In Len Deutchman's Jan. 13, 2009 publication on Law.com's Legal Technology pages, "Being Right and Still Losing," the discussion of the case Qualcomm Inc. v. Broadcom Corp. should have mentioned that the magistrate court later dissolved the Order to Show Cause Re Sanctions against 13 attorneys. The article should also have mentioned that on appeal, the district court dismissed sanctions against six other attorneys on the basis that the imposition of the sanctions had violated their due process rights. The Federal Circuit has not upheld sanctions against outside counsel in the case. And while the case did involve e-discovery issues, including the failure to turn over e-mails, spoliation was not an issue in the case.
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