Web Tracking Solutions, Inc. et al v. Google, Inc.

Filing 58

Letter regarding procedures for Markman hearing by Google, Inc., Web Tracking Solutions, Inc., Daniel Wexler (Curran, Patrick)

April 22, 2010 VIA ELECTRONIC FILING Magistrate Judge Ramon E. Reyes, Jr. United States District Court Eastern District of New York United States Courthouse 225 Cadman Plaza East, Room 263 Brooklyn, New York 11201 Re: Web Tracking Solutions, LLC and Daniel Wexler v. Google Inc., No. 1:08-cv-03139

Your Honor: The parties submit this joint letter to inform you of their plans for the April 29, 2010 Markman hearing at 10 a.m., and to invite any questions or comments Your Honor might have. The parties plan to present PowerPoint presentations. The presentations would generally include slides on: (1) the background of the technology (i.e., the type of information in the technical tutorials), (2) information about the patent and prosecution history, and (3) each parties' claim construction positions. Plaintiffs' counsel would present on all of these issues, followed by defendant's counsel. Subject to any different preferences Your Honor may have, the parties estimate each side will take 1.5 to 2 hours for these presentations. We understand that Your Honor has another conference at 2 p.m. Given that we are starting at 10 a.m., in view of the time estimates for each side the parties will be prepared to continue after the break for as long that afternoon as Your Honor finds necessary. The parties are available to discuss the procedures for the Markman hearing at Your Honor's convenience. Respectfully submitted, /s/ Steven M. Hayes Steven M. Hayes HANLY CONROY BIERSTEIN SHERIDAN FISHER & HAYES 112 Madison Avenue, 7th Floor New York, NY 10016 [phone] [e-mail] Counsel for Plaintiffs /s/ Edward J. DeFranco Edward J. DeFranco QUINN EMANUEL URQUHART & SULLIVAN 51 Madison Avenue, 22nd Floor New York, NY 10010 [phone] [e-mail] Counsel for Defendant