Perfect 10 Inc v. Google Inc et al

Filing 543

SUPPLEMENT to MOTION to Compel Perfect 10, Inc. to Produce Documents, Comply with the Protective Order, and Affix Document Control Numbers to its Document Productions #407 Google Inc.'s Supplemental Memorandum in Support of its Motion to Compel Perfect 10, Inc. to Affix Document Control Numbers to its Document Production filed by Counter Claimant Google Inc, Defendant Google Inc. (Attachments: #1 Second Supplemental Declaration of Rachel Herrick Kassabian in Support Thereof, #2 Exhibit 1, #3 Exhibit 2)(Herrick, Rachel)

1 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Michael T. Zeller (Bar No. 196417) [e-mail] 2 865 South Figueroa Street, 10th Floor 3 Los Angeles, California 90017-2543 Telephone: [phone] Facsimile: [phone] Charles K. Verhoeven (Bar No. 170151) [e-mail] 5 50 California Street, 22nd Floor 6 San Francisco, California 94111 Rachel Herrick Kassabian (Bar No. 191060) [e-mail] 7 555 Twin Dolphin Drive, Suite 560 8 Redwood Shores, California 94065 9 Attorneys for Defendant Google Inc. 10 11 12 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NO. CV 04-9484 AHM (SHx) [Consolidated with Case No. CV 054753 AHM (SHx)] SECOND SUPPLEMENTAL DECLARATION OF RACHEL HERRICK KASSABIAN IN SUPPORT OF GOOGLE'S MOTION TO COMPEL PERFECT 10 TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION Hon. Stephen J. Hillman Date: None [Currently under submission] Time: None Crtrm.: 550 Discovery Cutoff: None Set Pretrial Conference Date: None Set Trial Date: None Set

13 PERFECT 10, INC., a California corporation, 14 Plaintiff, 15 vs. 16 GOOGLE INC., a corporation; and 17 DOES 1 through 100, inclusive, 18 19 20 22 23 vs. Defendants. AND COUNTERCLAIM

PERFECT 10, INC., a California 21 corporation, Plaintiff,

24 AMAZON.COM, INC., a corporation; A9.COM, INC., a corporation; and 25 DOES 1 through 100, inclusive, 26 27
01980.51320/3118397.1

Defendants.

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SECOND SUPPLEMENTAL KASSABIAN DECLARATION IN SUPPORT OF GOOGLE'S MOTION TO COMPEL P10 TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION

1 2

I, Rachel Herrick Kassabian, declare as follows: 1. I am a member of the bar of the State of California and a partner with

3 Quinn Emanuel Urquhart Oliver & Hedges, LLP, counsel for Defendant Google Inc. 4 ("Google") in this action. I make this declaration of my personal and firsthand 5 knowledge and, if called and sworn as a witness, could and would competently 6 testify thereto. 7 2. Attached as Exhibit 1 is a true and correct copy of a disk containing 8 Plaintiff Perfect 10, Inc.'s August 12, 2009 document production, which has been 9 Bates-numbered using Adobe Acrobat Professional (version 9.0). 10 3. Attached as Exhibit 2 is a true and correct copy of a transcription of the 11 third segment of "How'd You Get So Rich" Season 1, Episode 3, which features 12 Norm Zada and his company, Perfect 10, Inc. The transcription was prepared by 13 employees of Quinn Emanuel Urquhart Oliver & Hedges, LLP under my direction. 14 "How'd You Get So Rich" is a nationally broadcast television program hosted by 15 Joan Rivers that profiles extremely wealthy individuals, and a description of the 16 program can be found at 17 http://www.tvland.com/prime/shows/howd_you_get_so_rich/index.jhtml. The 18 episode transcribed was broadcast nationwide on August 19, 2009 and is available to 19 view online at http://www.tvland.com/prime/fullepisodes/howd_you_get_so_rich/ 20 season1/index.jhtml?episodeId=22304. 21 I declare under penalty of perjury under the laws of the United States of 22 America that the foregoing is true and correct. Executed September 29, 2009 at 23 Redwood Shores, California. 24 25 26 27
01980.51320/3118397.1

__________________________ Rachel Herrick Kassabian -1-

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SECOND SUPPLEMENTAL KASSABIAN DECLARATION IN SUPPORT OF GOOGLE'S MOTION TO COMPEL P10 TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION