Motorola Mobility, Inc. v. Apple, Inc.
Filing
281
NOTICE by Apple, Inc. Notice of Filing of Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Further Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22) and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple's Motion to Compel Further Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22), # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit I, # 4 Exhibit Exhibit J, # 5 Exhibit Exhibit K, # 6 Exhibit Exhibit L)(Pace, Christopher)
EXHIBIT L
quinn emanuel
trial lawyers | san francisco
50 California Street, 22nd Floor, San Francisco, California 94111 | TEL: (415) 875-6600
FAX:
(415) 875-6700
WRITER'S DIRECT DIAL NO.
(415) 875-6344
WRITER'S INTERNET ADDRESS
davidperlson@quinnemanuel.com
November 14, 2011
VIA E-MAIL
Jill Ho, Esq.
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Re:
Motorola Mobility, Inc. v. Apple Inc., 10-cv-3580
Dear Jill:
I write in connection with Apple, Inc.'s ("Apple") November 10, 2011 service of subpoenas on
third parties AT&T, Inc., Comcast Corp., Mediacom Communications Corp., Time Warner
Cable, Inc., Bright House Networks, LLC, Charter Communications, Inc., Cox Communications,
Inc., and Suddenlink Communications ("the Third-Party Subpoenas").
Apple's Third-Party Subpoenas are overbroad and unnecessarily burden non-parties, and clients
of Motorola, with significant amounts of discovery, including information and documents that
can be requested of Motorola. In an effort to streamline discovery in this matter, Motorola
proposes that the parties discuss at our meet and confer scheduled for November 15 how these
various requests are relevant and which discovery requests may be addressed by Motorola rather
than the subpoenaed third-parties.
Motorola also notes that the Third-Party Subpoenas seek depositions in multiple locations on
both December 5 and December 12. We presume these are merely placeholder dates and that
Apple does not intend to proceed on these dates. Please let us know promptly if that is incorrect.
quinn emanuel urquhart & sullivan, llp
LOS ANGELES | 865 South Figueroa Street, 10th Floor, Los Angeles, CA 90017 | TEL (213) 443-3000 FAX (213) 443-3100
NEW YORK | 51 Madison Avenue, 22nd Floor, New York, NY 10010 | TEL (212) 849-7000 FAX (212) 849-7100
SILICON VALLEY | 555 Twin Dolphin Drive, Fifth Floor, Redwood Shores, CA 94065 | TEL (650) 801-5000 FAX (650) 801-5100
TOKYO | Akasaka Twin Tower Main Building, 6th Floor, 17-22 Akasaka 2-Chome, Minato-ku, 107-0052 | TEL +81 3 5561-1711 FAX +81 3 5561-1712
LONDON | 16 Old Bailey, London United Kingdom | TEL +44(0) 20 7653 2000 FAX +44(0) 20 7653 2100
Very truly yours,
/s/
David Perlson
2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?