Flowbee International, Inc. et al v. Google, Inc.
INITIAL DISCLOSURES by Google, Inc., filed.(Babcock, Charles)
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION FLOWBEE INTERNATIONAL, INC. and FLOWBEE HAIRCUTTER LIMITED PARTNERSHIP, Plaint iffs, v. GOOGLE INC., Defendant. § § § § § § § § § § §
Civil Action No. C-09-199
DEFENDANT GOOGLE INC.'S LIST OF PERSONS WITH RELEVANT KNOWLEDGE TO THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS: COMES NOW Defendant Google Inc. ("Google") and pursuant to paragraph 7 of the Order Regarding Cases Assigned to Janis Graham Jack, U.S. District Judge, would show the Court as follows: Google has identified those persons likely to have discoverable information that Google may use to support its claims or defenses who Google presently believes are most knowledgeable about the listed subjects, but Google reserves its right to supplement these disclosures as discovery progresses. Google employees or former employees, including those identified below, may be contacted only through Google counsel.
Defendant Google Inc.'s List of Persons with Relevant Knowledge Page 1
Name Heather Wilburn Rose Hagan Alana Karen Bill Lloyd Tracy Lee-Blumberg Prashanth Koppula
Subjects Informat ion concerning the operation of Google's search engine and AdWords program. Informat ion concerning Google's U.S. trademark policies relating to its AdWords program. Informat ion concerning AdWords advertisers and advertisements and the implementation of the Google AdWords service. Information relating to the processing of complaints concerning use of trademarks in AdWords program advertising. Informat ion relating to Flowbee's advertising account. Informat ion concerning the operation of Google's AdSense for Domains program.
The above individuals may be contacted only through counsel at Quinn Emanuel Urquhart Oliver & Hedges, 555 Twin Dolphin Drive, Suite 560, Redwood Shores, California, 94065, (650) 801-5000. In addition, current or former employees of Flowbee International and Flowbee Haircutter Limited Partnership are likely to have discoverable information that Google may use to support its claims or defenses. These disclosures do not include any expert witnesses who will be identified pursuant to Rule 26.
Defendant Google Inc.'s List of Persons with Relevant Knowledge Page 2
Respect fully submitted,
s/ Charles L. Babcock CHARLES L. "CHIP" BABCOCK LEAD LOCAL COUNSEL Texas State Bar No. 01479500 Federal Bar No. 10982 JACKSON WALKER L.L.P. 1401 McKinney, Suite 1900 Houston, TX 77010-4008 (713) 752-4210 (713) 308-4110 - Fax Email: firstname.lastname@example.org CARL C. BUTZER CO-LOCAL COUNSEL Texas State Bar No. 03545900 Federal Bar No. 16376 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-5902 (214) 661-6609 - Fax Email: email@example.com ATTORNEYS FOR DEFENDANT GOOGLE INC. OF COUNSEL: Margret M. Caruso (admitted pro hac vice) California State Bar No. 243473 Quinn Emanuel Urquhart Oliver & Hedges, LLP 555 Twin Dolphin Drive, Suite 560 Redwood Shores, California 94065 (650) 801-5101 (650) 801-5100 Fax Email: firstname.lastname@example.org ATTORNEY FOR DEFENDANT GOOGLE INC.
Defendant Google Inc.'s List of Persons with Relevant Knowledge Page 3
CERTIFICATE OF SERVICE I hereby certify that on September 22, 2009, I electronically submitted the foregoing document with the clerk of the court for the U.S. District Court, Southern District of Texas, using the electronic case files system of the court. The electronic case files system sent a "Notice of Electronic Filing" to individuals who have consented in writing to accept this Notice as service of this document by electronic means. All other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by first class mail today, September 22, 2009.
s/ Charles L. Babcock Charles L. Babcock
Defendant Google Inc.'s List of Persons with Relevant Knowledge Page 4
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