Personalized User Model LLP v. Google Inc.

Filing 685

REDACTED VERSION of 653 Letter to The Honorable Leonard P. Stark from Karen Jacobs regarding parties' 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
[phone]
[e-mail]

Original Filing Date: March 15, 2014
Redacted Filing Date: April 14, 2014
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 the Parties intend to play for the jury on
Monday March 17, 2014, time permitting. The parties held a meet and confer on March 15,
2014. The objections indicated on the attached Exhibits 1 & 2 remain. Exhibit 1 is PUM’s
designations and Exhibit 2 is Google’s designations.
Accompanying this letter are highlighted deposition transcripts of the testimony still
subject to objections. In Exhibit 1, PUM’s designations are highlighted in yellow and Google’s
are highlighted in pink. In Exhibit 2, PUM’s designations are highlighted in blue and Google’s
are highlighted in yellow. In both, the objected to areas are marked with a red box.
Respectfully,

/s/ Karen Jacobs
Karen Jacobs (#2881)
KJ/lm
cc:
Clerk of the Court (by hand)
All Counsel of Record (by e-mail)
8092513.1

EXHIBIT 1

REDACTED
IN ITS
ENTIRETY

EXHIBIT 2

REDACTED
IN ITS
ENTIRETY