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Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SKYHOOK WIRELESS, INC., Plaintiff, v. GOOGLE INC., Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 1:10-cv-11571-RWZ and Civil 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 CERTAIN DOCUMENTS RESPONSIVE TO SKYHOOKS DOCUMENT REQUESTS

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I, Azra M. Hadzimehmedovic, declare as follows: 1. I am an attorney at the law firm of Tensegrity Law Group LLP, counsel of record

for Skyhook Wireless, Inc. (Skyhook) in the above-captioned matter. I am an attorney in good standing licensed to practice in the State of California and the District of Columbia and admitted to practice before this Court pro hac vice in the above-captioned matter. I submit this

declaration in support of Skyhooks Motion to Compel Google Inc. To Produce Mr. Patrick Brady for a Deposition and To Produce Certain Documents Responsive to Skyhooks Document Requests. I am personally familiar with the facts stated herein, and, if called as a witness, could testify competently hereto. 2. An electronic search of Googles production, using Patrick Brady as a custodian

in the patent infringement case, yields 6648 documents. Mr. Bradys corporate deposition in Skyhooks state law case of tortious interference took place on November 4-5, 2011, and his individual deposition took place on January 31, 2012. Mr. Bradys documents, naming him as a custodian in the federal patent infringement case, were produced on March 29, 2012. 3. I met and conferred with Googles counsel Sanjeet Dutta regarding the TracBeam

litigation document request at least twice telephonically and I sent Googles counsel additional written correspondence on this issue. Skyhooks request for production of documents Google has 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 particularly interested in Googles depositions and discovery responses from that litigation (as Skyhooks request specifically stated in the including clause). I explained Skyhooks belief that the 2

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burden of turning over those limited, specific documents could not be significant. Litigation teams usually keep these files in folders that are easily accessible and well organized. I also explained the apparent overlap in the accused products between this case and TracBeams allegations against Google in that case, both of which involve Googles location-based products and services. I also stressed that there may be overlapping damages issues, all of which

warranted production of corporate and individual depositions of all witnesses. Finally, I also underscored Skyhooks continued concern with Googles unwillingness to provide complete discovery into the roles of Googles employees most knowledgeable about particular specific areas identified in Skyhooks interrogatories and corporate topics. In particular, I reminded Mr. Dutta about Skyhooks belief that Google has not provided sufficient discovery into its marketing, distribution and sales of the accused products, including the identification of persons involved 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 identify individuals whose depositions it was not willing to produce to Skyhook and the roles of those individuals. Google refused to provide identity of witnesses whose corporate or individual depositions 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 Responses

to Skyhooks First Set of Interrogatories, dated January 6, 2011. 5. Attached hereto as Exhibit 2 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook), T. Lundin (counsel for Google) re: Skyhook v. Google: Lars Fjeldsoe-Nielsons Responses and Objections and other discovery Issues, dated between June 7, 2013 and June 18, 2013.

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6.

Attached hereto as Exhibit 3 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook) and S. Dutta and T. Lundin (counsel for Google) re: Skyhook v. Google: Various Discovery Issues, dated between June 18, 2013 and June 24, 2013 7. Attached hereto as Exhibit 4 is a true and correct copy of an email from A.

Hadzimehmedovic to W. Abrams re: Skyhook/Google: Brin Deposition Notice, dated February 6, 2013. 8. Attached hereto as Exhibit 5 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook), W. Abrams and T. Lundin (counsel for Google) re: Skyhook v. Google Nos. 1:10-cv-11571-RWZ, dated between February 15, 2013 and March 6, 2013. 9. Attached hereto as Exhibit 6 is a true and correct copy of Googles Objections and

Responses to Skyhooks Third Set of Requests for Production (Nos. 176-316), dated May 2, 2013. 10. Attached hereto as Exhibit 7 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook) and T. Lundin and S. Dutta (counsel for Google) re: Skyhook v. Google: ESI and Mr. Brins Documents, dated between May 24, 2013 and June 3, 2013. 11. Attached hereto as Exhibit 8 is a true and correct copy of a screenshot of a

photograph of Sergey Brin with Steve Jobs at the 2008 Macworld Conference & Expo (http://www.zimbio.com/photos/Sergey+Brin/Steve+Jobs+Delivers+Keynote+Speech+Macworl d/SxICtx3779p). 12. Attached hereto as Exhibit 9 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook) and W. Abrams and T. Lundin (counsel for Google)

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re: Skyhook v. Google Nos. 1:10-cv-11571-RWZ, dated between February 15, 2013 and March 6, 2013. 13. Attached hereto as Exhibit 10 is a true and correct copy of email exchange

between S. Dutta (counsel for Google) and A. Hadzimehmedovic (counsel for Skyhook) re: Skyhook v. Google: ESI Terms, dated between June 18, 2013 and June 27, 2013. I declare under penalty of perjury that the foregoing is true and correct, and that this affidavit is executed on July 1, 2013 at McLean, VA.

Dated: July 1, 2013

Respectfully submitted: /s/ Azra M. Hadzimehmedovic Matthew D. Powers (pro hac vice) Steven S. Cherensky (pro hac vice) Paul T. Ehrlich (pro hac vice) William P. Nelson (pro hac vice) Azra M. Hadzimehmedovic (pro hac vice) Aaron M. Nathan (pro hac vice) TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 Phone: (650) 802-6000 Fax: (650) 802-6001 Email: matthew.powers@tensegritylawgroup.com steven.cherensky@tensegritylawgroup.com paul.ehrlich@tensegritylawgroup.com william.nelson@tensegritylawgroup.com azra@tensegritylawgroup.com aaron.nathan@tensegritylawgroup.com Thomas F. Maffei (BBO 313220) Douglas R. Tillberg (BBO 661573) GRIESINGER, TIGHE & MAFFEI, LLP 176 Federal Street Boston, Massachusetts 02110 (617) 542-9900

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tmaffei@gtmllp.com dtillberg@gtmllp.com Attorneys for Skyhook Wireless, Inc.

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CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing to be served via the ECF system of the District of Massachusetts this 1st day of July, 2013, on all counsel of record. /s/ Azra M. Hadzimehmedovic Azra M. Hadzimehmedovic

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EXHIBIT 1

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SKYHOOK WIRELESS, INC., Plaintiff and Counterclaim-Defendant, v. GOOGLE INC., Defendant and Counterclaimant. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:10-cv-11571-RWZ

GOOGLE INC.S RESPONSES TO SKYHOOK, INCS FIRST SET OF INTERROGATORIES Pursuant to Federal Rule of Civil Procedure 33, Defendant Google Inc. (Google) responds and objects to Plaintiff Skyhook, Inc.s (Skyhook) First Set of Interrogatories (Interrogatories) as follows: GENERAL OBJECTIONS 1. These responses are made solely for the purpose of this action. Each

response is subject to all objections as to competence, relevance, materiality, propriety and admissibility, and to any and all other objections on any grounds that would require the exclusion of any statements contained in these responses if such interrogatory response were asked of, or statements contained in the response were made by, a witness present and testifying in court, all of which objections and grounds are expressly reserved and may be interposed at the time of trial. 2. Discovery in this matter is ongoing. Accordingly, the following responses

are given without prejudice to Googles right to produce evidence of any subsequently discovered fact or facts that it may later recall or discover. Google further reserves the right to

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change, amend, or supplement any or all of the matters contained in these responses as additional facts are ascertained, analyses are made, research is completed, and contentions are made. 3. Objections to the Interrogatories are made on an individual basis below.

Googles response to each interrogatory is submitted without prejudice to, and without in any way waiving, the General Objections listed here, but not expressly set forth in that response. The assertion of any objection to an interrogatory in any response below is neither intended as, nor shall in any way be deemed, a waiver of Googles right to assert that or any other objection at a later date. 4. No incidental or implied admissions are intended by these responses. That

Google has answered or objected to any interrogatory should not be taken as an admission that Google accepts or admits the existence of any facts set forth or assumed by such interrogatory. That Google has answered part or all of any interrogatory is not intended to be, and shall not be construed to be, a waiver by Google of any part of any objection to any interrogatory. 5. Google objects to the Interrogatories (which include the Definitions and

Instructions that proceed them) and to each Interrogatory to the extent that they are vague, ambiguous, overly broad, unduly burdensome, or oppressive, or seek information that is neither relevant to the issues in this case nor reasonably likely to lead to the discovery of admissible evidence. 6. Google objects to the Interrogatories and to each Interrogatory on the

ground and to the extent that they purport to seek information protected by the work-product doctrine, attorney-client privilege or any other privilege or restriction on discovery. To the extent that any interrogatory is so vague or ambiguous that it may be interpreted to call for privileged or protected information, Google interprets each such request not to call for any privileged or protected information. 7. Google objects to the Interrogatories and to each Interrogatory to the

extent they seek information in the possession, custody, or control of individuals or entities other

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than Google on the grounds they are unduly burdensome and oppressive, and such information is equally available to Skyhook. 8. Google objects to the Interrogatories and to each Interrogatory to the

extent that they seek information already within Skyhooks possession, custody, or control on the grounds that they are duplicative, unduly burdensome, and oppressive, and such information is equally available to Skyhook. 9. Google objects to the Interrogatories and to each Interrogatory to the

extent they purport to impose on Google obligations that differ from or exceed those required by the Federal Rules of Civil Procedure, Local Rules, or the Courts orders. Google will not comply with any purported obligation not imposed by law. 10. Google objects to the Interrogatories and to each Interrogatory to the

extent they contain discrete subparts in violation of LR 26.1(c). Skyhooks Interrogatories contains no fewer than 4 interrogatories and discrete subparts. 11. Google objects to the Interrogatories and to each Interrogatory to the

extent they call for information related to Googles business activities outside the United States. Skyhooks rights under the patents-in-suit, if any, are limited to the United States. 12. Google objects to the Interrogatories and to each Interrogatory to the

extent they incorporate or reference Skyhooks overbroad, vague and ambiguous definition of Google Location and Google Wi-Fi Location Database. 13. Google objects to the Interrogatories and to each Interrogatory to the

extent they seek the disclosure of information that constitutes Googles trade secrets or confidential information. Information constituting Googles trade secrets or confidential information will be produced only after entry of a protective order satisfactory to Google and only if directly relevant to disputed allegations or contentions in the pending action. 14. Google objects to the Interrogatories and to each Interrogatory to the

extent they purport to seek discovery regarding claims not identified or asserted by Skyhook. Google will respond only with regard to the asserted claims.

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15.

The foregoing general objections shall be applicable to and included in

Googles responses to each and every one of Skyhooks interrogatories, whether or not specifically raised below. The objections set forth below are not a waiver, in whole or in part, of any of the foregoing general objections. OBJECTIONS AND RESPONSES TO SPECIFIC INTERROGATORIES Subject to the foregoing General Objections, and pursuant to the agreement of the parties, Google responds to each separate interrogatory as follows: INTERROGATORY NO. 1: Identify the five individuals, at least three of whom are present employees, whom You believe to be the most knowledgeable regarding each of the following topics: (a) the research and development of Google Location; (b) the structure, operation, and function of Google Location; and (c) sales and marketing in the United States of Google Location, and describe each individual's knowledge and the bases for that knowledge. RESPONSE TO INTERROGATORY NO. 1: Google objects to this interrogatory as vague and ambiguous, particularly with regard to the phrases research and development of Google Location, and sales and marketing in the United States of Google Location. Google further objects to this interrogatory to the extent it contains multiple subparts in violation of LR 26.1(c). Google objects to this request to the extent that it calls for production of confidential or proprietary information, trade secrets, future marketing, and business plans. Google objects to this interrogatory to the extent it purports to require Google to speculate. Google objects to this interrogatory to the extent it is redundant of Googles initial disclosures.

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Google objects to this interrogatory to the extent it calls for the indentification of an arbitrary and irrelevant number of individuals. Google will identify individuals who are reasonably likely to have significant, relevant information. Google objects to this interrogatory as premature and unduly burdensome. At this state of the case, it is impossible to identify with precision persons who do or do not have information relevant to the parties claims and defenses. Skyhook has not identified the specific accused insturmentality, identified the asserted claims, nor articulated its damages theory, and has yet to produce even a single document. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(a) (research and development witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding the research and development of Google Location: Zhengrong Ji, knowledge of research and development of Google Location, based on personal knowledge derived from work on Google Location; Arunesh Mishra, knowledge of research and development of Google Location, based on personal knowledge derived from work on Google Location; Phil Gossett, knowledge of research and development of Google Location, based on personal knowledge derived from work on Google Location; and Tsuwei Chen, knowledge of research and development of Google Location, based on personal knowledge derived from work on Google Location. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(b) (structure, operation, and function witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding the structure, operation, and function of Google Location:

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Zhengrong Ji, knowledge of the structure, operation, and function of Google Location, based on personal knowledge derived from work on Google Location;

Arunesh Mishra, knowledge of the structure, operation, and function of Google Location, based on personal knowledge derived from work on Google Location;

Ken Norton, knowledge of the structure, operation, and function of Google Location, based on personal knowledge derived from work on Google Location;

Tsuwei Chen, knowledge of the structure, operation, and function of Google Location, based on personal knowledge derived from work on Google Location; and

Marc Stogaitis, knowledge of the structure, operation, and function of Google Location, based on personal knowledge derived from work on Google Location.

Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(c) (sales and marketing witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding sales and marketing in the United States of Google Location: Patrick Brady, knowledge of sales and marketing in the United States of Google Location, based on personal knowledge derived from work on Google Location; and Ken Norton, knowledge of sales and marketing in the United States of Google Location, based on personal knowledge derived from work on Google Location. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. INTERROGATORY NO. 2: Set Forth The Complete Basis For Your allegations that You have not willfully infringed the Patents-in-Suit, including those allegations made in the Answer.

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RESPONSE TO INTERROGATORY NO. 2: Google objects to this interrogatory as vague and ambiguous. Google objects to this interrogatory to the extent that it calls for information protected by the attorney-client and/or work product privileges. Gooogle objects to this interrogatory as premature. To date, Skyhook has not disclosed any basis whatsoever for any claim that Google has willfully infringed any of the Patents-in-Suit. Subject to its objections, and without waiving any objections, Google states that Skyhook has not identifed any evidence that Skyhook put Google on notice of any alleged infringement.

Dated: January 6, 2011

Google Inc., By its attorneys, /s/ Susan Baker Manning Jonathan M. Albano, BBO #013850 jonathan.albano@bingham.com BINGHAM McCUTCHEN LLP One Federal Street Boston, MA 02110-1726, U.S.A. 617.951.8000

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William F. Abrams (admitted pro hac vice) william.abrams@bingham.com BINGHAM McCUTCHEN LLP 1900 University Avenue East Palo Alto, CA 94303-2223 650.849.4400 Robert C. Bertin (admitted pro hac vice) robert.bertin@bingham.com Susan Baker Manning (admitted pro hac vice) susan.manning@bingham.com BINGHAM McCUTCHEN LLP 2020 K Street, NW Washington, DC 20006-1806 202.373.6000

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VERIFICATION OF INTERROGATORY RESPONSES

I, John LaBane, declare under penalty of perjury that I am Litigation Counsel for Google Inc. and am authorized to make this Verification on its behalf. I have read Google Inc.'s Responses To Skyhook Inc.'s First Set Oflnterrogatories dated January 6, 2011, know its . contents, and, to the best of my knowledge, information, and belief, formed after a reasonable inquiry, the response is true and accurate as of the time submitted on January 6, 2011. Signed this 6th day of January, 2011 in Mountain View, CA.

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CERTIFICATE OF SERVICE I hereby certify that on January 6, 2011, I served the forgoing Responses To Skyhook Inc.s First Set Of Interrogatories via email to the following:

Thomas F. Maffei Griesinger, Tighe & Maffei, LLP Suite 400 176 Federal Street Boston, MA 02110 Telephone: 617-542-9900 Facsimile: 617-542-0900 tmaffei@gtmllp.com

John C. Hueston Irell & Manella 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067-4276 Telephone: 310-277-1010 jhueston@irell.com

Douglas R. Tillberg Griesinger, Tighe & Maffei, LLP Suite 400 176 Federal Street Boston, MA 02110 Telephone: 617-542-9900 Facsimile: 617-542-0900 dtillberg@gtmllp.com Morgan Chu Irell & Manella, LLP 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067 Telephone: 310-277-1010 mchu@irell.com

Samuel K. Lu Irell & Manella LLP 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067 Telephone: 310-277-1010 slu@irell.com

/s/ Audrey Lo audrey.lo@bingham.com

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EXHIBIT 2

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Tuesday, J une 1 8, 2 013 3 :32:53 P M P acic Daylight Time

Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues Date: Tuesday, June 18, 2013 3:32:05 PM Pacific Daylight Time From: To: Lundin, Tom Azra Hadzimehmedovic, dl.zzmgoogleskyhookext@bingham.com, Google/Skyhook K&S, Abrams, William, Pada, Roxane Skyhook_Service

Azra

CC:

Thanks for your message. I am in depositions tomorrow, but Sanj is available any time during the range that you suggest. Please send a meeting notice to Sanj with dial-in information. Thanks. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Tuesday, June 18, 2013 3:15 PM To: Lundin, Tom; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service Subject: Re: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Tom, I have tried to reschedule my other commitments so that we could do a call at 4 PM today, as you proposed, but I was not able to do so. I am available tomorrow between 4 and 6 PM Eastern. Please let me know if that works. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

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From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Tuesday, June 18, 2013 10:58 AM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Azra Further to my below message, please note the following: Depositions 1. In your June 13 email message, Skyhook requested the deposition of Mr. Zelinka on July 10. Google accepts that date. Mr. Zelinka will be made available at King & Spaldings Redwood Shores offices. 2. In the same message, you confirmed that Google would not be making Messrs. Stogaitis or Williams available on the dates (June 17 and 19, respectively) noticed in Skyhooks individual deposition notices served May 23. That is correct. Google is working to determine dates on which Messrs. Stogaitis and Williams will be made available. Further, with respect to Skyhooks individual deposition notices, Google is requesting a meet and confer to discuss the depositions of Messrs. Brady and Lee, each of whom was deposed in the State case Mr. Brady over multiple days. Please be prepared to discuss what testimony Skyhook is seeking from these persons beyond the testimony provided in the State case. Absent some compelling need that Skyhook can show, Google believes that it is unduly burdensome for Skyhook to attempt to require these persons to appear for deposition again in this action. 3. Google is confirming availability to take the Skyhook depositions on the dates that you offered, with the exeption of Mr. Morgan, and we expect to be able to let you know in the next day or so. With respect to Mr. Morgan, Skyhooks offered date is unacceptable because it is a day before the close of claim construction fact discovery. Mr. Morgan is an inventor on asserted patents for which the parties need to conduct claim construction fact discovery. Further, Mr. Morgan is a founder of Skyhook and former CEO, with essential knowledge about all of the patents in suit. In view of the claim construction fact discovery deadline, Skyhook needs to make Mr. Morgan available in July. Bain/Agarwal Subpoenas We have explained why Google is seeking information such as documents concerning companies that compete with Skyhook" and "documents defining or describing the market in which Skyhook products compete, and the market share of Skyhook or its competitors from Bain and Mr. Agarwal because Bain is an investor in Skyhook and Mr. Agarwal is a Bain employee and Skyhook board member. As I explained to you in my previous message, these facts make Bain and Mr. Agarwal markedly distinct from other third parties, such as Apple, which is the only third party to have responded to a Google document subpoena in this matter. As to how [Google] would expect a third party to search for and find documents on these and the other requests, we would expect Bain and Mr. Agarwal to search hard copy files, and shared sources and emails for documents responsive to the requests.
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Skyhooks Third RFPs During our previous two meet-and-confers on Skyhooks Third RFPs, you requested that Google consider various proposals, confirm various positions, and provide you with final responses/positions. Certain of those final responses/positions are as follows: RFP 226: Google produced additional documents last week. RFP 227: Google has confimed that it has no responsive documents. RFP 203: We believe that Googles ESI search terms would have captured any responsive documents, consistent with Googles response. You stated that Googles response was inconsistent with its response to RFP 27 and requested that Google supplement RFP 27 to be consistent. Google will do so. RFP 210: We understand that there were two remaining issues: First, based on Skyhooks definition of Google Location, whether Google has produced/will produce documents concerning Google phones, laptops, and tablets. Google will produce responsive documents for devices that Google directly sells that use Google Location Services. Second, with respect to this and other RFPs, whether Google would reconsider its objection to producing worldwide data. Google maintains its objection to producing worldwide data. RFPs 254/255: Google has confirmed that there are no non-privileged documents responsive to these requests. RFP 303: We understand that in this request, Skyhook seeks all discovery in the Tracbeam litigation. Googles position is unchanged that this request is overbroad, unduly burdensome, seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action, including without limitation because the asserted patents in the Tracbeam action are not the same as the asserted Skyhook patents in this action. Nevertheless, Google is willing to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. To the extent that Skyhook seeks documents, discovery responses, or deposition transcripts beyond that scope, please explain what exactly Skyhook is seeking and why it allegedly is relevant. RFP 305: Google believes that it has produced any responsive documents. RFP 307: Google has confimed that it does not have responsive documents in its possession, custody, or control. RFP 311: Google maintains its objection that this request seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action. Further, Google does not believe that it has any information, beyond publicly available third party reporting, concerning Googles market share for mobile advertising. Nevertheless, Google is confirming again and agrees to produce any such documents that exist. RFP 312: Following the parties meet-and-confer, and Skyhooks attempt to explain the relevant of this request, Google maintains its objection that this request seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action. RFPs 313/314: Google has confirmed that it does not track or maintain documents and information sought in the ordinary course of business. Google does not have responsive documents in its possession, custody, or control. RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist. ESI issues
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1. Skyhooks Proposed New Search Terms (Skyhook II patents) and Proposed Amended Search Terms (amending initial federal terms): As I have explained in our previous conferrals, Google has been analyzing Skyhooks proposals. In each instance, Google believes that Skyhooks proposals result in an overly broad and unduly burdensome scope more so for Skyhooks proposed new terms than for Skyhooks proposed amended terms. Google is formulating a counter proposal in each instance that Google believes will result in a reasonable scope. Google believes that it will be able to provide such a proposal in the next several days. 2. Skyhooks June 3 proposal concerning Sergey Brins documents: We previously advised you that, although Skyhook has made no showing of any basis to search Mr. Brins documents, Google searched Mr. Brins emails for Skyhook, Ted Morgan, and MacWorld and there were no relevant documents. In response, you proposed several additional terms that Skyhook contended Google should use to search Mr. Brins documents, including (Mike or Michael) w/3 Shean and (Ted or Edward) w/3 Morgan. Google has now searched Mr. Brins emails for the following: Skyhook, Morgan, Shean, and MacWorld each of which is broader than the searches Skyhook requested. No relevant documents resulted from these searches. Google maintains its objection to any further searching of Mr. Brins documents. Please let us know when you are available to confer concerning the responses to the Bain and Agarwal subpoenas, including dates of production. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com
From: Lundin, Tom Sent: Monday, June 17, 2013 2:04 PM To: Azra Hadzimehmedovic; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Azra Thanks for your message. In the interim between my message and your response, the schedule today became filled up, so we are not available this afternoon. We propose tomorrow afternoon at the same time (4 pm Eastern). Please let us know if that works for you; if so, Ill circulate a calendar notice with dial-in information. Further, I will respond in writing to some of your points, and provide you final positions on some of the outstanding issues and confirm some dates, later this evening, in advance of the meet and confer.
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Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Friday, June 14, 2013 4:33 PM To: Lundin, Tom; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service Subject: Re: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Tom, We expect to complete Mr. Fjeldsoe-Nielsen's production and update privilege and redaction log entries that involve him by Monday, June 17. Thus, Mr. Fjeldsoe-Nielsen's deposition can and will proceed on July 2 unless the Court responds to our joint request for a hearing on July 2. As we already said, we will give you an alternative date if and when the Court accepts the parties' proposed date. With respect to the remainder of the Jed Rice privileged or redacted documents, I have told Google weeks ago that we are working to complete that re-review by July 1. Google had no objection to that at the time, and you cannot now fabricate new deadlines and threaten a motion to compel this Monday if we do not complete that review by Monday. Further, Google's rhetoric and requests stand in sharp contrast with what it itself is agreeing to do in this case, which makes them all that much more unreasonable. I have asked you many times to confirm that you will complete the relevant productions two weeks before the depositionsas we are doing with Mr. Fjeldsoe-Nielsenbut you have not so agreed. We have met and conferred on Skyhook's Third Set of Document Requests over several sessions, and you were not prepared at the last telephonic meet and confer to give us Google's final positions on those requests. You did not have Google's response regarding search terms Skyhook proposed nor about Skyhook's request for Mr. Brin's documents. You did not have any deposition dates to offer but one. Please be prepared to discuss each of these issues on Monday and provide deposition dates for the remaining deponents, or provide a written response in advance. I am available at 4 PM Eastern on Monday. If that time works, I will circulate a meeting invitation and a dial-in. We can discuss Bain Capital's responses to Google's subpoena at the same time. On that issue, you are are misstating our discussion. I have asked you to explain why Google is seeking information from third parties that is burdensome and overbroad, such as "documents concerning companies that compete with Skyhook" or "documents defining or describing the market in which Skyhook products compete, and the market share of Skyhook or its competitors." And then I pointed out that Google has served the very same subpoena on all third parties, and it appears no third party has given you production on your burdensome and overbroad requests such as the ones I pointed to. Please be prepared to discuss how exactly you would expect a third party to search for and find documents on these and the other requests on which Bain Capital has offered at least three times so far to confer, but Google was not prepared to do so. Finally, we are assuming that the dates for Mr. Zelinka's and Skyhook's proposed depositions work for Google (given that they are scheduled for dates Mr. Zelinka and Google's counsel are available), but to avoid any doubt, please

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confirm by Monday that you have accepted all proposed dates. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Thursday, June 13, 2013 11:53 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections

Azra Im writing to follow up on the below message and Googles multiple, longstanding requests that Skyhook produce documents improperly withheld under a claim of privilege and produce new privilege logs for any documents Skyhook continues to withhold. First, below, Google agreed to depose Mr. Fjeldsoe-Nielsen on July 2 on the conditions that by June 17, (1) Mr. Fjeldsoe-Nielsen produces documents; and (2) Skyhook completes its rereview of its privilege and redaction logs and produces documents and a new log with sufficient information. We have not received any response confirming that Skyhook will make those productions by June 17. In addition, the parties requested a status conference/hearing with the Court on July 2, on the condition that Skyhook provide alternate dates close to July 2 for Mr. Fjeldsoe-Nielsens deposition, if the Court agrees to hold the status conference/hearing on that date. Skyhook has not provided those alternate dates. Please provide alternate dates for Mr. Fjeldsoe-Nielsen, in the event that the Court agrees to July 2, and please confirm that Mr. Fjeldsoe-Nielsens documents will be produced by June 17. Second, with respect to the privilege log and purportedly privileged documents, Google has been requesting since April 9 that Skyhook produce documents withheld under a claim of privilege relating to Jed Rice. The parties exchanged multiple messages and discussed the issue in more than one meet-and-confer. By May 16, Skyhook had promised to re-review all
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documents withheld on a claim of privilege relating to Mr. Rice, but would not commit to a date certain by which it would produce previously withheld documents or provide new privilege and redaction logs. Google has made plain, multiple times, and most recently below, that the privileged documents must be produced sufficiently in advance of depositions beginning to allow for meaningful review. Skyhook must confirm by tomorrow, June 14, that it will produce formerly withheld documents and new privilege and redaction logs on June 17, or Google will be forced to file a motion to compel on Monday. Let me know if you have any questions. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

From: Lundin, Tom Sent: Saturday, June 08, 2013 5:10 PM To: Azra Hadzimehmedovic; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections

Azra Thanks for your message. We remain available to depose Mr. Fjeldsoe-Nielsen on July 2, but that date will work only if by June 17 (1) Mr. Fjeldsoe-Nielsen produces documents; and (2) Skyhook completes its re-review of its privilege and redaction logs, which Google has been requesting since at least April 9, for at least those entries involving Mr. Fjeldsoe-Nielsen (approximately 60-70 entries), and provides a new log with sufficient information to assess the privilege claims or produces previously withheld nonprivileged documents, as Skyhook has promised to provide since May 16. Please let us know this week whether Skyhook and Mr. Fjeldsoe-Nielsen will do the foregoing, so that we can go forward with his deposition on July 2. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134
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tlundin@kslaw.com

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Friday, June 07, 2013 11:24 PM To: dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane; Lundin, Tom Cc: Skyhook_Service Subject: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections

Tom, Please see attached Mr. Fjeldsoe-Nielsen's Responses and Objections to Google's Subpoena. Mr. Fjeldsoe-Nielsen is available for his deposition on July 2. Please confirm your availability early next week. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

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EXHIBIT 3

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RE: Skyhook v. Google: Various Discovery Issues


Dutta, Sanjeet <SDutta@KSLAW.com>
Mon 6/24/2013 10:34 PM
To:Azra

Hadzimehmedovic <azra@tensegritylawgroup.com>; Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>; Douglas Tillberg <dtillberg@gtmllp.com>; William <BAbrams@KSLAW.com>; Pada, Roxane <RPada@KSLAW.com>; Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>; dl.zzmgoogleskyhookext@bingham.com <dl.zzmgoogleskyhookext@bingham.com>; 1 attachment

Cc:Abrams,

Skyhook v. Google - ESI;

Azra- Apologies for failing to a1ach Googles message from Saturday. It is a1ached now. -sanj-
From: Dutta, Sanjeet Sent: Monday, June 24, 2013 10:32 PM To: 'Azra Hadzimehmedovic'; Skyhook_Service; Douglas Tillberg Cc: Abrams, William; Pada, Roxane; Google/Skyhook K&S; dl.zzmgoogleskyhookext@bingham.com Subject: RE: Skyhook v. Google: Various Discovery Issues

Dear Azra- We have discussed at length since February that Mr. Brin is not relevant to any aspect of Skyhooks case. Skyhook noGced Mr. Brins deposiGon without any basis other than to harass one of the highest ranking execuGves and co-founder of Google. Google repeatedly asked Skyhook to explain Mr. Brins relevance to Skyhooks patent case. Skyhooks response provided no basis: We understand that Mr. Brin was at the Macworld event in January 2008 at which Apple announced that it was using Skyhook's locaGon technology in its iPhone and that Mr. Brin had discussions with Apple representaGves about that announcement and Google's displeasure with it. Skyhook has never provided any basis for its asserGon that Mr. Brin has any connecGon to this case. We pointed out that roughly 50,000 persons a1ended Macworld in 2008 with Mr. Brin. Nevertheless, Google searched Mr. Brins emails for the terms Skyhook, Ted Morgan, and Macworld. No documents indicate that Mr. Brin has any personal knowledge of any issue relevant to the claims or defenses in this acGon. Google has conducted a reasonable search for documents from Mr. Brin, determined that the resulGng documents are not relevant and has no obligaGon to conduct any addiGonal searches. We will bring a moGon for protecGve order and seek sancGons if Skyhook persists in this harassment. Regarding the ESI Search terms, Google responded on Saturday. In case you did not receive it, I am a1aching

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Googles response that explains the large cost and burden involved in reviewing and producing documents that would result from Skyhooks over-broad search strings. Regarding deposiGons, Google conrms the availability of Mike Lockwood to appear on July 23. As we discussed during our meet and confer, Skyhook deposed Mr. Brady for two days in the state court acGon. Mr. Brady explained in his deposiGon that he manages partner relaGonships. Other than asserGng that the state court case is dierent than the current case, Skyhook has not provided an explanaGon why Mr. Brady should be deposed again and in this patent case. Please explain what knowledge Skyhook believes Mr. Brady has that is specic to the issues of this patent case that Skyhook did not already cover in its two day deposiGon of Mr. Brady. Mr. Zelinka will be available for his deposiGon on July 10. Google disagrees that it is under any obligaGon to produce Mr. Zelinkas documents, solely because he will be one of Googles technical 30(b)(6) witnesses. Skyhook has not provided any authority or caselaw to the contrary. As we discussed, Google has produced millions of pages of documents including Googles source code that explains the operaGon of Googles product. In view of this, Skyhook has not provided any reason why Mr. Zelinkas documents are needed above-and-beyond Googles thorough producGon of technical documents. Regarding RFPs 254 and 255 which both ask for policies regarding third party patents, acer a reasonable search, Google has not located any such policies. With regard to Skyhooks requests for Tracbeam discovery, Skyhook has not explained the relevance of Googles discovery responses in Tracbeam. The patents in the Tracbeam case are not related to the patents asserted by Skyhook and accordingly, Google should not bear the cost and burden of producing the transcripts and discovery responses that are not relevant to this acGon. If you have any quesGons, please let me know. Best regards,

_______________________________________
Sanjeet K. Du,a | Partner | King & Spalding LLP 333 Twin Dolphin Dr., Ste. 400 | Redwood Shores, CA 94065 Tel: 650.590.0730 | Cell: 408.644.4064 | sduCa@kslaw.com


From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Sunday, June 23, 2013 9:35 PM To: Lundin, Tom; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service; Douglas Tillberg Subject: Skyhook v. Google: Various Discovery Issues

Dear Sanjeet, I write to follow up on our latest June 20 meet and confer, in particular since Skyhook did not receive the follow-up responses on several of these issues on Friday, June 21, which you had committed to provide. On each of the issues addressed below (except on Mr. Zelinka's documents), unless by close of business on Tuesday Google agrees to produce documents or provide conrmations Skyhook has been seeking for weeks

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now, Skyhook will move to compel production. Individual Depositions Skyhook Noticed on May 23: Google's explanation that its in-house counsel has been unable to get availability from any of the seven deponents Skyhook noticedfor a whole monthis simply unacceptable. Google is not complying with its discovery obligations, and unless Google provides proposed dates for each of the noticed deponents by close of business on Tuesday, Skyhook will move to compel those depositions. Separately, please get back to us on our proposal that the parties forgo subpoenas for party witnesses and agree to produce non-duplicative relevant documents from those witnesses' possession. Mr. Brin's Documents: Absent Google's response to our requests, specically identied in my email attached below and discussed further at our June 20 meet and confer, by close of business on Tuesday, Skyhook will move to compel production of Mr. Brin's documents. ESI Search Terms: Google has not yet responded to Skyhook's June 3 request to run additional ESI searches and produce responsive documents, and Skyhook will move to compel production absent a response by close of business on Tuesday. Skyhook's Third Set of Document Requests: Skyhook pointed out during our meet and confer that it is still awaiting Google's responses on RFPs 199 (licenses and negotiations with OEMs) and 304 (how Google uses location data in its advertising) and Google has not yet provided a response. Further, on RPFs 254 (policies regarding studies of Google's patents) and 255 (policies regarding comparisons of Google's products with third-party patents), to the extent Google maintains that documents responsive to these RPFs are privileged, Google must identify such documents on its privilege log. Finally, with respect to Trackbeam litigation documents (RFP 303), Google has agreed to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. Skyhook requested conrmation that Google will include its discovery responses provided in that litigation as well as all deposition transcripts (including corporate depositions). To the extent that Google deems certain of the witnesses somehow irrelevant to this litigation, Skyhook has asked that Google identify those witnesses to Skyhook. Given that these follow-up requests are all within the scope of our late May discussions, Skyhook will move to compel production absent Google's agreement to produce documents or explain its belief that it has already produced responsive documents by close of business on Tuesday. Mr. Zelinka's Documents: Google has identied Mr. Zelinka as its corporate deponent on core technical topics, indeed he is the sole corporate deponent that Google has agreed to make available for deposition to date. You explained in the meet and confer that Google identied him as the corporate witness for these topics because he has the most comprehensive institutional knowledge among Google's employees currently working on the features of the accused products relevant to the topics on which he has been identied. Google also identied Mr. Zelinka in its January 30, 2013 second supplemental initial disclosures as one of only eleven Google employees knowledgeable about the issues in this litigation, and moreover, as one of only half-dozen employees

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knowledgeable about the operation of the accused products. However, Google has not collected, and has not produced, Mr. Zelinka's documents in this litigation and its position is that it will only produce Mr. Zelinka's documents if Skyhook can identify documents in Mr. Zelinka's les that it has not received from other custodians. This position is clearly improper because Google, not Skyhook, has access to Mr. Zelinka's documents, and given the importance Google has assigned to Mr. Zelinka's knowledge of the operation of the accused products by virtue of his designation as a corporate witness. Skyhook will proceed with Mr. Zelinka's deposition on July 10, reserving its right to seek production of Mr. Zelinka's documents after the deposition and to reopen or continue his deposition after Google produces his documents. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Date: Wednesday, June 19, 2013 1:49 PM To: "Lundin, Tom" <TLundin@KSLAW.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: Re: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and ObjecGons and other discovery issues Tom, thank you for your responses. I will address several of them in this email in the hopes of streamlining our telephonic meet and confer. First, Google has selected Mr. Zelinka as a corporate representative on some of the core technical deposition topics, yet has not named him as a custodian nor produced his documents. Under the circumstances, Mr. Zelinka's responsive documents clearly should be produced. Please conrm that you will produce Mr. Zelinka's responsive documents at least two weeks prior to his deposition. Second, it is unacceptable that nearly one month after Skyhook noticed seven Google's employees for their individual depositions, Google has not responded with a proposed date for even one of those deponents. Google appears intent on delaying the resolution of this most straightforward issue, forcing motion practice

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knowing that it will take time for the opposing briefs to get led, only so that Google will thenon the eve of the court's hearingpropose deposition dates. This very thing just happened with Google's interrogatory responses it had been refusing to provide until Skyhook led its motion to compel. It is both unreasonable and unfair for Google to be delaying Skyhook's case in this manner and wasting both Skyhook's and the Court's resources on such issues. Third, Skyhook's deposition notices for Messrs. Lee and Brady in this case are wholly appropriate, and Google's arguments about overlap in those witnesses' depositions between this and the state case are unavailing. Skyhook's patent infringement case is separate and different from its state tortious interference case. The technical, willfulness, and the damages issues in the patent case are specic to this case. Further, Google cannot legitimately argue that Mr. Lee's and Mr. Brady's state-case depositions that took place before their custodian productions in this case even commenced and before Google produced the bulk of its production in this case are sufcient discovery of those witnesses for this case. We repeat our request for an immediate identication of their availability as well as the availability of all individual witnesses Skyhook has noticed nearly a month ago. Finally, with respect to Skyhook's request for Mr. Brin's documents, Skyhook requested that Google search the following search strings:

i. Skyhook ii. (Ted or Edward) w/3 Morgan iii. (Mike or Michael) w/3 Shean iv. (MacWorld or Mac World) and (Apple or Jobs or location or driv* or beacons or triangulat*) v. Location-based services or LBS or GLS
vi. (Location or Wi-Fi or WiFi or Wi?Fi or wireless or WLAN) and (advert* or revenue or value) Please explain why Google refuses to search Mr. Brin's documents for search strings v and vi. Please let us know how many documents each of our individual requested search strings yielded. (To the extent that the MacWorld search you ran yielded a large number of responsive documents, please let us know how many documents are responsive to our proposed search string no. iv, which is signicantly narrower.) And please conrm that Google is refusing to produce the documents that those six search strings yield and expects Skyhook and the Court to rely on Google's representation that although responsive documents were found, not one is relevant. I have already circulated a meeting invite and a dial-in for Sanjeet for our meet and confer tomorrow at 4 PM Eastern. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

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TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Tuesday, June 18, 2013 6:32 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and ObjecGons and other discovery issues

RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist.

King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

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Tuesday, J une 2 5, 2 013 1 0:29:07 A M P acic Daylight Time

Subject: Skyhook v. Google - ESI Date: Saturday, June 22, 2013 6:07:05 PM Pacific Daylight Time From: To: CC:
Azra -I'm writing to follow up on the conversation between you and Sanj on Thursday. As we have explained previously, Google has been diligently analyzing both Skyhook's requests to 1) amend the search terms used in the "Skyhook I" action using the amended search terms that Skyhook proposed; and 2) add new search terms that Skyhook asserts are relevant to the "Skyhook II" action. The analysis of Skyhook's proposals is now complete, and the results show that it would be extremely costly and unduly burdensome to gather and produce documents resulting from Skyhook's proposed search terms. The results of the analysis show the following estimated costs and times required: A) Approximately $1,225,000 and 38 days to review approximately 644,000 documents in response to Nos. 1 & 2 above; B) Approximately $633,000 and 19 days to review approximately 318,000 documents for only No. 1 above; and C) Approximately $1,072,000 and 33 days to review approximately 560,000 documents for only No. 2 above. The foregoing would be unquestionably unduly burdensome, even had Google not already produced more than 2.7 million pages of documents in the Skyhook I litigation, and made the key technical information -the source code of the accused instrumentality in both actions -- available many years ago. Particularly in light of those facts, as well as the plainly overburdensome and over broad nature of Skyhook's proposals, Google request that Skyhook provide a more reasonable set of search strings (including, by way of example only, fewer terms, with closer proximities, and with narrower Boolean connectors) that are more narrowly focused to target documents that Skyhook contends that it needs to prove the claims asserted in the former Skyhook II case--that would not be duplicative of the information found in the vast volume of documents already produced. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

Lundin, Tom Azra Hadzimehmedovic, Dutta, Sanjeet, dl.zzmgoogleskyhookext@bingham.com, Google/Skyhook K&S, Abrams, William, Pada, Roxane Skyhook_Service

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EXHIBIT 4

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Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Skyhook/Google: Brin Deposition Notice February 6, 2013 11:10 AM

Dear Bill, in the attached notice, Skyhook is requesting Sergey Brin's deposition on February 28, 2013. Please produce Mr. Brin's emails relating to Skyhook, development of Google's location-based services, the value of location data to Google, and any related analyses or valuations. These documents are responsive to at least the following Skyhook's RFPs: 2-6, 32, 39, 156, and 159-161. Please complete this production or confirm completion of production of Mr. Brin's email by no later than February 20, 2013.
AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

2013-02-0C.pdf (74 KB)

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EXHIBIT 5

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Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Re: Skyhook v. Google -- No. 1:10-cv-11571-RWZ March 6, 2013 2:09 PM Dear Bill, We understand that Mr. Brin was at the Macworld event in January 2008 at which Apple announced that it was using Skyhook's location technology in its iPhone and that Mr. Brin had discussions with Apple representatives about that announcement and Google's displeasure with it. He is uniquely able to discuss his reactions to the announcement, and his subsequent conversations regarding it, as well as any actions taken or policies adopted by Google as a consequence thereof. You have confirmed that Google has not collected any of Mr. Brin's own documents or emails and that Google's counsel has not even spoken with Mr. Brin to determine the extent of relevant and non-cumulative information he possesses. We also believe that Google has failed to collect any documents from its executives. Nonetheless, based on our review of Google's production, for example, Google's Location-Based Services meeting notes reveal that both Mr. Brin and Mr. Page received briefings about the development of Google's Location-Based Services, and that they participated in product reviews and "sales readiness" evaluations. Further, among those briefings, Mr. Brin appears to have received briefings about Google's effort to place Google's location services in the iPhone (instead of Skyhook or other third parties) so that Google could collect the user's WiFi information. Therefore, Mr. Brin has unique first- hand knowledge about the development of the accused products and the strategic value of those services to Google. Further, Google cannot deny that its executives, both Mr. Page and Mr. Brin, have placed a great value on Google's location services and the extraordinary value Google receives from location-based data. They can speak to that value from their unique position at the helm of the company and their judgment and perspective on the issue cannot be replaced or supplanted by other witnesses. And based on our understanding, Google's representation that Mr. Brin was not keenly aware of the development of the location-based services products is incorrect. We have seen at least one email string in which Mr. Brin suggests to Google's engineers how to fix a bug related to Google's location servicesa thread that appears to have been prompted because Mr. Brin's own location itself was buggy: "Sergey's location ping pongs around at night. . . ." Mr. Brin can speak to the accused products from the perspective of an executive who understands the accused technology and cares about its inner workings as well as its strategic importance to Google. Thus, Skyhook believes that Mr. Brin has unique and non-repetitive knowledge regarding willful infringement and damages issues. As we are sure you are aware, Google has recently been faced with a similar issue in its Oracle case, where it tried to resist providing Mr. Page's deposition. Just like in this case, Google argued that its founder did not have first-hand knowledge of the issues relevant to willful infringement, but the Court did not believe Google's excuses. Although the Court understood that Mr. Page may not have even participated directly in the negotiations at issue in that case, the Court held that it was "highly likely that Mr. Page participated in decision-making regarding [those] negotiations." Oracle Am., Inc. v. Google, Inc., 2011 U.S. Dist. LEXIS 79465, at *6-7 (N.D. Cal. July 21, 2011). We also note that so far Google has only made unfounded claims of harassment, but Google has not denied Mr. Brin's knowledge on any the issues Skyhook has raised. Google's position is especially troubling given your statements during our Rule 26 conference that Skyhook's own CEO was a per se non-cumulative and highly relevant deponent despite the undisputed fact that he was not even present at Skyhook until very recently and was not capable of having percipient knowledge of any of the relevant background events in which Mr. Brin, by contrast, was personally and instrumentally involved. Thus, we respectfully repeat our request that you in fact speak with Mr. Brin about his knowledge related to the activities we have identified. And we request that Google tells usspecificallywhy it believes other Google employees are the more appropriate deponents than Mr. Brin on the specific topics we have

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identified for Mr. Brin. Thank you. Best, Azra AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Abrams>, William <BAbrams@KSLAW.com> Date: Monday, February 25, 2013 10:55 AM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Cc: Aaron Nathan <aaron.nathan@tensegritylawgroup.com>, Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>, Douglas Tillberg <dtillberg@gtmllp.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Evans, Laura" <LEvans@irell.com>, "Lu, Sam (SLu@irell.com)" <SLu@irell.com>, "Lundin, Tom" <TLundin@KSLAW.com> Subject: RE: Skyhook v. Google -- No. 1:10-cv-11571-RWZ
Dear Azra - You have not provided any support for your "understanding ... that Mr. Brin is knowledgeable on these topics and could offer testimony and perspective that is not directly available to Google's other witnesses." What is the basis for this understanding? We've asked you several times for this, but you have not provided any evidence to support it. Mr. Brin is a founder and senior leader of one of the largest companies in the world. Skyhook bears the initial burden of showing that a person in Mr. Brin's position has unique knowledge on relevant subject matter, i.e., not just his own perspective on information available from others or through other means. In addition, Skyhook must have actually sought the information in another, less burdensome way before seeking this deposition and establishing that it is necessary. Skyhook has not met any of its burdens, and there is no basis for imposing on Mr. Brin given the lack of any showing by Skyhook as we have stated. The deposition notice appears tactical and intended to harass Mr. Brin and Google, particularly given that the notice is served at the beginning of taking depositions in the case, before Skyhook has examined any witnesses regarding relevant subject matter. We are prepared to seek a protective order, and sanctions, if Skyhook does not withdraw the deposition notice for Mr. Brin. Bill

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From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Tuesday, February 19, 2013 3:33 PM To: Lundin, Tom Cc: Abrams, William; Aaron Nathan; Skyhook_Service; Douglas Tillberg; Google/Skyhook K&S; Evans, Laura; Lu, Sam (SLu@irell.com) Subject: Re: Skyhook v. Google -- No. 1:10-cv-11571-RWZ

Tom, Thank you for following up on our conversation on Friday. Yes, the parties have agreed to reschedule the currently noticed depositions and have also agreed not to wait for the Court to hold the hearing regarding Google's motion to consolidate, but to proceed in the meantime to work on rescheduling the previously noticed depositions. With respect to Skyhook's requests for Mr. Brin's deposition and production of relevant email, Google confirmed that it has not in fact spoken to Mr. Brin to determine whether he has information relevant to Skyhook's case. Skyhook therefore requests that Google specifically confirm with Mr. Brin whether he has relevant knowledge in the following areas: (1) attendance and participation at Macworld 2008, including discussions relating to Skyhook's or Google's location technology; (2) discussions with Apple regarding Google's location-based services; (3) direction and management of the development of Google's location-based services; (4) value of location-based data to Google; (5) knowledge of and participation in discussions relating to Skyhook's location technology and Google's valuation and knowledge about that technology; and (6) decisions/discussions regarding the Motorola and Samsung deals and/or potential deals with Skyhook relating to location technology. If Mr. Brin is willing to submit a declaration that he has not participated in the activities outlined above and does not have any firsthand knowledge in these areas, then we would be willing to consider withdrawing our deposition notice and request for Mr. Brin's email. Our understanding, however, is that Mr. Brin is knowledgeable on these topics and could offer testimony and perspective that is not directly available to Google's other witnesses. Further, unless Mr. Brin is willing to declare under oath that he in fact has no relevant knowledge related to Skyhook's case, Google's objection to conducting targeted searches of his email on the limited topics Skyhook has identified is improper. Best, Azra
AZRA HADZIMEHMEDOVIC

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TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax) On 2/15/13 5:41 PM, "Lundin, Tom" <TLundin@KSLAW.com> wrote: Azra -- I'm confirming our conversation earlier today. We agreed that, with respect to the depositions noticed by each party thus far, neither party has the expectation that the depositions will occur on the dates set forth in the notices/subpoenas. With one exception, noted below, the parties will continue to work on identifying dates for the noticed witnesses and will communicate further on potential rescheduled dates. The exception noted above applies to the deposition notice Skyhook issued for Mr. Brin. Although we did not discuss the Brin notice today, it was discussed during the Rule 26(f) conference on Monday, when Google reiterated its previously emailed objection and request that Skyhook withdraw the Brin notice. During the Rule 26(f) conference you proposed sending us some information concerning Skyhook's desire to depose Mr. Brin. We said that we would review the information, but did not withdraw our request that the notice be withdrawn. Please let us know whether Skyhook will agree to withdraw the Brin notice, so that we can determine whether Google needs to move for a protective order. Please don't hesitate to call with any questions. Have a good weekend. Regards, TCL King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

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EXHIBIT 6

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SKYHOOK WIRELESS, INC., Plaintiff and Counterclaim-Defendant, v. GOOGLE INC., Defendant and Counterclaimant. ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:10-cv-11571-RWZ Case No. 1:13-cv-10153-RWZ

GOOGLE INC.S OBJECTIONS AND RESPONSES TO SKYHOOK WIRELESS, INC.S THIRD SET OF REQUESTS FOR PRODUCTION Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, defendant and counterclaimant Google Inc. (Google) hereby responds and objects to the Third Set Of Requests For Production Of Documents And Things (Nos. 176-316) (the Third Requests) served by plaintiff and counterclaim-defendant Skyhook Wireless, Inc. (Skyhook). GENERAL OBJECTIONS AND RESPONSES Google objects to the Third Requests as unreasonably duplicative and cumulative of Skyhook Wireless, Inc.'s First Set Of Requests For Production To Google Inc. (the First Requests) and Skyhook Wireless, Inc.'s Second Set Of Requests For Production To Google Inc. (the Second Requests), to the extent that the requests are directed to the 988, 694, 897, and 245 patents. During discovery in these cases, Google has produced more than 2.5 million pages of documents (1) collected from a large number of technical document repositories, i.e., internal sites, wikis, and dashboards, and (2) from agreed-upon custodians and additional custodians demanded by Skyhook that were responsive to search terms relevant to the case. Google also has made available for inspection source code relevant to the Accused Products since October

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2011. These productions contain documents and information relevant to the claims and defenses in Skyhook Wireless, Inc. v. Google Inc., No. 1:10-cv-11571-RWZ (D. Mass.) filed September 15, 2010 (Skyhook I), as well the claims and defenses in Skyhook Wireless, Inc. v. Google Inc., No. 1:10-cv-10153-RWZ (D. Mass.) (Skyhook II). Accordingly, Google objects to Skyhooks Third Requests as unduly burdensome and unreasonably duplicative to the extent Google has already produced information responsive to the Skyhooks Third Requests. Google hereby incorporates by reference as if fully set forth herein its General Objections stated in the First Requests and Second Requests, and its objections and responses to individual requests stated in the First Requests and Second Requests, to the extent that those requests are duplicated by requests in the Third Requests, and limits its responses herein to the patents named in Skyhook II. Google further asserts the General Objections, Objections To Definitions, and Objections To Instructions stated in Exhibit A hereto. OBJECTIONS AND RESPONSES TO SPECIFIC REQUESTS FOR PRODUCTION Subject to and without waiving the foregoing and to the objections stated in Exhibit A, Google responds to each request for production as follows: REQUEST FOR PRODUCTION NO. 176: All Documents Relating To the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 176: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the

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attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 1, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 177: All Documents Relating To any of the Skyhook Patent Inventors. RESPONSE TO REQUEST FOR PRODUCTION NO. 177: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 2, and seeks materials previously produced by Google. 3

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 178: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development, of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 178: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, including without limitation source code, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 179: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development of Google Location Service. RESPONSE TO REQUEST FOR PRODUCTION NO. 179: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location Services, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 6, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 6. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 180: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development of Googles Network Location Provider. RESPONSE TO REQUEST FOR PRODUCTION NO. 180: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and

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defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 7, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 7. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 181: All Documents Relating To the structure, function, operation, design, development, creation, testing, optimization, use, and storage of, and collection and processing of data for the Google Wi-Fi Location Database, including an electronic version of Googles Wi-Fi Location database, including access to Googles database of raw data. RESPONSE TO REQUEST FOR PRODUCTION NO. 181: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Wi-Fi Location Database and Googles database of raw data, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine.

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Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 8, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 8. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request as it relates to the asserted patents in Skyhook I; and Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 182: All Documents Relating To the structure, function, and operation of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database with respect to their use to determine the location of a Wi-Fi-enabled device or a device having a Wi-Fi radio.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 182: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms Google Location, Google Location Services, Google Wi-Fi Location Database, and Wi-Fi enabled device, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 9. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 183: All Documents Relating To the manner in which Google Location determines which location technique to use in estimating the location of a Wi-Fi enabled device, e.g., Cell ID, cell tower triangulation, Wi-Fi, and GPS. 8

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RESPONSE TO REQUEST FOR PRODUCTION NO. 183: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location and Wi-Fi enabled device, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 9. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 184: All Documents Relating To the accuracy or estimated accuracy of Googles Wi-Fi location calculations, including the accuracy or estimated accuracy of location estimates of Wi-Fi enabled mobile devices and Wi-Fi access points.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 184: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms accuracy, estimated accuracy, and Wi-Fi enabled mobile devices, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 8 and 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 8 and 9. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 185: All Documents Relating to the comparative accuracy of location estimations based on Googles Wi-Fi Location Database as opposed to other location techniques such as Cell ID, cell tower triangulation, and GPS. 10

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RESPONSE TO REQUEST FOR PRODUCTION NO. 185: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms comparative accuracy, Google Wi-Fi Location Database, and other location techniques, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 8 and 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 8 and 9. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 186: All Documents Relating To the structure, function, and operation of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database

11

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as used in conjunction with Google mobile services applications on a Wi-Fi enabled device such as an Android Enabled Mobile Phone or Tablet. RESPONSE TO REQUEST FOR PRODUCTION NO. 186: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Google mobile services applications, Wi-Fi enabled device and Android Enabled Mobile Phone or Tablet, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 10, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 10. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, including

12

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but not limited to all relevant source code, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 187: All Documents Relating To the research and development of Google Location, including blueprints, schematics, drawings, diagrams, notebooks, lab books, memoranda, data sheets, computer logs, electronic files, Software, and other records of activity, including as they Relate To calculating a location using Wi-Fi signals, generating a database of Wi-Fi access points and associated location information, detecting and correcting errors in such database, utilizing Wi-Fi location information in conjunction with other location techniques such as Cell ID, cell tower triangulation, and GPS, identifying new Wi-Fi access points, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 187: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Software, associated location information, Wi-Fi location information, and other location techniques, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 11, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 11. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). 13

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 188: All Documents Relating To the design, manufacture, and functionality of Google Location, including Software, specifications, schematics, flow charts, and other technical Documents including as they Relate To calculating a location using Wi-Fi signals, generating a database of Wi-Fi access points and associated location information, detecting and correcting errors in such database, utilizing Wi-Fi location information in conjunction with other location techniques such as Cell ID, cell tower triangulation, and GPS, identifying new Wi-Fi access points, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 188: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Software, associated location information, Wi-Fi location information, and other location techniques, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 12, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 12. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

14

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 189: All presentations, training materials, user guides, manuals, memoranda, or other instructional Documents Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 189: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 13, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 13. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

15

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 190: All Documents Relating To the identity, structure, function, operation, design, development, and creation of hardware, including servers, used to collect, process, and store Wi-Fi location data and provide Google Location beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 190: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 14 and 15, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 14 and 15. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

16

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 191: Documents sufficient to identify the location of each Google Location server. RESPONSE TO REQUEST FOR PRODUCTION NO. 191: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 14 and 15, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 14 and 15. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). 17

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 192: All Documents Relating To any data, information, or records Concerning Wi-Fi access points used, organized, stored, recorded, collected, added, generated, modified, updated, or calculated as part of Google Location, including Googles Wi-Fi location database and raw scan data and all source code Relating to the collection of Wi-Fi access point data, processing such data into the Google Wi-Fi location database, and the source code of the Wi-Fi location database itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 192: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Googles Wi-Fi location database, and raw scan data, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 16, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 16. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

18

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 193: All Documents Relating To how data, information, or records in the Google Wi-Fi Location Database is used, organized, stored, recorded, collected, added, generated, modified, updated, or calculated, including Googles Wi-Fi location database and raw scan data and all source code Relating to the collection of Wi-Fi access point data, processing such data into the Google Wi-Fi location database, and the source code of the Wi-Fi location database itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 193: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms Google Wi-Fi Location Database and raw scan data, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 17, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 17. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The 19

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 194: All Documents Relating To the structure, function, and operation of the source code electing, initiating, or controlling any communications or transmissions between Wi-Fi access points and Wi-Fi-enabled devices or devices having a Wi-Fi radio as part of Google Location, including all such source code itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 194: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms electing and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 18, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 18. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

20

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 195: All Documents Relating To the structure, function, and operation of computer hardware, Software, or algorithms used in Google Location, including hardware specifications and inventories, functional specifications, and all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 195: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 19, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 19. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

21

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 196: All Documents Relating To the structure, function, and operation of computer hardware, Software, or algorithms used in Google Location to determine the location of a Wi-Fi-enabled device or a device having a Wi-Fi radio, including hardware specifications and inventories, functional specifications, and all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 196: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software, Google Location, and Wi-Fi-enabled device, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 20, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 20. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The

22

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 197: All articles, speeches, symposiums, conference papers, abstracts, and other publications, whether generated by Google or otherwise, Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 197: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 21, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 21. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

23

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 198: All Documents Relating To Googles participation in conferences or trade shows in which Google Location, or literature relating thereto, was displayed, promoted, sold, or otherwise discussed. RESPONSE TO REQUEST FOR PRODUCTION NO. 198: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 22, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 22. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 199: All Documents Relating To any agreements with Motorola, Samsung, LG, HTC, any other OEM, or any Person Concerning Google Location, including all documents reflecting negotiations concerning any such agreement.

24

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RESPONSE TO REQUEST FOR PRODUCTION NO. 199: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 23, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 23. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 200: All Documents Relating To any Communications with Motorola, Samsung, LG, HTC, any other OEM, or corporate or governmental entity, Concerning Google Location, including marketing materials. 25

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RESPONSE TO REQUEST FOR PRODUCTION NO. 200: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 24, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 24. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 201: All Documents including specifications, user guides, manuals, instructional Documents, or Technical Documents provided by Google to Motorola, Samsung, LG, HTC, any other OEM, or any Person Relating To Google Location. 26

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RESPONSE TO REQUEST FOR PRODUCTION NO. 201: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 25, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 25. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 202: All marketing and sales Documents Relating To Google Location, including product literature, promotional brochures, catalogues, press releases, and advertisements. RESPONSE TO REQUEST FOR PRODUCTION NO. 202: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this

27

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action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 26, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 26. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 203: All Google press releases or draft press releases that discuss (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 203: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Patents-inSuit, Related Patents, and Skyhook Technology, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or 28

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that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 27, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 27. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 204: All Documents Relating To Your strategic plans, business plans, business strategies, licensing plans, licensing proposals, licensing forecasts, prospectuses, market surveys, marketing strategies, market analyses, and/or marketing forecasts of customer demand for Google Location beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 204: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the

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extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 28, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 28. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 205: All Documents Relating To analyst reports, industry surveys, and published studies about the location determination industry, including article searches on specific attributes and competitive analyses of the location determination market that have been known to Google employees whose work involves the design, development, creation, marketing, maintenance, or provision of Google Location, beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 205: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms location determination industry and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the 30

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discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 29, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 29. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 206: Documents sufficient to identify all product lines, features, names, and codes for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 206: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including

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without limitation Request No. 30, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 30. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 207: All Documents Relating To internal and external financial statements, profitability studies and reports, gross-margin studies and reports, and turnover studies and reports for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 207: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 32 and 110, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 32 and 110.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 208: Documents sufficient to identify your accounting methods for revenues, cost allocation, and profits for Google Location, including accounting procedures manuals and charts of accounts. RESPONSE TO REQUEST FOR PRODUCTION NO. 208: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 33, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 33. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 209: Documents sufficient to show the total research and development costs of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 209: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 34, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 34. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 210: All Documents Relating To sales and revenue information for Google Location from August 30, 2007, to the present, broken down by quarter and by U.S. versus worldwide sales and revenue, including all Documents sufficient to explain any acronyms or terminology employed by Googles accounting system, and including sales volume and amount of revenue for products and

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services that Google Location comprises, groups, divisions, or other units, responsible for the same. RESPONSE TO REQUEST FOR PRODUCTION NO. 210: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 35, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 35. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 211: All Documents Relating To profit and margin information, including gross profits, operating profits, net profits, and profits before taxes, for Google Location from August 30, 2007,to the present, broken down by quarter and by U.S. versus worldwide sales and revenue, including profit and loss statements for products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same, and including all Documents sufficient to explain any acronyms or terminology employed by Googles accounting system. RESPONSE TO REQUEST FOR PRODUCTION NO. 211: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 36, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 36.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 212: Documents sufficient to identify the total uses of Google Location on a monthly or quarterly basis. RESPONSE TO REQUEST FOR PRODUCTION NO. 212: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase total uses of Google Location and the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 37, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 37. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 213: All Documents Relating To sales and revenue associated with Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same), including reports, forecasts, and strategic plans. RESPONSE TO REQUEST FOR PRODUCTION NO. 213: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 38, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 38. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 214: All Documents Relating To advertising sales associated with Google Location, including sales reports, sales forecasts, and strategic plans beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 214: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 39, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 39. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126).

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 215: All Documents Relating To forecasted, contemplated, planned or prospective gross and net profit or loss for Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same), including profit margins and profit and loss statements. RESPONSE TO REQUEST FOR PRODUCTION NO. 215: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 40, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 40.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 216: All Documents Relating To forecasted, contemplated, planned or prospective planned or prospective gross and net profit or loss for the use of Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same) in any region outside of the United States, including profit margins and profit and loss statements. RESPONSE TO REQUEST FOR PRODUCTION NO. 216: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 41, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 41. 41

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 217: All Documents Relating To market and customer demand, need, or market potential for Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same) or location determination technology. RESPONSE TO REQUEST FOR PRODUCTION NO. 217: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 42, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 42. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 218: All Documents reviewed by, prepared by, or received by Google Relating To any test, evaluation, analysis, study, or investigation of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 218: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 45, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 45. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 219: All Documents Relating To customer or user comments, questions, or complaints Concerning Google Location.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 219: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 46, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 46. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 220: All Documents Relating To any actual, proposed, forecasted, contemplated, planned, or prospective business plan or strategy Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 220: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 48, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 48. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 221: All Documents Relating To any actual, proposed, forecasted, contemplated, planned or prospective business plan or strategy Concerning the use of Google Location in any region outside of the United States. RESPONSE TO REQUEST FOR PRODUCTION NO. 221: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including 45

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without limitation Request No. 49, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 49. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 222: All Documents Relating To any actual, proposed, forecasted, contemplated, planned or prospective business plan or strategy Concerning the Patents-in-Suit, the Related Patents, or Skyhook Technology. RESPONSE TO REQUEST FOR PRODUCTION NO. 222: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit, Related Patents, and Skyhook Technology, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 50, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 50. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has 46

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 223: All Documents and Communications Relating To license agreements or royalty agreements entered into by Google as a licensee in technological fields including geolocation, location services, mobile services, and targeted advertising, beginning in 2003 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 223: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase technological fields including geolocation, location services, mobile services, and targeted advertising, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 51, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 51. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. 47

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REQUEST FOR PRODUCTION NO. 224: All Documents and Communications Relating To patent license agreements, settlement agreements, or other agreements containing a license to patent rights, to which Google is or was a party including patents in the fields of geolocation, location services, mobile services, and targeted advertising, beginning in 2003 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 224: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase technological fields including geolocation, location services, mobile services, and targeted advertising, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 52, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 52. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request.

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REQUEST FOR PRODUCTION NO. 225: All Documents and Communications Relating To license agreements, settlement agreements, or other agreements Relating To Google Location or Skyhook Technology and all products or services utilizing said technologies. RESPONSE TO REQUEST FOR PRODUCTION NO. 225: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Skyhook Technology, and all products or services utilizing said technologies, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 53, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 53. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 226: All Documents and Communications Relating To end user license agreements, software license agreements, or any other licenses for use of or access to Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 226: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 54, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 54. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 227: All Documents Relating To Your corporate licensing policy, practices, or procedures, with respect to licensing of intellectual property or software Relating to Google Location or other location-related technology, and with respect to licensing patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 227: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location and other location-related technology, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 55, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 55. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 228: All Documents Relating To indemnity agreements or any agreements of any kind Concerning (a) the Patents-in-Suit or the Related Patents or (b) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 228: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 59, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 59. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 229: All Documents Relating To any meeting with stock, financial, or similar analysts at which Google Location was discussed. RESPONSE TO REQUEST FOR PRODUCTION NO. 229: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the

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grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 60, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 60. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 230: All Documents Relating To any marketing plan, competitive assessment, market share study, marketing budget, advertising budget, or promotion strategy plans Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 230: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 61, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 61. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 231: All Documents Relating To advertisements, including internet web pages, made by or on behalf of Motorola, Samsung, LG, HTC, any other OEM, or any other Person Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 231: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to 54

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this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 62, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 62. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 232: All Documents Relating To any Communications with Motorola, Samsung, LG, HTC, any other OEM, or any Person Concerning: (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 232: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, location determination technology, Patents-in-Suit, Related Patents, and Skyhook Technology, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 63, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 63.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 233: Documents sufficient to identify the organizational structure, location, and personnel of each of Your units, departments, divisions, or other entities involved in the research, development, production, manufacture, marketing, or sales of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 233: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 65, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 65. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. 56

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REQUEST FOR PRODUCTION NO. 234: Documents sufficient to identify the name, location, title and role of all employees involved in the research, development, production, manufacture, marketing, or sales of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 234: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 66, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 66. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 235: All board of directors minutes, memoranda, reports, meeting agendas and other Documents, including Documents of any board committee, subcommittee or similar group, Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 235: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, location determination technology, Patents-in-Suit, Related Patents, and Skyhook Technology, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 67, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 67. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 236: All reports, meeting agendas, meeting minutes and other Documents of management, sales, and marketing personnel Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 236: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, location determination technology, Patents-in-Suit, Related Patents, and Skyhook Technology, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 68, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 68. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 237: All internal memoranda, newsletters, bulletins, and other Documents Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 237: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, location

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determination technology, Patents-in-Suit, Related Patents, and Skyhook Technology, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 69, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 69. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 238: All Documents Relating To when and how Google first became aware of the existence of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 238: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the

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attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 70, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 70. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that documents responsive to this request, as it relates to the patents asserted in Skyhook II the Complaint filed in Skyhook II and its exhibits are in the possession of Skyhook. REQUEST FOR PRODUCTION NO. 239: All Documents Relating To actions that Google took upon becoming aware of the existence of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 239: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests,

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including without limitation Request No. 71, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 71. REQUEST FOR PRODUCTION NO. 240: All Documents Relating To any Communications with Skyhook Relating To Skyhook Technology, the Patents-in-Suit, or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 240: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit, Related Patents, and Skyhook Technology, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 73, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 73. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I.

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REQUEST FOR PRODUCTION NO. 241: All Documents reviewed by, prepared by, or received by Google Relating To any test, evaluation, analysis, study, or investigation of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 241: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 75, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 75. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 242: All Documents Relating To searches or investigations Relating To the scope, validity, infringement, or enforceability of each of the Patents-in-Suit or the Related Patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 242: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 76, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 76. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 243: All Documents Relating To any analysis, opinion, or inquiry regarding potential infringement of the inventions claimed in each of the Patents-in-Suit or the Related Patents, including but not limited to any Documents Concerning pre-litigation investigations performed by or on behalf of Defendant, Defendants partners, Defendants licensors, Defendants customers, Defendants resellers, and/or Defendants affiliates, Relating To the potential infringement by any products, systems, or processes made, used, offer for sale, and/or sold by Defendant, Defendants partners, Defendants licensors, Defendants customers, Defendants resellers, and/or Defendants affiliates.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 243: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 77, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 77. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 244: All Documents Relating To any risk or damages analysis of potential infringement of the Patents-in-Suit or the Related Patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 78: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 78, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 78. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 245: All Documents Relating To any written or oral opinion of counsel Concerning the Patents-inSuit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 245: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related

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Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 79, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 79. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 246: All Documents Relating To the validity or invalidity of any of the claims of the Patents-In-Suit or the Related Patents, including any prior art, claim charts, invalidity charts, validity search, prior art search or patentability search conducted in connection with the Patents-In-Suit or the Related Patents, including search reports or requests or instructions for prior art searches. RESPONSE TO REQUEST FOR PRODUCTION NO. 246: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible

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evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 80, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 80. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 247: Assuming that Google were held to infringe the Patents-in-Suit, all Documents upon which Google relies, or intends to rely, to support its position that such infringement is not deliberate or willful. RESPONSE TO REQUEST FOR PRODUCTION NO. 247: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Patents-in-Suit, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in 68

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the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 82, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 82. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 248: All Documents Relating To Your analysis of the liability or risk factors associated with the development of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 248: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase liability or risk factors and the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or

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duplicative of other Requests, including without limitation Request No. 83, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 83. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 249: All Documents Relating To any comparisons between the Patents-in-Suit or the Related Patents and any Google products, systems, or processes. RESPONSE TO REQUEST FOR PRODUCTION NO. 249: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 84, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 84. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will

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produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 250: All Documents Relating To any comparisons between Skyhook Technology and Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 250: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location and Skyhook Technology, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 85, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 85. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 251: All Documents Relating To the use of GPS, Assisted GPS, Cell ID, or cell tower triangulation in Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 251: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 86, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 86. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 252: All Documents Relating To any comparisons between Google Location and GPS, Assisted GPS, Cell ID, or cell tower triangulation. RESPONSE TO REQUEST FOR PRODUCTION NO. 252: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 87, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 87. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 253: All Documents that have any bearing on the interpretation or construction of the claims of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 253: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related

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Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 88, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 88. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 254: All Documents Relating To Your policy or practice, whether formal or informal, Concerning the analysis of patents owned by or assigned to entities other than Google, including patents in the fields of location services technology, location-based marketing, and geolocation. RESPONSE TO REQUEST FOR PRODUCTION NO. 254: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms location services technology, location-based marketing, and geolocation, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information 74

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concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 90, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 90. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 255: All Documents Relating To Your policy or practice, whether formal or informal, Concerning the comparison of any Google products, systems, or processes with the claims of patents owned by or assigned to entities other than Google including patents in the field of location technology or geolocation. RESPONSE TO REQUEST FOR PRODUCTION NO. 255: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms location technology and geolocation, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused

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in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 256: All Documents Relating To any analysis or effort by Google to design products around the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 256: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the

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extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 94, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 94. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 257: All Documents Relating To design alternative studies or design change orders for Google Location, including engineer lab notebooks, notes, memoranda, electronic mail messages, schematics, block diagrams, blue prints, drawings, and Software. RESPONSE TO REQUEST FOR PRODUCTION NO. 257: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or 77

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duplicative of other Requests, including without limitation Request Nos. 94, 95, and 256, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 94, 95, and 256. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 258: All Documents Relating To technical or financial studies Concerning the value or application of the inventions claimed in the Patents-In-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 258: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request

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No. 96, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 96. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 259: All Documents Relating To technical or financial studies Concerning the value or application of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 259: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms application and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests,

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including without limitation Request No. 98, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 98. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 260: All Documents Relating To any product, system, or process that competes with Google Location including any documents Relating to Your testing, analysis, or planning with respect to such competing products. RESPONSE TO REQUEST FOR PRODUCTION NO. 260: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 99, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 99. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The 80

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Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 261: All market studies, consumer analyses, and competitive analyses Relating To any product, system, or process that competes with Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 261: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 100 and 260, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 100 and 260. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 262: All versions of Software that has been or is being used in Google Location including all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 262: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 101, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 101. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 263: All Documents Relating To the structure, function, and operation of Software that has been or is being used in Google Location, including functional specifications and source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 263: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 101, 102 and 262, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 101, 102 and 262. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 264: All Documents, including Software, functional specifications, and source code, Relating To any updates of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 264: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software and Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 101, 103 and 262, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 101, 103 and 262. Google further objects to this Request on the grounds stated in Google Inc.s Opposition To Skyhooks Supplemental Brief Regarding Skyhooks Motion To Compel The Production Of Documents Responsive To Skyhooks Requests For Production And Skyhooks Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 265: All Documents furnished to, or discussed with, any fact witness contacted, interviewed, or consulted by Google or its agents or attorneys in connection with this litigation, the Patents-inSuit, or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 265: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Patents-in-Suit and Related Patents, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 106, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 106. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook I.

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REQUEST FOR PRODUCTION NO. 266: All financial statements from August 30, 2007, to present Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 266: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 110 and 112, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 110 and 112. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 267: All financial statements from August 30, 2007, to present of any and all of Your business segments, groups, divisions, sectors and/or subsidiaries Relating To Google Location.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 267: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 112, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 112. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 268: All profit and loss statements from August 30, 2007, to present Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 268: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the

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grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 114, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 114. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 269: Documents sufficient to identify Your profit or loss Relating To Google Location for each quarter and year from August 30, 2007, to present. RESPONSE TO REQUEST FOR PRODUCTION NO. 269: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 116, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 116. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 270: Documents sufficient to identify Your revenue, for each quarter and year from August 30, 2007, to present, Relating To Google Location for each quarter and year from August 30, 2007, to present. RESPONSE TO REQUEST FOR PRODUCTION NO. 270: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in 89

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Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 118, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 118. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 271: Documents sufficient to identify all expense items, for each quarter and year from August 30, 2007, to present, including but not limited to, cost of goods sold, sales and marketing, research and development, and general and administrative, Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 271: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Location, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product 90

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doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 120, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 120. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 272: Documents sufficient to show the structure, function, operation, design, development, testing, valuation and forecasts Relating To Googles Location-Based Advertising. RESPONSE TO REQUEST FOR PRODUCTION NO. 272: Google objects to this Request as vague, ambiguous, and unintelligible, including without limitation in its use of the terms or phrases structure . . . Relating to Googles Location-Based Advertising, function . . . . . . Relating to Googles Location-Based Advertising, operation . . . Relating to Googles Location-Based Advertising, design . . . Relating to Googles Location-Based Advertising, development . . . Relating to Googles Location-Based Advertising, testing . . . Relating to Googles Location-Based Advertising, and LocationBased Advertising, as overly broad and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the

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work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 122-132, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 122-132. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 273: Documents sufficient to show the structure, function, operation, design, development, testing, valuation and forecasts Relating To Mobile Advertising as it Relates To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 273: Google objects to this Request as vague, ambiguous, and unintelligible, including without limitation in its use of the terms or phrases structure . . . Relating to Mobile Advertising as it Relates To Google Location, function . . . . . . Relating to Mobile Advertising as it Relates To Google Location, operation . . . Relating to Mobile Advertising as it Relates To Google Location, design . . . Relating to Mobile Advertising as it Relates To Google Location, development . . . Relating to Mobile Advertising as it Relates To Google Location, testing . . . Relating to Mobile Advertising as it Relates To Google Location, and Google Location, as overly broad and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the

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extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 133-143, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 133-143. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 274: Documents sufficient to identify the total number of Wi-Fi enabled devices in the United States, by quarter and by year for each year from August 30, 2007, to the present, that have or had Google Location installed, downloaded or uploaded on them. RESPONSE TO REQUEST FOR PRODUCTION NO. 274: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location and Wi-Fi enabled devices, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent 93

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that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 144-145, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 144-145. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 275: Documents sufficient to identify the total number of Wi-Fi enabled devices in the United States, by quarter and by year for each year from August 30, 2007, to the present, that have or had any application making use of Google Location, installed, downloaded, or uploaded on them. RESPONSE TO REQUEST FOR PRODUCTION NO. 275: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location and Wi-Fi enabled devices, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google 94

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objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 146-147, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 146-147. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 276: All Documents Relating To any presentation made to shareholders, potential shareholders, investors, potential investors, lenders, potential lenders, analysts, and/or members of the economic media Relating To Google Location, Location Determination Technologies, LocationBased Advertising, and/or Mobile Advertising. RESPONSE TO REQUEST FOR PRODUCTION NO. 276: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Location Determination Technologies, Location-Based Advertising, and Mobile Advertising, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without

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limitation Request No. 156, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 156. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 277: All Documents Relating To any study, survey, or analysis Relating To Location-Based Advertising, Mobile Advertising, and/or any or all Google Location products. RESPONSE TO REQUEST FOR PRODUCTION NO. 277: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Location-Based Advertising Mobile Advertising, and Google Location products, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 158, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 158.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 278: All versions of Software that has been or is being used in Googles Wi-Fi Location Database, including source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 278: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Software and Wi-Fi Location Database, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 174-175, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 174-175. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 279: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate an expected error of a position estimate or otherwise estimate a distance between a calculated position and an actual position. RESPONSE TO REQUEST FOR PRODUCTION NO. 279: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and expected error, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request.

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REQUEST FOR PRODUCTION NO. 280: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate an expected error of a position estimate based in whole or in part on signal strength, estimated geographic location, or signal coverage area. RESPONSE TO REQUEST FOR PRODUCTION NO. 280: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and expected error, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request.

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REQUEST FOR PRODUCTION NO. 281: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to determine that a previous location of a Wi-Fi access point has changed or is incorrect. RESPONSE TO REQUEST FOR PRODUCTION NO. 281: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted

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in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 282: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to determine that a location associated with a Wi-Fi access point is not the present location of the Wi-Fi access point. RESPONSE TO REQUEST FOR PRODUCTION NO. 282: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 281, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 281. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be

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responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 283: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to calculate the position of a device based on information gathered from Wi-Fi access points by the device and information about the Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 283: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 281-282, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 281-282. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith

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search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 284: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate the position of a device using information from Wi-Fi access points and to use such estimate as an initial position for a satellite positioning system. RESPONSE TO REQUEST FOR PRODUCTION NO. 284: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 281-283, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 281-283. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will

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produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 285: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to calculate an uncertainty estimate in a position estimated by using information from Wi-Fi access points and to provide such uncertainty estimate along with an initial position to a satellite positioning system. RESPONSE TO REQUEST FOR PRODUCTION NO. 285: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and uncertainty estimate, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-284, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-284. 104

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 286: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate the geographic location of a device by using, in whole or in part, user-input information relating to Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 286: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and user-input information relating to Wi-Fi access points, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos.

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280-285, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-285. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 287: All Documents Relating to https://services.google.com/fb/forms/wifibugs/, including without limitation the submissions received through this service, dates and number of submissions received through this service, and the date and reasons why Google discountinued [sic] the service. RESPONSE TO REQUEST FOR PRODUCTION NO. 287: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google.

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Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 288: All Documents Relating to the use of Android Enabled Mobile Phones or Tablets to gather information about Wi-Fi access points, including without limitation identifying the location of access points, or determining that the access points have moved. RESPONSE TO REQUEST FOR PRODUCTION NO. 288: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted

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in Skyhook Iexcluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 289: All Documents Relating To caching of information on Android Enabled Mobile Phones or Tablets about detected Wi-Fi access points, including all documents concerning the use of such cached data to estimate the position or movement of Android Enabled Mobile Phones or Tablets, or to provide location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 289: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted

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in Skyhook Iexcluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 290: All Documents Relating To the cache.wifi cache on Android Enabled Mobile Phones or Tablets, including all documents concerning the use of the contents of cache.wifi (including time data) to estimate the position or movement of Android Enabled Mobile Phones or Tablets, or to provide location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 290: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted

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in Skyhook Iexcluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 291: All Documents Relating To the use of cached information on Android Enabled Mobile Phones or Tablets about detected Wi-Fi access points by either the Android Enabled Mobile Phones or Tablet on which the data is cached, or by the Google Location Server. RESPONSE TO REQUEST FOR PRODUCTION NO. 291: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location Server, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted 110

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in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 292: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to identify new Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 292: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-285, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-285. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted 111

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in Skyhook Iexcluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 293: All Documents Relating to the use of Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to add information about new Wi-Fi access points to the Google Wi-Fi Location Database or otherwise utilize such information for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 293: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and otherwise utilize such information for Google Location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith

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search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 294: All Documents Relating to the use in Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of GPS or other satellite positioning data, whether in conjunction with Wi-Fi location data, cell tower location data, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 294: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-293, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-293.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 295: All Documents Relating to the use in Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of cell tower location data, whether in conjunction with GPS or other satellite positioning data, Wi-Fi location data, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 295: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-294, and seeks materials previously

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produced by Google. Google incorporates herein its Response to Request No. 280-286 and 292294. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 296: All Documents Relating to the use in Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of any form of location data or method of estimating a location other than Wi-Fi location data, whether in conjunction with Wi-Fi location data or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 296: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, Android Enabled Mobile Phone or Tablet, and any other method of estimating a location other than Wi-Fi location data, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the

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public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-295, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-295. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 297: All Documents Relating to the use in Google Location, Google Location Service, Googles Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of GPS or other satellite positioning data in conjunction with updating or correcting the Google Wi-Fi Location Database or any aspect of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 297: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Google Location, Google Location Service, Google Wi-Fi Location Database, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the

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extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-296, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-296. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhooks Amended Complaint not asserted in Skyhook Iexcluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 298: All Documents Relating to MacWorld 2008. RESPONSE TO REQUEST FOR PRODUCTION NO. 298: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through

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less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 299: All Documents Relating to Googles communications with Apple concerning location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 299: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term location-based services, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 300: All Documents You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Googles Street View project.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 300: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 301: All Documents Relating To location data that You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Googles Street View project. RESPONSE TO REQUEST FOR PRODUCTION NO. 301: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through

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less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165 and 301, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 302: All Documents Relating To Wi-Fi data collection that You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Googles Street View project. RESPONSE TO REQUEST FOR PRODUCTION NO. 302: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165 and 301-302, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 303: 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.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 303: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 304: All Documents Relating to Googles use of location-based data in providing Location-Based Advertising or Mobile Advertising, including without limitation the use of AdWords service. RESPONSE TO REQUEST FOR PRODUCTION NO. 304: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms location-based data, Location-Based Advertising, Mobile Advertising, and AdWords service, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is

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within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 122-143 and 272-273, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 122-143 and 272-273. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 305: All Documents Relating to any tests, evaluations, comparisons, or other analysis of any changes to Googles Wi-Fi-based location services, including for example any changes in completeness of the Google Wi-Fi Location Database, accuracy, time to fix, uncertainty, or error, between 2007 and the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 305: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Googles Wi-Fi-based location services, completeness, Google Wi-Fi Location Database, accuracy, time to fix, uncertainty, and error, and the phrase any changes in completeness of the Google Wi-Fi Location Database, accuracy, time to fix, uncertainty, or error, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the

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extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 306: All Documents Relating to the presence, usage, maintenance, or turnover of any data in the Google Wi-Fi Location Database from 2010 until the present that was collected during CityBlock or StreetView driving. RESPONSE TO REQUEST FOR PRODUCTION NO. 306: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Google Wi-Fi Location Database, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 307: Documents sufficient to show the total number of Android Enabled Mobile Phones or Tablets, by month, for each year from 2007 to the present, in the United States that are installed with any of the Google Location products.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 307: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Android Enabled Mobile Phones or Tablets and Google Location products, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks any financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 308: Documents sufficient to show the total number of times, by month, for each year from 2007 to the present, of Android Enabled Mobile Phones or Tablets in the United States that have accessed Googles Wi-Fi Location Database. RESPONSE TO REQUEST FOR PRODUCTION NO. 308: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Googles Wi-Fi Location Database and Android Enabled Mobile Phones or Tablets, on the grounds that it seeks

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information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 309: Documents sufficient to show the total number of times, by month, for each year from 2007 to the present, Wi-Fi enabled devices anywhere in the world have accessed Googles Wi-Fi Location Database in the United States. RESPONSE TO REQUEST FOR PRODUCTION NO. 309: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Googles Wi-Fi Location Database and Wi-Fi enabled devices, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily 125

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obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 310: Documents Relating To any valuation or attempted valuation of Wi-Fi based location data to Google, including without limitation the valuation shown in GOOGSKYFED_0181945 and any similar analyses. RESPONSE TO REQUEST FOR PRODUCTION NO. 310: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Wi-Fi based location data, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request. 126

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REQUEST FOR PRODUCTION NO. 311: Documents sufficient to show Googles market share of the U.S. Mobile Advertising market from 2007 to the present, and anticipated market trends or forecasts through 2030. RESPONSE TO REQUEST FOR PRODUCTION NO. 311: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms Mobile Advertising and Mobile Advertising market, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 312: All Documents Relating To Googles patents or patent applications relating to geolocation technology, geolocation devices, or geolocation products. RESPONSE TO REQUEST FOR PRODUCTION NO. 312: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms geolocation technology, geolocation devices, and geolocation products, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to

127

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lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 313: All Documents Relating To any estimates of the economic value of each of the following: Google-owned, Google-licensed, Google cross-licensed, non-Google, Skyhook, and nonSkyhook patented technology in Android Enabled Mobile Phones or Tablets related to location or Wi-Fi location. RESPONSE TO REQUEST FOR PRODUCTION NO. 313: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase Google-owned, Googlelicensed, Google cross-licensed, non-Google, Skyhook, and non-Skyhook patented technology, and the terms Android Enabled Mobile Phone or Tablet, related to location, and related to . . . Wi-Fi location, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or

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control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 314: All Documents Relating To any estimates of the economic value of the respective contributions of GPS, cell tower triangulation, and Wi-Fi to the overall economic value of location services provided in Android Enabled Mobile Phones or Tablets. RESPONSE TO REQUEST FOR PRODUCTION NO. 314: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms overall economic value of location services, location services, and Android Enabled Mobile Phone or Tablet, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request.

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REQUEST FOR PRODUCTION NO. 315: All Documents Relating To costs to Google, on an annual and cumulative basis since 2004, to establish and maintain Wi-Fi-based geolocation services. RESPONSE TO REQUEST FOR PRODUCTION NO. 315: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term Wi-Fi-based geolocation services, on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 316: All Documents authored, sent, or received by Sergey Brin, or in the network folders, email accounts, hard drives, or any other source of electronically stored information of Sergey Brin, Relating To Skyhook or Googles strategic decisions and valuation Relating To Google Location, or including any of the following terms:
1

Skyhook MacWorld or Mac World in the same document as 2008, Apple, Jobs, location, driven, beacons, triangulat* 1 or cool Street View or StreetView CityBlock or City Block

The asterisk symbol is intended as a wildcard. 130

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Location-based services or LBS Location or Wi-Fi or WiFi in the same document as advert* or revenue Apple or *apple.com in the same document as Wi-Fi or Wi-Fi or data Wi-Fi location database Any search term identified in the document entitled Skyhook v. Google ESI Information.pdf that was sent via email to Skyhooks counsel by Tom Lundin on March 27, 2013.

RESPONSE TO REQUEST FOR PRODUCTION NO. 316: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks any financial information predating December 21, 2010, the earliest issue date of the patents in Skyhooks Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google.

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/s/ Sanjeet K. Dutta William F. Abrams (pro hac vice) Sanjeet K. Dutta (pro hac vice) John O. Gilmore (pro hac vice) KING & SPALDING LLP 333 Twin Dolphin Drive Redwood Shores, CA 94065 Telephone: (650) 590-0700 wabrams@kslaw.com sdutta@kslaw.com jgilmore@kslaw.com Thomas C. Lundin Jr (pro hac vice) KING & SPALDING LLP 1180 Peachtree Street Atlanta, GA 30309 Telephone: (404) 572-2808 tlundin@kslaw.com Jonathan M. Albano, BBO #013850 Susan Baker Manning (pro hac vice) Robert C. Bertin (pro hac vice) BINGHAM McCUTCHEN LLP One Federal Street Boston, MA 02110-1726 Telephone: (617) 951-8000 jonathan.albano@bingham.com susan.manning@bingham.com r.bertin@bingham.com ATTORNEYS FOR DEFENDANT AND COUNTERCLAIMANT GOOGLE INC.

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EXHIBIT A GENERAL OBJECTIONS 1. Google incorporates by reference each and every General Objection, Objection

To Definitions, and Objection To Instructions stated herein into each and every objection to an individually numbered request in the Third Requests. Googles failure to include a General Objection, Objection To Definitions, or Objection To Instructions in a response to an individually numbered request shall not be interpreted as a waiver of that General Objection, Objection To Definitions, or Objection To Instructions. 2. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 3. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information that are not relevant to the claims or defenses in this action, or not reasonably calculated to lead to the discovery of admissible evidence. 4. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation. 5. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is overly broad, unduly burdensome, or oppressive.

A-1

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6.

Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information not in Googles actual knowledge, possession, custody, or control; that is within Skyhooks knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. 7. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information without temporal limit or qualification, or is not limited to the relevant time period under 35 U.S.C. 286. 8. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information protected by the attorney-client privilege, the attorney work product doctrine, or any other applicable law, privilege, doctrine, or other immunity from discovery. Google will not disclose any information so protected, and the inadvertent disclosure or identification of any such information is not intended as, and will not constitute, a waiver of such privilege, doctrine, or immunity. 9. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery that calls for a legal conclusion. 10. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery that is properly the subject of expert testimony.

A-2

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11.

Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery concerning products that are not accused in this action. 12. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is cumulative or duplicative; seeks documents or information already provided to Skyhook in response to other discovery in this action; or seeks documents or information obtainable from another source that is more convenient, less burdensome, or less expensive. 13. Discovery in this action is not yet complete. Google will conduct a diligent

search and reasonable inquiry in a good faith effort to discover documents responsive to the Third Requests and will produce relevant, responsive, non-privileged documents, subject to its general and specific objections, of which it becomes aware. Google reserves the right to amend and/or supplement its objections and responses to the Third Requests if and when any additional facts, information, or documents are discovered. Additionally, because Google bases its objections and responses on facts, information and documents that Google has identified to date, the foregoing objections and responses shall not preclude Google from later relying on facts, information, or documents discovered or generated pursuant to subsequent investigation or discovery. Googles partial objection or response to any portion of the Third Requests shall not be construed as a waiver of any of its objections or responses, or its right to object or respond, to any other portion of the Third Requests. Google reserves the right to object to the relevance and/or admissibility of any information or documents provided in response to the Third Requests.

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14.

Googles response to the Third Requests, and each individually numbered request

incorporated therein, is hereby made without in any way waiving or intending to waive, but rather, to the contrary, by preserving and intending to preserve: (a) All questions as to the competence, relevance, materiality, and admissibility as evidence for any purpose of the information or documents, or the subject matter thereof, in any aspect of this investigation or any other action or judicial or administrative proceeding or investigation; The right to object on any ground to the use of any such information or documents, or the subject matter thereof, in any aspect of this investigation or any other action or judicial or administrative proceeding or investigation; The right to object at any time for any further response to this or any other request for information or production of documents; and The right at any time to supplement this response.

(b)

(c) (d) 15.

By agreeing to produce documents in response to a particular request, Google

does not represent or acknowledge that such responsive documents exist. OBJECTIONS TO DEFINITIONS 1. Google objects to the Definitions set forth in the Third Requests to the extent that

any Definition purports to enlarge or alter in any way the plain meaning and scope of any specific request on the grounds that such enlargement or alteration renders the request vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation. 2. Google objects to the Third Requests to the extent that any Definition, or any

request by its incorporation therein, to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

A-4

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3.

Google objects to the definition of 954 Patent because Skyhook has stated that

it is not asserting the 954 Patent in this action. 4. Google objects to the definition of 245 Patent because the Court held the 245

Patent invalid. See D.I. 96. 5. Google objects to the definition of 988 Patent because the Court held the 988

Patent invalid. See D.I. 96. 6. Google objects to the definition of Communication to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 7. Google objects to the definition of Concerning or Relating to to the extent

that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; and as vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation, and unintelligible, including without limitation because the definition includes the defined term relating to. 8. Google objects to the definition of Document to the extent that it is inconsistent

with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 9. Google objects to the definition of Google, Defendant, You, and Your as

overly broad, unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of

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admissible evidence, to the extent that it purports to include all related entities, parents, subsidiaries or divisions, and any predecessor or successor entities and any of its officers, directors, agents, attorneys, consultants, accountants, employees, representatives, contractors, and any other persons acting, or purporting to act for or on its behalf. Google interprets any reference to Google, Defendant, You, or Your in the Third Requests as referring to Google Inc. and will provide only responsive, non-privileged information that is in the possession, custody, or control of Google. 10. Google objects to the definition of Google Location as overly broad and unduly

burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, to the extent that it purports to include any products, systems, or processes not properly accused in this action or not within the scope of discovery in this action. Google interprets any reference to Google Location in the Third Requests as referring solely to the accused aspects of the accused product. 11. Google objects to the definition of Google Wi-Fi Location Database as vague,

ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. Google hereby incorporates its objections to the definition of Software. 12. Google objects to the definition of Mobile Advertising as overly broad, unduly

burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence.

A-6

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13.

Google objects to the definition of Location Determination Technologies as

vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. 14. Google objects to the definition of Location-Based Advertising as vague,

ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that it purports to incorporate the definition of Location Determination Technologies. Google hereby incorporates its objections to the definition of Location Determination Technologies. 15. Google objects to the definition of Android, Android Operating System,

Android OS, Google Maps, Google Latitude, Mozilla Firefox, Google Toolbar, and My Location to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. 16. Google objects to the definition of Patents-in-Suit to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those

A-7

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imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that it purports to include the 945 Patent, which is not asserted; or the 245 Patent or 988 Patent, which the Court held invalid. See D.I. 96. 17. Google objects to the definition of Related Patents to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that the term is used in any request in connection with the term Patentsin-Suit. 18. Google objects to the definition of Skyhook as overly broad, unduly

burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, to the extent that it purports to include all related entities, parents, subsidiaries or divisions, and any predecessor or successor entities and any of its officers, directors, agents, attorneys, consultants, accountants, employees, representatives, and any other persons acting, or purporting to act for or

A-8

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on its behalf. Google interprets any reference to Skyhook as referring to Skyhook Wireless, Inc. 19. Google objects to the definition of Skyhook Technology as vague, ambiguous,

and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, as seeking a legal conclusion, as seeking expert testimony, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, and as seeking information that is not within Googles knowledge, possession, custody, or control to the extent that it purports to include Skyhooks intellectual property, products, proposed products, systems, or processes, including the inventions claimed in Skyhooks patents, Skyhooks Wi-Fi positioning system, and Skyhooks XPS positioning system. 20. Google objects to the definition of Software as vague and ambiguous, overly

broad and unduly burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or is not reasonably calculated to lead to the discovery of admissible evidence. 21. Google objects to the definition of Android and Android OS to the extent that

it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence.

A-9

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22.

Google objects to the definition of Android Enabled Mobile Phone or Tablet to

the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. OBJECTIONS TO INSTRUCTIONS 1. Google objects to Instruction A to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties, including without limitation to the extent that it purports to require production of information in the possession of Your present and former attorneys, accountants, advisors, representatives, agents, employees, or other persons directly or indirectly employed by, or connected with, You or Your attorneys, and anyone else otherwise subject to Your control. 2. Google objects to Instruction B to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties, including without limitation rules, orders, agreements, or stipulations concerning production of electronically stored information. 3. Google objects to Instruction C to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal

A-10

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Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 4. Google objects to Instruction D on the grounds that it is an improper interrogatory

and to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 5. Google objects to Instruction E-G to the extent that they are inconsistent with or

seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Courts Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

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CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I am a citizen of the United States, over the age of 18, and am not a party to the within action. I am employed in the City of Redwood City, County of San Mateo, and my business address is 333 Twin Dolphin Drive, Suite 400, Redwood Shores, California, 94065. I am readily familiar with the firms practice of collection and processing of documentation for business mailing. On May 2, 2013, following ordinary business practices, I served the foregoing document entitled GOOGLE INC.S OBJECTIONS AND RESPONSES TO SKYHOOK WIRELESS, INC.S THIRD SET OF REQUESTS FOR PRODUCTION on the parties in this action by causing a true copy thereof to be emailed to the addressees at the e-mail addresses indicated below:

Douglas R. Tillberg Griesinger, Tighe & Maffei, LLP 176 Federal Street, Suite 400 Boston, MA 02110 Telephone: (617) 542-9900 Facsimile: (617) 542-0900 dtillberg@gtmllp.com

Matthew D. Powers Tensegrity Law Group, LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 (650) 802-6010 matthew.powers@tensegritylawgroup.com Skyhook_Service@tensegritylawgroup.com

I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. /s/ Diana Sciamanna Diana Sciamanna

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EXHIBIT 7

Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 2 of 12


Tuesday, J une 4 , 2 013 1 :25:38 P M P acic Daylight Time

Subject: Skyhook v. Google: ESI and Mr. Brin's Documents Date: Monday, June 3, 2013 8:51:33 PM Pacific Daylight Time From: To: CC: Azra Hadzimehmedovic Lundin, Tom, Abrams, William, Dutta, Sanjeet Skyhook_Service, dl.zzmgoogleskyhookext@bingham.com, Google/Skyhook K&S, Pada, Roxane

Dear Sanjeet and Tom, This email responds to the following two issues addressed in Tom's email attached below: ESI Search Terms for Skyhook 2 and Mr. Brin's document production. This also includes the search strings we are proposing for production of documents related to Apple, which Sanjeet and I discussed. ESI RELATED ISSUES-- First, Google's apparent failure to identify any documents for production pursuant to Skyhook's Third Set of RFPs nearly 1 month after these responses were due and its failure to identify any additional search terms relevant to that set of requests and Skyhook's 9 patents asserted in Skyhook 2 is improper. Google's position that no additional documents ought to be collected is untenable given that Skyhook has asserted an additional 9 patents since Google has created its original search term lists and that list (as shown below) is clearly deficient. We reserve our rights with respect to these issues, but in an attempt to move the process along, and responding to Google's request that Skyhook identify search terms, we do so below. Please note that this does not absolve Google from searching for responsive documents on its shared drives, wikis and similar repositories (collectively, "shared repositories"), and to the extent possible, the same search terms should be applied to Google's shared repositories. I. PLEASE AMEND THE EXISTING LIST OF SEARCH TERMS AS FOLLOWS: Many of Googles searches have proximities of two to five words. This is too limiting. Therefore, for at least the search strings highlighted in yellow in the attached, please replace those proximities with W/10. Add patent numbers for Skyhooks Patents in its Amended Complaint that are not on Googles ESI list already, including adding the full patent numbers and also the three last numbers, for example, the following string for the 219 patent: 8054219 or 8,054,219 or *219 w/5 patent Add WLAN or wireless to each string involving Wi-fi II. PLEASE ADD THE FOLLOWING SEARCH STRINGS: WPS Android w/20 (cityblock or citi block or streetview or street view or driv!) Android and ((AP or "access point" or wifi or wi-fi or Wi?Fi or WLAN or wireless) w/10 (collect! Or scan! Or target or area or all or substantial!)) Collect! w/5 (Android or user or handset or mobile) (Wifi or Wi?Fi or wi-fi or wireless or WLAN or "access point*" or AP or (Google w/5 Location) or GLL or GLS or LBS) w/20 (advertis! or "ad" or "ads" or "LBA*") Android w/3 (advertis! or ad or ads or LBA*) ("mobile advertis! " or "local advertis!" or "location-based advertis! " or "hyperlocal advertis!" or "local ads" or mobile ads or location-based ads or hyperlocal ads or LBA*) W/20 (strategy or plan) ("mobile advertis! " or "local advertis!" or "location-based advertis! " or "hyperlocal
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advertis!" or "local ads" or mobile ads or location-based ads or hyperlocal ads or LBA*) w/20 (analysis OR report OR survey OR study) ("mobile advertis! " or "local advertis!" or "location-based advertis! " or "hyperlocal advertis!" or "local ads" or mobile ads or location-based ads or hyperlocal ads or LBA*) w/20 royalt* royalt* w/20 (LBS or GLS or NLP) (license or contract or eula) and ((Google w/10 location) or GLS or LBS) (mov! Or relocate! Or present) w/10 (AP or "access point" or wifi or wi-fi or Wi?Fi or cache!) Aperture w/10 (AP or "access point" or wifi or Wi-Fi or WLAN or wireless or cluster) (mov! Or relocate! Or present) w/20 (MaxLRE or algorithm or cluster) (Distance or threshold) and GPS and (AP or "access point" or wifi or cluster) ((satellite!) w/10 (raw or 2 or two or 3 or three)) and (AP or "access point" or wifi or wi-fi or Wi?Fi) (calc* or estimat* or determine*) w/10 (locat* or position*) w/10 (error or accura*) cach! w/10 (AP or "access point" or wifi or wi-fi or Wi?Fi or prefetch! or station! or move!) wifi.cach! (GPS or (assisted GPS) or triangulat*) and ((Google w/5 location) or GLS) and (Wi-fi or Wifi or Wi?Fi or WLAN or wireless or (access w/3 point) or WAP or AP) (Wi-fi or Wifi or Wi?Fi or WLAN or wireless or (access w/3 point) or WAP or AP) w/5 (GPS or locat* or position) ACD w/50 GPS CDD w/50 GPS Compatib* w/50 GPS LocationManager w/50 (GPS or satellites) (Qualcomm or Texas Instruments or TI) and GPS Wifiscan ActiveCollector LocatorManager Wifilocalizerinterface wificlustering ClientlocationEstimation locserver NetworkLocator Aple WifiLocationEstimator MaxLreLocalizer WifiLocator Wifilocalizer Wifipoint ClientReporter NetworkLocationClient ap_stats gls_locator GlsClient GlsLocatorResult (MacWorld or Mac World) and (Apple or Jobs or location or driv* or beacons or triangulat*) (Apple or Jobs) and (location or WiFi or Wi-Fi or wireless or WLAN)
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Second, we propose Thursday at 4 PM Eastern for the exchange of Skyhook's search terms and custodians from the state court case and Google's clear identification of the custodians and search terms applied in each of the two cases. MR. BRIN'S DOCUMENTS-- As I told Sanjeet on our meet and confer on Friday, Skyhook cannot just accept Google's representation that its search of Mr. Brin's documents yielded no relevant document. As a compromise, we are willing to significantly narrow the list of search terms for Mr. Brin's documents, so we propose that Google run only the following searches on Mr. Brin's emails and other files and produce all documents responsive to those searches: i. Skyhook ii. (Ted or Edward) w/3 Morgan iii. (Mike or Michael) w/3 Shean iv. (MacWorld or Mac World) and (Apple or Jobs or location or driv* or beacons or triangulat*) v. Location-based services or LBS or GLS vi. (Location or Wi-Fi or WiFi or Wi?Fi or wireless or WLAN) and (advert* or revenue or value) Please get back to us on both of these issues no later than Friday, June 7, but please do confirm your agreement to the Thursday exchange tomorrow. Thank you. Best, Azra
AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Wednesday, May 29, 2013 10:08 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "Abrams, William" <BAbrams@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Subject: RE: Skyhook v. Google -- Follow-up on meet and confer today

Azra Thanks for your below message. This message responds to your comments and questions,
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and follows up on our meet and confer call Friday and your request that Google provide responses by today on certain specific issues that you raised. I. Response To Your Below Message Sent This Afternoon A. Googles Motion to Limit Number of Asserted Claims and Require New Infringement Contentions Your response to Googles good faith attempt to meet and confer to narrow the dispute misses the point of Googles motion. Googles motion seeks to reduce the number of claims in suit to reduce the unreasonable burden (i) on Google in having to provide non-infringement and invalidity contentions for at least 89 claims, (ii) on Skyhook in having to analyze Googles contentions, and (iii) on the court in potentially having to address disputes about those contentions. This is particularly the case where Skyhook concedes that the number of claims needs to be narrowed or limited, but asserts that it is premature to do so at this stage in part because Skyhook has not received non-infringement and invalidity contentions from Google. It is not premature for Skyhook to limit the claims in suit to those that it reasonably expects to assert at trial. This is true at least for the reason that Skyhooks expert has been reviewing Googles source code that explains the operation of the accused products for years at this point, and as a result Skyhook should be in a position to narrow its claims. This fact distinguishes the situation in this case from other cases where claims were narrowed at a later stage. As for Skyhooks suggestion that its narrowing of its claims in suit should be contingent upon Googles agreement to limit the number of invalidity references on which it will rely, the number of Googles invalidity references will be narrowed by necessity when Skyhook limits the number of claims in suit no separate agreement is necessary on that point. Second, concerning the separate issue of Skyhooks infringement contentions, your response again misses the point. It would be unduly burdensome and wasteful for Google to respond to, and the parties to have to engage in discovery concerning, invalidity contentions that are deficient when the contentions can and should be corrected, and should be focused on a more limited set of claims in suit. As you know, Googles invalidity contentions and the agreed-to non-infringement contentions are due on June 15. We have made clear the basis for Googles motion and attempted in good faith to resolve or narrow the dispute, but Skyhook has refused. Unless Skyhook is willing to reverse the position stated in your below response, to meaningfully limit its claims prior to the deadline for Googles invalidity and non-infringement contentions, Google intends to file its motion and to seek expedited consideration by the Court. B. Corporate and Individual Depositions We again confirm that Google will designate corporate representative witnesses for some topics pending the resolution of its motion for protective order. As we understand your below message, that confirmation addresses most of your questions. With respect to the timing of Googles designations, Google will work with Skyhook to determine a mutually agreeable date and time when both parties are prepared to identify designees and discuss the scheduling of corporate witnesses, and to discuss the scheduling of the noticed individual depositions. Google has asked for dates for Skyhooks corporate and individual deponents. To date, Skyhook has not suggested a date and time when it is prepared to designate and discuss scheduling of its witnesses. As noted below, Sanjeet will be available on Friday to continue the conferral concerning Googles responses to Skyhooks document requests, and to begin the discussion concerning scheduling, which will need to encompass some dialog concerning witness availability to avoid double-tracking depositions. Responding to your more general point under this heading, Google committed to further
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consideration of several topics raised in our conferrals on May 16 and 20 concerning Skyhooks 30(b)(6) notice. We have responded concerning Googles position concerning some of those, we respond below to your repeated requests concerning others, and we continue to consider still others. As I noted in our Friday conferral, we are in the process of parsing and responding to your 18-page letter sent Thursday, which unhelpfully reiterates positions set forth in your previous letters rather than focusing on and summarizing the parties discussions, and we will respond to remaining issues in that letter in due course. C. Ongoing and Upcoming Conferrals We believe that the below information addresses most of your message under this heading. As I stated during our conferral last Friday, I am not available at any time this Friday. Sanjeet will be available on Friday at 2 p.m. PDT. Thank you for informing us that you represent Mr. Fjeldsoe-Nielsen. We look forward to receiving alternate dates that are in the near future. II. Follow-Up On Friday Conferral And Requested Responses A. ESI Exchange/Information First, the parties exchanged certain ESI information approximately two months ago, on March 27, 2013. Google provided a consolidated list of shared ESI locations, custodians, and search terms used for both the state case and the Skyhook I case, inasmuch as the documents were deemed cross-produced; Skyhook provided a list of shared ESI locations, custodians, and search terms used for the Skyhook I case. Following that exchange, Skyhook posed certain questions concerning Googles ESI disclosure, and Google answered all of Skyhooks questions and, in one example, agreed to provide a separate list of custodians and search terms for each of the state and Skyhook I cases, if Skyhook would agree to provide the same. See my April 22, 2013 email message to you. At the same time that Google provided answers to all of Skyhooks initial questions, Google asked certain initial questions of Skyhook. See id. Skyhook did not answer Googles questions. Instead, Skyhook stated that a reciprocal exchange of information would be agreeable, but made that exchange contingent upon Googles responding to another set of questions from Skyhook. See your May 2, 2013 email message to me. As we have discussed multiple times since then, Google is working diligently to determine whether it has and can provide to Skyhook answers to those additional questions. At this time, we can provide answers to three of the six questions, noted below. While Google continues to investigate the remaining questions, to move the ESI discussion or conferral forward, we propose that (1) the parties exchange the agreed-to information, i.e., the separate lists of shared sources, custodians, and search terms for the state and Skyhook I cases; and (2) Skyhook provide answers to the three questions that Google asked on April 22. Googles three questions are akin to the five questions that Skyhook initially asked, and that Google fully answered, and there is no reason why Skyhooks responses to those questions should be contingent upon Google answering all six of Skyhooks additional questions. If Skyhook agrees to the exchange in Item (1), but not to provide the answers in Item (2), please explain the basis for Skyhooks refusal. This proposal moots Skyhooks threatened motion to compel on this issue stated in your below message. The three answers to the questions in your May 2 email that we can provide now are: (1) Based on your email, we understand that Google has provided to us a combined collection of terms and custodians for state and federal cases. Google should explain which terms it used and which custodians it searched for each of the actions and for which time periods. Google agrees to provide this information as part of the reciprocal exchange of separate lists for the state and Skyhook I cases. (5) What are "CLL and MADA documents" you referred to?

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(5) What are "CLL and MADA documents" you referred to? CLL stands for Client Location Library; MADA stands for Mobile Application Distribution Agreement. We have agreed to identify for Skyhook the document production numbers of those documents in Googles production. Our initial identification of CLLs/MADAs, or documents concerning CLLs/MADAs, includes documents bearing the following production numbers: GOOGSKYFED_0532029, GOOGSKYFED_0532032, GOOGSKYFED_0532064, GOOGSKYFED_0532120, GOOGSKYFED_0532488 - GOOGSKYFED_0532499, GOOGSKYFED_0532500 - GOOGSKYFED_0532522, GOOGSKYFED_0532548 GOOGSKYFED_0532569, GOOGSKYFED_0532570 - GOOGSKYFED_0532580, GOOGSKYFED_0532584 - GOOGSKYFED_0532585, GOOGSKYFED_0532701 GOOGSKYFED_0532710, GOOGSKYFED_2477194 - GOOGSKYFED_2477861, GOOGSKYFED_2477862 - GOOGSKYFED_2477909, and GOOGSKYFED_2478565 GOOGSKYFED_2478586. (6) Did Google apply search terms to the "shared sources" (defined above under 2), and if so, which search terms were applied to which shared source and for which time period? Google applied the search terms to the custodian sources. Documents gathered from shared sources were identifiable by category. B. Search Terms for Skyhook II Patents You demanded, under the threat of a motion to compel, that Google provide a response by today on whether Google was willing to apply additional search terms for the Skyhook II patents and, if so, what search terms. As we have stated in previous conferrals, Googles initial assessment was that no additional search terms would be required as a result of the inclusion of the Skyhook II patents, inasmuch as the same accused products are at issue for which documents already have been identified, gathered, and produced. We stated that Google was carefully continuing to evaluate that position, and having done so, Google maintains that position. Google is willing to consider, and confer with Skyhook on a list of additional terms that Skyhook believes are relevant to the Skyhook II patents that are not included within or fairly represented by the list of search terms used in the Skyhook I and state cases. Skyhook has had Googles consolidated list of search terms used in those cases for more than two months, yet it has not proposed any additional terms that it believes Google should use. Google has conducted its analysis and concluded that none are required; if Skyhook wishes to propose additional terms, Google is willing to consider them. Any motion practice concerning ESI terms for Skyhook II would be premature until Skyhook proposes a list of additional terms that it believes are required and Google has had a chance to consider them, and this proposal moots Skyhooks threatened motion to compel on this issue. C. RFP 316 of Skyhooks Third Set of RFPs, seeking documents of Sergey Brin You demanded, under the threat of a motion to compel, that Google provide a response by today to the question of whether there was a subset of search terms that it would agree to use to search Mr. Brins documents, and if so that Google provide a concrete proposal as to those search terms. Google maintains its position that Skyhook has failed to show any reason to believe that Mr. Brin has any personal knowledge of any issues relevant to the claims or defenses in this action and, accordingly, has failed to show any basis for searching Mr. Brins documents. Without waiving or in any way deviating from that position, in response to your request, Googles proposal is that it search Mr. Brins emails for the terms Skyhook, Ted Morgan, and Macworld. Google has performed those searches. No documents indicating that Mr. Brin has any personal knowledge of any issue relevant to the claims or defenses in this action have resulted. This proposal and searches moot Skyhooks threatened motion to compel on this issue.
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D. RFP 223 and 224, seeking license agreements and settlement agreements Google has identified certain CLL and MADA agreements in its production, and explained the meaning of those acronyms, above. Google will be producing additional settlement agreements that it has identified that may be responsive to these requests. Google currently is not aware of any additional documents responsive to these requests. Once Skyhook has reviewed the CLL and MADA agreements that Google produced, some as long ago as November 2012, and that Google has identified in its production, if Skyhook has additional questions, Google will endeavor to respond. This response moots Skyhooks threatened motion to compel on this issue. Please let us know when we can expect to receive the supplemental Skyhook production of recent technology agreements, e.g., with Comodo, that Skyhook agreed to produce. E. Identification of Location of Google Servers You demanded, under the threat of a motion to compel, that Google provide a response by today on the proposal in your 18-page letter sent Thursday that Google provide City and State information for the location of its servers. Google does not agree to Skyhooks proposal. As Google has stated on previous occasions, the location of Googles servers in the United States is not relevant to any issues in this action. Google has offered to stipulate that Google servers are located in the United States, and that requests from within the United States go to servers located in the United States. Google has noted that such a stipulation, or a sworn interrogatory response, has the same evidentiary value to Skyhook as witness testimony. Nevertheless, although Google will not produce documents identifying the location of its servers, it will designate a corporate witness to testify to the facts as stated in Googles proposed stipulation. This agreement moots Skyhooks threatened motion to compel on the issue of a corporate representative on this topic. F. Worldwide Data As we agreed to do in our conferral concerning Googles objections to Skyhooks Amended Rule 30(b)(6) Notice, Google has further considered its position on production of worldwide data. Google maintains its position that worldwide data is not relevant to any claims or defenses in this action. We have considered your suggestion of scenarios where worldwide data purportedly might be relevant, including purportedly in connection with objective indicia of nonobviousness, and we disagree with your arguments. G. Documents Concerning Advertising Revenue As we agreed to do in our conferral concerning Googles objections to Skyhooks Amended Rule 30(b)(6) Notice, Google has further considered whether any additional financial information concerning location-related advertising can be produced. Without waiving its objections and position that such information is not relevant to any claims or defenses in this action, Google has identified and will produce additional financial documents concerning mobile advertising revenue. Google already has agreed to designate corporate witness(es) to testify concerning the financial documents produced in this action, and such witness(es) will be prepared to testify concerning these additional documents. This agreement moots Skyhooks threatened motions to compel concerning corporate representative testimony and document production. H. Identification of Dashboards

In our conferral concerning Googles objections to Skyhooks Amended Rule 30(b)(6) Notice, Google agreed to identify the dashboards that it has produced. The Dashboards are in the following document production number range GOOGSKYFED_0000001 GOOGSKYFED_0007899.
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Please let us know if you have any questions. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Wednesday, May 29, 2013 4:55 PM To: Lundin, Tom; Abrams, William Cc: Skyhook_Service; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Pada, Roxane Subject: Re: Skyhook v. Google -- Follow-up on meet and confer today

Tom, thank you for your message below. Google's Threatened Motion Regarding Number of Asserted Claims and Infringement Contentions First, Google's request that Skyhook limit its asserted claims on the 11 patents-in-suit to a total of 20 at this stage is premature. Google has not yet served its invalidity or non-infringement contentions, has not provided a single fact witness in corporate or individual capacity, and has not even commenced its production relevant to the 9 "Newly Asserted" patents. Nothing in the cases Google has identified to us suggests otherwise, and in fact, those cases support Skyhook's position. We are willing to entertain a meaningful, reciprocal agreement where Skyhook would narrow the number of claims and Google would narrow the number of invalidity references, and we are willing to discuss the appropriate timing for such narrowing and even limits that may make sense. But to be clear, the time for such narrowing is not now. Second, we see no reason why it would be appropriate at this time to amend Skyhook's contentions to respond to the few, minor alleged deficiencies Google has identified, and moreover, how these alleged issues could be in any way impeding Google's ability to provide non-infringement or invalidity contentions. Skyhook intends to take discovery on the areas Google identified, and we are willing to prioritize related corporate and individual depositions, but without such discovery, we do not believe it is proper to seek our amendments now. This is so in particular because Google should be more than able to serve its noninfringement contentions in response to Skyhook's existing contentions. For example, Google complains that Skyhook accused the Gears API that may have been discontinued during a portion of time for which Skyhook may be seeking damages. First, we need to take discovery to ascertain the exact timing of the transition from the Gears API to a new API and the circumstances surrounding it. Your current interrogatory response on the issue is not sufficient and does not warrant our supplementation at this time. Second, it is Google who should know when and how Google switched from Gears API to the API it currently uses and it can provide that detail in its noninfringement contentions. Similarly, with respect to whether Google believes that it is Qualcomm chip that performs some of the infringing functionality for the 219 patent, Google should state the basis for its belief in its noninfringement contentions, and Skyhook plans to examine Google's witnesses on the scope of their knowledge about this functionality. In short, even if the few alleged deficiencies in Skyhook's contentions were real, which they are not, they are not a reason to postpone
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the service of Google's contentions. Corporate and Individual Depositions With respect to scheduling of Skyhook's corporate depositions of Google's witnesses, we understand from your last email that Google will not insist on waiting for the Court to resolve Google's motion for protective order, but will proceed to schedule corporate depositions. Will you be ready this Friday to identify your corporate witnesses, the topics they will be testifying about, and their availability and also confirm individual noticed deponents' availability ? Further, if we misunderstood your last email (and you are refusing to schedule any corporate depositions), then please confirm that you will proceed to schedule the individual depositions Skyhook has noticed whether or not you expect the same witness to be called later as a corporate witness after Google's motion has been resolved. Please respond today. On a more general point, as my May 23 letter described in great detail, Skyhook's understanding until the moment Google filed its motion for protective order was that Google specifically committed to reconsidering its objections to Skyhook's Rule 30(b)(6) topics. We had requested your responses on most topics by last Friday and on a couple of topics by today. Please provide those responses today, and if you are not going to provide them, please let us know so that we can accurately reflect the state of play to the Court. Ongoing and Upcoming Meet and Confers First, we are expecting today your response on the Skyhook 1 and 2 ESI issues we have been discussing. That is, we have asked that you tell us when you will be ready to exchange information we have been discussing and to tell us search terms you intend to use for Skyhook 2 production. Second, we are available on Friday, between 1 and 4 PM Eastern, to continue our discussion regarding Google's responses to Skyhook's Third Set of RFPs. Please be prepared to give us your responses on the issues we have previously discussed. At the same time, we are available to discuss Skyhook's objections to Google's corporate notice and Bain Capital's objections to Google's subpoena. We plan to make Mr. Agarwal available but only after Google narrows the scope of its document requests to Mr. Agarwal and Bain and these third parties are able to complete their production. Of course, if you are satisfied with the scope of production Bain and Mr. Agarwal have agreed to produce, we will proceed under that agreement. Third, we represent Mr. Lars Fjeldsoe-Nielsen. Due to a previously planned trip to China, he is not available on the noticed date, but we should be able to provide an alternative date shortly. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP


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555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Friday, May 24, 2013 8:17 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "Abrams, William" <BAbrams@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Subject: Skyhook v. Google -- Follow-up on meet and confer today

Azra and Aaron Im writing to follow up on two issues discussed in our conferral this afternoon. First, you asked whether the filing today of Googles Motion For Protective Order with respect to Skyhooks Second Amendment to Rule 30(b)(6) Notice meant that Google would refuse to provide any corporate representative witnesses until the motion was resolved. The answer is no. As stated in the motion itself, Google does not dispute that some topics in Skyhooks 30(b)(6) notice are relevant. We requested that Skyhook narrow the notice so that Google could prepare witnesses and the parties could move forward, but Skyhook refused. Nevertheless, Google is willing to provide corporate representative witnesses for reasonable topics of reasonable scope. In connection with the scheduling of Rule 30(b)(6) witnesses, please let us know when Skyhook is prepared to discuss scheduling of its designees in response to Googles Rule 30(b)(6) Notice. Second, we met and conferred concerning Googles request that Skyhook reduce the number of claims in suit from at least 89 currently to a maximum of 20 or 30. I provided you several reasons why we believe that such a reduction would promote judicial economy and efficient management of the case for the parties and the Court. We also discussed Googles request that Skyhook provide new infringement contentions for the reduced set of patent claims that correct inadequacies in its current infringement contentions. You asked that we provide you with our requests, bases therefor, and supporting authority in writing. In response, Ive attached a draft of a motion requesting that the Court issue an order requiring Skyhook to reduce the number of asserted claims and provide adequate infringement contentions. The draft motion is provide in connection with Googles good faith attempt to narrow the dispute and without prejudice to its right to modify the motion before filing, if Skyhook does not agree to the relief Google is requesting. In view of the imminent deadline for Googles invalidity contentions, and agreed-to non-infringement contentions, please let us know by Wednesday whether Skyhook is willing to reduce the claims in suit and to provide new infringement contentions. Regards,
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Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

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EXHIBIT 8

Sergey Brin Photos - Steve Jobs Delivers Keynote Speech At Macworld Conference & Expo - Zimbio

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Steve Jobs Delivers Keynote Speech At Macworld Conference & Expo In This Photo: Sergey Brin, Chad Hurley (L-R) You Tube founder, Chad Hurley, Google CEO Eric Schmidt, Apple CEO and cofounder Steve Jobs and Google co-founder Sergey Brin, talk after Jobs delivered the keynote speech to kick off the 2008 Macworld at the Moscone Center January 15, 2008 in San Francisco, California. Apple CEO and co-founder Steve Jobs introduced the wireless Time Capsule backup appliance, iTV 2 and the new ultra thin laptop MacBook Air.
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Sergey Brin Photos - Steve Jobs Delivers Keynote Speech At Macworld Conference & Expo - Zimbio

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Home Sergey Brin Sergey Brin Pictures Steve Jobs Delivers Keynote Speech At Macworld Conference & Expo

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Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 1 of 5

EXHIBIT 9

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 2 of 5

Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Re: Skyhook v. Google -- No. 1:10-cv-11571-RWZ March 6, 2013 1:52 PM

Dear Bill, We have produced the TracBeam settlement agreement, and as required by that agreement, we have marked it Highly Confidential Attorneys' Eyes Only. That is, Google's in-house counsel or any Google employees cannot have access to it. Further, our production pursuant to Google's RFP 61 is complete. We similarly request that Google produce to Skyhook the documents produced in TracBeam case, including discovery responses and depositions, to the extent that those materials relate to Google Location,
Google Location Service, or Location-Based Advertising. See, e.g., Skyhook's RFPs 5, 6, and 122.

Thank you. Best, Azra


AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Abrams>, William <BAbrams@KSLAW.com> Date: Wednesday, March 6, 2013 12:32 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Cc: Aaron Nathan <aaron.nathan@tensegritylawgroup.com>, Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>, Douglas Tillberg <dtillberg@gtmllp.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Evans, Laura" <LEvans@irell.com>, "Lu, Sam (SLu@irell.com)" <SLu@irell.com>, "Lundin, Tom" <TLundin@KSLAW.com> Subject: RE: Skyhook v. Google -- No. 1:10-cv-11571-RWZ

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Dear Azra:

You have not responded to my February 25 email regarding Mr. Brin's deposition. Please confirm if Skyhook will withdraw the deposition notice. If not, Google will bring a motion for protective order that the deposition not proceed.

Bill

From: Abrams, William Sent: Monday, February 25, 2013 10:55 AM To: Azra Hadzimehmedovic Cc: Aaron Nathan; Skyhook_Service; Douglas Tillberg; Google/Skyhook K&S; Evans, Laura; Lu, Sam (SLu@irell.com); Lundin, Tom Subject: RE: Skyhook v. Google -- No. 1:10-cv-11571-RWZ

Dear Azra - You have not provided any support for your "understanding ... that Mr. Brin is knowledgeable on these topics and could offer testimony and perspective that is not directly available to Google's other witnesses." What is the basis for this understanding? We've asked you several times for this, but you have not provided any evidence to support it. Mr. Brin is a founder and senior leader of one of the largest companies in the world. Skyhook bears the initial burden of showing that a person in Mr. Brin's position has unique knowledge on relevant subject matter, i.e., not just his own perspective on information available from others or through other means. In addition, Skyhook must have actually sought the information in another, less burdensome way before seeking this deposition and establishing that it is necessary. Skyhook has not met any of its burdens, and there is no basis for imposing on Mr. Brin given the lack of any showing by Skyhook as we have stated. The deposition notice appears tactical and intended to harass Mr. Brin and Google, particularly given that the notice is served at the beginning of taking depositions in the case, before Skyhook has examined any witnesses regarding relevant subject matter. We are prepared to seek a protective order, and sanctions, if Skyhook does not withdraw the deposition notice for Mr. Brin. Bill

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Tuesday, February 19, 2013 3:33 PM To: Lundin, Tom Cc: Abrams, William; Aaron Nathan; Skyhook_Service; Douglas Tillberg; Google/Skyhook K&S; Evans, Laura; Lu, Sam (SLu@irell.com) Subject: Re: Skyhook v. Google -- No. 1:10-cv-11571-RWZ

Tom, Thank you for following up on our conversation on Friday. Yes, the parties have agreed to reschedule the currently noticed depositions and have also agreed not to wait for the Court to hold the hearing regarding Google's motion to consolidate, but to proceed in the meantime to work on rescheduling the previously noticed depositions. With respect to Skyhook's requests for Mr. Brin's deposition and production of relevant email, Google confirmed that it has not in fact spoken to Mr. Brin to determine whether he has

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 4 of 5

information relevant to Skyhook's case. Skyhook therefore requests that Google specifically confirm with Mr. Brin whether he has relevant knowledge in the following areas: (1) attendance and participation at Macworld 2008, including discussions relating to Skyhook's or Google's location technology; (2) discussions with Apple regarding Google's location-based services; (3) direction and management of the development of Google's location-based services; (4) value of location-based data to Google; (5) knowledge of and participation in discussions relating to Skyhook's location technology and Google's valuation and knowledge about that technology; and (6) decisions/discussions regarding the Motorola and Samsung deals and/or potential deals with Skyhook relating to location technology. If Mr. Brin is willing to submit a declaration that he has not participated in the activities outlined above and does not have any firsthand knowledge in these areas, then we would be willing to consider withdrawing our deposition notice and request for Mr. Brin's email. Our understanding, however, is that Mr. Brin is knowledgeable on these topics and could offer testimony and perspective that is not directly available to Google's other witnesses. Further, unless Mr. Brin is willing to declare under oath that he in fact has no relevant knowledge related to Skyhook's case, Google's objection to conducting targeted searches of his email on the limited topics Skyhook has identified is improper. Best, Azra
AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax) On 2/15/13 5:41 PM, "Lundin, Tom" <TLundin@KSLAW.com> wrote: Azra -- I'm confirming our conversation earlier today. We agreed that, with respect to the depositions noticed by each party thus far, neither party has the expectation that the depositions will occur on the dates set forth in the notices/subpoenas. With one exception, noted below, the parties will continue to work on identifying dates for the noticed witnesses and will communicate further on potential rescheduled dates.

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 5 of 5

The exception noted above applies to the deposition notice Skyhook issued for Mr. Brin. Although we did not discuss the Brin notice today, it was discussed during the Rule 26(f) conference on Monday, when Google reiterated its previously emailed objection and request that Skyhook withdraw the Brin notice. During the Rule 26(f) conference you proposed sending us some information concerning Skyhook's desire to depose Mr. Brin. We said that we would review the information, but did not withdraw our request that the notice be withdrawn. Please let us know whether Skyhook will agree to withdraw the Brin notice, so that we can determine whether Google needs to move for a protective order. Please don't hesitate to call with any questions. Have a good weekend. Regards, TCL King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 1 of 10

EXHIBIT 10

Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 2 of 10


Friday, J une 2 8, 2 013 4 :38:07 P M P acic Daylight Time

Subject: RE: Skyhook v. Google: ESI Terms Date: Thursday, June 27, 2013 6:26:28 PM Pacific Daylight Time From: To: CC: Dutta, Sanjeet Azra Hadzimehmedovic, Skyhook_Service, Douglas Tillberg Abrams, William, Pada, Roxane, Google/Skyhook K&S, dl.zzmgoogleskyhookext@bingham.com

Dear Azra: I write to respond to various issues we discussed on the phone yesterday. IT/e-mail Delivery When we spoke yesterday, you stated that Skyhook did not receive Tom Lundins message from Saturday evening. We confirmed that our local counsel (included in the distribution) did receive the message when it was sent. You stated that you would confirm whether your local counsel received the message and if there was any IT issue on your end. We want to make sure that you are receiving our correspondence at the time it is sent. Skyhooks Proposed Search Terms for Skyhook II (1) Googles estimated document counts are estimates that intend to exclude documents that are duplicative of the previously produced documents. (2) Google produced all responsive documents by performing a linear substantive (Responsive/NonResponsive) review of documents and their family members where at least one document in the family had a hit on one of the search terms. As discussed yesterday, the result of our running the search terms that your requested is that it demonstrates that Skyhooks proposed search terms are too broad and need to be narrowed. For example, these search strings that Skyhook provided are especially problematic in breadth: Apple Wifiscan ActiveCollector LocatorManager Wifilocalizerinterface locserver NetworkLocator WifiLocationEstimator MaxLreLocalizer WifiLocator ClientReporter NetworkLocationClient GlsClient GlsLocatorResult Android w/20 (cityblock OR citi block OR streetview OR street view OR driv~) Android AND ((AP OR "access point" OR wifi OR "wi-fi" OR Wi?Fi OR WLAN OR wireless) w/10 (collect~ OR scan~ OR target OR area OR substantial~)) Collect~ w/5 (Android OR user OR handset OR mobile) (Wifi OR Wi?Fi OR "wi-fi" OR wireless OR WLAN OR "access point*" OR AP OR (Google w/5 Location) or GLL or GLS or LBS) w/20 (advertis~ OR ad OR ads OR LBA*) (license OR contract OR eula) AND ((Google w/10 location) OR GLS OR LBS) (mov~ OR relocate~ OR present) w/10 (AP OR "access point" OR wifi OR "wi-fi" OR Wi?Fi OR cache~) (Distance OR threshold) AND GPS AND (AP OR "access point" OR wifi OR cluster) cach~ w/10 (AP OR "access point" OR wifi OR "wi-fi" OR Wi?Fi OR prefetch~ or station~ or move~) (GPS OR "assisted GPS" OR triangulat*) AND ((Google w/5 location) OR GLS) AND ("Wi-fi" OR Wifi OR Page 1 of 9

Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 3 of 10


(GPS OR "assisted GPS" OR triangulat*) AND ((Google w/5 location) OR GLS) AND ("Wi-fi" OR Wifi OR Wi?Fi OR WLAN OR wireless OR (access w/3 point) OR WAP OR AP) ("Wi-fi" OR Wifi OR Wi?Fi OR WLAN OR wireless OR (access w/3 point) OR WAP OR AP) w/5 (GPS OR locat* OR position) (Qualcomm OR Texas Instruments OR TI) AND GPS (Apple OR Jobs) and (location OR WiFi OR "Wi-Fi" OR wireless OR WLAN) The single word search strings are especially problematic. Google requests again that Skyhook provide a more reasonable set of search strings (including, by way of example only, fewer terms, with closer proximities, and with narrower Boolean connectors) that are more narrowly focused to target documents that Skyhook contends that it needs to prove the claims asserted in the consolidated case--that would not be duplicative of the information found in the vast volume of documents already produced. Production of Skyhook Witness Personal Documents On our call yesterday, you asked whether Google agreed to produce personal documents of its witnesses two weeks in advance of their depositions. Google does not agree to search personal documents of its employees. Skyhook has provided no reason why searching Googles personal documents would lead to any relevant documents. In contrast, Skyhooks document production demonstrates that its employees used personal e-mail accounts for business purposes. (See e.g., SKYFED6_000031143, SKYFED6_000022581 relevant to invalidity) Google explained to Skyhook that it seeks the deponents personal materials not in Skyhooks possession, custody or control that were not previously produced by Skyhook. Because Skyhooks witnesses were using personal and non-company emails on matters relevant to this case, as demonstrated in Skyhooks production, it is relevant for them to search personal and non-company emails. There is no such evidence for Googles employees. Please confirm that Skyhook will produce personal documents from its witnesses. Additional Google Witness Availability Vikram Gundotra is available for his deposition on July 24. Because Mr. Gundotras deposition would conflict with the date we provided for Arunesh Mishra, Mr. Mishra will instead be available on July 31 for his deposition. Case Schedule In View of Document Production Google received Skyhooks ESI Terms for Skyhook II on June 3. We worked diligently with Skyhook to accommodate Skyhooks overly broad and burdensome request for documents beyond the 2.5+ million pages already produced by Google. There was no delay by Google. In contrast, Skyhook has not yet completed its document production (for example, Skyhooks improperly redacted and withheld documents and documents responsive to Googles 4th set of RFPs). Yesterday, you stated that Skyhook would not agree to discuss a revised schedule considering Skyhooks new demand for review of roughly 640,000 documents that require 8 weeks to complete, and the parties ongoing document productions. Google requests that Skyhook reconsider its position before inconveniencing witnesses whose depositions are likely to occur before productions are complete. RFPs 199 and 304 When we spoke yesterday, you requested a response regarding Skyhooks RFP 199 (All Documents Relating To any agreements with Motorola, Samsung, LG, HTC, any other OEM, or any Person Concerning Google Location, including all documents reflecting negotiations concerning any such agreement.) As discussed, Google produced documents responsive to this RFP including: GOOGSKYFED_0532029, GOOGSKYFED_0532032, GOOGSKYFED_0532064, GOOGSKYFED_0532120, GOOGSKYFED_0532488 - GOOGSKYFED_0532499, GOOGSKYFED_0532500 - GOOGSKYFED_0532522, GOOGSKYFED_0532548 - GOOGSKYFED_0532569, GOOGSKYFED_0532570 - GOOGSKYFED_0532580, GOOGSKYFED_0532584 - GOOGSKYFED_0532585, GOOGSKYFED_0532701 - GOOGSKYFED_0532710,
Page 2 of 9

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GOOGSKYFED_2477194 - GOOGSKYFED_2477861, GOOGSKYFED_2477862 - GOOGSKYFED_2477909, and GOOGSKYFED_2478565 - GOOGSKYFED_2478586. Regarding RFP 304 (All Documents Relating to Googles use of location-based data in providing Location- Based Advertising or Mobile Advertising, including without limitation the use of AdWords service), Google continues to collect, review and produce documents responsive to this request. Any motion to compel would be premature considering the Googles efforts to accommodate Skyhooks request for documents responsive to the search terms discussed above. Deposition Location Google agrees to present its witnesses at Tensegritys offices in Redwood Shores. We appreciate your offer to provide break-out rooms. We will provide the same for Skyhooks witnesses at our offices in Redwood Shores and Binghams offices in Boston. Best regards, -sanj-
From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Wednesday, June 26, 2013 12:42 PM To: Dutta, Sanjeet; Skyhook_Service; Douglas Tillberg Cc: Abrams, William; Pada, Roxane; Google/Skyhook K&S; dl.zzmgoogleskyhookext@bingham.com Subject: Re: Skyhook v. Google: ESI Terms

Sanjeet, I understand from your voicemail today that you wish to discuss Google's production pursuant to Skyhook's ESI Terms and scheduling of related depositions. I am available at 5 Eastern/ 2 Pacific. Please call me at my desk. In fact, we were meaning to ask you for the following information so that we can determine whether we are at an impasse with respect to Google's production. To make sure we understand Google's position, we ask for the following clarifications: (1) Please confirm whether Google's estimated document counts in Tom's email include documents duplicative of the previously produced documents. My understanding from our meet and confer is that Google's system is able to generate a number of documents that would include only the newly identified, not previously produced, documents, so please provide that number, by each individual search string. And please confirm that these counts include or may include multiple copies of the same document, so that the total number of unique documents is less than the number you provided. If you have the number of unique, or "de-duped" documents, please provide that information, by search string. (2) Google's suggestion that it would have to review every single document responsive to a search string appears inconsistent with its prior statements. Our understanding based on our discussions regarding search-term methodology has been that Google has produced all non-privileged documents that included a search term or string; that is, Google has only implemented a privilege screen, not a further relevance review. For example, we asked whether Google has produced all non-privileged documents that included the term Skyhook, and Google responded that it has. April 22, 2013 Email from T. Lundin re: ESI from Skyhook 1. If our understanding is incorrect, please let us know and explain your April 22, 2013 response. If our understanding is correct, please provide counts, by search string, for the documents that would be caught by the privilege filter and which Google then may want to review. Could you please be prepared to provide this information to us at our meet and confer or work with your client to provide it to us by the end of the day tomorrow? Thanks very much. Best, Azra

AZRA HADZIMEHMEDOVIC
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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 5 of 10

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Dutta>, Sanjeet <SDutta@KSLAW.com> Date: Tuesday, June 25, 2013 1:34 AM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, Skyhook_Service <Skyhook_Service@tensegritylawgroup.com>, Douglas Tillberg <dtillberg@gtmllp.com> Cc: "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com> Subject: RE: Skyhook v. Google: Various Discovery Issues

Azra- Apologies for failing to attach Googles message from Saturday. It is attached now. -sanj-
From: Dutta, Sanjeet Sent: Monday, June 24, 2013 10:32 PM To: 'Azra Hadzimehmedovic'; Skyhook_Service; Douglas Tillberg Cc: Abrams, William; Pada, Roxane; Google/Skyhook K&S; dl.zzmgoogleskyhookext@bingham.com Subject: RE: Skyhook v. Google: Various Discovery Issues

Dear Azra- We have discussed at length since February that Mr. Brin is not relevant to any aspect of Skyhooks case. Skyhook noticed Mr. Brins deposition without any basis other than to harass one of the highest ranking executives and co-founder of Google. Google repeatedly asked Skyhook to explain Mr. Brins relevance to Skyhooks patent case. Skyhooks response provided no basis: We understand that Mr. Brin was at the Macworld event in January 2008 at which Apple announced that it was using Skyhook's location technology in its iPhone and that Mr. Brin had discussions with Apple representatives about that announcement and Google's displeasure with it. Skyhook has never provided any basis for its assertion that Mr. Brin has any connection to this case. We pointed out that roughly 50,000 persons attended Macworld in 2008 with Mr. Brin. Nevertheless, Google searched Mr. Brins emails for the terms Skyhook, Ted Morgan, and Macworld. No documents indicate that Mr. Brin has any personal knowledge of any issue relevant to the claims or defenses in this action. Google has conducted a reasonable search for documents from Mr. Brin, determined that the resulting
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documents are not relevant and has no obligation to conduct any additional searches. We will bring a motion for protective order and seek sanctions if Skyhook persists in this harassment. Regarding the ESI Search terms, Google responded on Saturday. In case you did not receive it, I am attaching Googles response that explains the large cost and burden involved in reviewing and producing documents that would result from Skyhooks over-broad search strings. Regarding depositions, Google confirms the availability of Mike Lockwood to appear on July 23. As we discussed during our meet and confer, Skyhook deposed Mr. Brady for two days in the state court action. Mr. Brady explained in his deposition that he manages partner relationships. Other than asserting that the state court case is different than the current case, Skyhook has not provided an explanation why Mr. Brady should be deposed again and in this patent case. Please explain what knowledge Skyhook believes Mr. Brady has that is specific to the issues of this patent case that Skyhook did not already cover in its two day deposition of Mr. Brady. Mr. Zelinka will be available for his deposition on July 10. Google disagrees that it is under any obligation to produce Mr. Zelinkas documents, solely because he will be one of Googles technical 30(b)(6) witnesses. Skyhook has not provided any authority or caselaw to the contrary. As we discussed, Google has produced millions of pages of documents including Googles source code that explains the operation of Googles product. In view of this, Skyhook has not provided any reason why Mr. Zelinkas documents are needed above-and-beyond Googles thorough production of technical documents. Regarding RFPs 254 and 255 which both ask for policies regarding third party patents, after a reasonable search, Google has not located any such policies. With regard to Skyhooks requests for Tracbeam discovery, Skyhook has not explained the relevance of Googles discovery responses in Tracbeam. The patents in the Tracbeam case are not related to the patents asserted by Skyhook and accordingly, Google should not bear the cost and burden of producing the transcripts and discovery responses that are not relevant to this action. If you have any questions, please let me know. Best regards,

_______________________________________

Sanjeet K. Dutta| Partner |King & Spalding LLP 333 Twin Dolphin Dr., Ste. 400 | Redwood Shores, CA 94065 Tel: 650.590.0730 | Cell: 408.644.4064 |sdutta@kslaw.com

From: Azra Hadzimehmedovic [mailto:azra@tensegritylawgroup.com] Sent: Sunday, June 23, 2013 9:35 PM To: Lundin, Tom; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service; Douglas Tillberg Subject: Skyhook v. Google: Various Discovery Issues

Dear Sanjeet, I write to follow up on our latest June 20 meet and confer, in particular since Skyhook did not receive the follow-up responses on several of these issues on Friday, June 21, which you had committed to provide. On each of the issues addressed below (except on Mr. Zelinka's documents), unless by close of business on Tuesday Google agrees to produce documents or provide confirmations Skyhook has been seeking for

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weeks now, Skyhook will move to compel production. Individual Depositions Skyhook Noticed on May 23: Google's explanation that its in-house counsel has been unable to get availability from any of the seven deponents Skyhook noticedfor a whole monthis simply unacceptable. Google is not complying with its discovery obligations, and unless Google provides proposed dates for each of the noticed deponents by close of business on Tuesday, Skyhook will move to compel those depositions. Separately, please get back to us on our proposal that the parties forgo subpoenas for party witnesses and agree to produce nonduplicative relevant documents from those witnesses' possession. Mr. Brin's Documents: Absent Google's response to our requests, specifically identified in my email attached below and discussed further at our June 20 meet and confer, by close of business on Tuesday, Skyhook will move to compel production of Mr. Brin's documents. ESI Search Terms: Google has not yet responded to Skyhook's June 3 request to run additional ESI searches and produce responsive documents, and Skyhook will move to compel production absent a response by close of business on Tuesday. Skyhook's Third Set of Document Requests: Skyhook pointed out during our meet and confer that it is still awaiting Google's responses on RFPs 199 (licenses and negotiations with OEMs) and 304 (how Google uses location data in its advertising) and Google has not yet provided a response. Further, on RPFs 254 (policies regarding studies of Google's patents) and 255 (policies regarding comparisons of Google's products with third-party patents), to the extent Google maintains that documents responsive to these RPFs are privileged, Google must identify such documents on its privilege log. Finally, with respect to Trackbeam litigation documents (RFP 303), Google has agreed to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. Skyhook requested confirmation that Google will include its discovery responses provided in that litigation as well as all deposition transcripts (including corporate depositions). To the extent that Google deems certain of the witnesses somehow irrelevant to this litigation, Skyhook has asked that Google identify those witnesses to Skyhook. Given that these follow-up requests are all within the scope of our late May discussions, Skyhook will move to compel production absent Google's agreement to produce documents or explain its belief that it has already produced responsive documents by close of business on Tuesday. Mr. Zelinka's Documents: Google has identified Mr. Zelinka as its corporate deponent on core technical topics, indeed he is the sole corporate deponent that Google has agreed to make available for deposition to date. You explained in the meet and confer that Google identified him as the corporate witness for these topics because he has the most comprehensive institutional knowledge among Google's employees currently working on the features of the accused products relevant to the topics on which he has been identified. Google also identified Mr. Zelinka in its January 30, 2013 second supplemental initial disclosures as one of only eleven Google employees knowledgeable about the issues in this litigation, and moreover, as one of only half-dozen employees knowledgeable about the operation of the accused products. However, Google has not collected, and has not produced, Mr. Zelinka's documents in this litigation and its position is that it will only produce Mr. Zelinka's documents if Skyhook can identify documents in Mr. Zelinka's files that it has not received from other custodians. This position is clearly improper because Google, not Skyhook, has access to Mr. Zelinka's documents, and given the importance Google has assigned to Mr. Zelinka's knowledge of the operation of the accused products by virtue of his designation as a corporate witness. Skyhook will proceed with Mr. Zelinka's deposition on July 10, reserving its right to seek production of Mr. Zelinka's documents after the deposition and to reopen or continue his deposition after Google produces his documents.

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Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Date: Wednesday, June 19, 2013 1:49 PM To: "Lundin, Tom" <TLundin@KSLAW.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com> Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: Re: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Tom, thank you for your responses. I will address several of them in this email in the hopes of streamlining our telephonic meet and confer. First, Google has selected Mr. Zelinka as a corporate representative on some of the core technical deposition topics, yet has not named him as a custodian nor produced his documents. Under the circumstances, Mr. Zelinka's responsive documents clearly should be produced. Please confirm that you will produce Mr. Zelinka's responsive documents at least two weeks prior to his deposition. Second, it is unacceptable that nearly one month after Skyhook noticed seven Google's employees for their individual depositions, Google has not responded with a proposed date for even one of those deponents. Google appears intent on delaying the resolution of this most straightforward issue, forcing motion practice knowing that it will take time for the opposing briefs to get filed, only so that Google will thenon the eve of the court's hearingpropose deposition dates. This very thing just happened with Google's interrogatory responses it had been refusing to provide until Skyhook filed its motion to compel. It is both unreasonable and unfair for Google to be delaying Skyhook's case in this manner and wasting both Skyhook's and the Court's resources on such issues. Third, Skyhook's deposition notices for Messrs. Lee and Brady in this case are wholly appropriate, and Google's arguments about overlap in those witnesses' depositions between this and the state case are unavailing. Skyhook's patent infringement case is separate and different from its state tortious interference case. The technical, willfulness, and the damages issues in the patent case are specific to this case. Further, Google cannot legitimately argue that Mr. Lee's and Mr. Brady's state-case depositions that took place before their custodian productions in this case even commenced and before Google produced the bulk of its production in this case are sufficient discovery of those witnesses for this case. We repeat our request for an immediate identification of their availability as well as the availability of all individual witnesses Skyhook has noticed nearly a month ago.

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Finally, with respect to Skyhook's request for Mr. Brin's documents, Skyhook requested that Google search the following search strings:

i. Skyhook ii. (Ted or Edward) w/3 Morgan iii. (Mike or Michael) w/3 Shean iv. (MacWorld or Mac World) and (Apple or Jobs or location or driv* or beacons or triangulat*) v. Location-based services or LBS or GLS
vi. (Location or Wi-Fi or WiFi or Wi?Fi or wireless or WLAN) and (advert* or revenue or value) Please explain why Google refuses to search Mr. Brin's documents for search strings v and vi. Please let us know how many documents each of our individual requested search strings yielded. (To the extent that the MacWorld search you ran yielded a large number of responsive documents, please let us know how many documents are responsive to our proposed search string no. iv, which is significantly narrower.) And please confirm that Google is refusing to produce the documents that those six search strings yield and expects Skyhook and the Court to rely on Google's representation that although responsive documents were found, not one is relevant. I have already circulated a meeting invite and a dial-in for Sanjeet for our meet and confer tomorrow at 4 PM Eastern. Thank you. Best, Azra

AZRA HADZIMEHMEDOVIC

TENSEGRITY LAW GROUP LLP 555 Twin Dolphin Drive, Suite 360 Redwood Shores, CA 94065 650-802-6055 (phone) 202-321-3879 (mobile) 650-802-6001 (fax)

From: <Lundin>, "Lundin, Tom" <TLundin@KSLAW.com> Date: Tuesday, June 18, 2013 6:32 PM To: Azra Hadzimehmedovic <azra@tensegritylawgroup.com>, "dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>, Google/Skyhook K&S <Google_SkyhookK&S@KSLAW.com>, "Abrams, William" <BAbrams@KSLAW.com>, "Pada, Roxane" <RPada@KSLAW.com>
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Cc: Skyhook_Service <Skyhook_Service@tensegritylawgroup.com> Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist.

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