, and (ii) the analysis regarding the predominance of legal advice in the communications at issue and Ambac Assur. Corp. v. Countrywide Home Loans, Inc.6 both expand the scope of privilege to protect certain content unrelated to ongoing litigation. See infra S IV. Indeed, Defendant refers to New Yor

hone usage. Participants operating in the wireless handset / headset industry include large public companies such as Motorola Mobility, Ines, Palm, Inc.6, Nokia Corp., Plantronics Inc., Research in Motion Ltd., Netgear Inc., and Logitech International SA, as well as a number of smaller companies such

hone usage. Participants operating in the wireless handset / headset industry include large public companies such as Motorola Mobility, Ines, Palm, Inc.6, Nokia Corp., Plantronics Inc., Research in Motion Ltd., Netgear Inc., and Logitech International SA, as well as a number of smaller companies such

hone usage. Participants operating in the wireless handset / headset industry include large public companies such as Motorola Mobility, Ines, Palm, Inc.6, Nokia Corp., Plantronics Inc., Research in Motion Ltd., Netgear Inc., and Logitech International SA, as well as a number of smaller companies such