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)

REDACTED - PUBLIC VERSION

EXHIBIT 2

CONTAINS CONFIDENTIAL BUSINESS INFORMATION SUBJECT TO PROTECTIVE ORDER

IN THE UNITED STATES DISTRICT COURT
FOR THE 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.

APPLE’S SUPPLEMENTAL OBJECTIONS AND RESPONSES TO MOTOROLA
MOBILITY AND MOTOROLA’S FIRST SET OF INTERROGATORIES
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Defendant
and Counterclaim-Plaintiff Apple, Inc. (“Apple”) objects and responds to the
interrogatories served by Plaintiff and Counterclaim-Defendant Motorola Mobility, Inc.
and Counterclaim-Defendant Motorola, Inc. (collectively “Motorola”) as follows.

CONTAINS CONFIDENTIAL BUSINESS INFORMATION SUBJECT TO PROTECTIVE ORDER

INTERROGATORY NO. 8
For each Apple Asserted Claim, separately identify, by product name, version,
description and/or other identifying characteristic, every Embodying Product covered by
the Apple Asserted Claim and describe, on an element-by-element basis, the basis for
your contention, whether made now or in the past, that the product so identified practices
the Apple Asserted Claim.
RESPONSE TO INTERROGATORY NO. 8
In addition to its General Objections, Apple objects to this interrogatory as
unlimited in time and therefore overly broad and unduly burdensome to the extent that as
defined by Counterclaim-Defendants, “Embodying Product(s)” requires Apple to provide
an element-by-element analysis of every product ever made by any entity that is thought
to embody an Apple Asserted Claim. Apple further objects to this interrogatory to the
extent that it seeks information that is (a) confidential, proprietary, or trade secret; (b)
subject to Apple’s legal or contractual obligation of nondisclosure or confidentiality to a
third party; and/or (c) not within Apple’s possession, custody or control. Apple expressly
reserves the right to amend, supplement, and/or correct its response to this interrogatory
as additional information becomes available to Apple during the course of its discovery
and investigation.

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CONTAINS CONFIDENTIAL BUSINESS INFORMATION SUBJECT TO PROTECTIVE ORDER

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 8
Subject to its General and Specific Objections, Apple identifies the following
Apple products that embody one or more of the Apple Asserted Patents:

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 17, 2012, I served the foregoing
document via electronic mail on all counsel of record identified on the attached Service
List.

/s/ Jill Ho
Jill Ho

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