I/P Engine, Inc. v. AOL, Inc. et al
STIPULATION - See Attached Document for Specifics. Signed by District Judge Raymond A. Jackson and filed on 4/17/2013. (bnew)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
APR 17 2013
CILRK, US. DiSIHlCJ CUURT
No-i UX VA
IT ENGINE, INC.
Civil Action No. 2:1 l-cv-512
AOL INC., et al.,
Counsel for Plaintiff I/P Engine, Inc. ("I/P Engine") and Counsel for Defendants AOL
Inc., Google Inc., IAC Search and Media, Inc., Target Corporation and Gannett Company, Inc.
(collectively "Defendants") stipulate to the following:
On November 20,2012, this Court entered judgment against Defendants in this
case (the"Judgment") in the amounts of $15,800,000 against Google Inc., $7,943,000 against
AOL, Inc., $6,650,000 against IAC Search & Media, Inc., $4,322 against Gannett Co., Inc., and
$98,833 against Target Corp. (Docket No. 801.)
The parties have agreed to stay any proceeding to execute or enforce the
Judgment against Defendants pending resolution of the related pending appeals (Case Nos. 131307 and 13-1313), and for thirty (30) days thereafter.
The parties have also agreed that a supersedeas bond is not necessary to protect
I/P Engine's interests pending Defendants' appeal of this case.
Consistent with Local Rule 62(B) for the United States District Court for the
Eastern District of Virginia, the requirement of the postingof a supersedeas bond pending
Defendants' appeal of this case is waived.
This stipulation will terminate thirty (30) days after service of the issuance of a
mandate from the United States Court of Appeal for the Federal Circuit, unless Defendants post a
supersedeas bond in an amount sufficient to coverthe Judgment amounts that remain after
Because Google is indemnifying the other Defendants for the Judgment, Google
will satisfy in full any Judgment amounts that remain after appeal against all Defendants.
This stipulation has no relation to, and does not affect any request by I/P Engine
for any future damages, including ongoing royalties, or any opposition to such request by
This Stipulation represents the entire agreement of the parties to this action
regarding the matters set forth herein.
Dated: April 1(^,2013
Donald <£ Schultz (Virginia1 Bar No.W531)
W. Ryan Snow (Virginia Bar No. 47423)
CRENSHAW, WARE & MARTIN PLC
150 West Main Street
Norfolk, VA 23510
Jeffrey K. Sherwood (Virginia Bar No. 19222)
Frank C. Cimino, Jr.
Kenneth W. Brothers
Charles J. Monterio, Jr.
DICKSTEIN SHAPIRO LLP
1825 Eye Street, NW
Washington, DC 20006
Dawn Rudenko Albert
DICKSTEIN SHAPIRO LLP
New York, NY 10019
Counsel firf9 Plaintiff I/P Engine, Inc.
Dated: April 1^2013
^Street, Suite 2100
Telephone: (757) 624-3239
QUINN EMANUEL URQUHART &
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: (415) 875-6600
Counsel for Defendants AOL Inc., Google Inc., IAC
Search and Media, Inc., Target Corporation and
Gannett Company, Inc.
Raymond AL. Jackson
United States District Judge
Honorable Raymond A. Jackson