Polaris IP, LLC v. Google Inc. et al

Filing 507

RESPONSE in Opposition re 460 MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay filed by AOL, LLC., Google Inc., Yahoo!, Inc.. (Attachments: # 1 Sistos Decl. ISO Defendants' Response, # 2 Branting Decl ISO Defendants' Response, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit)(Sistos, Antonio)

Polaris IP, LLC v. Google Inc. et al

Doc. 507 Att. 15

EXHIBIT K

Dockets.Justia.com

From: Subject: Date: To: Chuck,

"Pridham, David" <[e-mail]> RE: Firepond Consulting Services February 19, 2003 3:51:59 AM PST "Chuck Williams" <[e-mail]>

Thanks for the reply. I am sorry that you are not able to consult for Firepond. However, we are hoping that you can provide some basic information about the Brightware / Chase implementation. I think you may be the only person who would provide this information. Please advise if you are willing to answer some basic questions in email form. Best Regards, D a vi d David M. Pridham, Esq. Corporate Counsel Firepond, Inc. Waltham Woods Corporate Center 890 Winter Street Waltham, Massachusetts 02451 Telephone: [phone] Facsimile: 781.487.8514 Mobile: [phone] email: [e-mail]

STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify FirePond, Inc. immediately at [phone], and destroy all copies of this message and any attachments.

-----Original Message----From: Chuck Williams [mailto:[e-mail]] Sent: Tuesday, February 18, 2003 11:29 PM To: Pridham, David Subject: RE: Firepond Consulting Services D a vi d , I'm sorry but I'm not going to be able to provide consulting to Firepond. In the end, people here are just not comfortable with me doing it. Sorry it worked out this way. Best of luck, Chuck Chuck Williams President InQuira, Inc. [e-mail]

-----Original Message----From: Pridham, David [mailto:[e-mail]]

Sent: Tuesday, February 18, 2003 10:28 AM To: Chuck Williams Subject: RE: Firepond Consulting Services Chuck, I hope all is well. Please advise if there is any update re: your ability to perform consulting services for Firepond. I look forward to hearing from you. D a vi d David M. Pridham, Esq. Corporate Counsel Firepond, Inc. Waltham Woods Corporate Center 890 Winter Street Waltham, Massachusetts 02451 Telephone: [phone] Facsimile: 781.487.8514 Mobile: [phone] email: [e-mail]

STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify FirePond, Inc. immediately at [phone], and destroy all copies of this message and any attachments. -----Original Message----From: Chuck Williams [mailto:[e-mail]] Sent: Tuesday, February 04, 2003 10:22 PM To: Pridham, David Subject: RE: Firepond Consulting Services

D a vi d , I haven't consulted in 2 years, but when I did all of my clients paid my standard rate of $5,000 a day. I would consider this at the same rate, but not less. Also, I need to understand the level of time commitment required, whether or not any travel would be required, and any kind of engagement letter or other agreement you would want me to execute. Finally, I would need to pass this by my Board to ensure they do not view this as a conflict with my employment agreement with InQuira. If the time commitment is not great, the agreements are minimal, and we agree on the rate, then I would go forward and check with my Board. I believe I could help you with all 6 areas you outline below. I'll be in the office tomorrow at [phone] so we can discuss. Chuck Chuck Williams President

President InQuira, Inc. [e-mail] -----Original Message----From: Pridham, David [mailto:[e-mail]] Sent: Tuesday, February 04, 2003 5:49 AM To: Chuck Williams Subject: Firepond Consulting Services Chuck, Thank you for speaking with me regarding the possibility of you serving as a consultant to Firepond. I apologize for the delay in getting back to you. This email is intended to serve as a synopsis of the consulting services Firepond is requesting. The consulting services would include: 1. Providing historical context to the E Z Reader project and the implementation at Chase Manhattan Bank. 2. Providing historical context to the development of BrightResponse. 3. Providing historical context to Brightware's patent portfolio / applications. 4. Providing an understanding of the email management industry. 5. Providing an understanding of the history of email management software. 6. Serving as an expert in the field of email management software. The fees are certainly negotiable but typically experts receive $2,500 $3,000 a day for time and services (not inclusive of reasonable expenses). Please contact me upon review to discuss. Best Regards, D a vi d David M. Pridham, Esq. Corporate Counsel Firepond, Inc. Waltham Woods Corporate Center 890 Winter Street Waltham, Massachusetts 02451 Telephone: [phone] Facsimile: 781.487.8450 Mobile: [phone] email: [e-mail]

STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify FirePond, Inc. immediately at [phone], and destroy all copies of this message and any attachments.