Personalized User Model LLP v. Google Inc.

Filing 735

NOTICE OF CROSS APPEAL to the Federal Circuit of 724 Order . Cross Appeal filed by Personalized User Model LLP, Konig Yochai. (Tigan, Jeremy)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, L.L.P.,

)
)
)
Plaintiff,
)
)
v.
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GOOGLE, INC.,
)
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Defendant.
)
______________________________________ )
GOOGLE, INC.,
)
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Counterclaimant,
)
)
v.
)
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PERSONALIZED USER MODEL, L.L.P.
)
and YOCHAI KONIG,
)
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Counterclaim-Defendants.
)

C.A. No. 09-525 (LPS)

NOTICE OF CROSS-APPEAL
Notice is hereby given that Plaintiffs and Counterclaim-Defendants Personalized User
Model, L.L.P. and Dr. Yochai Konig (collectively, “PUM”) cross-appeal to the U.S. Court of
Appeals for the Federal Circuit from the District Court’s September 17, 2014 Order (D.I. 724) to
the extent it denied PUM’s motion for new trial (D.I. 704), and from all other adverse orders,
opinions, judgments, verdicts, decisions, and rulings in this action leading to that Order,
including but not limited to the jury verdict (D.I. 666) entered on March 20, 2014, the District
Court’s letter opinion (D.I. 677) entered on April 7, 2014, the District Court’s judgment on the
jury verdict (D.I. 689) entered on April 17, 2014, and the reasons for denying PUM’s Motion for
a New Trial that the Court stated at the September 11, 2014 hearing. PUM also appeals from the

District Court’s Claim Construction Order (D.I. 348) to the extent it adopted constructions
adverse to PUM or refused to adopt PUM’s proposed constructions.
Google Inc.’s Notice of Appeal (D.I. 725) was filed on September 17, 2014, and assigned
to U.S. Court of Appeals for the Federal Circuit docket number 2014-1841. In accordance with
Fed. R. App. P. 4(a)(1)(A), this Notice of Cross-Appeal is being filed within 30 days after entry
of the judgment appealed from (D.I. 724).
Contemporaneously with the filing of this Notice of Cross-Appeal, PUM is making
payment of $505.00, representing the $500.00 docketing fee required by 28 U.S.C. § 1913 and
Fed. R. App. P. 3(e), and the $5.00 fee for filing a notice of appeal required by 28 U.S.C. § 1917
and the local rules of this Court.

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MORRIS, NICHOLS, ARSHT & TUNNELL LLP

/s/ Jeremy A. Tigan

OF COUNSEL:
Marc S. Friedman
DENTONS US LLP
1221 Avenue of the Americas
New York, NY 10020-1089
[phone]
Mark C. Nelson
Richard D. Salgado
DENTONS US LLP
2000 McKinney Avenue, Suite 1900
Dallas, TX 75201
[phone]

_________________________________________
Karen Jacobs (#2881)
Jeremy A. Tigan (#5239)
Regina Murphy (#5648)
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899-1347
[phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Personalized User Model, L.L.P. and
Yochai Konig

Jennifer D. Bennett
DENTONS US LLP
1530 Page Mill Road, Suite 200
Palo Alto, CA 94304-1125
[phone]
October 2, 2014

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CERTIFICATE OF SERVICE
I hereby certify that on October 2, 2014, I caused the foregoing to be electronically filed
with the Clerk of the Court using CM/ECF which will send electronic notification of such filing
to all registered participants.
Additionally, I hereby certify that true and correct copies of the foregoing were caused to
be served on October 2, 2014, upon the following individuals in the manner indicated:
BY E-MAIL

BY E-MAIL

Richard L. Horwitz
David E. Moore
POTTER ANDERSON & CORROON LLP
1313 N. Market St., 6th Floor
Wilmington, DE 19801

Brian C. Cannon
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, CA 94065
Charles K. Verhoeven
David A. Perlson
Antonio R. Sistos
Andrea Pallios Roberts
Joshua Lee Sohn
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111

/s/ Jeremy A. Tigan
___________________________
Jeremy A. Tigan (#5239)