Google, Inc. v. Eolas Technologies Inc. et al

Filing 1

COMPLAINT against Eolas Technologies Incorporated. The Regents of the University of California. Filed byGoogle, Inc.(Filing fee $400.00, receipt number 0971-8262256.). (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Civil Cover Sheet)(Mitro, Keith) (Filed on 12/30/2013) Modified on 12/31/2013 (ha, COURT STAFF). Modified on 1/3/2014 (jlmS, COURT STAFF).

Exhibit C

MCKOOL SMITH
John B. Campbell
Direct Dial: [phone]
Jcampbell~mckoolsmith.com

300 W. 6th Street
Suite 1700
Austin, TX 78701

Telephone: [phone]
Facsimile: [phone]

December 19, 2013

VIA CERTIFIED MAIL
Google Inc.
c/o Corporation Service Company d/b/a CSC
701 Brazos Street, Suite 1050
Austin, Texas 78701-3232
RE:

Infringement of United States Patent Nos. 8,082,293 and 8,086,662

Dear Google Inc.,
I write on behalf of our client Eolas Technologies Incorporated, who has an exclusive
license to United States Patent Nos. 8,082,293 and 8,086,662 ("the '293 and '662 Patents"). The
'293 and '662 Patents are entitled "Distributed hypermedia method and system for automatically
invoking external application providing interaction and display of embedded objects within a
hypermedia document" and were issued on December 20, 2011 and December 27, 2011,
respectively. Copies of the '293 and '662 Patents are enclosed for your convenience.
We are making you aware of the '293 and '662 Patents because we believe that by
making, using, selling, offering to sell, and/or importing in or into the United States: (i) web
pages and content to be interactively presented in browsers, including, without limitation, the
web pages and content accessible via www.google.com and maintained on servers located in
and/or accessible from the United States under the control of Google; (ii) software, including,
without limitation, browser software and software that allows content to be interactively
presented in and/or served to browsers, including, without limitation, Chrome for Windows and
Chrome for the Mac; and/or (iii) computer equipment, including, without limitation, computer
equipment that stores, serves, and/or runs any of the foregoing that Google directly infringes the
'293 and '662 Patents. In addition, we believe that Google indirectly infringes one or more
claims of the '293 and '662 Patents by active inducement under 35 U. S.C. § 27 1(b) by inducing
and continuing to induce users of the web pages, software, and computer equipment identified
above to directly infringe one or more claims of the '293 and '662 Patents. We believe Google
indirectly infringes one or more claims of the '293 and '662 Patents by contributory infringement
under 35 U.S.C. § 271(c) by providing the web pages, software, and computer equipment
identified above to users of said web pages, software, and computer equipment.
Please provide us with assurance that you will immediately cease and desist from
engaging in the foregoing acts that constitute infringement of the '293 and '662 Patents.
McKool Smith
Austin

I Dallas I Houston I

McKool 947471vl

A Professional Corporation -Attorneys
Los Angeles I Marshall I New York I Silicon Valley

I Washington, DC

December 19, 2013
Page 2

Best regards,

John B. Campbell
JBC
Enclosures
cc: Doug Lumish
Latham & Watkins
140 Scott Drive
Menlo Park, CA 94025

McKool 947471v I

MC~oo SMIH

PROFESSIONAL CORPORATION - ATI-ORNEYS
300 W. 6iii STRI~ET, 17TH F,.on

Austin, Texas 78701-3232

CSC
701 Brazos Street, Suite 1050

Google Inc.
c/o Corporation Service Company d/b/a

?000 1670 0011 5380 000.3

*0$08.172

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