`Case 5:19-cv-00036—RWS Document 160-4 Filed 12/06/19 Page 1 of 2 PageID #: 6245
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`EXHIBIT 4
`EXHIBIT 4
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`Case 5:19-cv-00036-RWS Document 160-4 Filed 12/06/19 Page 2 of 2 PageID #: 6246
`Maggisg,%®fi-Eyp00036-RWS Document 160-4 Filed 12/06/19 Page 2 of 2 PageID #: 6246
`
`T. Beasley
`August 27. 2019
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`Page 2
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`In other words in 2013 HC‘Ex’Hitachi Ltd. assigned the srnartphone portfolio to Hitachi Maxell
`and transferred over its files that related thereto. HC‘Ez‘Hitaclri. Ltd. did n_0t transfer over files that
`related to its other portfolios that were not assigned to Hitachi Maxell. such as files relating to
`Hitachi. Ltd‘s wearable patent portfolio. Given the fact that Hitachi Maxell has no interest in or
`to such portfolio. there was no reason to.
`
`Maxell does not deny that it relies 011 the June 25. 2013 meeting wherein Apple was
`presented with the opportunity to license the srnar‘tphone portfolio for its allegations of willfulrress.
`And to that end. 1\~Iaxell has )roduced the documents related to the smart )hone ortfolio that were
`
`
`
`
`a
`is not 111 possession, custo V'. or contro of
`ess. as prevrous y statec. Maxe
`such documents because they were not transferred by HC‘Ei“'Hitachi. Ltd. to Hitachi Maxell.
`
`
`
`There
`.
`1 Apple admits "Maxell has produced one document provided by Hitachi to Apple during the meeting. .
`were actually three documents relating to the smartphone portfolio provided during the meeting. all of which have
`been produced by Maxell.
`
`
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