IconFind, Inc. v. Google, Inc.

Filing 92

JOINT STATUS REPORT by IconFind, Inc.. (Haan, Brian)

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WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP
Thomas G. Redmon (SBN 47090)
[e-mail]
Daniel L. Baxter (SBN 203862)
[e-mail]
400 Capitol Mall, 22nd Floor
Sacramento, CA 95814
Phone: [phone]
Fax: [phone]

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NIRO, HALLER & NIRO
Raymond P. Niro (Admitted Pro hac vice)
[e-mail]
Raymond P. Niro, Jr. (Admitted Pro hac vice)
[e-mail]
Brian E. Haan (Admitted Pro hac vice)
[e-mail]
Anna B. Folgers (Admitted Pro hac vice)
[e-mail]
181 West Madison, Suite 4600
Chicago, IL 60602-4515
Phone: [phone]
Fax: [phone]

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Attorneys for Plaintiff, IconFind, Inc.

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

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ICONFIND, INC.,

Case No. 2:11-cv-00319-GEB-JFM

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Plaintiff,
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JOINT STATUS REPORT RE
DISCOVERY DISAGREEMENT

v.
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GOOGLE INC.,
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Defendant.
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Pursuant to Magistrate Judge John F. Moulds’ April 25, 2012 Order, Dkt. No. 91,
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Plaintiff IconFind, Inc. (“IconFind”) and Defendant Google Inc. (“Google”) hereby file their
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joint status report and advise the Court that a hearing is not necessary with respect to
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IconFind’s discovery motion regarding the propriety of Google’s redacted document production

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and corresponding privilege log. See Not. of Hearing, Dkt. No. 81.

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Pursuant to the Court’s Order, the parties met and conferred on May 4, 2012 via

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telephone. Specifically, the parties discussed IconFind’s request for Google to supplement its

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March 27, 2012 revised privilege log (“Revised Log”) to reflect the 360 documents that it

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initially identified but later removed from its August 25, 2011 initial privilege log (“Initial Log”)

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as nonresponsive, including the 220 documents that were produced in redacted form and the 140

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documents that were withheld, and to identify them with the same level of specificity used to

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identify the 19 entries on the Revised Log. Google agreed to supplement the Revised Log to

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include the 360 documents. Given the upcoming deposition and claim construction schedule, the

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parties agreed that Google would make reasonable efforts to provide the supplemental privilege

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log in a timely manner, but not later than June 8, 2012.

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The parties agree that the foregoing agreement resolves the outstanding issues regarding

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IconFind’s discovery motion. See Not. of Hearing, Dkt. No. 81. Accordingly, the parties thank

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the Court for its guidance on these issues and advise the Court that a hearing is not necessary.

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Respectfully submitted,
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NIRO, HALLER & NIRO
Raymond P. Niro (Pro hac vice)
[e-mail]
Raymond P. Niro, Jr. (Pro hac vice)
[e-mail]
Brian E. Haan (Pro hac vice)
[e-mail]
Anna B. Folgers (Pro hac vice)
[e-mail]

/s/ Brian H. Haan
WILKE, FLEURY, HOFFELT, GOULD &
BIRNEY, LLP
Thomas G. Redmon (SBN 47090)
[e-mail]
Daniel L. Baxter (SBN 203862)
[e-mail]
Attorneys for Plaintiff, IconFind, Inc.

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JOINT STATUS REPORT RE DISCOVERY DISAGREEMENT

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on May 7, 2012 the foregoing:

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JOINT STATUS REPORT RE DISCOVERY DISAGREEMENT

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was filed with the Clerk of Court using the CM/ECF system, which will then send a notification
of such filing to the following counsel of record.

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Michael J. Malecek
[e-mail]
Kenneth Maikish
[e-mail]
Kaye Scholer LLP
Two Palo Alto Square, Suite 400
3000 El Camino Real
Palo Alto, California 94306
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant Google Inc.
I certify that all parties in this case are represented by counsel who are CM/ECF participants.

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/s/Brian E. Haan
Attorney for Plaintiff

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JOINT STATUS REPORT RE DISCOVERY DISAGREEMENT