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)

EXHIBIT 16

John Duchemin
From:
Sent:
To:
Cc:
Subject:

John Duchemin
Thursday, February 23, 2012 7:47 PM
'Ansley, Sutton'; '[e-mail]'; '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 [mailto:[e-mail]]
Sent: Tuesday, February 21, 2012 12:37 PM
To: John Duchemin; '[e-mail]'; 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
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