Connectu, Inc. v. Facebook, Inc. et al

Filing 92

APPENDIX/EXHIBIT re #85 #83 #89 #91 MOTION for Summary Judgment on Plaintiffs' Claims for Breach of Contract, Breach of the Covenant of Good Faith and Fair Dealing, and Promissory Estoppel by Dustin Moskovitz, Andrew McCollum, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Exhibit A and B)(Chatterjee, I.) Modified on 9/4/2007 (Nici, Richard). Modified on 9/4/2007 (Nici, Richard).

Connectu, Inc. v. Facebook, Inc. et al

Doc. 92

Case 1:07-cv-10593-DPW

Document 92

Filed 08/29/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA, Plaint iff, v. FACEBOOK, INC., MARK ZUCKERBERG, EDUARDO SAVERIN, DUSTIN MOSKOVITZ, ANDREW MCCOLLUM, and FACEBOOK, LLC, Defendants.

Civil Action No. 1:07-CV-10593-DPW

APPENDIX TO MEMORANDA OF POINTS AND AUTHORITIES IN SUPPORT OF MOTIONS TO DISMISS SUBMITTED BY ZUCKERBERG; MOSKOVITZ AND MCCOLLUM; AND FACEBOOK, INC. AND FACEBOOK, LLC; AND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT SUBMITTED BY ZUCKERBERG AND FACEBOOK, INC. AND THEFACEBOOK LLC.

OHS West:260294707.1

Dockets.Justia.com

Case 1:07-cv-10593-DPW

Document 92

Filed 08/29/2007

Page 2 of 2

To assist the Court in evaluating the Facebook Defendants' Motions to Dismiss, the Defendants (other than Eduardo Saverin) submit this Appendix to provide a roadmap to arguments presented in the motion. Attached hereto as Exhibit A is a chart entitled "HIERARCHY OF ARGUMENTS TO DISMISS CLAIMS." This chart outlines the theories asserted by Defendants for disposing of the entire First Amended Complaint, one or more claims and/or some parties. This Exhibit attempts to give a top-down approach from starting with legal issues resolving all of the claims down to specific legal issues as to particular claims. Attached hereto as Exhibit B is a separate chart detailing, by claim, the arguments proffered by Defendants for disposing of those claims.

OHS West:260294707.1