Apple Inc.

Filing 1

COMPLAINT Ex Parte Application for An Order Pursuant to 28 U.S.C. 1782 Granting Leave to Obtain Discovery for Use in Foreign Proceedings and Supporting Memorandum against Apple Inc. ( Filing fee $ 350 receipt number 0540-3410912.), filed by Apple Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Declarataion of Christine Saunders Haskett in Support, # 4 Haskett Ex. 1, # 5 Haskett Ex. 2, # 6 Haskett Ex. 3)(Haslam, Robert)

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS

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In re Ex Parte Application of

Case No.

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APPLE INC.; APPLE RETAIL
GERMANY GMBH; and APPLE SALES
INTERNATIONAL,

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Applicants,

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[PROPOSED] ORDER GRANTING
APPLE’S EX PARTE APPLICATION
FOR AN ORDER PURSUANT TO 28
U.S.C. § 1782 GRANTING LEAVE
TO OBTAIN DISCOVERY FOR USE
IN FOREIGN PROCEEDINGS

For an Order Pursuant to 28 U.S.C. § 1782
Granting Leave to Obtain Discovery from
Ericsson Inc. for Use in Foreign
Proceedings.

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ORDER RE EX PARTE APPLICATION
PURSUANT TO 28 U.S.C. § 1782

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This matter comes before the Court on the Ex Parte Application of Apple Inc.;

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Apple Retail Germany GmbH; and Apple Sales International (“Apple”) for an Order to

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Obtain Discovery for Use in Foreign Proceedings pursuant to 28 U.S.C. § 1782(a) (the

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“Application”), which seeks documents from Ericsson Inc. (“Ericsson”) in connection with

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various foreign patent litigations pending between Apple and Motorola, Inc., Motorola

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Mobility, Inc. and their affiliates.

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The Court, having fully considered the papers on file and submitted herewith, and
good cause appearing:
HEREBY GRANTS the Application of Apple.

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IT IS HEREBY ORDERED THAT APPLE IS GRANTED LEAVE TO issue a
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subpoena for documents in substantially the form attached as Exhibit B to the Application,
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directing Ericsson to produce the documents requested in the subpoena at the offices of
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counsel for Apple, Covington & Burling LLP, One Front Street, San Francisco, CA or another
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location mutually agreeable to Apple and Ericsson.
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It is further ORDERED that copies of the Application and Memorandum in Support
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thereof and this Order shall be mailed to the following:
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Ericsson Inc.
6300 Legacy Drive, Plano, Texas, 75025

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IT IS SO ORDERED.

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Dated:

_
United States District Judge

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ORDER RE EX PARTE APPLICATION
PURSUANT TO 28 U.S.C. § 1782