Opposer Gface GmbH (“Gface” or “Opposer”) by and through its attorneys, submits this reply memorandum in support of its motion to compel Applicant iConnectUS LLC’s (“iConnectUS” or “Applicant”) Initial Disclosures and responses to Opposer’s First Set of Interrogatories and First Request for Documents (“Opposer’s Discovery Requests”) filed on March 25, 2013.

On June 7, 2013 Mr. Branthover received an email from Mr. Barak Vaughn, an attorney with Gersh & Derby LLP, advising Mr. Bramthover that Mr. Vaughn’s firm is in the process of being retained by the Applicant.

AppIicant’s argument that Opposer’s attorney “left the situation in an ambiguous status because Applicant had no way of knowing What was discussed between Messrs. Branthover and Mr. Vaughn” is absurd on its face because Mr. Fetyko was sent a copy of the email from Mr. Vaughn dated June 26, 2013 in response to Opposer’s attorney’s email of the same date making it clear that Mr. Vaughn was not representing Applicant and Opposer was seeking responses to its discovery requests that were past due.

assert objections other than attorney client privilege and require Applicants to respond to Opposer’s Discovery Requests and Initial Disclosures in fifteen (15) days.