Sprint Communications Company LP v. Vonage Holdings Corp., et al

Filing 87

NOTICE by Defendants theglobe.com, Inc., Voiceglo Holdings, Inc. of taking deposition of Sprint Communications Company L.P. on April 20, 2006. (Nehrbass, Scott)

Sprint Communications Company LP v. Vonage Holdings Corp., et al

Doc. 87

Case 2:05-cv-02433-JWL

Document 87

Filed 04/11/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS SPRINT COMMUNICATIONS COMPANY L.P., Plaintiff, - against THEGLOBE.COM, INC., VOICEGLO HOLDINGS, INC., VONAGE HOLDINGS CORP., and VONAGE AMERICA, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 05-2433 JWL

NOTICE OF DEPOSITION PLEASE TAKE NOTICE that pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, defendant Voiceglo Holdings, Inc. will take the deposition upon oral examination of the plaintiff, Sprint Communications Company L.P. ("SCC"), by a person having knowledge of the following matters: 1. The factual basis of the allegation, made in paragraph 20 of the First Amended

Complaint, that defendant Voiceglo Holdings, Inc. ("Voiceglo") allegedly is "infringing the `572 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patents." 2. The factual basis of the allegation, made in paragraph 25 of the First Amended

Complaint, that defendant Voiceglo allegedly is "infringing the `561 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patents." 3. The factual basis of the allegation, made in paragraph 30 of the First Amended

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Case 2:05-cv-02433-JWL

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Complaint, that defendant Voiceglo allegedly is "infringing the `052 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patent." 4. The factual basis of the allegation, made in paragraph 35 of the First Amended

Complaint, that defendant Voiceglo allegedly is "infringing the `932 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patent." 5. The factual basis of the allegation, made in paragraph 40 of the First Amended

Complaint, that defendant Voiceglo allegedly is "infringing the `429 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patent." 6. The factual basis of the allegation, made in paragraph 45 of the First Amended

Complaint, that defendant Voiceglo allegedly is "infringing the `064 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patent." 7. The factual basis of the allegation, made in paragraph 50 of the First Amended

Complaint, that defendant Voiceglo allegedly is "infringing the `294 Patent by making, using, selling, offering for sale, contributing to the use by others, and/or inducing others to use products and services that infringe Sprint's patent." 8. The factual basis of plaintiff's pleaded allegations that Voiceglo's alleged

infringement of patents identified in the First Amended Complaint has been "willful and deliberate."

9.

The factual basis of plaintiff's Answer to Interrogatory No. 1 of Voiceglo's First

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Set of Interrogatories to plaintiff, including without limitation the location and identity of the particular apparatus and acts referred to in the right hand column of Exhibit A to plaintiff's Answer to Interrogatory No. 1 of Voiceglo's First Set of Interrogatories to plaintiff. The deposition will proceed at the offices of Foulston, Siefkin LLP, 9 Corporate Woods, Suite 450, 9200 Indian Creek Parkway, Overland Park, Kansas 66210, commencing at 10:00 a.m. on April 20, 2006, and continuing thereafter from day-to-day until concluded. The

deposition will be recorded stenographically and on videotape. You are invited to attend and cross-examine. Dated: April 11, 2006 FOULSTON SIEFKIN LLP By /s/ Scott C. Nehrbass James D. Oliver (#8604) Scott C. Nehrbass ( #16285) 9 Corporate Woods, Suite 450 9200 Indian Creek Parkway Overland Park, Kansas 66210 Telephone: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] James W. Dabney (admitted pro hac vice) Henry C. Lebowitz (admitted pro hac vice) Malcolm J. Duncan (admitted pro hac vice) FRIED, FRANK, HARRIS, SHRIVER & JACOBSON LLP One New York Plaza New York, New York 10004 Telephone: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail]

ATTORNEYS FOR DEFENDANTS THEGLOBE.COM, INC. and VOICEGLO HOLDINGS, INC. 3

Case 2:05-cv-02433-JWL

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CERTIFICATE OF SERVICE I hereby certify that on this 11th day of April, 2006, I electronically filed the above and foregoing with the clerk of the court by using the CM/ECF system, which will send a notice of electronic filing to the following: Trent Webb [e-mail] Adam P. Seitz [e-mail] Eric A. Buresh [e-mail] Shook Hardy & Bacon L.L.P. 2555 Grand Blvd. Kansas City, MO 64108-2613 Telephone: [phone] Fax: [phone] ATTORNEYS FOR PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P. Don R. Lolli [e-mail] Patrick J. Kaine [e-mail] Dysart Taylor Lay Cotter & McMonigle, P.C. 4420 Madison Avenue Kansas City, MO 64111 Telephone: [phone] Fax: [phone] Patrick D. McPherson [e-mail] Patrick C. Muldoon [e-mail] Barry Golob [e-mail] Duane Morris, LLP 1667 K Street, N.W. Washington, DC 20006-1608 Telephone: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANT VONAGE HOLDINGS CORPORATION AND VONAGE AMERICA, INC. /s/ Scott C. Nehrbass
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