256 14
256 14
EXHIBIT N
From: ShenNan10111233
Sent: Tuesday, November 26, 2013 09:33:49
To: huyM 63118
Cc: ShenJianFeng148755
Subject: Reply: vringo Counter measures
I discussed with Attorney Cui regarding the counter measures against Vringo in China, and there are two issues that
we need to pay attention to:
1.
Timing of the filing of the case: As this month we have entered case clearing stage at the end of the year, there is no new
case filed till the end of December. Whether this is consistent with our strategy, we need to discuss it. In addition,
Attorney Cui also mentioned that we can have Wang Dong to coordinate to file the case in advance.
2.
Basic evidence for filing of the case: As this case is an anti -trust case, the regulations include abuse of market position,
bundled sales, and behaviors as such. Thus, we need evidence to show that there is suspicion for Vringo's bundled sales,
including the judgment from the UK and email communications. There is an issue, in our communications, it stated
"subject to FRCP
408" or other similar confidential marks. Are these evidence usable? Does it break our promise? Is it break of
contract? Attorney Cui says it is not clear either. Thus, you need to confirm that with the attorney overseas.
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To
Shen Jianfeng 148755 /user /zte_ltd
Cc
Shen Nan 10111233 /user /zte_ltd
Subject
vringo Counter measures
EXHIBIT ND.
DATE: 7 S ZTE005319
Reporter - Laurie A. Collins
Case 1:14-cv-04988-LAK-FM Document 256-14 Filed 09/08/15 Page 3 of 7
[Attachment "Vringo counter measure plan.xlsx" was deleted by Shen Nan 10111233/user /zte_ltd ]
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Case 1:14-cv-04988-LAK-FM Document 256-14 Filed 09/08/15 Page 4 of 7
From: ShenNan10111233
Sent: Tuesday, November 26, 2013 09:33:49
To: h uyi 163118
Cc: ShenJianFeng148755
Subject: V: vringoa$11 AMA
N 163118/user/zte_Itd
2013/11/25 19:20
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Case 1:14-cv-04988-LAK-FM Document 256-14 Filed 09/08/15 Page 5 of 7
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Case 1:14-cv-04988-LAK-FM Document 256-14 Filed 09/08/15 Page 6 of 7
TRANSPERFECT
I, Alitasha Younger, hereby affirm that the following is to the best of my knowledge an belief, a
true and accurate translation from Chinese to English of the document with the following Bates
numbers:
ZTE005319-ZTE005320
Alitasha Younger
Signature
EN1DA KUWANCIC
Notary Public State of New York
No. 01KU8322856
Qualified in KING County
Commission
. ---.L. s
ires AO 13, 2019
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Case 1:14-cv-04988-LAK-FM Document 256-14 Filed 09/08/15 Page 7 of 7