STC.UNM v. Intel Corporation

Filing 176

DECLARATION re 175 Response in Opposition to Motion,, of Brian L. Ferrall in Support of Intel's Opposition to STC's Motion to Strike and Dismiss Intel's Invalidity Affirmative Defense and Counterclaim by Intel Corporation (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K - part 1, # 12 Exhibit K - part 2, # 13 Exhibit L)(Atkinson, Clifford)

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Trevor White From: Franks, Tim (Perkins Coie) [] Sent: Thursday, December 29, 2011 3:08 PM To: UNM2-Intel Client Subject: FW: STC v. Intel - Draft Motion to Strike Attachments: Motion to Strike Counterclaim and Defenses.docx From: George Summerfield [] Sent: Thursday, December 29, 2011 4:07 PM To: Franks, Tim (Perkins Coie);; Cc: Rolf Stadheim; Joe Grear; Keith Vogt; Steve Pedersen Subject: STC v. Intel - Draft Motion to Strike All Recent caselaw suggests that a defendant can no longer plead a laundry list of affirmative defenses/counterclaims with no specificity attendant thereto. Attached is a draft motion directed to those defenses and counterclaims asserted by Intel that run afoul of this prohibition. We would like to avoid bothering the Court with this motion, if possible. We also see this is a good opportunity for eliminating the defenses and counterclaims that Intel does not intend to pursue seriously. To that end, please let us know by January 3rd whether Intel will re-file its latest amended answer and counterclaims to provide the requisite specificity to the defenses and counterclaims that it intends to pursue, and to remove those defenses and counterclaims for which Intel cannot provide the requisite specificity. If we have not heard from you by close of business on January 3, we will assume that you will not be amending your answer and counterclaim, and will file the attached motion. Regards, George George C. Summerfield STADHEIM & GREAR 400 North Michigan Avenue Suite 2200 Chicago, Illinois 60611 (312) 755-4400 IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with Treasury Department and IRS regulations, we inform you that, unless expressly indicated otherwise, any federal tax advice contained in this communication (including any attachments) is not intended or written by Perkins Coie LLP to be used, and cannot be used by the taxpayer, for the purpose of (i) avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein (or any attachments). ********** NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you. EXHIBIT I 1/17/2012

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