`EXHIBIT A
`
`MAYER I BROWN
`
`M:,ye, ~ LLP
`1999 KS.,.,,,H.W.
`\•~on, O.C. 200~1101
`
`f,t,i\ T !I +t 20'2 2i3 3000
`M»'I Fax i-120'2 ~J!3:)J0
`nw~~-orotMl.CO'll
`
`Jamie B. Beaber
`Direct Tel +-120'2 ~'""13153
`Direct fox +1 202 ~l 5209
`joeXE:13ffil}~'"D!Olffl.CO'll
`
`September ll. 2019
`
`HAE-1\IAIL
`
`Mr. Satosbi Matsuo
`Departlllent Manager. IP Business Platform Departlllent
`Hitachi. Ltd. Intellectual Property Division
`Momnnnrh, C:i'OtPf Ride
`1-6-1 Marunohcbi, Chiyoda-lm Tok")'o 100-8220, Japan
`satoshi.U1atsuo.zk@bitachi.coU1
`
`Re: Request for Materials in Connection with Maxell, Ltd .. v. Apple Inc... Case No.
`5:19-cv-00036-RWS (E.D. Te.'1.)
`
`Dear lvlatsuo-san:
`
`We write on behalf of Maxell, Ltd. ("Maxell''). Maxell is engaged in litigation in the United
`States adverse to Apple, Inc. ("Apple") wherein Ma.xe.ll has alleged infringement by Apple of
`several patents that were assigned by Hitachi Consumer Elecironics, Ltd. to Hitachi Maxell, Ltd.
`in 2013 as part of a larger sU1.1rtphone portfolio. See Attached Co1Uplaint.
`
`In connection with the litigation. Apple bas requested the production of several categories
`of U1aterial.s which Apple asserts are relevant to the case. More specifically. Apple has requested
`production of the following categories of doCUU1ents that relate to interactions between Apple and
`Hitachi. Ltd./Hitachi Consumer Electronics, Ltd. between
`
`• All documents and conununications relating to the June 2013 U1eeting between Apple and
`Hitachi.
`
`•
`
`•
`
`Maxell has searched its files and does not have the lll3terials requested by Apple within its
`possession.. Nevertheless. Apple has asserted that Maxell has the practical ability to obtam such
`docwuents ftolll Hitachi given Hitaclli·s role as a predecessor-in-irueresr with respect ro the
`smanpbone portfolio. relying Oil Kmnara11/ v. Be11Q Corp .. 2005 U.S. Dist. LEXIS 42762. •11.
`2005 WL 2455825 (ED. Tex. Oct.6. 2005) (eitingBankofNew for.h. Mmdle11Bla0Bank Ta11: ..
`171 F .R.D. 135 (S.D.N.Y. 1997)).
`As a courtesy to Apple given Apple's position. ,w request Oil behalf of Maxell that Hitlchi
`pl= provide io Mil.'tdl's outside co=l. Mayer Brown LLP. any documents within Hit3chi.
`Ltd.· s possession, CUS1ody. or control tbat fall within lilc three categories outlined above. We
`further request tb.1t Hitachi provide a response to MaxelJ's request no laier than September 16.
`2019_
`
`cc: Counsel ofRerord
`
`
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