Motorola Mobility, Inc. v. Apple, Inc.

Filing 205

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)

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.

MOTOROLA MOBILITY, INC. AND MOTOROLA, INC.'S
FIRST SET OF REQUESTS FOR PRODUCTION TO APPLE INC. (NOS. 1-88)
Pursuant to Federal Rules of Civil Procedure 26 and 34, Plaintiff/Counterclaim
Defendant Motorola Mobility, Inc. ("Mobility") and Counterclaim Defendant Motorola, Inc.
("Motorola") (collectively, "Counterclaim-Defendants") request that Defendant Apple Inc.
respond fully and in writing to this First Set of Requests for the Production of Documents and
Things (“Requests”) and produce the documents and things requested herein in accordance with
the following instructions and definitions at the offices of Quinn Emanuel Urquhart & Sullivan,
LLP, 51 Madison Avenue, 22nd Floor New York, NY 10010 within thirty (30) days from the
date of service of these Requests.

REQUEST FOR PRODUCTION NO. 14.
All communications and correspondence between Apple and the named inventors of the
Apple Asserted Patents.
REQUEST FOR PRODUCTION NO. 15.
All documents concerning the scope, validity, or enforceability of any of the Apple
Asserted Patents.
REQUEST FOR PRODUCTION NO. 16.
All documents concerning any secondary consideration or other objective evidence of
non-obviousness of the Apple Asserted Claims, including commercial success, long-felt need,
commercial acquiescence, expressions of skepticism, copying, teaching away, failed attempts by
others, or simultaneous development and any nexus between such secondary consideration or
other objective evidence of non-obviousness and the Apple Asserted Claims.
REQUEST FOR PRODUCTION NO. 17.
All documents and things concerning Apple's contention as to what constituted the level
of skill of a person of ordinary skill in the art to which the subject matter of each of the Apple
Asserted Patents pertains, at the time of filing with the U.S. Patent and Trademark Office the
original application resulting in each Apple Asserted Patent.
REQUEST FOR PRODUCTION NO. 18.
All documents and things concerning any Prior Art relating to the Apple Asserted
Patents, including any document or thing identified as potential Prior Art to Apple by any third
party.

7

Dated: December 29, 2010

Respectfully submitted,
/s/ Mark D. Baker____________
Edward J. DeFranco
Alexander Rudis
Mark D. Baker
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010
Tel.: [phone] / Fax: [phone]
Charles K. Verhoeven
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Tel.: [phone] / Fax: [phone]
David A. Nelson
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
Tel.: [phone] / Fax: [phone]
Edward M. Mullins
Astigarraga Davis Mullins & Grossman, P.A.
701 Brickell Avenue, 16th Floor
Miami, Florida 33131
Tel.: [phone] / Fax: [phone]
Attorneys for Motorola Mobility, Inc. and
Motorola, Inc.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 29, 2010, I served the following document via
electronic mail on all counsel of record identified on the attached Service List.

___/s/ Mark Baker______
Mark Baker

SERVICE LIST
Motorola Mobility, Inc. versus Apple Inc.
Case No. 1:10cv023580-Civ-UU
United States District Court, Southern District of Florida
Christopher R.J. Pace
[e-mail]
Weil, Gotshal & Manges LLP
1395 Brickell Avenue, Suite 1200
Miami, Florida 33131
Tel.: [phone]
Matthew D. Powers
[e-mail]
Steven S. Cherensky
[e-mail]
Jill J. Ho
[e-mail]
Weil, Gotshal & Manges, LLP
201 Redwood Shores Parkway
Redwood Shores, California 94065-1134
Telephone: [phone]
Mark G. Davis
[e-mail]
Weil, Gotshal & Manges LLP
1300 Eye Street, N.W., Suite 900
Telephone: [phone]
Patricia Young
[e-mail]
Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, New York 10153
Telephone: [phone]
[e-mail]
Attorneys for Apple, Inc.
Electronically served via email