WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 212

MOTION for Protective Order by Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Text of Proposed Order)(Wynne, Richard)

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EXHIBIT D onson&Elkins Ajeet P Pai apai@velaw com Tel +1 512 542 8798 Fax +1 512 236 3317 May 31, 2012 Via Email Richard L. Wynne, Jr. Thompson & Knight LLP 1722 Routh Street, Suite 1500 Dallas, Texas 75201 Re: Wi-LANv. Alcatel-Lucent USA et al. (10-cv-521) (E.D. Tex.) Infringement Contentions / Sony and Ericsson Productions Dear Rich: As you will recall, Wi-LAN's preliminary infringement contentions include "all other [Sony/Ericsson] products which are reasonably similar in structure and/or operation" to the listed products. The products identified in Wi-LAN's response to Defendants' Common Interrogatory No. 4 (many of which were released by Sony or Ericsson after Wi-LAN's preliminary infringement contentions were served) are such products and indeed infringe because they implement the same functionality described in the standards listed in those contentions. Accordingly, all these products are already included within Wi-LAN's preliminary infringement contentions. That said, we reserve our right to supplement those contentions as appropriate under P.R. 3-6(a) without leave of Court. Ajeet P. Pai US 1421403 Vinson & Elkins LLP Attorneys at Law 2801 Via Fortuna, Suite 100 Abu Dhabi Austin Beijing Dallas Dubai Hong Kong Houston London Austin TX 78746-7568 Moscow New York Palo Alto Riyadh Shanghai Tokyo Washington Tel+1 512 542 8400 Fax+1 512 542 8612 www.velaw.com

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