AGENCE FRANCE PRESSE v. GOOGLE INC.

Filing 45

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

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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:JJKaufman@Venable.com] 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 VENABLE LLP 575 7th Street, NW Washington, DC 20004 Voice 202.344.8538 Fax 202.344.8300 jjkaufman@venable.com www.venable.com CONFIDENTIAL MATERIAL: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorneyclient privilege and/or may be attorney work product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (202) 344-8538. Dockets.Justia.com Case 1:05-cv-00546-GK Document 45-3 Filed 07/14/2006 Page 2 of 3 Note to clients: This e-mail may contain attorney-client privileged communications, and the privilege may be lost if you forward or disclose to third parties. Please exercise due care. When in doubt, consult your attorney. -----Original Message----From: Bain, Scott [mailto:SBain@wrf.com] 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) _____________________ Scott E. Bain Wiley Rein & Fielding LLP 1776 K St. NW Washington, DC 20006 (202) 719-7485 sbain@wrf.com <mailto:sbain@wrf.com> www.wrf.com NOTICE: This message (including any attachments) from Wiley Rein & Fielding LLP may constitute an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. 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