Motorola Mobility, Inc. v. Apple, Inc.
Plaintiff's MOTION to Amend/Correct 88 Order on Motion for Miscellaneous Relief the Procedural Schedule to Serve Supplemental Invalidity Contentions, Accompanying Memorandum of Law in Support and Declaration of Cathleen Garrigan in Support Thereof by Motorola Mobility, Inc.. Responses due by 1/6/2012 (Attachments: # 1 Declaration of Cathleen Garrigan, # 2 Exhibit A to Declaration of Cathleen Garrigan, # 3 Exhibit B to Declaration of Cathleen Garrigan, # 4 Exhibit C to Declaration of Cathleen Garrigan, # 5 Exhibit D to Declaration of Cathleen Garrigan, # 6 Exhibit E to Declaration of Cathleen Garrigan, # 7 Exhibit F to Declaration of Cathleen Garrigan, # 8 Exhibit G to Declaration of Cathleen Garrigan, # 9 Exhibit H to Declaration of Cathleen Garrigan, # 10 Exhibit I to Declaration of Cathleen Garrigan, # 11 Exhibit J to Declaration of Cathleen Garrigan, # 12 Exhibit K to Declaration of Cathleen Garrigan, # 13 Exhibit L to Declaration of Cathleen Garrigan, # 14 Exhibit M to Declaration of Cathleen Garrigan, # 15 Exhibit N to Declaration of Cathleen Garrigan)(Mullins, Edward)
Ho, Jill [email@example.com]
Wednesday, November 30, 2011 12:45 PM
John Duchemin; AppleCov; Apple Moto Weil
RE: Motorola v. Apple (SDFL): Supplemental Preliminary Invalidity Contentions
Our position, as we've stated repeatedly, is that unless and until the Court rules otherwise, the current deadlines
concerning contentions govern. Please withdraw your supplemental invalidity contentions.
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
+1 650 802 3163 Direct
+1 650 802 3100 Fax
From: John Duchemin [mailto:firstname.lastname@example.org]
Sent: Wednesday, November 30, 2011 11:48 AM
To: AppleCov; Apple Moto Weil
Subject: Motorola v. Apple (SDFL): Supplemental Preliminary Invalidity Contentions
Attached are Motorola’s Supplemental Preliminary Invalidity Contentions including Supplemental Exhibits D, E and F.
The supplemental invalidity contentions are served in response to ongoing discovery, including but not limited to
Apple’s late production of prior art from its litigation against Samsung in the Netherlands and positions that Apple first
revealed at the technical tutorial and Markman hearings regarding the alleged inventions disclosed in the ‘116 and ‘646
Given Apple’s position regarding infringement contentions, please let us know by close of business tomorrow if Apple
contends that, despite the fact that its own June 20 invalidity contentions served after the Court’s June 1 Order reserved
Apple’s right to supplement its invalidity contentions in light of the continuing discovery process, the June 20 were
intended to be “final contentions,” or if it intends to seek to strike these supplemental contentions.
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650.801.5000 Main Office Number
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