Match Group, LLC v. Bumble Trading Inc.

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

Exhibit B

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Exhibit B From: Caplan, Matt To: John Summers Cc: Drayton, Joe; Whelan, Rose; z/Bumble-Match.com; Deron Dacus; match@caldwellcc.com; melissa@gillamsmithlaw.com; John Palmer Subject: Re: 18-cv-80: Custodians and Corporate Witnesses Date: Saturday, July 13, 2019 2:41:17 PM Hi John, we are still working through this with our client and hope to have a response for you this week. Matt Caplan Cooley LLP 310-528-1361 On Jul 11, 2019, at 5:23 PM, John Summers <jsummers@caldwellcc.com> wrote: Counsel, Last month, we had a call negotiating ESI terms and discussed how non-party entities such as Match Group, Inc. and Badoo would be treated for purposes of document collection and production, possible supplemental initial disclosures, and ESI Order negotiations. On July 1, I sent you a proposal concerning how the parties would treat certain affiliated non-party information for purposes of document collection and ESI Order negotiations. On July 8, I followed up asking whether you had any input. (That e-mail thread is attached.) No one has responded to either of these e-mails. Obviously we need to figure out where you all stand on what entities you will be collecting information from and whether you all will be making information and deponents from these entities available. I will reiterate our proposal again: 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. Is Bumble in agreement or not? Regards, John John F. Summers /// Caldwell Cassady & Curry 2101 Cedar Springs Rd., Suite 1000, Dallas, TX 75201 Telephone: 214.888.4847 jsummers@caldwellcc.com www.caldwellcc.com <mime-attachment> 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. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. If you are the intended recipient, please be advised that the content of this message is subject to access, review and disclosure by the sender's Email System Administrator.