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`Michael G. Rhodes (SBN 116127)
`COOLEY LLP
`101 California Street, 5th Floor
`San Francisco, California 94111-5800
`Telephone: (415) 693-2000
`Facsimile: (415) 693-2222
`
`
`Heidi L. Keefe (SBN 178960)
`Mark R. Weinstein (SBN 193043)
`Lowell D. Mead (SBN 223989)
`COOLEY LLP
`3175 Hanover Street
`Palo Alto, California 94304
`Telephone: (650) 843-5000
`Facsimile: (650) 849-7400
`
`Phillip E. Morton (pro hac vice)
`Emily E. Terrell (SBN 234353)
`Stephen C. Crenshaw (pro hac vice)
`COOLEY LLP
`1299 Pennsylvania Avenue, NW
`Suite 700
`Washington, DC 20004
`Telephone: (202) 842-7800
`Facsimile: (202) 842-7899
`Attorneys for Defendant
`FACEBOOK, INC.
`
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
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`WINDY CITY INNOVATIONS, LLC
`Plaintiff,
`
`
`
`v.
`FACEBOOK, INC.,
`Defendant.
`
`
`
`Case No. 4:16-cv-01730-YGR
`
`FACEBOOK, INC.’S WRITTEN
`STATEMENT IN RESPONSE TO
`JANUARY 23, 2019 ORDER TO
`SHOW CAUSE (DKT. 143)
`
`Date: January 28, 2019
`Time: 2:01 p.m.
`Ctrm: Courtroom 1, Fourth Floor
`
`The Honorable Yvonne Gonzalez Rogers
`
`
`Counsel for Defendant Facebook, Inc. (“Facebook”) respectfully submits the following written
`statement in response to the Court’s January 23, 2019 Order to Show Cause re: Sanctions for Failure
`to Comply with Standing Order (Dkt. 143):
`We apologize that our letter requesting a Pre-filing Conference for Facebook’s Motion for
`Summary Judgment (Dkt. 140) did not meet Your Honor’s expectations. We believed that we were
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`1.
`
`FACEBOOK WRITTEN STATEMENT IN RESPONSE TO
`ORDER TO SHOW CAUSE
`CASE NO. 4:16-CV-01730-YGR
`
`
`
`
`
`Case 4:16-cv-01730-YGR Document 144 Filed 01/25/19 Page 2 of 2
`
`required to comply with both Civil Local Rule 3-4(a) requiring a case caption on the first page of
`papers presented for filing with the Court, and Paragraph 9(a) of Your Honor’s Standing Order
`requiring a single-spaced three page letter. We thought that the format used for our submission was
`the best way to comply with both rules. We did not intend to circumvent any rule or the applicable
`page limits. We apologize for any misunderstanding or inconvenience to the Court.
`We have submitted herewith a new version of the letter, which contains the content of our
`earlier submission, but is on our firm letterhead and uses the standard font and formatting that we use
`when employing this letterhead. (Exhibit A.) All of the original content of the letter remains and has
`not been changed, and all of it fits within three pages. Accordingly, the format employed in our letter
`requesting a Pre-filing Conference for Facebook’s Motion for Summary Judgment (Dkt. 140) did not
`allow us to include any more content than a three page letter on our standard firm letterhead.
`Further, I attest that all attorneys appearing for Facebook in this matter have read Your Honor’s
`Standing Order in Civil Cases, and have, at every turn, attempted to comply with it. We again sincerely
`apologize to the extent we failed to do so in this instance.
`
`
`
`January 25, 2019
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`COOLEY LLP,
`
`/s/ Heidi L. Keefe
`Heidi L. Keefe
`
`
`
`
`
`Attorney for Defendant
`Facebook, Inc.
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`2.
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`FACEBOOK WRITTEN STATEMENT IN RESPONSE TO
`ORDER TO SHOW CAUSE
`CASE NO. 4:16-CV-01730-YGR
`
`
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