`
`
`
`October 11, 2024
`
`
`
`
`Via ECF
`Hon. Julien X. Neals, U.S.D.J.
`Martin Luther King, Jr. Federal Building
`and U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07101
`
`
`
`
`
`
`Re: In re Apple Inc. Smartphone Antitrust Litigation,
` Civil Action No. 2:24-md-03113 (JXN)(LDW)
`
`
`Dear Judge Neals:
`
`
` On behalf of Hausfeld LLP and Susman Godfrey LLP as Proposed Co-Lead Counsel
`(“Proposed Co-Leads”) for the Direct Purchaser Plaintiff (“DPP”) Class, we respond to Your
`Honor’s inquiries in Text Orders issued over the past two days concerning the technology tutorial
`scheduled for November 6, 2024 and “organizational and other matters.”
`
` Daniel Weick and Mark Musico, along with either the undersigned or Michael Critchley,
`will attend the November 6th technology tutorial on behalf of the Proposed Co-Leads, assuming
`that no hearing on other issues is scheduled on that date.
`
` We have reviewed the letter filed yesterday by James E. Cecchi – to whom we tried
`reaching out on Wednesday to coordinate a single letter on behalf of all private plaintiffs, direct
`and indirect. The Proposed Co-Leads are prepared to address the lead counsel issue at the Court’s
`convenience. However, should the Court prefer first to take up the motion to dismiss directed to
`the complaint filed by the DOJ and state attorneys general, we stand ready to proceed in whatever
`manner the Court deems most efficient. In this regard, though, it bears mention that the Proposed
`Co-Leads have pleaded factual allegations beyond those of the governmental entities and other
`private plaintiffs, and we intend to plead additional anticompetitive conduct by Apple.
`
`
`
`Respectfully Submitted,
`
`/s/ Joseph J. DePalma
`
`Joseph J. DePalma
`
`
`
`JJD:cd
`
`1010214.1
`
`

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