From: Cunningham, Laura [mailto:lcunningham@cooley.com]
`Sent: Thursday, May 22, 2014 6:21 PM
`To: Hollis, Amanda
`Cc: Altieri, Stephen; Graves, Jon; Wang, Jing; z/IPR2014-00003; Holland, Elizabeth;
`Hardman, Cynthia Lambert; De Vries, Mike W.; Schmidt, Leslie M.; J. Mitchell Jones
`Subject: RE: IPR2014-00003: Protective Order
`
`Amanda,
`
`We have accepted your edits and made additional edits in redline. Please provide
`Aker’s position on this draft as soon as possible. While we had hoped the PO could
`incorporate the parties’ agreement regarding at least some specific ITC documents, no
`such agreement has yet been reached, and we need to get a protective order in place
`before additional depositions take place to avoid issues such as those we had during
`yesterday’s deposition.
`
`Regards,
`Laura
`
`From: Hollis, Amanda [mailto:ahollis@kirkland.com]
`Sent: Sunday, May 11, 2014 8:25 PM
`To: Cunningham, Laura
`Cc: Altieri, Stephen; Graves, Jon; Wang, Jing; z/IPR2014-00003; Holland, Elizabeth;
`Hardman, Cynthia Lambert; De Vries, Mike W.; Schmidt, Leslie M.; J. Mitchell Jones
`Subject: RE: IPR2014-00003: Protective Order
`
`Laura,
`
`Attached are our edits to your proposed Protective Order. We do not think a provision
`allowing counsel access to all confidential ITC trial exhibits is necessary, especially
`considering that there were many issues and documents in the ITC case that are not
`relevant to the IPR. Instead we propose that if the parties wish to use confidential
`documents from the ITC case they attempt to work out an agreement as to those
`specific documents.
`
`Regards,
`Amanda
`
`Amanda Hollis | Kirkland & Ellis LLP
`300 North LaSalle | Chicago, IL 60654
`
`1
`
`AKBM 1111
`
`

`
`312-862-2011 | amanda.hollis@kirkland.com
`
`
`From: Cunningham, Laura [mailto:lcunningham@cooley.com]
`Sent: Thursday, May 08, 2014 8:36 AM
`To: Hollis, Amanda
`Cc: Altieri, Stephen; Graves, Jon; Wang, Jing; z/IPR2014-00003; Holland, Elizabeth;
`Hardman, Cynthia Lambert; De Vries, Mike W.; Schmidt, Leslie M.; J. Mitchell Jones
`Subject: RE: IPR2014-00003: Protective Order
`
`Amanda,
`
`Please let us know when you expect to be able to provide AKBM’s position on the
`proposed protective order. We need to get this in place as soon as possible, and of
`course, before depositions begin.
`
`Regards,
`Laura
`
`_____________________________________________
`From: Cunningham, Laura
`Sent: Monday, May 05, 2014 10:24 AM
`To: Hollis, Amanda
`Cc: Altieri, Stephen; Graves, Jon; Wang, Jing; z/IPR2014-00003; Holland, Elizabeth;
`Hardman, Cynthia Lambert; De Vries, Mike W.; Schmidt, Leslie M.; J. Mitchell Jones
`Subject: IPR2014-00003: Protective Order
`
`
`
`Amanda,
`
`Further to the parties’ discussions, attached is our proposed draft protective order.
`Please let us know if this is agreeable to AKBM as soon as possible.
`
`Regards,
`Laura
`
`Laura J. Cunningham
`Cooley LLP • One Freedom Square • Reston Town Center
`11951 Freedom Drive • Reston, VA 20190-5656
`Direct: (703) 456-8091• Fax: (703) 456-8100
`Email: lcunningham@cooley.com • www.cooley.com
`
`<< File: Doc#106559479_v2_IPR2014-00003 - Protective Order.DOCX >>
`
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