Motorola Mobility, Inc. v. Apple, Inc.

Filing 129

MOTION to Bring Electronic Equipment into the courtroom for use during the October 6, 2011 and October 17, 2011 hearings by Apple, Inc.. Responses due by 10/21/2011 (Attachments: # 1 Text of Proposed Order)(Pace, Christopher) Modified on 10/4/2011 (ls).

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-UU

MOTOROLA MOBILITY, INC.,
Plaintiff,

JURY TRIAL DEMANDED

v.
APPLE INC.,
Defendant.
APPLE INC.,
Counterclaim Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

MOTION FOR LEAVE TO BRING EQUIPMENT INTO COURTROOM FOR
USE DURING THE OCTOBER 6, 2011 AND OCTOBER 17, 2011 HEARINGS
Defendant and Counterclaim-Plaintiff Apple, Inc. (“Apple”) respectfully
move this Court for entry of an order permitting counsel to bring into Court certain
computer and technological devices for use during the tutorial and Markman hearings,
scheduled for October 6, 2011 and October 17, 2011, respectively. In support of the
instant Motion, Apple states:
1.

Apple intends to conduct presentations at the October 6, 2011 and October

17, 2011 hearings that rely on the use of computer technology and other technological

equipment.

To accomplish these objectives, Apple will require a several laptop

computers and their external drives, two flash drives, and additional audio/video
presentation equipment, consisting of: cables, power strips, extension cords, presentation
clickers and laser pointers. Apple’s presentations may also include certain demonstrative
devices, including: iPhone 4, iPad, iPad 2, PF-1500 pager, Bravo pager, PageWriter
2000x pager, P935 TimePort pager, an exemplary Motorola set-top box and remote
control, Droid, Droid 2, Droid 2 Global, Droid X, and Xoom tablet.
2.

A number of out-of-state attorneys will attend and/ or participate in the

October hearings. Attorneys not admitted in Florida wish to bring their personal laptops,
blackberries, iPhones and/or other personal phones for email access. Apple seeks the
Court’s permission also to bring these items into the courtroom.
3.

Apple understands that the aforementioned items will be subject to

examination for security purposes as are all other materials brought into the courthouse.
4.

Apple also requests that it be allowed two (2) hours on October 5, 2011

between 2:00-5:00 p.m. (or any other time convenient for the Court) to check and set this
equipment up in the courtroom for use during the October 6, 2011 hearing and two (2)
hours on October 14, 2011 between 2:00-5:00 p.m. (or any other time convenient for the
Court) to check and set this equipment up for the October 17, 2011 hearing.
CONCLUSION
WHEREFORE Apple respectfully requests that this Court enter an order
granting this joint motion for leave to bring the aforementioned equipment into the
courtroom for use during the October 6, 2011 and October 17, 2011 hearings and for
leave to set up its equipment on October 5, 2011 and October 14, 2011 between 2:00-

2

5:00 p.m. (or any other time convenient for the Court). A proposed order is attached
hereto as Exhibit “A.”
Dated: October 4, 2011

Respectfully submitted,
_/s/ Christopher R. J. Pace ____________
Christopher R. J. Pace
[e-mail]
Edward Soto
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1395 Brickell Avenue, Suite 1200
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Attorneys for Apple Inc.

Of Counsel:
Matthew D. Powers
[e-mail]
Steven Cherensky
[e-mail]
Tensegrity Law Group LLP
201 Redwood Shores Parkway, Suite 400
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: 650-802-6001
Jill J. Ho
[e-mail]
WEIL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway, Suite 500
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
Mark G. Davis
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]

3

Robert T. Haslam
[e-mail]
COVINGTON & BURLING LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
Robert D. Fram
[e-mail]
Christine Saunders Haskett
[e-mail]
Samuel F. Ernst
[e-mail]
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

CERTIFICATE OF SERVICE
I hereby certify that on October 4, 2011, I filed the foregoing document with the
Clerk of the Court. I also certify that the foregoing document is being served this day on
all counsel of record identified on the attached Service List via email and CM/ECF.

/s/ Christopher R. J. Pace
Christopher R.J. Pace (Fla. Bar No. 0721166)

4

SERVICE LIST
Case No. 1:10cv023580-Civ-UU
Edward M. Mullins
Fla. Bar No. 863920
[e-mail]
ASTIGARRAGA DAVIS MULLINS & GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Attorneys for Motorola Mobility, Inc.
Electronically served via CM/ECF and via email
Of Counsel:
Charles K. Verhoeven
QUINN EMANUEL URQUHART & SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 93111
[phone]
Edward J. DeFranco
QUINN EMANUEL URQUHART & SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
[phone]
David A. Nelson
QUINN EMANUEL URQUHART & SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
[phone]
[e-mail]
Attorneys for Motorola Mobility, Inc.
Electronically served via email

5