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. 11

case 3:08-cv-00490-TLS document 88-12

filed 02/01/10 page 1 of 1
LLP
._ ._

BAKER & DANIELS
__ .. _ EST. 1863 _. __ ._. __

First Bank Building, 205 W. Jefferson Blvd., Suite 250 · South Bend, Indiana 46601 Tel. [phone]· Fax [phone]
INDIANA WASHINGTON, D.C.

www.bakerdaniels.com

GERARD

T. GALLA HER

Attorney at Law Direct 574.239.1921 [e-mail]

CHINA

Mr. Ryan M. Fou tain Attorney at Law 420 Lincoln Way West Mishawaka, IN 4 544 Re: He land Recreational Vehicles LLC Fr nt End Design for Fifth Wheel Recreational Vehicles o Reference: HRV-GOOOI 973963.2

Dear Ryan: I am writ' Vehicles LLC, h trailer that woul 2006/0038379 A extremely valuabl that if Forest Ri pending applicati g to follow up on my letter of May 16, 2006. Our client, Heartland Recreational s reason to believe that Forest River is preparing to introduce a ne I fifth-wheel infringe claims of Heartland's U.S. Patent Application Public~~ion No. US when those claims issue. The technology covered by the '379 ~6blication is and Heartland will take all necessary steps to enforce its rights. I da~ assure you er introduces an infringing product Heartland will expedite prosecution of the n and seek a preliminary injunction against Forest River to preven sales of the

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I would a reciate it if you would let me know if you no longer represent Fore will direct this co espondence to Mr. Liegl. We look forward to hearing from you. Very truly yours, BAKER & DANIELS LLP

I

l River and I
I

GTG/mr cc: Mr. Brian . Brady James R. B otherson, Esq.

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