Exhibit 2 

Case 5:17-cv-00220-LHK Document 682-2 Filed 04/12/18 Page 1 of 8
PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S THIRD INTERROGATORIES

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

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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 

PLAINTIFF FEDERAL TRADE 

COMMISSION’S OBJECTIONS AND 

RESPONSES TO DEFENDANT 

QUALCOMM’S THIRD SET OF 

INTERROGATORIES 

Pursuant to Federal Rules of Civil Procedure 26 and 33 and the Local Civil Rules of the 

United States District Court for the Northern District of California, the Case Management Orders 

entered by the Court in the above-captioned action on April 19, 2017 (ECF No. 75) and 

November 15, 2017 (ECF No. 308), and the Protective Order Governing Confidential Material 

entered May 1, 2017 (ECF No. 81) (“Protective Order”), Plaintiff Federal Trade Commission 

(“FTC”) submits these Objections and Responses to Defendant Qualcomm Incorporated’s Third 

Set of Interrogatories (“Third Interrogatories”), dated February 16, 2018. 

The FTC will supplement and amend these objections and responses in accordance with 

Federal Rule of Civil Procedure 26(e), including by asserting additional or different objections 

when and if it becomes necessary. 

GENERAL OBJECTIONS 

The following General Objections apply to each of Qualcomm’s Interrogatories and are 

incorporated into each subsequent Interrogatory. 

1. The FTC objects that Qualcomm has exceeded the limit of 20 interrogatories set by the 

April 19, 2017 Case Management Order (ECF No. 75). 

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PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S THIRD INTERROGATORIES

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2. The FTC objects that the usefulness of each interrogatory is outweighed by the burden of 

responding to it. 

3. The FTC objects that each interrogatory is comprised of multiple distinct subparts. 

The FTC reserves all rights to assert additional objections to and / or respond to each 

interrogatory should the Court determine that it falls within Qualcomm’s allowance of 20 

interrogatories. 

OBJECTIONS AND RESPONSES TO SPECIFIC INTERROGATORIES 

Subject to and without waiver of the foregoing General Objections, or any other 

objections or claims of privilege, the FTC presents its Specific Objections to Qualcomm’s Third 

Interrogatories. 

Interrogatory No. 16 

If You contend that any Baseband Processor supplier needed or desired a License from 

Qualcomm but was unable to obtain such a License, provide the following information: 

a) The identity of each such Baseband Processor supplier; 

b) Whether each identified Baseband Processor supplier brought a FRAND Challenge 

against Qualcomm for any alleged refusal by Qualcomm to license its Cellular SEPs; 

c) The reasons each identified Baseband Processor supplier did not bring a FRAND 

Challenge against Qualcomm; and 

d) All other facts and documents supporting Your contention. 

RESPONSE: 

The FTC incorporates by reference its General Objections. 

Interrogatory No. 17 

If You contend that Qualcomm’s practices of (1) not selling chips to companies without a 

Qualcomm License or (2) not licensing companies that make or sell baseband processors 

(collectively “Qualcomm’s Licensing Practices”) caused the demand for any Baseband 

Processor supplier’s products to be reduced because of a raise in any Cellular Device 

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PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S THIRD INTERROGATORIES

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manufacturer’s all-in prices (as that term is used in ¶63 of the Complaint), provide the following 

information: 

a) Identify each such Baseband Processor supplier and each such affected Baseband 

Processor product; 

b) Specify the sales volume, by product, for each identified Baseband Processor 

supplier’s products during the relevant period of time; 

c) Specify what the sales volume, by product, for each identified Baseband Processor 

supplier’s products would have been absent the Qualcomm Licensing Practices 

claimed to have caused the reduction in demand; 

d) Identify each Cellular Device manufacturer whose all-in prices were raised; 

e) Specify the amount by which each identified Cellular Device manufacturer’s all-in 

prices were raised because of Qualcomm’s Licensing practices, by product; and 

f) All facts and documents supporting Your contention.

RESPONSE: 

The FTC incorporates by reference its General Objections. 

Interrogatory No. 18 

If You contend that the existence or terms of any Agreement between Qualcomm and a 

Qualcomm Licensee or other Cellular Device manufacturer involving any marketing fund, 

market development fund, strategic fund, incentive fund, or similar fund or payment (collectively, 

“Fund”), caused the Licensee or other Cellular Device manufacturer to select a Qualcomm 

Baseband Processor for a Cellular Device over a competitor’s Baseband Processor, provide the 

following: 

a) Identify each such Licensee or other Cellular Device manufacturer; 

b) Identify the competitor and Baseband Processor product that would have been 

selected absent the Fund, for each Cellular Device model of each identified Licensee 

or other Cellular Device manufacturer; 

c) Identify any anticompetitive effect caused by any Fund; and 

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PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S THIRD INTERROGATORIES

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d) All facts supporting Your contention. 

RESPONSE 

The FTC incorporates by reference its General Objections. 

Dated: March 30, 2018 Respectfully submitted, 

/s/ J. Alexander Ansaldo 

 J. Alexander Ansaldo 

 FEDERAL TRADE COMMISSION 

 600 Pennsylvania Avenue, NW 

 Washington, DC 20580 

 (202) 326-3695 

 jansaldo@ftc.gov 

Counsel for Plaintiff Federal Trade 

Commission 

Case 5:17-cv-00220-LHK Document 682-2 Filed 04/12/18 Page 5 of 8
PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S FOURTH INTERROGATORIES

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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 

PLAINTIFF FEDERAL TRADE 

COMMISSION’S OBJECTIONS AND 

RESPONSES TO DEFENDANT 

QUALCOMM’S FOURTH SET OF 

INTERROGATORIES 

Pursuant to Federal Rules of Civil Procedure 26 and 33 and the Local Civil Rules of the 

United States District Court for the Northern District of California, the Case Management Orders 

entered by the Court in the above-captioned action on April 19, 2017 (ECF No. 75) and 

November 15, 2017 (ECF No. 308), and the Protective Order Governing Confidential Material 

entered May 1, 2017 (ECF No. 81) (“Protective Order”), Plaintiff Federal Trade Commission 

(“FTC”) submits these Objections and Responses to Defendant Qualcomm Incorporated’s Fourth 

Set of Interrogatories (“Fourth Interrogatories”), dated February 23, 2018. 

The FTC will supplement and amend these objections in accordance with Federal Rule of 

Civil Procedure 26(e), including by asserting additional or different objections when and if it 

becomes necessary. 

GENERAL OBJECTIONS 

The following General Objections apply to each of Qualcomm’s Interrogatories and are 

incorporated into each subsequent Interrogatory. 

1. The FTC objects that Qualcomm has exceeded the limit of 20 interrogatories set by the 

April 19, 2017 Case Management Order (ECF No. 75). 

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PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S FOURTH INTERROGATORIES

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2. The FTC objects that the usefulness of each interrogatory is outweighed by the burden of 

responding to it. 

3. The FTC objects that each interrogatory is comprised of multiple distinct subparts. 

The FTC reserves all rights to assert additional objections to and / or respond to each 

interrogatory should the Court determine that it falls within Qualcomm’s allowance of 20 

interrogatories. 

OBJECTIONS AND RESPONSES TO SPECIFIC INTERROGATORIES 

Subject to and without waiver of the foregoing General Objections, or any other 

objections or claims of privilege, the FTC presents its Specific Objections to Qualcomm’s Fourth 

Interrogatories. 

Interrogatory No. 19 

If you contend that Qualcomm ever charged any Cellular Device manufacturer a price 

for a Baseband Processor that was lower than Qualcomm's cost of such Baseband Processor, 

then identify: 

a) Each such Cellular Device manufacturer; 

b) Each Baseband Processor Qualcomm sold below Qualcomm's cost; 

c) Qualcomm's costs you contend were higher than the prices of such Baseband 

Processors, including whether such costs represent Qualcomm's marginal costs, 

average variable costs or some other measure of costs; 

d) the price at which such Baseband Processors were sold; and 

e) any “penalties”, “discounts” or rebates You contend should be applied to lower the 

effective price of such Baseband Processors, including those alleged in Paragraph 

125(c) of Your Complaint, and all reasons You contend such penalties, discounts or 

rebates should be applied to Baseband Processors you contend were sold below cost 

rather than to other Baseband Processors. 

RESPONSE: 

The FTC incorporates by reference its General Objections. 

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PLAINTIFF FEDERAL TRADE COMMISSION’S OBJECTIONS AND RESPONSES TO DEFENDANT QUALCOMM 

INCORPORATED’S FOURTH INTERROGATORIES

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Interrogatory No. 20 

Interpreting all quoted terms as used in your response to Interrogatory Nos. 4 and 5, for 

each “premium handset” that You contend was marketed or sold from 2011 to the present, 

provide the following: 

a) Identify each such “premium handset” by make and model; 

b) Identify all “reasonable substitutes” (if any) for each of the handsets so identified; 

c) Identify and describe each “unique feature” (if any) of each handset so identified that 

makes it a “premium handset”; and 

d) Provide all facts supporting any “industry recognition” of “premium handsets” as a 

“distinct product market.” 

RESPONSE: 

The FTC incorporates by reference its General Objections. 

Dated: March 30, 2018 Respectfully submitted, 

/s/ J. Alexander Ansaldo

 J. Alexander Ansaldo 

 FEDERAL TRADE COMMISSION 

 600 Pennsylvania Avenue, NW 

 Washington, DC 20580 

 (202) 326-3695 

 jansaldo@ftc.gov 

Counsel for Plaintiff Federal Trade 

Commission 

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