Intermec Technologies Corp. v. Palm, Inc.

Filing 19

EXHIBITS re 15 Response ( Non Motion ) Exh D filed byGoogle Inc.. (Related document(s) 15 ) (Kobialka, Lisa) (Filed on 5/29/2009)

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Intermec Technologies Corp. v. Palm, Inc. Doc. 19 Case3:09-mc-80097-WHA Document19 Filed05/29/09 Page1 of 3 EXHIBIT D Dockets.Justia.com Case3:09-mc-80097-WHA Document19 Filed05/29/09 Page2 of 3 Freeborn & Peters LLP April 30, 2009 By E-mail and U.S. Mail AttoTneysatLaw 311 South Wacker Drive Suite 3000 Chicago, Ilinois Scott T. Weingaertner King & Spalding LLP 1185 Avenue of the Americas New York, NY 10036-4003 Re: Intermec Technologies Corp. Subpoena to Google in Intermec Technologies Corp. v. Palm, Inc., 07-272-SLR-LPS Dear Scott: 60606-6677 Tel 3 i 2.360.6000 Jeffrey M. Hansen Partner Direct 312.360.6379 Fax 312.360.6594 jhansen~ freehornpeters.com Than you for taking the time to speak with us yesterday by phone. As we discussed during the call, while what follows is a fair summation of the areas of information and testimony we are seeking, we are not waiving our right to seek all information permissible by law pursuant to our subpoena: A. Chicago Springfield Information regarding whether Google products/applications use a form of client-server architecture. B. The manner in which the client and server make requests for data from each other and how they respectively respond to such a request (for example, if the client application downloads from the server any executable code, including client-side scripting such as Javascript, AJAX, or Jscript, the maner in which the client application uses and executes that scripting code). 1. The manner in which the client side of a Google product/application searches its own data, if at all, prior to requesting data from the server and examples of when and how this occurs. C. The manners in which the client (handheld device/Palm device) and server sides of a Google product use and store data (i.e. flat fie, database, etc.). D. F or mobile versions of Google applications, a list of protocols or scripting languages that are supported. Case3:09-mc-80097-WHA Document19 Filed05/29/09 Page3 of 3 Freeborn & Peters LLP Scott T. Weingaertner April 30, 2009 Page 2 E. General information regarding the architecture used in Google products/applications (for example, identifying the tiers and the functions each tier performs). We understand that you wil initially focus on GMail, Google Maps, and Google Calendar given the logistical issues you stated exist. We can also state, per your request, that it has not been Intermec's intention to join Google as a pary to this litigation and, per the court's scheduling order, the time for adding paries has lapsed. If you have any questions regarding any of this, please do not hesitate to contact me at 312-360-6379 or at jhansen(▀freebornpeters.com. As we mentioned during the call, we are facing a May 18, 2009 discovery deadline and wil need to be aware of Google's response sometime in the next few days in order to avoid having to seek relief in the appropriate court. We wil also need dates and times for a deposition (or depositions, based upon your statements to us that multiple individuals may be necessary to discuss Intermec's areas of inquiry) as soon as possible. Sincerely yours, JMH/jlg 1817606vl