Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 1 of 18
`
`Exhibit L
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 2 of 18
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
`
`PHILIPS NORTH AMERICA LLC,
`
`Plaintiff,
`
`v.
`
`FITBIT, INC.
`
`Defendant.
`
`
`
`C.A. No.: 1:19-cv-11585-IT
`
`PLAINTIFF PHILIPS NORTH AMERICA LLC’S
`
`SUPPLEMENT OF MAY 28th, 2021 TO CONFIDENTIAL PRIVILEGE LOG
`
`Plaintiff Philips North America LLC (“Philips”), by and through its attorneys, hereby
`
`provide the attached supplemental to the confidential privilege log for the emails of Arie Tol,
`
`attached as Exhibit A, and further prepared in accordance with the Stipulation on Discovery of
`
`April 2, 2020 (Dkt. No. 59-01). This supplement is provided in response to requests by defendant
`
`Fitbit, Inc. as related to entries Nos. 5, 13-17, 42-47, 70, 80, 144, 148-149, 155-156, 176, 179-
`
`180, 216-217, 255, 299-301, 408-431, 433, 437-438, 440-444, 446, and 450-464. Philips
`
`designates the contents of this supplemental privilege log as CONFIDENTIAL pursuant to the
`
`protective order.
`
`
`
`
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 3 of 18
`
`Dated: May 28, 2021
`
`Respectfully Submitted,
`
`
`
`
`
`
`
`/s/ Ruben Rodrigues
`
`Lucas I. Silva (BBO 673,935)
`Ruben J. Rodrigues (BBO 676,573)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (671) 342-4001
`lsilva@foley.com
`
`Eley O. Thompson (pro hac vice to be filed)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
`
`
`Counsel for Plaintiff
`Philips North America LLC
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 4 of 18
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above document was
`
`served on May 28, 2021 on counsel for Defendant via electronic mail.
`
`
`
`
`
`/s/ Ruben J. Rodrigues
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 5 of 18
`Case 1:19-cv-11586—FDS Document 200-12 Filed 06/18/21 Page 5 of 18
`
`
`
`EXHIBIT A
`
`EXHIBIT A
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 6 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 2021 Supplement to Privilege Log re A. T01 E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`TO
`CC
`
`Privilege
`Previous Privilege Description
`Additional Description
`
`
`
`42
`
`' 5/18/2016
`
`Erik Pastink
`
`
`
`
`
`
`
`AC
`
`
`Correspondence reflecting legal
`advice concerning potential
`
`amendments to patent purchase
`
`
`
`
`Reflects legal advice of Dutch
`Patent Attorney Erik Pastink
`with regards to Quy patents and
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 7 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 7 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 202] Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`
`43
`
`5/20/2016
`
`Arie Tol
`
`
`
`David
`Schreiber
`
`
`
`_
`I -
`
`Privilege
`
`Previous Privilege Description
`agreement relating to Quy
`patents.
`
`Additional Description
`amendment to patent puchase
`agreement.
`
`
`
`
`Reflects legal advice of Dutch
`Correspondence reflecting legal
`Patent Attorney Erik Pastink
`advice concerning potential
`
`amendments to patent purchase with regards to Quy patents and
`
`agreement relating to Quy
`amendment to patent puchase
`
`patents.
`agreement.
`
`-
`
`I
`
`46
`
`47
`
`l
`.w-IAC'adviceconcerningpotential
`
`
`6/8/2016
`
`Arie Tol
`
`6/10/2016
`
`Erik Pastink
`
`Arie Tol
`
`AC
`
`
`
`Correspondence reflecting legal
`Reflects legal advice of Dutch
`
`amendments to patent purchase
`
`agreement relating to Quy
`
`patents.
`Reflects legal advice of Dutch
`Correspondence reflecting legal
`Patent Attorney Erik Pastink
`advice concerning potential
`amendments to patent purchase with regards to Quy patent and
`agreement relating to Quy
`amendment to patent puchase
`. atents.
`a ; reement.
`
`PatentAttorneyErikPastink
`
`with regards to Quy patent and
`amendment to patent puchase
`agreement.
`
`
`
`
`
`70
`
`9/30/2016
`
`Jako Eleveld
`
`Arie Tol
`
`Reflects work product relating to
`Correspondence reflecting work
`pre-suit investigation for present
`product relating to pre-suit
`litigation as well as other
`investigation for present
`unrelated ongoing and potential
`litigation as well as other
`litigation matters
`ongoing and potential litigation
`matters.
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 8 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 8 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 202] Supplcmcnt to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`
`Privilege
`
`Previous Privilege Description
`
`Additional Description
`
`11/17/2017
`
`Navin
`Natoewal
`
`
`
`AC / WP Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`present litigation with Fitbit and
`potential litigation with others.
`
`Reflect legal advice of Dutch
`Patent Attorney Erik Pastink
`with regards to patent unrelated
`to those asserted in this matter,
`
`
`as well as material protected by
`work product concerning pre-
`
`suit investigation.
`
`
`
`
`iiili§|
` 144
`
`
`
`
`
`Pierre Hendriks Arie Tol
`
`Gabrielle
`Wellens
`
`AC
`
`12/13/2017
`
`Erik Pastink
`
`156
`
`12/13/2017
`
`Pierre Hendriks
`
`'
`Reflects legal advice of Dutch
`
`'
`'
`Patent Attorney Erik Pastink
`with regards to Quy patents and
`
`amendment to patent puchase
`
`
`agreement.
`
`Reflects legal advice of Dutch
`
`Patent Attorney Erik Pastink
`
`with regards to Quy patents and
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 9 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 9 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 202] Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No.
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`Previous Privilege Description
`
`r esent l-m-gaflenwmd-'
`
`Additional Description
`amendment to patent puchase
`
`_
`
`agreement.
`
`-
`
`-
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 10 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 10 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 202] Supplcmcnt to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`Previous Privilege Description
`
`Additional Description
`
`299
`
`2/12/2019
`
`Arie Tol;
`Edward Blocker
`
`
`
`
`
`AC/ WP
`
`Reflects the legal advice of U.S.
`Correspondence reflecting legal
`advice and work product relating Attorney Ed Blocker with regards
`to pre-suit investigation for the
`to dispute with- and
`potential litigation with
`related work product.
`
`
`
`
`
`
`
`
`
`
`300
`
`301
`
`2/13/2019
`
`Erik Pastink
`
`Arie Tol;
`Edward Blocker
`
`2/13/2019
`
`Erik Pastink
`
`Brint Yorks
`
`Arie Tol
`
`Reflects work product relating to
`pre-suit investigation for the
`potential litigation with-.
`
`Reflects work product relating to
`Correspondence reflecting work
`pre-suit investigation for the
`product relating to pre-suit
`potential litigation with-.
`investigation for the potential
`
`litigation with-.
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`liti ation with
`.
`
`408
`
`7/23/2019
`
`Tol, Arie
`
`Jako Eleveld
`
`_-
`
`I
`
`
`Reflects legal advice of U.S.
`Edward Blocker AC / WP Correspondence reflecting legal
`advice and work product relating Attorney Ed Blocker concerning
`
`to pre-suit investigation for the
`dispute with- and work
`
`potential litigation with-.
`product concerning pre-suit
`investigation for potential
`
`
`
`litigation with
`
`.
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 11 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 11 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 2021 Supplcmcnt to Privilege Log re A. To] E—mails.
`
`Exhibit A
`
` No.
`Privilege
`Previous Privilege Description
`Additional Description
`investigation for potential
`litigation with Lifescan.
`
`Edward Blocker Arie Tol
`
`
`7/24/2019
`
`
`
`
`
`
`Reflects legal advice of US.
`Correspondence reflecting legal
`Attorney Ed. Blocker concerning
`advice relating to pre—suit
`
`
`dispute with-
`investigation for the potential
`
`litigation with
`.
`
`
`
`Reflects legal advice of US.
`Correspondence reflecting legal
`
`advice and work product relating Attorney Ed. Blocker concerning
`
`
`to pre-suit investigation for the
`dispute with- and work
`
`potential litigation with- product concerning pre-suit
`
`investigation for potential
`
`litigation with-.
`
` 414
`Reflects legal advice of U5.
`Correspondence reflecting legal
`7/24/2019
`Edward Blocker
`Jako Eleveld
`Arie Tol
`advice and work product relating
`Attorney Ed. Blocker concerning
`
`
`dispute with- and work
`to pre-suit investigation for the
`
`
`potential litigation with-
`product concerning pre-suit
`
`
`
`investigation for potential
`litigation with
`.
`
`
`Correspondence reflecting legal
`AC / WP
`Edward Blocker Arie Tol
`Jako Eleveld
`Reflects legal advice of US.
`advice and work product relating Attorney Ed. Blocker concerning
`
`to pre-suit investigation for the
`dispute with- and work
`
`potential litigation with-.
`product concerning pre—suit
`
`investigation for potential
`
`
`litigation with
`.
`
`Reflects legal advice of US.
`AC / WP Correspondence reflecting legal
`advice and work product relating Attorney Ed. Blocker concerning
`
`to pre-suit investigation for the
`dispute with- and work
`
`potential litigation with- product concerning pre-suit
`
`investigation for potential
`
`litigation with
`
`
`
`
`7/24/2019
`
`Jako Eleveld
`
`Edward Blocker AC / WP
`
`
`
`Edward Blocker
`
`Jako Eleveld
`
`Arie Tol
`
`7/25/2019
`
`7/25/2019
`
`
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 12 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 12 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 2021 Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`Date
`
`7/26/2019
`
`TO
`
`Edward Blocker Arie Tol
`
`Privilege
`
`7/26/2019
`
`Edward Blocker
`
`7/26/2019
`
`Edward Blocker
`
`7/28/2019
`
`Edward Blocker Arie Tol
`
`7/29/2019
`
`Edward Blocker
`
`
`
`potential litigation witl-. Reflects legal advice of U.S.
`
`
`Previous Privilege Description
`Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`potential litigation with-.
`
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`litigation with-.
`
`Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`potential litigation witl-.
`
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`litigation with-.
`
`Correspondence reflecting work
`product relating to pre—suit
`investigation for the potential
`litigation with
`
`Additional Description
`Reflects legal advice of U.S.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with
`.
`Reflects request for legal advice
`from U.S. Attorney Ed. Blocker
`concerning dispute with-
`and work product concerning
`pre-suit investigation for
`potential litigation with
`Reflects legal advice of U.S.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with-.
`
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with
`Reflects legal advice of U.S.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre—suit
`investigation for potential
`liti ; ation with
`.
`
`Reflects legal advice of U.S.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with
`
`7/29/2019
`
`Edward Blocker
`
`Correspondence reflecting legal
`advice and work product relating
`to pre—suit investigation for the
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 13 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 13 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 2021 Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`Previous Privilege Description
`Privilege
`& / WP Correspondence reflecting work
`product relating to pre—suit
`investigation for the potential
`litigation with
`
`AC/WP Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`potential litigation with-
`
`Additional Description
`Reflects request for legal advice
`from us. Attorney Ed. Blocker
`concerning dispute with-
`and work product concerning
`pre—suit investigation for
`potential litigation with
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with
`.
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`
`litigation with-.
`
`No. Date
`7/29/2019
`
`FROM
`Tol, Arie
`
`CC
`
`TO
`Edward Blocker
`
`
`
`7/29/2019
`
`Edward Blocker Arie Tol
`
`7/30/2019
`
`Edward Blocker
`
`7/31/2019
`
`Edward Blocker Arie Tol
`
`
`
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`
`litigation with —
`Reflects request for legal advice
`from us. Attorney Ed. Blocker
`concerning dispute with-
`
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute witl-.
`
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with-.
`
` Reflects legal advice of US.
`
`potential litigation with-
`
`AC / WP Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`potential litigation witi-.
`
`AC / WP Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`
`427
`
`7/31/2019
`
`Edward Blocker
`
`
`
`7/31/2019
`
`Edward Blocker
`
`7/31/2019
`
`Edward Blocker
`
`
`
`AC
`
`AC
`
`AC
`
`Correspondence reflecting legal
`advice relating to pre—suit
`investigation for the potential
`litigation with
`.
`Correspondence reflecting legal
`advice relating to pre-suit
`investigation for the potential
`liti. tion with
`
`Correspondence reflecting legal
`advice relating to pre-suit
`investigation for the potential
`litigation with
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 14 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 14 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 2021 Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`Date
`
`FROM
`
`TO
`
`CC
`
`No.
`430
`
`8/1/2019
`
`Tol, Arie
`
`Edward Blocker
`
`
`
`Arie Tol
`
`431
`
`8/1/2019
`
`433
`
`8/19/2019
`
`Edward Blocker
`
`
`
`Edward Blocker
`
`10/10/2019
`
`Tol, Arie
`
`Kevin Ecker
`10/10/2019i
`
`438
`
`Arie Tol
`
`440
`
`10/11/2019 -w
`
`AC/WP
`
`Correspondence reflecting legal
`advice and work product
`concerning potential litigation
`with
`
`with-.
` 437
`
`Privilege
`AC
`
`Previous Privilege Description
`Correspondence reflecting legal
`advice relating to pre-suit
`investigation for the potential
`litigation with
`
`AC
`
`AC/WP
`
`Correspondence reflecting legal
`advice relating to pre-suit
`investigation for the potential
`litiation with
`.
`
`Correspondence reflecting legal
`advice and work product relating
`to pre-suit investigation for the
`potential litigation with- .
`
`AC/WP
`
`Correspondence reflecting legal
`advice and work product
`concerning potential litigation
`with-
`
`AC/WP
`
`Correspondence reflecting legal
`advice and work product
`concerning potential litigation
`
`Additional Description
`Reflects request for legal advice
`from US. Attorney Ed. Blocker
`concerning dispute with
`, as well as legal advice
`of US. Attorney Ed Blocker wiht
`regards to same.
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with-
`
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- and work
`product concerning pre-suit
`investigation for potential
`litigation with-; further
`request legal advice from us.
`Attorney Kevin Ecker
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- Reflects
`legal advice of us. Attorney
`Kevin Ecker with regards to
`same; additionally reflects work
`product concerning pre-suit
`investigation for potential
`litigation with
`.
`Reflects legal advice of us.
`Attorney Ed. Blocker concerning
`dispute with-; Reflects
`legal advice of US. Attorney
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 15 of 18
`Case 1:19—cv-11586-FDS Document 200-12 Filed 06/18/21 Page 15 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 202] Supplement to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`Previous Privilege Description
`
`
`
`Additional Description
`Kevin Ecker with regards to
`
`same; additionally reflects work
`
`product concerning pre—suit
`
`investigation for potential
`|iti_ation with
`
`441
`
`
`
`
`
`
`
`
`
`
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`advice and work product
`
`
`concerning potential litigation
`dispute with- Reflects
`Wm.-
`legal advice of U5. Attorney
`
`Kevin Ecker with regards to
`same; additionally reflects work
`
`product concerning pre-suit
`
`
`investigation for potential
`
`
`
`JakoEleveld E!AC/WPCorrespondencereflectinglegal
`
`
`443
`
`
`10/14/2019
`
`10/11/2019
`
`Tol, Arie
`
`Jako Eleveld
`
`Reflects legal advice of US.
`Attorney Ed. Blocker concerning
`dispute with- Reflects
`legal advice of US. Attorney
`Kevin Ecker with regards to
`same; additionally reflects work
`
`product concerning pre-suit
`
`investigation for potential
`
`litigation wit
`
`AC / WP Correspondence reflecting legal
`advice and work product
`concerning potential litigation
`with--
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 16 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 16 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 202] Supplcmcnt to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`Previous Privilege Description
`
`Additional Description
`
`
`iil: il
`_
`
`
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`litigation with-
`
`
`
`450
`
`12/9/2019
`
`Tol, Arie
`
`451
`
`12/9/2019
`
`Kevin Ecker
`
`I
`I
`I _ _
`I
`
`
`
`I
`I
`I
`I
`
`
`Reflects legal advice of U5.
`
`Attorney Ed. Blocker concerning
`dispute with- Reflects
`
`legal advice of US. Attorney
`
`Kevin Ecker with regards to
`same; additionally reflects work
`product concerning pre-suit
`investigation for potential
`litigation with
`Reflects legal advice of US.
`Attorney Kevin Ecker with
`regards to same; additionally
`reflects work product
`concerning pre-suit investigation
`for potential litigation with
`
`
`
`
`
`
`
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`litigation with-
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 17 of 18
`Case 1:19—cv-11586-FDS Document 200-12 Filed 06/18/21 Page 17 of 18
`
`Philips v. Fitbit (D. Mass) - May 28, 202] Supplcmcnt to Privilege Log re A. To] E-mails.
`
`Exhibit A
`
`No. Date
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`Previous Privilege Description
`
`Additional Description
`
`
`
`
`
`
`
`458
`
`12/12/2019
`
` Reflects legal advice of U.S.
`
`AC—I—WP Correspondence reflecting legal
`advice and work product relating
`Attorney Kevin Ecker with
`regards to dispute with-
`to pre-suit investigation for the
`
`potential litigation with
`
`
`
`
`
`12/13/2019 Kevin Ecker
`
`460
`
`
`
`AC—l—WP
`
`
`Correspondence reflecting legal
`advice and work product relating
`
`to pre-suit investigation for the
`potential litigation with
`
`Reflects legal advice of U.S.
`Attorney Kevin Ecker with
`regards to dispute with-
`
`
`
`459
`
`12/13/2019
`
`Tol, Arie
`
`Kevin Ecker
`
`A_C WP
`
`
`Reflects request for legal advice
`of U.S. Attorney Kevin Ecker with
`regards to dispute with-
`
`
`
`EKeVinEeker
`
`
`
`
`

`

`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 18 of 18
`Case 1:19-cv-11586-FDS Document 200-12 Filed 06/18/21 Page 18 of 18
`
`Philips v. Fitbit (D. Mass) — May 28, 2021 Supplement to Privilcgc Log re A. To] E-mails.
`
`Exhibit A
`
`No.
`
`Date
`
`FROM
`
`TO
`
`CC
`
`Privilege
`
`12/17/2019 -w
`12/17/2019w-
`
`AC/WP
`
`regards to dispute with-
`
`Previous Privilege Description
`Correspondence reflecting work
`product relating to pre-suit
`investigation for the potential
`litigation with
`Correspondence reflecting legal
`advice and work product relating
`to pre—suit investigation for the
`totential liti _ation with
`
`Additional Description
`Reflects request for legal advice
`of US. Attorney Kevin Ecker with
`regards to dispute with l.-
`
`Reflects legal advice of US.
`Attorney Kevin Ecker with
`
`