NON-PARTY APPLE’S STATUS REPORT RE: DOCUMENT PRODUCTION

CASE NOS. 5:17-CV-00220-LHK-NMC & 5:17-MD-02773-LHK-NMC

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BOIES SCHILLER FLEXNER LLP

William A. Isaacson (Pro Hac Vice App. to be filed)

DC Bar No. 414788, wisaacson@bsfllp.com

Karen L. Dunn (Pro Hac Vice App. to be filed)

DC Bar No. 1002520, kdunn@bsfllp.com

Amy J. Mauser (Pro Hac Vice App. to be filed)

DC Bar No. 424065, amauser@bsfllp.com

1401 New York Avenue, N.W.

Washington, DC 20005

Telephone: (202) 237-2727

Facsimile: (202) 237-6131

BOIES SCHILLER FLEXNER LLP

Edward H. Takashima, SBN 270945

etakashima@bsfllp.com 

401 Wilshire Blvd, Suite 850 

Santa Monica, CA 90401

Telephone: (310) 752-2400

Facsimile: (310) 752-2490

Attorneys for Non-Party APPLE INC.

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

NON-PARTY APPLE INC.’S STATUS 

REPORT REGARDING DOCUMENT 

PRODUCTION

Courtroom: 7, 4th Floor

Judge: Hon. Nathanael M. Cousins 

IN RE QUALCOMM ANTITRUST 

LITIGATION

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

Case 5:17-cv-00220-LHK Document 403 Filed 12/15/17 Page 1 of 3
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NON-PARTY APPLE’S STATUS REPORT RE: DOCUMENT PRODUCTION

CASE NOS. 5:17-CV-00220-LHK-NMC & 5:17-MD-02773-LHK-NMC 

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Pursuant to the Court’s October 18, 2017 Order on Discovery Disputes (ECF No. 239), 

Non-Party Apple Inc. (“Apple”) submits the following status report regarding its document 

production in these cases: 

Collection of Documents and Uploads to Apple’s E-Discovery System: We have 

substantially completed document collection for all of Apple’s custodians. Four sets of 

supplemental electronic document collections are being uploaded to Apple’s e-discovery system, 

but we believe those documents are largely duplicative of documents already collected and 

uploaded. We are also in the process of uploading hardcopy documents collected from one 

custodian. 

Search and De-Duplication: After the application of search terms and de-duplication, 

approximately 6.5 million documents have been slated for review. That number may grow by a 

small amount based on the ongoing uploading, de-duplication, and processing of documents. 

Review and Production: Of the documents slated for review, we have produced 

approximately 2.6 million documents (16.5 million pages) and determined that approximately 

350,000 documents are in document families that are fully non-responsive. We have completed 

initial review of approximately 1.3 million additional documents, which are in various stages of 

the quality control process. We anticipate that several hundred thousand documents will clear 

that process by the middle of next week, at which point the responsive non-privileged documents 

will move into production. 

Review Process: We have over 500 attorneys on document review for this matter, in 

addition to outside counsel and Apple’s in-house litigation support team. In order to facilitate the 

production of remaining responsive non-privileged documents, we have moved documents that 

are highly likely to be privileged or protected from discovery to the back of our manual review 

queue. 

As noted in our earlier status reports, in order to expedite the flow of document production 

and meet the deadlines set by the Court, we are identifying some groups of custodial documents 

that we will produce without manual review, subject to potential claw-back. Because those 

documents will not have been manually reviewed, they will be designated “Apple Highly 

Case 5:17-cv-00220-LHK Document 403 Filed 12/15/17 Page 2 of 3
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NON-PARTY APPLE’S STATUS REPORT RE: DOCUMENT PRODUCTION

CASE NOS. 5:17-CV-00220-LHK-NMC & 5:17-MD-02773-LHK-NMC 

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Confidential-Attorneys’ Eyes Only” and produced based on an agreement between counsel that 

they will only be reviewed by outside counsel pending the entry of a supplemental Protective 

Order applicable to Apple’s production of documents. If counsel for Qualcomm, Class Plaintiffs, 

or the FTC believe any specific documents should be designated at a lower level of 

confidentiality, Apple is willing to meet and confer regarding those documents. 

Dated: December 15, 2017 Respectfully submitted,

By: /s/ Edward H. Takashima

William A. Isaacson 

wisaacson@bsfllp.com

Karen L. Dunn 

kdunn@bsfllp.com

Amy J. Mauser

amauser@bsfllp.com

BOIES SCHILLER FLEXNER LLP

1401 New York Avenue, N.W.

Washington, DC 20005

Telephone: (202) 237-2727

Facsimile: (202) 237-6131

Edward H. Takashima 

etakashima@bsfllp.com 

BOIES SCHILLER FLEXNER LLP

401 Wilshire Blvd, Suite 850 

Santa Monica, CA 90401

Telephone: (310) 752-2400

Facsimile: (310) 752-2490

Attorneys for Non-Party APPLE INC.

Case 5:17-cv-00220-LHK Document 403 Filed 12/15/17 Page 3 of 3