Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 104

Attachment 7
Declaration in Support of 102 MOTION to Compel ABWF to (1) Produce Documents, (2) Produce an Affidavit, and (3) Schedule Depositions filed byGoogle Inc., Google Inc.. (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 Exhibit M# 14 Exhibit N)(Related document(s)102) (Krishnan, Ajay) (Filed on 6/8/2006)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 104 Att. 7 Case 5:03-cv-05340-JF Document 104-8 Filed 06/08/2006 Page 1 of 3 EXHIBIT G Dockets.Justia.com Message Case 5:03-cv-05340-JF ;'i Document 104-8 Filed 06/08/2006 Page 2 of 3 Page 1 of2 Ajay Krishnan From: Plater, Caroline C. iCPlater(ÇKelleyDrye.com) Sent: Tuesday, April 18, 2006 7:44 AM To: Ajay Krishnan Cc: Klaus Hamm Subject: RE: Ajay & Klaus- i believe we will be sending out most if not all of our supplemental documents by the end of this week. lean confirm that we do not have any documents regarding the choice ofthe American Blind name. i have explained why we have no documents regarding the name choice -- and you are free to question our 30(b) of the trademarks, inso making his choice. However, I believe we have documentation regarding the selection far as this is contained in the trademark files. I will follow up on that aspect of your inquiry. . Regards, Carrie (6) witness, Steve Katzman, on why the company made this choice and did not generate any documents in . -----Original Messagemn From: Ajay Krishnan (mailto:AKrishnan(§kvn.com) Sent: Thursday, April 13, 2006 9:24 PM To: Plater, Caroline C. Cc: Klaus Hamm Subject: Dear Carrie, Thank you for your letter from April 1 0, 2006. Could i please have a date or a schedule as to when ABWF plans to produce the documents you agreed to produce? As you know, our 30(b)(6) deposition of ABWF is scheduled for May 11. We will need to have the documents well in advance of that date so that we can evaluate whether ABWF's production is satisfactory, and possibly seek more documents, prior to the deposition. Also, i wanted to clarify something: you've taken the position (both with regard to items 4 and 6 in your April 10 letter), that ABWF has no documents as to (1) how it decided to name its business or (2) hòw it trademarks. Is that correct? If this is so, could you please explain why no such selected any of its in your April 10 letter (with regard to item 4) that this is because ABWF documents exist? You suggest adopted or registered chose its name a long time ago. But some of ABWF's claimed trademarks were only relatively recently. i just want to be sure that i understand your position. One last thing -- i will be out of the office from tomorrow (April 14th) until Tuesday (April 18th). So, could you please be sure to address any correspondence about ABWF's production to both me and Klaus? He'll be handling this when I'm gone. Thanks, Ajay Ajay S. Krishnan Keker & Van Nest LLP 710 Sansome Street San Francisco, CA 94111 (415) 391-5400 6/1/2006 Message Case 5:03-cv-05340-JF ,1 Document 104-8 Filed 06/08/2006 Page 2 of2 Page 3 of 3 akrishnan(Çkvn.com This message is intended only for the use of the individual or entity to whom it is addressed. The message is confidential and may contain attorney-client information, attorney work product or other privileged hereby notified that any use or dissemination of information. If you are not the intended recipient, you are this message is strictly prohibited. If you received this message in error, please notify the sender by replying to the message. When complete, please delete the original message. Thank you. Pursuant to Treasury Regulations, any U.S. federal tax advice contained in this communication, unless otherwise stated, is not intended and canot be used for the purpose of avoiding tax-related penalties. The information contained in this E-mail message is privileged, confidential, and may be protected from disclosure; please be aware that any other use, printing, copying, disclosure or dissemination of you think that you have received this communication may be subject to legal restriction or sanction. If this E-mail message in error, please reply to the sender. This E-mail message and any attachments have been scanned for viruses and are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened. However, it is the responsibility ofthe recipient to ensure that it is virus free and no responsibility is accepted by Kelley Drye & Warren LLP for any loss or damage arising in any way from its use. 6/1/2006

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