Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 1 of 10 PageID #:
` 5763
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`No. 2:15-cv-01278-JRG-RSP
`
`CONSOLIDATED INTO
`
`No. 2:15-cv-01274-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`
`
`BLITZSAFE TEXAS, LLC,
`
`Plaintiff,
`
` v.
`
`VOLKSWAGEN GROUP OF AMERICA,
`INC. and VOLKSWAGEN GROUP OF
`AMERICA CHATTANOOGA
`OPERATIONS, LLC,
`
`
`Defendants.
`
`
`DEFENDANTS
`VOLKSWAGEN GROUP OF AMERICA, INC. AND VOLKSWAGEN GROUP
`OF AMERICA CHATTANOOGA OPERATIONS, LLC’S
`NOTICE OF SUBPOENA TO STILLWATER DESIGNS, INC.
`
`Please take notice that pursuant to Fed. R. Civ. P. 30(b)(6) and 45, counsel for defendants
`
`Volkswagen Group of America, Inc. and Volkswagen Group of America Chattanooga
`
`Operations, LLC (“VWGoA”) will cause the attached subpoena to be served on Stillwater
`
`Designs, Inc., 3100 N. Husband St., Stillwater, OK 74075. Pursuant to that subpoena, VWGoA
`
`will take the deposition upon oral examination of a representative of Stillwater Designs, Inc. The
`
`deposition will be taken at the Hampton Inn & Suites Stillwater, 717 E. Hall of Fame Ave.,
`
`Stillwater, OK 74075, on September 15, 2016, at 9:00 a.m., or at some other place and time
`
`mutually agreed upon by counsel. The deposition will be taken before an officer authorized to
`
`administer oaths, and will continue day to day until completed. The deposition will be recorded
`
`by audio, audiovisual, and/or stenographic means.
`
`
`
`
` 5763
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`No. 2:15-cv-01278-JRG-RSP
`
`CONSOLIDATED INTO
`
`No. 2:15-cv-01274-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`
`
`BLITZSAFE TEXAS, LLC,
`
`Plaintiff,
`
` v.
`
`VOLKSWAGEN GROUP OF AMERICA,
`INC. and VOLKSWAGEN GROUP OF
`AMERICA CHATTANOOGA
`OPERATIONS, LLC,
`
`
`Defendants.
`
`
`DEFENDANTS
`VOLKSWAGEN GROUP OF AMERICA, INC. AND VOLKSWAGEN GROUP
`OF AMERICA CHATTANOOGA OPERATIONS, LLC’S
`NOTICE OF SUBPOENA TO STILLWATER DESIGNS, INC.
`
`Please take notice that pursuant to Fed. R. Civ. P. 30(b)(6) and 45, counsel for defendants
`
`Volkswagen Group of America, Inc. and Volkswagen Group of America Chattanooga
`
`Operations, LLC (“VWGoA”) will cause the attached subpoena to be served on Stillwater
`
`Designs, Inc., 3100 N. Husband St., Stillwater, OK 74075. Pursuant to that subpoena, VWGoA
`
`will take the deposition upon oral examination of a representative of Stillwater Designs, Inc. The
`
`deposition will be taken at the Hampton Inn & Suites Stillwater, 717 E. Hall of Fame Ave.,
`
`Stillwater, OK 74075, on September 15, 2016, at 9:00 a.m., or at some other place and time
`
`mutually agreed upon by counsel. The deposition will be taken before an officer authorized to
`
`administer oaths, and will continue day to day until completed. The deposition will be recorded
`
`by audio, audiovisual, and/or stenographic means.
`
`
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 2 of 10 PageID #:
` 5764
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /s/ Sheila Mortazavi
`Deron R. Dacus
`Texas State Bar No. 00790553
`Peter A. Kerr
`Texas State Bar No. 24076478
`THE DACUS FIRM, P.C.
`821 ESE Loop 323
`Suite 430
`Tyler, TX 75701
`Telephone: (903) 705-1117
`Facsimile: (903) 705-1117
`Email: ddacus@dacusfirm.com
`Email: pkerr@dacusfirm.com
`
`Michael J. Lennon (admitted pro hac vice)
`Sheila Mortazavi (admitted pro hac vice)
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Telephone: (212) 425-7200
`Facsimile: (212) 425-5288
`Email: mlennon@kenyon.com
`Email: smortazavi@kenyon.com
`
`Susan A. Smith (admitted pro hac vice)
`KENYON & KENYON LLP
`1500 K Street, N.W.
`Washington D.C. 20005
`Telephone: (202) 220-4200
`Facsimile: (202) 220-4201
`Email: ssmith@kenyon.com
`
`Attorneys for Defendants VOLKSWAGEN
`GROUP OF AMERICA, INC. and
`VOLKSWAGEN GROUP OF AMERICA
`CHATTANOOGA OPERATIONS, LLC
`
`
`
`
`2
`
`Dated: September 1, 2016
`
`
`
`
`
`
`
`
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 3 of 10 PageID #:
` 5765
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 1, 2016, a copy of the foregoing document was served via
`
`
`
`email on all counsel for plaintiff Blitzsafe Texas, LLC who are deemed to have consented to
`
`electronic service. Local Rule CV-5(d).
`
`
`
`
`
`/s/ Michael Turner
`
`
`
`
`
`
`
`
`
`3
`
`
`
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`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 5 of 10 PageID #:
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`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 6 of 10 PageID #:
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`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 7 of 10 PageID #:
` 5769
`
`SCHEDULE A
`
`TOPICS FOR DEPOSITION
`
`DEFINITIONS
`
`1.
`
`“You” means Stillwater Designs, Inc., also known as “Kicker,” in its capacity as
`
`the entity formerly operating as SoundGate or The Putman Group, Inc.
`
`2.
`
`“Interface” means any aftermarket integration device or system made, sold, or
`
`offered for sale by you, in the United States, for integrating aftermarket media devices such as
`
`CD players, MP3 players, DVD players, or satellite radio receivers, with original equipment
`
`manufacturer (“OEM”) car stereo systems.
`
`
`
`TOPICS
`
`1.
`
`Any Interfaces made, sold or offered for sale by You in the United States before
`
`June 27, 2006, for playing media from an aftermarket media device on an OEM car stereo
`
`system by translating communications between the aftermarket electronic media device protocol
`
`and the OEM protocol, or by integrating operating buses, including, for example, the SoundGate
`
`ALFDIV3 CD Changer Interface, SoundGate Docking Station SDS1, and devices interfaces
`
`connectable to the SoundGate Docking Station SDS1.
`
`2.
`
`The electronic control components of any Interfaces made, sold or offered for sale
`
`by You in the United States before June 27, 2006, including any processor, microprocessor,
`
`microcontroller, or digital signal processor programmed or pre-programmed for:
`
`a.
`
`remotely controlling an aftermarket media device from an OEM car
`
`stereo;
`
`
`
`1
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 8 of 10 PageID #:
` 5770
`
`b.
`
`receiving data from an aftermarket media device and transmitting data to
`
`an OEM car stereo;
`
`c.
`
`d.
`
`switching between audio device input sources;
`
`generating device presence signals to maintain an OEM car stereo in an
`
`operational or responsive state.
`
`3.
`
`The sale or offer for sale by You in the United States before June 27, 2006 of any
`
`Interface responsive to Topic No. 1.
`
`4.
`
`Promotional materials provided by You describing any Interface responsive to
`
`Topic No. 1.
`
`5.
`
`Your response to the subpoena issued to you in Marlowe Patent Holdings, LLC v.
`
`Ford Motor Co., No. 3:11-cv-07044-PGS-DEA (D.N.J.).
`
`
`
`
`
`
`
`2
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 9 of 10 PageID #:
` 5771
`
`SCHEDULE B
`
`REQUESTS FOR THE PRODUCTION OF DOCUMENTS AND THINGS
`
`DEFINITIONS
`
`3.
`
`“You” means Stillwater Designs, Inc., also known as “Kicker,” in its capacity as
`
`the entity formerly operating as SoundGate or The Putman Group, Inc.
`
`4.
`
`“Interface” means any aftermarket integration device or system made, sold, or
`
`offered for sale by you, in the United States, for integrating aftermarket media devices such as
`
`CD players, MP3 players, DVD players, or satellite radio receivers, with original equipment
`
`manufacturer (“OEM”) car stereo systems.
`
`
`
`DOCUMENTS REQUESTED
`
`6.
`
`Documents describing any Interfaces made, sold or offered for sale by You in the
`
`United States before June 27, 2006, for playing media from an aftermarket media device on an
`
`OEM car stereo system by translating communications between the aftermarket electronic media
`
`device protocol and the OEM protocol, or by integrating operating buses, including, for example,
`
`the SoundGate ALFDIV3 CD Changer Interface, SoundGate Docking Station SDS1, and devices
`
`interfaces connectable to the SoundGate Docking Station SDS1.
`
`7.
`
`Documents describing the electronic control components of any Interfaces made,
`
`sold or offered for sale by You in the United States before June 27, 2006, including any
`
`processor, microprocessor, microcontroller, or digital signal processor programmed or pre-
`
`programmed for:
`
`a.
`
`remotely controlling an aftermarket media device from an OEM car
`
`stereo;
`
`
`
`3
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 155-1 Filed 09/20/16 Page 10 of 10 PageID #:
` 5772
`
`b.
`
`receiving data from an aftermarket media device and transmitting data to
`
`an OEM car stereo;
`
`c.
`
`d.
`
`switching between audio device input sources;
`
`generating device presence signals to maintain an OEM car stereo in an
`
`operational or responsive state.
`
`8.
`
`Records of the sale or offer for sale by You in the United States before June 27,
`
`2006 of any Interface responsive to Document Request No. 1, including purchase orders,
`
`invoices, customer lists, or service agreements.
`
`9.
`
`Promotional materials provided by You describing any Interface responsive to
`
`Document Request No. 1.
`
`10.
`
`Documents produced in response to the subpoena issued to You in Marlowe
`
`Patent Holdings, LLC v. Ford Motor Co., No. 3:11-cv-07044-PGS-DEA (D.N.J.).
`
`*
`
`*
`
`*
`
`*
`
`*
`
`If necessary, confidential
`
`information may be designated as “CONFIDENTIAL” or
`
`“RESTRICTED – ATTORNEYS’ EYES ONLY” under the protective order in this case, which
`
`is attached.
`
`
`
`4
`
`
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