Google Inc. v. Rockstar Consortium US LP et al

Filing 31

Declaration of Kristin J. Madigan in Support of 30 Google Inc.'s Opposition to Defendants' Motion to Dismiss or Transfer filed byGoogle Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19 - Part 1 of 3, # 20 Exhibit 19 - Part 2 of 3, # 21 Exhibit 19 - Part 3 of 3, # 22 Exhibit 20, # 23 Exhibit 21 - Part 1 of 2, # 24 Exhibit 21 - Part 2 of 2, # 25 Exhibit 22, # 26 Exhibit 23, # 27 Exhibit 24, # 28 Exhibit 25, # 29 Exhibit 26, # 30 Exhibit 27, # 31 Exhibit 28, # 32 Exhibit 29, # 33 Exhibit 30, # 34 Exhibit 31, # 35 Exhibit 32, # 36 Exhibit 33, # 37 Exhibit 34, # 38 Exhibit 35, # 39 Exhibit 36, # 40 Exhibit 37)(Related document(s) 30 ) (Warren, Matthew) (Filed on 2/7/2014) Modified on 2/10/2014 (cpS, COURT STAFF).

EXHIBIT 17

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EXHIBIT Q

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Richard L. Brophy
From:
Sent:
To:
Subject:

Abramov, Kirill Y <[e-mail]>
Thursday, December 12, 2013 2:46 PM
John R. Labbe
FW: Patent Discussion and Second Notice of Infringement

Second notice.
From: Mark Wilson [mailto:[e-mail]]
Sent: Friday, November 08, 2013 11:47 AM
To: Abramov, Kirill Y; Long, David
Cc: Chad Hilyard; Alfi Guindi; John Garland
Subject: Patent Discussion and Second Notice of Infringement

To: Kirill Abramov, VP and Senior Council
Cc: David Long, Kelley Drye LLP
RE: Patent Infringement – Second Notice
Thank you again for taking time to meet with Chad, Alfi and me this morning. Following up on our discussion,
below please find 3 additional Rockstar patents that are used with the indicated Charter services and products:

Patent

5,583,862
Callon
6,130,893
Whittaker
6,321,253
McKeen

IP VPNs PacketRFC 4364 Cable

Title

Method And Apparatus For Routing For
Virtual Networks
Method And Apparatus For Multiplexing
Telephone Lines Over A Common Access
Network
Systems and Methods for Simultaneous
Network Management Of Voice and Data
Signals

Impacted Services



Charter Business Level 3 VPN Servi
(BGP/MPLS)


Charter Phone Service
Charter supplied MTA’s



Charter Phone Services
Charter Internet Services
(PacketCable 1.5 and E-MTAs)

We believe that Charter Communications has affirmative responsibility to ensure that it has
secured all necessary patent rights to sell its services and products that are infringing Rockstar's
intellectual property, including those patents listed above and in the March 13, 2012 letter to Mr.
Rutledge.

1

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Please note that the 9 patents on notice to Charter Communications at this time is a sample.
Rockstar cannot assure Charter that all patents of interest have been identified due to the size
and changing composition of our portfolio.
As we reiterated today, in order for the negotiations to continue the parties have to enter into an
NDA. Charter's repeated refusal to enter into an NDA has prevented both parties from being able
to share the information necessary to negotiate and enter into a licensing agreement. We are
pleased that Charter now appears willing to enter into an NDA; however, because Charter has
now had our proposed draft for more than six months, we ask that you please return your
comments in short order.
Regards,

This Communication is Confidential and is being sent in accordance with the terms set out at

2

http://ip-rockstar.iv-design.ca/email_disclaimer/

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