exhibit d thorugh k motorola dodging tivos phone calls

8/6/2019 Exhibit D Thorugh K Motorola Dodging TiVos Phone Calls

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EXHIBIT D

Case 2:11-mc-00201-LDD Document 1-3 Filed 07/22/11 Page 1 of 27


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[OlA'\PERApril 25, 2011VIA EMArLMs. Laure-n J. GalganoRobins. t


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Ms. l.auVll.n J. G a J ~ n oApril 25, 2011P ~ $ ' i " " Q

RegllFding Ihe ElGM3,250, we hllVe 'Gorllfirmed Ihllt Motorola does not have any sOlJl'Oecode forElllY software f\,mningon toot et\ip.Regardi"Q Microsoft,we Illa\ieconliJmed that Motorola does not have a: y source code tor IfleIC!'0601l ~ a r e ref,rrecl to 11'1 the d'OCUl'net1t cit i- your letter.

'Cuel ll,jQI!l of SOlll'lOe COde iReYJllWn.aJly, il has been over one mo til since IIVO last inspooled M o t o r ' ~ l a ' s SOIlJOEl cede.Aceordll'lgly. we assume thM nvo's review of 'Motorola", 'source code Is complete, anel we plan

tosllourtl thAt source COM and repurpoSll Ihe computer and pillllonl'l8l supportillg Ute review nolaleHtlan M a 1st.

-Bnan K, Efickson

Sh'lOOrell'.DL:;(lIPpe:rr LLP (US_).,....,._7 ~ ~ ? :/ - . , .... -



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Ottley, Sandra K.

From: Erickson, Brian [[email protected]]

Sent: Monday, April 25, 2011 4:40 PM

To: Galgano, Lauren J.

Cc: Zimmerman, Lila M.; Ottley, Sandra K.

Subject: RE: TiVo's subpoena to Motorola, TiVo v. Verizon, Case No. 2:09-cv-257 (E.D. Tex.)

Attachments: Tivo-MMI - 4-25-11 Erickson ltr to Galgano.pdf

Page 1 of 2

4/28/2011

Dear Lauren,

Please see the attached.

Regards,Brian

From: Galgano, Lauren J. [mailto:[email protected]]Sent: Friday, April 15, 2011 4:45 PM

To: Erickson, Brian

Cc : Zimmerman, Lila M.; Ottley, Sandra K.

Subject: TiVo's subpoena to Motorola, TiVo v. Verizon, Case No. 2:09-cv-257 (E.D. Tex.)

Dear Brian,

Please see the attached correspondence regarding Motorola's document and source code production.

Best Regards,

Lauren

Lauren J. GalganoAttorneyRobins, Kaplan, Miller & Ciresi L.L.P.2800 LaSalle Plaza800 LaSalle AvenueMinneapolis, MN 55402

(612) 349-8405

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promoting, marketing or recommending to another person any tax-related matter.

Thank you in advance for your cooperation.

Robins, Kaplan, Miller & Ciresi L.L.P.http://www.rkmc.com____________________________________________________

Please consider the environment before printing this email.

The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole use of the intended

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Page 2 of 2

4/28/2011



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EXHIBIT E



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2800 LASALLE PLAZA800 LASALLE AVENUEMINNEAPOLIS, MN 55402-20TEL: 612-349-8500 FAX: 612-3www.rkrnc.com

L L P

ATTORNEYS AT LAW

PETER M. ROUTHIER612-349-8286

June 20, 2011VIA EMAIL

Brian EricksonDLA Piper LLP401 Congres, Suite 2500Austin, TX 78701

Re:iVo Inc. V. Verizon et al.Dear Brian:This letter memorializes the meet and confer we had today.You told us that Motorola should be able to produce all the documents andsource code we previously discussed by the end of next week: July 1. Meanwhile, youagreed to compile a final list of the versions of source code Motorola will be producingand to send that list to us tomorrow. You also agreed to seek permission fromBroadcom for the production of its source code and to let us know when Broadcom hadgiven its consent.

Finally, you told us that you still did not know whether or how Motorola mightseek additional protections beyond the existing protective order in this case. You alsodid not know what additional protections Motorola was considering. We told you thatwe don't want to be in a position where you are putting unreasonable restrictions on usas we get closer to Motorola's production and that we wanted to talk about anyconcerns Motorola has right away. You explained that if we didn't hear from you thenMotorola would produce without any additional restrictions.

Sincerely,ROBJI, KAPLAN, MILLER & CIRESI L.L.P.

Peter M. Routhier

TLANTA-BOSTONLOSANGELES NNEAPOLISNAPLESNEWYO



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EXHIBIT F



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RECNkb) DLA Piper LLP (US)401 Congress Avenue, Suite 2500Austin, Texas 78701-3799www.dlapiper.comBrian K. [email protected] 512.457.7059F 512.721.2263

R O B I N S , K A P L A N , M I L L E R &CIRESI L .L .R

D A T E 7- / /BY

July 1, 2011VIA OVERNIGHT MAIL

Ms. Lauren J. GalganoRobins, Kaplan, Miller & Ciresi, L.L.P.2800 LaSalle Plaza800 LaSalle Ave.Minneapolis, MN 55402(612) 349-8500Re:ase No. 2:09-CV-257-DF; TiVo Inc. v. Verizon Communications Inc., Subpoena to

Motorola Mobility, Inc.Dear Lauren:

Enclosed is a CD containing Motorola Mobility Inc.'s document production, Bates Nos.MMI0006584 through MMI0010020.

With respect to source code, Motorola has identified 29 additional versions of software that mayhave been deployed by Verizon. Motorola is prepared to produce all 29 versions for TiVo's inspection onthe source code review computer in our Boston office. However, we are informed that the parties in thelitigation may agree to treat a small handful of software versions as representative. Thus, we believe it ispremature to produce those 29 versions now. Please let us know if TiVo disagrees.

As with the previous production, this production is made pursuant to the agreement by TiVo andVerizon, memorialized in your letter dated December 3, 2010, that disclosure of Motorola's confidentialinformation will be limited to outside-counsels' eyes only. I.e., TiVo and Verizon agree that Motorola'sconfidential information will only be disclosed to those persons described in paragraphs 6(a) to 6(d) of theJoint Stipulation and Protective Order dated July 30, 2010 and will not be disclosed to those personsdescribed in paragraphs 6(e) and/or 6(f) of that Order. If either party disputes that agreement, theyshould notify me immediately and return the documents so that Motorola may seek a further protectiveorder from the Court.

Further, as we have discussed, Motorola Mobility is going to seek additional protections for itsconfidential information from the parties and, if necessary, the Court, in light of TiVo's failure to properlyprotect Motorola Mobility's confidential information under the current protective order.

Please let me know if you have any questions.Very truly yours,

rian K. EricksonDLA Piper LLP (US)Encl .WEST1223834751.1



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EXHIBIT G



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Routhier, Peter M.

From: Routhier, Peter M.

Sent: Thursday, June 16, 2011 1:41 PM

To: 'Erickson, Brian'

Cc: Collyard, Michael A.Subject: RE: TiVo v. Verizon-MMI subpoena

Page 1 of 3

7/18/2011

Brian,

We waited over twenty minutes for you but you never called in to our scheduled meet and confer. I called andemailed you during the scheduled time but have received no response.

We really need to speak with Motorola's counsel today about these matters. We can make ourselves available forthe rest of the day except for 3-4pm central. Please email us right away and let us know.

Sincerely,

Peter M. RouthierAttorneyRobins, Kaplan, Miller & Ciresi L.L.P.2800 LaSalle Plaza800 LaSalle AvenueMinneapolis, MN 55402Direct: (612) 349-8268




Cc: Collyard, Michael A.Subject: RE: TiVo v. Verizon-MMI subpoena

Hi Brian,

Will you be joining us this afternoon?

Thanks,

Peter


Sent: Wednesday, June 15, 2011 9:13 AM


Cc : Collyard, Michael A.

Subject: RE: TiVo v. Verizon-MMI subpoena

Brian,

Yes, 1pm Central on Thursday is fine. Let's use this call in information: 877-260-4544, participant

code 6123490975.



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Thanks,

Peter

From: Erickson, Brian [mailto:[email protected]]

Sent: Tuesday, June 14, 2011 6:03 PMTo: Routhier, Peter M.


Subject: RE: TiVo v. Verizon-MMI subpoena

Peter,Does 1pm Central Thursday work for you?Brian

From: Routhier, Peter M. [mailto:[email protected]]

Sent: Tuesday, June 14, 2011 4:11 PM

To: Erickson, Brian

Cc : Collyard, Michael A.Subject: RE: TiVo v. Verizon-MMI subpoena

Brian,

I sent you an email yesterday asking if you would be available to talk today about theoutstanding issues on the Motorola subpoena. I followed up on that email with avoicemail this morning but you haven't responded. Motorola has had a couple ofweeks now to look into these issues and many months to respond to TiVo'ssubpoena. As I've explained in my emails and messages, timing is extremely importantright now. Can you please let me know if you can be available to meet and confertomorrow morning on these outstanding issues. If you can't, please let me know if anytime on Thursday works for you. Either way, please give me the courtesy of a

response.

I would also like some clarification from Motorola now that you've had a chance toreview the list of deployed versions provided by Verizon. I sent you a copy of that listyesterday. You'll notice that the versions of firmware that Motorola has produced toTiVoDel Mar 23.54A and 23.54Bare not on that list. You previously told us thatthose were the versions currently in use on Verizon's QIP products. Canyou confirm whether the source code Motorola has made available to TiVo to datedoes in fact represent what is currently in use on Verizon's QIP products?

I don't mean to continue to bother you, but you surely understand the importance ofthese issues. I look forward to hearing from you.

Sincerely,


Page 2 of 3

7/18/2011



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Subject: RE: TiVo v. VerizonMMI subpoena

Brian,

We understand that you have been working with Verizon to identify thedeployed versions of Motorola software that we talked about. As you probablyknow, Verizon is amending its response to an interrogatory on this and is goingto send it to us tomorrow. They gave us permission to share this informationwith you so we'll do that right away when we get it.

We'd like to set up a time to talk with you on Monday so we can move the ballforward on Motorola's production. You should have all the information you needby that time. Please let us know if you can be available to talk at 9:30 AM CSTor 3:30PM CST.

Sincerely,


Page 3 of 3

7/18/2011



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EXHIBIT H



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Routhier, Peter M.

From: Galgano, Lauren J.

Sent: Tuesday, July 05, 2011 5:26 PM


Cc: Collyard, Michael A.; Specht, Brock J.; Routhier, Peter M.; Felkins, Julie B.; Zimmerman, Lila M.Subject: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Page 1 of 1

7/21/2011

Dear Brian,

We received Motorola's production of additional documents today. We'll take a look at thesedocuments and let you know if we see any issues that require follow up.

Regarding the source code versions, thank you for confirming that as many as 29 additionalversions of potentially responsive code exist. I understand that you had agreed to provide mycolleague Peter Routhier a list of these versions. Please do so right away.

In terms of the code production, we disagree that it is premature for Motorola to produce theadditional versions of code now. We have been asking for this code for many months, and wecannot delay any longer.

You are correct that we have considered the possibility of designating representative softwareversions. We did so at your suggestion--in your letters of April 25 and May 6 youtold us thatthe code Motorola had already produced was sufficient to show the functionality of all of theaccused QIP products, and on the June 16 meet and confer you reiterated this point andsuggested a stipulation to that effect.We agree that a stipulation of this type could save a lot ofwork and expense for everyone involved. IfMotorolais willing to enter into a writtenagreement thattheDelMar 23.54A and 23.54B software versions are representative ofall of thedeployed versions ofsoftware provided to Verizon for purposes of the current lawsuitbetweenTiVo and Verizon, please let us know right away. We are available tomorrowmorning if you would like to schedule a brief call to follow up on this.

In any event, we have been waiting for many months now to obtain the additional versions ofsource code, and we need either the code or a written agreement regarding representativeversions by the end of this week.

Kind Regards,

Lauren

Lauren J. GalganoAttorneyRobins, Kaplan, Miller & Ciresi L.L.P.800 LaSalle Avenue | 2800 LaSalle Plaza | Minneapolis,MN 55402Direct: 612.349.8405 | Fax: [email protected] | www.rkmc.com



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EXHIBIT I



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Routhier, Peter M.


Sent: Thursday, July 07, 2011 8:40 PM


Cc: Collyard, Michael A.; Galgano, Lauren J.Subject: RE: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Page 1 of 2

7/21/2011

Brian,

We haven't heard back from you. We keep asking you to respond but you don't. We really want to work with youbut we can't if you won't be responsive. Please let us know if you'd like to talk about a stipulation. If you're notwilling to do so at this time then we need you to produce the source code for the deployed versions immediately.

If we don't hear from you tomorrow like we requested, we'll have no choice but to file our motion.

Sincerely,

Peter RouthierAttorneyRobins, Kaplan, Miller & Ciresi L.L.P.Direct: (612) 349-8268




Cc: Collyard, Michael A.; Specht, Brock J.; Routhier, Peter M.; Felkins, Julie B.; Zimmerman, Lila M.

Subject: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Dear Brian,

We received Motorola's production of additional documents today. We'll take a look atthese documents and let you know if we see any issues that require follow up.

Regarding the source code versions, thank you for confirming that as many as 29additional versions of potentially responsive code exist. I understand that you hadagreed to provide my colleague Peter Routhier a list of these versions. Please do so rightaway.

In terms of the code production, we disagree that it is premature for Motorola to producethe additional versions of code now. We have been asking for this code for manymonths, and we cannot delay any longer.

You are correct that we have considered the possibility of designating representativesoftware versions. We did so at your suggestion--in your letters of April 25 and May 6youtold us that the code Motorola had already produced was sufficient to show thefunctionality of all of the accused QIP products, and on the June 16 meet and confer youreiterated this point and suggested a stipulation to that effect.We agree that a stipulation



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of this type could save a lot of work and expense for everyone involved. IfMotorolaiswilling to enter into a written agreement thattheDelMar 23.54A and 23.54B softwareversions are representative ofall of the deployed versions ofsoftware provided toVerizon for purposes of the current lawsuit betweenTiVo and Verizon, please let usknow right away. We are available tomorrow morning if you would like to schedule abrief call to follow up on this.

In any event, we have been waiting for many months now to obtain the additionalversions of source code, and we need either the code or a written agreement regardingrepresentative versions by the end of this week.

Kind Regards,

Lauren


Page 2 of 2

7/21/2011



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EXHIBIT J



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Routhier, Peter M.

From: Erickson, Brian [[email protected]]

Sent: Monday, July 11, 2011 1:02 AM

To: Routhier, Peter M.

Cc: Collyard, Michael A.; Galgano, Lauren J.Subject: RE: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Page 1 of 3

7/21/2011

Peter,

My letters of April 25 and May 6 stated that the code already produced was, in fact, the source code for all of theMotorola software on all of the deployed DVRs. TiVo's more recent request for source code for historical releasesof software that are not deployed on any DVR is a different issue. Motorola is not a party to the litigation betweenTiVo and Verizon and, therefore, lacks the ability to enter into any representative product agreement. Motorolahas repeatedly requested that the parties enter into such an agreement between themselves for purposes of theirlitigation to reduce the burdens on each other, the Court, and third parties such as Motorola, but those effortshave so far proved fruitless.

Accordingly, please let me know whether the parties will agree on a subset of code and Motorola will produce thatsubset. Obviously, Motorola would not be pleased to produce all of its source code, only to learn that the partiesthen reach an agreement that some subset of code is representative. In case that occurs, Motorola reserves itsright to seek compensation from TiVo for Motorola's expenses in needlessly retrieving, reviewing, and producingcode, particularly archived code.

A review of the Court's scheduling order reveals that discovery will not close for several months after the claimconstruction order, which has not issued yet. Moreover, TiVo has failed to update its infringement contentionssince Motorola's production of source code for all deployed DVRs in early March, implying that Motorola's code isnot relevant to TiVo's infringement contentions. Accordingly, there does not appear to be any need in the shortterm for a premature production of additional source code.

Finally, I'm not sure what you mean by "our motion". If you would like to meet and confer regarding a motion,

please let me know.

Regards,Brian



To: Erickson, Brian

Cc: Collyard, Michael A.; Galgano, Lauren J.

Subject: RE: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Brian,

We haven't heard back from you. We keep asking you to respond but you don't. We really want to workwith you but we can't if you won't be responsive. Please let us know if you'd like to talk about a stipulation.If you're not willing to do so at this time then we need you to produce the source code for the deployedversions immediately.

If we don't hear from you tomorrow like we requested, we'll have no choice but to file our motion.

Sincerely,



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Cc : Collyard, Michael A.; Specht, Brock J.; Routhier, Peter M.; Felkins, Julie B.; Zimmerman, Lila M.


Dear Brian,

We received Motorola's production of additional documents today. We'll take alook at these documents and let you know if we see any issues that require followup.

Regarding the source code versions, thank you for confirming that as many as 29additional versions of potentially responsive code exist. I understand that you hadagreed to provide my colleague Peter Routhier a list of these versions. Please do soright away.

In terms of the code production, we disagree that it is premature for Motorola toproduce the additional versions of code now. We have been asking for this code formany months, and we cannot delay any longer.

You are correct that we have considered the possibility of designating

representative software versions. We did so at your suggestion--in your letters ofApril 25 and May 6 youtold us that the code Motorola had already produced wassufficient to show the functionality of all of the accused QIP products, and on theJune 16 meet and confer you reiterated this point and suggested a stipulation tothat effect.We agree that a stipulation of this type could save a lot of work andexpense for everyone involved. IfMotorolais willing to enter into a writtenagreement thattheDelMar 23.54A and 23.54B software versions are representativeofall of the deployed versions ofsoftware provided to Verizon for purposes of thecurrent lawsuit betweenTiVo and Verizon, please let us know right away. We areavailable tomorrow morning if you would like to schedule a brief call to follow up

on this.

In any event, we have been waiting for many months now to obtain the additionalversions of source code, and we need either the code or a written agreementregarding representative versions by the end of this week.

Kind Regards,

Lauren

Page 2 of 3

7/21/2011



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____________________________________________________

Information contained in this e-mail transmission may be privileged, confidential and covered bythe Electronic Communications Privacy Act, 18 U.S.C. Sections 2510-2521.

If you are not the intended recipient, do not read, distribute, or reproduce this transmission.

If you have received this e-mail transmission in error, please notify us immediately of the error byreturn email and please delete the message from your system.

Pursuant to requirements related to practice before the U. S. Internal Revenue Service, any taxadvice contained in this communication (including any attachments) is not intended to be used,and cannot be used, for purposes of (i) avoiding penalties imposed under the U. S. InternalRevenue Code or (ii) promoting, marketing or recommending to another person any tax-relatedmatter.




The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole use of the

intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified that any unauthorizedreview, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If

you have received this communication in error, please reply to the sender and destroy all copies of the message. To contact usdirectly, send to [email protected]. Thank you.

Page 3 of 3

7/21/2011



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EXHIBIT K



24/27


25/27

From: Erickson, Brian [mailto:[email protected]]

Sent: Monday, July 11, 2011 1:02 AM

To: Routhier, Peter M.

Cc : Collyard, Michael A.; Galgano, Lauren J.

Subject: RE: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Peter,

My letters of April 25 and May 6 stated that the code already produced was, in fact, the source codefor all of the Motorola software on all of the deployed DVRs. TiVo's more recent request for sourcecode for historical releases of software that are not deployed on any DVR is a different issue.Motorola is not a party to the litigation between TiVo and Verizon and, therefore, lacks the ability toenter into any representative product agreement. Motorola has repeatedly requested that theparties enter into such an agreement between themselves for purposes of their litigation to reducethe burdens on each other, the Court, and third parties such as Motorola, but those efforts have sofar proved fruitless.

Accordingly, please let me know whether the parties will agree on a subset of code and Motorola willproduce that subset. Obviously, Motorola would not be pleased to produce all of its source code,only to learn that the parties then reach an agreement that some subset of code is representative.In case that occurs, Motorola reserves its right to seek compensation from TiVo for Motorola'sexpenses in needlessly retrieving, reviewing, and producing code, particularly archived code.

A review of the Court's scheduling order reveals that discovery will not close for several months afterthe claim construction order, which has not issued yet. Moreover, TiVo has failed to update itsinfringement contentions since Motorola's production of source code for all deployed DVRs in earlyMarch, implying that Motorola's code is not relevant to TiVo's infringement contentions. Accordingly,there does not appear to be any need in the short term for a premature production of additionalsource code.

Finally, I'm not sure what you mean by "our motion". If you would like to meet and confer regardinga motion, please let me know.

Regards,Brian



To: Erickson, Brian

Cc : Collyard, Michael A.; Galgano, Lauren J.Subject: RE: TiVo v. Verizon - TiVo's Subpoena served on Motorola

Brian,

We haven't heard back from you. We keep asking you to respond but you don't. We reallywant to work with you but we can't if you won't be responsive. Please let us know if you'd liketo talk about a stipulation. If you're not willing to do so at this time then we need you toproduce the source code for the deployed versions immediately.

If we don't hear from you tomorrow like we requested, we'll have no choice but to file ourmotion.

Sincerely,

Page 2 of 4

7/21/2011



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Cc : Collyard, Michael A.; Specht, Brock J.; Routhier, Peter M.; Felkins, Julie B.;

Zimmerman, Lila M.


Dear Brian,

We received Motorola's production of additional documents today.We'll take a look at these documents and let you know if we see any

issues that require follow up.

Regarding the source code versions, thank you for confirming that asmany as 29 additional versions of potentially responsive code exist. Iunderstand that you had agreed to provide my colleague Peter Routhiera list of these versions. Please do so right away.

In terms of the code production, we disagree that it is premature forMotorola to produce the additional versions of code now. We have beenasking for this code for many months, and we cannot delay any longer.

You are correct that we have considered the possibility of designatingrepresentative software versions. We did so at your suggestion--in yourletters of April 25 and May 6 youtold us that the code Motorola hadalready produced was sufficient to show the functionality of all of theaccused QIP products, and on the June 16 meet and confer youreiterated this point and suggested a stipulation to that effect.We agreethat a stipulation of this type could save a lot of work and expense foreveryone involved. IfMotorolais willing to enter into a writtenagreement thattheDelMar 23.54A and 23.54B software versions arerepresentative ofall of the deployed versions ofsoftware provided toVerizon for purposes of the current lawsuit betweenTiVo and Verizon,please let us know right away. We are available tomorrow morning ifyou would like to schedule a brief call to follow up on this.

In any event, we have been waiting for many months now to obtain theadditional versions of source code, and we need either the code or awritten agreement regarding representative versions by the end of thisweek.

Kind Regards,

Page 3 of 4

7/21/2011



27/27

Lauren


____________________________________________________

Information contained in this e-mail transmission may be privileged, confidential andcovered by the Electronic Communications Privacy Act, 18 U.S.C. Sections 2510-2521.

If you are not the intended recipient, do not read, distribute, or reproduce thistransmission.

If you have received this e-mail transmission in error, please notify us immediately ofthe error by return email and please delete the message from your system.

Pursuant to requirements related to practice before the U. S. Internal RevenueService, any tax advice contained in this communication (including any attachments)is not intended to be used, and cannot be used, for purposes of (i) avoiding penaltiesimposed under the U. S. Internal Revenue Code or (ii) promoting, marketing orrecommending to another person any tax-related matter.




The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole

use of the intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified

that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or anyof its contents, is strictly prohibited. If you have received this communication in error, please reply to the sender

and destroy all copies of the message. To contact us directly, send to [email protected]. Thank you.

Page 4 of 4


exhibit d thorugh k motorola dodging tivos phone calls

Documents