REPLY EXHIBIT 2

Case 5:17-cv-00220-LHK Document 889-3 Filed 10/04/18 Page 1 of 4
+1-212-474-1686

jcarlson@cravath.com

June 28, 2018

In re: Qualcomm Litigation, No. 17-cv-0108 (S.D. Cal.)

FTC v. Qualcomm Incorporated, No. 17-cv-0220 (N.D. Cal.)

In re: Qualcomm Antitrust Litigation, No. 17-md-02773 (N.D. Cal.)

Dear Counsel:

Below please find credentials for an FTP site containing non-privileged 

documents Bates numbered QAPPCMSD10052188 – QAPPCMSD10052361, which 

Qualcomm is producing in response to Apple Inc.’s First Set of Requests for Production, 

dated July 28, 2017, Apple Inc.’s Second Set of Requests for Production, dated 

January 18, 2018, Apple Inc.’s Third Set of Requests for Production, dated February 5, 

2018, Apple Inc.’s Fourth Set of Requests for Production, dated March 30, 2018, Apple 

Inc.’s Fifth Set of Requests for Production, dated April 11, 2018, Compal Electronics, 

Inc., FIH Mobile Ltd., Hon Hai Precision Industry Co., Ltd., Pegatron Corporation, and 

Wistron Corporation’s (collectively, the “CMs”) First Set of Requests for Production, 

dated September 18, 2017, the CMs’ Second Set of Requests for Production, dated 

October 31, 2017, the CMs’ Third Set of Requests for Production, dated February 26, 

2018, and the CMs’ Fourth Set of Requests for Production, dated April 11, 2018

(collectively, the “Requests”). The credentials to access the contents of this production 

will be sent to you separately by email.

URL: https://fileshare.cravath.com

Username: 002614_00150_062718_01

Qualcomm makes this production subject to its Responses and Objections 

to Apple Inc.’s First Set of Requests for Production, dated September 5, 2017; its 

Responses and Objections to Apple Inc.’s Second Set of Requests for Production, dated 

February 20, 2018; its Responses and Objections to Apple Inc.’s Third Set of Requests 

for Production, dated March 7, 2018; its Responses and Objections to Apple Inc.’s Fourth 

Case 5:17-cv-00220-LHK Document 889-3 Filed 10/04/18 Page 2 of 4
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Set of Requests for Production, dated April 30, 2018; its Responses and Objections to 

Apple Inc.’s Fifth Set of Requests for Production, dated May 14, 2018; its Responses and 

Objections to the CMs’ First Set of Requests for Production, dated September 29, 2017; 

its Responses and Objections to the CMs’ Second Set of Requests for Production, dated 

November 30, 2017; its Responses and Objections to the CMs’ Third Set of Requests for 

Production, dated March 28, 2018; its Responses and Objections to the CMs’ Fourth Set 

of Requests for Production, dated May 14, 2018; and any supplements or amendments 

thereto. Qualcomm will make additional productions in response to the Requests on a 

rolling basis.

Pursuant to paragraph 4 of the Joint Stipulation and Discovery 

Coordination Order, entered in In re: Qualcomm Litigation, No. 17-cv-0108 (S.D. Cal.), 

on January 25, 2018, ECF No. 295, in FTC v. Qualcomm Incorporated, No. 17-cv-0220 

(N.D. Cal.), on January 24, 2018, ECF No. 513, and In re: Qualcomm Antitrust 

Litigation, No. 17-md-2773 (N.D. Cal.), on January 24, 2018, ECF No. 305, Qualcomm 

also is producing these documents in FTC v. Qualcomm Incorporated, No. 17-cv-0220-

LHK-NMC (N.D. Cal.), and In re: Qualcomm Antitrust Litig., No. 17-md-2773-LHKNMC (N.D. Cal.).

These documents are produced pursuant to the Protective Order 

Governing Confidential Material, entered in FTC v. Qualcomm Incorporated, No. 17-cv0220 (N.D. Cal.) on May 1, 2017, ECF No. 81, and the Protective Order Governing 

Confidential Material, entered in In re: Qualcomm Antitrust Litigation, No. 17-md-2773 

(N.D. Cal.) on May 29, 2017, ECF No. 46 (collectively, the “N.D. Cal. Protective 

Orders”), and the Protective Order Governing Confidential Material, entered in In re: 

Qualcomm Litigation, No. 17-cv-0108 (S.D. Cal.) on October 24, 2017, ECF No. 163 

(the “S.D. Cal. Protective Order”). This production contains documents Qualcomm has 

designated “Highly Confidential – Attorneys’ Eyes Only”. Such documents should be 

treated in accordance with the N.D. Cal. and S.D. Cal. Protective Orders.

Sincerely,

/s/ James W. Carlson

James W. Carlson

Edward H. Takashima

Boies, Schiller & Flexner LLP 

401 Wilshire Blvd, Suite 850

Santa Monica, CA 90401

etakashima@bsfllp.com

Case 5:17-cv-00220-LHK Document 889-3 Filed 10/04/18 Page 3 of 4
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Theodore J. Boutrous, Jr.

Gibson, Dunn & Crutcher LLP 

333 South Grand Avenue

Los Angeles, CA 90071-3197

tboutrous@gibsondunn.com

Hugh F. Bangasser 

K&L Gates LLP

925 Fourth Avenue, Suite 2900

Seattle, Washington 98104 

hugh.bangasser@klgates.com

J. Alexander Ansaldo, Esq. 

Bureau of Competition

Federal Trade Commission 

400 Seventh Street, SW

Washington, DC 20024

jansaldo@ftc.gov

Adam J. Zapala, Esq.

Cotchett Pitre & McCarthy LLP 

840 Malcolm Road, Suite 200

Burlingame, CA 94010

azapala@cpmlegal.com

BY EMAIL

Copies to: Contact Attorneys listed in the Coordination Order

BY EMAIL

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