Rockstar Consortium US LP et al v. Google Inc

Filing 177

NOTICE by Nortel Networks Inc re 150 MOTION for Protective Order Regarding Privileged and Confidential Nortel Documents , Providing Notice of Filings in Nortel Bankruptcy Proceeding (Attachments: # 1 Exhibit A - Notice of Debtors Motion for Bankruptcy Relief re Third-Party Discovery, # 2 Exhibit B - Debtors' Motion for Bankruptcy Relief re Third-Party Discovery, # 3 Exhibit C - Ross Declaration ISO Bankruptcy Motion, # 4 Exhibit D - Notice of Cost-Sharing Motion, # 5 Exhibit E - Cost Sharing Motion)(Supko, Mark)

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
Marshall Division
ROCKSTAR CONSORTIUM US LP and
NETSTAR TECHNOLOGIES LLC,
Plaintiffs,
Case No. 2:13-cv-00893-JRG-RSP
v.
GOOGLE INC.,
Defendant.
NON-PARTY NORTEL NETWORKS INC.’S NOTICE OF
FILINGS IN BANKRUPTCY PROCEEDING
Non-party Nortel Networks Inc. (“NNI”) hereby notifies the Court and all parties of
record that NNI has filed the following documents in the bankruptcy proceeding styled In re
Nortel Networks Inc., et al., Chapter 11 Case No. 09-10138 (KG) (Bankr. D. Del.):
1.

Notice of Debtors’ Motion for (A) an Order Enforcing and/or
Extending the Automatic Stay, (B) an Order Enforcing the Court’s
Prior Orders, (C) Protective Order, and (D) Related Relief Under
Section 105(a);

2.

Debtors’ Motion for (A) an Order Enforcing and/or Extending the
Automatic Stay, (B) an Order Enforcing the Court’s Prior Orders, (C)
Protective Order, and (D) Related Relief Under Section 105(a);

3.

Declaration of Timothy C. Ross in Support of Debtors’ Motion for (A)
an Order Enforcing and/or Extending the Automatic Stay, (B) an
Order Enforcing the Court’s Prior Orders, (C) Protective Order, and
(D) Related Relief Under Section 105(a) (“Ross Declaration”);

4.

Notice of Debtors’ Motion Pursuant to 11 U.S.C. §§ 105 and 363 for
Entry of an Order Approving the Sharing of Costs Related to ThirdParty Discovery; and

5.

Debtors’ Motion Pursuant to 11 U.S.C. §§ 105 and 363 for Entry of an
Order Approving the Sharing of Costs Related to Third-Party
Discovery.

Copies of the foregoing documents, with the exception of the lengthy exhibits to the
Appendix to the Ross Declaration, are attached hereto as Exhibits A through E. Those exhibits,
which consist of eighteen (18) subpoenas that have been served on NNI, former NNI employees
(most of whom are attorneys), and former NNI legal and business advisors in connection with
various pending litigations involving patents that NNI and other Nortel entities jointly sold to
Rockstar Bidco, LP in June of 2011 will be filed separately. For this filing, only the first page of
each subpoena is included for identification.
Respectfully submitted,
September 26, 2014

/s/ Mark M. Supko
Mark M. Supko
Crowell & Moring LLP
1001 Pennsylvania Avenue, NW
Washington, DC 20004
202.624.2500 (phone)
202.628.5116 (fax)
[e-mail]
Attorneys for Nortel Networks Inc.

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who have consented to
electronic service are being served with a copy of this document via the Court’s CM/ECF system
per Local Rule CV-5(a)(3) on this 26th day of September, 2014.
/s/ Mark M. Supko
Mark M. Supko

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