Xerox Corporation v. Google Inc. et al

Filing 163

CLAIM CONSTRUCTION ANSWERING BRIEF re 141 Claim Construction Opening Brief filed by Xerox Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11)(Day, John)

RE: Xerox v. Google, et al. - Claim Terms and Constructions
David Perlson <[e-mail]> to:

Scott
Leslie

03/10/2011 07:26 PM

"'[e-mail]'", "'[e-mail]'"
,
"'[e-mail]'" , Andrea P Roberts,
"'[e-mail]'", "'Fenwick, Anthony I.'", "'Lisson,
David'"
, "'Moore, David E.'"
,
, Google-Xerox,
Cc: "'[e-mail]'"
"'[e-mail]'", "'[e-mail]'"
,
"'Brodsky, Jeremy'", "'[e-mail]'",
"'[e-mail]'", "'[e-mail]'" , 'Richard
Stark'
History:

This message has been forwarded.

Scott, responses below.
One question I have, will Xerox be sticking to its construction of “organized classification of
document content” with the “may be” language in it? Thanks

David

From: Scott Leslie [mailto:[e-mail]]
Sent: Thursday, March 10, 2011 3:38 PM
To: David Perlson
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.';
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
David Thank you for promptly getting us Defendants' revised chart.
First, regarding the limitation in Claim 5 that "the organized classification of document content is defined
using a hierarchical organization", we cannot tell from Defendants' proposed construction whether, in
order to be hierarchical, every single category in the organized classification must be a parent or a child
of another category. We do not believe that a hierarchical organization precludes the presence of some
categories that are neither parents nor children of other categories, and that is simply what our proposed
construction reflects. Please let us know whether you think we have a substantive disagreement
concerning this construction.

‐‐We do not think so.

Second, we notice that Defendants have retained their construction for the "characteristic vocabulary"
limitation of Claim 10 (namely, "one or more words or phrases that describe the category of information
corresponding to the class"). We are still unsure whether there is a dispute between the parties
concerning this claim term because we are unsure what "category of information" Defendants are

referring to in their proposed construction. Are you referring to the "category of information" in the
information retrieval system, as referenced in steps (a) and (d) of Claim 1?

‐‐Yes
Finally, regarding the "defining an organized classification of document content" limitation, we want to be
absolutely sure that we are in substantive agreement. Defendants have proposed "setting an organized
classification of document content", i.e., setting the particular organized classification of document
content that is to be used in performing the steps of the claimed method. We thought all parties agreed
that, for purposes of whether this construction is satisfied, it is immaterial whether the particular organized
classification of document set for use in the claimed method is (1) created by the performer of the
method, (2) selected from existing classifications by the performer of the method or (3) modified by the
performer of the method from an existing classification. Is that correct, or do Defendants have a different
understanding?

‐‐Correct

Thank you.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
Scott Leslie <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, Google-Xerox <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Brodsky, Jeremy'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, 'Richard Stark'
<[e-mail]>
Date:
Subject:

03/10/2011 03:26 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

Scott,
Attached is a revised chart.
We have moved the order of steps to be a disputed term.
Also, for “organized classification of document content,” we have included the following
construction “the organized classification of document content is defined using
categories that are “parents” or “children” of other categories.” This is the construction
that you had proposed on the call and then emailed to us. We cannot agree to your
revised construction of “the categories in the organized classification of document
content may be “parents” or “children” of other categories.” In particular, the “may be”
language renders what follows an essentially meaningless addition. Please advise
promptly if you will agree to what you previously proposed.
We confirm as you request regarding “memory.”
As to your confirmation regarding the “defining an organized classification of document
content" limitation, we will confirm as follows: Defendants will not argue that this
construction ("setting an organized classification of document content") of this limitation
("defining an organized classification of document content") distinguishes among
classifications on the basis of whether they were (1) created by the performer of the
method, vs. (2) selected by the performer of the method, vs. (3) modified by the
performer of the method from an existing classification."
David
From: Scott Leslie [mailto:[e-mail]]
Sent: Thursday, March 10, 2011 10:46 AM
To: David Perlson
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
David I'm not sure what rhetoric you're referring to. But in any event, Xerox will consent to seek an extension
for the chart until Tuesday if Defendants will provide their edits to the chart, and the confirmation
requested in my prior email, by close of business today.
Best,

Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
Scott Leslie <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Lisson, David'" <[e-mail]>, "'Moore, David
E.'" <[e-mail]>, Eugene Novikov <[e-mail]>, "'[e-mail]'"
<[e-mail]>, Google-Xerox <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Brodsky, Jeremy'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, 'Richard Stark'
<[e-mail]>
Date:
Subject:

03/10/2011 01:30 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

Scott, I won’t respond to you rhetoric.  
Lets do an extension to Tuesday.
We will respond with our edits to your chart in the next few hours or so.
David
From: Scott Leslie [mailto:[e-mail]]
Sent: Thursday, March 10, 2011 10:28 AM
To: David Perlson; 'Fenwick, Anthony I.'
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions

David and Tony We have not received any response to my email below, and we do not even know whether Defendants
still want to request an extension for the Joint Claim Construction Chart, which is due today. If not,
please immediately provide any comments on the draft chart as well as the confirmation requested in my
email, and please let us know when we can expect to receive Defendants' intrinsic evidence citations.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

Scott Leslie/NYC/Cravath

To:
David Perlson <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Lisson, David'" <[e-mail]>, "'Moore, David
E.'" <[e-mail]>, Eugene Novikov <[e-mail]>, "'[e-mail]'"
<[e-mail]>, Google-Xerox <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Brodsky, Jeremy'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, 'Richard Stark'
<[e-mail]>
Date:
Subject:

03/09/2011 07:52 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

David and Tony Please use the joint claim chart and accompanying comparison that are attached to this email, as
opposed to the files attached to my earlier email. The files I previously sent were not the most updated
versions.
Apologies for any confusion.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)
[attachment "Joint Claim Construction Chart (Xerox rev. 3-9-11).doc" deleted by Scott
Leslie/NYC/Cravath] [attachment "Joint Claim Chart Comparison.pdf" deleted by Scott
Leslie/NYC/Cravath]

From:

Scott Leslie/NYC/Cravath

To:
David Perlson <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, Eugene Novikov
<[e-mail]>, "'[e-mail]'" <[e-mail]>, Google-Xerox
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'Brodsky, Jeremy'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, 'Richard Stark' <[e-mail]>
Date:
Subject:

03/09/2011 07:18 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

David and Tony As discussed on our call today, attached is a revised version of the joint claim construction chart and a
comparison showing changes from the version David circulated last night. Please note that, as we
indicated during the call, we have modified the first row in the "order of steps" section, which is currently
in the "Agreed Constructions" section. If Defendants do not agree with these modifications, please let us
know what language Defendants wish to use, and we will move this element into the "Disputed
Constructions" section.
As discussed during the call, Xerox agrees with Defendants' proposal that "memory" (Claim 18) does not
require construction based on Defendants' representation that they will not contend that "memory"
excludes any of the categories of memory devices (e.g., disk drives, floppy disks (or diskettes), optical
disks, magnetic tape, semiconductor memories such as RAM, ROM, PROMs, etc.) expressly enumerated
in the specification of the ’979 Patent. If Defendants do not agree with this understanding, please let us
know.
Similarly, Xerox accepts Defendants' proposed construction for "defining an organized classification of
document content" (Claims 1 and 18) given Defendants' representation that they will not argue that this
construction precludes either creating an organized classification of document content or

selecting/modifying an existing organized classification of document content in performing the claimed
method. Please confirm Defendants' agreement on this issue.
Defendants indicated on the call that they may wish to get an extension to complete their citations to
intrinsic evidence. Please let us know if that is the case and, if so, what time frame Defendants are
proposing. Otherwise, if the parties will be filing the joint claim construction chart tomorrow, we would
appreciate receiving Defendants' responses to the attached as soon as possible, and no later than
tomorrow morning.
Thank you.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)
[attachment "Joint Claim Construction Chart (Xerox rev. 3-9-11).doc" deleted by Scott
Leslie/NYC/Cravath] [attachment "Joint Claim Chart Comparison.pdf" deleted by Scott
Leslie/NYC/Cravath]

From:

David Perlson <[e-mail]>

To:
Scott Leslie <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, Eugene Novikov
<[e-mail]>, "'[e-mail]'" <[e-mail]>, Google-Xerox
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'Brodsky, Jeremy'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, 'Richard Stark' <[e-mail]>
Date:
Subject:

03/09/2011 04:00 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

866-939-8416
Part. Passcode: 518165

From: Scott Leslie [mailto:[e-mail]]
Sent: Wednesday, March 09, 2011 12:56 PM
To: David Perlson
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
David Do you have a dial-in number that we should use for the call?
Thanks.

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
Scott Leslie <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, Eugene Novikov
<[e-mail]>, "'[e-mail]'" <[e-mail]>, Google-Xerox
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'Brodsky, Jeremy'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, 'Richard Stark' <[e-mail]>
Date:
Subject:

03/09/2011 12:39 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

1 pm pacific  would work for Google.

From: Scott Leslie [mailto:[e-mail]]
Sent: Tuesday, March 08, 2011 7:42 PM
To: David Perlson
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
David A call tomorrow in the early afternoon Pacific time would work for Xerox.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
David Perlson <[e-mail]>, Scott Leslie <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, Eugene Novikov
<[e-mail]>, "'[e-mail]'" <[e-mail]>, Google-Xerox
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'Brodsky, Jeremy'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, 'Richard Stark' <[e-mail]>
Date:
Subject:

03/08/2011 10:04 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

Scott, attached is a clean version and redline from your prior document.
One thing to note, you see that for ““organized classification of document content” we have

noted to be discussed. We have been trying to come up with a compromise using your
construction, which uses ontology—a term that the jury may need help with. Perhaps if
we can discuss the claim term on a meet and confer we can reach agreement. Would
tomorrow afternoon pacific time work for Xerox?
David
From: David Perlson
Sent: Monday, March 07, 2011 5:27 PM
To: Scott Leslie
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
Thanks Scott.  We will be looking to get you a revised chart tomorrow.
David
From: Scott Leslie [mailto:[e-mail]]
Sent: Monday, March 07, 2011 1:14 PM
To: David Perlson
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]'; Andrea P Roberts;
'[e-mail]'; 'Fenwick, Anthony I.'; 'Lisson, David'; 'Moore, David E.'; Eugene Novikov;
'[e-mail]'; Google-Xerox; '[e-mail]'; '[e-mail]'; 'Brodsky,
Jeremy'; '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Richard
Stark'
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
David Regarding "memory", if there is nothing about Xerox's definition (which simply tracks the examples of
"memory" set forth in the specification) that Defendants disagree with, Xerox would agree to remove this
term from the chart.
Regarding Claim 10, an "organized classification of document content" consists of categories (i.e.,
classes). Claim 10 simply requires that each category/class be associated with a "characteristic
vocabulary." It seems to us that "vocabulary" is self-explanatory, and a "characteristic vocabulary" would,
self-evidently, be a vocabulary that is characteristic of the category. If Defendants believe this term
requires construction, please let us know what construction defendants would propose.
As you know, the parties must file the joint claim construction chart on Thursday. Defendants have now
had Xerox's draft claim chart for over 10 days, since February 24, and have raised only the two issues
addressed above. Please let us know Defendants' positions on those two issues no later than tomorrow.
With respect to all other issues, please send us Defendants' response to the February 24 chart today.

Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
'Scott Leslie' <[e-mail]>
Cc:
"'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>,
"'[e-mail]'" <[e-mail]>, Andrea P Roberts <[e-mail]>,
"'[e-mail]'" <[e-mail]>, "'Fenwick, Anthony I.'" <[e-mail]>,
"'Lisson, David'" <[e-mail]>, "'Moore, David E.'" <[e-mail]>, Eugene Novikov
<[e-mail]>, "'[e-mail]'" <[e-mail]>, Google-Xerox
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'Brodsky, Jeremy'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'"
<[e-mail]>, 'Richard Stark' <[e-mail]>
Date:
Subject:

03/06/2011 11:13 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

Scott,
As we continue to consider Xerox’s proposals we have a few questions.
Xerox has sought to construe “memory.” Our initial reaction is that this is not a term that should
need construction. Is there some reason why Xerox feels this is needed to be explained to the
jury?

Xerox did not identify “characteristic vocabulary” in claim 10 as a term for construction. Can
you explain what Xerox believes this phrase intends to convey? This term seems to be one that
would warrant a construction, but we have not yet formulated one. Perhaps Xerox’s explanation
of this term could assist in this process given the short time we have to provide constructions.
Thanks,
David
From: Scott Leslie [mailto:[e-mail]]
Sent: Thursday, February 24, 2011 1:01 PM
To: David Perlson
Cc: [e-mail]; [e-mail]; [e-mail]; Andrea P Roberts;
[e-mail]; Fenwick, Anthony I.; Lisson, David; Moore, David E.; Eugene Novikov;
[e-mail]; Google-Xerox; [e-mail]; [e-mail]; Brodsky,
Jeremy; [e-mail]; [e-mail]; [e-mail]; Richard
Stark
Subject: RE: Xerox v. Google, et al. - Claim Terms and Constructions
Counsel Attached is an updated Joint Claim Construction Chart with Xerox's additions. As you will see, we have
reformatted the document for filing and have updated various sections of the charts themselves. To the
extent we have altered anything in the charts beyond Xerox's own proposed constructions and mere
formatting, we have shaded those changes in gray.
Please let us know if you have any questions.
Best,
Scott

Scott A. Leslie
Cravath, Swaine & Moore LLP
825 Eighth Avenue
New York, NY 10019
[phone] (phone)
[phone] (fax)

From:

David Perlson <[e-mail]>

To:
Scott Leslie <[e-mail]>, Andrea P Roberts <[e-mail]>
Cc:
"[e-mail]" <[e-mail]>, "[e-mail]" <[e-mail]>,
"[e-mail]" <[e-mail]>, "[e-mail]" <[e-mail]>,
"Fenwick, Anthony I." <[e-mail]>, "Lisson, David" <[e-mail]>, "Moore, David E."
<[e-mail]>, Eugene Novikov <[e-mail]>, "[e-mail]"
<[e-mail]>, Google-Xerox <[e-mail]>, "[e-mail]"
<[e-mail]>, "[e-mail]" <[e-mail]>, "Brodsky, Jeremy"
<[e-mail]>, "[e-mail]" <[e-mail]>, "[e-mail]"

<[e-mail]>, "[e-mail]" <[e-mail]>, Richard Stark <[e-mail]>
Date:
Subject:

02/17/2011 02:10 PM
RE: Xerox v. Google, et al. - Claim Terms and Constructions

Scott, here is the chart we discussed on call yesterday.
David
[attachment "3972040_Joint Claim Construction Chart (2).doc" deleted by Scott
Leslie/NYC/Cravath]
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deleted by Scott Leslie/NYC/Cravath]
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