Apple, Inc. v. Motorola, Inc. et al

Filing 264

Notice by Plaintiff Apple, Inc. re 258 Letter responding to Court's letter re trial location. (Ferguson, Brian)

1300 Eye Street NW, Suite 900
Washington, DC 20005-3314
[phone] tel
[phone] fax

Weil, Gotshal & Manges LLP

Brian E. Ferguson
[phone]
Brian.ferguson@weilcom

November 16, 2011
The Honorable Barbara B. Crabb
United States District Court for the
Western District of Wisconsin
Robert W. Kastenmeier Courthouse
120 N. Henry Street, Rm. 540
Madison, Wisconsin 53701
Re: Apple Inc. et al.. v. Motorola, Inc. et al., Civil No. 10-cv-662-bbc
Dear Judge Crabb:
We write on behalf of Apple in response to the Court’s letter of November 10 regarding the possibility
of moving this case to Chicago for trial. Apple has given the Court’s suggestion careful consideration,
and although we very much appreciate the Court’s efforts to maintain this case on an expeditious
schedule, Apple respectfully requests that this case remain in Madison for pretrial and trial purposes.
Given the Court’s investment in the issues involved in this case to date, and the fact that both parties
voluntarily chose to bring their claims in this Court (indeed, Motorola dismissed its case pending the
Northern District of Illinois in favor of proceeding here), we would prefer for the case to continue before
this Court. That said, Apple will make every effort to streamline the case for trial.
In addition, we believe that Madison is a more neutral forum for this dispute than the Chicago area,
where Motorola is headquartered. Finally, the resolution of the instant case is likely to involve issues
that will overlap with the 178 case, which is to remain in Madison, potentially leading to a more
efficient resolution of the 178 case.
Respectfully submitted,

Brian E. Ferguson
Cc:

Catherine Cetrangolo (counsel for Apple)
Matthew Powers (counsel for Apple)
Robert Haslam (counsel for Apple)
Charles Verhoeven (counsel for Motorola)
Scott Hansen (counsel for Motorola)