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DDB Technologies v. AOL

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					                            UNITED STATES DISTRICT COURT
                            NORTHERN DISTRICT OF ILLINOIS
                                  EASTERN DIVISION

                                            )
                                            )
IN RE SUBPOENA TO STATS, L.L.C.             )    Misc. Civil Action No. 11-CV-3272
                                            )
                                            )
                                            )
                                            )
DDB Technologies, L.L.C.,                   )    Underlying Civil Action
                                            )
                    Plaintiff,              )    Civil Action No. 10-CV-00246 (JRN)
                                            )
                                            )    Pending in the United States
                                            )    District Court for the Western
                                            )    District of Texas, Austin Division
       v.                                   )
                                            )
                                            )    Judge James R. Nowlin
AOL, Inc.,                                  )
                                            )
                    Defendant.              )
                                            )


     DDB TECHNOLOGIES, L.L.C.'S MOTION TO COMPEL PRODUCTION
OF DOCUMENTS AND DEPOSITION TESTIMONY FROM NON-PARTY STATS L.L.C.
I.         INTRODUCTION

           Pursuant to Federal Rule of Civil Procedure 45, Plaintiff DDB Technologies, L.L.C.

("DDB") hereby respectfully moves this Court for an order compelling Nonparty STATS L.L.C.

("STATS") to produce subpoenaed documents and to provide testimony concerning subpoenaed

deposition topics. This motion is necessary because STATS is improperly refusing to produce

highly-relevant information that is in STAT's sole possession, including information about the

collection, storage, and processing of the live sporting event data that powers Defendant AOL, Inc.'s

("AOL's") accused product. As such, DDB respectfully requests that the Court order STATS to

produce the subpoenaed information immediately, so that DDB can use that information to prepare

its expert reports due May 23, 2011, conduct any necessary follow up before discovery closes on June

3, 2011, and prepare for trial in early July 2011.



II.        BACKGROUND

           In the first half of 2010, DDB filed Complaints for Patent Infringement and Damages against

several Defendants, including AOL, in the District Court for the Western District of Texas. (See e.g.,

Ex. A). As set forth in those Complaints, DDB believes that the Defendants have infringed and

continue to infringe U.S. Patent Nos. 5,526,479, 5,671,347, 6,204,862, and 7,373,587 (collectively,

"the DDB Patents") by making, selling, offering for sale, and using products and/or services covered

by the claims of those patents. (Id.).

           The DDB Patents relate generally to a method and system for generating a computer

simulation of a live sporting event for display on a viewer's computer. 1 One embodiment of the

invention is illustrated in Figure 1 of the DDB Patents:



1
    The DDB Patents all claim priority to a common parent application and share an identical specification.
                                                            2
        Within this configuration, an observer of a live sporting event (e.g., a baseball game) may

collect data about that event by entering symbols (or codes) representative of the plays of the event

into a computer. These symbols may then be used in a computer simulation of the live sporting

event. For instance, the observer's computer may use the symbols to generate and transmit data

about the live sporting event to a centralized database computer, which receives such data and then

updates a database based on the received data. The database computer can then broadcast

information about the live sporting event to a viewer's computer. In the example of baseball, this

information may include: score, inning, outs, count, batter, player on base, etc., as well as details

of the plays. In turn, the viewer computer may use this broadcast information to display a

simulation of the live sporting event to a viewer.

        In December 2010, DDB served interrogatories on the Defendants to obtain further

information concerning the products and/or services covered by the claims of the DDB patents. (See,

e.g., Ex. B). In response to those interrogatories, several Defendants identified STATS as an entity

that was providing products and services relevant to DDB's infringement claims. (See, e.g., Ex. C,

AOL's Responses to DDB's Interrogatories Nos. 3-6). In particular, several Defendants pointed to

STATS in response to inquiries concerning the collection of data about a live sporting event as well

as the processing and distribution of that data for use in a computer simulation of the live sporting

event. (Id.).

                                                     3
        In view of the Defendants' interrogatory responses, DDB served two subpoenas on STATS on

February 14, 2011. (See Exs. D and E). The first of these subpoenas commanded STATS to produce

documents by February 28, 2011 from several categories that are highly relevant to the operation of

AOL's accused product (and thus DDB's infringement claims), including documents concerning

STATS's collection, storage, and processing of the live sporting event data that it provided to the

Defendants. (See Ex. D, Request Nos. 1-7, 13). The second of these subpoenas then commanded

STATS to produce a witness on March 31, 2011 to testify about several topics that are highly relevant

to the operation of AOL's accused product (and thus DDB's infringement claims), including STATS's

collection, storage, and processing of the live sporting event data that it provided to the Defendants.

(See Ex. E, Topic Nos. 1-5, 12).

        On February 28, 2011, STATS served its responses to DDB's document subpoena. (See Ex.

F). In those responses, STATS first set forth several General Objections to DDB's document

subpoena, including objections based on the alleged confidential and proprietary nature of the

requested documents, the alleged breadth and burden of DDB's requests, and an allegation that DDB

was "fishing for information to use in a future lawsuit" against STATS. (Id.). STATS's responses

then stated that it "incorporate[d] by reference the foregoing General Objections to each of DDB's

Document Categories," without specifying which objections applied to which document request or

otherwise responding to those document requests. (Id.).

        After receiving STATS's objections, DDB's counsel contacted STATS's counsel in March to

discuss a reasonable compromise concerning the scope of DDB's document subpoena. (Baldwin

Decl. ¶3). During that discussion, DDB's counsel informed STATS's counsel that certain Defendants

in the litigation had recently settled, and that DDB thus agreed to narrow the scope of the document

subpoena to encompass only those documents concerning the relevant products and services that

STATS provided to the remaining Defendants. (Baldwin Decl. ¶3). DDB's counsel also agreed to

                                                    4
identify documents encompassed by the document subpoena that had already been produced by the

remaining Defendants in the litigation, to further reduce the burden on STATS. (Baldwin Decl. ¶3).

In return, STATS's counsel agreed that STATS would begin the process of identifying responsive

documents for production. (Baldwin Decl. ¶3).

         Subsequent to DDB's initial discussion with STATS, two things occurred that had a bearing

on the discovery DDB was requesting from STATS. First, DDB was able reach settlement terms

with yet another Defendant, leaving AOL as the only remaining Defendant to which STATS appears

to provide relevant products and services. (Baldwin Decl. ¶4). Second, DDB's counsel had engaged

in several meet and confers with AOL's counsel about AOL's document production, during which

time AOL's counsel repeatedly represented that STATS was in sole possession of discoverable

information concerning the collection, storage, and processing of the live sporting event data that

powered AOL's accused products. (Baldwin Decl. ¶4).

         In view of these occurrences, DDB's counsel followed up with STATS via email in mid-

April. (See Ex. G). At that time, DDB's counsel agreed to narrow the scope of the document

subpoena even further, to encompass only those documents concerning the relevant products and

services that STATS provided to AOL. (Id.). Additionally, DDB's counsel notified STATS's counsel

that because STATS was the only entity in possession of discoverable information concerning the

collection, storage, and processing of the live sporting event data that powered AOL's accused

products, DDB would need to move forward with its request to obtain this information from STATS.

(Id.).

         On April 22, 2011, DDB's counsel and STATS's counsel engaged in another discussion

concerning DDB's subpoenas. (Baldwin Decl. ¶5). During that discussion, DDB's counsel reiterated

its agreement to narrow the scope of the document subpoena to encompass only those documents

concerning the relevant products and services that STATS provided to AOL as reflected in email

                                                   5
correspondence between DDB and STATS on April 24, 2011 and April 25, 2011. (See Exs. H and I).

As part of this agreement, DDB's counsel also agreed to withdraw certain requests that did not relate

to AOL. (Id.). In return, STATS's counsel agreed that STATS would comply with the document

subpoena and produce responsive documents, subject to its objections. (Id.).

       As of April 28, 2011, DDB had still not received any documents from STATS. (Baldwin

Decl. ¶6). As such, DDB's counsel contacted STATS's counsel to inquire about STATS's document

production as well as the scheduling of the related deposition. (See Ex. J). In response, STATS's

counsel indicated that STATS expected to begin producing documents "within the next few days,"

and suggested that the parties engage in a further discussion concerning the deposition of STATS.

(See Ex. K).

       On April 29, 2011, DDB's counsel and STATS's counsel engaged in yet another discussion

concerning DDB's subpoenas. (Baldwin Decl. ¶7). During that discussion, STATS's counsel

indicated that STATS would begin producing its documents during the week of May 2nd, starting

with agreements with AOL followed by relevant technical documents. (Baldwin Decl. ¶7).

STATS's counsel also indicated—for the first time—that STATS may be withholding some

documents concerning its collection, storage, and processing of the live sporting event data that

powered AOL's accused products, because STATS alleges that such documents are not specifically

related to AOL. (Baldwin Decl. ¶7). In response, DDB's counsel informed STATS's counsel that the

parties may have a dispute regarding the limitations STATS was imposing on its production, but that

DDB would wait to review STATS's production before discussing these issue further. (Baldwin

Decl. ¶7). During the discussion, DDB's counsel and STATS's counsel also discussed scheduling the

deposition of STATS during the week of May 9th. (Baldwin Decl. ¶7).

       As of May 6, 2011, DDB had still not received any documents from STATS. (Baldwin Decl.

¶8). As such, DDB's counsel emailed STATS's counsel to once again inquire about STATS's

                                                   6
document production. (See Ex. L). At this time, DDB's counsel also indicated that it wished to

proceed with the deposition of STATS on May 13, 2011, and that DDB was willing to work with

STATS concerning the location and timing of that deposition to make the processes as convenient for

STATS's witnesses as is reasonably possible. (Id.).

       Shortly after emailing STATS's counsel, DDB's counsel received STATS's first production of

documents responsive to DDB's document subpoena. (See Ex. M). STATS's counsel indicated that

such documents were being designated "CONFIDENTIAL - ATTORNEY'S EYES ONLY" under

the Amended Protective Order entered February 8, 2011 in the litigation between DDB and AOL.

(Id.). STATS's counsel also indicated that STATS would be producing additional documents the

following week. (Id.).

       On May 9, 2011, DDB's counsel received an email from STATS's counsel indicating that

STATS was making its second—and likely final—production of documents responsive to DDB's

document subpoena. (See Ex. N). STATS's counsel also indicated that STATS may be able to make

one or more witnesses available for deposition on the afternoon of May 13 in Chicago, but that

STATS would confirm the deposition the following day. (Id.).

       On May 10, 2011, DDB's counsel then received a letter from STATS's counsel concerning the

deposition of STATS. (See Ex. O). In that letter, STATS's counsel stated that STATS would make a

witness available on the afternoon May 13th, but that the deposition would be limited to three hours—

which is less than half of the seven hours that DDB is entitled to under Federal Rule of Civil

Procedure 30. (Id.). STATS's counsel failed to provide any justification for this improper time

limitation, however, instead, STATS's counsel baldly speculated that this shortened timeframe

"should be more than sufficient time to complete the deposition." (Id.).

       Even more problematic, STATS's counsel also informed DDB's counsel—for the first time

that STATS was refusing to produce a witness testify on "many" highly relevant topics in DDB's

                                                   7
deposition subpoena, including all topics directed to STATS's collection, storage, and processing of

the live sporting event data that powers AOL's accused product. (Id.). To apparently justify this

improper limitation, STATS's counsel asserted both that all subject matter encompassed by these

topics constitutes "trade secrets and other highly sensitive competitive and proprietary information"

and that the subject matter encompassed by these topics "appears irrelevant to [DDB's] lawsuit with

AOL." (Id.). As such, STATS's counsel expressed his intention to instruct STATS's witness not to

answer any questions concerning these highly relevant topics, even if that witness has personal

knowledge of such topics, to ensure that the deposition did not "devolve into a fishing expedition of

what the witness knows about STATS's business." (Id.).

       STATS's counsel concluded the May 10th letter by informing DDB's counsel that STATS

would not proceed with the deposition on May 13, 2011 unless DDB agreed with these unreasonable

constraints imposed on the deposition. (Id.).

       On May 11, 2011, DDB's counsel contacted STATS's counsel to discuss the unilateral

limitations that STATS was imposing on its production of information responsive to DDB's

subpoenas. (Baldwin Decl. ¶9). During that discussion, DDB's counsel urged STATS to reconsider

its refusal to produce documents and to provide testimony concerning STATS's collection, storage,

and processing of the live sporting event data that powers AOL's accused product. (Baldwin Decl.

¶9). As DDB's counsel explained, this information is highly relevant to DDB's infringement claims,

both because this information constitutes the primary evidence that the operation AOL's accused

product meets certain aspects DDB's patent claims and because STATS is the only entity that has

access to this information. (Baldwin Decl. ¶9). Nevertheless, STATS would not agree to produce

this information without an order from the Court. (Baldwin Decl. ¶9). As such, the parties decided to

delay the deposition of STATS until these discovery issues were resolved.



                                                   8
       In view of the foregoing, DDB hereby certifies that it has made numerous good faith attempts

to resolve this issue pursuant to Federal Rule of Civil Procedure 37(a)(1) and LR 37.2. DDB now

brings the present motion to compel STATS to immediately produce documents and to provide

testimony concerning STATS's collection, storage, and processing of the live sporting event data that

powers AOL's accused product.



III.   ARGUMENT

       Pursuant to Federal Rule of Civil Procedure 45(c)(2)(B), Plaintiff DDB hereby respectfully

moves this Court for an order compelling nonparty STATS to produce subpoenaed documents and

to provide testimony concerning subpoenaed deposition topics. This motion is necessary because

STATS is improperly refusing to produce highly-relevant information that is in the sole possession of

STATS, including information concerning the collection, storage, and processing of the live sporting

event data that powers Defendant AOL's accused product. (See, Ex. D Request Nos. 1-7, 13; Ex. E

Topic Nos. 1-5, 12). Indeed, STATS's bases for withholding this essential information do not meet

the standards set forth in Federal Rule of Civil Procedure 45. As such, DDB respectfully requests

that the Court order STATS to produce the subpoenaed information immediately, so that DDB can

use that information to prepare its expert reports due May 23, 2011, conduct any necessary follow up

before discovery closes on June 3, 2011, and prepare for trial in early July 2011.

       A.      STATS's Relevance Objection is Utterly Baseless

       As an initial matter, the information being withheld by STATS is highly relevant to DDB's

infringement claims, and any assertion by STATS to the contrary is utterly baseless. Indeed, as

noted above, the DDB Patents relate to a method and system for generating a computer simulation

of a live sporting event for display on a viewer's computer. As part of that method, an observer of

the live sporting event collects data about that event by entering symbols (or codes) representative

                                                   9
of the plays of the event into a computer. The observer's computer then uses these symbols to

generate and transmit data about the live sporting event to a centralized database computer, which

stores the data for future use in generating the computer simulation. Accordingly, information

concerning the collection, storage, and processing of the live sporting event data that powers

AOL's accused product is highly relevant to the operation of AOL's accused product, and thus to

DDB's patent infringement claims against AOL.

        B.      STATS's Trade Secret Objection does not Preclude Production

        Beyond STATS's baseless relevance objection, STATS other objection to producing this

highly-relevant information appears to be that such information allegedly constitutes "trade secrets

and other highly sensitive competitive and proprietary information." In making this objection,

STATS appears to be relying upon Federal Rule of Civil Procedure 45(c)(3)(B), which provides that

a court "may, on motion, quash or modify [a] subpoena if it requires . . . disclosing a trade secret or

other confidential research, development, or commercial information."

        DDB does not dispute that Federal Rule of Civil Procedure 45(c)(3)(B) provides some limited

protection to a nonparty for disclosure of trade secret or other confidential information. Instead, DDB

submits that STATS cannot meet the standards set forth in Federal Rule of Civil Procedure 45(c)(3)

for obtaining that protection.

                1.      STATS Cannot Show that All Requested Information Qualifies
                        as a Trade Secret or Other Protectable Confidential Information

        To obtain protection under Federal Rule of Civil Procedure 45(c)(3), STATS first has the

burden of showing that all withheld information qualifies as "a trade secret or other confidential

research, development, or commercial information." See R.J. Reynolds Tobacco v. Philip Morris,

Inc., 29 Fed. App'x 880, 882 (3d Cir. 2002). Factors to consider in making this determination may

include the extent to which the information is known outside the business; the extent to which the


                                                   10
information is known by employees and others involved in the business; the measures taken to

guard the information's secrecy; the value of the information to the business or its competitors; the

amount of time, money, and effort expended in the development of the information; and the ease

or difficulty of duplicating or properly acquiring the information. See, e.g., Andrew Corp. v. Rossi,

180 F.R.D. 338, 341 (N.D. Ill. 1998). Applying these factors to the present case, it is clear that

STATS cannot meet this burden for all of its withheld information.

       For instance, STATS is apparently asserting trade secret protection over any and all

information concerning the manner in which STATS collects the live sporting event data that powers

AOL's accused product, including but not limited to any manuals or specifications used by STATS's

observers during such data collection. STATS, however, cannot meet its burden of showing that this

type of information qualifies as "a trade secret or other confidential research, development, or

commercial information." Indeed, many of the documents within this category are presumably

distributed to every one of STATS's observers at every game site, and are then publicly used by those

observers during data collection at the game sites.

       For similar reasons, STATS will also be unable to meet its burden of showing that other high-

level information concerning the collection, processing, storage, and distribution of live sporting

event data qualifies as "a trade secret or other confidential research, development, or commercial

information." For this reason alone, STATS should be required to produce this high-level

information immediately.

               2.      STATS Cannot Show that it Will be Harmed by
                       the Production of the Requested Information

       To obtain the protection set forth in Federal Rule of Civil Procedure 45(c)(3), STATS also has

the burden of showing that its disclosure of the withheld information will result in a clearly defined

and serious injury to STATS. See R.J. Reynolds, 29 Fed. App'x at 882; Transcor, Inc. v. Furney


                                                   11
Charters, Inc., 212 F.R.D. 588, 592 (D. Kan. 2003). STATS also cannot meet this burden,

however.

        As an initial matter, neither of the remaining parties in the litigation (DDB and AOL) are

competitors of STATS.2 Indeed, neither DDB nor AOL currently provides any products or

services in the field of live sporting event simulation. And even when AOL previously provided

live sporting event simulation products, AOL never competed with STATS in the field of live

sporting event data collection, processing, or distribution. To the contrary, AOL contracted to

receive STATS's live sporting event data specifically because AOL did not perform its own live

sporting event data collection, processing, or distribution. Accordingly, for this reason alone,

STATS cannot show that disclosure of information concerning its collection, storage, and

processing of live sporting event data will result in any injury.

        Moreover, STATS has the ability to produce its confidential information under the

Amended Protective Order entered February 8, 2011 in the case between DDB and AOL, which

places substantial limitations on the manner in which such information can be used. (See Ex. P).

This Amended Protective Order resulted from extensive negotiations between the parties, and

there is no reason to believe that it cannot provide sufficient protection for any information

disclosed by STATS. Indeed, STATS has already availed itself of this protection for other

material, thereby admitting the sufficiency of the Amended Protective Order. Accordingly, for

this additional reason, STATS cannot show that disclosure of information concerning its

collection, storage, and processing of live sporting event data will result in any injury whatsoever.

See R.J. Reynolds, 29 Fed. App'x at 882 (finding that Wawa "cannot meet the additional showing of




2
  While one potential competitor of STATS has yet to be formally dismissed from the pending litigation, DDB expects
that such dismissal will occur during the week or May 16th.
                                                        12
good cause for restricting dissemination on the ground that it would be harmed by its disclosures"

where the disclosures would be made under the limitations of a previously entered protective order).

                3.      DDB has a Substantial Need for the Requested Information

        Even if STATS could meet its burden to show both that all withheld information qualifies

for protection under Federal Rule of Civil Procedure 45(c)(3)—which it cannot—this protection is

not absolute. Fed. Open Market Comm. v. Fed. Reserve Sys., 443 U.S. 340, 362 & 363 n.24 (1979)

(finding that "there is no absolute privilege for trade secrets and similar confidential information" and

that "[o]rders forbidding any disclosure of trade secrets or confidential commercial information are

rare"). Rather, DDB can still obtain production of this information by "show[ing] a substantial need

for the testimony or material that cannot be otherwise met without undue hardship." Fed. R. Civ. P.

45(c)(3)(C)(i). DDB can easily make this showing in the present case. Indeed, as discussed above,

the information being withheld by STATS is highly relevant to the operation of AOL's accused

product, and thus to DDB's patent infringement claims. Moreover, it is undisputed that STATS is the

only entity that has possession of this information. Taking these facts together, DDB clearly has a

"substantial need" for information from STATS concerning the collection, storage, and processing of

the live sporting event data that powers AOL's accused product. Cf. Mycogen Plant Science, Inc. v.

Monsanto Co., 164 F.R.D. 623, 627 (E.D. Pa. 1996) (finding a "substantial need" for documents from

a nonparty even where the plaintiff could have pursued many of the same documents from the

defendant).

        C.      STATS Cannot Withhold Production on the Basis of Burden

        It is unclear whether STATS is additionally objecting to the subpoenaed document

requests and deposition topics on the basis of burden. To the extent STATS is relying on a burden

objection, however, it cannot establish that such requests meet the "undue burden" standard set

forth in Federal Rule of Civil Procedure 45(c)(3)(A)(iv). Factors to consider in determining

                                                   13
whether this "undue burden" standard it met include: (1) relevance, (2) the need of the party for

the documents, (3) the breadth of the document request, (4) the time period covered by the request,

(5) the particularity with which the documents are described, and (6) the burden imposed.

Builders Ass'n of Greater Chicago v. City of Chicago, No. 96-1122, 2001 WL 664453, at *8 (N.D.

Ill. June 12, 2001).

       As noted above, the relevance and need of the requested information in this case is clear,

because this information constitutes the primary evidence that the operation of AOL's accused

product meets certain aspects of DDB's patent claims and because STATS is the only entity that has

access to this information. Moreover, the breadth of DDB's document requests and deposition topics

is reasonable, especially in light of DDB's willingness to narrow the scope of these requests and

topics to encompass only those documents concerning the relevant products and services that STATS

provided to AOL. Accordingly, any burden objection lodged by STATS should be ignored.



IV.    CONCLUSION

       In view of the foregoing, DDB respectfully requests that the Court issue an order compelling

STATS to immediately produce subpoenaed documents responsive to Request Nos. 1-7 and 13

and to provide subpoenaed testimony on Topics 1-5 and 12.



 Dated: May 16, 2011                               Respectfully submitted,

                                                   /s/Alison J. Baldwin

                                                   Michael D. Gannon (IL Bar No. 6206940)
                                                   Alison J. Baldwin (IL Bar No. 6271901)
                                                   Rory P. Shea (IL Bar No. 6290745)
                                                   John D. Smith (IL Bar No. 6300912)
                                                   McDonnell Boehnen Hulbert & Berghoff LLP
                                                   300 South Wacker Drive, Suite 3100
                                                   Chicago, Illinois 60606

                                                  14
    Tel: (312) 913-0001
.   Fax: (312) 913-0002
    gannon@mbhb.com
    baldwin@mbhb.com
    shea@mbhb.com
    smith@mbhb.com

    Counsel for Plaintiff
    DDB Technologies L.L.C




    15
                                CERTIFICATE OF SERVICE
       I certify that on the 16th day of May, 2011, I served a copy of the foregoing via Email and

First Class Mail to the following:

Counsel for Defendant AOL, Inc.:

Alan D Albright (alan.albright@bgllp.com)          Clinton H. Brannon (brannonc@howrey.com)
Bracewell & Giuliani LLP                           Vivian S. Kuo (kuov@howrey.com)
111 Congress Ave., Suite 2300                      Howrey LLP
Austin, TX 78701                                   1299 Pennsylvania Ave., N.W.
                                                   Washington, DC 20004-2402
                                                   Tel: (202) 783-0800
                                                   Fax: (202) 783-0800

Edward F. Valdespino                               Corrine M. Saylor (csaylor@winston.com)
(edward.valdespino@strasburger.com)                Winston & Strawn LLP
Strasburger & Price, LLP                           1700 K Street, N.W.
300 Convent St., Suite 900                         Washington, DC 20006-3817
San Antonio, TX 78205                              Tel: (202) 282-5892
                                                   Fax: (202) 282-5100

Floyd R. Nation (fnation@winston.com)
Kevin A. Keeling (kkeeling@winston.com)
Gary J. Fischman (gfischman@winston.com)
Joshua S. Wyde (jwyde@winston.com)
Winston & Strawn LLP
1111 Louisiana, 25th Floor
Houston, TX 77002

Counsel for Nonparty STATS, L.L.C.:

Aaron R. Feigelson, Ph.D. (afeigelson@leydig.com)
Leydig, Voit & Mayer, LTD.
Two Prudential Plaza
180 N. Stetson Avenue, Suite 4900
Chicago, IL 60601-6731
Tel: (312) 616-5600
Fax: (312) 616-5700



                                                            /s/Alison J. Baldwin

				
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