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)
Trevor White
From:
Franks, Tim (Perkins Coie) [TFranks@perkinscoie.com]
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 [mailto:summerfield@stadheimgrear.com]
Sent: Thursday, December 29, 2011 4:07 PM
To: Franks, Tim (Perkins Coie); bferrall@kvn.com; PMaholtra@kvn.com
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?