FTC’S MOTION FOR LEAVE TO FILE RESPONSE TO 

BRIEF OF AMICUS CURIAE NOKIA TECHNOLOGIES 

Case No. 17-cv-00220-LHK-NMC

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Jennifer Milici, D.C. Bar No. 987096

Joseph R. Baker, D.C. Bar No. 490802

Geoffrey M. Green, D.C. Bar No. 428392

Rajesh James, N.Y. Bar No. 4209367

Daniel Matheson, D.C. Bar No. 502490

Kenneth H. Merber, D.C. Bar No. 985703

Mark J. Woodward, D.C. Bar No. 479537

Federal Trade Commission

600 Pennsylvania Avenue, N.W.

Washington, D.C. 20580

(202) 326-3695; (202) 326-3496 (fax)

jmilici@ftc.gov

Attorneys for Plaintiff Federal Trade Commission

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

FEDERAL TRADE COMMISSION’S 

MOTION FOR LEAVE TO FILE 

RESPONSE TO BRIEF OF AMICUS 

CURIAE NOKIA TECHNOLOGIES 

REGARDING FTC’S MOTION FOR 

PARTIAL SUMMARY JUDGMENT

Date: October 18, 2018

Time: 1:30 p.m.

Courtroom: 8, 4th Floor

Judge: Hon. Lucy H. Koh

Case 5:17-cv-00220-LHK Document 897 Filed 10/11/18 Page 1 of 2
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FTC’S MOTION FOR LEAVE TO FILE RESPONSE TO

BRIEF OF AMICUS CURIAE NOKIA TECHNOLOGIES 

Case No. 17-cv-00220-LHK-NMC

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NOTICE OF MOTION AND MOTION

To the Honorable Court, all parties, and their attorneys of record: 

Please take notice that on October 18, 2018, at 1:30 p.m., in Courtroom 8, United States 

Courthouse, 280 South 1st Street, San Jose, California 95113, Plaintiff Federal Trade 

Commission will and hereby does move the Court for leave to file a response to the amicus 

curiae brief of Nokia Technologies Oy (“Nokia”) in support of Qualcomm Incorporated’s 

Opposition to the FTC’s Motion for Partial Summary Judgment (motion for leave filed Oct. 3, 

2018) (ECF No. 888) (motion for leave granted Oct. 4, 2018) (ECF No. 890). 

At approximately 10 p.m. on October 3, 2018, Nokia filed a proposed amicus brief in 

support of Qualcomm’s opposition to the FTC’s motion for partial summary judgment. (ECF No. 

888.) Nokia’s 11-page amicus brief contains arguments that supplement the arguments in 

Qualcomm’s opposition to the FTC’s motion (corrected version filed Sept. 25, 2018) (ECF No. 

879). The FTC did not, however, have a reasonable opportunity to respond to Nokia’s arguments 

before filing its reply brief on October 4, 2018. (ECF No. 893.) The FTC has thus filed this 

motion for leave to file a short response to Nokia’s amicus brief. The FTC’s proposed brief is 

two pages long and limited to responding to arguments contained in Nokia’s amicus brief. The 

FTC respectfully requests that the Court grant this motion for leave to file the attached 

responsive brief.

Qualcomm has indicated that it cannot take a position on the motion before reviewing the

contents of the responsive brief.

Respectfully submitted,

Dated: October 11, 2018

 /s/ Jennifer Milici

JENNIFER MILICI

RAJESH JAMES

DANIEL MATHESON

KENNETH H. MERBER

Attorneys for Plaintiff Federal Trade 

Commission

Case 5:17-cv-00220-LHK Document 897 Filed 10/11/18 Page 2 of 2