Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 1 of 14 PageID #:296
`
`UNITED STATES DISTRICT COURT FOR
`THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`ROSETTA-WIRELESS CORP., an Illinois
`Corporation,
`
`Plaintiff
`
`v.
`
`APPLE INC., a California Corporation,
`SAMSUNG ELECTRONICS CO. LTD., a
`Foreign Corporation, SAMSUNG
`ELECTRONICS AMERICA, INC., a New
`York Corporation, MOTOROLA MOBILITY
`LLC, a Delaware Corporation, LG
`ELECTRONICS CO., a Foreign Corporation,
`LG ELECTRONICS USA INC., a Delaware
`Corporation, HIGH TECH COMPUTER
`CORP., a/k/a HTC CORP., a Foreign
`Corporation, and HTC AMERICA INC., a
`Washington Corporation,
`
`Defendants.
`
`Civil Action No. 15-cv-00799
`
`Judge Joan H. Lefkow
`
`Date: June 24, 2015
`Time: 10:00am
`Courtroom: 2201
`
`DEFENDANTS’ MEMORADNUM OF LAW IN SUPPORT OF THEIR
`MOTION TO TEMPORARILY SUSPEND THE PATENT LOCAL RULE DEADLINES
`PENDING RESOLUTION OF THE RULE 12(b)(6) MOTION TO DISMISS
`
`ROSETTA-2007
`
`0001
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 2 of 14 PageID #:297
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`Defendants Apple, HTC, LG, Motorola, and Samsung (collectively, “Defendants”)1
`
`hereby submit their memorandum of law in support of their Motion to Temporarily Suspend the
`
`Patent Local Rule Deadlines Pending Resolution of the Rule 12(b)(6) Motion to Dismiss. For
`
`the reasons set forth below, there is good cause to grant the requested relief. See Fed. R. Civ. P.
`
`1; LPR 1.1.
`
`I.
`
`BACKGROUND
`
`On January 27, 2015, Rosetta-Wireless Corp. (“Rosetta”) filed a Complaint accusing
`
`Defendants of infringing U.S. Patent No. 7,149,511 (“the ’511 patent”) “directly and indirectly”
`
`via “acts [that] include, but are not limited to, the manufacture, use, sale, or offer for sale within
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`the United States, or the importation into the United States of products that embody the patented
`
`invention, including the products listed for each Defendant in the attached Exhibit B.” (Dkt. No.
`
`1 at ¶ 18.) Approximately 300 smartphones and tablets sold by five Defendants are listed in
`
`Exhibit B. (Id. at Exhibit B.) Each of these accused products contains many hundreds of
`
`features and functionalities, but Rosetta’s Complaint did not identify which of these features or
`
`functionalities are accused of infringement. (See id. at ¶ 18 and Exhibit B.)
`
`Because this single conclusory paragraph in Rosetta’s Complaint—the only allegation in
`
`the entire Complaint purporting to describe the alleged infringement—failed under Fed. R. Civ.
`
`P. 8(a) to sufficiently notify Defendants of the claims being asserted against them, Defendants
`
`individually reached out to counsel for Rosetta for more detail. (See Declaration of Jenny
`
`Colgate (“Colgate Decl.”) at ¶¶ 2, 4.) In response, Rosetta provided Defendants with exemplary
`
`1
`Rosetta’s Amended Complaint names as Defendants the following entities: Apple Inc. (referred to herein
`as “Apple”); Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc. (referred to herein as
`“Samsung”); Motorola Mobility LLC (referred to herein as “Motorola”); LG Electronics Co. and LG Electronics
`USA Inc. (referred to herein as “LG”); and High Tech Computer Corp. a/k/a HTC Corp. and HTC America Inc.
`(referred to herein as “HTC”). Rosetta had originally named but later voluntarily dismissed Motorola, Inc. and
`Samsung Telecommunications America, LLC from this action. (See Dkt. Nos. 9, 37.) It should additionally be
`noted that several of the aforementioned defendants were misnamed. For example, LG Electronics Co. should be
`LG Electronics, Inc.
`
`ROSETTA-2007
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`0002
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 3 of 14 PageID #:298
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`infringement claim charts under Federal Rule of Evidence 408 for purposes of possible
`
`settlement. (Id. at ¶¶ 3-4.) Rule 408, however, prohibits the use of the information for purposes
`
`of proving the validity or amount of a disputed claim; therefore, Defendants could not use such
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`information to define the scope of Plaintiff’s infringement claims. Furthermore, requiring
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`Defendants to rely on these settlement-related claim charts to prepare responsive pleadings
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`would put Defendants in an untenable situation of being bound by their responsive pleading
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`while Rosetta was not bound by its Rule 408 claim charts.
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`In view of these issues, Defendants collectively contacted Rosetta on May 21, 2015,
`
`notifying Rosetta of the deficiencies in its Complaint. (Id. at ¶ 5 and Exhibit 1.) Rosetta
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`responded on May 26, 2015, disagreeing with Defendants’ position that Rosetta’s claims of
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`direct infringement were not properly pled, but agreeing to drop its claims of indirect
`
`infringement. (Id. at ¶ 6 and Exhibit 2.) On June 1, 2015, Rosetta did just that, filing an
`
`Amended Complaint that dropped the indirect infringement allegations. (Dkt. No. 82.)
`
`However, the Amended Complaint, like its now-discarded predecessor, again recites only the
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`barest of allegations with respect to the direct infringement claim. These allegations, in their
`
`entirety, accuse Defendants of having
`
`“infringed directly and continu[ing] to infringe directly” the ’511 patent via acts that
`“include, but are not limited to, the manufacture, use, sale, or offer for sale within the
`United States, or the importation into the United States of products that embody the
`patented invention, including the products listed for each Defendant in the attached
`Exhibit B.” (Id. at ¶ 15.)
`
`The same Exhibit B, listing approximately 300 smartphones and tablets sold by Defendants, is
`
`attached to Rosetta’s Amended Complaint. (Id. at Exhibit B.)
`
`On June 9, 2015, Defendants responded to Rosetta, maintaining Defendants’ position that
`
`Rosetta should file an Amended Complaint setting forth with more specificity
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`the
`
`2
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`ROSETTA-2007
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`0003
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 4 of 14 PageID #:299
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`functionality(ies) accused of infringing the asserted patent. (Colgate Decl. at ¶ 8 and Exhibit 3.)
`
`Defendants also alerted Rosetta that, without this additional information, Defendants would have
`
`to produce technical documents pursuant to the Local Patent Rule disclosure obligations in the
`
`absence of a complaint that identifies the features or functionalities that are relevant to Rosetta’s
`
`infringement claims. Thus, Defendants offered to meet and confer with Plaintiff on June 10.
`
`(Id.) Rosetta responded on June 10, 2015, maintaining its position that it has properly pled its
`
`direct infringement claims and failing to address Defendants’ offer to meet and confer. (Id. at
`
`¶ 9 and Exhibit 4.) Consequently, on June 15, 2015, Defendants acknowledged the impasse that
`
`the parties had reached and asserted that they would be filing their motions on June 18, 2015.
`
`(Id. at ¶ 10 and Exhibit 5.) Defendants are filing their Rule 12(b)(6) Motion to Dismiss, or In the
`
`Alternative, For a More Definite Statement concurrently with this motion.
`
`II.
`
`ARGUMENT
`
`This Court should temporarily stay or suspend the Local Patent Rule deadlines in this
`
`case because Rosetta’s Amended Complaint does not identify what features or functionalities of
`
`the accused smartphones and tablets are accused of infringement. Further, it is not apparent
`
`from the patent-in-suit alone what features or functionalities of the accused smartphones and
`
`tablets are accused of infringement, as there are 80 possible claims covering multiple different
`
`devices (including a wireless intelligent personal network server (“WIPs”) (’511 patent,
`
`independent claims 1 and 58), a wireless telephone (independent claim 23), and/or a display
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`device (independent claims 35 and 73)). The patent-in-suit has a large number of claims, and the
`
`claims have substantial breadth. Each of the accused products contains hundreds of features and
`
`functionalities.2
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`In the face of these issues, Defendants’ production of technical documents
`
`2
`For example, the devices can be used to (1) send and receive text messages; (2) send and receive email; (3)
`send and receive audio or video files; (4) play audio or video files; (5) stream audio or video files to another device;
`3
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`ROSETTA-2007
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`0004
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 5 of 14 PageID #:300
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`pursuant to Local Patent Rule 2.1 would occur based on Rosetta’s general and vague pleading
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`and without information about what features and functionalities are relevant to infringement.
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`This Court has the authority to stay proceedings or suspend deadlines. Landis v. N. Am.
`
`Co., 299 U.S. 248, 254 (1936). In considering whether or not to issue a stay, courts typically
`
`consider the following factors:
`
`(i) whether a stay will reduce the burden of litigation on the parties and the court;
`
`(ii) whether a stay will simplify the issues in question and streamline the case; and
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`(iii) whether a stay will unduly prejudice or tactically disadvantage the non-moving party.
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`Id. A stay is appropriate so long as there is not a fair possibility that the stay would damage
`
`someone else. Pfizer Inc. v. Apotex Inc., 640 F. Supp. 2d 1006, 1007 (N.D. Ill. 2009) (citing
`
`Landis, 299 U.S. at 255).
`
`Here, a brief stay is appropriate. The Local Patent Rules of this Court place heavy,
`
`immediate and fast-paced disclosure obligations on parties in patent cases. See, e.g., LPR 2.1
`
`(requiring, inter alia, parties opposing claims of patent infringement to produce within 14 days
`
`of filing an answer or other response (1) documents sufficient to show the operation and
`
`construction of all aspects or elements of each accused apparatus, product, device, component,
`
`process, method or other instrumentality identified with specificity in the pleading of the party
`
`asserting patent infringement; and (2) a copy of each item of prior art of which the party is aware
`
`that allegedly anticipates each asserted patent and its related claims or renders them obvious or,
`
`if a copy is unavailable, a description sufficient to identify the prior art and its relevant details).
`
`(6) share files using, e.g., (a) WiFi, (b) Bluetooth, (c) Near Field Communications, or (d) a wired connection; (7)
`share the device’s screen with another device; (8) become a mobile hotspot; (9) place phone calls; (10) operate with
`third party peripherals (such as, for instance, a credit card reader); (11) send signals to (and control via those signals)
`another device; (12) compose and edit text files; (13) store and access files on removable storage media; (14)
`communicate over various wired or wireless interfaces; and, generally, (15) perform any functions that a general
`purpose computer with networking capabilities may perform.
`4
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`ROSETTA-2007
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`0005
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 6 of 14 PageID #:301
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`These same rules, however, allow this Court to modify the obligations and deadlines of the Local
`
`Patent Rules based on the circumstances of a particular case. LPR 1.1; see also Fed. R. Civ. P. 1.
`
`Temporarily suspending the Local Patent Rule deadlines while the Court considers the
`
`issues presented in Defendants’ motion to dismiss would conserve the parties’ resources without
`
`causing any material delays or prejudice to Rosetta. Judges in this District have stayed discovery
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`deadlines pending the resolution of dispositive motions in other cases, especially where the stay
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`is requested early in the case and the case is one in which discovery is burdensome and costly.
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`See generally, e.g., Visual Interactive Phone Concepts, Inc. v. U.S. Cellular Corp., No. 11-cv-
`
`5289, Dkt. Nos. 77 and 79 (N.D. Ill. Aug. 3, 2011) (granting motion to temporarily suspend the
`
`local patent rule deadlines pending resolution of motion for summary judgment); Coss v. Playtex
`
`Prods., LLC, No. 8-cv-50222, 2009 WL 1455358, at *5 (N.D. Ill. May 21, 2009) (granting in
`
`part motion to stay discovery pending resolution of motion to dismiss for failure to state a claim
`
`and explaining that “[e]xpensive and burdensome discovery will not be compelled by the court
`
`prior to the district court ruling on the motion to dismiss . . . [b]ut, in the interest of moving the
`
`case forward, some limited discovery may be appropriate.”). For the reasons set forth in
`
`Defendants’ Rule 12(b)(6) Motion to Dismiss and herein, the circumstances of this case justify
`
`this Court modifying/temporarily suspending the deadlines of the Local Patent Rules until this
`
`Court has had an opportunity to rule on Defendants’ Motion to Dismiss and, if this Court grants
`
`Rosetta a third bite at the apple, until Rosetta files a new pleading that satisfies the standard set
`
`forth in Fed. R. Civ. P. 8(a).
`
`First, a brief stay would reduce the burden of litigation on the parties and the Court.
`
`Rosetta’s Amended Complaint fails to put Defendants on notice regarding the claims asserted
`
`against them. While the Amended Complaint identifies a list of accused products, that list
`
`5
`
`ROSETTA-2007
`
`0006
`
`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 7 of 14 PageID #:302
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`consists of approximately 300 smartphones and tablets, each having hundreds of different
`
`features and a myriad of different functionalities. Because Rosetta did not specify any accused
`
`functionalities or any asserted claims (from which Defendants may have been able to use the
`
`language of the claims to discern what functionalities are accused), it is unclear to Defendants
`
`what about the accused smartphones and tablets purportedly infringes one or more of the claims
`
`of the patent-in-suit. This uncertainty is particularly acute because there are 80 claims of the
`
`patent-in-suit, and the claims cover multiple different devices (including, inter alia, a wireless
`
`intelligent personal network server (“WIPS”) and a display device). For example, it is unclear
`
`whether Rosetta is alleging that the accused devices are equivalent to WIPS, display devices, or
`
`entire “wireless data communication systems” under the claims of the patent-in-suit.
`
`LPR 2.1(b)(1) requires Defendants to produce technical documentation relating to
`
`accused functionality identified “with specificity” in a complaint. However, without an
`
`identification of the accused features and functionalities in the complaint, Defendants would
`
`have to undertake this technical document production based on Rosetta’s general and vague
`
`pleading and without information about what features and functionalities are relevant to
`
`infringement. The lack of detail in Rosetta’s Amended Complaint similarly affects Defendants’
`
`ability to identify relevant prior art pursuant to their disclosure obligations under LPR 2.1(b)(2).
`
`A brief stay of the Local Patent Rule deadlines, until this Court has had an opportunity to rule on
`
`Defendants’ Motion to Dismiss (and, if granted, until Rosetta files a new pleading that satisfies
`
`the standard set forth in Fed. R. Civ. P. 8(a)), would result in more focused disclosures. Both the
`
`parties and the Court would benefit from more focused litigation.
`
`Second, suspending the patent local rule deadlines while this Court considers Defendants’
`
`pending motion to dismiss would simplify the issues in question because it will directly affect
`
`6
`
`ROSETTA-2007
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`0007
`
`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 8 of 14 PageID #:303
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`the content and scope of the disclosures due under the Local Patent Rules. See generally, e.g.,
`
`DSM Desotech, Inc. v. 3D Sys. Corp. et al., No. 08-cv-1531, 2008 WL 4812440, at *3 (N.D. Ill.
`
`Oct. 28, 2008) (Lefkow, J.) (finding that the principles underlying Twombly (i.e., discovery
`
`would be burdensome and expensive) counsel in favor of granting defendants’ motion to stay
`
`discovery); Coss, 2009 WL 1455358, at *2-3 (“If the complex case is one susceptible to the
`
`burdensome and costly discovery contemplated by Bell Atlantic and Iqbal, the district court
`
`should limit discovery once a motion to dismiss for failure to state a claim has been filed.”)
`
`(citing DSM Desotech); Nexstar Broadcasting, Inc. v. Granite Broadcasting Corp., No. 11-cv-
`
`249, 2011 WL 4345432, at *3 (N.D. Ill. Sept. 15, 2011) (finding that “granting the motion to stay
`
`is appropriate because of both the nature of the case as well as the arguments in Granite’s Motion
`
`to Dismiss” especially given that the case was an antitrust case which invoked the concerns from
`
`Twombly about burdensome and expensive discovery and the claims were such that multiple
`
`potential theories were at issue).
`
`Third, suspending the Local Patent Rule deadlines would not unduly prejudice or
`
`tactically disadvantage Rosetta. To the extent a brief stay might delay resolution of the litigation
`
`at all—which it will not, since any delay would be modest in length and will help focus
`
`discovery in the interim—Rosetta could be adequately compensated by monetary damages (if it
`
`eventually prevails on the merits). See, e.g., SP Techs., LLC v. HTC Corp., No. 08-cv-3760, 2009
`
`U.S. Dist. LEXIS 38076, at *9 (N.D. Ill. May 6, 2009) (finding non-competitor plaintiff would
`
`not be prejudiced by stay because it could recover monetary damages to compensate for its
`
`losses at the end of trial). Further, Defendants dispute that a delay would prejudice Rosetta at all
`
`because Rosetta is not a competitor with the Defendants. (See also Dkt. No. 82 ¶ 17 (“Rosetta
`
`has never sold a product in the United States”) and “Prayer for Relief” (no request for a
`
`7
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`ROSETTA-2007
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`0008
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`

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`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 9 of 14 PageID #:304
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`preliminary injunction).) Finally, any delay is a product of Rosetta’s own refusal to provide
`
`sufficient information about Rosetta’s infringement claims in either its original Complaint or its
`
`Amended Complaint.
`
`For the reasons herein, Defendants respectfully request that this Court temporarily
`
`suspend the patent local rule deadlines.
`
`Dated: June 18, 2015
`
`Respectfully submitted,
`
`/s/_James R. Figliulo___________________
`Steven Lieberman
`Jenny Colgate
`Brian A. Tollefson
`Rothwell, Figg, Ernst & Manbeck, P.C.
`607 14th Street, NW
`Washington, District of Columbia 20005
`+1 (202) 783-6040
`slieberman@rfem.com
`jcolgate@rfem.com
`btollefson@rfem.com
`
`James R. Figliulo
`Thomas Daniel Warman
`Lisa Michelle Mazzone
`Figliulo & Silverman
`10 South LaSalle Street
`Suite 3600
`Chicago, IL 60603
`(312) 251-4600
`jfigliulo@fslegal.com
`twarman@fslegal.com
`lmazzone@fslegal.com
`
`Counsel for Defendants LG Electronics, Inc. and
`LG Electronics U.S.A., Inc.
`
`/s/ Martin R. Bader_____________________
`Stephen S. Korniczky (pro hac vice)
`Martin R. Bader (pro hac vice)
`Ryan P. Cunningham (pro hac vice)
`Sheppard Mullin Richter & Hampton LLP
`12275 El Camino Real, Suite 200
`
`8
`
`ROSETTA-2007
`
`0009
`
`

`
`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 10 of 14 PageID #:305
`
`San Diego, CA 92130-2006
`858-720-8900
`skorniczky@sheppardmullin.com
`mbader@sheppardmullin.com
`rcunningham@sheppardmullin.com
`
`Bradley C. Graveline
`Sheppard Mullin Richter & Hampton LLP
`70 West Madison Street, 48th Floor
`Chicago, IL 60602
`312-499-6300
`bgraveline@sheppardmullin.com
`
`Counsel for Defendants HTC Corp. and HTC
`America, Inc.
`
`/s/ Steven Pepe_______________________
`Marc A. Cavan (SBN 6255725)
`Ropes & Gray LLP
`191 North Wacker Drive
`32nd Floor
`Chicago, IL 60606
`(312) 845-1200
`marc.cavan@ropesgray.com
`
`James R. Batchelder (pro hac vice)
`Ropes & Gray LLP
`1900 University Avenue
`6th Floor
`East Palo Alto, CA 94303
`(650) 617-4000
`james.batchelder@ropesgray.com
`
`Steven Pepe (pro hac vice)
`Alexander E. Middleton (pro hac vice)
`Ropes & Gray LLP
`1211 Avenue of the Americas
`New York, NY 10036
`(212) 596-9000
`steven.pepe@ropesgray.com
`alexander.middleton@ropesgray.com
`
`Matthew J. Rizzolo (pro hac vice)
`Ropes & Gray LLP
`700 12th Street, NW
`
`9
`
`ROSETTA-2007
`
`0010
`
`

`
`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 11 of 14 PageID #:306
`
`One Metro Center
`Washington, DC 20005
`(202) 508-4600
`matthew.rizzolo@ropesgray.com
`
`Counsel for Defendant Motorola Mobility LLC
`
`/s/ _Anish R. Desai______________________
`Stacie R. Hartman (SBN 6237265)
`A. Taylor Corbitt (SBN 6299553)
`SCHIFF HARDIN LLP
`233 South Wacker Drive, Suite 6600
`Chicago, IL 60611
`(312) 258-5607
`(312) 258-5600 FAX
`shartman@schiffhardin.com
`tcorbitt@schiffhardin.com
`
`Brian E. Ferguson (pro hac vice)
`Anish R. Desai (pro hac vice)
`David M. DesRosier (pro hac vice)
`Megan H. Wantland (pro hac vice)
`WEIL, GOTSHAL & MANGES LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`(202) 682-7000
`(202) 857-0940 FAX
`brian.ferguson@weil.com
`anish.desai@weil.com
`
`Counsel for Defendant Apple Inc.
`
`/s/ _Gene W. Lee_______________________
`Richard T. McCaulley (SBN 6225506)
`Eric Wei-inn Chang (SBN 6317702)
`Ropes & Gray LLP
`191 N. Wacker Drive
`32nd Floor
`Chicago, IL 60606
`(312) 845-1200
`richard.mccaulley@ropesgray.com
`eric.chang@ropesgray.com
`
`Gene W. Lee (pro hac vice)
`
`10
`
`ROSETTA-2007
`
`0011
`
`

`
`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 12 of 14 PageID #:307
`
`Julian Moore (pro hac vice)
`Seung woo Hur (pro hac vice)
`Ropes & Gray LLP
`1211 Avenue of the Americas
`New York, NY 10036
`(212) 596-9000
`gene.lee@ropesgray.com
`julian.moore@ropesgray.com
`ben.hur@ropesgray.com
`
`Counsel for Defendants Samsung Electronics Co.
`Ltd., a Foreign Corporation, and Samsung
`Electronics America, Inc.
`
`11
`
`ROSETTA-2007
`
`0012
`
`

`
`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 13 of 14 PageID #:308
`
`CERTIFICATE OF SERVICE
`
`The undersigned attorney states that he caused a copy of the attached:
`
`DEFENDANTS’ MEMORANDUM OF LAW IN SUPPORT OF THEIR
`MOTION TO TEMPORARILY SUSPEND THE PATENT LOCAL RULE DEADLINES
`PENDING RESOLUTION OF THE RULE 12(b)(6) MOTION TO DISMISS
`
`to be filed with the United States District Court’s ECF filing system on June 18, 2015. Counsel
`named below will be served a copy of same via this Court’s ECF notification system.
`
`Electronic Mail Notice List
`
`The following are those who are currently on the list to receive e-mail notices for this case.
`
`/s/ James R. Figliulo
`
`x
`
`x
`
`x Martin R. Bader
`mbader@sheppardmullin.com,kgrauer@sheppardmullin.com
`James R. Batchelder
`james.batchelder@ropesgray.com,courtalert@ropesgray.com
`x Marc Andrew Cavan
`marc.cavan@ropesgray.com,mikeisha.walker@ropesgray.com,andrea.jakubas@ropesgra
`y.com,CourtAlert@RopesGray.com
`x Eric Wei-inn Chang
`eric.chang@ropesgray.com,courtalert@ropesgray.com
`Jenny L Colgate
`jcolgate@rfem.com
`x Ashley Taylor Corbitt
`tcorbitt@schiffhardin.com
`x Ryan Patrick Cunningham
`rcunningham@sheppardmullin.com
`x David Mitchell DesRosier
`david.desrosier@weil.com
`x Anish R. Desai
`anish.desai@weil.com,Apple.Rosetta.NDIL.799.paras@weil.com
`x Michael C Fasano
`michael.fasano@kobrekim.com
`x Brian E. Ferguson
`Brian.Ferguson@Weil.com
`James R. Figliulo
`jfigliulo@fslegal.com
`x Bradley C. Graveline
`bgraveline@sheppardmullin.com,acastro@sheppardmullin.com,pramirez@sheppardmulli
`n.com
`
`x
`
`12
`
`ROSETTA-2007
`
`0013
`
`

`
`Case: 1:15-cv-00799 Document #: 91 Filed: 06/18/15 Page 14 of 14 PageID #:309
`
`x
`
`x
`
`x
`
`x
`
`Stacie Rachel Hartman
`shartman@schiffhardin.com,edocket@schiffhardin.com
`x Kyle L. Harvey
`harvey@stadheimgrear.com,meid@stadheimgrear.com,ichou@stadheimgrear.com
`Seung woo Hur
`ben.hur@ropesgray.com,courtalert@ropesgray.com
`Joo mee Kim
`jkim@rfem.com
`Stephen Sandor Korniczky
`skorniczky@sheppardmullin.com,jbond@sheppardmullin.com,amertens@sheppardmulli
`n.com
`x Gene W. Lee
`gene.lee@ropesgray.com,courtalert@ropesgray.com
`Steven Lieberman
`slieberman@rothwellfigg.com,nhage@rfem.com
`x Lisa Michelle Mazzone
`lmazzone@fslegal.com
`x Richard T. McCaulley
`richard.mccaulley@ropesgray.com,mikeisha.walker@ropesgray.com,courtalert@ropesgr
`ay.com
`x Alexander Ernest Middleton
`alexander.middleton@ropesgray.com,courtalert@ropesgray.com
`Julian Moore
`julian.moore@ropesgray.com,courtalert@ropesgray.com
`x Michael K Ng
`michael.ng@kobrekim.com
`Steven Pepe
`steven.pepe@ropesgray.com,CourtAlert@RopesGray.com
`x Matthew Joseph Rizzolo
`matthew.rizzolo@ropesgray.com,CourtAlert@RopesGray.com
`x Brian A. Tollefson
`btollefson@rfem.com,biddinn@rfem.com
`x Megan H Wantland
`megan.wantland@weil.com
`x Thomas Daniel Warman
`twarman@fslegal.com
`
`x
`
`x
`
`x
`
`Manual Notice List
`
`Jill J. Schmidt
`Sidley Austin LLP
`1001 Page Mill Road, Building One
`Palo Alto, CA 94304
`
`13
`
`ROSETTA-2007
`
`0014