UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`The Honorable Rodney Gilstrap
`
`Civil Action No. 2:19-cv-00310-JRG-RSP
`2:19-cv-00311-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`§ § § § § § § § §
`
`
`
`GREE, INC.,
`
`v.
`
`SUPERCELL OY,
`
`Plaintiff,
`
`Defendant.
`
`DEFENDANT SUPERCELL OY’S NOTICE OF
`DEPOSITION OF TOMOKI YASUHARA
`
`PLEASE TAKE NOTICE THAT, pursuant to Rule 30(b)(1) of the Federal Rules of Civil
`
`Procedure, Defendant Supercell Oy, by and through its attorneys, will take the deposition upon
`
`oral examination of Tomoki Yasuhara on September 9, 2020 or at such other time as otherwise
`
`agreed to by counsel for the parties, and at a place as agreed to by counsel for the parties or by
`
`virtual deposition.
`
`Supercell reserves the right to record the deposition either via stenographic means by a
`
`court reporter certified to record depositions, or a digital reporter utilizing state-of-the-art digital
`
`recording equipment. Both the court reporter and digital reporter are authorized to administer the
`
`oath and serve as the deposition officer. Supercell further reserves the right to record the
`
`deposition utilizing audio or video technology. Supercell also reserves the right to utilize Exhibit
`
`Capture (picture-in picture) technology in which any exhibit reviewed by the deponent during the
`
`deposition can be captured visually.
`
`Should the deposition be recorded in either video format, Supercell reserves the right to
`
`utilize at trial any portion of the audio or video recording of the proceeding. In the event
`
`Supercell utilizes the stenographic reporting method, Supercell reserves the right to utilize
`
`Supercell
`Exhibit 1030
`Page 1
`
`
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`The Honorable Rodney Gilstrap
`
`Civil Action No. 2:19-cv-00310-JRG-RSP
`2:19-cv-00311-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`§ § § § § § § § §
`
`
`
`GREE, INC.,
`
`v.
`
`SUPERCELL OY,
`
`Plaintiff,
`
`Defendant.
`
`DEFENDANT SUPERCELL OY’S NOTICE OF
`DEPOSITION OF TOMOKI YASUHARA
`
`PLEASE TAKE NOTICE THAT, pursuant to Rule 30(b)(1) of the Federal Rules of Civil
`
`Procedure, Defendant Supercell Oy, by and through its attorneys, will take the deposition upon
`
`oral examination of Tomoki Yasuhara on September 9, 2020 or at such other time as otherwise
`
`agreed to by counsel for the parties, and at a place as agreed to by counsel for the parties or by
`
`virtual deposition.
`
`Supercell reserves the right to record the deposition either via stenographic means by a
`
`court reporter certified to record depositions, or a digital reporter utilizing state-of-the-art digital
`
`recording equipment. Both the court reporter and digital reporter are authorized to administer the
`
`oath and serve as the deposition officer. Supercell further reserves the right to record the
`
`deposition utilizing audio or video technology. Supercell also reserves the right to utilize Exhibit
`
`Capture (picture-in picture) technology in which any exhibit reviewed by the deponent during the
`
`deposition can be captured visually.
`
`Should the deposition be recorded in either video format, Supercell reserves the right to
`
`utilize at trial any portion of the audio or video recording of the proceeding. In the event
`
`Supercell utilizes the stenographic reporting method, Supercell reserves the right to utilize
`
`Supercell
`Exhibit 1030
`Page 1
`
`
`
`
`
`instant visual display such that the reporter’s writing of the proceeding will be available to all
`
`who are a part to this proceeding to request and receive in RealTime.
`
`NOTICE IS FURTHER GIVEN that Supercell reserves the right to conduct this
`
`deposition utilizing a paperless exhibit display process called “Exhibit Share,” provided and
`
`supported by Veritext Legal Solutions. The parties are advised that one paper set of exhibits will
`
`be utilized at the deposition for the court reporter’s purposes of compiling, exhibit stamping, and
`
`ultimate production of the final certified transcript. However, no other paper copies will be
`
`provided as they will be available for visual display using Exhibit Share.
`
`Please contact the noticing attorney prior to the deposition to advise that it is your desire
`
`to be set up for Exhibit Share access so that the necessary credentials, testing, and information, if
`
`necessary, can be provided to you prior to the proceedings. For information and available
`
`tutorial videos demonstrative Exhibit Share, please utilize this link to access additional
`
`information: http://www.veritext.com/services/exhibitshare/.
`
`NOTICE IS FURTHER GIVEN that Supercell reserves the right to conduct this
`
`deposition utilizing the secure web-based deposition option afforded by Veritext or, in the
`
`alternative, video teleconferencing (VTC) services or telephonically only to provide
`
`remote/virtual access for those parties wishing to participate in the deposition via the internet
`
`and/or telephone. Also take notice that the court reporter may be remote via one of the options
`
`above for the purposes of reporting the proceeding and may or may not be in the presence of the
`
`deponent. Please contact the noticing attorney prior to the deposition to advise that it is your
`
`desire to appear via this remote participating means so that the necessary credentials, call-in
`
`numbers, testing, and information, if necessary, can be provided to you prior to the proceedings.
`
`2
`
`Supercell
`Exhibit 1030
`Page 2
`
`
`
`
`
`Supercell reserves the right to utilize instant visual display technology such that the court
`
`report’s writing of the proceeding will be displayed simultaneous to their writing of same on
`
`one’s laptop, iPad, tablet, or other type of display devise connected to the court reporter.
`
`
`
`Dated: August 24, 2020
`
`Respectfully submitted,
`
`
`
` /s/ Jessica M. Kaempf
`Jeffrey A. Ware (Admitted E.D. Texas)
`Jessica M. Kaempf (Admitted E.D. Texas)
`FENWICK & WEST LLP
`1191 Second Avenue, 10th Floor
`Seattle, WA 98101
`Telephone:
`206.389.4510
`Facsimile:
`206.389.4511
`Email:
`jware@fenwick.com
`
`
`jkaempf@fenwick.com
`
`
`Michael J. Sacksteder (Admitted E.D. Texas)
`Bryan A. Kohm (Admitted E.D. Texas)
`Shannon E. Turner (Admitted pro hac vice)
`Christopher L. Larson (Admitted E.D. Texas)
`Winnie Wong (Admitted E.D. Texas)
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, California 94104
`Telephone:
`415.875.2300
`Facsimile:
`415.281.1350
`Email:
`msacksteder@fenwick.com
`
`
`bkohm@fenwick.com
`
`
`sturner@fenwick.com
`
`clarson@fenwick.com
`
`winnie.wong@fenwick.com
`
`
`
`Geoffrey R. Miller
`(Texas State Bar No. 24094847)
`FENWICK & WEST LLP
`902 Broadway, Suite 14
`New York, NY 10010-60355
`Telephone: 212.430.2600
`Email:
`gmiller@fenwick.com
`
`3
`
`Supercell
`Exhibit 1030
`Page 3
`
`
`
`
`
`
`
`Deron R. Dacus
`(Texas State Bar No. 00790553)
`THE DACUS FIRM, PC
`821 ESE Loop 323, Suite 430
`Tyler, Texas 75701
`Telephone:
`903.705.1117
`Facsimile:
`903.581.2543
`Email:
`ddacus@dacusfirm.com
`
`Attorneys for Defendant Supercell OY
`
`
`
`4
`
`Supercell
`Exhibit 1030
`Page 4
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on August 24, 2020, a true and correct copy of the foregoing
`
`document was served via email on each party through their counsel of record.
`
`Alton L. Absher, III
`Kilpatrick Townsend & Stockton LLP
`Email: aabsher@kilpatricktownsend.com
`
`Andrew W. Rinehart
`Kilpatrick Townsend & Stockton LLP
`Email: arinehart@kilpatricktownsend.com
`
`John C Alemanni
`Kilpatrick Townsend & Stockton LLP
`Email: jalemanni@kilpatricktownsend.com
`
`Kasey E. Koballa
`Kilpatrick Townsend & Stockton LLP
`Email: kkoballa@kilpatricktownsend.com
`
`Melissa Richards Smith
`Gillam & Smith, LLP
`Email: melissa@gillamsmithlaw.com
`
`Harry L. Gillman
`Gillam & Smith, LLP
`Email: gil@gillamsmithlaw.com
`
`Michael T. Morlock
`Kilpatrick Townsend & Stockton LLP
`Email: mmorlock@kilpatricktownsend.com
`
`Norris Power Boothe
`Kilpatrick Townsend & Stockton LLP
`Email: nboothe@kilpatricktownsend.com
`
`Rishi Gupta
`Kilpatrick Townsend & Stockton LLP
`Email: rgupta@kilpatricktownsend.com
`
`Taylor Higgins Ludlam
`Kilpatrick Townsend & Stockton LLP
`Email: taludlam@kilpatricktownsend.com
`
`Taylor Jacqueline Pfingst
`Kilpatrick Townsend & Stockton, LLP
`Email: tpfingst@kilpatricktownsend.com
`
`Steven David Moore
`Kilpatrick Townsend & Stockton, LLP
`Email: smoore@kilpatricktownsend.com
`
`
`
`
`
`
`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
`
`
`
`
`
`5
`
`Supercell
`Exhibit 1030
`Page 5
`
`
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