Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 37

Letter/request (non-motion) from Skyhook Wireless, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Somait, Lina)

EXHIBIT A

I

RELL

& MANELLA

LLP

A REGISTERED LIMITED LIABILITY LAW PARTNERSHIP
INCLUDING PROFESSIONAL CORPORATIONS
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WRITER'S DIRECT
TELEPHONE [phone]

[e-mail]

June 20, 2011

VIA E-MAIL
Susan Baker Manning, Esq.
Bingham McCutchen LLP
2020 K Street NW
Washington, DC 20006-1806
Re:

Skyhook Wireless, Inc. v. Google Inc.,
Case No. 10-cv-11571-RWZ (D. Mass.)

Dear Susan:
As you know, the Court has not yet issued a ruling on Skyhook's and Google's crossmotions for a protective order. While we are hopeful that the Court will soon enter a
protective order, given the upcoming claim construction deadlines, we believe that the
parties should begin producing documents now, including at least the documents that should
have been produced with the parties' preliminary disclosures under Local Rule 16.6 as well
as any documents that would be useful to the claim construction process.
We therefore propose that the parties produce documents with the understanding that
they will be treated under the terms of Google's proposed protective order until a final
protective order is entered by the Court. At that point, the documents would then be treated
in accordance with the Court-issued protective order.
Please let me know whether Google is amenable to this proposal.
We look forward to your response.
Sincerely,
/s/ Lina F. Somait
Lina F. Somait

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