`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)))))))))
`
`ROBOCAST, INC.,
`
`
`
`
`v.
`
`
`NETFLIX, INC.,
`
`
`Plaintiff and
`Counterclaim Defendant,
`
`C.A. No. 1:22-cv-00305-RGA-JLH
`
`
`Defendant and
`Counterclaim Plaintiff.
`
`
`)
`)
`
`DEFENDANT NETFLIX, INC.’S NOTICE OF DEPOSITION TO
`PLAINTIFF ROBOCAST, INC. PURSUANT TO FED. R. CIV. P. 30(B)(6)
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
`
`Procedure, Defendant and Counterclaim Plaintiff Netflix, Inc. (“Netflix”), by and through its
`
`counsel, will take the deposition of Plaintiff and Counterclaim Defendant Robocast, Inc.
`
`(“Robocast”) by one or more of its officers, directors, managing agents, or other person designated
`
`by Robocast who are most qualified, knowledgeable, and competent to testify on its behalf as to
`
`all matters known or reasonably available to Robocast with respect to the Topics identified in the
`
`attached Schedule A. Robocast is requested to identify each person so designated and to set forth
`
`the matters on which that person will testify at least five (5) days before the deposition.
`
`The deposition will commence on October 2, 2023 at 9:00 am ET, or on a date and at a
`
`time to be mutually agreed upon in writing by counsel for the parties, and take place at the law
`
`offices of Latham & Watkins LLP, 555 Eleventh Street NW, Suite 1000, Washington, D.C. 20004,
`
`or at a location to be mutually agreed upon in writing by counsel for the parties. The deposition
`
`will be conducted under oath by an officer authorized to take such testimony and administer oaths,
`
`for use at trial and all other purposes permissible under the Federal Rules of Civil Procedure and
`
`
`
`Case 1:22-cv-00305-RGA-JLH Document 116 Filed 09/21/23 Page 2 of 2 PageID #: 4588
`
`Local Rules of the United States District Court of the District of Delaware. The deposition will
`
`continue from day to day, or may be continued to a future date or dates, until completed—with
`
`weekends and holidays excepted. This notice is served without waiver of the ability to serve
`
`additional notices to Robocast identifying additional topics of deposition.
`
`PLEASE TAKE FURTHER NOTICE that the deposition will be taken by oral examination
`
`and recorded by stenographic means and videotaped.
`
`
`
`
`
`
`OF COUNSEL:
`
`Tara D. Elliott
`Rachel Weiner Cohen
`Ashley M. Fry
`Diane E. Ghrist
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW
`Suite 1000
`Washington, DC 20004-1304
`(202) 637-2200
`
`Kimberly Q. Li
`LATHAM & WATKINS LLP
`200 Clarendon Street
`Boston, MA 02116
`(617) 880-4500
`
`Dated: September 21, 2023
`
`
`
`
`
`
`
`
`/s/ Kelly E. Farnan
`Kelly E. Farnan (#4395)
`Tyler E. Cragg (#6398)
`RICHARDS, LAYTON & FINGER P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`farnan@rlf.com
`cragg@rlf.com
`
`Attorneys for Defendant and Counterclaim
`Plaintiff Netflix, Inc.
`
`
`
`2
`
`
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