Motorola Mobility, Inc. v. Apple, Inc.

Filing 323

MOTION to Amend/Correct the Procedural Schedule by Apple, Inc.. Responses due by 5/4/2012 (Attachments: # 1 Affidavit Declaration of Mark G. Davis, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Supplement Notice of Filing Under Seal, # 10 Text of Proposed Order Proposed Order Granting Motion to Amend Procedural Schedule)(Pace, Christopher)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-RNS
MOTOROLA MOBILITY, INC.,
Plaintiff,
v.
APPLE INC.,
Defendant.
APPLE INC.,

JURY TRIAL REQUESTED
Counterclaim Plaintiff,

v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

APPLE INC.’S MOTION TO AMEND THE PROCEDURAL SCHEDULE

TABLE OF CONTENTS
Page
I.

INTRODUCTION ............................................................................................................. 1

II.

BACKGROUND ............................................................................................................... 3

III.

ARGUMENT..................................................................................................................... 5
A.
B.

Additional Time Is Needed For Discovery Relating To Motorola’s
Amended Invalidity Contentions ........................................................................... 8

C.

Additional Time Is Needed To Complete Already-Served Discovery .................. 9

D.
IV.

Apple’s Proposed Consolidation Best Serves Judicial Economy .......................... 6

Additional Time Is Needed To Complete Discovery For Motorola II ................ 11

CONCLUSION................................................................................................................ 12

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TABLE OF AUTHORITIES
Page
CASES
Young v. City of Palm Bay, Fla.
358 F.3d 859 (11th Cir. 2004) ........................................................................................... 5
Sosa v. Airprint, Sys., Inc.
133 F.3d 1417 (11th Cir. 1998) ......................................................................................... 5
Young v. City of Palm Bay, Fla
358 F.3d 859 (11th Cir. 2004) ........................................................................................... 5
STATUTES
Fed. R. Civ. P. 16(b)(4).................................................................................................................. 5

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I.

INTRODUCTION
Apple Inc. (“Apple”) and Motorola Solutions, Inc. and Motorola Mobility, Inc.

(“Motorola”) are currently engaged in a number of patent litigations, two of which are currently
pending before this Court.1 Motorola filed the second action, Motorola Mobility, Inc. v. Apple,
Inc. (“Motorola II”), Case No. 12-cv-20271, after Judge Ungaro denied Motorola’s attempt to
add newly released products to the current litigation. D.E. 198. In response, Apple filed
counterclaims in Motorola II on March 12, 2012, adding additional patent infringement claims
against Motorola as well as HTC Corporation, HTC America, Inc., One & Company Design,
Inc., and HTC America Innovation, Inc. (collectively “HTC”). HTC’s response is due on
May 11, 2012. In addition, on April 13, 2012, Motorola filed a motion for leave to amend its
Motorola II complaint to add additional patent infringement claims against Apple.
After Judge Ungaro granted Apple’s Motion to Strike Motorola’s Supplemental
Infringement Contentions, however, the case was transferred. On March 9, 2012, this Court
issued its Order Allowing Motorola to Supplement Invalidity Contentions, D.E. 259, allowing
new invalidity references to be added and inviting the parties to adjust the procedural schedule as
needed.

Pursuant to that order, the parties met and conferred regarding alterations to the

procedural schedule but were unable to agree on the most efficient way to try the claims in the
two cases pending before this Court or the amount of additional time required to try those claims.
On March 23, 2012, the Parties filed a Joint Motion to Amend the Scheduling Order, seeking an
agreed-upon extension, but noting that Apple would separately move for a further extension that
Apple believed was needed for discover regarding the new invalidity contentions and the state of
discovery in general. D.E. 277. The Court granted this Joint Motion. D.E. 283. Since then, the
1

Apple and Motorola will be in trial for six weeks in June and July for another litigation pending
in the Northern District of Illinois.
1

parties have continued to meet and confer regarding the schedules in both cases, most recently
including counsel for HTC in their discussions. While all are in agreement that the current
procedural schedules must be modified, the parties have not been able to agree on a proposed
extension. Indeed, HTC has indicated that it will not be able to substantively evaluate any
proposed amendments to the schedule until after it files its responsive pleading on May 11.
Based upon these new circumstances, Apple respectfully files the instant motion seeking an
extension in the form of consolidation of the two cases pending before this Court and a
consolidated schedule as set forth below:
Event

Infringement contentions
Invalidity contentions
Markman Hearing
Close of fact discovery
Opening expert reports
Rebuttal expert reports
Close of expert discovery
Deadline to file
dispositive motions
Deadline to file pretrial
motions
Deadline to file joint
pretrial stipulations / jury
instructions
Calendar call
Trial

Current
Schedule for
Motorola I
---5/4/12
5/11/12
6/8/12
7/3/12
7/13/12

Current
Schedule for
Motorola II
---6/8/12
6/8/12
7/9/12
7/30/12
8/13/12

Proposed Consolidated Schedule

7/13/12
8/10/12
11/2/12
80 days after Markman order issues
90 days after Markman order issues
120 days after Markman order issues
150 days after Markman order issues
160 days after Markman order issues

7/20/12

10/29/12

180 days after Markman order issues

9/13/12

1/11/13

220 days after Markman order issues

10/16/12
10/22/12

1/22/13
1/28/13

250 days after Markman order issues
260 days after Markman order issues

Apple believes that under the current circumstances, consolidation of the two cases
pending before this Court would best serve the interests of judicial efficiency and economy.
Moreover, good cause exists to grant the requested modifications to the procedural schedules,
which are necessary to allow sufficient time for discovery and for the parties to serve contentions
regarding the newly-asserted patents.

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I.

BACKGROUND
Motorola initiated the above-captioned patent-infringement action on October 6, 2010.

See D.E. 1. Apple filed its Answer, Affirmative Defenses, and Counterclaims on November 18,
2010 and its Amended Answer on March 18, 2011. See D.E. 17 and D.E. 68. Motorola filed its
second patent-infringement action in this district on January 24, 2012, asserting the same six
patents-in-suit against newly released Apple products. See Motorola II, D.E. 1. On March 12,
2012, Apple filed its Answer, Affirmative Defenses, and Counterclaims, asserting infringement
of four patents also asserted in this action by newly released Motorola products, plus
infringement of six additional patents by Motorola and HTC.

Motorola II, D.E. 27.

At

Motorola’s insistence, however, the parties jointly submitted a proposed schedule for Motorola II
on March 2, 2012, before Apple filed its answer. Motorola II, D.E. 24. The parties explicitly
noted that the agreed-upon schedule would likely need to be modified if additional patents were
asserted. Id.
On December 19, 2011, Motorola filed a Motion to Amend the Procedural Schedule To
Serve Supplemental Invalidity Contentions. D.E. 205. Oral argument on that motion was held
on March 9, 2012. See Davis Exh. A. During that hearing, counsel for Apple explained that
allowing Motorola to add the alleged prior art references to its invalidity contentions would
require additional, time-intensive discovery. Id. at 22:10-24:2, 24:13-27:2. Later that same day,
the Court issued an order granting Motorola’s motion, but also explained:
The Court … does not take lightly Apple’s concerns regarding
adequate time for discovery, preparation of dispositive motions,
and preparation for trial under the current schedule. Therefore, in
order to ensure fairness to both parties, the Court is willing to
adjust case deadlines, including the trial date, as may be
necessary…. If the parties are unable to agree [upon alterations to
the schedule], they are of course free to motion the Court
independently. The Court will grant the relief requested, if
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reasonable, and adjust the schedule as required. This is not one of
those Courts that is wedded to its schedule above all else.
D.E. 259 at 2 (emphasis added).
Pursuant to the Court’s order, the parties met and conferred on March 19, 2012 to discuss
an appropriate extension to the current procedural schedule. See Davis Decl. at ¶ 3. Motorola
rejected Apple’s proposed schedule, arguing that a one-month extension was sufficient. See
Davis Exh. B at 3. On March 21, 2012, Apple explained that, even if none of the claims from
Motorola I and Motorola II were consolidated, additional discovery was needed and such
discovery would require much longer than one month to complete. See Davis Exh. B at 1-2. On
March 22, 2012, the parties met and conferred again, but were still unable to reach an agreement.
See Davis Decl. at ¶ 5. Nonetheless, the parties agreed to jointly move to amend the procedural
schedule to the extent agreed upon, with the understanding that Apple would separately move for
a further extension to the schedule, which it believed was necessary. Id. That joint motion was
filed on March 23, 2012 and granted on March 26, 2012. See D.E. 277 and 283.
Subsequently, the parties continued to meet and confer regarding the most efficient way
to try the claims pending before this Court. Specifically, on April 9, 2012, Apple sent Motorola
a proposed schedule for consolidating the two actions currently pending before this Court. See
Davis Exh. C at 2-3. On April 10, 2012, Motorola responded that it did not agree to full
consolidation of the two actions and proposed an alternate schedule for a partial consolidation of
the issues. See Davis Exh. C at 1-2. Motorola’s proposed schedule was the same as Apple’s
proposed extension for Motorola I without any consolidation of issues. Compare Davis Exh. C
at 1-2 with Davis Exh. B at 4. On April 13, 2012, Apple responded that it was willing to
consider Motorola’s proposal for partial consolidation, but explained that Motorola’s proposed
timeline did not allow sufficient time for discovery on the new issues that would be included in

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this action. See Davis Exh. D at 3. Although stating that a fully consolidated schedule was most
appropriate, Apple sent Motorola and HTC proposed schedules for both this action and Motorola
II to facilitate discussions amongst the parties. See Davis Exh. E. Later that day, the parties met
and conferred again, but while the parties agreed the current schedules were unworkable and
needed to be further extended, the parties were unable to reach agreement on a procedural
schedule for either case. See Davis Decl. at ¶ 9. Moreover, during the April 13, 2012 meet and
confer, counsel for HTC indicated that the HTC entities would be in no position to substantively
evaluate proposed amendments to the procedural schedule until after HTC filed its responsive
pleading on May 11. See Davis Exh. D at 2. Motorola indicated it was willing to continue
discussions on the procedural schedule for Motorola II, but did not believe that the parties could
reach agreement without HTC’s input. Id. With the parties at an impasse, Apple informed
Motorola that it intended to file a motion to amend the procedural schedule to seek the Court’s
guidance. Id. at 1-2.
III.

ARGUMENT
There is no dispute by any of the parties that the current schedules in both cases need to

be extended. District courts have “broad discretion” to manage their dockets as they see fit.
Young v. City of Palm Bay, Fla., 358 F.3d 859, 864 (11th Cir. 2004). Here, good cause exists to
grant Apple’s proposed consolidation and amendment to the procedural schedule. See Fed. R.
Civ. P. 16(b)(4) (“A schedule may be modified only for good cause and with the judge’s
consent.”); Sosa v. Airprint, Sys., Inc., 133 F.3d 1417, 1418 (11th Cir. 1998) (quoting 1983
Advisory Comm. Notes, subdivision (b)) (“This good cause standard precludes modification
unless the schedule cannot ‘be met despite the diligence of the party seeking the extension.’”).
As described in further detail below, Apple’s proposed extension of the current procedural

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schedule by combining this case with Motorola II is not only reasonable, it is necessary because
of Motorola’s consistent attempts to thwart Apple’s diligent efforts at obtaining discovery
needed to prove its case.
A.

Apple’s Proposed Consolidation Best Serves Judicial Economy

The parties do not dispute that the schedules for the current case and Motorola II need to
be extended. The questions to be resolved by the Court, however, are: (1) the appropriate length
of the extension and (2) whether this case should be consolidated with Motorola II. As set forth
below, because of the overlapping issues and the fact that there are several circumstances that
require the current procedural schedule in this action to be extended significantly, judicial
economy weighs in favor of combining this case with Motorola II.
First, the rationale underlying Motorola’s filing of the second action no longer applies.
Judge Ungaro denied Motorola’s attempt to amend its infringement contentions to maintain the
then-applicable procedural schedule. That schedule has since been extended and the parties
agree that it needs to be further extended.2 Given the extensive overlap between the two cases
and the agreement in principle that the schedule must be adjusted, it now makes sense to
combine the two cases. All of the patents-in-suit in this action have been asserted—against
newly released Apple and Motorola products—in Motorola II. In addition, there is overlap in
patent families. Apple’s ’721 patent in Motorola II is a continuation of Apple’s ’849 patent in
this action and therefore has the same specification and inventors. The ’721 patent is asserted
against both Motorola and HTC, so any additional discovery regarding this patent should be

2

As a result of the agreed-upon extensions, the schedules in both cases are now overlapping with
another litigation between Apple and Motorola pending in the Northern District of Illinois, which
is set for a six-week trial before Judge Posner in June and July. Apple respectfully requests that
the schedule in this case and Motorola II take into account this conflict.
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coordinated with both of these parties, which cannot occur until after HTC files its responsive
pleading on May 11.
Further, Motorola seeks discovery in this case about Apple products that are only accused
of infringement in Motorola II. See Davis Exh. F (requesting 30(b)(6) testimony on Apple’s
App Store, which is not being accused in Motorola I). Motorola’s attempt to blur the lines
between Motorola I and Motorola II discovery in this fashion presents yet another reason why
consolidation of the two cases makes sense and will be most efficient. Moreover, on April 13,
2012, Motorola moved for leave to amend its complaint in Motorola II, adding infringement
claims for six additional patents. Motorola II, D.E. 64. Most of those new Motorola patents
appear to be aimed at the same products that are accused of infringing Motorola’s patents in this
action, e.g., Apple’s iPhone, iPad, Mac, and MacBook products. In addition, the new accused
set-top box (“STB”) products in Motorola II are likely to implicate some of the same witnesses
that Motorola has yet to schedule in Motorola I (e.g., someone who will testify about hardware
design for the accused STBs). Indeed, it would be more efficient for Motorola to address the
deficiencies in its discovery responses with respect to all of the accused STB products. This is
even more true for the third-party cable providers and IPG makers that Apple subpoenaed. If the
two cases are consolidated, Apple will not have to go back to those third parties to seek
additional information about the newly accused STBs in Motorola II after those parties have
finalized their document productions, declarations, and deposition testimony.
Given the overlap, consolidating the two actions will best serve the interests of judicial
economy and efficiency for the parties. Motorola argues that consolidation of the two cases will
delay a decision on its claims in this case, see Davis Exh. C at 3-4, but Motorola has no room to

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complain. It was Motorola that chose to file a second action and Motorola has been pushing to
include the claims in Motorola II in this case despite the impact it would have on the schedule.
In any event, Motorola’s self-serving proposal that only some of the pending claims in
Motorola II be consolidated with this case is unworkable under Motorola’s proposed schedule.
Motorola’s proposed extension is too short and would not allow adequate time for the parties to
coordinate overlapping discovery between the two casese. Thus, multiple depositions of Apple
engineers would likely be required for any products, e.g., Apple’s iPhone or iPad products, that
are accused of infringing Motorola’s (and possibly HTC’s) patents in Motorola II. Further, by
excluding HTC from its proposed consolidation of Apple’s claims regarding ’721 patent, any
discovery relating to the ’721 patent would be duplicated in Motorola II, which is extremely
inefficient.

Even coordinating discovery with HTC would be difficult under Motorola’s

proposed schedule. Likewise, Motorola’s proposed schedule does not allow enough time for
Apple to obtain all of the discovery it needs from third parties for the newly accused STBs given
that those third parties have resisted providing discovery in the current case for months.
B.

Additional Time Is Needed For Discovery Relating To Motorola’s Amended
Invalidity Contentions

Good cause exists to amend the procedural schedule in light of the Court’s order allowing
Motorola to amend its invalidity contentions. D.E. 259. As explained during the March 9th
hearing, discovery regarding the additional references asserted to be prior art will be extensive
and time-consuming.

See Davis Exh. A at 22:10-24:2, 24:13-27:2.

Apple must conduct

considerable third-party discovery that includes the depositions and document collections from
both domestic and foreign entities, even though it is Motorola’s burden to prove that the
references are invalidating prior art. Although Apple has begun this process, it has faced
significant resistance from third parties who have been subpoenaed thus far.

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For example, one of the references asserted to be prior art to Apple’s set-top box patents
is the ’185 patent, which on its face does not qualify as prior art. Motorola’s invalidity responses
were insufficient, so Apple has sought more detailed responses from Motorola, but Motorola has
yet to respond to this request. See Davis Exh. G. Also, as explained at the hearing, Apple has
begun seeking discovery by serving subpoenas on the inventors. Once Motorola supplements its
invalidity contentions, Apple must examine the alleged conception date for that patent and
whether the inventors were diligent in reducing the subject matter of the ’185 patent to actual or
constructive practice. See D.E. 211 at 7-8 (explaining that Motorola intends to rely on the
inventors’ earlier conception and reduction to practice instead of the filing date for the ’185
patent); see also Davis Exh. A at 22:10-24:2. Further, given Motorola’s lack of details in its
invalidity contentions for the ’185 Patent, Apple may also need to seek additional discovery after
it receives Motorola’s invalidity expert reports.
Apple also needs to seek and review documents concerning the Neonode phone alleged
to be prior art to Apple’s ’849 patent. For example, whether the Neonode phone was offered for
sale in the United States before Apple’s inventions disclosed in the ’849 patent requires review
of foreign documents. Moreover, neither of Neonode’s Rule 30(b)(6) designees was able to state
definitively when the first US sales of the device occurred or which unlocking functionalities
were included on that device. Thus, further discovery on this issue may be necessary.
C.

Additional Time Is Needed To Complete Already-Served Discovery

The inadequate duration of the current discovery period is further compounded by the
fact that Motorola continues to supplement its production of documents on a rolling basis and
still has not produced many of the relevant and responsive documents that Apple has requested.
Apple has had unjustifiably protracted and repeat exchanges with Motorola to obtain just a

9

portion of these relevant documents in a timely manner, while some requests go ignored. See,
e.g., Davis Exhs. H-L. Indeed, Apple has already been forced to file two motions to compel
Motorola to produce some of this requested discovery. D.E. 281; D.E. 282. As of the filing of
this motion, however, several categories of these documents still have not been produced. Based
on Motorola track record of delay and unfulfilled promises, it is highly unlikely that the parties
will resolve their outstanding discovery disputes and Motorola will complete its responses and
document productions before May 4.
In addition, Apple asked Motorola to prioritize its designation and provision of witnesses
related to Apple’s set-top box patents back in December of 2011, but Motorola did not make its
first witnesses available until late February. Only after Apple filed a motion to compel did
Motorola agree to provide three additional technical witnesses.

However, because those

witnesses were not adequately prepared to address certain topics and because new information
not previously provided by Motorola was learned from those depositions, additional depositions
are required. Furthermore, with less than three weeks left before the current discovery deadline,
Apple is still waiting for Motorola to provide deposition dates for key individual witnesses and
additional Rule 30(b)(6) designees. Id.; see also Davis Exh. M; Davis Decl. at ¶ 17.
Apple is also still in negotiations with many third party IPG makers and cable providers
to produce relevant documents and provide knowledgeable witnesses despite subpoenaing these
parties months ago. See Davis Decl. at ¶ 18. Thus far, Apple has received very little in the way
of substantive responses. Many of these third parties have been withholding documents on the
basis that production is unduly burdensome, particularly since they believe Motorola is likely to
have the same or similar information. For instance, Rovi Corporation—the leading IPG maker
for the accused Motorola STBs—only recently agreed to produce certain license agreements and

10

present witnesses for deposition. See Davis Exh. N. As for other third parties, in the hope of
avoiding motion practice, Apple has agreed to pursue declarations in lieu of deposition
testimony. If Apple cannot reach agreeable declarations with the third parties (and Motorola
continues to ignore Apple’s request that Motorola stipulate to the use of third-party materials),
however, Apple may be forced to turn to motion practice to obtain the needed discovery
Motorola has thus far failed to deliver despite promises to produce documentation on behalf of
the subpoenaed parties. Obtaining a decision on any motions and scheduling any subsequently
ordered discovery could take months and certainly more time than the current schedule permits.
In short, despite Apple’s diligent efforts to complete discovery in a timely manner, there
is still much discovery remaining in Motorola I as a result of Motorola’s amended invalidity
contentions and uncooperative discovery practices to date. In addition, Motorola continues to
request depositions of Apple witnesses, yet has rejected dates offered by Apple. Given the busy
schedules of Apple’s engineers, Motorola’s unwillingness to proceed when these witnesses are
available may mean that certain depositions will need to be taken after the current close of
discovery. The proposed extensions are therefore reasonable and, additionally, should limit the
parties from burdening the Court with further motions to amend the procedural schedule.
D.

Additional Time Is Needed To Complete Discovery For Motorola II

The fact discovery deadline in Motorola II that was set before Apple answered
Motorola’s complaint is June 8, 2012. By agreement of the parties and by order of the Court,
however, the HTC entities have until May 11, 2012 to respond to Apple’s counterclaims, leaving
less than a month to complete discovery. Motorola II, D.E. 55 and 56. The parties are unlikely
to reach agreement on modifications to the Motorola II schedule in the near term, as HTC’s
counsel stated that HTC will not be in a position to substantively evaluate proposed amendments

11

to the procedural schedule until after that date. See Davis Exh. D at 2. Moreover, given
Motorola’s recent motion to amend its complaint to add six new patents and the likelihood that
HTC will add its own patents to the case, additional time will be necessary to address these new
patents. Thus, there exists good cause for Apple’s proposed consolidation and amendments to
the procedural schedule.
IV.

CONCLUSION
Given the circumstances presented above, the scheduling extensions proposed by this

motion are reasonable and supported by good cause. Despite Apple’s diligent efforts, substantial
discovery remains which cannot be completed within the timeframe of the current procedural
schedule for this action. Moreover, it has become apparent that all parties cannot begin to
discuss amendments to the procedural schedule for Motorola II until HTC files its responsive
pleading on May 11. So the parties have a reasonable opportunity to obtain all of the facts
necessary to defend themselves against claims of infringement and fairly try their own claims,
Apple respectfully asks this Court to consolidate the two pending actions and amend the
procedural schedule as proposed herein.
CERTIFICATE OF GOOD FAITH CONFERENCE
Pursuant to Local Rule 7.1(a)(3), I hereby certify that counsel for Apple has conferred
with counsel for Motorola in a good faith effort to resolve the issues raised in the motion and has
been unable to do so.

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DATED: April 17, 2012

Respectfully submitted,
/s/ Christopher R. J. Pace
Christopher R. J. Pace
[e-mail]
Edward Soto
WEIL, GOTSHAL & MANGES LLP
1395 Brickell Avenue, Suite 1200
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Attorneys for Apple Inc.

Of Counsel:
Matthew D. Powers
[e-mail]
Steven Cherensky
[e-mail]
Tensegrity Law Group LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: 650-802-6001
Mark G. Davis
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Anne M. Cappella
[e-mail]
Jill J. Schmidt
[e-mail]
WEIL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

Robert T. Haslam
[e-mail]
COVINGTON & BURLING LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
Robert D. Fram
[e-mail]
Christine Saunders Haskett
[e-mail]
Samuel F. Ernst
[e-mail]
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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CERTIFICATE OF SERVICE
I hereby certify that on April 17, 2012, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
is being served this day on all counsel of record or pro se parties identified on the attached
Service List in the manner specified, either via transmission of Notices of Electronic Filing
generated by CM/ECF or in some other authorized manner for those counsel or parties who are
not authorized to received electronically Notices of Electronic Filing.

/s/ Christopher R. J. Pace
Christopher R. J. Pace (Fla. Bar No. 0721166)

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SERVICE LIST
Motorola Mobility, Inc. versus Apple Inc.
Case No. 1:10cv023580-Civ-RNS
United States District Court, Southern District of Florida

Edward M. Mullins
Fla. Bar No. 863920
[e-mail]
ASTIGARRAGA DAVIS MULLINS & GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Of Counsel:
Charles K. Verhoeven
David A. Perlson
QUINN EMANUEL URQUHART & SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 93111
[phone]
Raymond N. Nimrod
Edward J. DeFranco
QUINN EMANUEL URQUHART & SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
[phone]
David A. Nelson
QUINN EMANUEL URQUHART & SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
[phone]
[e-mail]
Attorneys for Motorola Mobility, Inc. and Motorola, Inc.
Electronically served via email

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