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)

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UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
Chapter 11
In re
Case No. 09-10138 (KG)
Nortel Networks Inc., et al.,
Jointly Administered
Debtors.

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) A PROTECTIVE
ORDER, AND (D) RELATED RELIEF UNDER SECTION 105(A)
I, Timothy C. Ross, state and declare as follows:
1.

I am the Chief Financial Officer and Corporate Secretary for Nortel Networks Inc.

(“NNI”), and I have served in this role since May 31, 2013. I have primary management
responsibility for the day-to-day operations of the company as it winds down in connection with
its pending bankruptcy.
Third-Party Discovery Demands on NNI
2.

In the past few months, NNI has been served with third-party subpoenas seeking

production of a broad range of documents in connection with the following lawsuits involving
patents that NNI and the other Nortel corporate entities (collectively, “Nortel”) sold to Rockstar
Bidco, LP pursuant to an Asset Sale Agreement dated June 30, 2011 (the “ASA”):
a.

Constellation Techs. LLC v. Time Warner Cable, Inc. et al., No. 2:13-cv-

01079-RSP (E.D. Tex.) (“the ‘1079 Litigation”), with the subpoena having been served by Time
Warner Cable, Inc. (“TWC”) on June 9, 2014 (Appendix, Tab 1);

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Google Inc. v. Rockstar Consortium US LP et al., No. 4:13-cv-05933-CW

(N.D. Cal.) (“the ‘5933 Litigation”), with the subpoena having been served by Google on July
17, 2014 (Appendix, Tab 2);
c.

Rockstar Consortium US LP et al. v. Google Inc., No. 2:13-cv-00893-JRG

(E.D. Tex.) (“the ‘893 Litigation”), with the subpoena having been served by Google, Inc.
(“Google”) on July 18, 2014 (Appendix, Tab 3);
d.

Rockstar Consortium US LP et al. v. ASUSTek Computer, Inc. et al., No.

2:13-cv-00894-JRG (E.D. Tex.) (“the ‘894 Litigation”), with the subpoena having been served
jointly by Google and Samsung Electronics Co., Ltd. on August 11, 2014 (Appendix, Tab 4); and
e.

Spherix Inc. v. Verizon Services Corp. et al., No. 1:14-cv-721-GBL (E.D.

Va.), with the subpoena having been served jointly by numerous Verizon entities on or around
September 5, 2014 (Appendix, Tab 5).
3.

The subpoenas served on NNI are remarkable in terms of the number and breadth

of the document requests to which NNI must respond.

The three Google subpoenas, for

example, each contain more than one hundred and fifteen (115) separate document requests, the
vast majority of which are not limited in time and seek documents that have little or no direct
relationship to the small number of patents at issue in those cases. More particularly, the
subpoenas seek production of virtually every document in NNI’s possession, custody or control
relating to the valuation and sale of Nortel’s patent portfolio and business lines in connection
with these bankruptcy proceedings, including documents protected from disclosure by the
attorney-client privilege and attorney work-product immunity as well as documents subject to
confidentiality obligations to numerous other parties.

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In addition to the foregoing subpoenas to NNI, I am aware that in connection with

the ‘893 Litigation, Google has issued subpoenas to the following former Nortel employees
seeking documents and, in at least one case, deposition testimony:
a.

Christopher C. Cianciolo, former IP Counsel for Nortel who later became

Chief IP Counsel for Rockstar (Appendix, Tab 6);
b.

Art Fisher, former Vice President, IP Law for Nortel (Appendix, Tab 7);

c.

Peter A. Fortman, a former Nortel engineer who is the named inventor on

an alleged prior art patent (Appendix, Tab 8);
d.

Raj Krishnan, former IP Counsel for Nortel who later became an Assertion

Attorney for Rockstar (Appendix, Tab 9); and
e.
5.

Richard Weiss, former Deputy IP Counsel for Nortel (Appendix, Tab 10).

I understand that, notwithstanding Nortel having timely reminded the former

employees of their obligations under their respective employment agreements to return and
deliver all writings, documents, materials, and other property owned or leased by or relating to
Debtors, certain of these former Nortel employees may be in possession of NNI documents.
6.

Several of these individuals have requested that NNI represent them or otherwise

assist them in responding to Google’s subpoenas. Thus far, NNI has agreed to provide counsel
for Mr. Cianciolo and Mr. Fortman in order to help protect NNI’s privilege and confidentiality
interests. The document requests in these subpoenas are very extensive, again seeking not only
documents specifically related to the patents at issue in the ‘893 Litigation, but also virtually any
and all documents relating to Nortel’s past patent licensing and enforcement practices, as well as
the auction and eventual sale of its patent portfolio and business lines.

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I am also aware that Google has served several subpoenas in connection with the

pending Litigations on at least two of Nortel’s legal and business advisors, Global IP Law Group
(“Global IP”) and Lazard Freres & Co. LLC (“Lazard”), as well as three former Lazard
employees (Appendix, Tabs 11-18). Again, the document requests in these subpoenas are wideranging, seeking virtually any and all documents relating to Nortel’s auction and eventual sale of
its patent portfolio and business lines. Both Global IP and Lazard have contacted NNI for
assistance in connection with responding to these subpoenas.
NNI Has Extremely Limited Resources to Respond to Third-Party Discovery
8.

As of today, in addition to having sold the majority of its patent portfolio to

Rockstar, NNI has divested all of its various business operations.

Accordingly, NNI’s

operations, such as they are, exist only to facilitate resolution of the ongoing bankruptcy
proceedings.
9.

NNI has only one (1) remaining business facility, located in Research Triangle

Park, North Carolina, and no remaining employees. The company’s ongoing administrative
operations are being handled by a group of only seven (7) former Nortel employees working on a
contract basis, including me. None of us ever held a technical or legal position in the company
that related in any relevant way to what I generally understand to be the subject matter of the
various patent infringement suits in connection with which NNI has been subpoenaed.
NNI’s Remaining Document Stores Are Difficult to Search
10.

In part due to standard disaster recovery procedures in place when NNI was

actively operating its businesses and in part due to litigation-related holds, including in the
context of the ongoing bankruptcy proceedings, NNI has vast stores of paper and electronic
records. Due to the nature of how those records have been maintained, however, it is extremely

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difficult, and in many cases essentially impossible, to determine whether any particular category
of documents exists or where such documents may be located.
11.

NNI has control over more than a decade’s worth of digital media archives,

comprising more than 142,000 physical items (mostly magnetic tapes), that are presently
maintained by Iron Mountain at approximately six (6) different locations around the country.
Iron Mountain maintains a high-level online catalog of these digital media archives, but that
catalog does not contain any information regarding the contents of the particular media stored.
In at least some cases, it may be possible with a substantial degree of effort to trace portions of
the archives back to the Nortel organization that provided them to Iron Mountain, but that would
only enable identification of the system or server to which a backup tape corresponds. In order
to view the contents of any given tape, it would be necessary to load the tape onto whichever
system/server it came from, if it still exists, and use the corresponding computer application to
review the contents. Of course, this assumes that the magnetic tape is still readable, which is by
no means a given due to the physical degradation that magnetic tape undergoes over time.
12.

Iron Mountain is also holding more than 171,000 boxes of documents and other

physical items (e.g., laptops, computer hard drives, books, etc.) at more than fifteen (15)
warehouses across the country. Some of this material comprises records put in off-site storage
for safekeeping in the ordinary course of Nortel’s business operations, but much of it was sent to
Iron Mountain as Nortel was shutting down its operations in the course of the bankruptcy
proceedings. As with the digital media archives discussed above, Iron Mountain maintains a
high-level online catalog for these physical items, but that catalog provides little or no
information regarding the contents of the items stored. Again, in at least some cases, it may be
possible with a substantial degree of effort to trace a particular pallet of boxes back to the Nortel

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organization that provided them to Iron Mountain, but in order to determine the contents of any
particular box it would be necessary to retrieve the box from Iron Mountain and physically
inspect the contents.
13.

Any effort to locate particular documents, or even broad categories of documents,

within the physical and electronic stores under NNI’s control is made all the more complicated
by the fact that the personnel remaining at NNI have little or no personal knowledge of the
relevant business and/or legal operations of the company. Accordingly, even a seemingly simple
request such as “find all of John Smith’s documents” requires a laborious effort that begins with
searching human resource records to determine who “John Smith” was, which organization he
worked for and in which facility, scouring any accessible paper and/or computer records for that
organization to try to determine whether and where it may have archived its documents, calling
back from Iron Mountain potentially thousands of boxes of documents associated with the
organization, and then physically inspecting each box to determine whether any of them contain
“John Smith’s” documents. Quite literally, this is like looking for the proverbial needle in a
haystack.
14.

In addition to the above-described archives, NNI has kept a small number of its

computer systems operational in order to assist with the administrative aspects of the company’s
wind-down. These include a human resources/personnel system, certain financial systems, and
the “LiveLink” document management system.
a.

The LiveLink system was available to the various Nortel business

organizations to use, on a largely voluntary basis, as a document repository that could be
accessed by the members of the organization regardless of where they were physically working.
However, there was no standard method by which documents and information were posted to or

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organized on LiveLink. Furthermore, at one time, there was a physical instance of the LiveLink
system residing on each of several Nortel servers located around the world, and these various
instances were logically connected so that users could access documents seamlessly regardless of
where the documents were physically stored. Today, however, as a result of the divestitures,
NNI has possession of, and access to, only the U.S.-based instance of the LiveLink system.
b.

The LiveLink system to which NNI has access has not been actively

maintained for at least three (3) years, but it does provide some rudimentary searching
capabilities. The system supports a relatively crude (by today’s standards) Boolean search
syntax that enables AND/OR/NOT type searches on specified text strings (e.g., “patent AND
infring* AND NOT trademark”), but it does not support proximity searches (e.g., “patent w/5
infring*). Consequently, it is often not possible to structure a search in a way that returns a
manageable number of reasonably relevant “hits.”
c.

When a search is run in the LiveLink system, the hits can be viewed

online in various formats, including a preview mode that will highlight search terms in the
document.

However, the system does not include any facility for efficiently downloading

documents returned in a search. Rather, it is necessary to open each individual document desired
to be downloaded and save that document to a storage location (e.g., a Windows folder resident
on the computer on which the search was run or a portable drive). This is an extremely tedious
and time-consuming task if any substantial number of documents needs to be downloaded, as it
typically takes at least 15-20 seconds to access and download each individual document.
d.

The documents maintained in LiveLink include some basic metadata

fields, including the date a document was created and the name of the individual who first stored
the document in the system. The metadata does not identify the business unit with which that

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individual was associated, nor does it associate the document with any particular Nortel entity.
Accordingly, in order to determine whether any particular document “belongs to” NNI or one of
the other Nortel estates (i.e., for purposes of assessing NNI’s confidentiality obligations and/or
who owns any privilege), it would be necessary to trace the individual who stored the document
in LiveLink back to the Nortel entity by whom he or she was employed using the available
human resources records.
Most of the Documents Sought by the Subpoenas Were Previously
Searched for, Collected, and Transferred to Others
15.

The various third-party subpoenas that have been served on NNI and related third-

parties to date seek documents falling into two broad categories: (i) “patent documents,”
including documents relating not only to the particular patents being asserted in the respective
litigations, but also documents relating more broadly to Nortel’s entire portfolio of thousands of
patents, most but not all of which were sold to Rockstar, and (ii) “valuation documents,”
including documents relating to Nortel’s effort to assess the potential value of its patents and
business lines prior to putting those assets up for sale, and documents relating to the sales
themselves, including documents submitted to Nortel by both the successful and unsuccessful
bidders. As discussed further below, the vast majority of responsive documents in category (i)
should now be in Rockstar’s possession, custody or control; and the vast majority of the
responsive documents in category (ii) were collected for purposes of the allocation litigation
among the various Nortel estates.
16.

In connection with the various asset sales pursuant to the bankruptcy proceedings,

Nortel maintained electronic data rooms with confidential diligence materials. As each data
room was created, NNI and the other Nortel entities searched for, collected, and included in the
electronic data rooms relevant documents and information for each respective sale process.

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Access to the confidential diligence materials and the data rooms was limited to persons covered
by confidentiality and non-disclosure agreements. NNI has transferred to the purchasers a large
percentage of the paper and electronic documents relating to its former business operations.
a.

For example, in connection with the sale of more than 7,000 patents and

patent applications to Rockstar, NNI transferred to Rockstar a vast collection of records
designated “Patent Related Documentation” under the Nortel/Rockstar ASA, including: (i) all of
the physical and electronic patent prosecution files relating to the transferred patents, (ii)
documents relating to licensing of the transferred patents, including copies of all license
agreements and all statements to standards-setting organizations regarding licensing; (iii) all
litigation files relating to assertions of the transferred patents; (iv) all infringement charts relating
to the transferred patents; (v) all books, records, files, ledgers and similar documents stored in
Nortel’s document management systems used to track, organize or maintain the patents; (vi) all
documents at any time contained in the electronic data room that was made available to Rockstar
and other bidders in connection with the auction of Nortel’s patent portfolio and business lines;
(vii) copies of acquisition agreements for any transferred patents that had previously been
purchased by Nortel; and (viii) all assignment agreements relating to the transferred patents.
b.

In addition, approximately twenty-six (26) former Nortel employees, most

of whom worked in Nortel’s IP Legal department, transitioned to Rockstar in connection with
the transaction, and those employees were authorized and instructed to transfer to Rockstar any
paper or electronic documents in their possession that related to the transferred patents. Rockstar
also took possession of approximately twenty-six (26) desktop and laptop computers previously
used by Nortel personnel, again for the purpose of transferring any electronic documents on
those computers related to the transferred patents.

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Accordingly, Rockstar should have at least a copy, and in many if not

most instances the original, of virtually every document previously in NNI’s possession, custody
or control relating to the patents transferred to Rockstar, including all of the patents now being
asserted in the above-identified litigations.
d.

In addition to the sale of patents to Rockstar, Nortel sold eight (8) specific

business lines to separate purchasers, including Avaya, Ciena, Ericsson, Genband, Hitachi,
Kapsch, and Radware. Similar to the Nortel/Rockstar ASA, the asset transfer agreements for
these business line sales included provisions for transferring to the purchasers Nortel’s paper and
electronic documents relating to the transferred business lines.
17.

In connection with the ongoing litigation among the various Nortel estates

regarding allocation of the proceeds from the sale of Nortel’s patent portfolio and business lines,
each of the Nortel estates was tasked with searching for and collecting broad categories of
documents potentially relevant to the allocation dispute, including documents concerning
valuation of the patents and other business assets that were sold.

These documents were

collected not only from each of the Nortel estates, but also from Nortel’s legal and business
advisors, including the Global IP Law Group and Lazard Freres. This effort resulted in the
collection of approximately 3,000,000 documents, all of which were loaded into a database
accessible by the Nortel estates and their counsel. I understand that the original source of many
of these 3,000,000 documents is not readily identifiable or easily obtainable at this time. I also
understand that there ended up being approximately 2,200 exhibits cited in submissions or
otherwise used at trial. Most of these trial exhibits include highly confidential information, and
many of them include attorney-client privileged information.

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To the extent NNI still has in its possession, custody or control certain of the

“patent documents” and “valuation documents” as described above, the vast majority of those
documents are subject to confidentiality obligations and/or claims of attorney-client privilege
and work-product immunity, rendering any effort to review such documents for possible
production in response to discovery requests extremely burdensome. This is because:
a.

the asset purchase agreements between Nortel and the purchasers,

including Rockstar, include extensive confidentiality restrictions that obligate NNI to take all
reasonably appropriate steps to preserve the confidentiality and privileged status of such
documents;
b.

NNI has confidentiality and privilege obligations with respect to each of

the other Nortel estates and the other “Core Parties” to the allocation litigation, as well as to
Rockstar and the business line purchasers, to the extent documents exchanged and/or used in
connection with the allocation trial relate to the assets each of them acquired or otherwise
implicate their interests.
19.

In view of these various obligations, it is extremely burdensome and time-

consuming for NNI to review, designate and produce documents sought by the above-described
subpoenas. For instance, in order to avoid breaching its contractual obligations, NNI must have
its counsel review each document to identify both attorney-client privileged information and
confidential information.

As to each category of protected information, NNI must then

determine whether that information relates to assets sold to Rockstar or one of the business line
purchasers. Once the interested third-parties are identified, NNI is required to give them notice
and an opportunity to object before any such documents are disclosed to others. In addition, the
information in the requested valuation documents that were collected for the allocation litigation

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are subject to protective orders and confidentiality orders issued by the Delaware Bankruptcy
Court and therefore NNI would have to consult extensively with the other Nortel estates and
Core Parties. Moreover, the documents sought include highly technical business information,
and outside counsel or third parties may not be able to identify readily which buyers or other
third parties may have an interest therein.
The Majority of the Subpoenaed Documents Can Be Obtained
More Efficiently from Sources Other than NNI
20.

Based on my understanding of the scope of the document requests that have been

served on NNI to date, as well as my general knowledge of the identification, availability, and
accessibility of the documents remaining in NNI’s possession, custody or control, I believe that
the documents being sought can be obtained in a far more efficient, more cost-effective and less
burdensome manner from sources other than NNI.
21.

With respect to the requested patent documents, as noted above, substantially all

of those documents should be in Rockstar’s possession. Rockstar is in a far better position than
NNI to undertake the burden and expense of searching for, reviewing and producing such
documents.

Moreover, for the following reasons, Rockstar would seem to be the more

appropriate entity to be making determinations as to the confidential and/or privileged status of
those documents.
a.

Prompted by the subpoena that TWC issued to NNI, Rockstar warned NNI

not to disclose any of Rockstar’s confidential and/or privileged information in response to
subpoenas served in litigations involving the patents that Rockstar purchased from Nortel.
Indeed, Rockstar indicated that it would seek damages against NNI in connection with any
allegedly unauthorized disclosure of Rockstar’s confidential and/or privileged information,

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confirming that protection of such information was a material term of the Asset Purchase
Agreement between Rockstar and Nortel.
b.

In connection with the sale of patents to Rockstar, the Nortel sellers

entered into Common Interest Agreements, dated July 29, 2011, with each of Rockstar and
Rockstar Consortium Inc.

Under the Common Interest Agreements, the Nortel sellers are

obligated to not disclose “Common Interest Information” and not waive any privilege applicable
to any such information. The parties also agreed that Common Interest Information shall be
“Purchaser Confidential Information” under the ASA and, therefore, subject to the ongoing
confidentiality obligations under the ASA.
22.

With respect to the valuation documents, again as noted above, all such

documents were collected not only from each of the Nortel estates, but also from Nortel’s legal
and business advisers, for purposes of the allocation litigation among the estates. As required by
the Bankruptcy Court, and consistent with the protective and confidentiality orders entered by
the Bankruptcy Court, the roughly 2,200 trial exhibits that were prepared from this collection are
now being reviewed for confidentiality and privilege by counsel for the respective Nortel estates,
in consultation with the other Core Parties and certain purchasers, licensees and tax authorities,
in order to prepare public versions. On information and belief, those trial exhibits are likely to
contain most of the valuation-related documents that are reasonably, or at least arguably, relevant
to the issues in the above-identified patent litigations. NNI intends to produce all of the public
versions of the trial exhibits to the parties who have issued subpoenas to NNI seeking such
documents.

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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
---------------------------------------------------------------X
:
In re
:
Chapter 11
:
:
Case No. 09-10138(KG)
Nortel Networks Inc., et al.,1
:
Jointly Administered
Debtors.
:
:
: Hearing Date: Nov. 4, 2014 at 10:00 a.m.
: Objections Due: Oct. 14, 2014 at 4:00 p.m.
---------------------------------------------------------------X
APPENDIX TO 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) A PROTECTIVE ORDER, AND (D) RELATED RELIEF UNDER SECTION 105(A)

1

The Debtors in these Chapter 11 cases, along with the last four digits of each Debtor's tax
identification number, are: Nortel Networks Inc. (6332), Nortel Networks Capital Corporation (9620),
Nortel Altsystems Inc. (9769), Nortel Altsystems International Inc. (5596), Xros, Inc. (4181), Sonoma
Systems (2073), Qtera Corporation (0251), CoreTek, Inc. (5722), Nortel Networks Applications
Management Solutions Inc. (2846), Nortel Networks Optical Components Inc. (3545), Nortel Networks
HPOCS Inc. (3546), Architel Systems (U.S.) Corporation (3826), Nortel Networks International Inc.
(0358), Northern Telecom International Inc. (6286), Nortel Networks Cable Solutions Inc. (0567) and
Nortel Networks (CALA) Inc. (4226). Contact information for the U.S. Debtors and their petitions are
available at http://dm.epiq11.com/nortel.

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Description

1.

Time Warner Subpoena to Nortel Networks Inc. in Constellation Techs. LLC v. Time
Warner Cable, Inc. et al., No. 2:13-cv-01079-RSP (E.D. Tex.), served June 9, 2014

2.

Google Subpoena to Nortel Networks Inc. in Google Inc. v. Rockstar Consortium US LP
et al., No. 4:13-cv-05933-CW (N.D. Cal.), served July 17, 2014

3.

Google Subpoena to Nortel Networks Inc. in Rockstar Consortium US LP et al. v.
Google Inc., No. 2:13-cv-00893-JRG (E.D. Tex.), served July 18, 2014

4.

Google/Samsung Subpoena to Nortel Networks Inc. in Rockstar Consortium US LP et
al. v. ASUSTek Computer, Inc. et al., No. 2:13-cv-00894-JRG (E.D. Tex.), served
August 11, 2014

5.

Verizon Subpoena to Nortel Networks Inc. in Spherix Inc. v. Verizon Services Corp. et
al., No. 1:14-cv-721-GBL (E.D. Va.), served September 5, 2014

6.

Google Subpoena to Christopher J. Cianciolo in Rockstar Consortium US LP et al. v.
Google Inc., No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 4, 2014

7.

Google Subpoena to Art Fisher in Rockstar Consortium US LP et al. v. Google Inc., No.
2:13-cv-00893-JRG (E.D. Tex.), served September 8, 2014

8.

Google Subpoena to Peter A. Fortman in Google Inc. v. Rockstar Consortium US LP et
al., No. 4:13-cv-05933-CW (N.D. Cal.), served August 18, 2014

9.

Google Subpoena to Raj Krishnan in Rockstar Consortium US LP et al. v. Google Inc.,
No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 4, 2014

10.

Google Subpoena to Richard Weiss in Rockstar Consortium US LP et al. v. Google Inc.,
No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 4, 2014

11.

Google Subpoena to Global IP Law Group in Rockstar Consortium US LP et al. v.
Google Inc., No. 2:13-cv-00893-JRG (E.D. Tex.), served August 20, 2014

12.

Google/Samsung Subpoena to Global IP Law Group in Rockstar Consortium US LP et
al. v. ASUSTek Computer, Inc. et al., No. 2:13-cv-00894-JRG (E.D. Tex.), served
August 14, 2014

13.

Google Subpoena to Lazard Freres & Co. LLC in Rockstar Consortium US LP et al. v.
Google Inc., No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 6, 2014

14.

Google/Samsung Subpoena to Lazard Freres & Co. LLC in Rockstar Consortium US LP
et al. v. ASUSTek Computer, Inc. et al., No. 2:13-cv-00894-JRG (E.D. Tex.), dated
August 14, 2014

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Tab

Description

15.

Google Subpoena to Lazard Freres & Co. LLC in Google Inc. v. Rockstar Consortium
US LP et al., No. 4:13-cv-05933-CW (N.D. Cal.), dated August 7, 2014

16.

Google Subpoena to David Descoteaux in Rockstar Consortium US LP et al. v. Google
Inc., No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 6, 2014

17.

Google Subpoena to Colin Keenan in Rockstar Consortium US LP et al. v. Google Inc.,
No. 2:13-cv-00893-JRG (E.D. Tex.), dated August 6, 2014

18.

Google Subpoena to Justin Lux in Rockstar Consortium US LP et al. v. Google Inc., No.
2:13-cv-00893-JRG (E.D. Tex.), dated August 6, 2014

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AO 88.13 (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the
Eastern District of Texas
CONSTELLATION TECHNOLOGIES LLC

)

Plaintiff

V.
TIME WARNER CABLE INC., et al.

Civil Action No, 2:13-CV-1079-RSP

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To:

Norte! Networks, Inc.
do CT CORPORATION SYSTEM, 150 FAYETTEVILLE ST., BOX 1011, RALEIGH NC 27601
(Name qfpersoh to whom this subpoena is direcied)

f.production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Documents and electronically stored information described in the attached Exhibit.

—Place: Regus - Meridian Pkwy, 2530 Meridian Parkway,
Durham, North Carolina, 27713

Date and Time:
06/20/2014 5:00 pm

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, .or
other property possessed or controlled by you at the time, date, and location set forth. below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

1Date and Time:

Place:

The following provisions of Fed. R.. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

/ jti,to 2be
CLERK OFCOURT

OR
Signature of Clerk or Deputy Clerk

Attorney ,s Arnature

The name, address, e-mail address, and telephone number of the attorney tepresenting (name of party)
, who issues or requests this subpoena, are:
Time Warner Cable, Inc..
Jonas R. McDavit, Desmarais LLP, 230 Park Ave., New York, NY 10169 [phone]
jmnrinvit@riesnw-amiqllp r.nm

Notice to the person who issues or requests this subpoena
A notice and a copy of the subpoena must be served on each patty in this ease before it is served on the person to whom
it is directed. Fed. R. Civ. P. 45(a)(4).

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AO 88B (Rev. U2/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the
District of California

Northern
Google Inc.
Plaintiff
V.

Civil Action No. 13-cv-5933-CW

Rockstar Consortium US LP and
MobileStar Technologies LLC
Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To: Nortel Networks Inc. c/o The Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801
(Name of person to whom this subpoena is directed)

X Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: See Attachment A, attached hereto.

Place: Parcels, Inc., 1111B South Governors Ave., Dover,

Date and Time:

Delaware 19904

July 31, 2014 at 9:00 a.m.

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date: July 17, 2014

CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney's signature

Matthew S. Warren
The name, address, e-mail address, and telephone number of the attorney representing (name of party) Google Inc.
, who issues or requests this subpoena, are:
Matthew S. Warren, Quinn Emanuel Urquhart & Sullivan, LLP, 50 California Street, 22nd Floor, San Francisco, California
94111, Quinn-Google-N.D.Cal.-13-059330quinnemanuel.com, [phone]
Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).
AO-88B

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the

Eastern District of __________
__________ District of Texas
Rockstar Consortium US LP & NetStar Technologies LLC
Plaintiff

v.
Google Inc.
Defendant

)
)
)
)
)
)

Civil Action No. 13-cv-00893-RG

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Christopher J. Cianciolo, Esq., Tyco International
6 Technology Park Drive, Westford, Massachusetts 01886

To:

(Name of person to whom this subpoena is directed)

✔ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
u
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Attachment A

Place: Michael L. Noble, Boston Corporate Attorney Services

Date and Time:

83 Wyman Street #2
Boston, MA 02130

08/18/2014 9:00 am

u Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

08/04/2014

CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Google Inc.
Michelle Ernst, Quinn Emanuel Urquhart & Sullivan, LLP, 51 Madison Ave., 22nd Floor, New York, NY 10010, 212-849-7531
[e-mail]

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the

Eastern District of __________
__________ District of Texas
Rockstar Consortium US LP & NetStar Technologies LLC
Plaintiff

v.
Google Inc.
Defendant

)
)
)
)
)
)

Civil Action No. 13-cv-00893-RG

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Art Fisher, Patent Dominion Partnership, LP
6103 Twin Oaks Circle, Dallas, Texas 75240

To:

(Name of person to whom this subpoena is directed)

✔ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
u
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Attachment A

Place: Steve Sessions, Advanced Discovery

Date and Time:

500 N Akard Street, Suite 250
Dallas, TX 75201

08/18/2014 9:00 am

u Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

08/04/2014

CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Google Inc.
Michelle Ernst, Quinn Emanuel Urquhart & Sullivan, LLP, 51 Madison Ave., 22nd Floor, New York, NY 10010, 212-849-7531
[e-mail]

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the

Eastern District of __________
__________ District of Texas
Rockstar Consortium US LP & NetStar Technologies LLC
Plaintiff

v.
Google Inc.
Defendant

)
)
)
)
)
)

Civil Action No. 13-cv-00893-RG

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Raj Krishnan, Esq., STMicroelectronics, Inc.
1310 Electronics Drive, Carrolton, Texas 75006

To:

(Name of person to whom this subpoena is directed)

✔ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
u
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Attachment A

Place: Steve Sessions, Advanced Discovery

Date and Time:

500 N Akard Street, Suite 250
Dallas, TX 75201

08/18/2014 9:00 am

u Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

08/04/2014

CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Google Inc.
Michelle Ernst, Quinn Emanuel Urquhart & Sullivan, LLP, 51 Madison Ave., 22nd Floor, New York, NY 10010, 212-849-7531
[e-mail]

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the

Eastern District of __________
__________ District of Texas
Rockstar Consortium US LP & NetStar Technologies LLC
Plaintiff

v.
Google Inc.
Defendant

)
)
)
)
)
)

Civil Action No. 13-cv-00893-RG

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Richard Weiss
McKinney, Texas

To:

(Name of person to whom this subpoena is directed)

✔ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
u
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Attachment A

Place: Steve Sessions, Advanced Discovery

Date and Time:

500 N Akard Street, Suite 250
Dallas, TX 75201

08/18/2014 9:00 am

u Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

08/04/2014

CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Google Inc.
Michelle Ernst, Quinn Emanuel Urquhart & Sullivan, LLP, 51 Madison Ave., 22nd Floor, New York, NY 10010, 212-849-7531
[e-mail]

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO SKB (Rev. 02114) Subpoena to Produce Documents, Ir.formation, or Objects or 10 Permit lnspeciioo of Premises in a Civil Action

UNITED STATES DISTRICT COURT
Eastern

for the
District of Texas

Rockstar Consortium US LP el al
Plaintiff

v.

Civil Action No. 2: I 3-cv-00894-JRG

ASUSTcK Computer, Im;. el al
DefeT1dam

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To: Global IP Law Group, c/o Patrick C. Turner
33 N La Salle St. 5'TE 1910. Chicago. Illinois 60602-3227
(Name of perscm to whom this subpoeT1a is tlirecte.d>

[x-J Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: See Attachment A, attached hereto.

Place: Quinn Emanuel Urquhart & Sullivan LLP

Date and Time:

500 W. Madison Street, Suite 2450, Chicago, IL 60661

August 28, 2014, 9:00 a.m.

[·]Inspection c~f'Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
ot.her property possessed or controlled by you al the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it

I

IPlaco

Date and Timeo

The following provisions of Fed. R. Civ. P. 45 are attached- Ruic 45(c), relating to the place of compliance;
Ruic 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date: August 14. 2014
CLERK OF COURT
OR
Altomey's signature

Sigflature of Clerk or Deputy Clerk

Ma thew Warren
The name, address, e-mail address, and telephone number of the attorney representing (name of party) Google Inc. and
Samsung Electronics Co .. Ltd.
, who issues or requests this subpoena, are:
Matthew S. Warren, Quinn Emanuel Urquhart & Sullivan, LLP, 50 California Street, 22nd Floor, San Francisco, CA 94111
[e-mail], [phone]

Notice to the person who Issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of' premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

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AO88B (Rev.02i14)SubpoenatoProduceDocuments.,Information,orObjectsortoPermitlnspectionofPremisesrnaCivilAction

UNrrsn Srares DrsrrucT CoURT
for the
Eastern District of Texas
Rockstar Consortium US LP & NeiStar Technologies
Plaintiff

LLC

)

Civil Action

No.

13-cv-00893-RG

Google lnc.
Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PRNMISES IN A CIVIL ACTION
David Descoteaux, Lazard Freres & Co. LLC
30 RockefellerPlaza, NewYork, NY 10112

To:

Qtlame of person to whom this subpoena is directed)

d

Production: YOIJ ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: Attachment A

Michelle Ernst, Quinn Emanuel Urquhart & Sullivan LLP
51 Madison Ave., 22nd Floor
New York, NY 10010

Date and Time:
08/2012014 9:00 am

A Inspection of Premises; YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the proper$ or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences ofnot doing so.

Date:

08lOOl2O14

CLERK OF COURT

Signature of Clerk or Deputy Clerk

".?t"fu;"dA
Attorney's signature

The name, address, e-mail address, and telephone number of the attorney representing

Gooqle lnc.

tr

(name

of party)

, who issues or requests this subpoena, are:

Michelle Ernst, Quinn Emanuel Urquhart & Sullivan, LLP, 51 Madison Ave.,22nd Floor, New York, NY 10010,212-849-7531

michelleernst@quinnemanue''"o*Noti""

to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. s(a)( ).

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