AGENCE FRANCE PRESSE v. GOOGLE INC.

Filing 45

STATUS REPORT by GOOGLE INC.. (Attachments: # 1 Exhibit Exhibit A# 2 Exhibit Exhibit B# 3 Exhibit Exhibit C# 4 Exhibit Exhibit D)(Kirby, Thomas)

AGENCE FRANCE PRESSE v. GOOGLE INC.

Doc. 45 Att. 2

Case 1:05-cv-00546-GK

Document 45-3

Filed 07/14/2006

Page 1 of 3

From: Kaufman, Joshua [mailto:[e-mail]] Sent: Friday, April 14, 2006 1:40 PM To: Bain, Scott Cc: Bloch, Axelle; Tarot, Gilles; Scherer, Eric Subject: RE: Sample dates Scott, The additional dates are acceptable. Thank you for your effort. Joshua

Joshua Kaufman, Esq.
"Counsel to the Creative & Innovative" TM -------------------------------------------------------Chair, Copyright & Licensing Practices

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Dockets.Justia.com

Case 1:05-cv-00546-GK

Document 45-3

Filed 07/14/2006

Page 2 of 3

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-----Original Message----From: Bain, Scott [mailto:[e-mail]] Sent: Thursday, April 13, 2006 2:17 PM To: Kaufman, Joshua Cc: Kirby, Thomas; Joseph, Bruce Subject: Sample dates

Dear Josh: As you recall, we agreed to replace the random sample dates for which Google had no html files (the 10/15/04 to 2/6/05 dates), mainly by shifting those dates back a year and adding some additional sample dates based on our birthdays. We have done this, and Google has checked its data for these new dates. Google does have html files (in the same form as the ones already produced to you, i.e., with thumbnail information as previously described, but not the thumbnails themselves) for all but three of these dates. The three that are missing all were in October 2003, when apparently there was little or no data saved. To summarize, below is the list of sample dates that result from the methods we discussed. We have either provided, or will provide following your acknowledgement, the html files reflecting Google News (without thumbnails) for each hour on each of these dates, in English and French. Please confirm whether or not these dates are acceptable for the purposes outlined in the parties' January 23, 2006 Stipulation. Note that the total now reflects 16 sample dates instead of 14. I take it from our prior conversations that you prefer the higher number. Thank you. Scott

Original Sample Dates, already produced: 8/12/03 9/25/03 11/17/03 (only French exists) 11/28/03 1/7/04 2/7/04 2/15/04 3/9/04 Additional/Revised Sample Dates, to be produced; 11/10/03 (i.e., the original sample date of 11/17/03 minus one week, because 11/17/02 is out of the date range) 1/6/04 (original 1/6/05 minus one year) 1/12/04 (original 1/12/04 minus one year) 1/29/04 (HR birthday)

Case 1:05-cv-00546-GK

Document 45-3

Filed 07/14/2006

Page 3 of 3

2/6/04 (original 2/6/05 minus one year) 4/12/04 (SB birthday) 7/7/04 (BJ birthday) 7/25/04 (TK birthday)

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