Match Group, LLC v. Bumble Trading Inc.

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

Exhibit C

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Exhibit C From: John Summers To: Drayton, Joe; Caplan, Matt; z/; Deron Dacus Cc:; John Palmer; Subject: 18-cv-80: Additional Parties Date: Tuesday, July 23, 2019 4:12:07 PM Counsel, As you know, we believe materials from Badoo and Worldwide Vision are unquestionably relevant to this case, and Bumble could easily produce these documents and make Badoo/Worldwide witnesses available—including Andrey Andreev and Idan Wallichman—to provide evidence related to the claims, counterclaims, and defenses in this lawsuit. Nevertheless, our understanding is that Bumble will not make these sources available absent court intervention. In light of this position, we wanted to let you know that we intend to add the Badoo entities and Worldwide as parties to the 18-cv-80 lawsuit on or before the August 2nd deadline to add parties. Alternatively, please let us know if Bumble will agree that: (1) relevant Badoo/Worldwide documents are under the custody and control of Bumble; (2) Match/IAC are permitted to depose relevant Badoo/Worldwide witnesses without need for a subpoena, including Idan Wallichman and Andrey Andreev; and (3) Badoo/Magic Lab/Worldwide agree to be bound by any adverse judgment against Bumble concerning Bumble's state law counterclaims. If not, please confirm that you will accept service for Badoo and Worldwide/Magic Lab entities when the amended complaint is filed. If you intend to decline to accept service, please let us know your availability for a call with the Court requesting alternative service through counsel. Regards, John F. Summers /// Caldwell Cassady & Curry 2101 Cedar Springs Rd., Suite 1000, Dallas, TX 75201 Telephone: 214.888.4847