`
`December 5, 2024
`
`
`
`
`
`
`
`
`VIA ECF
`
`Hon. Leda Dunn Wettre, U.S.M.J.
`United States District Court
`District of New Jersey
`Martin Luther King Building &
`U.S. Courthouse
`50 Walnut Street, Room 4015
`Newark, NJ 07101
`
`Re:
`
`
`Dear Magistrate Judge Wettre:
`
`Jawbone Innovations, LLC v. Sony Electronics Inc.
`Civil Action No. 2:23-cv-01161-MEF-LDW
`
` I
`
` represent Jawbone Innovations, LLC (“Jawbone”) in Jawbone Innovations, LLC v. Sony
`Electronics, Inc., Civil Action No. 2:23-cv-01161-MEF-LDW. I write to request that the Court
`enter a Supplemental Protective Order (attached hereto as Exhibit A) applicable to documents and
`source code to be produced by non-party Qualcomm Incorporated (“Qualcomm”).
`
`Qualcomm provides software and hardware related to the accused functionality in this case.
`Jawbone served a Subpoena on Qualcomm seeking relevant documents and source code.
`Qualcomm has requested that the attached Supplemental Protective Order be entered prior to its
`production of the documents and source code.
`
`Accordingly, Jawbone respectfully requests that the Court enter the Supplemental Protective Order
`attached hereto as Exhibit A. Counsel for Jawbone has conferred with counsel for Sony, who has
`confirmed that Sony does not oppose this request.
`
`Respectfully submitted,
`
`
`
`Peter Lambrianakos
`
`Attachment – Exhibit A
`
`cc: All Counsel of Record (via ECF and Email)
`
`
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