Personalized User Model LLP v. Google Inc.

Filing 514

REDACTED VERSION of 513 Letter to The Honorable Leonard P. Stark from Karen Jacobs Louden regarding Issues Raised at May 8, 2013 Hearing by Personalized User Model LLP. (Louden, Karen)

MORRIS, NICHOLS, ARSHT

&

TUNNELL

LLP

1201 N ORTH M ARKE T S T RE E T
P.O. B OX 1347
W ILMINGT ON , D E LAW ARE 19899-1347
[phone]
[phone] FAX
KAREN JACOBS LOUDEN
[phone]
[phone] FAX
[e-mail]

REDACTED - PUBLIC VERSION
Original Filing Date: May 10, 2013
Redacted Filing Date: May 16, 2013
BY E-FILING
The Honorable Leonard P. Stark
United States District Court
for the District of Delaware
844 North King Street
Wilmington, DE 19801
Re:

Personalized User Model, L.L.P. v. Google, Inc.
C.A. No. 09-525 (LPS)

Dear Judge Stark:
Pursuant to the Court’s direction at the May 8, 2013 Markman hearing, plaintiff
Personalized User Model LLC (“PUM”) hereby responds to Google’s letter of May 9, 2013
concerning which of Google’s arguments on its motion for summary judgment on noninfringement relate to which claims and products. In its letter, Google also added citations to the
briefing and a slide presentation, to which PUM responds. In light of the voluminous record,
PUM also would be pleased to provide the Court with citations to its expert reports for these
various arguments if the Court would find it helpful.
Respectfully,

/s/ Karen Jacobs Louden
Karen Jacobs Louden (#2881)
KJL/lm
Enclosure
cc:
Clerk of the Court (by hand)
All Counsel of Record (by e-mail)
7202065

PUM’S REBUTTAL CHART
REDACTED IN ITS ENTIRETY