Motorola Mobility, Inc. v. Apple, Inc.

Filing 224

MOTION to Compel Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22) by Apple, Inc.. Responses due by 2/16/2012 (Attachments: # 1 Affidavit Declaration of Jill Ho, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C-SEALED, # 5 Exhibit D-SEALED, # 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, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U-SEALED, # 23 Exhibit V-SEALED, # 24 Exhibit W-SEALED, # 25 Exhibit X-SEALED, # 26 Exhibit Y-SEALED, # 27 Exhibit Z-SEALED, # 28 Exhibit AA-SEALED, # 29 Exhibit BB-SEALED, # 30 Exhibit CC-SEALED, # 31 Exhibit DD-SEALED, # 32 Text of Proposed Order)(Pace, Christopher)

EXHIBIT B

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.

APPLE'S THIRD SET OF INTERROGATORIES
TO MOTOROLA MOBILITY AND MOTOROLA (NOS. 16-22)

Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant and
Counterclaim Plaintiff Apple Inc. ("Apple") requests that Plaintiff and Counterclaim
Defendant Motorola Mobility, Inc. ("Motorola Mobility") and Counterclaim Defendant
Motorola, Inc. ("Motorola") (collectively, the "Counterclaim Defendants") answer
separately, fully, in writing, and under oath the following interrogatories within thirty (30)
days after service hereof. Pursuant to Federal Rule of Civil Procedure 26(e), these

interrogatories are continuing in nature and therefore require Counterclaim Defendants to
furnish supplemental answers whenever they obtain different or additional knowledge,
information, or beliefs relative to these interrogatories.

DEFINITIONS
The definitions in Apple Inc.'s First Set ofInterrogatories (Nos. 1-10) and Second Set
ofInterrogatories (Nos. 11-15) are incorporated by reference.

INSTRUCTIONS
The instructions in Apple Inc.' s First Set of Interrogatories (Nos. 1-10) are
incorporated by reference.

INTERROGATORIES
INTERROGATORY NO. 16:
For each Motorola Accused Mobile Device, describe in detail how to lock and unlock
the touchscreen, including without limitation (i) the conditions under which the touchscreen
becomes locked; (ii) the way(s) in which a user may unlock a locked touchscreen; (iii) any
graphical elements presented by the user interface when the touchscreen is locked; (iv)
whether such graphical element(s) are interactive and, if so, how a user may interact with
such graphical element(s); and (v) an identification by file name(s) and directory location(s)
of the software, firmware, or other source code used to implement any of the aforementioned
locking and unlocking functionalities.

INTERROGATORY NO. 17:
For each Motorola Accused Mobile Device, identify with specificity, including by
file name(s) and directory location(s), the software, firmware, or other source code that
(i) detects the addition or removal of additional devices or peripherals; (ii) detects the

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addition or removal of additional display devices; or (iii) allocates video output between the
built-in display and additional display devices, including but not limited to the external
display service and any related libraries (e.g., extdispservice, iextdispservice, and
nativehdmiapis) as well as any software drivers for any HDMI transmitters provided by third
parties.

INTERROGATORY NO. 18:
For each Motorola Accused Mobile Device, identify with specificity, including by
file name(s) and directory location(s), the software, firmware, or other source code that
implements the Webtop and (HD) Entertainment Center applications.

INTERROGATORY NO. 19:
Identify each cable service provider that is or has been a party to a license, service, or
other agreement with Motorola and provide a narrative description of the relationship
between Motorola and each such cable service provider.

INTERROGATORY NO. 20:
Identify with specificity, each and every Motorola set-top box manufactured, used,
distributed, sold, offered for sale, or imported with an interactive program guide, by or on
behalf of Motorola, including without limitation the model name, trade name, marketing
name, internal name, type, description, design number, catalog number, and all other names
and/or designations used to identify such Motorola set-top boxes, and including any
associated hardware, such as remote control devices.

INTERROGATORY NO. 21:
For each Motorola set-top box and associated hardware identified in response to
Interrogatory No. 20 above, identify with specificity each entity who is or has been involved

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with the research, engineering, design, development, implementation, revision, support, or
provision of any version of the interactive program guides running on such Motorola set-top
boxes, including without limitation the name and location of each such entity, its relationship
with Motorola, and a narrative description of its involvement.

INTERROGATORY NO. 22:
For each Motorola set-top box and associated hardware identified in response to
Interrogatory No. 20 above, identify with specificity, including as appropriate the internal
and external part name and number, model name or number, manufacturer, source, supplier,
file name(s), directory name(s), and any version number, each microchip, microprocessor,
microcontroller, chipset, software, firmware, source code or other component that
implements, supports, or provides interactive program guide functions, including without
limitation mechanisms for obtaining television programming information from a source
signal, television programming listing displays, picture-in-picture displays, program
reminder mechanisms, program marking mechanisms, and recording mechanisms.

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Dated: November 14, 2011

Respectfully submitted,

lsi Jill J Ho
Christopher R. 1. Pace
[e-mail]
Edward Soto
edwart. [e-mail]
WElL, GOTSHAL & MANGES LLP
1395 Brickell Avenue, Suite 1200
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]

Attorneys for Apple Inc.

Of Counsel:
Jill 1. Ho
[e-mail]
WElL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

Robert T. Haslam
[e-mail]
COVINGTON & BURLING LLP
333 Twin Dolphon Drive
Suite 700
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

Mark G. Davis
mark. davi [e-mail]
WElL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Matthew D. Powers
[e-mail]
Steven S. Cherensky
Steven. [e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway, Suite 401
Redwood Shores, CA 94065
Telephone: [phone]

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Robert D. Fram
[e-mail]
Christine S. Haskett
[e-mail]
Samuel F. Ernst
[e-mail]
Winslow B. Taub
[e-mail]
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: (415) 591-609

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on November 14,2011, I served the foregoing
document via electronic mail on all counsel of record identified on the attached Service List.

lsi Jill Ho
Jill Ho

SERVICE LIST
Motorola Mobility, Inc. versus Apple Inc.
Case No. 1:10cv023580-Civ-UU
United States District Court, Southern District of Florida

Edward M. Mullins
Fla. Bar No. 863920
[e-mail]
& GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
ASTIGARRAGA DAVIS MULLINS

OfCounsel:
Charles K. Verhoeven
[e-mail]
David A. Perlson
davidperl [e-mail]
Anthony Pastor
[e-mail]
& SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 93111
[phone]
QUINN EMANUEL URQUHART

[e-mail]

Attorneys for Motorola Mobility, Inc. andMotorola, Inc.
Electronically served via email

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