Motorola Mobility, Inc. v. Apple, Inc.

Filing 305

RESPONSE/REPLY Surreply Regarding Apple's Motion to Compel Further Responses to Interrogatory Nos. 19-22 by Motorola Mobility, Inc.. (Attachments: # 1 Affidavit Declaration of John Duchemin in Support of Plaintiff's Surreply)(Mullins, Edward)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 1:10cv023580-Civ-RNS-TEB MOTOROLA MOBILITY, INC., Plaintiff, v. JURY TRIAL DEMANDED APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MOTOROLA, INC. and MOTOROLA MOBILITY, INC., Counterclaim Defendants. DECLARATION OF JOHN DUCHEMIN IN SUPPORT OF MOTOROLA’S SURREPLY REGARDING APPLE’S MOTION TO COMPEL FURTHER SUPPLEMENTAL RESPONSES TO INTERROGATORY NOS. 19-22 CASE NO. 1:10cv023580-Civ-RNS-TEB I, John Duchemin, declare: I am a member of the bar of the State of California, admitted pro hac vice in this action and an associate with Quinn Emanuel Urquhart & Sullivan, LLP, attorneys for Motorola Mobility, Inc. and Motorola Solutions, Inc. (f/k/a Motorola, Inc.) (collectively "Motorola"). I make this declaration of personal, firsthand knowledge, and if called and sworn as a witness, I could and would testify competently to the matters contained in this declaration. 1. Attached as Exhibit 1 is a true and correct copy of Apple’s Supplemental Objections and Responses to Motorola Mobility and Motorola's First Set of Interrogatories (No. 6). On page 4 of these contentions, Apple lists twenty-seven Accused Set-Top Boxes. None of these Accused Products is a remote control. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 9th day of April 2012 at Redwood Shores, California. /s/ John Duchemin John Duchemin 2 EXHIBIT 1 FILED UNDER SEAL

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