Exhibit B 

Case 2:23-cv-00285-JRG-RSP Document 52-2 Filed 04/30/24 Page 1 of 2 PageID #: 872
Subject:Subject: RE: Cobblestone v. Samsung

Date:Date: Tuesday, March 26, 2024 at 1:56:36PM Central Daylight Time

From:From: Olga Slobodyanyuk

To:To: ptong@raklaw.com, Brice Lynch, rak_cobblestone@raklaw.com

CC:CC: QE-Cobblestone-Samsung, Melissa Smith, Fair, Andrea

Counsel,

Thank you for a produc4ve meet-and-confer last week. Pursuant to that discussion, we have

served Samsung’s supplemental interrogatory responses, iden4fying accused user

equipment and base sta4ons. We also produced addi4onal technical documenta4ons about 

. Based on our current understanding of the MOTIE process, our hope and expecta4on is that

we will be making at least some of the source code available within a month.

We do not believe that the case law you provided bears on this discussion, since Samsung is fully

intending to comply with its discovery obliga4ons. In Societe Interna4onale Pour Par4cipa4ons

Industrielles Et Commerciales, S. A. v. Rogers, 357 U.S. 197, 206 (1958) the Court explicitly “h[e]ld only

that accommoda4on of the Rule in this instance to the policies underlying the Trading with the Enemy

Act jus4fied the ac4on of the District Court in issuing this produc4on order” and that it “do[es] not say

that this ruling would apply to every situa4on where a party is restricted by law from producing

documents over which it is otherwise shown to have control. Rule 34 is sufficiently flexible to be adapted

to the exigencies of par4cular li4ga4on.” 357 U.S. 197, 206 (1958). Linde v. Arab Bank, PLC concerned

“con4nuing refusals to produce” informa4on based on foreign bank secrecy laws and related comity

concerns. 269 F.R.D. 186, 192 (E.D.N.Y. 2010). For clarity, Samsung is willing and will make all the

relevant source code available as soon as MOTIE review is completed. We will let you know as soon as

we can once the relevant source code is approved for produc4on by MOTIE. We further note that fact

discovery in this case does not close un4l November 22, 2024. All of the source code will be provided to

Cobblestone several months in advance of that deadline and with plenty of 4me for Cobblestone to

review; and that there is no basis for any mo4on in these circumstances. 

We understand that Cobblestone intends to supplement its interrogatories in the next few weeks,

including but not limited to by providing substan4ve responses to interrogatories nos. 1, 4, 10, 15, 18,

and will be making addi4onal document produc4ons with at least in respect to informa4on called by

interrogatories nos. 7, 10, 12, 18, to the extent that any informa4on is found.

Addi4onally, the par4es discussed poten4al supplementa4on of conten4on interrogatories, such as

Cobblestone’s interrogatories nos. 7, 12, 20, 21, 23, 24 and Samsung’s interrogatories nos. 1, 5, 7. We

tenta4vely discussed agreeing on a date in May. Samsung will revert shortly with a concrete proposal

regarding conten4on interrogatory supplementa4on.

With respect to Cobblestone’s issues with Samsung’s interrogatory responses, we discussed the

following:

· Samsung promptly supplemen4ng with 33(d) cita4ons to interrogatory nos. 4, 13, 15, 16, 17,

18;

· Samsung promptly supplemen4ng with persons most knowledgeable in response to

interrogatory nos. 4, 5, & 6.

Case 2:23-cv-00285-JRG-RSP Document 52-2 Filed 04/30/24 Page 2 of 2 PageID #: 873