"The Apple iPod iTunes Anti-Trust Litigation"

Filing 366

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)

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(Additional counsel appear on signature page.)
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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
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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
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PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL)

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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
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PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL)

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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
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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

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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.
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520779_1

PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO RULE 56(f) - C-05-00037-JW(HRL)

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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
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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)

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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: [phone]

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: [phone]

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: [phone]

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: [phone]

310/442-7756 (fax)

26 27
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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: [phone]

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: [phone]

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

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27
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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: [phone]

619/231-7423 (fax)

E-mail:

[e-mail]

CAND-ECF-

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