In Re Application for Order Enforcing a Subpoena

Filing 1

APPLICATION for an order enforcing a subpoena Filing fee: $ 39, receipt number 0101-3391886 (Fee Status: Filing Fee paid) (Attachments: # 1 Memorandum in Support of TriQuint Motion to Compel, # 2 Affidavit of Laura T. Ewbank in Support of TriQuint's Motion to Compel, # 3 Exhibit A to Ewbank Aff., # 4 Exhibit B to Ewbank Aff., # 5 Exhibit C to Ewbank Aff., # 6 Exhibit D to Ewbank Aff.) (Burroughs, Allison) (Entered: 05/05/2011)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

TriQuint Semiconductor, Inc., a Delaware
corporation,

CIVIL ACTION NO. 11-91114

Plaintiff/Counterdefendant,
v.
Avago Technologies Limited, a Singapore
corporation; Avago Technologies U.S.,
Inc., a Delaware corporation, Avago
Technologies Wireless IP (Singapore) Pte.,
Ltd., a Singapore corporation,
Defendants/Counterclaimants.

PLAINTIFF'S MOTION TO COMPEL NON-PARTY SKYWORKS SOLUTIONS, INC.
TO PRODUCE DOCUMENTS REQUESTED IN THE SUBPOENA DUCES TECUM
Plaintiff TriQuint Semiconductor, Inc., ("TriQuint") moves the Court to compel nonparty Skyworks Solutions, Inc. ("Skyworks") to produce documents requested in the subpoena
duces tecum served on September 15, 2010. TriQuint has subpoenaed a narrow range of
documents from Skyworks, but despite Skyworks' confirmation that it is in possession of
documents responsive to the subpoena and numerous meet and confer conversations between the
parties over the past seven months, Skyworks has refused to search for and produce all
documents responsive to TriQuint's request.
WHEREFORE, for the reasons set forth more fully in the accompanying memorandum
and affidavit, Skyworks should ordered to produce documents responsive to the subpoena.

Dated: May 5, 2011

Respectfully submitted,
TRIQUINT SEMICONDUCTOR, INC.,
/s/ Allison D. Burroughs
Allison D. Burroughs (BBO# 609346)
NUTTER McCLENNEN & FISH LLP
World Trade Center West
155 Seaport Boulevard
Boston, Massachusetts 02210
Telephone: [phone]
Fax: [phone]
-and/s/ Debra R. Bernard
Debra R. Bernard
Laura T. Ewbank
PERKINS COIE, LLP
131 South Dearborn St. Suite 1700
Chicago, IL 60603-5559
Telephone: [phone]
Fax: [phone]

LOCAL RULE 7.1 AND 37.1 CERTIFICATION
I hereby certify that counsel for Plaintiff conferred with counsel for Skyworks and
attempted in good faith to resolve or narrow the issues presented in this motion. Laura Ewbank,
Katherine Galipeau, Susan Foster and/or Debra Bernard on behalf of TriQuint, and Robert Terry
and/or Dan Sasse on behalf of Skyworks, conferred by telephone on October 5, 15, and 21, 2010,
November 2, 2010, December 7, 2010, February 25, 2011, March 10, 2011, April 15 and 19,
2011, and May 3, 2011.
/s/ Allison D. Burroughs
CERTIFICATE OF SERVICE
I hereby certify that, on May 5, 2011, a copy of the foregoing document was filed
through the electronic filing system and served by email and first class mail to counsel for
Skyworks and counsel for Avago Technologies.
/s/ Allison D. Burroughs
2010039

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