Motorola Mobility, Inc. v. Apple, Inc.
RESPONSE in Opposition re 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 filed by Motorola Mobility, Inc.. (Attachments: # 1 Affidavit of David M. Elihu, # 2 Exhibit A to Declaration (redacted), # 3 Exhibit B to Declaration, # 4 Exhibit C to Declaration, # 5 Exhibit D to Declaration)(Escobar, Annette)
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10-cv-023580-Civ-RNS
MOTOROLA MOBILITY, INC.,
JURY TRIAL DEMANDED
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
DECLARATION OF DAVID M. ELIHU
IN SUPPORT OF MOTOROLA’S OPPOSITION TO APPLE’S MOTION TO
COMPEL RESPONSES TO INTERROGATORIES NOS. 7 AND 12
REGARDING PRODUCTS EMBODYING MOTOROLA’S ASSERTED PATENTS
I, David M. Elihu, declare:
I am a member of the bar of the State of New York, and an associate with Quinn
Emanuel Urquhart & Sullivan, LLP, attorneys for Motorola Mobility, Inc. and Motorola
Solutions, Inc. (f/k/a Motorola, Inc.) (collectively "Motoro1a). I make this declaration of
personal, firsthand knowledge, and if called and sworn as a witness, I could and would testify
competently to the matters contained in this declaration.
Attached hereto as Exhibit A is a true and correct copy of excerpts from Motorola
Mobility, Inc.'s Responses to Apple's First Set of Interrogatories, dated January 31, 2011.
Attached hereto as Exhibit B is a true and correct copy of Apple's Opposition to
Kodak's Motion to Compel Documents and Source Code, filed in Eastman Kodak Co. v. Apple
Inc., Dkt. No. 84, No. 6: 1 0-cv-06022-MAT-JWF (W.D.N.Y.) and dated May 20, 2011.
Attached hereto as Exhibit C is a true and correct copy of an email exchange
between Elena DiMuzio, counsel for Apple, and Marshall Searcy, counsel for Motorola, dated
January 19, 2012.
Attached hereto as Exhibit D is a true and correct copy of a print out of the
webpage "Leader Company Information—Company Overview" available at
http://www.leader.com/companyinformation.htm (as visited February 6, 2012).
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed this 6th day of February 2012 in New York, New York.
David M. Elihu
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