Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 67

AFFIDAVIT of Samuel K. Lu re 66 Opposition to Motion by Google Inc. to Preclude Presentations by Fact Witness at the Technology Tutorial by Skyhook Wireless, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Lu, Samuel)

EXHIBIT 1

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From: Manning, Susan Baker [[e-mail]]
Sent: Thursday, October 13, 2011 3:43 PM
To: Manning, Susan Baker; Somait, Lina
Cc: Murphy, Catherine R.; Lu, Sam; zzm google/skyhook (ext); Mueller, Mariandrea; Schuster, Leslie
Subject: RE: Skyhook v. Google - Joint Claim Construction and Pre-Hearing Statement
Lina -Following up on the voice mail message I just left you, we object. This is inappropriate for the reasons in our
previous letter, and we had understood that this was resolved. We hope Skyhook will reconsider this course. If we
have to go to Judge Zobel, we will do so; we are confident that she will not allow a key fact witness to testify in the
guise of a tutorial.
If Skyhook insists on revising the joint statement to express its desire to have Mr. Morgan present some or all of
the tutorial, we will need to include language regarding Google's strong objection.
Susan

_________________________________
Susan Baker Manning | Bingham McCutchen LLP
2020 K Street NW, Washington, DC 20006-1806
Tel: [phone] | Fax: [phone]
[e-mail]

From: Manning, Susan Baker
Sent: Thursday, October 13, 2011 6:29 PM
To: Somait, Lina
Cc: Murphy, Catherine R.; Lu, Sam; zzm google/skyhook (ext); Mueller, Mariandrea; Schuster, Leslie
Subject: Re: Skyhook v. Google - Joint Claim Construction and Pre-Hearing Statement

Lina -- We strongly object. You are not authorized to file the joint statement with the change you have
just proposed. I will call you to discuss.
Susan
On Oct 13, 2011, at 6:16 PM, "Somait, Lina" <[e-mail]> wrote:
Catherine,
Upon further consideration, we’ve decided that Skyhook’s tutorial will be presented by Ted
Morgan and/or counsel. I will revise the joint statement to reflect this change. I will be
filing the joint statement and exhibits within the next half hour.
Regards,
Lina

From: Murphy, Catherine R. [mailto:[e-mail]]
Sent: Thursday, October 13, 2011 2:12 PM
To: Somait, Lina; Lu, Sam
Cc: zzm google/skyhook (ext)

file://C:\Documents and Settings\jmil\My Documents\RE Skyhook v. Google - Joint Clai... 10/15/2011

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Subject: Skyhook v. Google - Joint Claim Construction and Pre-Hearing Statement
Lina,
Attached please find a revised version of the parties' Joint Claim Construction and Pre-Hearing
Statement. I have also attached a redline, reflecting the changes to the document since I sent it to
you yesterday afternoon. I have also attached Google's supporting exhibits. Please let me know if
you have any questions about the document before filing.
Thanks,
Catherine
Joint Claim Construction and Pre-Hearing Statement:
Redline:
Supporting Exhibits:
Catherine R. Murphy
Associate
T 202.373.6124
F 202.373.6001
[e-mail]
BINGHAM
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