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Re: None

Saturday, 11/24/2012 5:45:28 PM

Saturday, November 24, 2012 5:45:28 PM

Post# of 60937
Discovery Order:

1 - Roaming Agreements.

1a - TM will produce 15 including the largest ones.
1c - TM must produce agreements with Starbucks, FedEx, Barnes & Noble, and the next 12 largest providers.

3-5 - Voice Rate Plan Revenues.

Court agrees TM has produced requested information and remaining data is not maintained by TM.

6-7 Router Agreements and Specifications

6-7b - CLYW wanted documents exchanged between TM and any provider or manufacturer of wireless routers concerning the specifications of the wireless routers provided or to be provided for use by TM subscribers or for any TM "Hot Spot" calling service since 1/20/2004. Denied by Court.

9 - Documents about Patent-In-Suit

9 - CLYW narrows this category as "Any documents not already produced that evidence, reflect or relate to TM's awareness of the '923 patent before the filing date of the lawsuit."

TM indicated it "already produced what we found after a diligent search."

CLYW claims TM has not produced documents such as the attached email from Karl Warfel (3/2004), etc.

Denied by Court as untimely and overbroad.

13-14 - Patent Documents

CLYW wanted documents not yet produced that
a)contain reference or information relating in any way to the '923 patent, CLYW, or to any dealings, agreements, interaction or communication with CLYW and b)or ANY documents relating to patents 7623486,7646745,8116291,8145190,8189548,8189549 (TM patents I assume)

Denied by court as untimely and overbroad

15 - Emails from 26 current and former employees

Denied by Court

16 - Catchall

16b - Court orders TM to provide a formal discovery response stating that all documents in its possession related to this topic have been produced

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