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O'Melveny & Myers
BEIJING
lep
BRUSSELS
HONG KONG
TELEPHONE
LONDON
FACSIMILE
LOS ANGELES
(310) 553-67OO
(310) 246-6779
www.omm.com
NEWPORT BEACH
SAN FRANCISCO
SEOUL
SHANGHAI
SILICON VALLEY
SINGAPORE
TOKYO
NEW YORK
WASHINGTON, D.C.
VIA E-MAIL
(310) 246-6850
September 1, 2016
dpetrocelli@omm.com
David Hyman
General Counsel
Netflix, Inc.
100 Winchester Circle
Los Gatos, CA 95032
Re:
OMelvenya Myers
September 1, 2016 - Page 2
llp
Netflixs wrongful solicitation and hiring of Ms. Flynn also threatens Foxs trade secrets. As an
executive in creative affairs, Ms. Flynn has been privy to Foxs valuable trade secret
information. Indeed, Ms. Flynn and her group are currently producing a television show for
Netflix. Fox will take vigorous action to defend any misappropriation of its trade secrets by
Netflix.
Given the seriousness of these issues, Fox hereby notifies Netflix of its obligation to preserve all
documents, data, and tangible things (hereafter Records) in its possession, custody, and control
that are potentially related to this dispute, including all electronically stored information, and not
to destroy, delete, erase or over write any such Records. The scope of preservation should
include, at a minimum, all Records relating to the solicitation, hiring, and employment of Mr.
Waltenberg, Ms. Flynn, and any other current or former employees of Fox.
Fox reserves all rights and remedies, all of which are expressly reserved.
Very truly yours,
Daniel M. Petrocelli
of OMEL YEN Y & MYERS LLP
DMP:jcl