Motorola Mobility, Inc. v. Apple, Inc.

Filing 282

NOTICE by Apple, Inc. Notice of Filing of Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Production of Documents and Testimony Regarding Set-Top Box Components and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Production of Documents and Testimony Regarding Set-Top Box Components, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit G, # 6 Exhibit H)(Pace, Christopher)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-RNS-TEB

MOTOROLA MOBILITY, INC.,
Plaintiff,

JURY TRIAL DEMANDED

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

DECLARATION OF JILL J. HO IN SUPPORT OF APPLE INC.’S MOTION TO
COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY REGARDING
SET-TOP BOX COMPONENTS

I, Jill J. Ho,1 declare under penalty of perjury, that the following is true and
correct:
1.

I am a member of the bar of the State of California, admitted pro hac vice in this

action and an associate at the law firm of Weil, Gotshal & Manges LLP, counsel of
record for Apple Inc. (“Apple”) in the above-captioned matter. The matters referred to in
this declaration are based on personal knowledge, and if called as a witness I could, and
would, testify competently to these matters.
2.

Attached hereto as Exhibit A is a true and correct copy of a March 15, 2012 email

from John Duchemin of Quinn Emanuel Urqhart & Sullivan, LLP to my colleague Jason
Lang, cc’ing a service list of which I am a member.
3.

Attached hereto as Exhibit B is a true and correct copy of Apple’s First Set of

Requests for Production to Motorola Mobility and Motorola (Nos. 1-49), served on
December 29, 2010.
4.

Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.

5,594,509, asserted by Apple in this action.
5.

Attached hereto as Exhibit D is a true and correct copy of U.S. Patent No.

5,621,456, asserted by Apple in this action.
6.

Attached hereto as Exhibit E is a true and correct copy of the transcript from the

deposition of Evan Groat, taken on February 28, 2012.
7.

Attached hereto as Exhibit F is a true and correct copy of Motorola Mobility’s

Responses to Apple’s First Set of Requests for Production to Motorola Mobility and
Motorola (Nos. 1-49), served on January 31, 2011.
1

Jill Ho is currently in the process of adopting her married name, Jill Schmidt.

2

8.

Attached hereto as Exhibit G is a true and correct copy of Apple’s Proposed

Claim Constructions, served on July 7, 2011.
9.

Attached hereto as Exhibit H is a true and correct copy of Apple’s Proposed

Claim Constructions, served on July 7, 2011.
10.

Attached hereto as Exhibit I is a true and correct copy of a March 7, 2012 email

from Mr. Duchemin to my colleague Arjun Mehra, cc’ing a service list of which I am a
member.
11.

Attached hereto as Exhibit J is a true and correct copy of a March 9, 2012 email

from Mr. Mehra to Mr. Duchemin, cc’ing a service list of which I am a member.
12.

Attached hereto as Exhibit K is a true and correct copy of a March 22, 2012 email

from Mr. Duchemin to Mr. Lang, cc’ing a service list of which I am a member.
13.

Attached hereto as Exhibit L is a true and correct copy of a March 9, 2012 email

from Mr. Duchemin to my colleague Sutton Ansley, cc’ing a service list of which I am a
member.

I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed on March 26, 2012 at Redwood Shores, California
/s/ Jill J. Ho
Jill J. Ho

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