Personalized User Model LLP v. Google Inc.

Filing 223

REPLY BRIEF IN SUPPORT OF MOTION FOR LEAVE TO FILE MOTION FOR SUMMARY JUDGMENT re DI 196 SEALED MOTION for Leave to File [DEFENDANT AND COUNTERCLAIMANT GOOGLE INC.'S MOTION FOR LEAVE TO FILE ITS MOTION FOR SUMMARY JUDGMENT ON ITS BREACH OF CONTRACT COUNTERCLAIM, ITS DECLARATION OF OWNERSHIP COUNTERCLAIM, AND ITS AFFIRMATIVE DEFEN SE OF LACK OF STANDING (Exs. A-C)] filed by Google Inc.. (Attachments: # 1 Exhibit 1-7)(Moore, David)

Personalized User Model LLP v. Google Inc.

Doc. 223 Att. 1

EXHIBIT 1

Dockets.Justia.com

From: Sent: To: Cc: Subject: Gene-

Bennett, Jennifer D. [[e-mail]] Tuesday, February 01, 2011 7:47 PM Eugene Novikov; Friedman, Marc S.; Nelson, Mark C.; [e-mail]; [e-mail] Google-PUM; [e-mail]; [e-mail] Re: PUM v. Google - deposition dates

You are correct that PUM will not be available on the 7th to take the SRI deposition. Please provide alternate dates with the witness' availability. I will get back to you regarding Jeh on the 8th, however, it is also unlikely PUM is available. Please provide alternate dates when he is back in the country. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

From: Eugene Novikov <[e-mail]> To: Bennett, Jennifer D.; Friedman, Marc S.; Nelson, Mark C.; [e-mail] <[e-mail]>; [e-mail] <[e-mail]> Cc: Google-PUM <[e-mail]>; [e-mail] <[e-mail]>; [e-mail] <[e-mail]> Sent: Tue Feb 01 20:15:46 2011 Subject: PUM v. Google - deposition dates

Jennifer, on the call we offered the afternoon of February 7 for the 30(b)(6) deposition regarding SRI. As we have not heard from you we assume Plaintiff is not interested in that date. If we are wrong, please let us know immediately. Please note that the witness's availability after February 7 is limited and we may not be able to get you another date in the coming weeks. Additionally, Glen Jeh is available to be deposed on February 8, and will be out of the country for several weeks thereafter. Please let us know if Plaintiff will take his deposition on February 8.
Eugene Novikov Associate Quinn Emanuel Urquhart & Sullivan, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 415.875.6308 Direct 415.875.6600 Main Office Number

415.875.6700 FAX [e-mail] www.quinnemanuel.com

EXHIBIT 2

1

emanuel trial lawyers I San trancisco

50 California Screen , 22nd Fl oor, San Francisco , California 94111 1 T1a. 4.15-875-66oo FAX [phone]

WRITER'S DIRECT DIAL No. [phone] WRITER'S INTERNET ADDRESS [e-mail]

January 12, 2011

VIA EMAIL AND F'EDEX

Jennifer Bennett SNR Denton 1530 Page Mill Road Suite 200 Palo Alto, CA 94304-1125 Re: Personalized User Model LLP v. Google Inc., C.A. No. 09-00525-LPS

Dear Jennifer: Enclosed please find a CD of documents produced by third party SRI International in response to Google ' s subpoena.

Very truly yours, Isl Eugene Novikov Enclosures EN/dq

puinn emanuel urnuhart & suliiuan, up
LOS ANGELES 1865 Souffi Figueroa Street, loth Floor, Los Angeles, California 90017 1 TEL [phone] Fax [phone] NEW YORK 151 Madison Avenue, 22nd Floor, New York, New Yolk roolo I TEL [phone] FAX [phone]

SILICON VALLEY 1555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065 I TEr. 650-8oi-5000 FAX [phone] CHICAGO 1500 'W, Madison Street, Suite 1450, Chicago, Illinois 6o661 I TEL [phone] FAX [phone] LONDON' ^ 16 Old Bailey, London EC4M 7EG, United Kingdom TEL +44 (o) 20 7653-1000 FAX [phone]oo TOKYO ^ Akasaka Twin Towcr Main Bldg., 6th Floor, 17-22 Akasaka z-Chome, eMinaro-lot, Tokyo 107-0052, Japan I TEL [phone] FAX 41 (o) 3 5561-1712 MANNHEIM I EfzhergerstrafAe 5, 68165 Mannheim, Germany I TEL +49 (o) 621 43298-6ooo FAX +49 (o) 621 43298-610o

EXHIBIT 3

quinn emanuel trial lawyers | san francisco
50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL: [phone] FAX: [phone]

WRITER'S DIRECT DIAL NO. [phone] WRITER'S INTERNET ADDRESS [e-mail]

January 19, 2011 VIA EMAIL Jennifer Bennett SNR Denton LLP 1530 Page Mill Road Suite 200 Palo Alto, CA 94304-1125 Marc Friedman Mark C. Nelson SNR Denton LLP 1221 Avenue of the Americas New York, NY 10020-1089 Re: Personalized User Model LLP v. Google Inc., C.A. No. 09-00525-JJF

Dear Counsel: As indicated in the agreement being transmitted with this letter, Google has acquired SRI International's ownership rights in the patents-in-suit, as well as U.S. Patent 7,320,031. Google seeks to amend its Answer to bring a counterclaim for a declaratory judgment against Personalized User Model LLP, a claim for breach of contract against Yochai Konig, and any other claims that may be necessary and appropriate to assert and give full effect to Google's ownership rights in these patents. Please let us know by Friday if Plaintiff will consent to Google amending its Answer to assert these claims. As you represent Mr. Konig, and as he is a representative of PUM as indicated at the claim construction hearing, please also let us know by Friday if Mr. Konig will consent to
quinn emanuel urquhart & sullivan, llp
LOS ANGELES | 865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL [phone] FAX [phone] NEW YORK | 51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL [phone] FAX [phone] SILICON VALLEY | 555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL [phone] FAX [phone] CHICAGO | 500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 | TEL [phone] FAX [phone] LONDON | 16 Old Bailey, London EC4M 7EG, United Kingdom | TEL [phone] FAX [phone] TOKYO | NBF Hibiya Bldg., 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL [phone] FAX [phone] MANNHEIM | Erzbergerstraße 5, 68165 Mannheim, Germany | TEL [phone] FAX [phone]

being subject to personal jurisdiction in Delaware for purposes of this action. If Mr. Konig will not so consent, Google will move to dismiss for failure to join an indispensable party, and/or file an action against Mr. Konig in California and move to stay this case. Please let me know if you have any questions.

Sincerely, /s/ Eugene Novikov

01980.51645/3921631.1

2

EXHIBIT 4

From: Sent: To: Cc: Subject:

Andrea P Roberts Thursday, January 27, 2011 6:13 PM Andrea P Roberts; Bennett, Jennifer D. Google-PUM; Horwitz, Richard L.; Moore, David E. RE: PUM v. Google

Jennifer, As a follow up, I wanted to flag for you that we also added a laches defense. Thanks, Andrea
From: Andrea P Roberts Sent: Thursday, January 27, 2011 5:45 PM To: Bennett, Jennifer D. Cc: Google-PUM; Horwitz, Richard L.; Moore, David E. Subject: RE: PUM v. Google

Jennifer, Attached is a draft of the amended answer for your review. There are a few cite holes to be filled in, but that should not affect your review. Please promptly let us know whether PUM will consent to the filing of the attached. Thanks, Andrea
Andrea Pallios Roberts Quinn Emanuel Urquhart & Sullivan, LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, CA 94065 650-801-5023 Direct 650.801.5000 Main Office Number 650.801.5100 FAX [e-mail] www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.

From: Bennett, Jennifer D. [mailto:[e-mail]] Sent: Thursday, January 20, 2011 7:28 PM To: Eugene Novikov Cc: Google-PUM Subject: PUM v. Google Gene-

Please see the attached correspondence. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

EXHIBIT 5

From: Sent: To: Cc: Subject:

Andrea P Roberts Thursday, February 03, 2011 5:55 PM Bennett, Jennifer D. Google-PUM; [e-mail]; Moore, David E. PUM v. Google

Jennifer, I write regarding paragraph 6 of the September 29, 2010 Stipulated Amended Scheduling Order, which provides that no case dispositive motion may be filed early without leave of Court. Please let us know whether PUM and Mr. Konig will stipulate to Google filing a motion for summary judgment on patent ownership and standing issues prior to the date set forth in paragraph 6 for dispositive motions. As our amended pleading makes clear, there is no genuine issue of material fact as to the threshold issues of ownership and standing, making these issues appropriate for early resolution on summary judgment. Please let us know by Monday whether PUM and Mr. Konig agree so that we know whether to move forward with this motion. Thanks, Andrea

Andrea Pallios Roberts Quinn Emanuel Urquhart & Sullivan, LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, CA 94065 650-801-5023 Direct 650.801.5000 Main Office Number 650.801.5100 FAX [e-mail] www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.

EXHIBIT 6

From: Sent: To: Cc: Subject:

Bennett, Jennifer D. [[e-mail]] Wednesday, February 23, 2011 9:55 AM David Perlson [e-mail]; [e-mail]; Google-PUM RE: Activity in Case 1:09-cv-00525-LPS Personalized User Model LLP v. Google Inc. Motion for Leave to File

David, In answer to your email, the details supporting our position will be clearly set forth in our answering papers. Also, we will not consent to an abbreviated briefing schedule but we will endeavor to file our opposing brief and supporting papers as soon as possible. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

From: David Perlson [mailto:[e-mail]] Sent: Tuesday, February 22, 2011 3:54 PM To: Bennett, Jennifer D. Cc: Nelson, Mark C.; [e-mail]; [e-mail]; Google-PUM Subject: RE: Activity in Case 1:09-cv-00525-LPS Personalized User Model LLP v. Google Inc. Motion for Leave to File

Jennifer, Can you clarify why you believe the summary judgment motion is "premature," other than that is before the schedule set forth in the Case Management Order. Further, even if PUM persists on opposing Google's motion for leave, will PUM agree to expedite briefing on the issue? As you can imagine, Google would like to reach resolution of this issue as soon as possible and it seems there be no reason why PUM should not be able to oppose our brief motion for leave on short order. Thanks, David
From: Bennett, Jennifer D. [mailto:[e-mail]] Sent: Tuesday, February 22, 2011 3:44 PM To: David Perlson

Cc: Nelson, Mark C.; [e-mail]; [e-mail]; Google-PUM Subject: RE: Activity in Case 1:09-cv-00525-LPS Personalized User Model LLP v. Google Inc. Motion for Leave to File David, To be clear, PUM's position is that your Motion for Summary Judgment is premature (and unfounded) and that such a dispositive motion should be made only in accordance with the schedule set forth in the Case Management Order. As a result, we will oppose your request for leave and will be submitting opposing papers. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

From: David Perlson [mailto:[e-mail]] Sent: Tuesday, February 22, 2011 11:43 AM To: Bennett, Jennifer D. Cc: Nelson, Mark C.; [e-mail]; [e-mail]; Google-PUM Subject: FW: Activity in Case 1:09-cv-00525-LPS Personalized User Model LLP v. Google Inc. Motion for Leave to File

Jennifer, given today's hearing, I wanted to follow up on Google's motion for leave to determine whether it remains PUM's position that Google's Motion for Summary Judgment should not be briefed on the merits at this time. While PUM may oppose the relief sought in Google's Motion for Summary Judgment, that should not preclude it from briefed on the merits now. Please let us know. Thanks, David
From: [e-mail] [mailto:[e-mail]] Sent: Monday, February 21, 2011 3:29 PM To: [e-mail] Subject: Activity in Case 1:09-cv-00525-LPS Personalized User Model LLP v. Google Inc. Motion for Leave to File

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.

U.S. District Court District of Delaware Notice of Electronic Filing The following transaction was entered by Moore, David on 2/21/2011 at 6:29 PM EST and filed on 2/21/2011 Personalized User Model LLP v. Google Inc. Case Name: 1:09-cv-00525-LPS Case Number: Google Inc. Filer: Document Number: 196 Docket Text: SEALED MOTION for Leave to File [DEFENDANT AND COUNTERCLAIMANT GOOGLE INC.'S MOTION FOR LEAVE TO FILE ITS MOTION FOR SUMMARY JUDGMENT ON ITS BREACH OF CONTRACT COUNTERCLAIM, ITS DECLARATION OF OWNERSHIP COUNTERCLAIM, AND ITS AFFIRMATIVE DEFENSE OF LACK OF STANDING (Exs. A-C)] - filed by Google Inc.. (Moore, David) 1:09-cv-00525-LPS Notice has been electronically mailed to: Andrea P. Roberts Brian C. Howard David A. Perlson [e-mail], [e-mail] [e-mail], [e-mail] [e-mail], [e-mail]

David Ellis Moore [e-mail], [e-mail], [e-mail] Eugene Novikov [e-mail] [e-mail] [e-mail]

Jeremy Alexander Tigan Karen Jacobs Louden

Richard L. Horwitz [e-mail], [e-mail], [e-mail], [e-mail], [e-mail] 1:09-cv-00525-LPS Notice has been delivered by other means to: Brian C. Cannon The following document(s) are associated with this transaction: Document description:Main Document Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1079733196 [Date=2/21/2011] [FileNumber=1147690-0 ] [9b72bb94a409ba4ba0544c5575d9553e4b3ebed30914cf154d7141de8ef9aaac70f

764a4345c1b8c3b7359dd719ed14bd25dfe9bd96d09d0a8357b1c71cd1074]]

EXHIBIT 7

From: Sent: To: Cc: Subject: Andrea,

Bennett, Jennifer D. [[e-mail]] Tuesday, February 01, 2011 12:53 PM Andrea P Roberts; David Perlson Google-PUM; [e-mail]; [e-mail] PUM v. Google: Final Amended Answer

I write in response to Google's request for consent to file an amended answer and counterclaims. PUM will not oppose Google's motion for leave to file an amended answer and counterclaims, subject to PUM's reservation of rights to oppose on the merits (including any motion to dismiss), provided (1) Google agrees to extend the period of time PUM has to answer or otherwise respond to such counterclaims from 20 days to 35 days; (2) in addition to the 35 interrogatories and 15 depositions allowed by the Scheduling Order, Google agrees PUM can serve an additional 5 interrogatories and may notice an additional 3 depositions related to the issues raised in Google's answer and counterclaims, and if necessary, Google will not oppose any request by PUM to extend the current fact discovery deadline to conduct discovery relating to these issues; and (3) Google will not initiate a separate lawsuit in California. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

From: Andrea P Roberts [mailto:[e-mail]] Sent: Monday, January 31, 2011 4:08 PM To: David Perlson; Bennett, Jennifer D. Cc: Google-PUM; [e-mail]; [e-mail] Subject: RE: PUM v. Google: Final Amended Answer

Jennifer, Please see the attached answer with citations filled in. Also attached are Exhibits AD. Due to the volume, the remainder of the exhibits will follow by separate email. Regards,
Andrea Pallios Roberts Quinn Emanuel Urquhart & Sullivan, LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, CA 94065 650-801-5023 Direct

650.801.5000 Main Office Number 650.801.5100 FAX [e-mail] www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.

From: David Perlson Sent: Monday, January 31, 2011 10:35 AM To: Bennett, Jennifer D.; Andrea P Roberts Cc: Google-PUM; [e-mail]; [e-mail] Subject: RE: PUM v. Google: Final Amended Answer

Jennifer, we will provide the complaint with the citations filled in today. As for laches, the reason it is being added now is the apparent lack of witness memory of relevant events and seemingly missing and/or unattainable documents that form the basis for the defense have come to light based on recent depositions and correspondence.
From: Bennett, Jennifer D. [mailto:[e-mail]] Sent: Monday, January 31, 2011 10:27 AM To: Andrea P Roberts; David Perlson Cc: Google-PUM; [e-mail]; [e-mail] Subject: PUM v. Google: Final Amended Answer David and Andrea, P.U.M. will need to see the "final" proposed amended complaint before P.U.M. can provide its consent. Also, please provide Google's justification for seeking leave to amend to add a laches defense this late in discovery, as the two issues are completely unrelated. Thanks,

From: Andrea P Roberts [mailto:[e-mail]] Sent: Friday, January 28, 2011 1:27 PM To: Bennett, Jennifer D. Cc: Google-PUM; [e-mail]; [e-mail] Subject: RE: PUM v. Google

Jennifer, Please see the attached redline comparison. Thanks, Andrea
Andrea Pallios Roberts Quinn Emanuel Urquhart & Sullivan, LLP 555 Twin Dolphin Drive, 5th Floor

Redwood Shores, CA 94065 650-801-5023 Direct 650.801.5000 Main Office Number 650.801.5100 FAX [e-mail] www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.

From: Bennett, Jennifer D. [mailto:[e-mail]] Sent: Friday, January 28, 2011 10:18 AM To: Andrea P Roberts Cc: Google-PUM; [e-mail]; [e-mail] Subject: Re: PUM v. Google Andrea, Can you please send me a redline version showing the differences between the original and amended answers? Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.

From: Andrea P Roberts <[e-mail]> To: Andrea P Roberts <[e-mail]>; Bennett, Jennifer D. Cc: Google-PUM <[e-mail]>; Horwitz, Richard L. <[e-mail]>; Moore, David E. <[e-mail]> Sent: Thu Jan 27 20:12:40 2011 Subject: RE: PUM v. Google

Jennifer, As a follow up, I wanted to flag for you that we also added a laches defense. Thanks, Andrea
From: Andrea P Roberts Sent: Thursday, January 27, 2011 5:45 PM To: Bennett, Jennifer D.

Cc: Google-PUM; Horwitz, Richard L.; Moore, David E. Subject: RE: PUM v. Google

Jennifer, Attached is a draft of the amended answer for your review. There are a few cite holes to be filled in, but that should not affect your review. Please promptly let us know whether PUM will consent to the filing of the attached. Thanks, Andrea
Andrea Pallios Roberts Quinn Emanuel Urquhart & Sullivan, LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, CA 94065 650-801-5023 Direct 650.801.5000 Main Office Number 650.801.5100 FAX [e-mail] www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.

From: Bennett, Jennifer D. [mailto:[e-mail]] Sent: Thursday, January 20, 2011 7:28 PM To: Eugene Novikov Cc: Google-PUM Subject: PUM v. Google GenePlease see the attached correspondence. Thanks,

Jennifer D. Bennett Managing Associate SNR Denton US LLP D [phone] [e-mail] snrdenton.com

SNR Denton is the collective trade name for an international legal practice. This email may be confidential and protected by legal privilege. If you are not the intended recipient, disclosure, copying, distribution and use are prohibited; please notify us immediately and delete this copy from your system. Please see snrdenton.com for Legal Notices, including IRS Circular 230 Notice.