`
`Wilson Sonsini Goodrich & Rosati
`Professional Corporation
`222 Delaware Ave
`Suite 800
`Wilmington, Delaware 19801
`O: 302-304-7600
`F: 866.974.7329
`
`August 7, 2023
`
`VIA ELECTRONIC FILING
`
`IAN R. LISTON
`Internet: ILISTON@wsgr.com
`Direct dial: (302) 304-7606
`
`The Honorable William C. Bryson
`U.S. Court of Appeals, Fed. Cir.
`717 Madison Place, NW
`Washington, D.C. 220439
`
`Re:
`
`Impossible Foods Inc. v. Motif FoodWorks, Inc. and
`Ginkgo Bioworks, Inc.,
`C.A. No. 22-311 (WCB)
`
`
`
`Dear Judge Bryson:
`
`I write on behalf of all parties pursuant to the Court’s Oral Order dated July 26, 2023,
`regarding limits on the discovery mechanisms in the yeast patents case (D.I. 161). The parties
`agree that the following limits should apply:
`
` Requests for Admission. A maximum of 25 requests for admission are permitted for each
`party. Requests for admission directed to the authenticity of documents do not count
`against the foregoing limit on the number of requests for admission.
`
`
`
`Interrogatories. A maximum of 25 interrogatories, including contention interrogatories,
`are permitted for each party.
`
` Depositions. Each party will be limited to 70 hours per side for depositions, including
`third-party and inventor depositions and excluding expert depositions. Unless otherwise
`stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours. Any party or
`representative (officer, director, or managing agent) of a party filing a civil action in this
`district court must ordinarily be required, upon request, to submit to a deposition at a place
`designated within this district. Exceptions to this general rule may be made by order of the
`court or by agreement of the parties. A defendant who becomes a counter-claimant, cross-
`claimant, or third-party plaintiff shall be considered as having filed an action in this district
`court for purposes of this provision.
`
`AUSTIN BEIJING BOSTON BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO
`SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE
`
`
`
`Case 1:22-cv-00311-WCB Document 170 Filed 08/07/23 Page 2 of 2 PageID #: 15177
`
`The Hon. William C. Bryson
`August 7, 2023
`Page 2
`
`cc:
`
`All counsel of record (via CM-ECF)
`
`Respectfully,
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`
`/s/ Ian R. Liston
`Ian R. Liston (#5507)
`Counsel for Plaintiff Impossible Foods, Inc.
`
`
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