UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`
`HUGHES NETWORK SYSTEMS, LLC and
`HUGHES COMMUNICATIONS, INC.,
`
`Petitioners,
`
`v.
`
`CALIFORNIA INSTITUTE OF TECHNOLOGY,
`
`Patent Owner.
`____________________________
`
`IPR2015-00059 (Patent 7,916,781)
`____________________________
`
`PETITIONERS’ RESPONSE IN OPPOSITION TO PATENT OWNER’S
`MOTION FOR ROUTINE AND ADDITIONAL DISCOVERY
`
`
`
`
`
`
`
`
`____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`
`HUGHES NETWORK SYSTEMS, LLC and
`HUGHES COMMUNICATIONS, INC.,
`
`Petitioners,
`
`v.
`
`CALIFORNIA INSTITUTE OF TECHNOLOGY,
`
`Patent Owner.
`____________________________
`
`IPR2015-00059 (Patent 7,916,781)
`____________________________
`
`PETITIONERS’ RESPONSE IN OPPOSITION TO PATENT OWNER’S
`MOTION FOR ROUTINE AND ADDITIONAL DISCOVERY
`
`
`
`
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`Patent Owner’s assertion that non-parties DISH Network Corporation, DISH
`
`Network L.L.C., and dishNET Satellite Broadband L.L.C. (collectively, “DISH”)
`
`are unnamed real parties-in-interest (“RPII”) is based on speculation, application of
`
`an incorrect legal test, and improper reliance on factors that the Board has
`
`previously held are insufficient to create RPII status. As a result, Caltech’s motion
`
`for additional discovery fundamentally fails because it does not, and cannot,
`
`demonstrate beyond speculation how any of its requests would be substantively
`
`useful to its allegations that DISH is a RPII. Caltech admits that it does not know
`
`what it will find, and even admits that it does not know if requested documents
`
`exist. Such speculative discovery is not allowed in an IPR proceeding and should
`
`be denied.
`
`Caltech’s additional discovery requests are also improperly invasive of the
`
`attorney-client privilege. Many of the requests seek privileged information, such
`
`as communications between members of a joint defense group, or billing records.
`
`Caltech also improperly uses its motion as an unauthorized reply to
`
`Hughes’s additional briefing on RPII issues. Seeking to reargue the issues again,
`
`Caltech mischaracterizes the statements of Hughes and Timothy Jezek concerning
`
`the RPII issue. Petitioners’ brief on the RPII issue is clear. DISH did not fund,
`
`direct, or control these IPRs, nor did it have the ability to do so. To the extent
`
`
`
`1
`
`
`
`Caltech argues or responds to Petitioners’ brief on this issue, Hughes respectfully
`
`requests the Board disregard Caltech’s unauthorized arguments.
`
`II. CALTECH FAILS TO SHOW HOW THE REQUESTS FOR
`ADDITIONAL DISCOVERY ARE NECESSARY
`IN THE
`INTERESTS OF JUSTICE
`
`The moving party seeking discovery has the burden of demonstrating that
`
`the additional discovery is necessary “in the interest of justice.” 37 C.F.R. §
`
`42.51(b)(2); TPG, at 48,761; Garmin Int’l, Inc. v. Cuozzo Speed Tech., LLC, Case
`
`IPR2012-00001, Paper 26, at 6 (PTAB Mar. 5, 2013). The Board in Garmin has
`
`identified five factors important in determining whether a discovery request meets
`
`this “interest of justice” requirement. Id., at 6–7.
`
`An important factor when evaluating a request for additional discovery is
`
`whether the party seeking additional discovery has shown that there is more than a
`
`“mere possibility of finding something useful, and mere allegation that something
`
`useful will be found.” Apple Inc. v. Achates Reference Publishing, Inc., IPR2013-
`
`00080, Paper 17, at 5 (PTAB Apr. 3, 2013). Instead, “the requester of information
`
`should already be in possession of a threshold amount of evidence or reasoning
`
`tending to show beyond speculation that something useful will be uncovered.”
`
`Garmin, at 7. In this context, the concept of “‘useful’ means favorable in
`
`substantive value to a contention of the party moving for discovery.” Id.
`
`Therefore, the party moving for discovery must show more than mere relevance,
`
`
`
`2
`
`
`
`but must show beyond speculation, that in fact something useful to a contention of
`
`the moving party will be uncovered. See Garmin, at 6–7.
`
`Caltech argues that additional discovery is required into whether DISH is an
`
`unnamed RPII. In an IPR proceeding, “the ‘real party-in-interest’ may be the
`
`petitioner itself, and/or it may be the party or parties at whose behest the petition
`
`has been filed.” TPG, at 48,759 (emphasis added). The question is whether an
`
`unnamed party “funds and directs and controls an IPR” petition or whether that
`
`other party is “litigating through a proxy.” TPG at 48,760; Aruze Gaming Macau,
`
`Ltd. v. MGT Gaming, Inc., IPR2014-01288, Paper 13, at 12 (PTAB Feb. 20, 2015).
`
`Therefore,
`
`to satisfy
`
`its burden, Caltech must demonstrate beyond
`
`speculation that something substantively useful will be uncovered regarding its
`
`contention that the IPR petitions were filed “at the behest of” DISH. Caltech fails
`
`to satisfy this heavy burden.
`
`A. Caltech’s Requests Rely on the Wrong Legal Test
`Caltech ignores the discovery standard in IPR proceedings and instead
`
`attempts to seek discovery under the more liberal relevance standard available in
`
`district court. In support of each discovery request, Caltech merely argues that the
`
`requested information is “relevant.” But, the requesting party’s burden to show the
`
`information will be “useful” in the context of an additional discovery request “does
`
`not mean merely ‘relevant’ and/or ‘admissible.’” Garmin, at 7.
`
`
`
`3
`
`
`
`Specifically, Caltech alleges that RFP No. 1 and Interrogatory No. 3 seek
`
`“relevant documents” and that production of no documents in response “would be
`
`highly relevant.” Paper 17, at 7. Caltech also argues that RFP No. 2 seeks
`
`“documents [that] are relevant to specific positions advanced by Hughes. . . .”
`
`Paper 17, at 8 (emphasis added). In support of RFP Nos. 3–5 Caltech states that
`
`the requests are “in the interest of justice, as they are directed to information that is
`
`highly relevant.” Paper 17, at 9, 11 (emphasis added). Interrogatory Nos. 1–2 also
`
`merely argue that the information sought is “relevant” to the RPII issue. Paper 17,
`
`at 12, 15.
`
`Patent Owner cites a previous CBM decision as granting additional
`
`discovery before cross-examination. Paper 17, at 7. However, CBM proceedings
`
`have a “more liberal ‘good cause’ standard” as compared to the “interests of
`
`justice” standard for discovery in an IPR. TPG, at 48,761; Bloomberg Inc. v.
`
`Markets-Alert Pty. Ltd., CBM2013-00005, Paper No. 32, at 2 (PTAB May 29,
`
`2013) (“While an interests of justice standard is employed in granting additional
`
`discovery in inter partes reviews, a good cause standard is applied in post-grant
`
`reviews and covered business method patent reviews.”). Therefore, Caltech’s
`
`requests should be denied as relying on the incorrect legal standard.
`
`
`
`4
`
`
`
`B. Caltech Fails to Show Beyond Speculation that Something Useful
`will be Found
`
`The party requesting discovery in an IPR must do more than merely allege
`
`the possibility of finding something useful. Garmin, at 6. Instead, the party
`
`moving for discovery “should already be in possession of evidence tending to
`
`show beyond speculation that in fact something useful will be uncovered.” Id.
`
`(emphasis added). Because Caltech’s requests are based on speculation, they
`
`should be denied.
`
`Caltech’s Requests Are Entirely Speculative
`
`1.
`As evidenced by its arguments in support of discovery, Caltech’s requests
`
`are largely a shot in the dark. First, Caltech admits that it does not know if many
`
`of the requested documents even exist. For example, in support of RFP Nos. 1 and
`
`5, and Interrogatory Nos. 2–3, Caltech argues that the non-existence of the
`
`requested documents would be “relevant.” Paper 17, at 7, 12. In addition, in
`
`support of RFP No. 5 and Interrogatory No. 2, Caltech argues that if “no
`
`documents are produced it will contribute to the totality of the circumstances”
`
`related to the issue of RPII. Paper 17, at 12. Caltech cannot satisfy its burden of
`
`showing the requests are in the interest of justice and that something useful will be
`
`found when it does not know if anything responsive even exists.
`
`Moreover, it is entirely unclear what Caltech expects to find as a result of
`
`RFP No. 1. Caltech merely speculates that “Mr. Jezek presumably needed to
`
`
`
`5
`
`
`
`review relevant documents” to support his declaration. Paper 17, at 7 (emphasis
`
`added). But, Caltech does not explain why Mr. Jezek would need to review
`
`specific documents, or what documents he would have necessarily reviewed and
`
`how they would be useful to support its contentions. Any documents referenced in
`
`Mr. Jezek’s declaration were disclosed concurrently with the declaration,
`
`consistent with § 42.51(b)(1)(i). See Jezek Decl., Paper 1070, at ¶ 11.
`
`2.
`
`Caltech Fails to Demonstrate Beyond Speculation that
`Something Useful Will be Found
`
`Even where Caltech actually knows the requested documents exist, it does
`
`not satisfy its burden of showing beyond speculation that something useful to its
`
`RPII contentions will be found as a result of any request.
`
`First, in support of RFP Nos. 1–5 and Interrogatory Nos. 1–3 and throughout
`
`its motion, Caltech generally alleges that each request would allow Caltech and the
`
`Board to evaluate the credibility or weight of Mr. Jezek’s declaration. Paper 17, at
`
`6–11, 13–14. Caltech does not support this bare allegation by stating what it
`
`expects to find. Nor does it explain how uncovered documents will be favorable to
`
`its RPII contentions. RFP No. 1 and Interrogatory No. 3 are entirely based on this
`
`generalized speculation that the information will allow it to “properly evaluate
`
`whether the testimony should be accorded any weight.” Paper 17, at 6–7. Because
`
`Caltech makes no attempt to show that it will uncover something useful to support
`
`its RPII contentions, these requests should be denied.
`
`
`
`6
`
`
`
`RFP No. 4 is also an entirely speculative attempt to discover documents for
`
`general “credibility” purposes. Mr. Jezek stated that “DISH did not direct, control,
`
`or suggest the filing of these Petitions. DISH did not provide any input into the
`
`content of the Petitions. DISH did not participate in the preparation or filing of the
`
`petitions.” Exhibit 1070, at ¶ 5. Caltech’s request for documents contrary to this
`
`statement are based entirely on speculation. Moreover, Caltech does not even
`
`allege that there are any communications between DISH and Hughes regarding the
`
`IPR petitions. Thus, this request is merely a blind fishing expedition. Caltech
`
`plainly does not know what it will find as a result of the requests. Nor has it shown
`
`that the uncovered information will be useful to support its contentions. Therefore,
`
`this request should be denied.
`
`RFP Nos. 2 and 3 generally seek facts that are insufficient to make a non-
`
`party a RPII. With regard to RFP No. 2, the only information Caltech seems to
`
`allege will be uncovered is that both DISH and Hughes participated in preparing
`
`the invalidity contentions filed in district court litigation. But, Caltech does not
`
`explain how that information would be useful in support of its contentions that the
`
`IPR was filed at the behest of DISH. Preparation of joint invalidity contentions is
`
`an entirely routine aspect of a joint defense group, which does not make a non-
`
`party an RPII of the petition, or even a privy of the petitioner. See TPG, at 48,760.
`
`Further, Hughes’s use of the previously filed invalidity contentions to inform its
`
`IPR petitions would be entirely consistent with its independent decision to file the
`
`7
`
`
`
`IPR. It would have been impractical, irrational, and a waste of resources to ignore
`
`the prior art already found in district court litigation. Caltech does not explain why
`
`the reuse of prior art is useful to its contentions.
`
`In support of RFP No. 3, Caltech alleges only that it will uncover an
`
`indemnity agreement between DISH and EchoStar that would cover “damages
`
`arising from intellectual property claims.” Paper 17, at 10. However, despite
`
`Caltech’s indication to the contrary, indemnification “is not one of the ‘substantive
`
`legal relationships’ cited in Taylor (e.g., assignee-assignor), and is significantly
`
`different from those relationships, which involve successive interests in property.”
`
`Achates, at 5 (finding an indemnify agreement insufficient to make a non-party an
`
`RPII, even when coupled with participation in a joint defense group). As a result,
`
`indemnification obligations are insufficient to “demonstrate beyond speculation”
`
`that a non-party is a RPII. Wavemarket Inc. v. Locationet Systems Ltd., IPR2014-
`
`00199, Paper 34, (August 11, 2014).
`
`Furthermore, Caltech argues that the existence of documents sought by RFP
`
`Nos. 2–3 are not “mere speculation.” Paper 17, at 8, 10. But merely showing that
`
`documents are likely to “exist” is not sufficient to satisfy the burden of showing
`
`the requests will be substantively useful to a contention. Accordingly, Caltech
`
`fails to show beyond speculation that something useful will be found through RFP
`
`Nos. 2–3.
`
`
`
`8
`
`
`
`RFP No. 5 and Interrogatory No. 2 are similarly speculative. These requests
`
`seek information as to whether Hughes and DISH were “walled off” from each
`
`other with respect to work on the IPR petitions. Caltech does not explain how
`
`either a “wall” between two separate law firms, or lack thereof, would be useful.
`
`Hughes is represented in district court litigation by counsel at a separate law firm
`
`from IPR counsel. Hughes is represented in district court by Wilmer Hale and
`
`represented in this IPR by Baker Botts. Separate firms do not typically have
`
`agreements to “wall off” from one another so a lack of a wall would not be
`
`informative, let alone useful. On the other hand, the existence of a wall would be
`
`useful to support Petitioners’ contentions that DISH is not an RPII, not Caltech’s.
`
`Therefore, Caltech has not satisfied its burden of showing beyond speculation that
`
`something useful in support of its own contentions will be found.
`
`As demonstrated by Caltech’s explanation, Interrogatory No. 1 is plainly
`
`based on speculation and should be denied. Caltech has not identified what it
`
`expects to find, or how it would be useful to its RPII contentions. Instead, Caltech
`
`argues that identification of decision-makers is designed to find “who did approve
`
`the filing” of the IPR, and “identify anyone who actually did perform [the]
`
`functions” of directing, controlling, or suggesting the IPR filings. Paper 17, at 14
`
`(emphasis original). Caltech even acknowledges that the subject of the request is
`
`“speculation.” Paper 17, at 14, n.3. Critically, again, Caltech does not allege that
`
`the request will find that someone at DISH controlled or approved the IPR
`
`9
`
`
`
`petitions. Because Caltech does not explain how a list of decision-makers will be
`
`useful to support its RPII contentions, Interrogatory No. 1 should be denied.
`
`C. The Requests Seek Information That is Not in Petitioner’s
`Possession or Control
`
`The requests seek information regarding documents and communications
`
`specific to DISH. But, as Hughes has made clear, DISH is a separate entity from
`
`the Petitioners. Paper 15, at 5. Hughes does not possess information specific to
`
`DISH. For example, RFP No. 2 seeks legal bills issued to DISH; RFP No. 3 seeks
`
`indemnification agreements between EchoStar and DISH; RFP No. 5 seeks
`
`instructions or agreements
`
`involving DISH or DISH
`
`litigation counsel;
`
`Interrogatory No. 1 asks for names of decision-makers at DISH; and Interrogatory
`
`No. 2 asks for information regarding DISH’s communications. Hughes could not
`
`produce this DISH specific information.
`
`When limited to the information in Hughes’s control, the speculative nature
`
`of the requests is apparent. For example, limited to only documents in the
`
`possession or control of Hughes, RFP No. 2 would only seek legal bills associated
`
`with Hughes’s own activities. Caltech has not and cannot show how this discovery
`
`would be in any way useful to its RPII contentions.
`
`D. The Requests are Overly Burdensome and Not Easily
`Understandable
`
`Requests for additional discovery must be “easily understandable.”
`
`Requests and accompanying instructions that are unclear should be denied because
`
`
`
`10
`
`
`
`they “are counter-productive and tend to undermine the responder’s ability to
`
`answer efficiently, accurately and confidently.” Garmin, at 6–7. In addition, the
`
`requests cannot be “overly burdensome to answer.” Garmin, at 7. The burden
`
`presented by the requests are reviewed in light of the short timeline in an IPR, and
`
`“includes financial burden, burden on human resources, and burden on meeting the
`
`time schedule of this review.” Id. Even if Hughes “suspects that no document
`
`meets a particular request, it is legally obligated to make a diligent search for
`
`information.” Id.
`
`First, the instructions and definitions make the discovery inherently overly
`
`burdensome and not easy to understand. The terms “document” and “thing” are
`
`defined with reference to Federal Rules of Civil Procedure, which does not apply
`
`in the PTAB. Ex. 2018, at 2. In addition, the definition of “communications”
`
`includes sending or receiving of information of “any kind through any means.”
`
`Ex. 2018, at 2. This overbroad definition is not easily understandable, and
`
`seemingly unlimited. For example, a shrug would seemingly be responsive to
`
`Caltech’s requests. Also, the instructions incorporate “instructions in the Office
`
`Patent Trial Practice Guide” without specifying which instructions are referred to
`
`or how to comply with them. Ex. 2018, at 1. The definitions of Hughes, EchoStar,
`
`and DISH are also overly burdensome because each definition includes an
`
`employee or agent of one of the listed companies, without limitation. Such an
`
`overbroad definition would require Hughes to consider the documents or
`
`11
`
`
`
`communications of countless individuals with no limitation on when they were
`
`employed or acted as an agent, or in what capacity.
`
`The instructions also impose an ongoing obligation to amend the responses
`
`and require producing a privilege log detailing documents withheld as privileged.
`
`Ex. 2018, at 1. But, these obligations are each themselves separate discovery
`
`requests that Caltech must separately support via a showing under the Garmin
`
`factors, which it has failed to do. These additional obligations or requirements are
`
`overly burdensome.
`
`The discovery requests themselves are also overly burdensome and not
`
`easily understandable. For example, RFP No. 1 asks for “[d]ocuments and things
`
`reviewed or considered.” The Board in Garmin denied a similar request as unduly
`
`burdensome that requested production of all documents and things “considered in
`
`preparing Your responses to patent owner’s Interrogatories.” Garmin, at 16 (“The
`
`undue breadth of such a request is self-evident.”). Documents produced by this
`
`request “need not contain anything useful or even relevant.” Id. Therefore, as in
`
`Garmin, there is “no valid reason for such an all-encompassing demand.” Id.
`
`RFP No. 2 seeks certain documents “sufficient to identify the entity that
`
`remitted payment for the legal services” or IPR filing fees, “whether directly or
`
`indirectly.” It is unclear what scope of documents would be included in the
`
`“indirect” payment of fees. In addition, RFP No. 3 asks for indemnity agreements
`
`“relating to” the IPRs, but it is unclear what would make an agreement “relate to”
`
`12
`
`
`
`the IPR and, therefore, be required to be produced. Similarly, Interrogatory No. 1
`
`seeks information regarding decision-making authority “with respect to” this IPR.
`
`It is unclear what authority “relates to” the IPR. For example, would an in-house
`
`IP attorney at DISH with the authority to generally file IPRs be included, even
`
`where that attorney in fact had no input into the filing of this IPR? There is also no
`
`limit to the scope or time period of decision-making authority in the request.
`
`RFP No. 4 is considerably burdensome, particularly in light of the obligation
`
`to create a privilege log for each document withheld due to privilege. This request
`
`includes communications concerning the prior art cited in the petitions, which was
`
`also cited in invalidity contentions in district court. Hughes and DISH are co-
`
`defendants and are in a joint defense group in that litigation. Any communications
`
`between members of the joint defense group would be common-interest privileged
`
`communications. Thus, each and every communication responsive to RFP No. 4
`
`would likely be privileged. As a result, Hughes would be required to look though
`
`all of its emails and its attorneys emails and provide privilege log summaries for
`
`each responsive email. That undertaking would be incredibly burdensome, time-
`
`consuming, expensive, and pointless.
`
`Responding to RFP No. 4 would also provide no useful information. The
`
`communications would be between two co-defendants discussing prior art in
`
`district court, entirely irrelevant to Caltech’s contention that DISH is an RPII.
`
`TPG, at 48, 760; Paramount Home Entertainment v. Nissim Corp., IPR2014-
`
`13
`
`
`
`00961, Paper 11 at 8 (PTAB Dec. 29, 2014) (finding a co-defendant or member of
`
`a joint defense group is not a RPII through that relationship).
`
`Therefore, the Board should deny these overly burdensome and ambiguous
`
`requests.
`
`E. Caltech Improperly Seeks Attorney-Client or Work-Product
`Privileged Information
`
`Caltech’s discovery requests are a thinly veiled attempt to force Petitioners
`
`to disclose privileged information in defense against its baseless RPII allegations.
`
`The requests plainly seek privileged information, such as communications between
`
`members of a joint defense group (RFP No. 4), or billing records (RFP No. 2).
`
`Petitioners should not be forced to produce such information, particularly in light
`
`of such speculative allegations.
`
`Caltech attempts to satisfy its burden by speculatively implying that these
`
`documents are assumed to be useful to its case because “if any documents
`
`responsive to this request exist it seems Hughes would readily produce them.” But
`
`Hughes should not have to waive the work-product protection and attorney-client
`
`privilege to respond to Caltech’s speculative and misguided RPII allegations.
`
`III. PATENT OWNER WAIVED ITS REQUEST FOR ADDITIONAL
`DISCOVERY INTO REAL PARTY-IN-INTEREST
`
`Caltech declined to seek timely discovery on this issue to inform its
`
`additional briefing. As of its Preliminary Response, Caltech must have been aware
`
`of its professed need for discovery into RPII. By delaying until well after the
`
`
`
`14
`
`
`
`parties filed their additional briefing on RPII authorized by the Board, Caltech has
`
`waived its motion for additional discovery into this issue. “A party should seek
`
`relief promptly after the need for relief is identified. Delay in seeking relief may
`
`justify a denial of relief sought.” 37 C.F.R. § 42.25(b).
`
`On January 29, 2015, Patent Owner filed its Preliminary Response
`
`dedicating approximately twelve pages to discussing allegations that the petitions
`
`do not identify all RPII. Paper 13, at 3–14. In response, on February 25, 2015, the
`
`Board conducted a conference call regarding Patent Owner’s RPII allegations.
`
`During that conference call, the Board indicated that it would consider “a well-
`
`tailored and very focused request” for additional discovery from Patent Owner.
`
`Ex. 2016, at p. 21. Immediately following that conference call, the Board
`
`authorized both parties to provide additional briefing “to the question of whether
`
`either of the Dish entities should have been named as a real party in interest.” Ex.
`
`2015. Instead, it waited over two months after it first raised the RPII issue, and
`
`well over a month after the Board authorized a motion for additional discovery.
`
`Therefore, Caltech’s delay is a waiver of the requested additional discovery. See
`
`37 C.F.R. § 42.25(b).
`
`IV. CONCLUSION
`For these reasons, Petitioners respectfully requests the Board deny each
`
`request proposed in Patent Owner’s Motion for Additional Discovery.
`
`
`
`
`
`
`
`15
`
`
`
`
`
`
`
`
`
`
`
`Date: May 6, 2015
`
`
`
`
`
`Respectfully Submitted,
`
` /Eliot D. Williams/
`
`
`
`
`
`Eliot D. Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road, Bld. 1, Suite 200
`Palo Alto, California 94304-1007
`650.739.7510
`
`Attorneys for Petitioners, Hughes Network
`Systems, L.L.C. and Hughes
`Communications, Inc.
`
`
`
`16
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`In accordance with 37 C.F.R. § 42.6(e), the undersigned certifies that on the
`6th day of May, 2015, a complete and entire copy of
`the foregoing
`PETITIONERS’ REPLY BRIEF REGARDING IDENTIFICATION OF
`REAL PARTIES-IN-INTEREST, including exhibits and testimony relied upon,
`were served on the Patent Owner at the correspondence address of record in the
`proceeding:
`
`Michael T. Roseto
`WILSON SONSINI GOODRICH & ROSATI
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`mrosato@wsgr.com
`
`Matthew A. Argenti
`WILSON SONSINI GOODRICH & ROSATI
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`margenti@wsgr.com
`
`
`
`
`
`
` /Eliot D. Williams/
`Eliot D. Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road, Bld. 1, Suite 200
`Palo Alto, California 94304-1007
`650.739.7510
`
`Attorneys for Petitioners, Hughes Network
`Systems, L.L.C. and Hughes
`Communications, Inc.
`
`
`
`
`
`Date: May 6, 2015
`
`
`
`
`
`
`
`
`
`
`
`17
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
