26, 2010, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the attached Manual Notice List. I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on April 26, 2010. s/ Bonny E. Sweeney BONNY E. SWEENEY ROBBINS GELLER RUDMAN &DOWDLLP 655 West Broadway, Suite 1900 San Diego, CA 92101-3301 Telephone: 619/231-1058 619/231-7423 (fax) E-mail: firstname.lastname@example.org CAND-ECF- Page 1 of 2 Mailing Information for a Case 5:05-cv-00037-JW Electronic Mail Notice List The following are those who are currently on the list to receive e-mail notices for this case. . Francis Joseph Balint, Jr email@example.com . Michael D Braun firstname.lastname@example.org . Michael D. Braun email@example.com,firstname.lastname@example.org . Todd David Carpenter email@example.com . Andrew S. Friedman rcreech @bffb.com,afriedman @bffb.com . Alreen Haeggquist firstname.lastname@example.org,email@example.com . Roy A. Katriel firstname.lastname@example.org,email@example.com . Thomas J. Kennedy firstname.lastname@example.org . 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