Overture Services, Inc. v. Google Inc.

Filing 176

Declaration of Ravind S. Grewal in Support of 175 Motion to Compel Production filed by Google Inc.. (Related document(s) 175 ) (Grewal, Ravind) (Filed on 6/29/2004)

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Overture Services, Inc. v. Google Inc. Doc. 176 Case 3:02-cv-01991-JSW Document 176 Filed 06/29/2004 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KEKER & VAN NEST, LLP JOHN W. KEKER - #49092 DARALYN J. DURIE - #169825 CHRISTINE P. SUN - #218701 RAVIND S. GREWAL - #220543 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Defendant and Counterclaimant GOOGLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION OVERTURE SERVICES, INC., Plaintiff and Counterdefendant, v. GOOGLE INC., Defendant and Counterclaimant. Case No. C 02-01991 JSW (EDL) DECLARATION OF RAVIND S. GREWAL IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT Date: August 3, 2004 Time: 9:00 a.m. Courtroom: E, 15th Floor Judge: Hon. Elizabeth D. Laporte 328901.01 DECLARATION OF RAVIND S. GREWAL IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT CASE NO. C 02-01991 JSW (EDL) Dockets.Justia.com Case 3:02-cv-01991-JSW Document 176 Filed 06/29/2004 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, RAVIND S. GREWAL, declare as follows: 1. I am an attorney licensed to practice in the State of California and am an associate at the law firm of Keker & Van Nest, LLP, counsel for Defendant and Counterclaimant Google Inc. in this matter. 2. Attached hereto as Exhibit A is a true and correct copy of Overture's privilege log, produced February 13, 2004. 3. Attached hereto as Exhibit B is a true and correct copy of a February 21, 1998 press release entitled, "GoTo.com, The First Ever Market-Driven Search Directory", (THD 00168-169). 4. Attached hereto as Exhibit C is a true and correct copy of a May 19, 1998 press release entitled, "GoTo.com Announces First Round of Financing Totaling More than Six Million Led by Draper-Fisher-Jurvetson", (OVG 015852-853). 5. Attached hereto as Exhibit D is a true and correct copy of a February 24, 1998 Wired article, "GoTo Searches With a Capitalist Engine", (THD 00172-173). 6. Attached hereto as Exhibit E is a true and correct copy of the relevant portions of Patent Application No. 09/322,677. 7. Attached hereto as Exhibit F is a true and correct copy of relevant portions of the Petition and Motion Under 37 CFR 1.102(d) to Make Application Special, dated October 22, 1999. 8. Attached hereto as Exhibit G is a true and correct copy of relevant portions of the Declaration in Support of Petition and Motion Under 37 CFR 1.102(d) to Make Application Special, dated October 22, 1999. 9. Attached hereto as Exhibit H is a true and correct copy of relevant portions of the Decision on Petition to Make Special, dated December 6, 1999. 10. Attached hereto as Exhibit I is a true and correct copy of the relevant portions of an Office Action, dated January 17, 2000, regarding Patent Application No. 09/322,677. 11. Attached hereto as Exhibit J is a true and correct copy of the relevant portions of a Response, dated April 6, 2000, regarding Patent Application No. 09/322,677. 1 DECLARATION OF RAVIND S. GREWAL IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT CASE NO. C 02-01991 JSW (EDL) 328901.01 Case 3:02-cv-01991-JSW Document 176 Filed 06/29/2004 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12. Attached hereto as Exhibit K is a true and correct copy of the relevant portions of an Office Action, dated June 18, 2000, regarding Patent Application No. 09/322,677. 13. Attached hereto as Exhibit L is a true and correct copy of relevant portions of an Interview Summary, dated August 1, 2000, regarding Patent Application No. 09/322,677. 14. Attached hereto as Exhibit M is a true and correct copy of relevant portions of an Amendment, dated September 28, 2000, regarding Patent Application No. 09/322,677. 15. Attached hereto as Exhibit N is a true and correct copy of relevant portions of the Declaration Under C.F.R 1.132, dated September 16, 2000. 16. Attached hereto as Exhibit O is a true and correct copy of the letter from Charles M. McMahon to Christine P. Sun, dated November 5, 2003. 17. Attached hereto as Exhibit P is a true and correct copy of the Order Granting In Part And Denying In Part Plaintiff's Motion To Compel and Granting In Part And Denying In Part Defendant's Motion To Compel, TV Interactive Data Corp. v. Microsoft Corp., No. C-022385 JSW (EDL), filed November 21, 2003. 18. Attached hereto as Exhibit Q is a true and correct copy of excerpts from the April 15, 2004 deposition of James B. Naughton. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 29th day of June, 2004, at San Francisco, California. /s/ Ravind S. Grewal RAVIND S. GREWAL 2 328901.01 DECLARATION OF RAVIND S. GREWAL IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT CASE NO. C 02-01991 JSW (EDL)

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