American Patents LLC v. Mediatek, Inc. et al

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

Exhibit D

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EXHIBIT D Levinson, Rebecca B. From: Zac Harrington <zac@ahtlawfirm.com> Sent: Tuesday, August 6, 2019 11:42 AM To: Levinson, Rebecca B. Cc: Ryan Pinckney; Lai Yip; VanHoutan, Tyler T.; aenglehart@oblon.com; eschweibenz@oblon.com; jkern@oblon.com; pamstutz@scottdoug.com; efindlay_findlaycraft.com; Martin Bader; Michael Hopkins; kpanderson@duanemorris.com; BGreene@duanemorris.com; pjhubert@duanemorris.com; mhudgeons@reedsmith.com; jlayne@reedsmith.com; dbjohnson@reedsmith.com; jmitchell@reedsmith.com; omohammed@reedsmith.com; Larry Thompson; Matt Antonelli; Michael Ellis; sdavis@stafforddavisfirm.com; cbartles@stafforddavisfirm.com Subject: Re: American Patents v MediaTek et al (C.A. No. 6:18-cv-339) – Proposed Protective Order Rebecca- We are not willing to work off of Defendants proposed protective, especially since we sent y'all our draft first. We proposed the Gilstrap protective order as a compromise seeing as it contains many provisions that defendants often request. Since Defendants do not want to work off of that draft, we will ask the Court to make one small change to the current protective order so that experts can review confidential information. We assume y'all oppose this change, and we will file an opposed motion to make this change unless y'all inform us otherwise. If Defendants want all of the extra (and in our view completely unwarranted) provisions in the protective order you attached, y'all can ask the Court for those separately and explain why there is good cause for each change. 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) zac@ahtlawfirm.com www.ahtlawfirm.com On Aug 2, 2019, at 2:48 PM, Levinson, Rebecca B. <RLevinson@mcguirewoods.com> wrote: Ryan, While we appreciate Plaintiff providing a proposed Protective Order, Defendants have also been working on a proposed Protective Order. See attached. 1 As all the Defendants have already agreed to the attached Protective Order, we think it would be more efficient if the parties could work from Defendants' proposed Protective Order. Please let us know if Defendants' proposed Protective Order is acceptable to Plaintiff or if there are any provisions that you would like to discuss. Regards, Rebecca Rebecca B. Levinson McGuireWoods LLP T: +1 202 828 2816 | M: +1 301 980 9714 From: Ryan Pinckney <ryan@ahtlawfirm.com> Sent: Thursday, August 1, 2019 6:13 PM To: Lai Yip <LYip@sheppardmullin.com>; VanHoutan, Tyler T. <TVanHoutan@mcguirewoods.com>; aenglehart@oblon.com; eschweibenz@oblon.com; jkern@oblon.c om; pamstutz@scottdoug.com; efindlay_findlaycraft.com <efindlay@findlaycraft.com>; Martin Bader <MBader@sheppardmullin.com>; Michael Hopkins <MHopkins@sheppardmullin.com>; kpanderson@duanemorris.com; BGreene@duanemorris.com; pjhu bert@duanemorris.com; mhudgeons@reedsmith.com; jlayne@reedsmith.com; dbjohnson@reedsmith. com; jmitchell@reedsmith.com; omohammed@reedsmith.com; Levinson, Rebecca B. <RLevinson@mcguirewoods.com> Cc: Larry Thompson <larry@ahtlawfirm.com>; Zac Harrington <zac@ahtlawfirm.com>; Matt Antonelli <matt@ahtlawfirm.com>; Michael Ellis <michael@ahtlawfirm.com>; 'sdavis@stafforddavisfirm.com'; 'cbartles@stafforddavisfirm.com' Subject: American Patents v Mediatek et al (C.A. No. 6:18‐cv‐339) – Proposed Protective Order Counsel, In advance of defendants' upcoming productions, we would like to get a protective order on file that allows our experts and consultants to review the materials in those productions. Attached is a proposed Protective Order that is based on Judge Gilstrap's model Protective Order. Please let us know if this is acceptable to defendants or if there are any provisions you would like to discuss. Best, Ryan Pinckney Antonelli, Harrington & Thompson LLP 4306 Yoakum Blvd., Ste. 450 Houston, Texas 77006 (713) 581‐3019 (direct) (713) 581‐3020 (fax) www.ahtlawfirm.com ryan@ahtlawfirm.com 2 This e‐mail from McGuireWoods may contain confidential or privileged information. If you are not the intended recipient, please advise by return e‐mail and delete immediately without reading or forwarding to others.<American Patents v. MediaTek et al. - Protective Order (from Defendants).docx> 3