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Case 1:22-cv-00304-JLH Document 225 Filed 06/20/24 Page 1 of 2 PageID #: 9636
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`ROBOCAST, INC.
`a Delaware corporation,
`
`
`
`
`
`YOUTUBE, LLC, a Delaware limited
`liability company; and GOOGLE LLC,
`a Delaware limited liability company,
`
`
`
`Plaintiff,
`
`v.
`
`Defendants.
`
`
`
`
`
`
`
`C.A. No. 22-304- JLH
`
`
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`MOTION FOR TELECONFERENCE TO RESOLVE DISCOVERY DISPUTES
`
`
`
`Defendants YouTube, LLC and Google LLC (together, “Defendants”) respectfully move
`
`the Court to schedule a teleconference to address an outstanding dispute with Plaintiff Robocast,
`
`Inc. pertaining to the following discovery matter:
`
`• Robocast’s refusal to provide substantive responses to Defendants’ Interrogatory
`
`Nos. 16-25 because of Google’s numerosity objections to Robocast’s Second Set
`
`of Interrogatories (Issue No. 1 in Robocast’s Motion for Teleconference to
`
`Resolve Discovery Disputes (D.I. 224)).
`
`The following attorneys, including at least one Delaware Counsel and at least one Lead
`
`Counsel per party, participated in verbal meet and confers by telephone concerning Google’s
`
`numerosity objections to Robocast’s Second Set of Interrogatories on at least the following dates:
`
`May 17, 2024 and June 11, 2024.
`
`Delaware Counsel: Ronald P. Golden III (Robocast); Fred Cottrell, Christine Haynes
`
`(Defendants).
`
`Lead Counsel: Marc Henschke (Robocast); Jordan Jaffe, Catherine Lacey, Callie Davidson
`
`(Defendants).
`
`RLF1 31121663v.1
`
`1
`
`

`

`Case 1:22-cv-00304-JLH Document 225 Filed 06/20/24 Page 2 of 2 PageID #: 9637
`
`The parties are generally available for a teleconference at the Court’s convenience and
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`further note that a teleconference before Judge Burke is currently scheduled on August 5, 2024.
`
`(D.I. 180).
`
`
`
`
`
`OF COUNSEL:
`
`Jordan R. Jaffe
`Amy H. Candido
`Catherine Lacey
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza, Suite 330
`San Francisco, CA 94105-1126
`
`Neil Desai
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`953 E. 3rd St., Suite #100
`Los Angeles, CA 90013
`
`Dated: June 20, 2024
`
`
`
`
`/s/ Christine D. Haynes
`Frederick L. Cottrell, III (#2555)
`Christine D. Haynes (#4697)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`haynes@rlf.com
`
`Attorneys for Defendants YouTube, LLC and
`Google LLC
`
`
`RLF1 31121663v.1
`
`2
`
`

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