Motorola Mobility, Inc. v. Apple, Inc.

Filing 276

NOTICE by Apple, Inc. of Filing Declaration of Jill J. Ho in Support of Apple Inc.'s Motion for Leave to File Amended Answer and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple Inc.'s Motion for Leave to File Amended Answer, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S)(Pace, Christopher)

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EXHIBIT R IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA Case No. 1:10cv023580-Civ-UU 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 THIRD SET OF INTERROGATORIES TO MOTOROLA MOBILITY AND MOTOROLA (NOS. 16-22) Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant and Counterclaim Plaintiff Apple Inc. (“Apple”) requests that Plaintiff and Counterclaim Defendant Motorola Mobility, Inc. (“Motorola Mobility”) and Counterclaim Defendant Motorola, Inc. (“Motorola”) (collectively, the “Counterclaim Defendants”) answer separately, fully, in writing, and under oath the following interrogatories within thirty (30) days after service hereof. Pursuant to Federal Rule of Civil Procedure 26(e), these interrogatories are continuing in nature and therefore require Counterclaim Defendants to furnish supplemental answers whenever they obtain different or additional knowledge, information, or beliefs relative to these interrogatories. DEFINITIONS The definitions in Apple Inc.’s First Set of Interrogatories (Nos. 1-10) and Second Set of Interrogatories (Nos. 11-15) are incorporated by reference. INSTRUCTIONS The instructions in Apple Inc.’s First Set of Interrogatories (Nos. 1-10) are incorporated by reference. INTERROGATORIES INTERROGATORY NO. 16: For each Motorola Accused Mobile Device, describe in detail how to lock and unlock the touchscreen, including without limitation (i) the conditions under which the touchscreen becomes locked; (ii) the way(s) in which a user may unlock a locked touchscreen; (iii) any graphical elements presented by the user interface when the touchscreen is locked; (iv) whether such graphical element(s) are interactive and, if so, how a user may interact with such graphical element(s); and (v) an identification by file name(s) and directory location(s) of the software, firmware, or other source code used to implement any of the aforementioned locking and unlocking functionalities. INTERROGATORY NO. 17: For each Motorola Accused Mobile Device, identify with specificity, including by file name(s) and directory location(s), the software, firmware, or other source code that (i) detects the addition or removal of additional devices or peripherals; (ii) detects the 2 addition or removal of additional display devices; or (iii) allocates video output between the built-in display and additional display devices, including but not limited to the external display service and any related libraries (e.g., extdispservice, iextdispservice, and nativehdmiapis) as well as any software drivers for any HDMI transmitters provided by third parties. INTERROGATORY NO. 18: For each Motorola Accused Mobile Device, identify with specificity, including by file name(s) and directory location(s), the software, firmware, or other source code that implements the Webtop and (HD) Entertainment Center applications. INTERROGATORY NO. 19: Identify each cable service provider that is or has been a party to a license, service, or other agreement with Motorola and provide a narrative description of the relationship between Motorola and each such cable service provider. INTERROGATORY NO. 20: Identify with specificity, each and every Motorola set-top box manufactured, used, distributed, sold, offered for sale, or imported with an interactive program guide, by or on behalf of Motorola, including without limitation the model name, trade name, marketing name, internal name, type, description, design number, catalog number, and all other names and/or designations used to identify such Motorola set-top boxes, and including any associated hardware, such as remote control devices. INTERROGATORY NO. 21: For each Motorola set-top box and associated hardware identified in response to Interrogatory No. 20 above, identify with specificity each entity who is or has been involved 3 with the research, engineering, design, development, implementation, revision, support, or provision of any version of the interactive program guides running on such Motorola set-top boxes, including without limitation the name and location of each such entity, its relationship with Motorola, and a narrative description of its involvement. INTERROGATORY NO. 22: For each Motorola set-top box and associated hardware identified in response to Interrogatory No. 20 above, identify with specificity, including as appropriate the internal and external part name and number, model name or number, manufacturer, source, supplier, file name(s), directory name(s), and any version number, each microchip, microprocessor, microcontroller, chipset, software, firmware, source code or other component that implements, supports, or provides interactive program guide functions, including without limitation mechanisms for obtaining television programming information from a source signal, television programming listing displays, picture-in-picture displays, program reminder mechanisms, program marking mechanisms, and recording mechanisms. 4 Dated: November 14, 2011 Respectfully submitted, /s/ Jill J. Ho __ Christopher R. J. Pace christopher.pace@weil.com Edward Soto edwart.soto@weil.com WEIL, GOTSHAL & MANGES LLP 1395 Brickell Avenue, Suite 1200 Miami, FL 33131 Telephone: (305) 577-3100 Facsimile: (305) 374-7159 Attorneys for Apple Inc. Of Counsel: Jill J. Ho jill.ho@weil.com WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 Facsimile: (650) 802-3100 Robert T. Haslam rhaslam@cov.com COVINGTON & BURLING LLP 333 Twin Dolphon Drive Suite 700 Redwood Shores, CA 94065 Telephone: (650) 632-4700 Facsimile: (650) 632-4800 Mark G. Davis mark.davis@weil.com WEIL, GOTSHAL & MANGES LLP 1300 Eye Street, N.W., Suite 900 Washington, DC 20005 Telephone: (202) 682-7000 Facsimile: (202) 857-0940 Matthew D. Powers Mathew.Powers@tensegritylawgroup.com Steven S. Cherensky Steven.Cherensky@tensegritylawgroup.com TENSEGRITY LAW GROUP LLP 201 Redwood Shores Parkway, Suite 401 Redwood Shores, CA 94065 Telephone: (650) 802-6000 5 Robert D. Fram rfram@cov.com Christine S. Haskett chaskett@cov.com Samuel F. Ernst sernst@cov.com Winslow B. Taub wtaub@cov.com COVINGTON & BURLING LLP One Front Street San Francisco, CA 94111 Telephone: (415) 591-6000 Facsimile: (415) 591-609 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 14, 2011, I served the foregoing document via electronic mail on all counsel of record identified on the attached Service List. /s/ Jill Ho Jill Ho SERVICE LIST Motorola Mobility, Inc. versus Apple Inc. Case No. 1:10cv023580-Civ-UU United States District Court, Southern District of Florida Edward M. Mullins Fla. Bar No. 863920 emullins@astidavis.com ASTIGARRAGA DAVIS MULLINS & GROSSMAN, P.A. 701 Brickell Avenue, 16th Floor Miami, FL 33131 Telephone: (305) 372-8282 Facsimile: (305) 372-8202 Of Counsel: Charles K. Verhoeven charlesverhoeven@quinnemanuel.com David A. Perlson davidperlson@quinnemanuel.com Anthony Pastor anthonypastor@quinnemanuel.com QUINN EMANUEL URQUHART & SULLIVAN, LLP 50 California Street, 22nd Floor San Francisco, CA 93111 (415) 875-6600 Moto-Apple-SDFL@quinnemanuel.com Attorneys for Motorola Mobility, Inc. and Motorola, Inc. Electronically served via email 7

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