ESN LLC v. Cisco Systems, Inc. et al
Filing
54
*WITHDRAWN PER ORDER # 122 * MOTION to Compel Response to Cisco's Seventh Interrogatory by Cisco Systems, Inc., Cisco-Linksys LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Text of Proposed Order Proposed Order)(Smith, Kevin) Modified on 9/11/2009 (mrm, ).
Exhibit D
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WRITER'S DIRECT DIAL No. (650) 801-5058 WRITER'S INTERNET ADDRESS sayurisharper @ quinnemanuel.com
August 14, 2008
VIA ELECTRONIC MAIL
Gerald C. Willis
McAndrews Held & Malloy LTD 500 West Madison Street
34th Floor Chicago, Illinois 60661
Re:
ESN LLC v. Cisco Systems, Inc.
Dear Gerald:
I write to address deficiencies in ESN's "Answers to Defendants' Second Set of Interrogatories," served on July 14, 2008. In its`response to Interrogatory No. 7, ESN made numerous improper objections and failed to provide a substantive response in compliance with the Federal and Local Rules.
Cisco's Interrogatory No. 7 requests:
State and describe in detail how the written description and any drawing(s) of ESN's Provisional Application No. 60/283,888 support the subject matter claimed in the '519 Patent, including: (i) the specific identification of any and all disclosures(s) in the provisional application for each element of each claim in the '519 Patent; and (ii) the specific identification of any and all disclosures(s) in the provisional application that enable a person skilled in the art to which the invention pertains to make and use the invention.
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