American Patents LLC v. Mediatek, Inc. et al

Western District of Texas, txwd-6:2018-cv-00339

Exhibit A (Feb. 5-7 email thread)

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EXHIBIT A Subject: RE: American Patents v. Lenovo Date: Thursday, February 7, 2019 at 11:28:13 AM Central Standard Time From: MarGn Bader To: Zac Harrington, Eric Findlay, Lai Yip, Toni Qiu CC: Larry Thompson, MaO Antonelli, Stafford Davis, Cate Bartles, Ryan Pinckney, Michael Ellis Zac, Thank you for the e-mail – it took us some time to connect with our client do to various scheduling conflicts. As you know, the Lenovo Defendants have not even been properly served with process in this case. Therefore, Plaintiff is not entitled to the deposition of Mr. Cranor or any other discovery at this juncture, and Lenovo does not agree to make Mr. Cranor available for deposition at this time. Best, Martin Martin R. Bader +1 858-720-7446 | direct | Bio SheppardMullin 12275 El Camino Real, Suite 200 San Diego, CA 92130-4092 +1 858-720-8900 | main | LinkedIn | Twitter From: Zac Harrington <> Sent: Thursday, February 7, 2019 9:20 AM To: Eric Findlay <>; MarGn Bader <>; Lai Yip <>; Toni Qiu <> Cc: Larry Thompson <>; MaO Antonelli <>; Stafford Davis <>; Cate Bartles <>; Ryan Pinckney <>; Michael Ellis <> Subject: Re: American Patents v. Lenovo Counsel- Where are y'all on this? If Lenovo needs more Gme to consider our proposal, can we agree to a two week extension for our opposiGon in the meanGme? Sent from my iPhone On Feb 5, 2019, at 5:42 PM, Zac Harrington <> wrote: Counsel- American Patents would like to depose Lenovo's declarant (Kurt Cranor) before responding to Lenovo's motion to dismiss. Please let me know if Lenovo will agree to this very limited discovery. We are fine doing the deposition in Morrisville, and the timing is generally up to Lenovo. American Patents would file its opposition to Lenovo's motion to dismiss one week after the Page 1 of 2 deposition. Please let me know if you would like to discuss. Best, Zac Zachariah S. Harrington Antonelli, Harrington & Thompson LLP 4306 Yoakum, Suite 450 Houston, TX 77006 (713) 581-3003 (direct) (713) 581-3020 (fax) (917) 370-1957 (cell) AOenGon: This message is sent by a law firm and may contain informaGon that is privileged or confidenGal. If you received this transmission in error, please noGfy the sender by reply e-mail and delete the message and any aOachments. Page 2 of 2