Wireless Recognition Technologies LLC v. A9.com, Inc. et al

Filing 68

RESPONSE in Opposition re 62 Opposed MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. § 1404(a)Opposed MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. § 1404(a)Opposed MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. § 1404(a) filed by Wireless Recognition Technologies LLC. (Attachments: # 1 Exhibit A - Declaration of Bradley J. Botsch, # 2 Exhibit B - Declaration of Craig Yudell, # 3 Exhibit C - "Hiding in Plain Sight, Google Seeks More Power," The New York Times, June 14, 2006, # 4 Exhibit D - Areas of Focus at Bangalore Center, Amazon Development Center, India, # 5 Exhibit E - Areas of Focus at Bangalore Center, Amazon Development Center, India, # 6 Exhibit F - Nokia Point & Find, May 17, 2010, # 7 Exhibit G - Unicorn Media Company, Executive Staff, # 8 Exhibit H - Unicorn Media Contact Information, # 9 Exhibit I - Declaration of Raymond F. Ratcliff, III, July 24, 2001, # 10 Exhibit J - U.S. Patent No. 7,392,287, # 11 Exhibit K - Revocation and Appointment of New Power of Attorney of Craig Yudell, February 19, 2009, # 12 Exhibit L - Power of Attorney Regarding Pillsbury Winthrop LLP, July 24, 2002, # 13 Exhibit M - Correspondence from Kelber to Assistant Commissioner for Patents, Regarding Revocation of Power of Attorney and New Power of Attorney Re Piper Rudnick LLP, April 21, 2004, # 14 Exhibit N - July 19, 2007 Amendment Re '287 Patent, # 15 Exhibit O - Northern District of California Judicial Caseload Profile, # 16 Exhibit P - Eastern District of Texas Judicial Caseload Profile, # 17 Exhibit Q - NovelPoint Learning LLC v. LeapFrog Enterprises, Inc., et al., Case No. 6:10-cv-229, (EDTX), Dkt. 67 Memorandum Opinion and Order, # 18 Exhibit R - Optimum Power Solutions LLC v. Apple Inc., et al., Case No. 6:10-cv-61 (EDTX), Dkt. 69 Defendant's Initial Disclosures, # 19 Exhibit S - Calypso Wireless, Inc. and Drago Daic v. T-Mobile USA, Inc., Case No. 2:08-cv-441 (EDTX), Dkt. 146, Order Denying Motion to Transfer)(Davis, William) (Additional attachment(s) added on 4/28/2011: # 20 Text of Proposed Order) (ch, ).

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EXHIBIT R Case 6:10-cv-00061-LED Document 69-3 Filed 09/22/10 Page 1 of 9 EXHIBIT C Case 6:10-cv-00061-LED Document 69-3 Filed 09/22/10 Page 2 of 9 Case 6:10-cv-00061-LED Document 69-4 Filed 09/22/10 Page 1 of 11 EXHIBIT D Case 6:10-cv-00061-LED Document 69-4 Filed 09/22/10 Page 2 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION OPTIMUM POWER SOLUTIONS LLC, Plaintiff, v. Case No. 6:10cv61-LED APPLE, INC., et al., Defendants. DELL INC.’S INITIAL DISCLOSURES Defendant Dell Inc. provides these initial disclosures in compliance with the Federal Rules of Civil Procedure, the Local Rules of the Eastern District of Texas, and the parties’ agreement memorialized in the Plaintiff’s Unopposed Motion for Extension of Time to Respond to Defendant’s Motion to Transfer Venue entered on August 19, 2010 (DKT# 50) and subsequently granted on August 25, 2010 (DKT# 51). These initial disclosures are based on information reasonably available to Dell at this time. Dell reserves the right to amend or supplement these disclosures based upon its continuing investigations and ongoing discovery. Dell’s disclosures are made without in any way waiving: (1) the right to object to such information on the grounds of competency, privilege, the work product doctrine, undue burden, relevancy and materiality, hearsay, and any other proper ground; (2) the right to object to the use of any such information, for any purpose, in whole or in part, in any subsequent proceeding in this action or any other action; and (3) the right to object on any and all grounds, at any time, to any discovery request or proceeding involving or relating to the subject matter of these disclosures. Case 6:10-cv-00061-LED Document 69-5 Filed 09/22/10 Page 1 of 11 EXHIBIT E Case 6:10-cv-00061-LED Document 69-5 Filed 09/22/10 Page 2 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION OPTIMUM POWER SOLUTIONS LLC, a Texas Limited Liability Company, Civil No. 6:10-CV-00061-LED Plaintiff, Before: Leonard E. Davis vs. APPLE INC., a California corporation, DELL INC., a Delaware corporation, HEWLETTPACKARD COMPANY, a California corporation, LENOVO (UNITED STATES) INC., a Delaware corporation, and SONY ELECTRONICS, INC., a Delaware corporation, Defendants. DEFENDANT HEWLETT-PACKARD COMPANY’S INITIAL DISCLOSURES Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, and the Court’s Orders of July 29, 2010 and August 25, 2010, Defendant Hewlett-Packard Company (“HP”) hereby provides the following Initial Disclosures. Pursuant to Rule 26(e) of Federal Rules of Civil Procedure, HP reserves the right to modify or supplement the information produced in these Initial Disclosures. HP further reserves the right to use and introduce such supplemental information or any subsequently identified or produced testimony, information, or documents at the trial of this action. HP does not waive any evidentiary objections to the information disclosed herein nor any applicable privileges or protections from discovery. HP’s disclosures are also made without waiving in any way: (1) the right to object on the grounds of competency, privilege, relevancy, and materiality, hearsay, or any other proper ground, to the use of such information, for any purpose, in whole or in part, in any subsequent proceeding in this action or any other action; and (2) the right to Case 6:10-cv-00061-LED Document 69-6 Filed 09/22/10 Page 1 of 9 EXHIBIT F Case 6:10-cv-00061-LED Document 69-6 Filed 09/22/10 Page 2 of 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION OPTIMUM POWER SOLUTIONS LLC, Plaintiff, v. APPLE INC., DELL INC., HEWLETT PACKARD COMPANY, LENOVO (UNITED STATES) INC., and SONY ELECTRONICS, INC., Defendants. § § § § § § § § § § § Civil Action No. 6:10-cv-61 (LED) Jury Trial Demanded DEFENDANT LENOVO (UNITED STATES) INC.’S INITIAL DISCLOSURES Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure and the Court’s Discovery Order, Defendant Lenovo (United States) Inc. (hereafter “Lenovo”) respectfully submits the following initial disclosures of information. These disclosures are based upon the information reasonably available to Lenovo at this time. Lenovo’s investigation is on-going. As discovery progresses, Lenovo reserves the right to revise, clarify, or supplement these disclosures pursuant to Rule 26(e)(1) of the Federal Rules of Civil Procedure or any other applicable rule. Information or materials protected by the attorney-client privilege and/or work product doctrine will not be disclosed as part of these initial disclosures. Lenovo reserves the right to object to the production and/or introduction of evidence of these disclosures and/or any document within the categories described below as well as to any testimony by any of the disclosed witnesses on the basis of competency, privilege, relevancy, materiality, hearsay, undue burden, or any other proper ground. 1 Defendant Lenovo (United States) Inc.’s Initial Disclosures Case 6:10-cv-00061-LED Document 69-7 Filed 09/22/10 Page 1 of 9 EXHIBIT G Case 6:10-cv-00061-LED Document 69-7 Filed 09/22/10 Page 2 of 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION OPTIMUM POWER SOLUTIONS LLC, Plaintiff; v. APPLE INC., DELL INC., HEWLETT PACKARD COMPANY, LENOVO (UNITED STATES) INC., and SONY ELECTRONICS INC., Case No. 6:10CV61 LED Defendants. INITIAL DISCLOSURES OF SONY ELECTRONICS INC. PURSUANT TO FED. R. CIV. P. 26(a)(1) AND DISCOVERY ORDER Pursuant to FED. R. CIV. P. 26(a)(1) Defendants Sony Electronics Inc. (“SEL”), by and through its undersigned counsel, hereby submit the following Initial Disclosures. These disclosures are based upon information reasonably available to the SEL at this time. SEL reserves the right to amend or supplement these disclosures as necessary during the course of discovery. By making these disclosures, SEL does not waive any applicable privilege, work product protection, or other objection, and reserve its rights to object to the production or admissibility of any information included in the categories below. SEL hereby incorporates by reference the Initial Disclosures of Apple Inc., Dell Inc.; Hewlett Packard Company, and Lenovo (United States) Inc. A. CORRECT NAMES OF THE PARTIES TO THE LAWSUIT The correct name of defendant SEL is Sony Electronics Inc.

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