Perfect 10 Inc v. Google Inc et al

Filing 765

RESPONSE TO STATUS REPORT re REQUEST for Hearing - REQUEST FOR TELEPHONIC CONFERENCE WITH JUDGE HILLMAN #749 Google Inc.'s Response To Perfect 10, Inc.'s Status Report Regarding Court-Ordered Meet And Confer Regarding Documents Not Produced By Google filed by Counter Claimant Google Inc, Defendant Google Inc. (Kassabian, 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)] DISCOVERY MATTER GOOGLE INC.'S RESPONSE TO PERFECT 10, INC.'S STATUS REPORT REGARDING COURTORDERED MEET AND CONFER REGARDING DOCUMENTS NOT PRODUCED BY GOOGLE Hon. Stephen J. Hillman Date: None Set Time: None Set 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 28
01980.51320/3317655.1

Defendants.

Case No. CV 04-9484 AHM (SHx) [Consolidated with Case No. CV 05-4753 AHM (SHx)] GOOGLE INC.'S RESPONSE TO PERFECT 10, INC.'S STATUS REPORT

1

Perfect 10, Inc. ("P10") has filed an unsolicited "Status Report."1 The Court

2 did not request that the parties file further pleadings regarding P10's demands for 3 production prior to the "conclusion of the meet and confer process." 2 P10 admits 4 that the meet and confer is not complete, confirming that P10's filing was in 5 contravention of the Court's instructions. 6 Google will not add to the burden that P10 has imposed on the Court's already 7 heavy docket by substantively responding to P10's unauthorized and premature 8 filing unless the Court directs a response. Suffice it to say, P10's Status Report is 9 incomplete, failing to provide a full picture of the parties' meet and confer efforts 10 regarding discovery. Meet and confer efforts are ongoing and are proceeding as 11 quickly as practicable. If the Court wishes additional details, Google will provide 12 them upon the Court's direction. 13 14 DATED: February 9, 2010 15 16 17 18 19 20 21 22 23 P10's document is entitled "Status Report Regarding Court-Ordered Meet and Confer Regarding Documents Not Produced by Google," filed on February 8, 2010 26 (Docket No. 764). 2 January 27, 2010 Order denying P10's Request for Telephonic Conference 27 (Docket No. 759). 28 01980.51320/3317655.1 Case No. CV 04-9484 AHM (SHx) [Consolidated -125
with Case No. CV 05-4753 AHM (SHx)] GOOGLE INC.'S RESPONSE TO PERFECT 10, INC.'S STATUS REPORT

Respectfully submitted, QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP By Michael T. Zeller (Bar No. 196417) Rachel M. Kassabian (Bar No. 191060) Attorneys for Defendant GOOGLE INC.

24

1