Polaris IP, LLC v. Google Inc. et al

Filing 365

RESPONSE in Opposition re 364 MOTION to Stay Discovery Ordered In Docket Number 355 Until An Amended Protective Order Is Entered And Pending The Resolution Of Yahoo!'s Motion For Partial Reconsideration filed by Bright Response LLC. (Attachments: # 1 Affidavit of Liz Wiley, # 2 Exhibit A, # 3 Exhibit B)(Wiley, Elizabeth)

EXHIBIT B

From: To: Subject: Date: Attachments:

Andrew Weiss Bright Response Fwd: Bright Response v. Yahoo [RESTRICTED CONFIDENTIAL-SOURCE CODE] Wednesday, June 16, 2010 9:31:44 PM Click Protection Reconsideration - Redacted.pdf ATT02426.htm

Begin forwarded message: From: "Sherwin, Scott" <[e-mail]> Date: June 16, 2010 7:28:32 PM PDT To: "David Pridham" <[e-mail]> Cc: "Marc Fenster" <[e-mail]>, "Andrew Spangler" <[e-mail]>, "Alexander Giza" <[e-mail]>, "Andrew Weiss" <[e-mail]>, ".BrightResponseYahoo" <[e-mail]>, "Josh Thane" <[e-mail]>, "Jennifer Doan" <[e-mail]> Subject: FW: Bright Response v. Yahoo [RESTRICTED CONFIDENTIAL-SOURCE CODE]
David, Please see the redacted version. Regards, Scott

From: Josh Thane [mailto:[e-mail]] Sent: Wednesday, June 16, 2010 12:12 AM To: '[e-mail]'; '[e-mail]'; '[e-mail]'; 'Andrew Spangler'; '[e-mail]' Cc: Rooklidge, William; White, Jason; Shah, Mansi; Sherwin, Scott; _Doan, Jennifer Subject: Bright Response v. Yahoo [RESTRICTED CONFIDENTIAL-SOURCE CODE]

Counsel, Please find attached docket number 363, which was filed under seal this evening. Please note that these documents are to be treated as "Restricted Confidential Source Code," and should not be disseminated to any counsel other than those copied on this email. Pursuant to the parties' agreement this afternoon, neither David Pridham nor others similarly situated should be given access to these documents without Yahoo!'s express permission. Further, we have agreed that the information in these confidential documents should not be communicated to David Pridham or others similarly situated for any reason by any person, including experts or those individuals reviewing source code. Please let us know immediately if you disagree or do not intend to comply with these representations, and we will arrange to resolve directly with the Court. Tomorrow, we will provide a redacted copy of the pleading

for Mr. Pridham's review pursuant to our agreement. Regards, Josh Josh Thane, J.D. HALTOM & DOAN

Crown Executive Center, Suite 100 6500 Summerhill Road Texarkana, Texas 75503 [phone] Direct [phone] Office [phone] Facsimile [e-mail] The preceding email message may be confidential or protected by the attorney - client privilege. It is not intended for transmission to, or receipt by, any unauthorized persons. If you have received this message in error, please (i) do not read it, (ii) reply to the sender that you received the message in error, and (iii) erase or destroy the message. Legal advice contained in the preceding message is solely for the benefit of the HALTOM & DOAN client(s) represented by the Firm in the particular matter that is the subject of this message, and may not be relied upon by any other party.