Motorola Mobility, Inc. v. Apple, Inc.

Filing 291

RESPONSE/REPLY (Redacted) to Apple's March 26, 2012 Sealed Motion to Compel Production of Documents and Testimony Regarding Set-Top Box Components by Motorola Mobility, Inc.. (Attachments: # 1 Exhibit 16, # 2 Exhibit 21, # 3 Exhibit 23)(Herrera, Sujey)

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EXHIBIT 16 John Duchemin From: Sent: To: Cc: Subject: John Duchemin Thursday, February 23, 2012 7:47 PM 'Ansley, Sutton'; ''; 'Apple Moto Weil' Moto-Apple-SDFL RE: Motorola-Apple (Florida): Apple's Production Requests Sutton, Certain schematics are included in the production volume MOTO_AP224 at the following Bates ranges: BegDoc# MOTO-APPLE-0007471649 MOTO-APPLE-0007471669 MOTO-APPLE-0007471697 MOTO-APPLE-0007471714 MOTO-APPLE-0007471731 MOTO-APPLE-0007471746 MOTO-APPLE-0007471761 MOTO-APPLE-0007471783 EndDoc# MOTO-APPLE-0007471668 MOTO-APPLE-0007471696 MOTO-APPLE-0007471713 MOTO-APPLE-0007471730 MOTO-APPLE-0007471745 MOTO-APPLE-0007471760 MOTO-APPLE-0007471782 MOTO-APPLE-0007471804 I note that several of the products on the list below are not listed as accused products in Apple’s infringement contentions. Schematics for those products have not been produced. Best, John From: Ansley, Sutton [] Sent: Tuesday, February 21, 2012 12:37 PM To: John Duchemin; ''; Apple Moto Weil Cc: Moto-Apple-SDFL Subject: Motorola-Apple (Florida): Apple's Production Requests John, We have reviewed Motorola's production to date and have located a number of schematics for only some of Motorola's accused set-top box products. Our extensive review shows deficiencies in Motorola's production. Specifically, Motorola has failed to produce schematics for the following accused set-top boxes: • • • • • • • DCT3400 DCT3412 DCT3416 DCT3080 DCT6200 DCT6208 DCT6400 1 • • DCT6412 DCT6416 • DCX3400 • • • • QIP2708 QIP6416 QIP7100 QIP7216 • DRC800 Schematics for the set-top boxes are responsive to at least Apple's Request for Production Nos. 2, 5 and 6. Please indicate by COB Wednesday, February 22, 2012 whether Motorola will cure this deficiency and produce complete schematics for the set-top box models listed, above, no later than three business days before Motorola's Rule 30(b)(6) depositions on set-top box topics (i.e., COB Thursday, February 23, 2012). If these documents are not produced pursuant to our agreement, we will be forced to hold open these Rule 30(b)(6) depositions. If Motorola believes that it has already produced complete schematics for these set-top box products, please indicate where in its production by bates number the schematics for the above-listed products can be found by COB Thursday February 23, 2012. We will not document again the numerous times that Apple has been requesting that Motorola cure these deficiencies relating to core documents such as these schematics. But, we do note that Mr. Groat's deposition is set for one week from today, and he is designated on topics that directly relate to these schematics. We look forward to your response. Please contact us with any questions. Best, Sutton W. Sutton Ansley Weil, Gotshal & Manges LLP 1300 Eye Street, NW, Suite 900 Washington, DC 20005 +1 202 682 7018 Direct +1 202 857 0940 Fax The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email,, and destroy the original message. Thank you. 2

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