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13-07-01 Declaration in Support of Skyhook Motion to Compel

13-07-01 Declaration in Support of Skyhook Motion to Compel

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Published by Florian Mueller
July 1, 2023 declaration (and exhibits) in support of Skyhook's motion to compel in its patent infringement case against Google in the District of Massachusetts (case no. 10-cv-11571)
July 1, 2023 declaration (and exhibits) in support of Skyhook's motion to compel in its patent infringement case against Google in the District of Massachusetts (case no. 10-cv-11571)

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Categories:Types, Business/Law
Published by: Florian Mueller on Jul 02, 2013
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09/06/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MASSACHUSETTSSKYHOOK WIRELESS, INC.,
Plaintiff,v.
GOOGLE INC.
,Defendant.))))))))))))))Civil Action No. 1:10-cv-11571-RWZandCivil Action No. 1:13-cv-10153-RWZ
AFFIDAVIT OF AZRA M. HADZIMEHMEDOVIC IN SUPPORT OF SKYHOOK WIRELESS, INC.’S MOTION TO COMPEL GOOGLE INC. TO PRODUCE MR.PATRICK BRADY FOR A DEPOSITION AND TO PRODUCE CERTAINDOCUMENTS RESPONSIVE TO SKYHOOK’S DOCUMENT REQUESTS
Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 1 of 7
 
2I, Azra M. Hadzimehmedovic, declare as follows:1.
 
I am an attorney at the law firm of Tensegrity Law Group LLP, counsel of recordfor Skyhook Wireless, Inc. (“Skyhook”) in the above-captioned matter. I am an attorney in goodstanding licensed to practice in the State of California and the District of Columbia and admittedto practice before this Court
 pro hac vice
in the above-captioned matter. I submit thisdeclaration in support of Skyhook’s Motion to Compel Google Inc. To Produce Mr. Patrick Brady for a Deposition and To Produce Certain Documents Responsive to Skyhook’s DocumentRequests. I am personally familiar with the facts stated herein, and, if called as a witness, couldtestify competently hereto.2.
 
An electronic search of Google’s production, using Patrick Brady as a custodianin the patent infringement case, yields 6648 documents. Mr. Brady’s corporate deposition inSkyhook’s state law case of tortious interference took place on November 4-5, 2011, and hisindividual deposition took place on January 31, 2012. Mr. Brady’s documents, naming him as acustodian in the federal patent infringement case, were produced on March 29, 2012.3.
 
I met and conferred with Google’s counsel Sanjeet Dutta regarding the TracBeamlitigation document request at least twice telephonically and I sent Google’s counsel additionalwritten correspondence on this issue. Skyhook’s request for production of documents Googlehas produced in the
TracBeam
litigation is as follows: All Documents or Things produced or made available for inspection in
TracBeam, L.L.C. v. Google, Inc.
, Case No. 6:13-cv-00093,including without limitation depositions and discovery responses.” Ex. 6 to this Affidavit at 120.In the two telephonic discussions with Mr. Dutta, I explained that Skyhook was particularlyinterested in Google’s depositions and discovery responses from that litigation (as Skyhook’srequest specifically stated in the “including” clause). I explained Skyhook’s belief that the
Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 2 of 7
 
3 burden of turning over those limited, specific documents could not be significant. Litigationteams usually keep these files in folders that are easily accessible and well organized. I alsoexplained the apparent overlap in the accused products between this case and TracBeam’sallegations against Google in that case, both of which involve Google’s location-based productsand services. I also stressed that there may be overlapping damages issues, all of whichwarranted production of corporate and individual depositions of all witnesses. Finally, I alsounderscored Skyhook’s continued concern with Google’s unwillingness to provide completediscovery into the roles of Google’s employees most knowledgeable about particular specificareas identified in Skyhook’s interrogatories and corporate topics. In particular, I reminded Mr.Dutta about Skyhook’s belief that Google has not provided sufficient discovery into itsmarketing, distribution and sales of the accused products, including the identification of personsinvolved in those activities and descriptions of their roles. After Google confirmed that it would produce some depositions from
TracBeam
litigation, I also requested that Google identifyindividuals whose depositions it was not willing to produce to Skyhook and the roles of thoseindividuals. Google refused to provide identity of witnesses whose corporate or individualdepositions Google was withholding and refused to provide discovery responses from the
TracBeam
litigation.4.
 
Attached hereto as Exhibit 1 is a true and correct copy of Google Inc.’s Responsesto Skyhook’s First Set of Interrogatories, dated January 6, 2011.5.
 
Attached hereto as Exhibit 2 is a true and correct copy of email exchange betweenA. Hadzimehmedovic (counsel for Skyhook), T. Lundin (counsel for Google) re: Skyhook v.Google: Lars Fjeldsoe-Nielson’s Responses and Objections and other discovery Issues, dated between June 7, 2013 and June 18, 2013.
Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 3 of 7

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