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`Exhibit D
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`
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`M ELISSA B. C OLLINS
`(202) 434-5916
`mcollins@wc.com
`
`
`Case 1:14-cv-02396-PGG-SN Document 249-4 Filed 04/07/21 Page 2 of 2
`
`
`
`
`
`
`VIA E-mail
`
`
`Amy E. Hayden
`Russ August & Kabat LLP
`12424 Wilshire Blvd., 12th Floor
`Los Angeles, CA 90025
`ahayden@raklaw.com
`
`March 5, 2021
`
`
`
`Re: Network-1 Technologies, Inc. v. Google LLC, et al. , Nos.
`
`
`
`1:14-cv-2396-PGG-SN & 1:14-cv-9558-PGG-SN (S.D.N.Y.)
`
`Dear Amy:
`
`I write in response to your March 3, 2021 letter. Defendants have not “re-open[ed]”
`discovery. Defendants have supplemented their responses to interrogatories and are in the
`process of supplementing their responses to requests for production, propounded by Network-1
`during the discovery period, in accordance with Defendants’ on-going obligations under Federal
`Rule of Civil Procedure 26(e). See, e.g., Lujan v. Cabana Mgmt., Inc. , 284 F.R.D. 50, 68
`(E.D.N.Y. 2012) (“The obligation to amend prior disclosures and discovery responses continues
`even after the conclusion of discovery.”). Neither leave of the Court nor permission from
`Network-1 is required, and your unsupported assertion that Defendants’ discovery
`
`supplementations “are not a part of these cases” carries no legal weight.
`
`
`In the spirit of cooperation, Defendants also have indicated that, should Plaintiff want to
`take additional discovery on this topic, Defendants would not oppose a request for additional
`30(b)(6) deposition testimony, provided that it is limited reasonably limited in time and scope to
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`address Defendants’ supplementation.
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`
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`Sincerely,
`
`/s/ Melissa B. Collins
`
`Melissa B. Collins
`
`
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