Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Exhibit A

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Exhibit A From: John Summers To: "Whelan, Rose" Cc: "Caplan, Matt"; "Lauter, Judd"; Seth Reich; "Hughes, Brendan"; Brad Caldwell Subject: RE: Match v. Bumble - Discovery and ESI Order Call Date: Monday, July 01, 2019 5:17:00 PM Counsel, As we're working on identifying custodians as we continue to discuss the ESI and discovery orders, here is a proposal to deal with separate entity issue for discovery purposes: Plaintiff Match Group, LLC will search and produce information (including potential witnesses) from Match Group, Inc. related to this lawsuit without the need for Defendants to serve a third-party subpoena on Match Group, Inc. Defendants Bumble Trading Inc. and Bumble Holding, Ltd. will search and produce information (including potential witnesses) related to this lawsuit from the Badoo entities (Badoo Software Limited, Badoo Trading Limited, Badoo Limited, Badoo Technologies Limited, Worldwide Vision/Magic Labs) without the need for Plaintiff to subpoena those entities. In identifying the most significant custodians, the parties would investigate potential custodians from these sources as well as from the named parties. Let us know if that will work. -John From: John Summers Sent: Tuesday, June 18, 2019 3:30 PM To: Whelan, Rose <rwhelan@cooley.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com>; Hughes, Brendan <bhughes@cooley.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Hi Rose, As promised, attached is an ESI proposal. Our view is that this would govern the entire proceedings, not just the patent aspects. I look forward to discussing with you all tomorrow afternoon. -John From: John Summers Sent: Monday, June 17, 2019 1:21 PM To: Whelan, Rose <rwhelan@cooley.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com>; Hughes, Brendan <bhughes@cooley.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Haha, no sweat. Talk to you then. From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, June 17, 2019 1:20 PM To: John Summers <jsummers@caldwellcc.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com>; Hughes, Brendan <bhughes@cooley.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Thanks John. It's apparently not my day for scheduling, because I just realized I have a conflict at 5-6 Eastern, which is 4-5 central. I've sent an updated invite for 3:30 central, which hopefully will work for you. Rose Whelan Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 (enter from 12th and E Streets) Washington, DC 20004-2400 +1 202 728 7070 office +1 202 842 7899 fax +1 202 674 3257 mobile rwhelan@cooley.com www.cooley.com Cooley is one of Fortune's 100 Best Companies to Work For Cooley GO > Start and build your business From: John Summers <jsummers@caldwellcc.com> Sent: Monday, June 17, 2019 2:14 PM To: Whelan, Rose <rwhelan@cooley.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com>; Hughes, Brendan <bhughes@cooley.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Yes, that should work for me as well. From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, June 17, 2019 1:13 PM To: John Summers <jsummers@caldwellcc.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com>; Hughes, Brendan <bhughes@cooley.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Hi John, My apologies, I misunderstood some availability on our end. Would it be possible to push this to after 4:00 p.m. central? If not, we can stick with our scheduled time. Rose Whelan Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 (enter from 12th and E Streets) Washington, DC 20004-2400 +1 202 728 7070 office +1 202 842 7899 fax +1 202 674 3257 mobile rwhelan@cooley.com www.cooley.com Cooley is one of Fortune's 100 Best Companies to Work For Cooley GO > Start and build your business From: John Summers <jsummers@caldwellcc.com> Sent: Monday, June 17, 2019 1:58 PM To: Whelan, Rose <rwhelan@cooley.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com>; Seth Reich <sreich@caldwellcc.com> Subject: RE: Match v. Bumble - Discovery and ESI Order Call Rose, Let's plan for 11 central on Wednesday. I will aim to get you a concrete proposal from our end on ESI before then. I assume you'll circulate a dial-in? Talk to you then. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, June 17, 2019 10:26 AM To: John Summers <jsummers@caldwellcc.com> Cc: Caplan, Matt <mcaplan@cooley.com>; Lauter, Judd <jlauter@cooley.com> Subject: Match v. Bumble - Discovery and ESI Order Call Hi John, How about Wednesday between 11 and 2 Central for a call to discuss the discovery order and ESI order? If that doesn't work, let us know your availability. Rose Whelan Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 (enter from 12th and E Streets) Washington, DC 20004-2400 +1 202 728 7070 office +1 202 842 7899 fax +1 202 674 3257 mobile rwhelan@cooley.com www.cooley.com Cooley is one of Fortune's 100 Best Companies to Work For Cooley GO > Start and build your business This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. 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