`Case 5:19-cv-00036—RWS DocumeBUmqVfiflédCOU/OBIZO Page 1 of 2 PageID #: 8847
`
`EXHIBIT C
`
`EXHIBIT C
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 212-4 Filed 03/06/20 Page 2 of 2 PageID #: 8848
`
`Miller, Tiffany A.
`From:
`Sent:
`To:
`
`Cc:
`Subject:
`
`Pensabene, Marc J. <mpensabene@omm.com>
`Tuesday, February 18, 2020 3:24 PM
`Siddiqui, Saqib; Silverman, Daniel; Levy, Kfir B.; Simmons, Luann L.;
`'melissa@gillamsmithlaw.com'; Beasley, Tony; Moon, Bo; Gore, Laura Bayne; Zhou,
`Vincent; #Maxell-Apple; 'Bobby Lamb'; Godfrey, Kristin; bstevens@wscllp.com;
`hcannom@wscllp.com; jquilici@orrick.com; Williamson, Brett J.
`FW-CLIENT-Maxell-Apple-Service; 'Geoff Culbertson'
`RE: Maxell Ltd. v. Apple Inc. (Case 5:19-cv-00036-RWS) - Interrogatory Response No. 12
`
`**EXTERNAL SENDER**
`
`Saqib,
`
`You are not correct in your understanding. As clearly stated in our response to interrogatory 12, the February
`6 supplement included source code made available for inspection as of January 31. We will be providing a
`further supplemental response in view of the recently produced code.
`
`Best
`Marc
`
`
`From: Siddiqui, Saqib <SSiddiqui@mayerbrown.com>
`Sent: Tuesday, February 18, 2020 2:57 PM
`To: Silverman, Daniel <dsilverman@omm.com>; Pensabene, Marc J. <mpensabene@omm.com>; Levy, Kfir B.
`<KLevy@mayerbrown.com>; Simmons, Luann L. <lsimmons@omm.com>; 'melissa@gillamsmithlaw.com'
`<melissa@gillamsmithlaw.com>; Beasley, Tony <tbeasley@omm.com>; Moon, Bo <bmoon@omm.com>; Gore, Laura
`Bayne <lbayne@omm.com>; Zhou, Vincent <vzhou@omm.com>; #Maxell‐Apple <maxellapple@omm.com>; 'Bobby
`Lamb' <wrlamb@gillamsmithlaw.com>; Godfrey, Kristin <kgodfrey@omm.com>; bstevens@wscllp.com;
`hcannom@wscllp.com; jquilici@orrick.com; Williamson, Brett J. <bwilliamson@omm.com>
`Cc: FW‐CLIENT‐Maxell‐Apple‐Service <Maxell‐Apple‐Service@mayerbrown.com>; 'Geoff Culbertson'
`<gpc@texarkanalaw.com>
`Subject: RE: Maxell Ltd. v. Apple Inc. (Case 5:19‐cv‐00036‐RWS) ‐ Interrogatory Response No. 12
`
`
`[EXTERNAL MESSAGE]
`
`Counsel,
`
`We are in receipt of Apple’s Third Supplemental Response to Interrogatory No. 12 dated February 6, 2020. It is our
`understanding from your letter dated February 14, 2020, that Apple considers its February 6th Supplemental Response as
`complete and final and will not be supplementing its response to this interrogatory again (with the exception of the third-
`party source code relating to the
` functionality).
`
`Please let us know if our understanding is incorrect and whether Apple intends to supplement again because as you know
`this interrogatory response provides the key that ties the source code to the accused products.
`
`Best,
`Saqib
`
`
`1
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`PUBLIC VERSION
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