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

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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
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Very truly yours,
/s/
David Perlson

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