Case 1:22-cv-00305-RGA-JLH Document 70 Filed 05/12/23 Page 1 of 2 PageID #: 891
`
`Tyler E. Cragg
`(302) 651-7705
`cragg@rlf.com
`May 12, 2023
`
`BY CM/ECF
`The Honorable Jennifer L. Hall
`United States District Court
`District of Delaware
`844 North King Street
`Wilmington, DE 19801
`
`Re: Robocast, Inc. v. Netflix, Inc., C.A. No. 22-305-RGA-JLH
`
`Dear Judge Hall:
`
`Defendant Netflix, Inc. (“Netflix”) respectfully submits this letter in response to Plaintiff
`Robocast, Inc.’s (“Robocast”) May 11, 2023 letter (D.I. 69, the “Letter”) seeking to strike Netflix’s
`Motion for Teleconference to Resolve Discovery Disputes (D.I. 68, the “Motion”). Contrary to
`Robocast’s assertions in the Letter, the discovery dispute raised in the Motion is ripe and overdue
`for submission to the Court.
`
`The issue raised in the Motion has been ripe for more than a month. The parties met and
`conferred regarding this dispute on March 28 and April 10, 2023, as stated in the Motion.
`Thereafter, on April 12, 2023, Netflix contacted Judge Andrews’ Chambers to raise the dispute in
`the Motion and obtained dates in early May. D.I. 66. Judge Andrews then referred this and other
`discovery disputes to Your Honor and directed the parties to follow Your Honor’s discovery
`dispute procedures. Id. It has now taken the parties a month to negotiate a procedural document
`to initiate the discovery disputes before Your Honor.
`
`During that time, the parties have remained at an impasse. As the Letter states, the parties
`met and conferred again on May 1, 2023. Although Robocast argued that its subsequent
`production of documents would resolve the dispute, Netflix disagrees. Robocast may not
`unilaterally declare the dispute resolved. Therefore, the dispute described in the Motion is still
`ripe and Netflix has satisfied its Local Rule 7.1.1 obligation.
`
`Finally, during the May 10, 2023 meet and confer Robocast stated it was available on May
`17 and June 9, 2023 for a teleconference with the Court and did not state that its availability was
`limited to specific issues. Accordingly, Netflix included those dates in the Motion, a copy of which
`was sent to Robocast prior to filing. Ex. A. Netflix requests that the Court schedule a discovery
`dispute conference at the Court’s convenience.
`
`

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`Case 1:22-cv-00305-RGA-JLH Document 70 Filed 05/12/23 Page 2 of 2 PageID #: 892
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`The Honorable Jennifer L. Hall
`May 12, 2023
`Page 2
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`cc: All Counsel of Record (CM/ECF)
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`Respectfully,
`
`/s/ Tyler E. Cragg
`
`Tyler E. Cragg (#6398)
`
`