Motorola Mobility, Inc. v. Apple, Inc.

Filing 225

MOTION to Compel Responses to Interrogatories Nos. 7 and 12 Regarding Products Embodying Motorola's Asserted Patents and Accompanying Memorandum of Law in Support by Apple, Inc.. Responses due by 2/16/2012 (Attachments: # 1 Affidavit Declaration of Elena Dimuzio, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Text of Proposed Order)(Pace, Christopher)

Download PDF
EXHIBIT 12 DiMuzio, Elena From: Sent: To: Cc: Subject: Ben Quarmby <> Friday, December 16, 2011 7:34 AM DiMuzio, Elena; David Perlson; Moto-Apple-SDFL 'Weil_TLG Apple Moto FL External'; AppleCov RE: Apple/Moto SDFL: Letter re Production of Embodying Products Dear Elena – I write in response to your letter dated December 14, 2011 regarding Apple’s request that Motorola identify any its products that embody the inventions claimed in the asserted Motorola patents. We agree that this topic was discussed during a recent meet and confer, but disagree with your characterization of Motorola’s representations. Motorola has consistently made clear that, to the extent it was to rely on any particular product or system as embodying its patents, it would identify such product or system to Apple. But there is no authority supporting your proposition that Motorola is under an obligation to conduct an exhaustive review of its many products to determine which, if any, embody any of the 6 asserted Motorola patents – and indeed your letter cites to none. We remain, however, willing to meet and confer on this matter. Please let us know whether you are available for a call early next week. Best regards, Ben Quarmby From: DiMuzio, Elena [] Sent: Wednesday, December 14, 2011 8:20 PM To: David Perlson; Moto-Apple-SDFL Cc: Weil_TLG Apple Moto FL External; AppleCov Subject: Apple/Moto SDFL: Letter re Production of Embodying Products David, Please see attached letter. Best Regards, Elena. Elena DiMuzio| Associate | COVINGTON & BURLING LLP One Front Street | San Francisco, CA 94111 |Phone: 415.591.7032 | Fax: 415.955.6532 | 1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?