Motorola Mobility, Inc. v. Apple, Inc.

Filing 231

NOTICE by Apple, Inc., Motorola Mobility, Inc. Regarding the Benefits of a Technology Tutorial (Mullins, Edward)

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10-cv-23580-RNS/TEB
MOTOROLA MOBILITY, INC.,
Plaintiff,
v.
JURY TRIAL DEMANDED
APPLE INC.,
Defendant.

APPLE INC.,
Counterclaim Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

JOINT NOTICE REGARDING THE BENEFITS
OF A TECHNOLOGY TUTORIAL
Pursuant to the Court's February 3, 2012 Order, Apple, Inc. (“Apple”) and Motorola
Solutions, Inc. and Motorola Mobility, Inc. (“Motorola”) (collectively, the “Parties”) jointly file
this notice regarding the benefits of presenting a technology tutorial for the Court.
1.

On October 6, 2011, the Parties presented a technology tutorial for the Honorable

Ursula Ungaro, the prior judge assigned to this matter.
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The Parties believe that the Court would benefit from a presentation similar to this

technology tutorial.

Case No. 1:10-cv-23580-RNS/TEB
3.

The Parties believe that this presentation should occur before the Court hears

other substantive Motions, but both could be scheduled for the same day.
4.

In addition, Apple believes that a legal tutorial, similar to that presented to Judge

Ungaro on October 17, 2011, may be beneficial for the Court.

Motorola will participate in any

legal tutorial that the Court finds necessary or helpful, but does not believe the legal tutorial on
claim construction presented to Judge Ungaro would be beneficial given that Judge Ungaro
already ruled on that issue in her Order dated December 1, 2011.

Apple disagrees, as there still

may be unresolved claim construction disputes and because the legal tutorial presented to Judge
Ungaro was not limited to claim construction issues.
The Parties therefore request that the Court enter an Order setting a time and date for this
technology tutorial to be held.
Dated: February 7, 2012

Respectfully submitted,

/s/ Edward M. Mullins
Edward M. Mullins
[e-mail]
Hal M. Lucas
[e-mail]
ASTIGARRAGE DAVIS MULLINS
& GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, Florida 33131
Telephone: [phone]
Facsimile: [phone]

/s/ Christopher R. J. Pace
Christopher R. J. Pace
[e-mail]
Edward Soto
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1395 Brickell Avenue, Suite 1200
Miami, Florida 33131
Telephone: [phone]
Facsimile: [phone]

Attorneys for Motorola Mobility, Inc.
and Motorola Solutions, Inc.

Attorneys for Apple Inc.

Of Counsel:
Mark D. Baker
[e-mail]
Edward J. DeFranco
[e-mail]
Alexander Rudis
[e-mail]

Of Counsel:
Matthew D. Powers
[e-mail]
Steven Cherensky
[e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway

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Case No. 1:10-cv-23580-RNS/TEB
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010
Telephone: [phone]
Facsimile: [phone]

Redwood Shores, California
Telephone: [phone]
Facsimile: 650-802-6001

94065

David A. Nelson
[e-mail]
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
Telephone: [phone]
Facsimile: [phone]

Robert D. Fram
[e-mail]
Christine Saunders Haskett
[e-mail]
COVINGTON & BURLING LLP
One Front Street
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

Attorneys for Motorola Mobility, Inc.
and Motorola Solutions, Inc.

Attorneys for Apple Inc.

Mark G. Davis
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Charles K. Verhoeven
[e-mail] Telephone: [phone]
David A. Perlson
Facsimile: [phone]
[e-mail]
QUINN EMANUEL URQUHART
Robert T. Haslam
& SULLIVAN, LLP
[e-mail]
50 California Street, 22nd Floor
COVINGTON & BURLING LLP
San Francisco, California 94111
333 Twin Dolphin Drive, Suite 700
Telephone: [phone]
Redwood Shores, California 94065
Facsimile: [phone]
Telephone: [phone]
Facsimile: [phone]

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 7, 2012, I electronically filed the foregoing
document with the Clerk of the Court using the CM/ECF filing system. I also certify that the
foregoing document is being served this date on all counsel of record or pro se parties on the
Service List, either via transmission of Notices of Electronic Filing generated by the CM/ECF
system or; in some other authorized manner for those counsel or parties who are not authorized
to receive electronically Notices of Electronic Filing.
/s/ Edward M. Mullins___________________
Edward M. Mullins (Fla. Bar No. 863920)

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