Personalized User Model LLP v. Google Inc.

Filing 684

REDACTED VERSION of 633 Letter to The Honorable Leonard P. Stark from Karen Jacobs regarding parties' submission of designated deposition testimony by Personalized User Model LLP. (Tigan, Jeremy)

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

Original Filing Date: March 9, 2014
Redacted Filing Date: April 14, 2014

[phone]
[e-mail]

REDACTED - PUBLIC VERSION
The Honorable Leonard P. Stark
United States District Court
for the District of Delaware
844 North King Street
Wilmington, DE 19801
Re:

VIA ELECTRONIC FILING

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

Dear Judge Stark:
As the Court directed during the February 26, 2014 Pretrial Conference, the parties
hereby submit the designated deposition testimony PUM intends to play for the jury on Tuesday
March 11, 2014, time permitting. The parties held a meet and confer on March 8, however the
objections indicated on the attached Exhibit 1 remain.
Accompanying this letter are highlighted deposition transcripts of the testimony still
subject to objections. PUM’s designations are highlighted in yellow and Google’s counter
designations are highlighted in pink. The objected to areas are marked with a red box. The
parties have also attached their respective objections and responses along with the transcripts.
Respectfully,

/s/ Karen Jacobs
Karen Jacobs (#2881)
KJ/lm
cc:
Clerk of the Court (by hand)
All Counsel of Record (by e-mail)
8074569.1

EXHIBIT 1

REDACTED
IN ITS
ENTIRETY