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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

Jennifer Milici, D.C. Bar No. 987096 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Avenue, N.W. 

Washington, D.C. 20580 

(202) 326-2912; (202) 326-3496 (fax) 

jmilici@ftc.gov 

Lin W. Kahn, Cal. Bar No. 261387 

FEDERAL TRADE COMMISSION 

901 Market Street, Suite 570 

San Francisco, CA 94103 

(415) 848-5115; (415) 848-5184 (fax) 

lkahn@ftc.gov 

Attorneys for Plaintiff Federal Trade Commission in Case No. 17-cv-00220-LHK-NMC 

SUSMAN GODFREY L.L.P. 

Kalpana Srinivasan (237460) 

1900 Avenue of the Stars, Suite 1400 

Los Angeles, CA 90067 

(310) 789-3100; (310) 789-3006 (fax) 

ksrinivasan@susmangodfrey.com 

COTCHETT, PITRE & MCCARTHY 

Adam J. Zapala (175481) 

840 Malcolm Road, Suite 200 

Burlingame, CA 94010 

(650) 697-6000; (650) 697-0577 (fax) 

azapala@cpmlegal.com 

Plaintiffs’ Interim Co-Lead Counsel in Case No. 17-md-02773-LHK-NMC 

CRAVATH, SWAINE & MOORE LLP 

Gary A. Bornstein (pro hac vice) 

Yonatan Even (pro hac vice) 

825 Eighth Avenue 

New York, New York 10019-7475 

(212) 474-1000; (212) 474-3700 (fax) 

gbornstein@cravath.com 

yeven@cravath.com 

KEKER, VAN NEST & PETERS LLP 

Robert A. Van Nest (SBN 84065) 

633 Battery Street 

San Francisco, CA 94111-1809 

(415) 391-5400; (415) 397-7188 (fax) 

rvannest@keker.com 

MORGAN, LEWIS & BOCKIUS LLP 

Donn P. Pickett (SBN 72257) 

Geoffrey T. Holtz (SBN 191370) 

One Market, Spear Street Tower San 

Francisco, CA 94105-1596 

(415) 442-1000; (415) 442-1001 (fax) 

donn.pickett@morganlewis.com 

geoffrey.holtz@morganlewis.com 

Attorneys for Defendant Qualcomm Incorporated 

Additional counsel listed on signature pages 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

FEDERAL TRADE COMMISSION

Plaintiff,

v.

QUALCOMM INCORPORATED, a 

Delaware corporation,

Defendant.

Case No. 5:17-CV-00220-LHK-NMC

SUPPLEMENTAL JOINT CASE 

MANAGEMENT STATEMENT

IN RE QUALCOMM ANTITRUST 

LITIGATION

Case No. 5:17-MD-02773-LHK-NMC

Case 5:17-cv-00220-LHK Document 633 Filed 03/20/18 Page 1 of 14
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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

On March 15, 2018, Qualcomm Incorporated (“Qualcomm”) and the Federal Trade 

Commission (“FTC”) jointly filed with this Court in Case No. 5:17-cv-00220-LHK-NMC a case 

management statement that discussed, among other issues, the status of various issues related to 

third party discovery. (ECF No. 621.) On March 15, 2018, Qualcomm and MDL Plaintiffs also 

jointly filed a case management statement in Case No. 5:17-md-02773-LHK-NMC, which 

discussed issues related to third party discovery. (ECF No. 382.) On March 16, 2018, the Court 

noted that the FTC, Qualcomm, and the MDL Plaintiffs (collectively, the “N.D. Cal. Parties”) 

“all seek third party discovery beyond the deadlines set by the Court”. (ECF No. 384.) The 

Court ordered the N.D. Cal. Parties “to meet and confer on these issues and submit updated Joint 

Case Management Statements by March 20, 2018.” (Id.) Counsel for the N.D. Cal. Parties and 

third party Apple Inc. (“Apple”) met and conferred on March 19, 2018. Counsel for the N.D. 

Cal. Parties met and conferred again on March 20, 2018.

A. Proposed Modifications to the Deposition Schedule

Following the meet and confers, the N.D. Cal. Parties agreed to jointly request 

permission for the following out-of-time third-party depositions:

Company Witness Date

Essential Products Andy Rubin April 2, 2018

InterDigital 30(b)(6) April 3, 2018 or April 4, 2018

Essential Products Matt Hershenson April 5, 2018

Lenovo Ira Blumberg April 10, 2018

Nokia 30(b)(6) April 17, 2018

Apple Bruce Sewell1[TBD]

 

1 Mr. Sewell’s deposition was originally scheduled for March 21-22, 2018 but needed to be 

postponed because of a personal matter. Apple is determining his availability in April.

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

B. Further Modifications to the Case Schedule

1. FTC Action (Case No. 5:17-cv-00220-LHK-NMC)

In light of the additional depositions described in Section A above, Qualcomm and the

FTC further propose for the Court’s approval the below revisions to the Court’s current schedule 

in Case No. 5:17-cv-00220-LHK-NMC. 

Plaintiff’s Opening Expert Reports April 30, 2018 (currently April 20, 2018)

Defendant’s Expert Reports June 4, 2018 (currently May 25, 2018)

Plaintiff’s Rebuttal Expert Reports July 2, 2018 (currently June 22, 2018)

Close of Expert Discovery July 27, 2018 (currently July 20, 2018)

All subsequent dates in the Court’s schedule would remain unchanged.

2. MDL Action (Case No. 5:17-MD-02773-LHK-NMC)

The MDL Plaintiffs and Qualcomm disagree as to whether outstanding third-party 

discovery warrants a change in the case schedule.

i. Plaintiff’s Position:

MDL Plaintiffs also propose for the Court’s approval the below revisions to the Court’s current 

schedule in Case No. 5:17-cv-02773-LHK-NMC.

MDL Plaintiffs’ Motion for Class 

Certification and supporting expert 

declarations

May 17, 2018 (currently May 3, 2018)

Defendant’s Opposition June 22, 2018 (currently June 8, 2018)

MDL Plaintiffs’ Reply July 20, 2018 (currently July 6, 2018)

Class Certification Hearing July 26, 2018 (unchanged)

All subsequent dates in the Court’s schedule would remain unchanged.

While Qualcomm does not join in MDL Plaintiffs’ proposal, MDL Plaintiffs note that 

revisions to the Court’s schedule are appropriate given the ongoing document productions by 

Qualcomm, the additional depositions, and given that the MDL Plaintiffs’ schedule was set to 

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Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

correspond to the FTC schedule. Qualcomm’s recognition of the need for an extension as to 

expert reports in the FTC case highlights the corresponding need for MDL Plaintiffs to have 

additional time to prepare their Class Certification Motion. A failure to account for late 

discovery in the MDL case would benefit Qualcomm, to MDL Plaintiffs’ detriment. Indeed, 

Qualcomm itself initially proposed that MDL Plaintiffs’ Motion for Class Certification would 

not be due until June 22 (with a May 6, 2019 trial date – just one week later than the trial date the 

Court has set). Dkt. 32. Additionally, the short extension is warranted given that Qualcomm is 

continuing to make large document productions. On March 17, 2018 alone, Qualcomm 

produced 3.8 million pages in the S.D. Cal. action, which appear relevant to this action as well. 

MDL Plaintiffs are also ingesting thousands of documents recently produced by Qualcomm in 

conjunction with their privilege re-review. Finally, just last week, Judge Cousins issued an order 

requiring Qualcomm to significantly revise its privilege log, which will almost certainly result in 

additional document productions. Although MDL Plaintiffs are evaluating the impact of these 

productions on the brink of the close of fact discovery, shifting the deadlines by two weeks is 

needed, particularly because such a modification to the schedule will not impact the hearing date 

for MDL Plaintiffs’ Motion to Certify the Class. 

Contrary to Qualcomm’s claim, Plaintiffs have diligently pursued discovery. Since the 

start of fact discovery, Plaintiffs have negotiated third party productions from over 50 different 

third parties – including obtaining the production of significant amounts of class-specific 

transactional data from cell phone manufacturers, retailers, and wireless carriers. Plaintiffs have 

also participated in approximately 60 depositions since January, with approximately 20 more 

depositions already scheduled. Plaintiffs’ request for a two week extension is due to the late 

discovery occurring in this case – the same discovery that Qualcomm thinks warrant an 

extension for the deadlines in the FTC action. Qualcomm has also not explained any burden that 

it would bear as a result of a change in the class certification deadlines. In addition, Plaintiffs 

intentionally proposed a change to the schedule that would allow the court to keep the current 

date for the class certification hearing but the Court could set a date for the class certification 

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

hearing two weeks later without altering any other deadlines in the case. 

ii. Qualcomm’s Position:

Qualcomm does not believe that the limited out-of-time third-party depositions described 

above warrant a change to the class certification briefing schedule. Qualcomm expects that the 

above-listed third-party depositions will be minimally, if at all, relevant to class certification 

issues. The non-Apple depositions are of other intellectual property licensors whose practices 

are similar to Qualcomm’s. This testimony will likely relate primarily to liability, not class 

certification. And, in any event, the last scheduled third-party deposition will occur on April 17, 

2018—weeks before the deadline to file a class-certification motion. Thus, Plaintiffs will have 

ample time to incorporate any relevant information into their motion. Moreover, Plaintiffs’ 

proposal would make their reply brief on class certification due a mere six days prior to the 

hearing on the motion. Plaintiffs’ complaints about the documents Qualcomm produced in the 

Southern District action and its complaints about the privilege log lack merit for the reasons 

detailed in Qualcomm’s prior case management statements, submissions to Magistrate Judge 

Cousins, and which are repeated briefly in Part D below. Moreover, Plaintiffs have made no 

showing, much less a compelling one, that the materials in question are non-cumulative as to 

class certification issues (or otherwise).

The Court heard the parties’ proposals regarding the overall case schedule and then 

determined what deadlines were appropriate in light of the overall demands of the MDL case. 

Plaintiffs’ insistence that the MDL schedule should “correspond” to the FTC case schedule does 

not make sense because the MDL case requires a class-certification motion while the FTC case 

does not.

The real issue here is that Plaintiffs waited far too long to serve their own discovery and 

now seek a schedule extension to complete that discovery. As further detailed in the Parties’ 

JCMS of last week, Plaintiffs waited until March 6 to request the depositions of six additional 

Qualcomm employees, all of whom Plaintiffs knew about for months, and waited until March 7 

to serve the document subpoenas mentioned below in Part C on four third parties. The 

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

depositions mentioned below in Part C fare no better. Plaintiffs did not serve notice of their 

intent to notice a deposition of Avanci until March 10, and did not serve the Apple deposition 

notice until March 15. The fact that some third-party depositions have not yet occurred should 

not excuse Plaintiffs’ lack of diligence in pursuing discovery.

C. Additional Third-Party Issues

Qualcomm and the MDL Plaintiffs note the following outstanding disagreements that one 

or more parties have with each other or with third parties concerning third party discovery in the 

above-captioned cases: (1) MDL Plaintiffs’ March 7, 2018 subpoenas served on BrightPoint 

North America LLC, Brightstar US, Inc., JEG & Sons, Inc. and Synnex Corp; (2) MDL 

Plaintiffs’ request for a 30(b)(6) deposition of Avanci, LLC; and (3) MDL Plaintiffs’ request for 

a 30(b)(6) deposition of Apple. 

This Supplemental Joint Case Management Statement is made without prejudice to any 

of the N.D. Cal. Parties’ positions regarding the appropriateness of any of this additional 

discovery. 

D. Qualcomm Discovery Issues

The N.D. Cal. Parties note the following outstanding disagreements concerning 

Qualcomm-related discovery in the above-captioned cases, which have not yet been resolved: 

(1) MDL Plaintiffs’ request for depositions for three Qualcomm employees, Messrs. Edward 

Tiedemann, Alexander Katouzian, and David Cianflone; (2) certain topics contained in the 

FTC’s request for a Rule 30(b)(6) deposition of Qualcomm; and (3) MDL Plaintiffs’ request for 

a Rule 30(b)(6) deposition of Qualcomm. In addition to noting the above issues, which remain 

under discussion, the parties note the following open issues:

1. FTC and MDL Plaintiffs’ Position:

The FTC and MDL Plaintiffs note that, despite their best efforts, there are additional 

outstanding issues, unrelated to third party discovery, which may render the schedule set forth 

above in Section B insufficient. While the Plaintiffs will make every effort to comply with any 

modified schedule that is approved by the Court, there are a number of uncertainties that they 

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

seek to bring to the Court’s attention now in the event that further modifications to the schedule 

are requested.

Today, March 20, 2018, without explanation, Qualcomm notified the FTC and MDL 

Plaintiffs that Paul Jacobs is no longer available for his previously-scheduled deposition on 

March 29-30, 2018. As former CEO and Chairman of the Board, Mr. Jacobs is a key witness in 

this case. The parties are meeting and conferring regarding Qualcomm’s request to reschedule 

the deposition, including the reason for the schedule change, and alternative dates on which Mr. 

Jacobs is available. Qualcomm informed the FTC today that Dr. Jacobs can appear for 

deposition April 16-17, and later revised that proposal to as early as April 4-5, 2018. The FTC 

has an immovable conflict during the April 4-5 dates, and believes that April 17 is too late for 

such a significant deposition, but can be flexible in finding a mutually agreeable date during the 

week of April 9. The FTC and MDL Plaintiffs reserve the right to seek additional modifications 

to the schedule, particularly given the timing of the expert discovery deadlines and the 

importance of Mr. Jacobs’ testimony.

Further, the FTC and MDL Plaintiffs continue to receive large volumes of additional 

documents produced by Qualcomm, including those produced in the Southern District of 

California action, and as a result of the privilege re-review process ordered by Magistrate Judge 

Cousins. See March 15, 2018 Joint Case Management Statement (ECF No. 621) at pp. 9-10. 

Since submitting the last Joint Case Management Statement less than a week ago on March 15, 

2018, Qualcomm has produced over 3.8 million pages of additional documents in the 

coordinated actions. The FTC and MDL Plaintiffs continue to reserve all rights to re-open 

depositions based on the production of new documents that are responsive to their respective 

discovery requests but were not produced in time in order to allow for effective use at the 

depositions of relevant witnesses. As a result, it is possible that the continuation of additional 

large productions by Qualcomm may impact the case schedule.

2. Qualcomm’s Position:

The issues discussed above regarding discovery of Qualcomm are not properly presented 

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

in a Supplemental Joint Case Management Statement that the Court ordered regarding third party 

discovery. Nevertheless, because the FTC and MDL Plaintiffs have chosen to include these 

issues, Qualcomm responds as follows.

First, the postponement of Paul Jacobs’s deposition was not a matter within Qualcomm’s 

control. As has been widely reported, Dr. Jacobs ceased to be the Executive Chairman of the 

company as of March 9, 2018. Dr. Jacobs informed Qualcomm today (March 20, 2018) that he 

now has a scheduling conflict that will prevent him from appearing for deposition on the 

scheduled dates of March 29-30, 2018, but that he can appear for deposition in April, as early as 

April 4-5, 2018. Qualcomm immediately informed the FTC and MDL Plaintiffs of Dr. Jacobs’s 

unexpected unavailability. The brief postponement of his deposition should not cause any 

prejudice to the FTC and MDL Plaintiffs or require any adjustments to the schedule beyond 

those set forth in Part B above regarding expert reports in the FTC action.

Second, the FTC and MDL Plaintiffs’ assertion that they are prejudiced by Qualcomm’s 

“continuation of additional large productions” is not justified, for the reasons set forth in 

Part IV.A of the case management statement filed on March 15, 2018. (ECF No. 621.) As 

Qualcomm has explained, these productions are being made in response to document requests 

served on Qualcomm by Apple and its contract manufacturers in the Southern District of 

California action, not in response to requests made in the above-captioned actions by the FTC or 

MDL Plaintiffs. Qualcomm has produced these documents to the FTC and MDL Plaintiffs 

pursuant to requirements of the Coordination Order signed by this Court and Judge Curiel in the 

Southern District. The Southern District action is proceeding along a different schedule, with 

fact discovery ending on May 11, 2018, and the productions about which the FTC and MDL 

Plaintiffs complain are timely in the action in which they are being made. Qualcomm’s 

document productions in the Southern District of California action should not affect the 

schedules in the above-captioned actions. 

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

Dated: March 20, 2018

Respectfully submitted,

CRAVATH, SWAINE & MOORE LLP,

/s/ Gary A. Bornstein

Gary A. Bornstein

Yonatan Even

Worldwide Plaza

825 Eighth Avenue

New York, NY 10019

Tel: (212) 474-1000

Fax: (212) 474-3700

gbornstein@cravath.com

yeven@cravath.com

Robert A. Van Nest

Asim M. Bhansali 

Eugene M. Paige 

KEKER, VAN NEST & PETERS LLP

633 Battery Street

San Francisco, CA 94111-1809

Tel: (415) 391-5400

Fax: (415) 397-7188

rvannest@keker.com

abhansali@keker.com

epaige@keker.com

Richard S. Taffet 

MORGAN, LEWIS & BOCKIUS LLP

101 Park Avenue

New York, NY 10178-0060

Tel: (212) 309-6000

Fax: (212) 309-6001

richard.taffet@morganlewis.com

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

Case Nos. 17-cv-0220-LHK-NMC & 17-md-2773-LHK-NMC

Willard K. Tom

MORGAN, LEWIS & BOCKIUS LLP

1111 Pennsylvania Ave. NW

Washington, DC 20004-2541

Tel: (202) 739-3000

Fax: (202) 739 3001 

willard.tom@morganlewis.com

Donn P. Pickett

Geoffrey T. Holtz

MORGAN, LEWIS & BOCKIUS LLP

One Market, Spear Street Tower

San Francisco, CA 94105-1126

Tel: (415) 442-1000

Fax: (415) 442-1001

donn.pickett@morganlewis.com

geoffrey.holtz@morganlewis.com

Attorneys for Qualcomm Incorporated

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

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Dated: March 20, 2018

FEDERAL TRADE COMMISSION

/s/ Elizabeth A. Gillen

Jennifer Milici

Wesley G. Carson

J. Alexander Ansaldo

Joseph R. Baker

Elizabeth A. Gillen

Federal Trade Commission

600 Pennsylvania Avenue, N.W.

Washington, D.C. 20580

(202) 326-2912; (202) 326-3496 (fax)

jmilici@ftc.gov

Attorneys for Federal Trade Commission

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SUPPLEMENTAL JOINT CASE MANAGEMENT STATEMENT

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Dated: March 20, 2018

SUSMAN GODFREY, L.L.P.

/s/ Kalpana Srinivasan

Kalpana Srinivasan 

Marc M. Seltzer 

Steven G. Sklaver 

Amanda Bonn 

Oleg Elkhunovich

SUSMAN GODFREY L.L.P.

1900 Avenue of the Stars, Suite 1400 

Los Angeles, CA 90067

Tel: (310) 789-3100

Facsimile: (310) 789-3006

mksrinivasan@susmangodfrey.com 

mseltzer@susmangodfrey.com

ssklaver@susmangodfrey.com

abonn@susmangodfrey.com

oelkhunovich@susmangodfrey.com

Joseph Grinstein

SUSMAN GODFREY L.L.P.

1000 Louisiana Street # 5100

Houston, TX 77002

Telephone: (713) 651-9366

Facsimile: (713) 654-6666

jgrinstein@susmangodfrey.com

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Joseph W. Cotchett 

Adam J. Zapala 

Brian Danitz

Mark F. Ram 

Michael A. Montaño

COTCHETT, PITRE & MCCARTHY, LLP

840 Malcolm Road, Suite 200

Burlingame, CA 94010

Telephone: (650) 697-6000

Facsimile: (650) 697-0577 

jcotchett@cpmlegal.com 

azapala@cpmlegal.com

bdanitz@cpmlegal.com

mram@cpmlegal.com

mmontano@cpmlegal.com

Plaintiff’s Interim Co-Lead Counsel

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FILER’S ATTESTATION

I, _______Gary A. Bornstein_______, am the ECF user whose identification and 

password are being used to file this Joint Stipulation and [Proposed] Order to Continue Case 

Management Conference. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that the 

signatories on this document have concurred in this filing.

 /s/ Gary A. Bornstein

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