Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 1 of 7 PageID #: 978
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`Exhibit "A"
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 2 of 7 PageID #: 979
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`CIVIL ACTION NO. 6:14-cv-982
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`CONSOLIDATED LEAD CASE
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`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC,
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC., ET AL.,
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`Defendants.
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`Request for International Judicial Assistance Pursuant to the Hague Convention
`of 18 March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters
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`Sender:
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`Ed Nelson
`NELSON BUMGARDNER
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`Direct: 817-377-3489
`ed@nelbum.com
`
`Central Authority of the Requested State:
`
`Maija Leppä
`PL 25
`00023 VALTIONEUVOSTO
`Telephone: +358 9 1606 7628
`Fax: +358 9 1606 7524
`Central.authority@om.fi
`
`Person to whom the executed request is to be returned:
`
`Ed Nelson
`NELSON BUMGARDNER
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`
`1
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 3 of 7 PageID #: 980
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`Direct: 817-377-3489
`ed@nelbum.com
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`Date by which the requesting authority requires receipt of the response to the Letter of Request:
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`The requesting authority, the District Court for the Eastern District of Texas, Tyler
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`Division, requests that the receipt of the response to this Request be returned within the standard
`timeframe that the Finnish Ministry of Justice has used to process such previous requests. This
`request is not made as an urgent request, but rather one to be handled within standard operating
`procedures.
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`IN CONFORMITY WITH ARTICLE 3 OF THE CONVENTION, THE UNDERSIGNED
`APPLICANT HAS THE HONOUR TO SUBMIT THE FOLLOWING REQUEST:
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`Requesting Judicial Authority:
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`United States District Court for the Eastern District of Texas, Tyler Division
`William M. Steger Federal Building and United States Courthouse
`211 West Ferguson Street
`Room 106
`Tyler, Texas 75702
`Phone: (903) 590-1000
`Fax: (903) 590-1015
`
`The above-mentioned Authority is making this Request to:
`
`Ministry of Justice, Finland
`PL 25
`00023
`VALTIONEUVOSTO
`Finland
`Central.authority@om.fi
`
`This Request is made under the following judicial proceeding:
`
`Cellular Communications Equipment LLC, plaintiff, v. LG Electronics, Inc., et al., Defendants,
`Civil Action File Number 6:14-cv-982
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`This Request is to be served upon:
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`Nokia Corporation
`Karaportti 3
`FI-02610 Espoo
`Finland
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`2
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 4 of 7 PageID #: 981
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`The nature of the case from which this Request stems is a complaint on patent
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`infringement of U.S. Patent No. 8,385,966. It alleges that certain defendants have and continue to
`infringe by selling, importing, making, using, offering for sale, among other things, certain
`mobile devices manufactured by Samsung. The same allegations are further alleged, but involve
`U.S. Patent Nos. 8,848,556; and 8,868,060. To this point in the litigation, the defendants have
`not filed an answer and counterclaim. However, the defendants have filed a motion to dismiss
`based on the alleged failure to plead indirect infringement with sufficient specificity. The
`Plaintiff opposed the motion, but the judge has not ruled on the motion as of the date of this
`Request.
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`The nature of the proceedings being requested in this letter is Request for Productions to
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`Nokia for certain documents kept and maintained through their course of business. This evidence
`is sought for the intended use at trial between Plaintiff and Defendants.
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`The evidence to be collected is as follows:
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`1. All licenses between Nokia (or its Affiliate(s)) and Alcatel-Lucent S.A. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`2. All licenses between Nokia (or its Affiliate(s)) and Amazon (or its Affiliate(s)) regarding
`the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`3. All licenses between Nokia (or its Affiliate(s)) and Apple Inc. (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`4. All licenses between Nokia (or its Affiliate(s)) and Dell Inc. (or its Affiliate(s)) regarding
`the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`5. All licenses between Nokia (or its Affiliate(s)) and LM Ericsson Telephone Company (or
`its Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`6. All licenses between Nokia (or its Affiliate(s)) and Handspring, Inc. (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`7. All licenses between Nokia (or its Affiliate(s)) and HTC Corporation (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`8. All licenses between Nokia (or its Affiliate(s)) and Huawei Technologies Co. Ltd. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`9. All licenses between Nokia (or its Affiliate(s)) and Kyocera Corporation (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`10. All licenses between Nokia (or its Affiliate(s)) and LG Electronics, Inc. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`11. All licenses between Nokia (or its Affiliate(s)) and Lenovo Group Ltd. (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`12. All licenses between Nokia (or its Affiliate(s)) and Microsoft Corporation. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 5 of 7 PageID #: 982
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`13. All licenses between Nokia (or its Affiliate(s)) and Mitsubishi Group (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`14. All licenses between Nokia (or its Affiliate(s)) and Motorola, Inc. (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`15. All licenses between Nokia (or its Affiliate(s)) and NEC and/or NEC Casio and/or NEC
`Casio Mobile Communications, Ltd. and/or NEC Corporation of America. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`16. All licenses between Nokia (or its Affiliate(s)) and Option Wireless and/or Option NV
`(or its Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556;
`and 8,868,060)
`17. All licenses between Nokia (or its Affiliate(s)) and Pantech Co., LTD. and/or Pantech
`Wireless, Inc. (or its Affiliate(s)) regarding the Patents-in-Suit.
`18. All licenses between Nokia (or its Affiliate(s)) and Koninklijke Philips N.V. (or its
`Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and
`8,868,060)
`19. All licenses between Nokia (or its Affiliate(s)) and Qualcomm Inc. (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`20. All licenses between Nokia (or its Affiliate(s)) and Research-in-Motion Limited and/or
`Research-in-Motion Corporation and/or Blackberry Limited and/or Blackberry
`Corporation (or its Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos.
`8,385,966; 8,848,556; and 8,868,060)
`21. All licenses between Nokia (or its Affiliate(s)) and Samsung Group (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`22. All licenses between Nokia (or its Affiliate(s)) and Siemens AG (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`23. All licenses between Nokia (or its Affiliate(s)) and Sierra Wireless (or its Affiliate(s))
`regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`24. All licenses between Nokia (or its Affiliate(s)) and ZTE Corporation and/or ZTE (USA)
`Inc. (or its Affiliate(s)) regarding the Patents-in-Suit. (U.S. Patent Nos. 8,385,966;
`8,848,556; and 8,868,060)
`25. Documents sufficient to show any license between Nokia (or its Affiliate(s)) and any
`other entity not included in Requests for Production Nos. 1-24 regarding any of the
`Patents-in-Suit. (U.S. Patent Nos. 8,385,966; 8,848,556; and 8,868,060)
`26. A complete and unredacted copy of the Contribution Agreement between Siemens
`Networks GmbH & Co. KG and Siemens Aktiengesellschaft dated September 28, 2006.
`27. A complete and unredacted copy of the Contribution Agreement between Nokia and
`Siemens Networks GmbH & Co. KG and D Zqei GmbH & Co. KG dated December 28,
`2007.
`28. Completed and unredacted copies of any schedules and/or Annexes referenced in the
`Contribution Agreement between Siemens Networks GmbH & Co. KG and Siemens
`Aktiengesellschaft dated September 28, 2006.
`29. A complete and unredacted copy of the Framework Agreement between Nokia
`Corporation and Siemens Aktiengesellschaft dated June 19, 2006 and referenced in the
`Contribution Agreement between Siemens Netowrks and GmbH & Co. KG and Siemens
`Aktiengesellschaft dated September 28, 2006.
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 6 of 7 PageID #: 983
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`30. Complete and unredacted copies of any agreement between Nokia (or its Afilliate(s)),
`Nokia Siemens Networks (or its Affiliate(s)), and//or Siemens Aktiengesellschaft (or its
`Afilliate(s)) related to or concerning the rights or licenses to the Patents-in-Suit,
`including, but not limited to, any acquisition by Nokia of rights to Nokia Siemens
`Networks held by Siemens, such acquisition first being publicly announced on or about
`July 1, 2013.
`31. Any agreement between Nokia (or its Affiliate(s)) and Qualcomm (or its Affiliate(s))
`creating a commitment by Nokia to Qualcomm, Inc. to offer licenses to current or future
`Qualcomm, Inc. component customers under certain terms and conditions, including,
`without limitation, maximum royalty rates for products of Qualcomm, Inc. customers.
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`There are no special requirements for the production of these documents, but Plaintiff
`respectfully requests that they be produced in the manner in which the documents are kept in the
`normal course of business and/or electronically or by means of computer disk. They do not need
`to be produced under oath or certified.
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`The request should be fulfilled by Nokia Corporation within a reasonable time period upon
`receipt of the Request from the Finnish Ministry of Justice and such responses to this Request
`should be sent, upon completion, to:
`
`
`Ed Nelson
`NELSON BUMGARDNER
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`Direct: 817-377-3489
`ed@nelbum.com
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`Any fees and/or costs that are incurred as a result of the production ordered under this
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`Request will be ordered to be paid by:
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`Ed Nelson
`NELSON BUMGARDNER
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`Direct: 817-377-3489
`ed@nelbum.com
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`5
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`Case 6:14-cv-00982-KNM Document 133-1 Filed 10/19/15 Page 7 of 7 PageID #: 984
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`Further, this Court offers reciprocity to the Finnish court, should that ever need assistance
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`in the United States.
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`This Request is hereby made on this ___ Day of October, 2015.
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`______________________________
`District Court Judge for the
`United States District Court for the
`Eastern District of Texas, Tyler Div.
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`Formal Seal of the Court:
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`______________________________
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