`
`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 1 of 11
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`Michael A. Sherman (SBN 94783)
`masherman@stubbsalderton.com
`Jeffrey F. Gersh (SBN 87124)
`jgersh@stubbsalderton.com
`Sandeep Seth (SBN 195914)
`sseth@stubbsalderton.com
`Wesley W. Monroe (SBN 149211)
`wmonroe@stubbsalderton.com
`Stanley H. Thompson, Jr. (SBN 198825)
`sthompson@stubbsalderton.com
`Viviana Boero Hedrick (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS, ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`
`Attorneys for PersonalWeb Technologies, LLC
`and Level 3 Communications, LLC
`[Additional Attorneys listed below]
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN JOSE DIVISION
`
`IN RE PERSONAL WEB TECHNOLOGIES,
`LLC, ET AL., PATENT LITIGATION
`
`
`CASE NO.: 5:18-md-02834-BLF
`
`AMAZON.COM, INC., et al.,
`
`Case No.: 5:18-cv-00767-BLF
`
` Plaintiffs,
`
`
`
`v.
`
`JOINT STATEMENT REGARDING
`DISCOVERY DISPUTE RELATING TO
`MOTION FOR SUMMARY JUDGMENT
`(DKT. NO. 315)
`
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
`
`
`
` Defendants.
`
`PERSONALWEB TECHNOLOGIES, LLC
`and LEVEL 3 COMMUNICATIONS, LLC,
`
`
`
`
`
`v.
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`Counterclaimants,
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICES, INC.,
`
`Counterdefendants.
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
` CASE NO: 5:18-cv-00767-BLF
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`

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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 2 of 11
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`I.
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`PERSONALWEB’S STATEMENT
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`At issue is whether the current causes of action against the Website Operators (and counter-
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`claim pleaded in the alternative against Amazon) involving CloudFront and certain specific subsys-
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`tems of S3 are barred by a prior action brought by PersonalWeb against Amazon and Dropbox in the
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`EDTX. involving other subsystems of S3. More specifically for purposes of the current discovery
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`dispute, PersonalWeb seeks discovery confirming that a predicate for claims preclusion is lacking, i.e.,
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`that during the period of infringement of January 8, 2012 to December 26, 2016 (“Infringement Pe-
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`riod”), Amazon was not “contractually obligated to indemnify defendants [website operators who
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`were customers of Amazon S3] for any losses stemming from a finding of infringement,” SpeedTrack
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`v. Office Depot, 2014 WL 1813292 at *6, May 6, 2014. Amazon’s summary judgment motion set for
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`hearing on February 7, 2019 recognizes the foundational nature of this issue, with its circular argu-
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`ment, the ipse dixit in its moving papers that “Amazon is in privity with its customers …[because]
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`Amazon is indemnifying its customers in this case.” [In re PersonalWeb Technologies, Dkt. 315, Am-
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`azon Mot. at 9:1-2.]
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`From publicly available (on-line) Amazon records, the earliest time that Amazon ever had any
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`contractual obligation to indemnify S3 customers for patent infringement claims asserted against Am-
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`azon customers, is June 28, 2017. That date is after the Infringement Period. Emphasizing the point,
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`Amazon’s consistent objection position to all of PersonalWeb’s propounded discovery is that Amazon
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`only recognizes the time period January 8, 2012 through December 26, 2016 as triggering a disclo-
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`sure/discovery obligation. For example, Amazon’s response to document requests propounded on it,
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`seeking indemnification-related documents and information is, inter alia, that:
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`“Amazon objects to the definition of “Indemnified” or “Indemnification” as vague and ambig-
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`uous, overly broad, unduly burdensome, and failing to describe the information sought with
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`reasonable particularity. Amazon will interpret this term to refer to the legal concept of in-
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`demnification. Amazon will interpret this term to refer to the time period of January 8, 2012
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`to December 26, 2016.” [Amazon’s Resp. to RFPs Set One 3:16-20.]
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`Amazon has uniformly applied this January 8, 2012-December 26, 2016 time period as a limitation to
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`nearly every written discovery request that PersonalWeb has propounded. See e.g. Suppl. Resp. to
`
`
`
`
`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`1
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
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`

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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 3 of 11
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`RFA 2 and S.R. 1; Resp. to RFP 3; Obj. to 30(b)(6) Notice, Topic 1(a). Clearly June 28, 2017 post-
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`dates the Infringement Period.
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`PersonalWeb had sought to take a representative (30(b)(6) deposition on indemnification-re-
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`lated topics, among other topics. Amazon had insisted that this deposition occur last Wednesday,
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`December 5, 2018. During the representative’s deposition he indicated no knowledge on any level
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`with any indemnification-related issues.
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`In meet and confers leading to this submission PersonalWeb had suggested as a compromise
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`to a continued 30(b)(6) deposition on indemnification obligation matters, that instead, Amazon simply
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`stipulate that (a) not until June 28, 2017 was Amazon contractually obligated to indemnify website
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`operator customers of S3 for claims of patent infringement, and (b) prior to that time no such contrac-
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`tual obligation existed between Amazon and its S3 customers requiring Amazon to indemnify its S3
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`customers. Amazon refuses.
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`That Amazon has just yesterday served additional supplemental interrogatory responses indi-
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`cating that there exists an Amazon Customer Agreement of June 28, 2017 which adds a section to the
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`effect that Amazon is purportedly “improving the terms of the AWS Customer Agreement related to
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`intellectual property rights” including “offering uncapped IP infringement protection” is not respon-
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`sive to the reason for the dispute, i.e., that PersonalWeb ought to be permitted to take a 30(b)(6) rep-
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`resentative’s deposition that sought information on the circumstances under which Amazon agreed to
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`indemnify and the facts underlying Amazon’s agreement to provide said indemnifications, see, Notice
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`of Taking Deposition and in particular, Responses and Objections of Amazon.Com, Inc. and Amazon
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`Web Services, Inc. to Notice of Taking Deposition, topics and responses to Indemnification, Topic 4,
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`at 26-33, attached hereto as Exhibit 1 (said discovery is specifically at issue). PersonalWeb never
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`agreed that by Amazon acknowledging what its public documents already demonstrate, i.e., that there
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`were material changes to Amazon indemnification policies in June, 2017, that would moot the discov-
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`ery issues.
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`Amazon argues that the stipulation PersonalWeb seeks is legally impermissible. But Amazon
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`overlooks that the proposed stipulation represents an effort to avoid another deposition session, where
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`inquiry would be made of a corporate representative, inter alia, (1) What do you mean by “uncapped
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`
`
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
`
`2
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
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`

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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 4 of 11
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`IP infringement protection”? (2) Prior to June 28, 2017 did Amazon offer “capped” IP infringement
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`protection, and if so, what did “capped” IP infringement protection mean? (3) Prior to June 28, 2017
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`did Amazon offer any contractual infringement protection for patent infringement claims, to website
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`operator customers of S3? (4) In non-privileged communications between Amazon and website oper-
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`ators sued, what specific interpretations did the parties convey to one another on the scope of Amazon
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`obligations during the period of alleged infringement, namely January 8, 2012 through December 26,
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`2016, including indemnification extending to claims of infringement outside of Amazon systems?
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`The parties have met and conferred, telephonically and by e-mail, concerning the indemnifi-
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`cation issue, on numerous instances beginning in the third week of November, 2018. The proposed
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`order filed concurrently (a) addresses the deposition issue, (b) further extends the deadline for re-
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`solving discovery disputes if the deposition is ordered and also given sub-(c) below, and (c) ad-
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`vances the date of discovery responses (RFA’s and Interrogatories served on December 7, 2018), at-
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`tached as Exhibit 2, given the present compressed time period. Amazon wrongly claims no tele-
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`phone meet and confers, despite knowing to the contrary and refusing to return multiple, recent calls.
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`II.
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`AMAZON’S STATEMENT
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`This discovery dispute is related to Amazon’s motion for summary judgment that Personal-
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`Web’s claims are barred by claim preclusion and the Kessler doctrine. (Dkt. No. 306 at 1; Dkt. No.
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`315.) Amazon has already provided all the non-privileged indemnification-related information that
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`PersonalWeb could possibly need in responding to Amazon’s motion: (1) it produced the AWS cus-
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`tomer agreement, (2) identified the produced agreement as the one pursuant to which it is indemnifying
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`its customers, (3) identified the customers it is indemnifying and detailed the terms of that indemnifi-
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`cation, (4) specified when the first indemnification demand was made in connection with Personal-
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`Web’s claims, and (5) identified the date, June 28, 2017, when the indemnification provision was
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`added to the customer agreement. (Exs. 3-4.) PersonalWeb claims it needs additional discovery to
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`confirm that “Amazon was not contractually obligated to indemnify” its customers during “January 8,
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`2012 to December 26, 2016.” But it does not explain why the identification of the agreement pursuant
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`to which Amazon is indemnifying its customers, the date when the indemnification provision was
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`added to that agreement, and all the terms of Amazon’s indemnification, are insufficient. Nor does it
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`3
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
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`explain why information such as whether indemnification is capped or uncapped is relevant to the
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`claim preclusion motion or to any issue in the case. It is not. And in any event, the AWS agreement
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`does not specify any indemnification caps.
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`It is clear from the language of PersonalWeb’s proposed stipulation that what PersonalWeb
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`actually wants is an admission from Amazon that PersonalWeb’s position on a disputed legal issue is
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`correct—it wants Amazon “to admit [PersonalWeb’s] interpretation of a disputed provision of the
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`[AWS customer] contract.” Gem Acquisitionco, LLC v. Sorenson Group Holdings, LLC, C 09-01484
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`SI, 2010 WL 1340562, at *3 (N.D. Cal. Apr. 5, 2010). The RFAs PersonalWeb just served on De-
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`cember 7, the responses to which it wants to expedite, confirm that. (Ex. 5.) Such requests, and similar
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`deposition topics, are not the proper subject of discovery. See id. (“legal conclusions are not a proper
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`subject of a request for admission”); see also Franklin v. Ryko Corp., No. CV 07-2921-VBF (JTL),
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`2008 WL 11334493, at *4 (C.D. Cal. Oct. 22, 2008) (“The topic that plaintiff has identified in his Rule
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`30(b)(6) notice sets forth, in essence, plaintiff’s legal theory. Therefore, plaintiff appears to be seeking
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`from defendant a witness who will merely affirm the theory underlying plaintiff’s claims. As such,
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`the request is improper.”).
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`cases and what it accused in its prior lawsuit against Amazon and Dropbox, PersonalWeb’s position
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`above includes several other mischaracterizations of the law and relevant facts. PersonalWeb incor-
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`rectly argues that a “predicate” for Amazon’s claim preclusion defense is that Amazon was contrac-
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`tually obligated to indemnify its customers during the period of alleged infringement. As explained
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`in Amazon’s motion, the customer defendants, as users of the accused S3 technology, are in privity
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`with Amazon—regardless of whether they are being indemnified. (See Dkt. No. 315 at pp. 8-9.) Am-
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`azon’s indemnification of its customers is a separate and independent basis for privity; it is not a nec-
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`essary predicate for the relief sought by the motion. (See id.) Moreover, contrary to PersonalWeb’s
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`assertion, whether Amazon became “contractually obligated” to indemnify its customers before or
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`after the expiration of PersonalWeb’s patents is legally irrelevant. Indemnification must, by its nature,
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`be tied to a particular claim. The AWS agreement does not provide any temporal limitation on the
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`indemnification obligation; it merely states that Amazon “will defend [its customers] against any third-
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 6 of 11
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`party claim alleging that the Services infringe or misappropriate that third party’s intellectual property
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`rights”—the very claims PersonalWeb makes in its lawsuits against Amazon customers. Both Ama-
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`zon and the customers, the parties to the agreement, interpreted the provision that way with respect to
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`PersonalWeb’s claims, as the customers requested indemnification under the agreement and Amazon
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`agreed to provide it in response. And, in any event, for purposes of claim preclusion, the indemnifi-
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`cation obligation need only exist at the time of the second case, and not necessarily during the period
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`of alleged infringement. Indeed, in Speedtrack, the court found that a supplier was in privity with its
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`customers for purposes of claim preclusion because it “is contractually obligated to indemnify [cus-
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`tomer] defendants for any losses stemming from a finding of infringement,” i.e. it was contractually
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`obligated to indemnify the customers at the time of the second lawsuit. SpeedTrack, 2014 WL
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`1813292 at *6 (emphasis added). And, finally, contrary to PersonalWeb’s contention, it has never
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`requested in any of the parties’ prior conferences that Amazon agree to the stipulation it proposes
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`above. Instead, during the parties’ last conference on the subject, the parties agreed that in lieu of a
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`deposition, Amazon would supplement its interrogatory response to identify the date of the first de-
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`mand for indemnity by any customer defendant and the date when the indemnification provision was
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`added to the AWS customer agreement (Amazon had already provided the other indemnification in-
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`formation by this time). Amazon served that supplemental response on December 10 as it agreed to
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`do. PersonalWeb went back on its agreement and decided to file this motion, in which for the first
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`time, and without any telephonic conference, it identified the specific additional facts it purportedly
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`needs, requested the extension of the discovery deadline, demanded expedited responses to the dis-
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`covery served last Friday, and requested a continued deposition to take place before December 21.
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`The Court should deny PersonalWeb’s motion in light of the compromise agreement the parties
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`already reached and with which Amazon abided, PersonalWeb’s failure to comply with the procedures
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`of the Court for raising discovery disputes (see July 16, 2018 Civil Scheduling and Discovery Standing
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`Order), and PersonalWeb’s inability to explain the relevance of the information it seeks.
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`5
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
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`

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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 7 of 11
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`Respectfully submitted,
`
`
`
`Dated: December 11, 2018
`
`STUBBS, ALDERTON & MARKILES, LLP
`
`
`
`By: /s/ Michael A. Sherman
`Michael A. Sherman
`Jeffrey F. Gersh
`Sandeep Seth
`Wesley W. Monroe
`Stanley H. Thompson, Jr.
`Viviana Boero Hedrick
`Attorneys for PersonalWeb Technologies, LLC
`and Level 3 Communications, LLC
`
`Dated: December 11, 2018
`
`
`
`MACEIKO IP
`
`Dated: December 11, 2018
`
`
`
`By: /s/ Theodore S. Maceiko
`Theodore S. Maceiko (SBN 150211)
`ted@maceikoip.com
`MACEIKO IP
`420 2nd Street
`Manhattan Beach, California 90266
`Telephone:
`(310) 545-3311
`Facsimile:
`(310) 545-3344
`Attorneys for Defendant
`PERSONALWEB TECHNOLOGIES, LLC,
`
`
`
`DAVID D. WIER
`
`
`
`By: /s/ David D. Wier
`David D. Wier
`david.wier@level3.com
`Vice President and Assistant General Counsel
`Level 3 Communications, LLC
`1025 Eldorado Boulevard
`Broomfield, CO 80021
`Telephone: (720) 888-3539
`Attorneys for Plaintiff
`LEVEL 3 COMMUNICATIONS, LLC
`
`
`
`Dated: December 11, 2018
`
`
`
`
`
`FENWICK & WEST LLP
`
`By: /s/ Saina S. Shamilov
`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`TODD R. GREGORIAN (CSB No. 236096)
`tgregorian@fenwick.com
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 8 of 11
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`PHILLIP J. HAACK (CSB No. 262060)
`phaack@fenwick.com
`RAVI R. RANGANATH (CSB No. 272981)
`rranganath@fenwick.com
`CHIEH TUNG (CSB No. 318963)
`ctung@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Attorneys for AMAZON.COM, INC. and AMA-
`ZON WEB SERVICES, INC.
`
`
`ATTESTATION
`
`The undersigned attests that concurrence in the filing of the foregoing document was ob-
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`tained from all of its signatories.
`
`Dated: December 11, 2018
`
`STUBBS, ALDERTON & MARKILES, LLP
`
`By: /s/ Michael A. Sherman
`Michael A. Sherman
`Attorney for PersonalWeb Technologies, LLC
`and Level 3 Communications, LLC
`
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 9 of 11
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`I declare as follows:
`
`PROOF OF SERVICE
`
` I
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` am employed in the County of Los Angeles, State of California. I am over the age of 18 and
`not a party to the within action. My business address is 15260 Ventura Blvd., 20th Floor, Sherman
`Oaks, California 91403. On December 11, 2018, I served the documents described as: JOINT
`STATEMENT REGARDING DISCOVERY DISPUTE RELATING TO MOTION FOR
`SUMMARY JUDGMENT (DKT. NO. 315) on the interested parties in this action as follows:
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`TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING
`(“NEF”) pursuant to FRCP, Rule 5(b)(2)(E) and JPML Rule 4.1 (Pursuant to con-
`trolling General Order(s) and Local Rule(s) (“LR”), the foregoing document will be
`served by the court via NEF and hyperlink to the document to counsel at the email ad-
`dress(s) listed on Case Docket 5:18-md-02834-BLF).
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`BY U.S. MAIL: (SEE ATTACHED SERVICE LIST) By depositing for collection
`and mailing in the ordinary course of business. I am “readily familiar” with the firm’s
`practice of collection and processing correspondence for mailing. Under that practice
`it would be deposited with U.S. Postal Service on the same day with postage thereon
`fully prepaid at Sherman Oaks, California in the ordinary course of business. I am
`aware that on motion of the party served, service is presumed invalid if postal cancel-
`lation date or postage meter date is more than one day after date of deposit for mailing
`on affidavit.
`
`
`I declare that I am employed in the office of a member of the bar of this court at whose direc-
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`tion the service was made. I declare under penalty of perjury under the laws of the United States of
`America that the above is true and correct. Executed on December 11, 2018, at Sherman Oaks, Cali-
`fornia.
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`/s/ Elizabeth Saal de Casas
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`ELIZABETH SAAL DE CASAS
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`8
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`4851-3132-3010, V. 1
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 10 of 11
`
`SERVICE LIST
`In Re: PersonalWeb Technologies, LLC Case No.: 5:18-md-02834-BLF
`AMAZON.COM, INC. et al., v. PERSONALWEB TECHNOLOGIES, LLC, et al., Case No.: 5:18-cv-00767-BLF
`
`
`AMICUS FTW, INC.
`The Corporation Trust Company
`Corporation Trust Center
`1209 Orange St.
`Wilmington, DE 19801
`
`BUZZFEED, INC.
`c/o CSC
`80 State Street
`Albany, NY 12207
`
`INTUIT, INC.
`c/o Becky DeGeorge
`CSC LAWYERS INCORPORATING SERVICE
`2710 Gateway Oaks Drive, Suite 150N
`Sacramento, CA 95833
`
`
`MWM MY WEDDING MATCH LTD.
`c/o Angel Pui, CEO
`609 Hastings St. W 11th Floor
`Vancouver
`British Columbia
`V6B4W4
`
`OATH, INC.
`c/o CT CORPORATION SYSTEM
`111 Eighth Avenue, 13th Fl
`New York, NY 10011
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`RETAILMENOT, INC.
`c/o Amy McLaren, Authorized Agent
`Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, DE 19801
`
`ROCKETHUB, INC.
`c/o Secretary of State, Authorized Agent
`99 Washington Avenue
`Albany, NY 12207
`
`NDCA Case No. 5:18-cv-00150-BLF
`Agent for Service of Process for Amicus
`FTW, Inc.
`By U.S. Mail
`
`
`NDCA Case No. 5:18-cv-06046-BLF
`Agent for Service of Process on behalf of
`BuzzFeed, Inc.
`Via U.S. Mail
`
`
`NDCA Case No. 5:18-cv-05611-BLF
`Agent for Service of Process on behalf of In-
`tuit, Inc.
`Via U.S. Mail
`
`
`NDCA Case No. 5:18-cv-03457-BLF
`Unrepresented Party
`Last known address
`Via U.S. Mail
`
`NDCA Case No. 5:18-cv-06044-BLF
`Agent for Service of Process on behalf of
`Oath, Inc.
`Via U.S. Mail
`
`NDCA Case No. 5:18-cv-05966
`Agent for Service of Process on behalf of
`RetailMeNot, Inc.
`Via U.S. Mail
`
`NDCA Case No. 5:18-cv-03583-BLF
`Authorized Agent for Service of Process on
`behalf of Rockethub, Inc.
`Via U.S. Mail
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
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`9
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`4851-3132-3010, V. 1
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 320 Filed 12/11/18 Page 11 of 11
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`ELEQT GROUP LTD.
`142 Cromwell Road
`London, SW7 4EF
`United Kingdom
`
`STACK EXCHANGE, INC.
`c/o CSC
`80 State Street
`Albany, NY 12207
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`UPWORK GLOBAL, INC.
`c/o Trisha Rosano
`REGISTERED AGENT SOLUTIONS, INC.
`1220 S. Street, Suite 150
`Sacramento, CA 95811
`
`NDCA Case No. 5:18-cv-03583-BLF
`Unrepresented Party Last known address
`Via U.S. Mail
`
`
`NDCA Case No. 5:18-cv-06045-BLF
`Agent for Service of Process on behalf of
`Stack Exchange, Inc.
`Via U.S. Mail
`
`NDCA Case No. 5:18-cv-05624-BLF
`Authorized Agent to Accept Service on be-
`half of UpWork Global, Inc.
`Via U.S. Mail
`
`ZIFF DAVIS, LLC
`c/o Corporation Service Company
`80 State Street
`Albany, NY 12207-2543
`
`
`SDNY Case No. 1:18-cv-10027-DLC-
`SDA
`Agent for Service of Process for Ziff Da-
`vis, LLC
`Via U.S. Mail
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`ZOOM VIDEO COMMUNICATIONS, INC.
`c/o Mason Tse
`Authorized Agent to Accept Service
`55 S. Almaden Boulevard, Suite 600
`San Jose, CA 95113
`
`NDCA Case No. 5:18-cv-05625-BLF
`Agent authorized to accept service on
`behalf of Zoom Video Communications,
`Inc.
`Via U.S. Mail
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`JOINT STATEMENT RE DISCOVERY DISPUTE
`RELATING TO MOTION FOR SUMMARY
`JUDGMENT (DKT. NO. 315)
`
`10
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`4851-3132-3010, V. 1
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`
`