Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 88

MOTION to Compel Production of Documents from Heartland and Baker & Daniels by Counter Claimant Forest River Inc. (Attachments: # 1 Exhibit A - Excerpt of '747 Patent, # 2 Exhibit B - Email of 3/14/05, # 3 Exhibit C - Excerpt of '841 Patent, # 4 Exhibit D - Excerpt of '650 Patent, # 5 Exhibit E - Excerpt of Taylor Dep., # 6 Exhibit F - FR Doc. Req. #9, # 7 Exhibit G - FR Doc. Req. #32, # 8 Exhibit H - Heartland Resp. to #9, # 9 Exhibit I - Heartland Resp. to #32, # 10 Exhibit J - B&D Subpoena, # 11 Exhibit K - Gallagher diary, # 12 Exhibit L - Brotherson CC, # 13 Exhibit M - Brotherson Letter, # 14 Appendix Rule 37 Certification, # 15 Supplement Supplement to Certification)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 88 Att. 1

case 3:08-cv-00490-TLS document 88-2

filed 02/01/10 page 1 of 1

Katt. Zellma
Sent: To:
From: Greg Cooper Monday, March 14, 200510:05 AM Grunden, Zellma Fwd: Re: Heartland Turning Radius Patent

SUbJect:

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Greg. I was wondering i (Braidn Brady) ha The real part of shot at is the im remolded the cap I have included B questions he has. assurance that is court over it. ho Call me when you Thanks. Scott TUttle

you could help me out with Borne of the questions my senior partner regarding our patent application. his appplication that we are concerned about and feel we have a good roved turning radius design where we cut back the frame and also esign to take advantage of that void in the frame. ian's repsonse to me with some One is, he is looking for some sort of this concept is even defensible? And if we were to have to go to much would we be looking at to defend it? an.

---------- Origi I Message -------------------.--------------From: Bbirish74@a I.com Date: Wed, 2 Mar 2005 09:35;46 EST Scott: The issue is whet er or not the patent is defensible. We need some assurances from our attorney(s) that his will be the case. For example, does Cambridge infringe che patent or? Cost to defend patent? as being applied Need more info. BB [This E-mail sea ed for viruses by Data Constructs Company]

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