Motorola Mobility, Inc. v. Apple, Inc.
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)
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.
From: DiMuzio, Elena [mailto:email@example.com]
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
Please see attached letter.
Elena DiMuzio| Associate | COVINGTON & BURLING LLP
One Front Street | San Francisco, CA 94111 |Phone: 415.591.7032 | Fax: 415.955.6532 | firstname.lastname@example.org
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