`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`SPEIR TECHNOLOGIES LTD.,
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`Case No. 6:22-cv-00077-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`v.
`
`APPLE INC.,
`
`
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`JOINT MOTION FOR ENTRY OF A SUPPLEMENTAL PROTECTIVE ORDER
`
`Plaintiff Speir Technologies Ltd. (“Speir”) and Defendant Apple Inc. (“Apple”)
`
`(collectively, “the Parties”) file this motion for entry of a Supplemental Protective Order. The
`
`Parties agree to the proposed Supplemental Protective Order, which is attached as Exhibit A. Non-
`
`party Qualcomm Inc. (“Qualcomm”) has requested a supplemental protective order for production
`
`of source code and/or documents that incorporate the confidential information of Qualcomm.
`
`Accordingly, the Parties respectfully request that the Court enter the proposed
`
`Supplemental Protective Order.
`
`
`
`Dated: September 6, 2022
`
`
`
`
`
` Respectfully submitted,
`
`/s/ Brett Cooper
`
`Brett E. Cooper (NY SBN 4011011)
`bcooper@raklaw.com
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Seth Hasenour (TX SBN 24059910)
`shasenour@raklaw.com
`Drew B. Hollander (NY SBN 5378096)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`dhollander@raklaw.com
`
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff Speir Technologies
`Limited
`
`
`
`
` /s/ Stepan Starchenko
`
`
`
` J. Travis Underwood
`GILLAM & SMITH LLP
`TX State Bar No. 24102587
`102 N. College, Suite 800
`Tyler, Texas 75702
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`travis@gillamsmithlaw.com
`
`James R. Batchelder (pro hac vice pending)
`Shong Yin (pro hac vice pending)
`Stepan Starchenko
`ROPES & GRAY LLP
`1900 University Avenue
`East Palo Alto, CA 94303-2284
`Tel: 650-617-4000
`Fax: 650-617-4090
`James.Batchelder@ropesgray.com
`
`Kevin Post (pro hac vice)
`Josef B. Schenker
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Telephone: (212) 596-9000
`Facsimile: (212) 596-9090
`Kevin.post@ropesgray.com
`
`Allen S. Cross (pro hac vice)
`Taylor J. Lawrence (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, N.W.
`Washington, DC 20006
`Telephone: (202) 508-4600
`Facsimile: (202) 508-4650
`Allen.Cross@ropesgray.com
`Taylor.lawrence@ropesgray.com
`
`2
`
`
`
`
`
`
`
`
`
`
`
`
`Attorneys for Defendant,
`Attorneys for Defendant,
`APPLE INC.
`APPLEINC.
`
`
`
`
`
`
`
`
`3
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this document is being served through CM/ECF on
`
`September 6, 2022.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Brett Cooper
`Brett Cooper
`
`
`
`
`
`
`
`
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
