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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 SKYHOOK’S 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 Skyhook’s Motion to Compel Google Inc. To Produce Mr. Patrick Brady for a Deposition and To Produce Certain Documents Responsive to Skyhook’s 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 Google’s production, using Patrick Brady as a custodian

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

litigation document request at least twice telephonically and I sent Google’s counsel additional written correspondence on this issue. Skyhook’s 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 Google’s depositions and discovery responses from that litigation (as Skyhook’s request specifically stated in the “including” clause). I explained Skyhook’s 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 TracBeam’s allegations against Google in that case, both of which involve Google’s 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 Skyhook’s continued concern with Google’s unwillingness to provide complete discovery into the roles of Google’s employees most knowledgeable about particular specific areas identified in Skyhook’s interrogatories and corporate topics. In particular, I reminded Mr. Dutta about Skyhook’s belief that Google has not provided sufficient discovery into 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 Skyhook’s First Set of Interrogatories, dated January 6, 2011. 5. Attached hereto as Exhibit 2 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook), T. Lundin (counsel for Google) re: Skyhook v. Google: Lars Fjeldsoe-Nielson’s Responses and Objections and other discovery Issues, dated between June 7, 2013 and June 18, 2013.

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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 Google’s Objections and

Responses to Skyhook’s 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. Brin’s 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, INC’S 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 Google’s 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.

Google’s 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 Google’s 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 Skyhook’s 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 Court’s 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). Skyhook’s 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 Google’s business activities outside the United States. Skyhook’s 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 Skyhook’s 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 Google’s trade secrets or confidential information. Information constituting Google’s 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

Google’s responses to each and every one of Skyhook’s 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 Google’s 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 LaBan·e, 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 acific  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 & Spalding’s 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 Skyhook’s 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 Skyhook’s 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, Skyhook’s 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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Skyhook’s Third RFPs During our previous two meet-and-confers on Skyhook’s 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 Google’s ESI search terms would have captured any responsive documents, consistent with Google’s response. You stated that Google’s 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 Skyhook’s 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. Google’s 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 Google’s 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 Skyhook’s 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. Skyhook’s 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 Skyhook’s proposals. In each instance, Google believes that Skyhook’s proposals result in an overly broad and unduly burdensome scope – more so for Skyhook’s proposed new terms than for Skyhook’s 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. Skyhook’s June 3 proposal concerning Sergey Brin’s documents: We previously advised you that, although Skyhook has made no showing of any basis to search Mr. Brin’s documents, Google searched Mr. Brin’s 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. Brin’s documents, including “(Mike or Michael) w/3 Shean” and “(Ted or Edward) w/3 Morgan.” Google has now searched Mr. Brin’s 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. Brin’s 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, I’ll 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  depositions—as  we  are  doing  with  Mr.  Fjeldsoe-­‐Nielsen—but  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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Case 1:10-cv-11571-RWZ Document 196-2 Filed 07/01/13 Page 7 of 9
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 – I’m writing to follow up on the below message and Google’s 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-Nielsen’s 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-Nielsen’s 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

Case 1:10-cv-11571-RWZ Document 196-3 Filed 07/01/13 Page 2 of 8

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  Google’s  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  Skyhook’s  case.    Skyhook noGced  Mr.  Brin’s  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.  Brin’s  relevance  to  Skyhook’s    patent  case.   Skyhook’s  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. Brin’s  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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Google’s  response  that  explains  the  large  cost  and  burden  involved  in  reviewing  and  producing  documents  that would  result  from  Skyhook’s  over-­‐broad  search  strings.   Regarding  deposiGons,  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  acGon.    Mr. Brady  explained  in  his  deposiGon  that  he  manages  partner  relaGonships.    Other  than  asserGng  that  the  state  court case  is  different  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  specific  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.  Zelinka’s  documents,  solely  because  he  will  be  one  of  Google’s  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  Google’s  source  code  that  explains  the  operaGon  of  Google’s  product.    In  view  of  this, Skyhook  has  not  provided  any  reason  why  Mr.  Zelinka’s  documents  are  needed  above-­‐and-­‐beyond  Google’s 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  Skyhook’s  requests  for  Tracbeam  discovery,  Skyhook  has  not  explained  the  relevance  of  Google’s 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 confirmations 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 noticed—for a whole month—is 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, 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

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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 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.   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 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

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knowing that it will take time for the opposing briefs to get filed, only so that Google will then—on the eve of the court's hearing—propose 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.   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

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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.

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Tuesday,  J une  2 5,  2 013  1 0:29:07  A M  P acific  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)

2013-02-0…C.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  services‹a  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  us‹specifically‹why  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 Skyhook’s Third Requests as unduly burdensome and unreasonably duplicative to the extent Google has already produced information responsive to the Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s Wi-Fi Location database, including access to Google’s 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 “Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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, Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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, Google’s Network Location Provider, or the Google Wi-Fi Location Database

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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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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

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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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

14

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

15

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

16

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Google’s 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,” “Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

18

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The 19

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

20

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

21

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

22

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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

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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 Google’s 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 Skyhook’s 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.

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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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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, Defendant’s partners, Defendant’s licensors, Defendant’s customers, Defendant’s resellers, and/or Defendant’s affiliates, Relating To the potential infringement by any products, systems, or processes made, used, offer for sale, and/or sold by Defendant, Defendant’s partners, Defendant’s licensors, Defendant’s customers, Defendant’s resellers, and/or Defendant’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The 80

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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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Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Google’s Location-Based Advertising,” “function . . . . . . Relating to Google’s Location-Based Advertising,” “operation . . . Relating to Google’s Location-Based Advertising,” “design . . . Relating to Google’s Location-Based Advertising,” “development . . . Relating to Google’s Location-Based Advertising,” “testing . . . Relating to Google’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted 110

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in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted 111

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in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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, Google’s 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 Skyhook’s 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 Skyhook’s Amended Complaint not asserted in Skyhook I—excluding 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s 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 “Google’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 “Google’s 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 Skyhook’s 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 Google’s 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 “Google’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Google’s 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

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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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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 Google’s 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 Skyhook’s 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 Skyhook’s 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 Skyhook’s 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. Google’s 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 Court’s 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.

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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 Google’s actual knowledge, possession, custody, or control; that is within Skyhook’s 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.

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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. Google’s 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.

Google’s 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 Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

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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 Court’s 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 Court’s 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 Court’s 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.

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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 Court’s 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

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imposed under the Federal Rules of Civil Procedure, the Court’s 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 Court’s 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

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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 Google’s knowledge, possession, custody, or control to the extent that it purports to include “Skyhook’s intellectual property, products, proposed products, systems, or processes, including the inventions claimed in Skyhook’s patents, Skyhook’s Wi-Fi positioning system, and Skyhook’s 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 Court’s 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 Court’s 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 Court’s 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 Court’s 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

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Rules of Civil Procedure, the Court’s 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 Court’s 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 Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

A-11

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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 firm’s 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

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Tuesday,  J une  4 ,  2 013  1 :25:38  P M  P acific  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  Google’s  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  Skyhook’s  Patents  in  its  Amended  Complaint  that  are  not  on  Google’s   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. Google’s Motion to Limit Number of Asserted Claims and Require New Infringement Contentions Your response to Google’s good faith attempt to meet and confer to narrow the dispute misses the point of Google’s motion. Google’s 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 Google’s 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 Skyhook’s expert has been reviewing Google’s 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 Skyhook’s suggestion that its narrowing of its claims in suit should be contingent upon Google’s agreement to limit the number of invalidity references on which it will rely, the number of Google’s 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 Skyhook’s 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, Google’s invalidity contentions and the agreed-to non-infringement contentions are due on June 15. We have made clear the basis for Google’s 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 Google’s 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 Google’s 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 Skyhook’s 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 Google’s responses to Skyhook’s 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 Skyhook’s 30(b)(6) notice. We have responded concerning Google’s 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 Google’s ESI disclosure, and Google answered all of Skyhook’s 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 Skyhook’s initial questions, Google asked certain initial questions of Skyhook. See id. Skyhook did not answer Google’s questions. Instead, Skyhook stated that a reciprocal exchange of information would be agreeable, but made that exchange contingent upon Google’s 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. Google’s three questions are akin to the five questions that Skyhook initially asked, and that Google fully answered, and there is no reason why Skyhook’s responses to those questions should be contingent upon Google answering all six of Skyhook’s 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 Skyhook’s refusal. This proposal moots Skyhook’s 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 Google’s 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, Google’s 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 Google’s 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 Skyhook’s threatened motion to compel on this issue. C. RFP 316 of Skyhook’s 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. Brin’s 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. Brin’s documents. Without waiving or in any way deviating from that position, in response to your request, Google’s proposal is that it search Mr. Brin’s 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 Skyhook’s threatened motion to compel on this issue.
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 8 of 12

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 Skyhook’s 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 Skyhook’s proposal. As Google has stated on previous occasions, the location of Google’s 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 Google’s proposed stipulation. This agreement moots Skyhook’s 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 Google’s objections to Skyhook’s 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 Google’s objections to Skyhook’s 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 Skyhook’s threatened motions to compel concerning corporate representative testimony and document production. H. Identification of Dashboards

In our conferral concerning Google’s objections to Skyhook’s 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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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 9 of 12

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 – I’m writing to follow up on two issues discussed in our conferral this afternoon. First, you asked whether the filing today of Google’s Motion For Protective Order with respect to Skyhook’s 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 Skyhook’s 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 Google’s Rule 30(b)(6) Notice. Second, we met and conferred concerning Google’s 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 Google’s 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, I’ve 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 Google’s 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 Google’s 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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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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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

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 3 of 5

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  

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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.

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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 10

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Friday,  J une  2 8,  2 013  4 :38:07  P M  P acific  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  Lundin’s  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.   Skyhook’s  Proposed  Search  Terms  for  Skyhook  II (1)        Google’s  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  Skyhook’s  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

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•                  (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  Google’s  personal  documents  would  lead  to  any relevant  documents.    In  contrast,  Skyhook’s  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  deponent’s  personal  materials  not  in Skyhook’s  possession,  custody  or  control  that  were  not  previously  produced  by  Skyhook.”    Because Skyhook’s  witnesses  were  using  personal  and  non-­‐company  emails  on  matters  relevant  to  this  case,  as demonstrated  in  Skyhook’s  production,  it  is  relevant  for  them  to  search  personal  and  non-­‐company  emails.   There  is  no  such  evidence  for  Google’s  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.  Gundotra’s  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  Skyhook’s  ESI  Terms  for  Skyhook  II  on  June  3.    We  worked  diligently  with  Skyhook  to accommodate  Skyhook’s  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,  Skyhook’s  improperly  redacted  and  withheld  documents and  documents  responsive  to  Google’s  4th  set  of  RFPs).    Yesterday,  you  stated  that  Skyhook  would  not  agree to  discuss  a  revised  schedule  considering  Skyhook’s  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  Skyhook’s  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,
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GOOGSKYFED_2477194  -­‐  GOOGSKYFED_2477861,  GOOGSKYFED_2477862  -­‐  GOOGSKYFED_2477909,  and GOOGSKYFED_2478565  -­‐  GOOGSKYFED_2478586.   Regarding  RFP  304  (All  Documents  Relating  to  Google’s  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  Google’s  efforts  to  accommodate  Skyhook’s  request  for  documents responsive  to  the  search  terms  discussed  above.   Deposition  Location Google  agrees  to  present  its  witnesses  at  Tensegrity’s  offices  in  Redwood  Shores.    We  appreciate  your  offer to  provide  break-­‐out  rooms.    We  will  provide  the  same  for  Skyhook’s  witnesses  at  our  offices  in  Redwood Shores  and  Bingham’s  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  Google’s  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  Skyhook’s  case.   Skyhook  noticed  Mr.  Brin’s  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.  Brin’s  relevance  to Skyhook’s    patent  case.    Skyhook’s  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.  Brin’s  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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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 6 of 10
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 Google’s  response  that  explains  the  large  cost  and  burden  involved  in  reviewing  and  producing  documents that  would  result  from  Skyhook’s  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.  Zelinka’s  documents,  solely  because  he  will  be  one  of  Google’s  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  Google’s  source  code  that  explains  the  operation  of  Google’s product.    In  view  of  this,  Skyhook  has  not  provided  any  reason  why  Mr.  Zelinka’s  documents  are  needed above-­‐and-­‐beyond  Google’s  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  Skyhook’s  requests  for  Tracbeam  discovery,  Skyhook  has  not  explained  the  relevance  of Google’s  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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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 7 of 10
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 noticed—for a whole month—is 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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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 8 of 10
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 then—on the eve of the court's hearing—propose 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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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 9 of 10
  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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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 10 of 10
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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