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`Exhibit 23
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`Case 5:16-cv-00179-RWS Document 287-26 Filed 08/07/18 Page 2 of 3 PageID #: 16860
`
`Sung, Ye-Eun
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Clark,
`
`O'Connell, Sara J. [sara.oconnell@pillsburylaw.com]
`Sunday, June 17, 2018 8:01 PM
`Bakewell, Clark S.
`ZTE_Hitachi; US-CLIENT-HM-ZTE-Service; Janet Orr; kbt@texarkanalaw.com;
`gpc@texarkanalaw.com; Eric Findlay; Brian Craft
`RE: Maxell v. ZTE - 6/17 Dislosures by Maxell
`
`We will not be presenting section 102 or 103 defenses for the ‘794, ‘493 or 729 patents.
`
`I will follow up on the other matters shortly.
`
`Sara J. O'Connell | Counsel
`Pillsbury Winthrop Shaw Pittman LLP
`501 West Broadway, Suite 1100 | San Diego, CA 92101-3575
`t 619.544.3185 | m 858.205.4314
`sara.oconnell@pillsburylaw.com | website bio
`
`From: Bakewell, Clark S. <CBakewell@mayerbrown.com>
`Sent: Sunday, June 17, 2018 4:53 PM
`To: O'Connell, Sara J. <sara.oconnell@pillsburylaw.com>
`Cc: ZTE_Hitachi <ZTEHitachi@Pillsburylaw.com>; US-CLIENT-HM-ZTE-Service <HM-ZTE-Service@mayerbrown.com>;
`Janet Orr <jorr@texarkanalaw.com>; kbt@texarkanalaw.com; gpc@texarkanalaw.com; Eric Findlay
`<EFindlay@FindlayCraft.com>; Brian Craft <BCraft@FindlayCraft.com>
`Subject: Maxell v. ZTE - 6/17 Dislosures by Maxell
`
`Hi Sara,
`
`Maxell makes the following disclosures:
`
`Documentary demonstratives (sent via FTP):
`• Demonstrative slides for voir dire
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`• Demonstrative slides for opening remarks
`
`•
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`The asserted patents
`
`• Demonstrative slides for the direct examination of Dr. Caloyannides
`
`Deposition designations:
`•
`Shengjuan Wang (72:13 – 73:17; 102:8 – 103:23)
`
`Exhibits subject to ongoing ZTE objections:
`•
`PX-165, 166, 167, 168, 282, 283, 284, 287, 289, 290, 293, 294, 298, 299, 300, 303
`
`Physical exhibits and non-documentary demonstratives (available for inspection):
`•
`Check boards for Dr. Maher with respect to the asserted claims of the ’491 and ’695 patents
`
`1
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`
`
`Case 5:16-cv-00179-RWS Document 287-26 Filed 08/07/18 Page 3 of 3 PageID #: 16861
`
`•
`
`PPX-5 and 6.
`
`Maxell also confirms that it will not be objecting to the physical demonstratives that ZTE disclosed this afternoon for use
`tomorrow.
`
`Lastly, we discussed a few matters this afternoon, which I wish to write up and confirm:
`
`1. Objections to physical exhibits, exhibits that are listed as demonstrative-only, and exhibits that are subject to
`outstanding objections will be due at 8am the day before trial (not noon), but otherwise ZTE accepts the
`proposal regarding trial management procedures sent via email by Kfir on 6/13.
`
`2.
`
`ZTE confirmed that it will not be using Colley either as an exhibit or otherwise, but maintained its notice
`regarding Alumbaugh
`
`Clark
`
`__________________________________________________________________________
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`
`2
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