`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`Civil Action No. 1:15-cv-04219-TWT
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`
`
`IRONBURG INVENTIONS LTD.,
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`Plaintiff,
`
`v.
`
`VALVE CORPORATION,
`
`Defendant.
`
`
`DEFENDANT VALVE CORPORATION’S
`MOTION TO COMPEL SUPPLEMENTAL INTERROGATORY
`RESPONSES AND TO COMPEL DOCUMENT PRODUCTION
`
`Defendant Valve Corporation (“Valve”) respectfully moves the Court,
`
`pursuant to Federal Rule of Civil Procedure 37 and Local Rule 37.1, for an order
`
`compelling Plaintiff Ironburg Inventions Ltd. (“Ironburg”) to fully supplement its
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`interrogatory responses and to produce documents responsive to Valve’s requests.
`
`In support of this Motion, Valve relies upon the accompanying Memorandum of
`
`Law and exhibits filed herewith.
`
`
`
`
`
`1
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`
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`Case 1:15-cv-04219-TWT Document 94 Filed 03/07/17 Page 2 of 3
`
`Dated: March 7, 2017
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`By: /s/ Patrick A. Lujin
`Patrick A. Lujin
`MO Bar No. 41392 (Pro Hac Vice)
`B. Trent Webb
`MO Bar No. 40778 (Pro Hac Vice)
`Mark D. Schafer
`MO Bar No. 67197 (Pro Hac Vice)
`SHOOK, HARDY & BACON L.L.P.
`2555 Grand Boulevard
`Kansas City, Missouri 64108
`Telephone: (816) 474-6550
`
`By: /s/ Ann Fort
`Thomas W. Curvin
`GA Bar No. 202740
`Ann G. Fort
`GA Bar No. 269995
`EVERSHEDS SUTHERLAND (US) LLP
`999 Peachtree Street N.E. Suite 2300
`Atlanta, GA 30309
`Telephone: (404) 853-8000
`
`Tanya L. Chaney
`TX Bar No. 24036375 (Pro Hac Vice)
`SHOOK, HARDY & BACON L.L.P.
`600 Travis Street, Suite 3400
`Houston, Texas 77002
`Telephone: (713) 227-8008
`
`Attorneys for Defendant
`VALVE CORPORATION
`
`
`
`2
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`Case 1:15-cv-04219-TWT Document 94 Filed 03/07/17 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 7, 2017, I electronically filed the foregoing
`
`MOTION TO COMPEL
`
`SUPPLEMENTAL
`
`INTERROGATORY
`
`RESPONSES AND TO COMPEL DOCUMENT PRODUCTION with the
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`Clerk of Court using the CM/ECF system which will automatically send email
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`notification of such filing to the following attorneys of record:
`
`Cynthia R. Parks, GA Bar No. 563929
`Parks IP Law LLC
`730 Peachtree St. NE, Suite 600
`Atlanta, GA 30308
`Telephone: (678) 365-4444
`Facsimile: (678) 365-4450
`
`Robert D. Becker, CA Bar No. 160648 (Pro Hac Vice)
`Manatt, Phelps & Phillips LLP-CA
`1841 Page Mill Road
`Palo Alto, CA 94304
`Telephone: (650) 812-1300
`
`
`
`
`
`By: /s/ Patrick A. Lujin
`Patrick A. Lujin
`SHOOK, HARDY & BACON L.L.P.
`2555 Grand Boulevard
`Kansas City, Missouri 64108
`Telephone: (816) 474-6550
`
`Attorney for Defendant
`VALVE CORPORATION
`
`3
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