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: Caplan, Matt To: John Summers Cc: Drayton, Joe; z/Bumble-Match.com; Deron Dacus; match@caldwellcc.com; John Palmer; melissa@gillamsmithlaw.com Subject: RE: 18-cv-80: Additional Parties Date: Thursday, July 25, 2019 1:31:10 PM Thanks, John. 5 CT today works. Matt Caplan Cooley LLP 101 California Street • 5th Floor San Francisco, CA 94111-5800 Direct: +1 415 693 2164 • Fax: +1 415 693 2222 • Cell: +1 310 528 1361 Bio: www.cooley.com/mcaplan • Practice: www.cooley.com/litigation Pronouns: he, him, his From: John Summers <jsummers@caldwellcc.com> Sent: Thursday, July 25, 2019 11:28 AM To: Caplan, Matt <mcaplan@cooley.com> Cc: Drayton, Joe <jdrayton@cooley.com>; z/Bumble-Match.com <zBumbleMatchcom@cooley.com>; Deron Dacus <ddacus@dacusfirm.com>; match@caldwellcc.com; John Palmer <Palmer@namanhowell.com>; melissa@gillamsmithlaw.com Subject: Re: 18-cv-80: Additional Parties Matt, I'll give you a call around 5 central today if that works. If not, I'm available at 10 central or after tomorrow. -John On Jul 25, 2019, at 11:08 AM, Caplan, Matt <mcaplan@cooley.com> wrote: Hi John, do you have time to discuss this later today or tomorrow? Matt Caplan Cooley LLP 310-528-1361 On Jul 23, 2019, at 2:12 PM, John Summers <jsummers@caldwellcc.com> wrote: 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 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. 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.