Personalized User Model LLP v. Google Inc.

Filing 549

Letter to The Honorable Leonard P. Stark from Richard L. Horwitz regarding request for dispute conference. (Horwitz, Richard)

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1313 North Market Street P.O. Box 951 Wilmington, DE 19899-0951 302 984 6000 Richard L. Horwitz Partner Attorney at Law 302 984-6027 Direct Phone 302 658-1192 Fax January 17, 2014 VIA ELECTRONIC FILING The Honorable Leonard P. Stark United States District Court 844 King Street Wilmington, DE 19801 Re: Personalized User Model, LLP v. Google Inc., C.A. No. 09-00525-LPS Dear Judge Stark: Google received PUM’s letter to the Court dated January 17, 2014 (D.I. 548) at 4:45 pm, while Google was reviewing a different draft of the letter that was supposed to be the parties’ joint submission. Google agrees that there are multiple issues for the Court to resolve: 1. Google’s request that PUM reduce the number of asserted claims and accused products, before Google is required to narrow its obviousness case. 2. PUM’s request that Google reduce the number of obviousness references earlier and beyond what Google has already committed to do by February 5. 3. When PUM is required to provide its portions of the Pretrial Order. While PUM states that its position is that it need first provide first its portions of the Pretrial Order that relate to “plaintiff’s case,” the Local Rules require PUM to provide all of its portions of the Pretrial Order first. Local Rule 16.3(c), (d)(1) ((providing “plaintiff’s” portions of the Pretrial Order due 30 days before the Pretrial Order is due, and “all other parties shall provide the plaintiff and each other party with their responses to the plaintiff’s draft order,” 14 days before the Pretrial Order is due).) To the extent that the Court decides to address these issues through a teleconference, Google requests permission to submit a letter brief in advance setting forth its positions in more detail. Respectfully, /s/ Richard L. Horwitz Richard L. Horwitz DEM/msb/1136705/34638 cc: Clerk of Court (via Hand Delivery) Counsel of Record (via Electronic Mail)

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