`Thursday, August 2, 2018 11:15 PM
`Simmons, LuannL.
`TeamCyweeSamsung; Ari Rafilson; Will Ellerman; Christopher Evans; Alfonso G Chan
`Samsung Google Communications
`
`From:
`Sent:
`To:
`Ce:
`Subject:
`
`Dear Luanne,
`
`| have been in Korea for 10 days taking deposition of Samsung personnel. | cannot give you specifics due to Protective
`Order designations by Samsung, but | have reasonto believe that there have been extensive communications between
`Samsung and Google beginning over a year ago that may create an estoppel of the Google IPR. Please produce as soon
`as practicable the following:
`
`1. The Samsung Android software license agreement;
`2. All communications between Samsung and Google (or lawyers representing one or both) that mention, refer or
`relate to CyWee, the CyWeepatents or the CyWee/Samsung lawsuit (including any notes, summaries or reports
`of such communications);
`3. All agreements between Samsung and Google that mention,refer or relate to CyWee, the CyWee patents or the
`Samsung/CyWeelawsuit;
`4. Any documents related to demands or requests from Samsung to Google that seek indemnity for CyWee’s
`claims, a defense of the CyWee/Samsungsuit or any aid from Google in defending the CyWeesuit of any kind or
`nature; and
`5. Any documents(internal to Google or shared between Google and any third party) that could conceivably be
`relevant to any potential claim by CyWee that Samsung and Google share any interestin invalidating the CyWee
`patents, including but not limited to any Joint Defense Agreements, Joint Interest Agreements or any other
`document or agreementthat indicates Samsung and Google’s interests are aligned in defeating CyWee’s claims.
`
`lam certain you appreciate the import of this information in both the pending lawsuits and the IPR. | would also like a
`Rule 30(b)(6) deponent on the abovetopics as well as soon as possible, regardless of whether Google contends any
`documents exist responsive to the above requests. If you need a formal discovery request beyond this email to comply
`within 33 days, please indicate by return email. |am happy to make the requests more formally if you think thatis
`appropriate.
`
`Warm regards,
`
`Michael
`
`001
`
`GOOGLE 1012
`GOOGLE1012
`
`001
`
`
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