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`Exhibit C
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`
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`Case 1:14-cv-02396-PGG-SN Document 249-3 Filed 04/07/21 Page 2 of 2
`
`
`
`!
`
`12424
`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
`
`Tel 310.826.7474
`Fax 310.826.6991
`www.raklaw.com
`
`
`
`
`
`Dear Melissa:
`On February 19, 2021 Defendants served supplemental interrogatory responses in the
`above-captioned cases. You indicated in your email of the same date that Defendants “are in the
`process of identifying relevant documents and will produce them when they are available” and
`“are prepared to make available a corporate representative for 30(b)(6) testimony” on topics
`related to these interrogatory responses and the forthcoming document production.
`As you know, fact discovery closed more than a year ago on November 1, 2019. Dkt. No.
`139 (Case No. 1:14-cv-2396-PGG-SN). Defendants cannot unilaterally re-open discovery. Nor
`can Network-1 grant permission for Defendants to do so. Defendants need to seek leave from
`the Court and make a showing of good cause. Because Defendants have not done so, the
`February 19, 2021 interrogatory responses and any subsequent production are not a part of these
`cases.
`
`Amy E. Hayden
`ahayden@raklaw.com
`
`March 3, 2021
`
`Via E-mail
`
`Melissa Collins
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
`mcollins@wc.com
`
`Re: Network-1 Technologies, Inc. v. Google LLC, et al., Nos. 1:14-cv-2396-
`PGG-SN & 1:14-cv-9558-PGG-SN
`
`Best regards,
`
`/s/ Amy E. Hayden
`
`Amy E. Hayden
`
`
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