Overture Services, Inc. v. Google Inc.
Filing
173
Declaration of Christine P. Sun in Support of 172 Request to File Documents Under Seal filed by Google Inc.. (Attachments: # 1 Exhibit A)(Related document(s) 172 ) (Sun, Christine) (Filed on 6/29/2004)
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Overture Services, Inc. v. Google Inc.
Doc. 173 Att. 1
Case 3:02-cv-01991-JSW
Document 173-2
Filed 06/29/2004
Page 1 of 2
EXHIBIT A
Dockets.Justia.com
,\
Case 3:02-cv-01991-JSW
Document 173-2
LAW OFFICES
Filed 06/29/2004
Page 2 of 2
KEKER
& VAN
LLP
NEST
710 SAN SOME STREET SAN FRANCISCO, CA 94111-1704 TELEPHONE (415) 391-5400 FAX (415) 397- 7188
WWW. KVN. COM
CHRISTINE P. SUN
CPS~KVN. COM
June 21
2004
VIA FACSIMILE
Andrew C. Byrnes , Esq. Heller Ehrman White & McAuliffe LLP 275 Middlefield Road Menlo Park, CA 94025-3506
Re:
Overture v.
Google
Dear Andrew:
I understand that the parties are still engaged in the mediation process. As stated in
Google s mediation brief, however, Google intends to file its motion to compel documents and
testimony re: the ' 361 patent prosecution should those discussions fail. Pursuant to Magistrate
Judge Laporte s standing order on confidential and sealed documents , I write to request that Overture de-designate certain exhibits that Google intends to file in support of its motion. Specifically, Google believes in good faith that the following exhibits marked by Overture as confidential or outside counsel only have been unnecessarily designated:
OVG047263- 0VG047271 Deposition of Darren J. Davis: pages 19 86- , 101- 102 , 159- 160 , 162, 172, and 187 Deposition of Elaine K. Lee: pages 10 31426192- , and 97Deposition of John G. Rauch: pages 144657656890- , 100- 101 , 171 , 173- 175 , 184- 186 , 196- 197 203
Please let me know by the end of the week (i. , by close of business on Friday, June 25) as to whether Overture nevertheless asserts that the above documents and deposition excerpts have been properly designated under the protective order in this case.
Thank you for your attention to this matter.
~ij
CPS
333924.
Very truly yours
CHRISTINE P. SUN
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