Preview
FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION
- -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - x
SAMSUNG ELECTRONICS CO., LTD., :
: Index No.: 656312/2022
Plaintiff, : (Hon. Melissa A. Crane)
:
-against- : STIPULATION GOVERNING
: ELECTRONIC DISCOVERY
MPEG LA, L.L.C., :
:
Defendant. :
- -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - x
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned
counsel for the parties, that discovery of electronically stored information (“ESI”) herein shall be
conducted as follows:
1. Preservation. Preservation of potentially relevant ESI will be reasonable and
proportionate. To reduce the cost and burden of preservation and to ensure proper ESI is p reserved,
the parties shall meet and confer regarding identification of custodians and data sources for which
ESI will be preserved and the date range for preservation of ESI. Specifically excluded from
preservation are currently in-use backup tapes, disks, SANs, and other forms of backup media;
server logs; information stored in volatile memory; voicemails; files on mobile phones or PDA;
and transient metadata.
2. Search Terms / Sources / Criteria.
a. Search Terms. No later than September 6, 2022, the parties shall exchange
proposed lists of initial electronic search terms. Within fourteen (14) days thereafter, the parties
shall meet and confer as necessary to agree upon final lists of initial electronic search terms, taking
into consideration proportionality (e.g., factors including the burden or expense of the proposed
discovery compared to its likely benefit, the amount in controversy, the parties’ resources, the
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importance of the issues at stake in the action, and the importance of the discovery in resolving the
issues) and whether any of the proposed search terms result in an excessive number of false hits.
b. Individual Custodians. No later than September 6, 2022, the parties shall
exchange proposed lists of the other party’s known individual custodians from whom ESI is to be
collected, searched, and produced. Within fourteen (14) days thereafter, the parties shall meet and
confer as necessary to agree upon lists of known individual custodians, taking into consideration
proportionality and an initial presumption that a search of no more than twenty (20) individual
custodians per side is reasonable and sufficient.
c. Server Based Systems / Databases. No later than September 6, 2022, each
party shall furnish a list of its own server based systems (e.g., e-mail servers, shared file servers,
databases) that are likely to contain responsive documents including the name of the system, a
brief description of the system, a brief description of the likely responsive data stored in the system,
and the name of the system custodian. Within fourteen (14) days thereafter, the parties shall meet
and confer as necessary to agree upon (i) final lists of such server based systems consisting of non-
structured data/non-databases from which ESI is to be collected, searched, and produced using the
search terms, criteria, and production format herein, and (ii) final lists of such server based systems
consisting of structured data/databases from which information is to be selected, gathered, and
produced in a manner other than as set forth herein and the manner of doing so. The parties shall
take into consideration proportionality and whether or not data is reasonably accessible.
d. Search Criteria / Date Range. The collection, search, and production of ESI
hereunder shall only apply to ESI created, modified, or received from January 1, 2014 through the
present. Attorney-client communications and protected work product that post-date the filing of
the Complaint herein on May 16, 2022, need not be produced or placed on a privilege log. The
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search terms herein are not required to be run on structured data / databases, which shall be the
subject of separate collection criteria to be agreed upon; on unallocated space; or on archived data
sources (including archived backup media) or disaster recovery media that are not reasonably
accessible.
e. Revisions / Updates. The parties may revisit the agreed-upon lists of search
terms, custodians, media to be searched or not to be searched, and server based systems and the
manner of selecting and gathering structured data / database information to the extent the agreed
upon lists or manner of selecting and gathering information subsequently prove impractical or
unduly burdensome or costly and to the extent that a search of additional terms, custodians, or
sources is necessary or appropriate. The parties shall meet and confer as necessary with respect to
such matters.
3. Review for Responsiveness / Relevance / Privilege / Confidentiality. The parties
retain the right to review ESI search results for relevance, responsiveness to document demands,
confidentiality, and privilege, and to limit production accordingly.
4. Production Format.
a. TIFF Format. ESI documents consisting of emails, Microsoft Word
documents, Powerpoint files, .pdf files, and similar documents shall be produced as single-page
Tagged Image File Format (“TIFF”) images with corresponding multi-page text. The load files
shall include an image load file (.opt) as well as a metadata (.dat) file with the following metadata
fields on the document level to the extent available : BEGBATES, ENDBATES, FILENAME,
FROM, TO, CC, BCC, SUBJECT, PARENTBATES, ATTACHBATES, BEGATTACH,
ENDATTACH, ATTACHCOUNT, ATTACHNAME, SENTDATE, SENTTIME, RCVDDATE,
RCVDTIME, CREATEDATE, CREATETIME, MODDATE, MODTIME, DOCDATE,
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DOCTIME, MD5HASH, TITLE, AUTHOR, CUSTODIAN, MODIFIED BY, FILE_EXT,
DOCTYPE, BODY, TEXTPATH, NATIVELINK. This list of fields does not create any
obligation to create or manually code fields that are not automatically generated by the processing
of ESI, that do not exist as part of the original metadata of the documents, or that would be unduly
burdensome or costly to obtain.
b. Native Format.
i. Audio and video files, including voicemail messages and recordings of Zoom,
Microsoft Teams, or similar meetings, shall be produced in native form only.
ii. Spreadsheets shall be produced in native format with a Bates-numbered slipsheet
indicating that it has been produced natively. Where the producing party believes that the
spreadsheet must be redacted, the parties shall meet and confer over the form of production.
iii. Other types of electronic documents shall be produced in the form in which they
are ordinarily maintained. To the extent such production is impossible or impractical, the parties
shall meet and confer over the form of production, but the production must in any event be in a
searchable format that is usable by the party receiving the discovery of the electronic production.
iv. A party that receives a document produced in non -native format may make a
reasonable request to receive the document in native format, and the parties shall meet and confer
regarding any post-production request that ESI previously produced in TIFF format be produced
in native format.
v. The producing party will not reformat, scrub, flatten, or otherwise alter the
ESI in a way that downgrades the usability of the data, including by generating .pdf files of
Microsoft Word documents, emails, or other documents which should be produced according to
Paragraph 4.a.
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c. Document Numbering. Each page of a document produced in TIFF format
shall have a legible, unique sequentially ascending production number (“Bates Number”) at a
location that does not obliterate, conceal, or interfere with any information from the source
document. The Bates Number for each page of each document will be created so as to identify the
producing party and the document number. Documents produced in native format shall be
accompanied by a Bates-numbered slipsheet.
d. Redaction / Confidentiality. Each page of a document produced in TIFF
format that contains information that is confidential as contemplated in any protective order or
confidentiality stipulation shall contain the appropriate designation. Each page of a document or
portion thereof produced in TIFF format that contains information that is privileged sh all contain
the appropriate designation on the redaction.
e. Structured Data / Database Information. The above production formats
shall not apply to the format of production for structured data / database information, which shall
be the subject of a meet and confer as set forth in paragraph 2, above.
f. Production Media. Each piece of production media (e.g., CD, DVD, flash
drive, external hard drive) shall be labeled with the: (i) name of the case, (ii) identification of the
producing party, date of production, and sequence of the material, and (iii) Bates range of the
production (e.g., Samsung v. MPEG LA, Index No. 656312/2022; Plaintiff Production
MM/DD/YYYY (Disk 1); Bates Nos. _______ to ______). Any replacement production media
shall cross-reference the original production media and Bates range being replaced, and identify
that it is a replacement media.
g. Electronic Production. Notice of any production being made via an
electronic transfer accessible by computer (e.g., producing documents through the use of a file
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server) shall be emailed to all counsel of record and that email shall contain the following
information: (i) name of the case, (ii) identification of the producing party, and (iii) Bates range of
the production.
h. Rolling Production. ESI shall be produced on a rolling basis, with both
parties making an initial production by September 30, 2022.
5. Burden and Initial Allocation of Cost. The Parties agree to tailor requests for ESI
to what is reasonable and proportionate, considering the burdens of the requested discovery, the
nature of the dispute, the amount in controversy, and the importance of the materials requested to
resolving the issues in question. The producing party shall bear the initial cost of collecting,
searching, and producing ESI pursuant hereto, subject to the right to seek relief from the Court
(e.g., a cost shifting award and pursuant to principles of proportionality).
6. Inadvertent Disclosure / Clawback. The inadvertent disclosure or production of
any information or document that is subject to an objection on the basis of attorney-client privilege,
work-product protection, or any other applicable privilege will not be deemed to waive a party’s
claim to its privileged or protected nature or estop that party or the privilege holder from
designating the information or document as attorney-client privileged, subject to the work product
doctrine, or subject to any other applicable privilege at a later date. Any party receiving any such
information or document shall return it upon request from the producing party , and may not
disclose or use the information or document in any manner or for any purpose (unless and until
any dispute concerning the privilege or protection claim is resolved). Within five (5) business
days of receiving such a request as to specific information or documents, and regardless of whether
the receiving party agrees with the claim of privilege and/or work -product protection, the receiving
party shall (a) return the information or documents to the producing party and destroy any and all
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copies, summaries, abstracts, or excerpts thereof, and (b) provide the producing party with the
name of every person who reviewed the information or document and take reasonable steps to
retrieve such information or document from any third party to whom it has disclosed the
information or document.
7. Protective Order. This Stipulation incorporates the Stipulation and Order for the
Production and Exchange of Confidential Information (the “Protective Order”) entered into by the
parties on September 6, 2022. In the case of a conflict between this Stipulation and the Protective
Order, the Protective Order shall govern.
8. Disputes. The Parties shall attempt in good faith to resolve disputes about ESI
through the informal meet and confer process before contacting the Court concerning same.
This Stipulation may be executed in counterpart and a facsimile signature shall be deemed
to have the same binding effect on the parties hereto as an original.
Dated: September 6, 2022
QUINN EMANUEL URQUHART & WINDELS MARX LANE &
SULLIVAN, LLP MITTENDORF, LLP
______________________________
/s/ Michael B. Carlinsky __________________________
Michael B. Carlinsky Craig P. Murphy
William B. Adams John D. Holden
Owen F. Roberts Delton L. Vandever
51 Madison Avenue, 22nd Floor Philip M. Taylor
New York, New York 10010 Ben Kusmin
(212) 849-7000 156 West 56 th Street
michaelcarlinsky@quinnemanuel.com New York, New York 10019
williamadams@quinnemanuel.com Telephone: (212) 237-1000
owenroberts@quinnemanuel.com Facsimile: (212) 262-1215
cmurphy@windelsmarx.com
Kevin Hardy (admitted pro hac vice) jholden@windelsmarx.com
1300 I Street, N.W., Suite 900 dvandever@windelsmarx.com
Washington, DC 20005 ptaylor@windelsmarx.com
(202) 538-8000 bkusmin@windelsmarx.com
kevinhardy@quinnemanuel.com Attorneys for Defendant
Attorneys for Plaintiff Samsung
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Electronics Co., Ltd. MPEG LA, L.L.C.
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Preview
FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: COMMERCIAL DIVISION - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - x SAMSUNG ELECTRONICS CO., LTD., : : Index No.: 656312/2022 Plaintiff, : (Hon. Melissa A. Crane) : -against- : STIPULATION GOVERNING : ELECTRONIC DISCOVERY MPEG LA, L.L.C., : : Defendant. : - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - - -- - x IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the parties, that discovery of electronically stored information (“ESI”) herein shall be conducted as follows: 1. Preservation. Preservation of potentially relevant ESI will be reasonable and proportionate. To reduce the cost and burden of preservation and to ensure proper ESI is p reserved, the parties shall meet and confer regarding identification of custodians and data sources for which ESI will be preserved and the date range for preservation of ESI. Specifically excluded from preservation are currently in-use backup tapes, disks, SANs, and other forms of backup media; server logs; information stored in volatile memory; voicemails; files on mobile phones or PDA; and transient metadata. 2. Search Terms / Sources / Criteria. a. Search Terms. No later than September 6, 2022, the parties shall exchange proposed lists of initial electronic search terms. Within fourteen (14) days thereafter, the parties shall meet and confer as necessary to agree upon final lists of initial electronic search terms, taking into consideration proportionality (e.g., factors including the burden or expense of the proposed discovery compared to its likely benefit, the amount in controversy, the parties’ resources, the 1 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 importance of the issues at stake in the action, and the importance of the discovery in resolving the issues) and whether any of the proposed search terms result in an excessive number of false hits. b. Individual Custodians. No later than September 6, 2022, the parties shall exchange proposed lists of the other party’s known individual custodians from whom ESI is to be collected, searched, and produced. Within fourteen (14) days thereafter, the parties shall meet and confer as necessary to agree upon lists of known individual custodians, taking into consideration proportionality and an initial presumption that a search of no more than twenty (20) individual custodians per side is reasonable and sufficient. c. Server Based Systems / Databases. No later than September 6, 2022, each party shall furnish a list of its own server based systems (e.g., e-mail servers, shared file servers, databases) that are likely to contain responsive documents including the name of the system, a brief description of the system, a brief description of the likely responsive data stored in the system, and the name of the system custodian. Within fourteen (14) days thereafter, the parties shall meet and confer as necessary to agree upon (i) final lists of such server based systems consisting of non- structured data/non-databases from which ESI is to be collected, searched, and produced using the search terms, criteria, and production format herein, and (ii) final lists of such server based systems consisting of structured data/databases from which information is to be selected, gathered, and produced in a manner other than as set forth herein and the manner of doing so. The parties shall take into consideration proportionality and whether or not data is reasonably accessible. d. Search Criteria / Date Range. The collection, search, and production of ESI hereunder shall only apply to ESI created, modified, or received from January 1, 2014 through the present. Attorney-client communications and protected work product that post-date the filing of the Complaint herein on May 16, 2022, need not be produced or placed on a privilege log. The 2 2 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 search terms herein are not required to be run on structured data / databases, which shall be the subject of separate collection criteria to be agreed upon; on unallocated space; or on archived data sources (including archived backup media) or disaster recovery media that are not reasonably accessible. e. Revisions / Updates. The parties may revisit the agreed-upon lists of search terms, custodians, media to be searched or not to be searched, and server based systems and the manner of selecting and gathering structured data / database information to the extent the agreed upon lists or manner of selecting and gathering information subsequently prove impractical or unduly burdensome or costly and to the extent that a search of additional terms, custodians, or sources is necessary or appropriate. The parties shall meet and confer as necessary with respect to such matters. 3. Review for Responsiveness / Relevance / Privilege / Confidentiality. The parties retain the right to review ESI search results for relevance, responsiveness to document demands, confidentiality, and privilege, and to limit production accordingly. 4. Production Format. a. TIFF Format. ESI documents consisting of emails, Microsoft Word documents, Powerpoint files, .pdf files, and similar documents shall be produced as single-page Tagged Image File Format (“TIFF”) images with corresponding multi-page text. The load files shall include an image load file (.opt) as well as a metadata (.dat) file with the following metadata fields on the document level to the extent available : BEGBATES, ENDBATES, FILENAME, FROM, TO, CC, BCC, SUBJECT, PARENTBATES, ATTACHBATES, BEGATTACH, ENDATTACH, ATTACHCOUNT, ATTACHNAME, SENTDATE, SENTTIME, RCVDDATE, RCVDTIME, CREATEDATE, CREATETIME, MODDATE, MODTIME, DOCDATE, 3 3 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 DOCTIME, MD5HASH, TITLE, AUTHOR, CUSTODIAN, MODIFIED BY, FILE_EXT, DOCTYPE, BODY, TEXTPATH, NATIVELINK. This list of fields does not create any obligation to create or manually code fields that are not automatically generated by the processing of ESI, that do not exist as part of the original metadata of the documents, or that would be unduly burdensome or costly to obtain. b. Native Format. i. Audio and video files, including voicemail messages and recordings of Zoom, Microsoft Teams, or similar meetings, shall be produced in native form only. ii. Spreadsheets shall be produced in native format with a Bates-numbered slipsheet indicating that it has been produced natively. Where the producing party believes that the spreadsheet must be redacted, the parties shall meet and confer over the form of production. iii. Other types of electronic documents shall be produced in the form in which they are ordinarily maintained. To the extent such production is impossible or impractical, the parties shall meet and confer over the form of production, but the production must in any event be in a searchable format that is usable by the party receiving the discovery of the electronic production. iv. A party that receives a document produced in non -native format may make a reasonable request to receive the document in native format, and the parties shall meet and confer regarding any post-production request that ESI previously produced in TIFF format be produced in native format. v. The producing party will not reformat, scrub, flatten, or otherwise alter the ESI in a way that downgrades the usability of the data, including by generating .pdf files of Microsoft Word documents, emails, or other documents which should be produced according to Paragraph 4.a. 4 4 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 c. Document Numbering. Each page of a document produced in TIFF format shall have a legible, unique sequentially ascending production number (“Bates Number”) at a location that does not obliterate, conceal, or interfere with any information from the source document. The Bates Number for each page of each document will be created so as to identify the producing party and the document number. Documents produced in native format shall be accompanied by a Bates-numbered slipsheet. d. Redaction / Confidentiality. Each page of a document produced in TIFF format that contains information that is confidential as contemplated in any protective order or confidentiality stipulation shall contain the appropriate designation. Each page of a document or portion thereof produced in TIFF format that contains information that is privileged sh all contain the appropriate designation on the redaction. e. Structured Data / Database Information. The above production formats shall not apply to the format of production for structured data / database information, which shall be the subject of a meet and confer as set forth in paragraph 2, above. f. Production Media. Each piece of production media (e.g., CD, DVD, flash drive, external hard drive) shall be labeled with the: (i) name of the case, (ii) identification of the producing party, date of production, and sequence of the material, and (iii) Bates range of the production (e.g., Samsung v. MPEG LA, Index No. 656312/2022; Plaintiff Production MM/DD/YYYY (Disk 1); Bates Nos. _______ to ______). Any replacement production media shall cross-reference the original production media and Bates range being replaced, and identify that it is a replacement media. g. Electronic Production. Notice of any production being made via an electronic transfer accessible by computer (e.g., producing documents through the use of a file 5 5 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 server) shall be emailed to all counsel of record and that email shall contain the following information: (i) name of the case, (ii) identification of the producing party, and (iii) Bates range of the production. h. Rolling Production. ESI shall be produced on a rolling basis, with both parties making an initial production by September 30, 2022. 5. Burden and Initial Allocation of Cost. The Parties agree to tailor requests for ESI to what is reasonable and proportionate, considering the burdens of the requested discovery, the nature of the dispute, the amount in controversy, and the importance of the materials requested to resolving the issues in question. The producing party shall bear the initial cost of collecting, searching, and producing ESI pursuant hereto, subject to the right to seek relief from the Court (e.g., a cost shifting award and pursuant to principles of proportionality). 6. Inadvertent Disclosure / Clawback. The inadvertent disclosure or production of any information or document that is subject to an objection on the basis of attorney-client privilege, work-product protection, or any other applicable privilege will not be deemed to waive a party’s claim to its privileged or protected nature or estop that party or the privilege holder from designating the information or document as attorney-client privileged, subject to the work product doctrine, or subject to any other applicable privilege at a later date. Any party receiving any such information or document shall return it upon request from the producing party , and may not disclose or use the information or document in any manner or for any purpose (unless and until any dispute concerning the privilege or protection claim is resolved). Within five (5) business days of receiving such a request as to specific information or documents, and regardless of whether the receiving party agrees with the claim of privilege and/or work -product protection, the receiving party shall (a) return the information or documents to the producing party and destroy any and all 6 6 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 copies, summaries, abstracts, or excerpts thereof, and (b) provide the producing party with the name of every person who reviewed the information or document and take reasonable steps to retrieve such information or document from any third party to whom it has disclosed the information or document. 7. Protective Order. This Stipulation incorporates the Stipulation and Order for the Production and Exchange of Confidential Information (the “Protective Order”) entered into by the parties on September 6, 2022. In the case of a conflict between this Stipulation and the Protective Order, the Protective Order shall govern. 8. Disputes. The Parties shall attempt in good faith to resolve disputes about ESI through the informal meet and confer process before contacting the Court concerning same. This Stipulation may be executed in counterpart and a facsimile signature shall be deemed to have the same binding effect on the parties hereto as an original. Dated: September 6, 2022 QUINN EMANUEL URQUHART & WINDELS MARX LANE & SULLIVAN, LLP MITTENDORF, LLP ______________________________ /s/ Michael B. Carlinsky __________________________ Michael B. Carlinsky Craig P. Murphy William B. Adams John D. Holden Owen F. Roberts Delton L. Vandever 51 Madison Avenue, 22nd Floor Philip M. Taylor New York, New York 10010 Ben Kusmin (212) 849-7000 156 West 56 th Street michaelcarlinsky@quinnemanuel.com New York, New York 10019 williamadams@quinnemanuel.com Telephone: (212) 237-1000 owenroberts@quinnemanuel.com Facsimile: (212) 262-1215 cmurphy@windelsmarx.com Kevin Hardy (admitted pro hac vice) jholden@windelsmarx.com 1300 I Street, N.W., Suite 900 dvandever@windelsmarx.com Washington, DC 20005 ptaylor@windelsmarx.com (202) 538-8000 bkusmin@windelsmarx.com kevinhardy@quinnemanuel.com Attorneys for Defendant Attorneys for Plaintiff Samsung 7 7 of 8 FILED: NEW YORK COUNTY CLERK 09/13/2022 05:49 PM INDEX NO. 656312/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 09/13/2022 Electronics Co., Ltd. MPEG LA, L.L.C. 8 8 of 8