Case 5:19-cv-00036-RWS Document 221-4 Filed 03/09/20 Page 1 of 2 PageID #: 8926
`Case 5:19-cv-00036—RWS DocumeHUMQVEflédCO‘S/OQIZO Page 1 of 2 PageID #: 8926
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`EXHIBIT C
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`EXHIBIT C
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 221-4 Filed 03/09/20 Page 2 of 2 PageID #: 8927
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`FirmName
`400 South Hope Street
`18ᵗʰ Floor
`Los Angeles, CA 90071-2899
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`T: +1 213 430 6000
`F: +1 213 430 6407
`omm.com
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`July 18, 2019
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`VIA E-MAIL
`
`Jamie B. Beaber
`Mayer Brown LLP
`1999 K Street, N.W.
`Washington, D.C. 20006-1101
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`File Number:
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`Tony Beasley
`D: +1 213 430 6529
`tbeasley@omm.com
`
`Re: Maxell, Ltd. v. Apple Inc., Case No. 5:19-cv-00036-RWS (E.D. Tex.)
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`Dear Mr. Beaber:
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`I write to provide a response to your June 18, 2019 letter. As you know, pursuant to
`Paragraphs 1-3 and 5 of the Discovery Order (Dkt. 42), requests for production are
`unnecessary as the parties are expected to produce documents that “are relevant to the
`pleaded claims or defenses involved in this action” without the need for any requests for
`production (Discovery Order at Paragraph 3(b)). Apple is complying and will continue to
`comply with all of its discovery obligations under the Court’s orders and rules.
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`Apple will treat your Requests for Production (“RFPs”), in conjunction with your subsequent
`correspondence and our collective and ongoing discussions related thereto, as notice of
`what materials Plaintiff believes are relevant and should be produced. As discussed in
`separate correspondence, Apple has been in the process of collecting relevant, responsive,
`non-privileged documents for production and began its rolling production on July 10, 2019.
`Apple will continue to produce documents sufficient to show information “relevant to the
`pleaded claims or defenses involved in this action” on a rolling basis and without awaiting
`further requests. To the extent that any questions or disputes arise over the scope of
`Apple’s production, Apple will address those through the correspondence chain that began
`with your July 11, 2019 letter.
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`Thanks,
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`/s/ Tony Beasley
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`Tony Beasley
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`Century City • Los Angeles • Newport Beach • New York • San Francisco • Silicon Valley • Washington, DC
`Beijing • Brussels • Hong Kong • London • Seoul • Shanghai • Singapore • Tokyo
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`PUBLIC VERSION
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