Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 1 of 20 PageID #: 9621
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`Case No. 5:19-cv-00036-RWS
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`Plaintiff,
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`Defendant.
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`LEAD CASE
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`JURY TRIAL DEMANDED
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`MAXELL, LTD.,
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`v.
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`APPLE INC.,
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`MAXELL, LTD.’S REPLY IN SUPPORT OF OPPOSED MOTION TO COMPEL
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 2 of 20 PageID #: 9622
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`Table of Contents
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`Continuing Deficiencies in Apple’s Production of Technical Documents. ........................... 3
`I.
`II. Continuing Issues with Apple’s Production of Non-Source Code Documents on Source
`Code Computer. ................................................................................................................... 10
`III. Continuing Issues with Apple’s Production of Non-Technical Documents. ....................... 12
`IV. Apple’s Request for Costs and Sanctions is Not Warranted................................................ 14
`V. Conclusion ........................................................................................................................... 15
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 3 of 20 PageID #: 9623
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`As an initial matter, Maxell did not violate this Court’s standing order requiring a meet
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`and confer. Maxell met and conferred with Apple, during which time Apple represented that
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`“after its reasonable search” certain documents (some that have now been produced) did not
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`exist. For the documents that Apple claims it was still investigating, Maxell allowed Apple
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`ample time to investigate and then addressed these in later correspondence to which Apple never
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`responded—even ignoring requests for additional meet and confers. Apple’s complaint that
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`Maxell failed to meet and confer is misleading, and underscores Apple’s abuse of the meet and
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`confer process (addressed in detail in Maxell’s motion for sanctions). As Apple’s production
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`since the filing of this motion reveals, the only thing that prompts Apple to comply with its
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`discovery obligations is motion practice (and even then it flouts the Court’s orders). This
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`conduct, not Maxell’s motion, is truly what “contravenes the stated goal of ‘maximiz[ing] the
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`best use of the Court’s limited resources.’”
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`And while Apple’s Opposition paints a rosy picture, the majority of the issues raised in
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`Maxell’s Motion to Compel have not been resolved. Apple’s representation of resolution more
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`often than not results from an overly-narrow view of the deficiencies (an issue that Maxell has
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`repeatedly highlighted to Apple). For example, with respect to schematics, the deficiency was
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`two-fold: 1) Apple failed to produce any schematics for 29 accused products, and 2) Apple failed
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`to produce complete schematics for many other products. Apple’s response only addressed the
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`missing 29 schematics while ignoring Maxell’s request for complete schematics for the other
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`products. For other deficiencies raised by Maxell, Apple limited its responsive production, and
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`response to the motion, to the specific examples called out by Maxell and ignored the categories
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`in full. Apple has used this strategy to limit and draw out discovery throughout the case despite
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`Maxell’s countless instructions otherwise, which is a major impetus for Maxell’s motion.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 4 of 20 PageID #: 9624
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`To the extent that Apple has begun to address deficiencies, the results reveal the obvious
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`inadequacy of Apple’s reasonable search and productions to date, suggesting that the conduct
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`was either intentional or grossly negligent. Many of the materials Apple has just recently
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`produced are highly relevant, repeatedly requested by Maxell, and should have been produced
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`long ago so that Maxell could have properly utilized them in performing its source code review,
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`preparing amended contentions, making its final election of asserted claims, taking 30(b)(6)
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`depositions, and preparing its case for trial before being foreclosed from seeking additional
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`discovery by the discovery deadline. Even more egregious, some of the documents now being
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`produced are documents Apple previously (and repeatedly) said do not exist. Apple’s counsel
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`made the following representation during the meet and confer: “
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`.” D.I. 197 at Ex. A. But not only do many of the
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`documents actually exist (and some produced), it is readily evident that Apple would easily have
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`found them if Apple had performed simple word-searches of its repositories and consulted with
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`knowledgeable engineers (including, but not limited to, those designated as corporate
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`representatives in this case long ago by Apple) as evidenced by relevant depositions.
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`While the deadline to take the remaining depositions and prepare expert reports has been
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`recently extended, the time to produce discovery is very nearly over. These deficiencies should
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`have been remedied many months ago, or at the very least as soon as they were raised by
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`Maxell.1 But Apple’s primary goal has been to intentionally frustrate the discovery process and
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`1 The parties initially had a meet and confer scheduled for March 13 to identify what issues from Maxell’s motion to
`compel remain open. When the March 17 hearing was cancelled, Maxell stated it believed a teleconference would
`still be beneficial, but Apple asked to reschedule it for the following Monday. On Sunday, Apple asked to
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 5 of 20 PageID #: 9625
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`the preparation of Maxell’s case notwithstanding its discovery obligations.
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`I.
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`Continuing Deficiencies in Apple’s Production of Technical Documents.
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`Apple’s technical document production remains incomplete. In fact, documents recently
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`produced by Apple reveal further deficiencies. And Apple’s strategy to address only the specific
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`examples provided by Maxell is most prevalent, and most prejudicial, when it comes to technical
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`documents. Apple is plainly aware of 1) the accused products, 2) the implicated components, and
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`3) the types of materials created by or provided to Apple in connection with the design and
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`testing of a functionality. Given its position, the burden is on Apple to identify and produce the
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`relevant materials for each product, component, and functionality that Maxell has identified and
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`relied on for its infringement claims in this case. Apple’s attempts to evade its burden by playing
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`dumb and blaming Maxell for not identifying what is missing flies in the face of this Court’s
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`discovery rules (e.g., blaming its lack of production based on Maxell not identifying the specific
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`products for which schematics are missing and not identifying the specific chipsets for which
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`manuals are missing). The remaining deficiencies of which Maxell is currently aware include:
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`Complete Schematics. Although Maxell informed Apple that schematics were missing,
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`Apple complains that Maxell did not identify them by model number and asserts that, if Maxell
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`had, the issue would have been quickly resolved. Yet, over a month has passed since Maxell
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`filed its motion, and the issue is still unresolved. Apple asserts that certain of the missing
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`schematics have now been produced; however, the cited documents are identifiable only by
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`internal model numbers—
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`—none of which have been linked to
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`accused products, which is required of Apple’s response to Interrogatory No. 1. In other words,
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`only Apple knows if these documents address the deficiencies, and Apple has refused to respond
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`reschedule again, but offered no alternative date. Maxell thus followed up with a letter detailing remaining
`deficiencies on March 17, but Apple has neither responded in writing nor via meet and confer.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 6 of 20 PageID #: 9626
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`to Maxell’s request for clarification. Based on the model numbers Apple has provided,
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`schematics are still missing for
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`Apple’s opposition does not even address Maxell’s request for complete schematics for
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`each product (including, e.g.,
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`). Apple has
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`provided incomplete schematics and this issue has not been resolved. Furthermore, Apple’s
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`corporate deponent, Adam Machalek, represented
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`. Ex. D (Rough Dep. Tr. at 72:22-73:20).
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`Documents Describing Cellular Functionalities. Throughout this case, Apple has
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`represented that the cellular functionalities of the accused products are
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`. Apple also took this position before the Court in February. D.I. 205 at
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`2. But it is not the case. This month, Apple produced
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`. Apple’s production proves that relevant, responsive documents exist at
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`Apple. See D.I. 241 at Siddiqui Decl. ¶23-25. Unfortunately, Apple has not produced these
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`materials for all relevant products/components. For example, Apple produced
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`,2 but has not produced it for
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`.3
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`2 The
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`. See, e.g., D.I. 241 at Siddiqui Decl. ¶24 and Ex.
`S. Apple knew this component was relevant and had previously produced a 17 page datasheet that did not
`address relevant functionality. Apple withheld the longer, useful document until the end of discovery.
`3 When Maxell subpoenaed
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`” See Ex. E, Mar. 16, 2020 E-mail from
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` to G. Culbertson (emphasis added).
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 7 of 20 PageID #: 9627
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`Apple produced
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`. One week before the close of fact discovery, Apple has now informed Maxell
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`that it is withholding discovery for these modems based on relevancy. According to Apple,
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`products incorporating these modems fall outside the relevant damages period. See Ex. F
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`(3/24/20 Ltr. Pensabene to Beaber). Notwithstanding the fact that these products are identified by
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`Maxell as “Accused Products,” the products including
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` modems have a
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`combined sales revenue of
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` within the time period that Apple notes as the
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`relevant damages time period. See Ex. G (APL-MAXELL_01147395 sales spreadsheet).
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`Moreover, the
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`for documents describing relevant cellular functionalities, including
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`. See, e.g., D.I. 241 at Siddiqui Decl. at ¶26. Apple began producing
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`such materials on March 25 at 8 p.m. eastern, but it is unclear whether the production is
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`complete. Similarly, documents Apple produced cite to similar design specifications for
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` full versions of which have also not been produced. Moreover, it is apparent Apple
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`has not searched for and produced documents discussing “closed-loop,” “open-loop,” and/or “PA
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`Bias Control” either. All extremely relevant functionality for this case and at least the asserted
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`‘193 patent.
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`In connection with this topic, Maxell also raised the fact that many specifications
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 8 of 20 PageID #: 9628
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`produced by Apple are incomplete or short versions. Apple asserts that the specific example
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`given in Maxell’s motion was not incomplete, but many other specification datasheets are, often
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`with only a dozen pages produced of a 70+ page document. Apple has the complete versions of
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`these datasheets, and they should be produced. Maxell even subpoenaed
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` in an attempt
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`to obtain complete datasheets for
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` components, but
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` outside
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`counsel conveyed to Maxell on February 25, 2020 that:
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`Ex. H (2/25/20 E-mail from
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` to Culbertson).
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`When Apple produced a complete version of just three datasheets, it was clear that the
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`complete datasheets disclosed highly relevant functionalities that mirror the claim language:
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`Recitation of Claim 1 of the ’193 Patent
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`Excerpt from Complete
`Datasheet
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`“controller controls said transmitter so that
`an open-loop power control is performed
`and then a closed-loop power control is
`performed according to said power control
`signal so as to control the transmitted
`power to converge into a range required by
`said cell-site station, and said controller
`controls a gain of said variable amplitude
`amplifier and a bias condition of said
`power amplifier using a set of bias and
`gain data stored in said memory.”
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`But Maxell continues to await production of complete versions of many such datasheets.
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`Apple’s conduct in withholding these materials is nothing short of brazen.
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` Code. Maxell’s Motion sought both
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` Given Apple’s response, directed only to code, Maxell agrees that its
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 9 of 20 PageID #: 9629
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`dispute regarding code is resolved. However, other
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` documentation remains missing
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`from Apple’s production, including complete (not partial or redacted)
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` datasheets,
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` These documents are
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`relevant to the
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` components in the accused products and must be produced.
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`Requirements Specifications. Another example of Apple narrowly construing a
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`category is Apple’s response that its reasonable search did not return any requirements
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`specifications
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`. Apple did not address requirements specifications generally, except to
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`state that the evidence cited by Maxell did not suggest Apple has any other documents relevant
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`to this case. Despite saying they did not exist, Apple has now recently produced requirements
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`specifications (including for
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` components), confirming that Apple does have such
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`documents and raising questions again about Apple’s “reasonable” search for documents.
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`Apple produced certain
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`—the night before the 30(b)(6) deposition of Mr. Machalek5—but Apple has yet to produce
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`complete
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`Maxell’s infringement contentions, including, but not limited to,
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` implicated by
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`. For example,
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`Apple produced one such
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`whereas for the remaining
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`, Apple produced only documents entitled
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`s. The longer documents are plainly relevant to the infringement of the ’794 patent, and
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`should have been produced well in advance of Apple’s corporate witness deposition on this
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`4 It appears Apple has begun producing such materials on March 25 at 8 p.m. eastern, but it is unclear whether the
`production is complete.
`5 The engineer designated with knowledge about the functionality included in these chips.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 10 of 20 PageID #: 9630
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`topic. Further, Mr. Machalek
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`. Ex. D
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`(Rough Dep. Tr. at 201:7-23). Complete versions of such specifications/datasheets should also
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`be produced for at least
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`Testing Documents. Apple has recently produced what appear to be documents
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`containing
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`that set forth testing protocols for the functionalities set forth in Maxell’s Motion. Based on its
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`response, Apple’s position is that such documents could not be located after a reasonable search.
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`Apple asserts that the evidence previously cited by Maxell does not support the existence of
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`testing documents, but this is not the only evidence of testing. Apple, for example, has SAR
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`Evaluation Reports that are prepared for purposes of FCC certification by UL Verification
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`Services Inc. At least these materials exist and should be produced.
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` User Manual/
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`Again Apple produced the materials for the
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`only, and has not produced complete User’s Manuals for
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` Specification.
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` given as examples
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` were produced for
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`. Furthermore, responsive materials that have been produced cite to a
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` (See Ex. I, APL-MAXELL_01175050) confirming they exist.
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`Such Specifications should be produced for each of the Accused ’794 Products as well.
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`Technical Specifications
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 11 of 20 PageID #: 9631
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`largest deficiency in Apple’s production. When Maxell started pressing for production of these
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`materials in September, Apple responded that
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`. See D.I. 197 at Ex. A.
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` Apple
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`ultimately produced a small subset of them. In response to Maxell’s Motion, Apple continues to
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`assert that “
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`” Opp. at 3. But again, that is factually incorrect, as shown by Apple’s recent selective
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`productions of such documents. The following items are still missing:
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`• Recent depositions confirm the existence of further relevant
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`• Apple has also produced some
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`on an incorrect representation that they did not relate to accused products. Although
`Maxell recently requested confirmation on whether all such specifications have now
`been produced, Apple has not responded.
`• Apple still has not produced a full version of the document produced at APL-
`MAXELL_01206870 (
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`• “
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`•
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`Camera Module Specifications.
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`it should be ensured that Apple’s search for such materials was actually and truly reasonable as
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 12 of 20 PageID #: 9632
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`these documents should exist based on Maxell’s experience.
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`Source Code. Apple recently made new source available but Maxell has been unable to
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`review it based on COVID-19 office closures and travel restrictions. Given Apple’s
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`representations, however, it appears the following source code remains missing:
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`•
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`Redacted Documents. Many documents Apple produced
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`in
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`this case contain
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`unexplained redactions. See Ex. L (exemplary redaction pages). Such redactions are not tied to
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`any entries on Apple’s privilege or redaction logs and are believed to be improper. For example,
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`in a
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` Apple redacted pages directed to the
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` and
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` for the product. Id. Maxell requested
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`an explanation for the improper and unexplained redactions, but has not received any response.
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`II.
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`Continuing Issues with Apple’s Production of Non-Source Code Documents on
`Source Code Computer.
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`Maxell and Apple have been unable to reach agreement regarding non-source code
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`documents produced on the Source Code Computers. Apple produced at least some material in
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`the ordinary course, but has not confirmed that such production is complete.
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`Apple also continues to refuse to produce native versions of spreadsheets initially
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`produced on the source code computer, and then produced in illegible, unusable format in the
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`ordinary course. Apple asserts that if one printed the native version, it would look identical to the
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`PDF. But that ignores the nature of native spreadsheets. In native spreadsheets a user is able to
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`track a particular column or row, and view the inputs or calculations of the data entered in the
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`spreadsheet, none of which is available in the PDF format. The only explanation for Apple’s
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`refusal to provide the native versions is that Apple is attempting to block Maxell from having
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 13 of 20 PageID #: 9633
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`ready access to such information. Apple has produced many other spreadsheets in native format
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`and thus has no blanket concern that such materials are not adequately protected under the
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`Protective Order. It simply does not want to produce these spreadsheets in native format.
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`Apple also continues to refuse to produce non-source code documents that it asserts
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`contain some source code in the ordinary course. An example of such a document is the
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` This is a
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`6 not
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`source code. Apple’s corporate representative testified that
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`Ex. J (Coleman Rough Dep. Tr.) at 22:23-23:10 (
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`). Apple is simply restricting Maxell’s access to technical documents
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`computer Maxell is unable to access at this time. This is a misuse and misapplication of the
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` by holding them on the source code computer—a
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`Protective Order to hinder Maxell’s prosecution of its case.
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`Furthermore, the document entitled
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` is unreadable on the
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`computer and has not otherwise been produced.
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`Maxell requested that Apple provide a list of documents Apple is still withholding on the
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`source code computer, the locations where these documents are stored on the source code
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`computer, and the basis for withholding them. Despite the pendency of this request for quite
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`some time, Apple has not responded, leading in part to the confusion of how to handle such
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`6 If Maxell were to print this document for use in the case, it would very nearly exhaust the printing limits agreed to
`for source code even though the printed pages would contain little, if any source code (under even Apple’s counsel’s
`incorrect interpretation of the definition of source code). Such obstruction to Maxell’s ability to utilize discovery is
`improper.
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`documents. Indeed, Apple never provided notice of this production of non-source code materials
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`on the source code computer, but left it to Maxell to happen on the thousands of documents
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`produced in this manner when reviewing source code – which is, in itself, improper.
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`III. Continuing Issues with Apple’s Production of Non-Technical Documents.
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`Forecast Documents. The most recent forecast document Apple produced contained
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`forecasted sales only through
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`. Apple asserts in its February response that it could not
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`locate any internal forecasts extending beyond
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` after a reasonable search. But there are
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`many public reports about forecasts released for 2020 (Q2 and beyond). It is clear Apple has not
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`produced all relevant forecast documents within its possession, custody, or control.
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`Licenses. Apple attempts to use Maxell’s request for 11 license agreements as an
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`example of how Maxell is abusing the discovery process. But it is Apple’s conduct, not Maxell’s,
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`that precipitated the need for this Motion. The discovery order places on Apple the burden to
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`produce relevant documents without the need for a discovery request. Thus, Maxell should not
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`even have to request such agreements, let alone explain their relevance.7 Once Apple raised a
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`question as to the relevance, Maxell did not rebuff Apple’s request, but explained that the request
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`fell within the Court’s prior order to produce license agreements and noted their relevance to the
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`issue of damages. Maxell also asked Apple to explain why the agreements were not relevant.
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`Apple did not respond to Maxell’s request, but instead accused Maxell of going on “a fishing
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`expedition for every Apple patent license agreement” and again demanding an explanation of
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`relevance, which Maxell endeavored to provide. Ex. K. A request for 11 specific license
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`agreements is hardly “a fishing expedition for every Apple patent license agreement.”
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`Apple also complains Maxell did not provide Apple time to evaluate the request. But
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`7 In fact, even where requests for production are used, the propounding party does not have to explain the relevance
`of each request at the time it is made.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 15 of 20 PageID #: 9635
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`Maxell requested the license agreements on January 27. It did not file its motion until February
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`14, 18 days later and, more importantly, 4 days after Apple was supposed to give a response
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`under the Discovery Order, but did not. And Apple’s statement that Maxell rebuffed Apple’s
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`requests for time to consult with other parties is clearly false. Apple has still not even agreed to
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`produce any of the agreements except one, though another month and a half has passed. Apple
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`never intended to comply and did not need additional time to come to that position.
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`Apple’s response to Maxell’s request for less than a dozen licenses is illustrative of its
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`conduct in the case generally. Maxell made a narrow request and provided an explanation of
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`relevance when asked. Instead of producing the agreements (which would require very little
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`effort), Apple analyzed the agreements to try to find support for an argument of irrelevance on
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`which it could withhold the license—looking for ways not to produce them rather than seeing the
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`reasons it should. But license agreements in particular are always going to have some level of
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`comparability and some level of difference. While Maxell has largely deferred to Apple’s
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`judgment in determining which agreements should and should not be produced, Maxell believed
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`that Apple’s production was missing a few relevant agreements. Rather than try to meet its
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`obligation and produce such agreements, Apple has dedicated it efforts to avoiding it.
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`Apple still has not produced license agreements with Immersion Corp., InterDigital, Inc.,
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`Valencell Inc., Imagination Technologies, ZiiLabs Inc., Ltd., Kudelski Group, Network-1
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`Technologies, Inc., InterTrust Technologies Corp., or Mobile Telecommunications Technology
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`LLC.8 As set forth in Maxell’s Motion, these agreements are relevant because they relate to
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`accused functionalities or establish Apple’s licensing policies for the accused products.
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`Marketing Surveys. It appears that Apple produced all relevant customer survey and
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`8 The HTC agreement has been produced and Maxell withdraws its request as to Wisconsin Alumni Research
`Foundation (WARF).
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`marketing materials requested by Maxell. It should not have taken a motion for Apple to provide
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`these materials. Subject to Apple’s confirmation, Maxell agrees this issue has been resolved.
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`Prior Litigation Documents. Apple produced three reports from the HTC and
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`Wisconsin Alumni Research Foundation cases. It is unclear whether these are the only reports
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`Apple was able to locate within its possession, custody, control, including from counsel
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`representing Apple in such cases. It is also not clear whether Apple refuses to produce the other
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`litigation materials, or whether no such materials could be located. To the extent is it the former,
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`this issue remains unresolved and Apple should be required to produce the materials related to
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`damages, and infringement of accused products as the infringement relates to relevant issues
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`present in this case, with overlapping products, features, or functionalities.
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`Maxell has not made an about-face on the relevance of CalTech. This case and CalTech
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`involve different technologies and are not substantially related matters. But it is likely that Apple
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`took positions in that case relating to damages that are relevant to damages issues present in the
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`instant case. That is why Maxell had limited its request for CalTech litigation materials to
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`damages, not technical documents – Apple intentionally ignores this point. Ex. K. Maxell’s
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`requests related to damages does not create a link between this case and CalTech.
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`IV. Apple’s Request for Costs and Sanctions is Not Warranted
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`Maxell seeks the Court’s assistance as a last resort.9 It has repeatedly requested many of
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`the documents sought in its Motion since September 2019. See D.I. 210 (Maxell Motion for
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`Sanctions). Apple’s arguments to the contrary are a direct result of Apple’s unwavering
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`insistence on addressing only specific examples of missing materials raised by Maxell rather
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`than Maxell’s complaints of categorical deficiencies. Moreover, Apple attacks Maxell for not
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`9 Despite Apple’s characterization of Maxell as a party that runs to the Court, Apple has filed considerably more
`motions than Maxell, including discovery motions.
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`adequately meeting and conferring when Apple is the party that failed to respond to numerous
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`requests by Maxell within the two-week time period set forth in the Discovery Order. Indeed,
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`Maxell saw Apple’s discovery misconduct as an issue early in the case, which precipitated
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`Maxell’s initial motion to compel which was largely granted by the Court. Maxell thereafter still
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`had to fight tooth and nail with Apple to get relevant discovery at substantial cost to Maxell (and
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`is still having to do so). Maxell exhausted every option in the hopes of not having to file
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`additional discovery motions with the Court. However, Apple heedlessly continued its discovery
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`misconduct.
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`Maxell has not mischaracterized or misrepresented documents. Maxell provided its
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`understanding of the documents on which it relied. That Apple’s counsel, who has the ability to
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`consult with Apple engineers and other personnel, may have a different understanding does not
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`render Maxell’s understanding to be intentionally incorrect.
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`Finally, Apple has produced a significant number of highly relevant documents and
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`source code in response to Maxell’s motion, including documents that Apple has repeatedly
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`insisted do not exist, even in its Opposition. But even so, a significant number of deficiencies
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`remain. Deficiencies on which Maxell has reached out to Apple prior to the filing of this Reply,
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`but for which Apple has not provided a response. If the filing of the motion could not resolve the
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`parties’ issues, it is clear that no amount of meet and confer efforts could have avoided them.
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`V.
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`Conclusion
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`By the time briefing on this motion is complete, fact discovery will be closed, depositions
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`will be ramping up again, and expert reports will be nearing their deadline. Apple must be
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`ordered to comply with its discovery obligations immediately rather than be permitted to control
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`Maxell’s ability to build its case through the use of discovery abuses.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 18 of 20 PageID #: 9638
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`Dated: March 26, 2020
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`By:
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`/s/ Jamie B. Beaber
`Geoff Culbertson
`Kelly Tidwell
`Patton, Tidwell & Culbertson, LLP
`2800 Texas Boulevard (75503)
`Post Office Box 5398
`Texarkana, TX 75505-5398
`Telephone: (903) 792-7080
`Facsimile: (903) 792-8233
`gpc@texarkanalaw.com
`kbt@texarkanalaw.com
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`Jamie B. Beaber
`Alan M. Grimaldi
`Kfir B. Levy
`James A. Fussell, III
`Baldine B. Paul
`Tiffany A. Miller
`Saqib J. Siddiqui
`Bryan C. Nese
`William J. Barrow
`Alison T. Gelsleichter
`Clark S. Bakewell
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`agrimaldi@mayerbrown.com
`klevy@mayerbrown.com
`jfussell@mayerbrown.com
`bpaul@mayerbrown.com
`tmiller@mayerbrown.com
`ssiddiqui@mayerbrown.com
`bnese@mayerbrown.com
`wbarrow@mayerbrown.com
`agelsleichter@mayerbrown.com
`cbakewell@mayerbrown.com
`
`Robert G. Pluta
`Amanda Streff Bonner
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 782-0600
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 19 of 20 PageID #: 9639
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`rpluta@mayerbrown.com
`asbonner@mayerbrown.com
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`Counsel for Plaintiff Maxell, Ltd.
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`Case 5:19-cv-00036-RWS Document 252 Filed 03/30/20 Page 20 of 20 PageID #: 9640
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 26th day of March 2020, with a copy of this document
`via electronic mail.
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`/s/ Jamie B. Beaber
`Jamie B. Beaber
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