WhatsApp Inc. v. NSO Group Technologies Limited — Entry #886
Case: WhatsApp Inc. v. NSO Group Technologies Limited cand · 4:19-cv-07123
filed October 29, 2019
What this document is
Docket entry #886 · filed October 30, 2026
Who is involved
- Bill Marczak
- Francisco Partners LP
- Josh Shaner
- King & Spalding LLP
- Meta Platforms, Inc.
- NSO Group Technologies Limited
- Q Cyber Technologies Limited
- Terry Divittorio
- The Citizen Lab
- United States Department of Justice
- Westbridge Technologies, Inc.
- WhatsApp Inc.
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Nebius: its former name “Yandex N.V.” appears in a filing in this case.
….8 11 Perfect 10, Inc. v. Yandex N.V., No. C 12-1521-WHA,…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved November 11, 2026. Federal court filings are public records.
Document text
16 page(s), 35,262 characters, converted from the PDF's text layer · plain text.
Full text
Case 4:19-cv-07123-PJH Document 886-3 Filed 10/30/26 Page 1 of 16 PageID
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EXHIBIT B
Case 4:19-cv-07123-PJH Document 886-3 Filed 10/30/26 Page 2 of 16 PageID
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1 Greg D. Andres
Antonio J. Perez-Marques
2 Luca Marzorati
(admitted pro hac vice)
3 DAVIS POLK & WARDWELL LLP
450 Lexington Avenue
4 New York, New York 10017
Telephone: (212) 450-4000
5 Facsimile: (212) 701-5800
Email: greg.andres@davispolk.com
6 antonio.perez@davispolk.com
luca.marzorati@davispolk.com
7
Micah G. Block (SBN 270712)
8 DAVIS POLK & WARDWELL LLP
900 Middlefield Road, Suite 200
9 Redwood City, California 94063
Telephone: (650) 752-2000
10 Facsimile: (650) 752-2111
Email: micah.block@davispolk.com
11
Attorneys for Plaintiffs WhatsApp LLC and Meta
12 Platforms, Inc.
13 UNITED STATES DISTRICT COURT
14 FOR THE NORTHERN DISTRICT OF CALIFORNIA
15 OAKLAND DIVISION
16 WHATSAPP LLC and META PLATFORMS, )
INC. ) Case No. 4:19-cv-07123-PJH
17 )
Plaintiffs, )
18 ) NOTICE OF ISSUANCE OF SUBPOENA
v. ) TO HIPPOCRENE VENTURES LLC
19 )
NSO GROUP TECHNOLOGIES LIMITED )
20 and Q CYBER TECHNOLOGIES LIMITED, )
)
21 Defendants. )
)
22 )
23
24
25
26
27
28
Case 4:19-cv-07123-PJH Document 886-3 Filed 10/30/26 Page 3 of 16 PageID
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1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that, pursuant to Rule 45 of the Federal Rules of Civil Procedure,
3 Plaintiffs WhatsApp LLC and Meta Platforms, Inc. have issued the subpoena attached hereto to:
4 Hippocrene Ventures LLC
c/o The Corporation Trust Company
5 1209 Orange Street
Wilmington, Delaware 19801
6
The subpoena commands the production of documents and electronically stored information
7
specified in Exhibit A to the subpoena. Pursuant to Rule 45(a)(4), a copy of the subpoena is being
8
served on all parties before it is served on Hippocrene Ventures LLC.
9
10 Dated: September 23, 2026 DAVIS POLK & WARDWELL LLP
11
12 By: /s/ Micah G. Block
Greg D. Andres
13 Antonio J. Perez-Marques
Luca Marzorati
14 (admitted pro hac vice)
DAVIS POLK & WARDWELL LLP
15 450 Lexington Avenue
16 New York, New York 10017
Telephone: (212) 450-4000
17 Facsimile: (212) 701-5800
Email: greg.andres@davispolk.com
18 antonio.perez@davispolk.com
luca.marzorati@davispolk.com
19
20 Micah G. Block (SBN 270712)
DAVIS POLK & WARDWELL LLP
21 900 Middlefield Road, Suite 200
Redwood City, California 94063
22 Telephone: (650) 752-2000
Facsimile: (650) 752-2111
23
Email: micah.block@davispolk.com
24
Attorneys for Plaintiffs
25 WhatsApp LLC and Meta Platforms, Inc.
26
27
28
1
NOTICE OF ISSUANCE OF SUBPOENA TO HIPPOCRENE VENTURES LLC
CASE NO. 4:19-CV-07123-PJH
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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
UNITED STATES DISTRICT COURT
for the
Northern District
__________ DistrictofofCalifornia
__________
)
Plaintiff )
v. ) Civil Action No.
)
)
Defendant )
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To:
(Name of person to whom this subpoena is directed)
Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material:
Place: Date and Time:
Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place: Date and Time:
The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
/s/
Signature of Clerk or Deputy Clerk Attorney’s signature
The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).
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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
I received this subpoena for (name of individual and title, if any)
on (date) .
I served the subpoena by delivering a copy to the named person as follows:
on (date) ; or
I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
$ .
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc.:
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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)
Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance. (ii) disclosing an unretained expert’s opinion or information that does
not describe specific occurrences in dispute and results from the expert’s
(1) For a Trial, Hearing, or Deposition. A subpoena may command a study that was not requested by a party.
person to attend a trial, hearing, or deposition only as follows: (C) Specifying Conditions as an Alternative. In the circumstances
(A) within 100 miles of where the person resides, is employed, or described in Rule 45(d)(3)(B), the court may, instead of quashing or
regularly transacts business in person; or modifying a subpoena, order appearance or production under specified
(B) within the state where the person resides, is employed, or regularly conditions if the serving party:
transacts business in person, if the person (i) shows a substantial need for the testimony or material that cannot be
(i) is a party or a party’s officer; or otherwise met without undue hardship; and
(ii) is commanded to attend a trial and would not incur substantial (ii) ensures that the subpoenaed person will be reasonably compensated.
expense.
(e) Duties in Responding to a Subpoena.
(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or (1) Producing Documents or Electronically Stored Information. These
tangible things at a place within 100 miles of where the person resides, is procedures apply to producing documents or electronically stored
employed, or regularly transacts business in person; and information:
(B) inspection of premises at the premises to be inspected. (A) Documents. A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of business or
(d) Protecting a Person Subject to a Subpoena; Enforcement. must organize and label them to correspond to the categories in the demand.
(B) Form for Producing Electronically Stored Information Not Specified.
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney If a subpoena does not specify a form for producing electronically stored
responsible for issuing and serving a subpoena must take reasonable steps information, the person responding must produce it in a form or forms in
to avoid imposing undue burden or expense on a person subject to the which it is ordinarily maintained or in a reasonably usable form or forms.
subpoena. The court for the district where compliance is required must (C) Electronically Stored Information Produced in Only One Form. The
enforce this duty and impose an appropriate sanction—which may include person responding need not produce the same electronically stored
lost earnings and reasonable attorney’s fees—on a party or attorney who information in more than one form.
fails to comply. (D) Inaccessible Electronically Stored Information. The person
responding need not provide discovery of electronically stored information
(2) Command to Produce Materials or Permit Inspection. from sources that the person identifies as not reasonably accessible because
(A) Appearance Not Required. A person commanded to produce of undue burden or cost. On motion to compel discovery or for a protective
documents, electronically stored information, or tangible things, or to order, the person responding must show that the information is not
permit the inspection of premises, need not appear in person at the place of reasonably accessible because of undue burden or cost. If that showing is
production or inspection unless also commanded to appear for a deposition, made, the court may nonetheless order discovery from such sources if the
hearing, or trial. requesting party shows good cause, considering the limitations of Rule
(B) Objections. A person commanded to produce documents or tangible 26(b)(2)(C). The court may specify conditions for the discovery.
things or to permit inspection may serve on the party or attorney designated
in the subpoena a written objection to inspecting, copying, testing, or (2) Claiming Privilege or Protection.
sampling any or all of the materials or to inspecting the premises—or to (A) Information Withheld. A person withholding subpoenaed information
producing electronically stored information in the form or forms requested. under a claim that it is privileged or subject to protection as trial-preparation
The objection must be served before the earlier of the time specified for material must:
compliance or 14 days after the subpoena is served. If an objection is made, (i) expressly make the claim; and
the following rules apply: (ii) describe the nature of the withheld documents, communications, or
(i) At any time, on notice to the commanded person, the serving party tangible things in a manner that, without revealing information itself
may move the court for the district where compliance is required for an privileged or protected, will enable the parties to assess the claim.
order compelling production or inspection. (B) Information Produced. If information produced in response to a
(ii) These acts may be required only as directed in the order, and the subpoena is subject to a claim of privilege or of protection as
order must protect a person who is neither a party nor a party’s officer from trial-preparation material, the person making the claim may notify any party
significant expense resulting from compliance. that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
(3) Quashing or Modifying a Subpoena. information and any copies it has; must not use or disclose the information
(A) When Required. On timely motion, the court for the district where until the claim is resolved; must take reasonable steps to retrieve the
compliance is required must quash or modify a subpoena that: information if the party disclosed it before being notified; and may promptly
(i) fails to allow a reasonable time to comply; present the information under seal to the court for the district where
(ii) requires a person to comply beyond the geographical limits compliance is required for a determination of the claim. The person who
specified in Rule 45(c); produced the information must preserve the information until the claim is
(iii) requires disclosure of privileged or other protected matter, if no resolved.
exception or waiver applies; or
(iv) subjects a person to undue burden. (g) Contempt.
(B) When Permitted. To protect a person subject to or affected by a The court for the district where compliance is required—and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court—may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been served, fails without adequate excuse to obey the
(i) disclosing a trade secret or other confidential research, subpoena or an order related to it.
development, or commercial information; or
For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
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EXHIBIT A
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PLAINTIFFS’ SUBPOENA FOR DOCUMENTS TO HIPPOCRENE VENTURES
LLC
YOU ARE HEREBY COMMANDED, pursuant to Fed. R. Civ. P. 45, to produce
the Documents and things designated herein for inspection at the offices of Davis Polk &
Wardwell LLP, 450 Lexington Avenue, New York, NY 10017, within 14 days of service
(or such later date on which both parties agree), as provided under the Federal Rules of
Civil Procedure. This Subpoena for Documents, including each individual Request for
Documents (collectively, the “Requests”), shall be read and interpreted in accordance with
the definitions and instructions identified below.
DEFINITIONS AND INSTRUCTIONS
Plaintiffs incorporate by reference all the instructions, definitions, and rules
contained in the Federal Rules of Civil Procedure, and for purposes of this Subpoena, the
following instructions and definitions shall apply:
1. “Communication” means the transmittal of information (in the form of facts,
ideas, inquiries or otherwise).
2. “Complaint” means the complaint filed by WhatsApp LLC (f/k/a
WhatsApp Inc.) and Meta Platforms, Inc. (f/k/a Facebook, Inc.) against Defendants in the
United States District Court for the Northern District of California, No. 4:19-cv-07123-
PJH on October 29, 2019.
3. “Defendants” refers to NSO and Q Cyber.
4. “Document” or “Documents” is defined to be synonymous in meaning and
equal in scope to the usage of the term “documents or electronically stored information” in
Fed. R. Civ. P. 34(a)(1)(A).
2
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5. “Hippocrene Ventures” means Hippocrene Ventures LLC, as well as its
subsidiaries, affiliates, branches, divisions, partnerships, properties, groups, special
purpose entities, joint ventures, predecessors, successors, or any other entity in which they
have or had a controlling interest, and any current or former employee, officer, director,
shareholder, partner, member, consultant, manager, associate, staff employee, independent
contractor, agent, attorney or other representative of any of those entities.
6. “Judgment Debtors” means NSO Group Technologies Limited and Q Cyber
Technologies Limited.
7. “Meta Platforms” means the requesting party Meta Platforms, Inc. (f/k/a
Facebook, Inc.).
8. “NorthPole NewCo” means NorthPole NewCo S.à r.l., a société à
responsabilité limitée organized under the laws of Luxembourg.
9. “NSO” means NSO Group Technologies Limited, as well as its directors,
employees, subsidiaries, corporate parents, affiliates, and representatives.
10. “Person” means any natural person or any legal entity, including, without
limitation, any business or governmental entity or association.
11. “Q Cyber” means Q Cyber Technologies Limited, as well as its directors,
employees, subsidiaries, corporate parents, affiliates, and representatives.
12. “Relating to” means concerning, referring to, describing, evidencing, or
constituting.
13. The “Relevant Period” is from January 1, 2025 through present.
14. “Transaction” means the acquisition by Hippocrene Ventures LLC of
secured creditor rights against NorthPole NewCo and/or Defendants in or about October
3
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2025, and the related transfer of shares of NorthPole NewCo, including all negotiations,
due diligence, agreements, and closing steps in connection therewith.
15. “WhatsApp” means the requesting party WhatsApp LLC (f/k/a WhatsApp
Inc.).
16. “You,” “Your,” and “Yours” shall mean Hippocrene Ventures, and any
other person acting on Your behalf, including but not limited to directors, employees,
subsidiaries, corporate parents, and representatives.
17. In producing Documents, You are requested to produce the original of each
Document requested together with all copies and drafts of that Document. In any
circumstance in which an agreement is reached to allow the production of copies of
Documents rather than originals, you shall retain all of the original Documents for
inspection or copying throughout the pendency of this case, any appeal(s), and any related
proceedings.
18. Any alteration of a responsive Document, including any marginal notes,
handwritten notes, underlining, date stamps, received stamps, endorsed or filed stamps,
drafts, revisions, modifications, and other versions of a Document, is a responsive
Document on its own and must be produced.
19. Documents and Communications shall be produced in a manner that
identifies all metadata, including but not limited to the sender, recipient, date, time, and
location, when available.
20. Documents shall be produced in the file folder, envelope, or other container
in which the documents are kept or maintained. If, for any reason, the container cannot be
produced, produce copies of all labels or other identifying marks.
4
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21. If identical copies of a Document are in the possession, custody, or control
of more than one natural Person or other Document custodian, a copy of that Document
shall be produced from each such natural Person or other Document custodian.
22. Produce all responsive Documents in Your possession, custody, or control,
regardless of whether such Documents are possessed directly by You or Persons under
Your control, including Your agents, employees, representatives, or attorneys, or their
agents, employees, or representatives.
23. If You object to part of a request, you must produce all Documents called
for which are not subject to that objection.
DOCUMENTS TO BE PRODUCED
Document Request No. 1:
All Documents Relating to the formation, organization, and governance of
Hippocrene Ventures LLC, including but not limited to: certificate of formation, operating
agreement(s), and all amendments thereto.
Document Request No. 2:
Documents and Communications sufficient to identify all current and former
members, managers, officers, directors, beneficial owners, equity holders, and any other
Persons with authority to act on behalf of or direct the activities of Hippocrene Ventures
LLC during the Relevant Period.
Document Request No. 3:
All Documents and Communications concerning the Transaction, including but not
limited to: purchase agreements, assignment agreements, credit bid documentation, loan
5
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transfer documents, participation agreements, closing documents, consideration paid, and
all negotiations, correspondence, due diligence materials, and drafts Relating thereto.
Document Request No. 4:
All Documents and Communications concerning the transfer of shares of NorthPole
NewCo to or by Hippocrene Ventures LLC, including but not limited to: share purchase
agreements, share transfer forms, notarial deeds, Luxembourg trade registry filings,
shareholder registers, consents, waivers, and any documents reflecting the consideration
paid or received for such transfers.
Document Request No. 5:
All Documents and Communications concerning any loans, financing
arrangements, credit facilities, promissory notes, or security interests involving Hippocrene
Ventures LLC, on the one hand, and Defendants, NorthPole NewCo, or OSY Technologies
S.à r.l., on the other hand.
Document Request No. 6:
Documents sufficient to identify all Financial Accounts of Hippocrene Ventures
LLC through which funds were received from or transmitted to Defendants, NorthPole
NewCo, or OSY Technologies S.à r.l. during the Relevant Period, including the name and
address of the financial institution, account number, account holder(s), authorized
signatory(ies), and current and historical balances during the Relevant Period.
Document Request No. 7:
For each Financial Account identified in response to Document Request No. 6, all
account statements, transaction records, wire transfer confirmations, and deposit and
6
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withdrawal records reflecting transfers of funds to or from Defendants, NorthPole NewCo,
or OSY Technologies S.à r.l. during the Relevant Period.
Document Request No. 8:
All Documents reflecting transfers of funds, property, securities, or other assets of
any kind between Hippocrene Ventures LLC, on the one hand, and Defendants, NorthPole
NewCo, or OSY Technologies S.à r.l., on the other hand, during the Relevant Period.
Document Request No. 9:
All Documents and Communications concerning the role of Hippocrene Ventures
LLC (or any of its members, managers, officers, or agents) in the management, governance,
direction, or control of Defendants or NorthPole NewCo, including but not limited to:
board seats, management rights, observer rights, veto rights, consent rights, or other
governance authority.
Document Request No. 10:
All Communications between Hippocrene Ventures LLC (including its members,
managers, officers, agents, attorneys, and representatives) and Defendants or NorthPole
NewCo during the Relevant Period Relating to any of the Judgment Debtors’ assets,
liabilities, financial condition, corporate structure, or the Transaction.
Document Request No. 11:
All Communications between Hippocrene Ventures LLC (including its members,
managers, officers, agents, and representatives) and Robert Simonds (or any entity owned
or controlled by Robert Simonds) concerning Defendants, NorthPole NewCo, or the
judgments entered in this action.
7
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Document Request No. 12:
All Documents concerning any assets of Defendants held by, pledged to, assigned
to, or maintained for the benefit of Hippocrene Ventures LLC, including but not limited to:
intellectual property, technology licenses, software, customer contracts, real property
interests, equipment, and intangible assets.
Document Request No. 13:
All Documents concerning any distributions, dividends, payments, interest, fees,
reimbursements, or other compensation of any kind received by Hippocrene Ventures LLC
from or on behalf of Defendants, NorthPole NewCo, or OSY Technologies S.à r.l. during
the Relevant Period.
Document Request No. 14:
All Documents and Communications concerning any restructuring, reorganization,
recapitalization, merger, consolidation, or change of control of Defendants or NorthPole
NewCo during the Relevant Period in which Hippocrene Ventures LLC participated,
consented to, or of which it had knowledge.
Document Request No. 15:
All Documents concerning any valuations, appraisals, or assessments of
Defendants, NorthPole NewCo, or any of their assets, equity, or business operations
performed by or for Hippocrene Ventures LLC during the Relevant Period.
Document Request No. 16:
All engagement letters, fee agreements, advisory mandates, or retainer agreements
between Hippocrene Ventures LLC and any financial advisor, investment bank, valuation
firm, management consultant, or other professional advisor concerning Defendants or
NorthPole NewCo.
8
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Document Request No. 17:
All Documents concerning any current or planned disposition, sale, assignment,
transfer, pledge, or encumbrance of Hippocrene Ventures LLC’s secured creditor rights,
equity interests, or any other rights against or Relating to Defendants or NorthPole NewCo.
Document Request No. 18:
All Documents and Communications concerning any legal proceedings,
arbitrations, mediations, or disputes between Hippocrene Ventures LLC and Defendants or
NorthPole NewCo, including but not limited to pleadings, demand letters, settlement
agreements, and correspondence with counsel.
Document Request No. 19:
Documents sufficient to show all sources of funding used by Hippocrene Ventures
LLC to acquire the secured creditor rights against NorthPole NewCo and/or Defendants,
including but not limited to: capital contributions by members, loan agreements, credit
facilities, investor subscription agreements, and bank records reflecting the flow of funds.
Document Request No. 20:
All Documents and Communications concerning any agreement, arrangement,
understanding, or Communication between Hippocrene Ventures LLC and any Person
regarding the satisfaction, enforcement, collection, or frustration of the judgments entered
against Defendants in WhatsApp LLC, et al. v. NSO Group Technologies Limited, et al.,
No. 4:19-cv-07123-PJH (N.D. Cal.).
Document Request No. 21:
All Documents concerning any indemnification, hold-harmless, or contribution
arrangements between Hippocrene Ventures LLC and Defendants or NorthPole NewCo,
9
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including but not limited to indemnification provisions in any agreement, side letter, or
governance document.
Document Request No. 22:
All minutes of meetings, written resolutions, or member and manager consents of
Hippocrene Ventures LLC that reference or concern Defendants, NorthPole NewCo, the
judgments entered in this action, or any matter Relating to the post-judgment proceedings
in this action.
Document Request No. 23:
Documents sufficient to show whether Hippocrene Ventures LLC and any entity
named “Hippocrene, LLC” (including any Delaware-registered entity by that name) share
common ownership, management, control, members, or officers.
10