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`EXHIBIT 2012
`EXHIBIT 20 1 2
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`

`

`Lauren Van Winkle
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Morgan, Christine <CMorgan@ReedSmith.com>
`Tuesday, November 12, 2013 2:55 PM
`Justin Nemunaitis
`Ericsson_D-Link; Mitchell, Jonah
`RE: Ericsson v. D-Link - Broadcom IPR
`
`Follow Up Flag:
`Flag Status:
`
`Follow up
`Flagged
`
`Justin – as far as we understand it, the IPR is a proceeding initiated by Broadcom to which our clients are not parties.
`We do not believe our clients are under any obligation to respond to your request or engage in any further dialogue
`about it. On behalf of our clients, we reserve all rights. Best - Chris
`
`
`Christine M. Morgan
`cmorgan@reedsmith.com
`+1 415-659-5970
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105-3659
`T: +1 415 543 8700
`F: +1 415 391 8269
`reedsmith.com
`From: Justin Nemunaitis [mailto:jnemunaitis@McKoolSmith.com]
`Sent: Tuesday, November 12, 2013 2:35 PM
`To: Morgan, Christine
`Cc: Ericsson_D-Link; Mitchell, Jonah
`Subject: RE: Ericsson v. D-Link - Broadcom IPR
`
`
`Chris,
`
`
`Does that mean that your clients are unwilling to provide this information due to the lack of a formal discovery request?
`
`
`Do your clients have any other objections to providing this information if, for example, a suitable protective order is
`obtained in the IPR?
`
`
`Regards,
`Justin
`
`
`From: Morgan, Christine [mailto:CMorgan@ReedSmith.com]
`Sent: Tuesday, November 12, 2013 3:44 PM
`To: Justin Nemunaitis
`Cc: Ericsson_D-Link; Mitchell, Jonah
`Subject: RE: Ericsson v. D-Link - Broadcom IPR
`
`Justin: This appears to be a request that should be directed to Broadcom in connection with the IPR proceeding, not to
`our clients, who are third parties. Best - Chris
`
`
`Christine M. Morgan
`cmorgan@reedsmith.com
`+1 415-659-5970
`
`1
`
`

`

`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105-3659
`T: +1 415 543 8700
`F: +1 415 391 8269
`reedsmith.com
`From: Justin Nemunaitis [mailto:jnemunaitis@McKoolSmith.com]
`Sent: Tuesday, November 12, 2013 1:31 PM
`To: Morgan, Christine
`Cc: Ericsson_D-Link
`Subject: RE: Ericsson v. D-Link - Broadcom IPR
`
`
`Counsel,
`
`
`Following up on my email below, please let me know if Defendants will be providing the requested information in a form
`that may be shared with the PTAB and with Ericsson’s IPR counsel.
`
`
`Regards,
`Justin
`
`
`From: Justin Nemunaitis
`Sent: Friday, November 08, 2013 4:15 PM
`To: Morgan, Christine (CMorgan@ReedSmith.com); ToshibaDefendants-Ericsson@foley.com; Dell-Ericsson@alston.com
`(Alston) (Dell-Ericsson@alston.com)
`Cc: Ericsson_D-Link
`Subject: RE: Ericsson v. D-Link - Broadcom IPR
`
`
`Counsel,
`
`
`Following up on my email below, please let me know if Defendants will be providing the requested information in a form
`that may be shared with the PTAB and with Ericsson’s IPR counsel.
`
`
`Thanks,
`Justin
`
`
`From: Justin Nemunaitis
`Sent: Wednesday, November 06, 2013 4:38 PM
`To: Morgan, Christine (CMorgan@ReedSmith.com); ToshibaDefendants-Ericsson@foley.com; Dell-Ericsson@alston.com
`(Alston) (Dell-Ericsson@alston.com)
`Cc: Ericsson_D-Link
`Subject: RE: Ericsson v. D-Link - Broadcom IPR
`
`
`Dear Counsel,
`
`I write in regard to Broadcom’s petitions for inter partes review of the patents found infringed in Ericsson v. D-Link.
`Ericsson believes that those petitions should be barred under 35 U.S.C. § 315(b) because at least one of the defendants
`in this case is the privy of Broadcom. To assist the PTAB in evaluating that issue, we request that Defendants allow the
`PTAB access to relevant documents. Specifically, Ericsson requests that Defendants provide non-confidential versions of
`the documents below that can be shared with the PTAB and with Ericsson’s IPR counsel:
`
`
`• All indemnity agreements between Defendants and Broadcom related to the products at issue in the lawsuit.
`
`• All joint defense agreements related to Ericsson v. D-Link signed by Broadcom and any of the defendants in
`this case.
`
`2
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`

`

`
`If Defendants will not agree to Ericsson’s requests, please let me know why.
`
`
`Thanks,
`Justin
`
`
`
`Justin Nemunaitis | McKool Smith
`300 Crescent Court, Suite 1500, Dallas, Texas 75201
`tel: 214.978.4213 fax: 214.978.4044
`
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