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 B

I

RELL

& MANELLA

LLP

A REGISTERED LIMITED LIABILITY LAW PARTNERSHIP
INCLUDING PROFESSIONAL CORPORATIONS
840 NEWPORT CENTER DRIVE, SUITE 400

18 0 0 AV E N U E O F T H E S TA R S , S U I T E 9 0 0

TELEPHONE [phone]

L O S A N G E L E S , C A L I F O R N I A 9 0 0 6 7 - 4 276

FACSIMILE [phone]

NEWPORT BEACH, CA 92660-6324
TELEPHONE [phone]
FACSIMILE [phone]

WEBSITE:

www.irell.com

WRITER'S DIRECT
TELEPHONE [phone]

[e-mail]

June 28, 2011

VIA E-MAIL
Susan Baker Manning, Esq.
Bingham McCutchen LLP
2020 K Street NW
Washington, DC 20006-1806
Audrey Lo, Esq.
Bingham McCutchen LLP
1900 University Avenue
East Palo Alto, CA 94303-2223
Dear Susan and Audrey:
We sent a letter more than a week ago proposing that the parties begin producing
documents now 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. You have
not responded, and the Court still has not entered a protective order. We assume your lack
of a response is a no. Pursuant to Local Rule 37.1, we would like to schedule a discovery
conference this week before bringing a motion to compel on this issue. Please let me know
your availability.
Sincerely,
/s/ Lina F. Somait
Lina F. Somait

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