Motorola Mobility, Inc. v. Microsoft Corporation

Filing 127

NOTICE by Microsoft Corporation re #126 Defendant's MOTION for Summary Judgment (Redacted) of Filing Exhibits (Attachments: #1 Appendix Statement of Material Facts, #2 Appendix Index to Exhibits, #3 Exhibit 1 (Part 1), #4 Exhibit 1 (Part 2), #5 Exhibit 2, #6 Exhibit 3, #7 Exhibit 4, #8 Exhibit 10, #9 Exhibit 11, #10 Exhibit 12, #11 Exhibit 13, #12 Exhibit 14, #13 Exhibit 17, #14 Exhibit 19, #15 Exhibit 20)(Miner, Curtis)

EXHIBIT 20

[Type text]

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO. I: I O-CV -24063-MORENO/TORRES

MOTOROLA MOBILITY, INC.,
Plaintiff,
v.

MICROSOFT CORPORATION,
Defendant.

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MICROSOFT CORPORATION,
Counterclaim Plaintiff,
v.

MOTOROLA MOBILITY, INC.
Counterclaim Defendant.

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PLAINTIFF MOTOROLA MOBILITY, INC.'S
FIRST SET OF INTERROGATORIES (NOS. 1-15)
TO DEFENDANT MICROSOFT CORPORATION

Pursuant to Rule 33 of the Federal Rules of Civil Procedure, PlaintiffCounterclaim Defendant Motorola Mobility, Inc. ("Motorola Mobility") requests that Defendant
Counterclaim Plaintiff Microsoft Corporation ("Microsoft") fully answer in writing and under
oath, within thirty (30) days of the service, each of the Interrogatories set forth below.

DEFINITIONS AND INSTRUCTIONS

Each individual Interrogatory in this First Set ofInterrogatories is subject to and
incorporates the following definitions and instructions as used herein.
DEFINITIONS

I.

"Motorola Mobility" or "Plaintiff' means, collectively and individually, Motorola

Mobility, Inc., and all its predecessors or successors (merged, acquired, or otherwise), parents,
divisions, subsidiaries, and affiliates thereof, and all officers, agents, employees, counsel and
other persons acting on its behalf, or any other person or entity subject to Motorola Mobility's
control, or which controls Motorola Mobility, including but not limited to Motorola, Inc ..
2.

"Microsoft," "Microsoft Corporation," or "Defendant" means, collectively and

individually, Microsoft Corporation, and all its predecessors or successors (merged, acquired, or
otherwise), parents, divisions, subsidiaries, and affiliates thereof, and all officers, agents,
employees, counsel and other persons acting on its behalf, or any other person or entity subject to
Microsoft's control, or which controls Microsoft.
3.

"Person" means any natural person or individual, and any and all legal entities,

including without limitation, corporations, companies, firms, partnerships, joint ventures,
proprietorships, associations, governmental bodies or agencies, or other form of business
enterprise.
4.

The terms "and" and "or" are terms of inclusion and not of exclusion and are to be

construed either disjunctively or conjunctively as necessary to bring within the scope of these
requests any documents or responses which might be otherwise construed to be outside the scope
of these requests.
5.

The term "any" includes "all," and the term "all" includes "any."

6.

The singular of any tenn includes the plural of that tenn, and the plural includes

the singular.
7.

The tenn "concerning" means identifying, referring to, concerning, regarding,

evidencing, demonstrating, summarizing, reflecting, constituting, containing, embodying,
mentioning, pertaining to, commenting upon, connected with, discussing, describing, analyzing,
showing, comprising, or relating to in any relevant way to a particular subject, in whole or in
part, either directly or indirectly.
8.

"Document" shall have the broadest meaning and scope ascribed under Rule 34 of

the Federal Rules of Civil Procedure, and include all tangible things which come within the
meaning of the tenns "writings and recordings," as used in Federal Rule of Evidence 1001 and
all electronically stored infonnation. A draft or non-identical copy is a separate document within
the meaning of this tenn.
9.

"Electronically stored infonnation" means infonnation created, manipulated,

communicated, stored, and/or best utilized in any type of electronic, magnetic or any other nonpaper fonn or machine-readable medium.
10.

"Communication" means any transmission, exchange, or transfer of infonnation

by any means regardless of content, fonnat and medium.
I I.

"Identify" or "identity" with respect to a natural person or individual means

providing at least the following infonnation for him or her: (a) full name; (b) present address and
telephone number, or ifnot known, last known address and telephone number; (c) current
employer; (d) title or position; and (e) employment duties, functions, and/or responsibilities.
12.

"Identify" or "identity" with respect to Microsoft's products, devices, or other

articles of manufacture means providing the following infonnation: (a) any designation used

internally by Microsoft or Microsoft's employees for that product, device, or article of
manufacture, including formal or informal nicknames; and (b) any designation used publicly by
Microsoft or Microsoft's employees for that product, device, or article of manufacture, including
but not limited to the part or model number and name.
13.

"Identify" or "identity" with respect to communications means providing the

following information: (a) the identity of the person(s) creating such communication; (b) the
identity of the recipient(s) of such communication; (c) the date of the communication; and (d) the
nature, substance, and contents of the communication.
14.

"Concurrent Litigation" refers to any pending litigation between Motorola and

Microsoft, including but not limited to Civil Action Nos. 3: 10-CV-00699 (W.D. Wis.), 3:1O-CV00700 (W.D. Wis.), and 3:10-cv-00826 (W.D. Wis.); 2: 1O-cv-O 1823-JLR (W.D. Wash.); and
ITC Investigation Nos. 337-TA-744 and 337-TA-752.
15.

"'839 Patent" means U.S. Patent No. 5,502,839.

16.

"'899 Patent" means U.S. Patent No. 5,764,899.

17.

"'001 Patent" means U.S. Patent No. 5,784,001.

18.

"'333 Patent" means U.S. Patent No. 6,272,333.

19.

'''176 Patent" means U.S. Patent No. 6,408,176.

20.

"'544 Patent" means U.S. Patent No. 6,757,544.

21.

'''370 Patent" means U.S. Patent No. 6,983,370.

22.

"Application" means any patent application or similar document submitted or

filed anywhere in the world, including but not limited to any provisional application, continuing
application, continuation-in-part application, divisional application, file-wrapper continuation,
reexamination proceeding, reissue application, and abandoned application.

23.

"Asserted Patents" means the "'839 Patent"; the '''899 Patent"; the "'001 Patent";

the '''333 Patent"; the "'176 Patent"; the "'544 Patent"; and the "'370 Patent" (collectively, or
individually).
24.

"Related Patents and Applications" means any patent or Application submitted or

filed anywhere in the world that is related to any Asserted Patent, including but not limited to
any patent or Application that (i) claims priority in whole or in part to or from any Asserted
Patent, (ii) is the basis for a claim of priority in whole or in part for any Asserted Patent, or (iii)
discloses the same subject matter as any Asserted Patent.
25.

"Accused Windows Technology" means all Microsoft Windows® operating

system technology released since 2004, including but not limited to Windows Vista, Windows 7,
Windows Phone 7, Windows Phone 6.5, Windows Server 2008, Windows Server 2008 R2,
Windows CE, Windows Embedded Compact and all other Microsoft Windows® products,
including those identified at http://www.microsoft.comlwindows/products/default.aspx.
26.

"Application Programming Interface" means any software rules, specifications,

instruction sets, programs, routines, data structures, object classes, commands or protocols
designed or operable to facilitate communication between two different software applications or
programs.
27.

"Graphics" means any visual representation of data in an electronic medium,

including but not limited to graphics, bitmaps, images, symbols, icons, cursors, animation or
other media, and all constituents thereof such as points, lines, curves, shapes and polygons.
28.

"Accused Graphics Technology" means any Microsoft Application Programming

Interface or other Microsoft software released since 2004 and designed or operable to build,
draw, render, generate or composite Graphics, including but not limited to DirectDraw, DirectX,

Direct2D, Direct3D 9Ex, DirectX 10 and DirectX Next, Direct3D 10, Direct3D II, Windows
Presentation Foundation (WPF) (any and all versions), Microsoft Silverlight (any and all
versions, including Microsoft Silverlight for Windows Phone), Microsoft Surface and Microsoft
XNA Framework (any and all versions).
29.

"Messaging" means any direct communication or transmission of information in

human-usable form between two or more people using personal computers, phones or mobile
devices along with client software, such information including but not limited to e-mail
messages, instant messages, chat messages, text messages, short messaging service (SMS)
messages, multimedia messaging service (MMS) messages, and voicemail messages.
30.

"Accused Messaging Technology" means all Microsoft products, software,

instruction sets, programs, routines, data structures, obj ect classes, commands or protocols,
released since 2004 and designed or operable to implement Messaging, including but not limited
to Microsoft Exchange Server (any and all versions), Exchange ActiveSync (any and all
versions, including versions 2.0, 2.1, 2.5,12.0,12.1,14.0, and 14.1) and all server-side and
client-side components of Exchange ActiveSync, Exchange Server Unified Messaging Server
Role (any and all versions), Microsoft Office Communications Server (any and all versions),
Lync Server (any and all versions), Microsoft Office Communications Server (any and all
versions), Exchange Online, Lync Online, Office Communications Online, Office 365, Lync
2010 client (including Microsoft Lync 2010, Microsoft Communicator for Mac 2011, Microsoft
Lync 2010 Mobile), Microsoft Office Communicator client (any and all versions), Windows
Live Hotmail (any and all versions), Windows Live Messenger (any and all versions, including
versions 8.0, 8.1, 8.5, 14.0 (Windows Live Messenger 2009), and 15.0 (Windows Live
Messenger 2011)), Windows Live Messenger for Mobile (any and all versions), MSN Messenger

(any and all versions, including versions 6.0, 6.2, 7.0, and 7.5), Messenger for Mac (any and all
versions, including versions 6.0, 6.03, 7.01, 7.02, and 8.0), Microsoft Notification Protocol,
Mobile Status Notification Protocol (MSNP), and Microsoft's .NET Messenger Service.
31.

"Accused Application Registry Technology" means all Microsoft products,

software, instruction sets, programs, routines, data structures, object classes, commands or
protocols released since 2004 and designed or operable to present, register, transfer, download,
upload, copy or manage software applications executable on a phone or mobile device, including
but not limited to Marketplace (for Windows Phone 7) and Windows Marketplace for Mobile.
32.

"Accused Location-Based Technology" means all Microsoft products, software,

instruction sets, programs, routines, data structures, object classes, commands or protocols
released since 2004 and designed or operable to provide maps or other information determined
based on location or geography, including but not limited to Bing Maps, Bing Maps (or Bing) for
Mobile, Bing Maps Platform, Bing Maps for Enterprise, and Bing Maps Server, and all
Application Programming Interfaces for Bing Maps, including but not limited to Bing Maps
AJAX Control, Bing Maps Silverlight Control, Bing Maps SOAP Services, Bing Maps REST
Services, and Bing Spatial Data Services.
33.

"Accused Products" includes all Accused Windows Technology, Accused

Graphics Technology, Accused Messaging Technology, Accused Application Registry
Technology, and Accused Location-Based Technology.
34.

"Prior Art" means any publication, patent, physical device, prototype, product,

use, sale, offer for sale, or other activity concerning the subject matter of the Asserted Patents
and existing on, or occurring at, a date such as to be relevant under any subdivision of 35 U.S.C.
§§ 102 or 103.

35.

"Infringe" and "infringement" means any and all types of patent infringement set

forth in 35 U.S.c. § 271, including but not limited to direct infringement, contributory
infringement, active inducement of infringement, literal infringement, and/or infringement under
the doctrine of equivalents.
36.

"Technical Documentation" means documents that relate to structure, electronic

circuitry, operation, function, and/or features, including but not limited to user guides, user
manuals, reference manuals, service manuals, product manuals, use cases, product descriptions,
white papers, administrator guides, installation guides, technical manuals, technical
specifications, functional specifications, software manuals, software design documents, memory
maps, block diagrams, theory of operation documents, road maps, datasheets, schematics,
computer screen shots, prototype designs, assembly drawings, engineering drawings, software
design drawings or software programming code samples, and Microsoft Internet resources
(including Microsoft TechNet, Microsoft Developer Network (MSDN), and Microsoft Support).
37.

"'536 Patent" means U.S. Patent No. 6,791,536.

38.

'''853 Patent" means U.S. Patent No. 6,897,853.

39.

"'214 Patent" means U.S. Patent No. 7,024,214.

40.

"'130 Patent" means U.S. Patent No. 7,493,130.

41.

"'460 Patent" means U.S. Patent No. 7,383,460.

42.

"'904 Patent" means U.S. Patent No. 6,897,904.

43.

'''901 Patent" means U.S. Patent No. 6,785,901.

44.

"Microsoft Counterclaim Patents" means the '536 Patent, the '853 Patent, the

'214 Patent, the '130 Patent, the '460 Patent, the '904 Patent, and the '901 Patent (collectively,
or individually).

45.

"Accused Motorola Products" means all Motorola products and services that

Microsoft has alleged infringe one or more Microsoft Counterclaim Patents in this action,
including but not limited to the Motorola Droid 2, the Motorola Droid X, the Motorola
DCH6416, and the Motorola BMC9012.
INSTRUCTIONS

I.

Each Interrogatory requests that each and every part and particular thereof be

answered with the same force and effect as if each part and particular were the subject of, and
were asked by, a separate Interrogatory. Where an Interrogatory relates to more than one person
or subject, it is to be answered as to each such person or subject separately.
2.

Microsoft should furnish all information which is available to it as of the date of

its answers to these Interrogatories. If Microsoft is unable to answer any of the Interrogatories
fully and completely, after exercising due diligence to secure the information necessary to make
such full and complete answer, so state, and answer each such Interrogatory to the fullest extent
possible, specifying the extent of Microsoft's knowledge and inability to answer the remainder,
setting forth whatever information or knowledge Microsoft possesses concerning the unanswered
portions thereof and the efforts made to obtain the requested information.
3.

With respect to the answer to each Interrogatory, or subpart thereof, identify all

Persons and Documents consulted in preparing an answer thereto, and state the source of the
information given therein with as much particularity as is reasonably possible, including, without
limitation, the identity of each Person who provided any information included in such answer. In
addition, identify each other Person known or believed to have some or all of the information
sought in such Interrogatory or subpart thereof.

4.

When an Interrogatory or any of its subparts calls for the factual basis of any of

Microsoft's allegations or any of its answers, the request calls Microsoft to set forth and describe
each Document which Microsoft contends tends to support its allegation or answer and identify
each Person who possesses facts supporting the allegation or answer.
5.

If any document or thing is withheld subject to a claim of attorney-client

privilege, attorney work product immunity, or any other privilege or immunity from disclosure,
Microsoft shall describe in sufficient detail the nature of the information withheld, its date, a
description of the subject matter, the names and addresses of all Persons participating in the
protected communication, and a statement of the grounds for withholding the information, such
that will enable other parties to assess the claim of privilege or immunity.
6.

If any Interrogatory is answered by reference to a Document, identify and produce

the Document containing the requested information.
a)

If, in responding to any of these Interrogatories, Microsoft reviews

or relies on documents that it has not previously produced in this litigation,
Microsoft is requested to produce the documents and identify each document
reviewed or relied upon.
b)

If Microsoft responds to any of these Interrogatories by specifying

its business records pursuant to Fed. R. Civ. P 33(d), Microsoft is requested to
identify each business record by production number(s).
7.

Documents shall be produced as they are kept in the usual course of business or

shall be organized and labeled to correspond to the Interrogatory to which they are responsive. If
a Document is responsive to more than one Interrogatory it shall be labeled to correspond to each
numbered Interrogatory to which it is responsive.

8.

These Interrogatories are continuing

III

nature, and responses must be

supplemented in accordance with Fed. R. Civ. P 26(e).

If additional information is later

discovered that is responsive to these Interrogatories, supplemental responses disclosing that
information must be submitted as promptly as possible.
INTERROGATORIES
INTERROGATORY NO.1

Separately for each release and/or version of each of the Accused Products, if Microsoft
contends that such product does not meet each and every limitation of any claim of the Asserted
Patents, please provide the legal and factual bases for Microsoft's contention(s), including:
(a)

the identity of any claim term(s) of the Asserted Patents that Microsoft contends
requires construction, how Microsoft contends that such term(s) should be
construed, and the intrinsic evidence (i.e. specific portions of claim language,
specification language, and the prosecution history) and extrinsic evidence that
supports such a construction;

(b)

the identity of each claim element that Microsoft contends is not literally satisfied
by such product or the use thereof, and a full explanation as to why it is not;

(c)

for each element that Microsoft contends is not literally satisfied, a full
explanation of why it is not satisfied under the doctrine of equivalents in light of
both the function/way/result test and the insubstantial differences test;

(d)

the full basis for any contention that the application of the doctrine of equivalents
is limited such as by prosecution history estoppel; and

(e)

the identity of the person(s) most knowledgeable concerning the facts underlying
each such contention.

INTERROGATORY NO.2
Separately for each release and/or version of each of the Accused Products, if Microsoft
contends that it does not indirectly infringe any of the Asserted Patents by inducement of
infringement, please provide the full legal and factual bases for Microsoft's contention(s) and the
identity of the person(s) most knowledgeable concerning the facts underlying each such
contention.

INTERROGATORY NO.3
Separately for each release and/or version of each of the Accused Products, if Microsoft
contends that it does not indirectly infringe any of the Asserted Patents through contributory
infringement, please provide the full legal and factual bases for Microsoft's contention(s),
including whether and why Microsoft contends that the product is (a) not especially made or
especially adapted for use in an infringement of such patent; (b) a staple article or commodity of
commerce suitable for substantial noninfringing uses, and the identity of the person( s) most
knowledgeable concerning the facts underlying each such contention.

INTERROGATORY NO.4
Separately for each claim, if any, of the Asserted Patents that Microsoft contends is
invalid under 35 U.S.C. §§ 101, 112, 113 or 133 or on any other basis, please describe in detail:
(a)

all factual and legal bases for Microsoft's contention that the claim is invalid;

(b)

the identity of all documents tending to support or refute each such contention;
and

(c)

the identity of the person(s) most knowledgeable concerning the facts underlying
each such contention.

INTERROGATORY NO.5
Separately for each claim, if any, of the Asserted Patents that Microsoft contends is
invalid as anticipated under 35 U.S.C. § 102, please:
(a)

identifY all prior art on which Microsoft relies;

(b)

identifY under what subsection(s), if any, of § 102 each reference, activity, etc.
qualifies as prior art;

(c)

identifY the effective date for each piece of prior art;

(d)

identifY specifically how the prior art anticipates or renders obvious the claim on
an element by element (e.g., claim chart) basis; and

(e)

identifY the person(s) most knowledgeable concerning the facts underlying each
such contention.

INTERROGATORY NO.6
Separately for each claim, if any, of the Asserted Patents that Microsoft contends is
invalid for obviousness under 35 U.S.C. § 103, please:
(a)

identifY all prior art on which Microsoft relies and explain how the prior art is to
be modified and/or combined;

(b)

identifY the reason, motivation, suggestion and/or teaching to modifY or combine
the prior art in such a manner;

(c)

identifY all evidence that supports Microsoft's obviousness contentions; and

(d)

identifY the person(s) most knowledgeable concerning the facts underlying each
such contention.

INTERROGATORY NO.7
Please state Microsoft's contention(s) as to the field of art and the level of ordinary skill
in that art pertinent to the issue of obviousness/nonobviousness under 35 U.S.C. § 103 with
respect to each of the Asserted Patents and identify the person(s) most knowledgeable
concerning the facts underlying each such contention.

INTERROGATORY NO.8
Please state in detail all factual and legal bases for Microsoft's contention(s), if any,
regarding any "objective evidence" or "secondary considerations" of non-obviousness for each
of the Asserted Patents in accordance with, for example, Graham v. John Deere Co., 383 U.S. I,
17 (1966), and identify the person(s) most knowledgeable concerning the facts underlying each
such contention.

INTERROGATORY NO.9
Separately for each, if any, of the Asserted Patents to which Microsoft contends that it
has any Affirmative Defense(s) to a claim of infringement that has not been specifically
addressed by the preceding interrogatories, please describe in detail all factual and legal bases for
Microsoft's contention(s), including the identity of all documents tending to support or refute
any such contention, and the identity of the person(s) most knowledgeable concerning the facts
underlying any such contention.

INTERROGATORY NO. 10
Separately for each release and/or version of each of the Accused Products, identify in
descending order of knowledge the three persons currently or formerly employed by Microsoft
who are most knowledgeable about each of the following topics concerning each Accused
Product:
(a)

structure, operation, and function;

(b)

design and development;

(c)

source code and object code;

(d)

Application Programming Interfaces and communication protocols, if any;

(e)

testing and deployment;

(f)

marketing, advertising, and promotion;

(g)

any formal or informal training, teclmical support, and customer feedback;

(h)

offers for sale;

(i)

licensing;

(j)

pricing;

(k)

sales;

(1)

financial reporting;

(m)

business planning and product management;

(n)

competition for licensing or sales of the Accused Products, in the United
States; and

(0)

any formal or informal tests, studies, comparisons, analyses, or reports, in
any form, involving, referring, or relating to the Accused Products.

INTERROGATORY NO. 11

Separately for any product for which any efforts were made to design around any of the
Asserted Patents to avoid infringing any claim of such patent, identifY such product(s) and
patent(s), describe those design-aronnd effort(s), and identifY in descending order of knowledge
the three persons currently or formerly employed by Microsoft who are most knowledgeable
about the facts and circumstances concerning those design-around efforts.

INTERROGATORY NO. 12
Identify and describe the circumstances under which Microsoft first became aware of
each of the Asserted Patents, including without limitation an identification of the source,
circumstances and timing of such awareness, an identification of all documents and
communications evincing such awareness, and all actions taken by or on behalf of Microsoft, its
directors, its officers, and its employees to evaluate or avoid infringing any such patent once
Microsoft became aware of each of the patents.
INTERROGATORY NO. 13
Identify and describe the results of all analyses, investigations, evaluations or other
studies known to Microsoft concerning the Asserted Patents, including analyses, investigations,
evaluations and studies concerning infringement/non-infringement, validity/invalidity (including
but not limited to any searches for prior art), enforceability/unenforceability, patentability, scope,
or interpretation of any claim of any of the Asserted Patents, including without limitation the
dates of any such study, the persons who conducted or prepared it, the persons who received or
to whom such study was reported, the subj ect matter of the study, and all documents constituting,
referring or relating thereto.
INTERROGATORY NO. 14
Separately for each release and/or version of each of the Accused Products and on a
quarterly and annual basis from January 2004 through the present, provide the:
(a)

total sales and/or revenues (in gross revenues, net revenues, and units)attributable
to sale or license of the Accused Product: (i) in the United States; and (ii) outside
of the United States;

(b)

itemized costs (including fixed, variable, and incremental), including but not
limited to any licensing fees, payments (including settlement payments), or

royalties paid by Microsoft in connection with an Accused Product (or any
component or element thereof), and specifying: (i) the name ofthe licensor, payee
or royalty recipient; (ii) the amount of each such fee, payment or royalty; (iii) the
time period during which such fee, payment or royalty was paid; and (iv) the
name of the product, component and/or element to which such fee, payment or
royalty relates; and
(c) profits (gross and net).
INTERROGATORY NO. 15

Separately, for each claim of each of the Microsoft Counterclaim Patents alleged to be
infringed by Motorola, either directly or indirectly, specifically identify each and every product,
apparatus, or method that Microsoft asserts is infringing; and state the legal and factual bases for
Microsoft's contention(s), including:
(a)

whether Microsoft contends that the alleged infringement is direct infringement,
induced infringement, and/or contributory infringement;

(b)

whether the alleged infringement is literal, under the doctrine of equivalents, or
both;

(c)

describe in detail where each element, limitation, or step of each claim is found,
i. e., read each claim on each accused product, apparatus, and method by

providing, separately for each claim element and product or activity, a claimelement by claim-element comparison of each claim to the corresponding
structure or function of the accused product or activity.
(d)

the identity of any claim term( s) of the Microsoft Counterclaim Patents that
Microsoft contends requires construction, how Microsoft contends that such
term(s) should be construed, and the intrinsic evidence (i.e. specific portions of

claim language, specification language, and the prosecution history) and extrinsic
evidence that supports such a construction;
(e)

the identity of the person(s) most knowledgeable concerning the facts underlying
each such contention.

January 21, 2011

Re~
Edward M. Mullins, Fla. Bar No. 863920
[e-mail]
Hal M. Lucas, Fla. Bar No. 0853011
[e-mail]
Astigarraga Davis Mullins
& Grossman, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Tel.: [phone]; Fax. [phone]
Local Counsel for Plaintiff,
MOTOROLA MOBILITY, INC.

Of Counsel:

Jesse J. Jenner
(admitted pro hac vice)
Steven Pepe
(admitted pro hac vice)
Ropes & Gray LLP
1211 Avenue of the Americas
New York, NY 10036
Telephone: [phone]
Facsimile: [phone]
Norman H. Beamer
(admitted pro hac vice)
Mark D. Rowland
(admitted pro hac vice)
Gabrielle E. Higgins

(admitted pro hac vice)
Ropes & Gray LLP
1900 University Avenue, 6th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Lead Counsel for Plaintiff,
MOTOROLA MOBILITY, INC.

CERTIFICATE OF SERVICE

I hereby certify that the foregoing Plaintiff Motorola Mobility, Inc.' s First Set Of
Interrogatories (Nos. 1-15) To Defendant Microsoft Corporation was caused to be served this
day by hand upon the counsel of record included in the attached Service List.

Edward M. Mullins

SERVICE LIST

Motorola Mobility, Inc. v. Microsoft Corp., Case No.1: 10-cv-24063-MORENO/TORRES
Roberto Martinez, Esq.
Curtis Miner, Esq.
COLSON HICKS EIDSON
255 Alhambra Circle, Penthouse
Coral Gables, Florida 33134
Attorneys for Defendant and Counterclaim Plaintiff, Microsoft Corporation

Of Counsel:
David T. Pritikin
Richard A. Cederoth
Douglas I. Lewis
John W. McBride
SIDLEY AUSTIN LLP
One South Dearborn
Chicago, IL 60603
Brian R. Nester
Kevin C. Wheeler
SIDLEY AUSTIN LLP
1501 K Street NW
Washington, DC 20005