Motorola Mobility, Inc. v. Apple, Inc.
Filing
211
MOTION to Amend/Correct the Procedural Schedule to Serve Supplemental Invalidity Contentions and Accompanying Memorandum of Law in Support by Motorola Mobility, Inc.. Responses due by 1/17/2012 (Attachments: # 1 Affidavit Cathleen Garrigan, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N)(Mullins, Edward)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-RNS
MOTOROLA MOBILITY, INC.,
Plaintiff,
v.
JURY TRIAL DEMANDED
APPLE INC.,
Defendant.
APPLE INC.,
Counterclaim Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.
MOTOROLA'S MOTION TO AMEND THE PROCEDURAL SCHEDULE
TO SERVE SUPPLEMENTAL INVALIDITY CONTENTIONS
AND ACCOMPANYING MEMORANDUM OF LAW IN SUPPORT
Plaintiff and Counterclaim Defendants Motorola Mobility, Inc. and Motorola Solutions,
Inc. (f/k/a/ Motorola, Inc.) (collectively "Motorola") request that the Court grant Motorola leave
to serve supplemental invalidity contentions with respect to certain of the patents asserted in the
Counterclaim brought by Defendant and Counterclaim Plaintiff Apple, Inc. ("Apple"). Good
cause exists because Motorola has been diligent in seeking pertinent discovery and notifying
Apple of its invalidity contentions. Supplementation is also necessary because of Apple's late
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1
production of documents and Apple's new positions with respect to the scope of its asserted
patents in its Counterclaim.
Apple seeks to prevent Motorola for supplementing its invalidity contentions despite the
fact that Apple failed to timely produce highly relevant "prior art" (that is, products or
publications available prior to the claimed "invention" in Apple's patents which could invalidate
those patents). In Netherlands litigation involving Apple, the court found that the prior art
asserted in that case potentially invalidates the European equivalent of one of the patents Apple
is asserting in this suit, U.S. Patent No. 7,657,849 B2 ("the '849 patent"). See Ex. A ¶¶ 4.45-4.48
(Netherlands court order discussing invalidity of the European counterpart to Apple’s asserted
'849 patent in light of the Neonode reference that was prior to the invention).1 Yet, Apple did
not produce this prior art until after Motorola demanded it by letter and now Apple seeks to
prevent Motorola from using this highly relevant prior art in its invalidity contentions. Apple
cannot possibly claim prejudice from prior art it was already aware of from another litigation, but
which it did not produce prior to the parties' exchange of invalidity contentions.2
Motorola also has good cause for supplementation in response to Apple's new and
expansive interpretation of Apple’s U.S. Patent Nos. 6,282,646 B1 ("the '646 patent") and
7,380,116 B2 ("the '116 patent"). At the technical tutorial in this matter, Apple asserted for the
first time that its '646 and '116 patents claim "Plug and Play," which refers to computer devices
that can be configured with no user intervention (the technical tutorial was held in October 2011,
1
"Ex. __" refers to the exhibits attached to the declaration of Cathleen Garrigan filed
concurrently with this motion.
2
Apple stated during the December 23, 2011 meet and confer that it was unaware of the
Netherlands prior art until August 3, 2011. Garrigan Decl. ¶ 18. Regardless of when Apple first
became aware of the prior art, it was not produced until after the exchange of invalidity
contentions, pursuant to Motorola’s demand letter, and therefore good cause exists to allow
supplementation.
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2
after the June 2011 exchange of invalidity contentions). Apple did not invent Plug and Play,
which was, for example, present in the Windows® 95 operating system. The Windows® 95
operating system was released three years before the priority date of the '646 and '116 patents
and thus constitutes potential invalidating prior art to Apple’s patents. In any event, Apple
improperly seeks to expand the scope of its '646 and '116 patents beyond the language of the
claims, and Motorola should be granted leave to respond to that expansion with supplemental
invalidity contentions.
If supplementation is not permitted in these circumstances, a party like Apple that
withholds theories until after the contention deadline passes will be rewarded by its tactics, as the
other party will be precluded from responding. Such gamesmanship should not be encouraged.
This is especially true for an issue such as the validity of patents, which has ramifications beyond
this litigation.
I.
BACKGROUND
A.
Procedural History
On April 25, 2011, the parties submitted a joint proposal to the Court requesting entry of
a scheduling order detailing the deadlines for preliminary contentions. (D.E. 77.) That proposal
included a June 20, 2011 deadline for preliminary invalidity contentions. (Id. at 1.) On June 1,
2011, the Court entered the parties' proposed scheduling order. (D.E. 88.)
In accordance with the scheduling order, the parties exchanged preliminary invalidity
contentions on June 20, 2011. Motorola served nearly two thousand pages of charts detailing
element-by-element the invalidity of Apple's six asserted patents. Both parties' preliminary
invalidity contentions explicitly stated that they were preliminary and reserved the right to
supplement in light of continued discovery. See. e.g. Ex. B at 7 (Apple's Invalidity Contentions
stating, "Discovery is ongoing, and Apple’s prior art investigation and third party discovery are
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therefore not yet complete. Apple reserves the right to present additional items of prior art under
35 U.S.C. § 102(a), (b), (e), and/or (g), and/or § 103 located during the course of discovery or
further investigation."); Ex. C at 1 (Motorola's Invalidity Contentions stating, "These invalidity
contentions are preliminary and are based on Motorola's current knowledge, understanding, and
belief as to the facts and information available as of the date of these contentions. Motorola has
not yet completed its investigation, discovery, or analysis of information related to this action,
and additional discovery may require Motorola to supplement or amend its invalidity
contentions.").3
B.
Apple's Production of '849 Prior Art After the Deadline for Invalidity
Contentions
Apple is engaged in litigation across the globe with various technology companies that
use the Android platform in their smartphones and tablet computers. Knowing that Apple is
engaged in many litigations involving the same or related patents, Motorola requested prior art
produced or identified in other litigations in the document requests it served on Apple. See e.g.
Ex. D at 7, Request for Production No. 18. Specifically, on December 29, 2010, Motorola
served a written request for the production of, "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." Id.
3
Apple has taken the position that the June 20 invalidity contentions were ―final‖ based
upon the fact that the word ―preliminary‖ was not included in the deadline. Apple previously
took a similar position before Judge Ungaro with respect to infringement contentions. (D.E. 197
at 1-2.) Ultimately, Apple was successful in arguing before Judge Ungaro that the infringement
contentions deadline was meant to be a final deadline. (D.E. 198.) While Motorola believes that
Apple’s positions are inconsistent with the parties’ intentions when submitting the agreed
scheduling order (as evidenced by both parties’ reservation of rights in their exchanged
infringement and invalidity contentions (D.E. 185 at 4-5) and Apple's position in the parties' copending litigation in Illinois (formerly Wisconsin) (D.E. 185 at 7-10)), Motorola seeks leave to
serve supplemental invalidity contentions given Judge Ungaro's prior order.
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On August 24, 2011, a Netherlands court issued an order in Apple's litigation against
Samsung Electronics denying Apple's requested relief with respect to EP 1 964 022 ("EP 022")
because "there is a reasonable chance that EP 022 . . . will be considered invalid" after a full trial
on the merits. Ex. A at ¶¶ 4.45-4.48. EP 022 is the European counterpart to Apple's '849 patent
that it is asserting against Motorola in this litigation. This ruling, of course, was entered months
after the "deadline" for invalidity contentions in this matter.
On September 1, 2011, Motorola sent a letter to Apple demanding the production of prior
art cited by Samsung in the Netherlands litigation along with litigation documents concerning EP
022. Ex. E. In its letter, Motorola noted that the requested prior art and other documents were
responsive to Motorola's discovery requests served nearly nine months earlier and should have
been produced in accordance with Apple's ongoing discovery obligations. Apple produced the
documents from the Netherlands litigation on September 13, 2011. Ex. F.
Upon reviewing the documents, Motorola discovered that they contained prior art that
had never been produced by Apple. Garrigan Decl. at ¶ 15. Accordingly, Motorola began
supplementing its invalidity contentions and pursuing third-party discovery related to the
recently-produced prior art.
C.
Apple's Change in Position Regarding the Scope of the '646 and '116 Patents
On October 6, 2011, the Court held a technical tutorial hearing. (See D.E. 135.) At that
hearing, Apple made a presentation with respect to the technology allegedly embodied in its
patents. With respect to the '646 and '116 patents, Apple represented to the Court:
Now, the invention is – a colloquial expression that's often used is
"plug and play," which just means exactly what it sounds like.
You don't have to wait for it to be rebooted. The system will
recognize it automatically without being rebooted or restarted.
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Ex. G (Oct. 6, 2011, Hrg. Tr. 108:20-24 (emphasis added)). The technical tutorial was the first
time in this litigation that Apple contended that the '646 or '116 patent claimed "Plug and Play."
Apple made this assertion months after the ―deadline‖ for invalidity contentions.
However, "Plug and Play" was well-known in the art years before the May 8, 1998
priority date of the '646 and '116 patents. See e.g. Ex. H at 593 ("The Plug and Play capabilities
in Windows 95 have been widely described as key benefits to moving to Windows 95, because
of the related reduction in hardware and software support costs."). Thus, if the inventions
embodied in the '646 and '116 patents are ―Plug and Play,‖ the patents are invalid.
D.
Motorola's Supplemental Invalidity Contentions
Motorola served its supplemental invalidity contentions on Apple on November 30, 2011.
The amendments to the invalidity contentions fall into three main categories: (1) the lateproduced prior art from Netherlands litigation; (2) supplementation of previously-disclosed
references in response to Apple's representation that the '646 and '116 patents claim "Plug and
Play"; and (3) new references asserted in response to Apple's representation that the '646 and
'116 patents claim "Plug and Play."
On November 30, 2011, Apple stated its position that the deadline for preliminary
invalidity contentions was the deadline for final invalidity contentions and demanded that
Motorola withdraw its supplemental invalidity contentions. Ex. I. On December 2, 2011, the
parties met and conferred regarding Motorola's supplemental invalidity contentions, but no
agreement was reached. Garrigan Decl. at ¶ 16.
On December 6, 2011, the Court granted Apple's motion to strike Motorola's
supplemental infringement contentions, holding that Federal Rule of Civil Procedure 16 applied
and good cause must be shown. (D.E. 198.) In light of the Court's order, Motorola withdrew its
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supplemental invalidity contentions and is now seeking leave of court to serve supplemental
invalidity contentions after the June 20 deadline.
On December 19, 2011, Motorola filed its motion for leave to serve supplemental
invalidity contentions, inadvertently omitting its certificate of good faith conference. (D.E. 205.)
The Court denied Motorola’s motion based on the failure to attach the certificate of good faith
conference. (D.E. 210.) On December 20, the parties met and conferred for a second time
regarding Motorola’s supplemental invalidity contentions. Garrigan Decl. ¶ 17. During that
meet and confer Apple indicated it might be willing not to oppose Motorola’s motion with
respect to the prior art produced from the Netherlands litigation. Id. On December 23, 2011, the
parties conferred again. Id. at ¶ 18. During this meeting, Apple stated it would oppose
Motorola's motion in its entirety. Id.
E.
Motorola's Recent Discovery of Prior Art Patent 7,100,185
Motorola recently learned that U.S. Patent No. 7,100,185 ("the '185 patent") is prior art to
three of Apple's asserted patents: U.S. Patent Nos. 5,583,560; 5,621,456 and 5,594,509
(collectively "the Florin patents").4 The priority date of the face of the '560, '456 and '509
patents is June 22, 1993. (See D.E. 17 at Exs. F-H.) The priority date on the face of the '185
patent is September 9, 1993. Ex. J. Thus, facially, the '185 patent did not purport to be prior art
to the Florin patents. However, during its investigation of this case, Motorola learned that the
prosecution history of the '185 patent contains a reference to an inventor declaration swearing
that the priority date of the '185 patent is earlier than the priority date of Apple's '560 patent. Ex.
K. Accordingly, the '185 patent and any system embodying the '185 patent are prior art to the
4
The '185 patent was not contained in the supplemental invalidity contentions that
Motorola served on Apple and later withdrew. However, if the Court grants leave, Motorola will
include the '185 patent in its supplemental invalidity contentions.
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Florin patents. Despite its diligence investigating these multi-patent facts, Motorola did not
uncover the true priority date of the '185 patent until after the exchange of invalidity contentions.
II.
ARGUMENT
The district court has broad discretion in managing pretrial discovery matters. Klay v. All
Defendants, 425 F.3d 977, 982 (11th Cir. 2005) (citing Perez v. Miami-Dade Cty, 297 F.3d 1255,
1263 (11th Cir. 2002)). Although this Court has not adopted patent local rules, it has found other
courts' rules instructive for purposes of discovery. See Suncast Techs., LLC v. Patrician Prods.,
Inc., 2008 WL 179648 *13-14 (S.D. Fla. Jan. 17, 2008) (considering the local patent rules of
other courts in determining the sequence of discovery).5 Many patent local rules permit the
amendment of invalidity contentions for good cause. See e.g. Ex. L (Northern District of
California Local Patent Rule 3-6); Ex. M (Eastern District of Texas Local Patent Rule 3-6(b)).
In particular, Northern District of California Patent Local Rule 3-6(b) provides that good cause
for amending invalidity contentions includes "Recent discovery of material, prior art despite
earlier diligent search."
Good cause exists to permit Motorola to serve supplemental invalidity contentions
because, despite its diligence, Motorola only learned of the withheld, relevant prior art and
Apple's Plug and Play theory after the deadline for contentions. Additionally, Apple will not be
prejudiced because it was aware of the prior art in the Netherlands litigation, aware of the art
disclosed but not charted in Motorola's invalidity contentions, and no-doubt aware of its
improper Plug and Play interpretation of the '646 and '116 patents.
A.
Apple's Production of Prior Art After the Deadline for Invalidity
Contentions Provides Good Cause for Motorola to Supplement its Invalidity
Contentions
5
For its part, Apple too relied on other courts' patent local rules in its successful motion
to strike Motorola's supplemental infringement contentions. (D.E. 178 at 7.)
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Good cause exists to allow Motorola to serve its supplemental invalidity contentions
because through diligent discovery, Motorola learned of the Netherlands prior art and demanded
its production from Apple. Here, the court order in the Netherlands litigation did not issue until
August 2011, after the June 20, 2011 "deadline" for invalidity contentions.
Moreover, nearly a year ago, Motorola served document requests on Apple. Ex. D at 7,
Request for Production No. 18. In accordance with its ongoing discovery obligations, Apple
should have produced documents from the Netherlands litigation—but failed to do so.
Nonetheless, when Motorola became aware of the Netherlands court's order, it requested
production of documents from that litigation. Motorola's request, and Apple's belated
production, revealed prior art that had never previously been produced or disclosed by Apple
despite its ongoing discovery obligations. Thereafter, Motorola began analyzing the prior art and
supplemented its '849 invalidity contentions.
Because the evidence supporting Motorola's '849 supplemental invalidity contentions was
not produced until after the June 20, 2011 deadline, good cause exists to permit Motorola to
serve its supplemental invalidity contentions. See Poole v. City of Plantation, Fla., 2010 WL
1791905 at *33 (S.D. Fla. 2010) ("Good cause exists when evidence supporting the proposed
amendment would not have been discovered in the exercise of reasonable diligence until after the
amendment deadline had passed."). Indeed, despite Motorola's diligent conduct, it could not
have supplemented its invalidity contentions with respect to the '849 patent before the June 20
because the Netherlands order was not even issued until two months after the deadline.
B.
Apple's New Position That the '646 and '116 Patents Claim "Plug and Play"
Provides Good Cause for Motorola to Supplement its Invalidity Contentions
On October 6, 2011, for the first time in this litigation and after the exchange of invalidity
contentions, Apple represented to the Court at the technical tutorial that the '646 and '116 patents
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claim "Plug and Play."6 Ex. G. ‖Plug and Play‖ is a concept that refers to computer devices that
can be configured with no user intervention, see Ex. H at 592, and was a concept well known by
at least by 1995. For example, "Plug and Play [was] one of the key ways in which Windows 95
enhanced[d] ease of use." Ex. N at 6. Additionally, the concept of a ―Plug and Play‖ monitor
was known in 1995. See e.g. Ex. H at 593 ("Add a new monitor by plugging it in and turning it
on.").
Apple's new assertion seeks to vastly expand the scope of the purported invention of the
'646 and '116 patents and provides good cause to allow Motorola to serve its supplemental
invalidity contentions. In response to this expanded scope, Motorola has supplemented its '646
and '116 invalidity contentions in two ways. First, Motorola supplemented references that were
previously disclosed as providing background information. Second, Motorola added references
specifically directed at ―Plug and Play‖.7
Because Apple only disclosed its new, expansive interpretation of the '646 and '116
patents on October 6, 2011, good cause exists to permit Motorola's supplemental invalidity
contentions.
6
For its part, Apple expressly reserved the right to supplement its own invalidity
contentions in precisely this situation. See Ex. B at 5 ("Apple is currently unaware of the extent,
if any, to which Motorola will contend that limitations of the asserted claims are not disclosed in
the prior art identified by Apple. To the extent that such an issue arises, Apple reserves the right
to identify additional teachings in the same references or in other references that anticipate or
would have made the addition of the allegedly missing limitation to the disclosed device or
method obvious.").)
7
The Court's claim construction order further demonstrates that Apple's "Plug and Play"
assertion is wrong. For example, the Court construed "modifying the allocation of the display
space" as "changing the allotment of the global coordinate space available for use by display
devices." (D.E. 194 at 48-51.) The Court's construction for the '116 patent similarly construed
display space as global coordinate space. (Id. at 51-52.) Accordingly, the claims are directed to
one global coordinate space that is modified, not a ―Plug and Play‖ monitor. (Id. at 51.)
Nonetheless, Apple continues to pursue its baseless infringement claims against Motorola.
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C.
Motorola Only Learned Through Diligent Discovery that the '185 Patent is
Prior Art to the Florin Patents
Motorola has been diligent with respect to its invalidity contentions. Despite its
diligence, Motorola only recently learned that the '185 patent is prior art to the Florin patents and
could not have disclosed this reference earlier. Because the face of the '185 patent indicates that
the earliest date to which it can claim priority is September 9, 1993, it was not apparent that this
patent was prior art to the Florin patents, which were filed in June 1993. However, further
investigation revealed a sworn declaration that the invention claimed in the '185 patent was
invented before the alleged inventions claimed in the Florin patents. Because Motorola only
recently learned of the '185 patent's status as prior art, it could not have disclosed this reference
earlier.
D.
Apple will not be Prejudiced by Allowing Service of Motorola's
Supplemental Invalidity Contentions
Allowing Motorola to supplement its invalidity contentions will not prejudice Apple.
Not only has Apple long been aware of the prior art from the Netherlands litigation, but it has
already been defending against it. Accordingly, Apple cannot credibly claim prejudice from the
assertion of the Netherlands prior art in this litigation.
Additionally, prohibiting Motorola from supplementing its invalidity contentions will
unfairly prejudice Motorola's ability to defend itself and exclude highly relevant information
from this litigation. See Graphic Packaging Int'l, Inc. v. C.W. Zumbiel Co., 2011 WL 5357833
at *5 (M.D. Fla. Nov. 3, 2011) (allowing prior art disclosed for first time in expert report
because "exclusion of evidence is an extreme sanction, and that all cases, but especially patent
cases, are best decided on their merits."). The exclusion of evidence is generally an extreme
sanction for failing to obey a court order. See e.g. Fed. R. Civ. Pro. 37(b)(2)(ii). In this case,
prohibiting Motorola's supplemental invalidity contentions will punish Motorola for diligent
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discovery and Apple's belated production of documents. Motorola has not violated any court
order.
Nor, can Apple claim prejudice from the '646 and '116 supplemental invalidity
contentions. Many of these references were disclosed in the initial invalidity contentions and
merely expanded upon in the supplemental contentions. Such supplementation in light of
continued discovery is appropriate. Indeed, Apple itself previously asserted that
supplementation under these circumstances is proper. (D.E. 197 at 2 n.2 ("[T]he parties may use
discovery obtained at any point during the discovery period to support the infringement theories
included in their infringement contentions exchanged prior to the June 1 deadline.").) Moreover,
when Apple claimed for the first time at the technical tutorial that it invented "Plug and Play," it
should reasonably have expected Motorola to respond by asserting "Plug and Play" references as
potential prior art to these patents. If Apple is permitted to assert its new and expansive
interpretation of the '646 and '116 patents after the deadline for invalidity contentions, Motorola
will be prejudiced unless it is able to assert concomitant prior art.
Finally, Apple will not be prejudiced by the supplemental invalidity contentions related
to the '185 patent. Apple has ample time to take any additional discovery it might claim it now
requires as fact discovery does not close until March 16, 2012. Moreover, it is Motorola, not
Apple, that bears the burden of establishing these references as prior art, and Apple will have
more than two months to respond in any invalidity rebuttal expert report that Apple wishes to
serve, which is due under the current schedule on April 16, 2012.
III.
CONCLUSION
For all of the above reasons and good cause shown, Motorola respectfully requests the
court grant Motorola leave to serve its supplemental invalidity contentions.
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CERTIFICATE OF GOOD FAITH CONFERENCE
The undersigned certifies that the parties have met and conferred on several occasions in
a good faith to attempt to resolve their disputes regarding Motorola's supplemental invalidity
contentions. Those efforts have been unsuccessful, and the parties are at impasse. Motorola,
therefore, seeks the Court's leave to serve its supplemental invalidity contentions.
/s/ Cathleen Garrigan
Cathleen Garrigan
Respectfully submitted,
Dated: December 28, 2011
MOTOROLA SOLUTIONS, INC. (f/k/a
MOTOROLA, INC.) AND MOTOROLA
MOBILITY, INC.
By:
/s/ Edward M. Mullins
Edward M. Mullins
Charles K. Verhoeven
David Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Email: charlesverhoeven@quinnemanuel.com
davidperlson@quinnemanuel.com
Edward M. Mullins (863920)
Astigarraga Davis Mullins & Grossman, P.A.
701 Brickell Avenue, 16th Floor
Miami, Florida 33131
Phone: (305) 372-8282
Fax: (305) 372-8202
Email: emullins@astidavis.com
Edward J. DeFranco
Raymond Nimrod
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010
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Phone: (212) 849-7000
Fax: (212) 849-7100
Email: eddefranco@quinnemanuel.com
David A. Nelson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
500 West Madison St., Ste. 2450
Chicago, IL 60661
Telephone: (312) 705-7400
Facsimile: (312) 705-7401
Email: davenelson@quinnemanuel.com
Marshall Searcy
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Email: marshallsearcy@quinnemanuel.com
Attorneys for Plaintiff and CounterclaimDefendants Motorola Solutions, Inc. and
Motorola Mobility, Inc.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 28, 2011, I electronically filed the foregoing
document with the Clerk of the Court using the CM/ECF filing system. I also certify that the
foregoing document is being served this date on all counsel of record or pro se parties on the
attached Service List in the manner specified, either via transmission of Notices of Electronic
Filing generated by the CM/ECF system or; in some other authorized manner for those counsel
or parties who are not authorized to receive electronically Notices of Electronic Filing.
/s/ Douglas J. Giuliano
Douglas J. Giuliano
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SERVICE LIST
Motorola Mobility, Inc. versus Apple Inc.
Case No. 1:10cv023580-Civ-RNS
United States District Court, Southern District of Florida
Christopher R.J. Pace
christopher.pace@weil.com
Weil, Gotshal & Manges LLP
1395 Brickell Avenue, Suite 1200
Miami, Florida 33131
Tel.: (305) 577-3100 / Fax: (305) 374-7159
Attorneys for Apple, Inc.
Electronically served via e-mail
Of Counsel:
Matthew D. Powers
matthew.powers.@weil.com
Steven S. Cherensky
steven.cherensky@weil.com
WEIL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: (650) 802-3000
Facsimile: (650) 802-3100
Mark G. Davis
mark.davis@weil.com
WEIL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Telephone: (202) 682-7000
Facsimile: (202) 857-0940
Robert T. Haslam
rhaslam@cov.com
COVINGTON & BURLING LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone: (650) 632-4700
Facsimile: (650) 632-4800
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Robert D. Fram
framrd@cov.com
Christine Saunders Haskett
chaskett@cov.com
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone: (415) 591-6000
Facsimile: (415) 591-6091
Attorneys for Apple, Inc.
Electronically served via e-mail
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