Exhibit K 
From: 

To: 

Cc: 

Subject: 

Date: 

Attachments: 

Rueckhelm, Mike 

Bobby Delafield 

Timothy Grochoclnskl; Ed Nelson; Rylle Parkins; Vidal, Kathi; Dale. Ahtoosa; Arbaugh. Natalie; Winston-MicronUnification; Jon Rastegar; Tong. Peter; Melsheimer. Tom 

RE: Unification Techs. v. Micron, won<-6-20-cv-0500 

Friday, July 16, 202110:55:48 AM 

lmage002.!pg 

image003.png 

07.09.2021 U1l Letter to Micron re 3rd Party Code.pdf 

Counsel, we are in receipt of your July 9, 2021 letter (attached) requesting Micron to produce 

third party source code that is not in Micron's possession, custody or control. We are 

confused by your statement that " [b ]ased on the agreements between Micron and the 

Controller Suppliers, Micron has the right to inspect such source code." UTL has not cited to 

any language in a Micron agreement that would support your request. Also, the case opinions 

you cite are inapposite. See Polaris PowerLED Technologies LLC v. Vizio, Inc. (ordering 

production of documents when a redacted agreement was found to give the defendant the 

"legal right to obtain documents upon demand"); LSI Corp. v. Visio, Inc., Case No. A-12-CV191 LY, 2012 WL 1883998, *4 (W.D. Tex. May 22, 2012) (requested materials from "a 

related corporate entity"). UTL is apparently aware of the fact that the requested materials are 

not in Micron's possession, custody or control as shown by the fact that UTL is pursuing third 

party discovery through subpoena practice. We request that UTL produce all communications 

and responses to those subpoenas. 

-Mike 

Michael R. Rueckheim 

Partner 

Winston & Strawn LLP 

275 Middlefield Road, Suite 205 

Menlo Park, CA 94025 

D: +1 650-858-6433 

M: +1 713-444-4447 

F: +1 650-858-6550 

.6.i.Q I ~ I .Em.ail I wioston com 

Admitted to practice in California, New York, Texas 

~ From: Bobby Delafield <bobby@nbafirm.com> 

Sent: Friday, July 9, 20211:47 PM 

To: Rueckheim, Mike <MRueckheim@winston.com> 

Cc: Timothy Grochocinski <tim@nbafirm.com>; Ed Nelson <ed@nbafirm.com>; Rylie Parkins 

<rylie@nbafirm.com>; Vidal, Kathi <KVidal@winston. com>; Dale, Ahtoosa <ADale@winston.com>; 

Arbaugh, Natalie <NArbaugh@winston.com>; Winston-Micron-Unification <Winston-MicronUnification@winston.com>; Jon Rastegar <Jon@nbafirm.com>; Tong, Peter <PTong@winston.com>; 

Melsheimer, Tom <TMelsheimer@winston.com> 

Subject: RE: Unification Techs. v. Micron, WDTX-6-20-cv-0S00 
Counsel, 

Please see the attached correspondence. 

Regards, 

Bobby 

Bobby Delafield 

Nelson Bumgardner Albritton PC 

3131 West7th Street, Suite 300 

Fort Worth, Texas 76107 

Office: (817) 377-3486 

Cell: (512) 297-4462 

bobby@nbafirm.com 

Artboard 7 copy 9@2x 

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