Match Group, LLC v. Bumble Trading Inc.

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

Exhibit C

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6 Exhibit C 6 From: John Summers To: "Whelan, Rose"; Drayton, Joe Cc: Brad Caldwell Subject: RE: Match v. Bumble Date: Tuesday, January 08, 2019 3:57:00 PM Rose, I think your edits are probably okay but I am still waiting on final sign-off. We disagree that the identification of Bumble's prosecution counsel is irrelevant to this issue; courts look to the specifics of the individual attorneys in particular roles, their locations, etc. in evaluating what level of risk there is of inadvertent disclosure, whether an ethical wall can guard against that risk, etc. As you probably predicted, we will inform the Court that you inexplicably refused to give us this requested information. In response to your question about what cases we intend to rely on, we will likely rely on the following reported decisions: In re Deutsche Bank Trust Co. Ams., 605 F.3d 1373 (Fed. Cir. 2010); Gen-Probe Inc. v. Becton, Dickinson & Co., 267 F.R.D. 679 (S.D. Cal. 2010); Valencell, Inc. v. Apple, Inc., No. 5:16-CV-1-D, 2016 WL 7217635 (E.D.N.C. Dec. 12, 2016); Realtime Data LLC v. Acronis, Inc., No. 17-CV-11279-IT, 2017 WL 9292268 (D. Mass. Nov. 28, 2017); Presidio Components, Inc. v. Am. Tech. Ceramics Corp., 546 F. Supp. 2d 951 (S.D. Cal. 2008); Digital Empire Ltd. v. Compal Elecs. Inc. Grp., No. 14-CV-1688-DMS(KSC), 2015 WL 10857544 (S.D. Cal. July 20, 2015); Ameranth, Inc. v. Pizza Hut, Inc., No. 3:11-CV-01810-JLS, 2012 WL 528248 (S.D. Cal. Feb. 17, 2012); Xerox Corp. v. Google, Inc., 270 F.R.D. 182 (D. Del. 2010). We also intend to rely on the Eastern District of Texas model for protective orders in patent cases. We propose a page limit of 3 pages per side. I can be flexible on the time for exchange. What time works best for you? At the agreed time, I propose that we just exchange proposals and accompanying exhibits. We (CCC) would then gather everything into one document and file. Match can use letters for exhibits and Bumble can use numbers. This way we don't have to change any ordering on that issue after exchange. Let me know if that works. Regards, John From: Whelan, Rose <rwhelan@cooley.com> Sent: Tuesday, January 08, 2019 3:34 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, Following up on this we also may rely on the protective order entered in St. Clair Intellectual Property Consultants, Inc. v. Acer, Inc., No. 09-cv-354-JJF-LPS, Provisions 3, 7, 13 (D. Del. June 23, 6 2010). Please let us know if there are cases that you are relying on. Also please let us know how you want to handle logistics for exchange of our arguments and filing. 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: Whelan, Rose Sent: Tuesday, January 8, 2019 3:18 PM To: 'John Summers' <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, Attached is a slightly revised version of the PO, adding in the language I suggested yesterday and fixing a few nits. I don't think anything in here is substantive, other than what I sent over yesterday, but let me know if you have any concerns or want to discuss. As requested, here is our position at a high level. The ethical wall requirement in Match's proposal is overly broad and unnecessary. The protective order and prosecution bar prevent any disclosure of highly-sensitive material to prosecution counsel. Bumble's litigation counsel would prudently abide by this, and prosecution counsel would take part in the litigation in a limited manner, such as with invalidity and prior art, which only relate to public, non-confidential information. Protective orders in other cases have provided for prosecuting attorneys' involvement in litigation and have shielded sensitive technical information from those individuals without requiring an ethical wall. (See Mirror Worlds Techs., LLC v. Facebook, Inc., No. 17-cv-3473-JGK, No. 98, Provisions 2.15, 5.2, 7.3, 8 (S.D.N.Y. Feb. 23, 2018) (distinguishing various document designations, including "Confidential," "Highly Confidential – Attorneys' Eyes Only," and "Highly Confidential – Patent Prosecution Bar").) With respect to your request that we identify by name Cooley attorney(s) involved in prosecution work for Bumble, we do not believe the identify of specific prosecution attorney(s) is relevant. Our position is the same regardless of the specific attorney involved, and we do not plan to identify any specific individuals in our argument. We can tell you that it is not any attorney that has entered an appearance in this litigation. 6 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, January 7, 2019 7:10 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, I will check on that as well. I'm optimistic that I could convince my client to sign off on the mutual exchange with no further briefing, but only under certain conditions. Would you be willing to send any entered protective orders or decisions that refused to implement an ethical wall in analogous circumstances now? If you don't have any, could you at least explain at a high level what your argument opposing the ethical wall is going to be? I'm not asking for your brief obviously, but at least a good faith description of your position and best support. Also, if y'all are planning to rely on any facts related to the subject matter prosecution efforts or of the relationship between prosecution counsel and litigation counsel or anything like that, we should in fairness know that ahead of the exchange. Although the closed-briefing, timed mutual exchange after a fulsome meet-and-confer process is my personal preference in filing like this, my fear is that you folks already know the general basis for our position but we're a bit more in the dark on yours and on the facts that may support or rebut it, which are distinctly within your possession. Right now, all we really know is that you want to have Bumble prosecution counsel that works at Cooley be able to help Cooley litigation counsel on invalidity issues. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, January 07, 2019 5:46 PM 6 To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Thanks John. One follow-up to the call—upon further consideration we'd prefer the procedure you suggested where both parties exchange their arguments and those are filed without further edits, rather than the one revision approach. Let me know if that still works 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, January 7, 2019 6:28 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, I think this is probably fine, but let me confirm with the team. Regards, John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, January 07, 2019 5:09 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Thanks John. I still need to run your revisions by our team, but for discussion purposes only, would Match agree to a slight modification of the following (shown in red): 1. To the extent a producing Party believes that certain Protected Material qualifying to 6 be designated CONFIDENTIAL is a trade secret or so sensitive that its dissemination deserves even further limitation, the producing Party may designate such Protected Material "RESTRICTED -- ATTORNEYS' EYES ONLY," or to the extent such Protected Material is computer source code and/or live data (that is, data as it exists residing in a database or databases) ("Source Code Material"), the producing Party may designate such Protected Material as "RESTRICTED CONFIDENTIAL SOURCE CODE." A producing party should not designate Protected Material RESTRICTED CONFIDENTIAL SOURCE CODE simply because a party's document (as opposed to a case filing or disclosure) refers to source code. However, if a party designates a document containing an excerpt of source code (as opposed to a native source code file itself) as RESTRICTED CONFIDENTIAL SOURCE CODE, that document should be produced in a separate directory or folder on the source code computer from the source code files themselves, unless that file is stored with the source code files in the ordinary course of business. To be clear if a document found elsewhere in the collection contained an excerpt of source code we would produce it in a separate directory. However, sometimes companies store non-source code files related to source code files with source code files. In that case we would produce those documents in the original folder structure (which I imagine Match would prefer). Let us know if that is agreeable. 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, January 7, 2019 5:56 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> 6 Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, Please see the attached redline. Please let me know when you have the information on Bumble's prosecution counsel. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, January 07, 2019 2:58 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, My apologies for not responding sooner. Today has gotten away from me. I'm available to discuss if you're free. I'm also free to discuss tomorrow morning if you prefer. 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, January 7, 2019 2:30 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi Rose, Did you still want to chat on these open issues today? -John 6 From: John Summers Sent: Friday, January 04, 2019 4:47 PM To: 'Whelan, Rose' <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, Thanks for getting back to me. I will take a look, and let's plan to chat on Monday afternoon. I should be available any time during that window. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Friday, January 04, 2019 3:41 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, Thank you for following up on this. Attached is a revised draft, however, we reserve the right to amend this draft based on additional input. We were able to agree to some of your proposals. For others we have made some additional revisions for your consideration. We are not able to agree to the ethical wall language in the prosecution bar section. We have inserted our alternative proposal. One point of clarification on your ethical wall provision that would be helpful—do you interpret that provision as applying only to outside counsel? It might make sense to have a brief follow-up meet and confer early next week. What is 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 6 From: John Summers <jsummers@caldwellcc.com> Sent: Thursday, January 3, 2019 11:08 AM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi Rose, I hope you were able to get a bit of a break over the holidays. Did you have an opportunity to look at this? Let me know if this proposal works. Regards, John From: John Summers Sent: Thursday, December 20, 2018 5:06 PM To: 'Whelan, Rose' <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi Rose, Attached is a redline of the most recent version of the PO based on our discussion yesterday. You had also asked about sample protective Orders about a couple of provisions. First, you wanted to see a P.O. where there were no page limits. To that end, I've attached a protective order entered into in a case between Baird v. BlinkMind, Inc., a case in which Cooley was defense counsel. In paragraph 8.7, you'll see that there's a consecutive page limit but not a total page limit and the burden-shifting is similar to what is in the current draft. You had also asked about a Protective Order provision concerning the use of a non-networked laptop, provided by the producing party, in the source code computer room for purposes of taking notes. On that point, I'm attached a Protective Order from the nCap v. Apple Inc. case at Paragraph 11.c.(iii). Let me know if it makes sense to discuss further or if you have any changes. Regards, John From: Whelan, Rose <rwhelan@cooley.com> Sent: Thursday, December 20, 2018 1:38 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble 6 Hi John, Thanks for putting this together. Please change the signature from Joe's signature to mine, but otherwise you have permission to file. 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: Thursday, December 20, 2018 2:31 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, Attached is a draft joint filing and proposed order. -John From: John Summers Sent: Thursday, December 20, 2018 12:56 PM To: 'Whelan, Rose' <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Yes, I think we're saying the same thing. If a document is marked "confidential," it would be treated as AEO until the protective order is entered. At that point, it would revert to the "confidential" designation and could be shown to anyone cleared to view material marked "confidential" under the PO. (Material marked AEO would obviously remain AEO.) 6 We will prepare the filing and circulate for your review. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Thursday, December 20, 2018 12:52 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, We are in agreement on the extension and maintaining any documents produced with any confidentiality designation before a protective order issues on an attorneys eyes only basis until the protective order issues. I believe this is what you are contemplating, but just to clarify, to the extent the documents are not actually deserving of the attorneys eyes only designation we would expect them to be down-designated once a protective order issues. Are you going to put together a filing to alert the Court of the agreed extension? 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: Thursday, December 20, 2018 1:03 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, Following up on our call yesterday, I think it makes sense to agree to an extension to continue our discussions on the protective order. I propose that we extend the deadline until January 8, 2019. Maybe we'll be able to get something on file before then, but that way we won't have to wrestle with conferring over the holidays for anything we can get worked out this week. 6 Since a protective order might not be filed or entered before a potential production occurs, please also confirm that any production labeled with any level of confidentiality occurring between now and entry of a protective order will be treated on an outside-attorney's-eyes only basis, and that any violation of that provision would be enforced as a violation of the to-be-filed protective order. If you're in agreement, please confirm so in writing. I will send an additional redline of the draft P.O. itself, consistent with our discussion, later today. Thank you. -John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, December 17, 2018 3:05 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, 2:00 p.m. Central Wednesday works for me. Thanks. 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, December 17, 2018 4:01 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, 6 Thank you for providing this today. It looks like we will have a few things to talk about. Why don't we plan to chat on Wednesday at 2:00 PM Central if that works? Regards, John From: Whelan, Rose <rwhelan@cooley.com> Sent: Monday, December 17, 2018 1:58 PM To: John Summers <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, Following up on this, attached is a revised draft incorporating our proposed edits. This is still subject to client approval, so we may have additional edits, but wanted to provide this now to move the ball forward. Let us know when will work for you to discuss. My schedule is tough tomorrow, but at least for now is generally open on Wednesday and Thursday. 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: Whelan, Rose Sent: Monday, December 17, 2018 10:52 AM To: 'John Summers' <jsummers@caldwellcc.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Hi John, We are reviewing the protective order and will have some proposed revisions. I hope to get you a revised draft later today or tomorrow. Are you available on Wednesday to meet and confer on this prior to filing on Thursday? 6 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, December 17, 2018 10:46 AM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: RE: Match v. Bumble Rose, I am following up on my e-mail below. Are there any issues with the protective order? Let us know. -John From: John Summers Sent: Tuesday, December 11, 2018 3:25 PM To: Whelan, Rose <rwhelan@cooley.com>; Drayton, Joe <jdrayton@cooley.com> Cc: Brad Caldwell <bcaldwell@caldwellcc.com> Subject: Match v. Bumble Rose, As promised, attached is a draft protective order. There may be some additional changes after further review from the client, but this should be close enough to start your review and our discussion. Please take a look and see if this works. If not, let me know what changes you'd propose and when you would like to discuss. Regards, John John F. Summers /// Caldwell Cassady & Curry 2101 Cedar Springs Rd., Suite 1000, Dallas, TX 75201 Telephone: 214.888.4847 6 jsummers@caldwellcc.com www.caldwellcc.com 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. 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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. 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. 6 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. 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