Performance Pricing, Inc. v. Google Inc. et al

Filing 241

MOTION to Compel Production of Documents by Third Parties Neal Cohen and Vista IP Law Group, LLP by AOL LLC, Google Inc.. (Attachments: # 1 Joint Stipulation Regarding Defendant Google Inc. and AOL LLC's Motion to Compel Production of Documents by Third Parties Neal Cohen and Vista IP Law Group, LLP, # 2 Declaration of Emily C. O'Brien in Support of Motion to Compel, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18 Exhibit P, # 19 Declaration of Christin Cho in Opposition to Motion to Compel, # 20 Errata 1, # 21 Exhibit 2, # 22 Exhibit 3, # 23 Proposed Order Granting Defendant Google Inc. and AOL LLC's Motion to Compel)(O'Brien, Emily) Modified on 9/25/2009 (sm, ). Modified on 9/25/2009 (sm, ).

x y x
Dockets.Justia.com

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS Performance Pricing, Inc. Plaintiff, v. Google, Inc. et al., 2:p7-cv-432 (LED} REVI5ED PRIVILEGE LOG CORRESPONDING TO: 1} SUBPOENA COMMANDING NON-PARTY NEAL M. COHEN TO PRODUCE DOCUMENTS; AND 2} SUBPOENA COMMANDING NON-PARTY VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS

Defendants.

The Revised Privilege Log attached hereto as Exhibit A is being Produced in
connection with: 1) RESPONSE TO SUBPOENA COMMANDING NON-PARTY NEAL M. COHEN TO PRODUCE DOCUMENTS ; and 2} RESPONSE TO SUBPOENA COMMANDING NON-PARTY VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS. Ail documents identified in said Privilege Log are being withheld on the bases identified, and are not being produced.

Abbreviations used in the Privilege Log: "NMC" means Neai M . Cohen;
"W L" means Wayne Lin;

"VLS" means Valerie L. Sarigumba, who was at ail relevant times an associate
attorney at Vista iP Law Group;

"JLL" means Jocelyn L. Lee, who was at al[ relevant times a senior paralegal at Vista IP Law Group; "HO" means Hidehiko Okada, who was at all relevant times an attorney at the law firm, Okada Patent & Trademark Office; "SS" means Samuel B. Stone, who was at all relevant times a partner at Lyon & Lyon
LLP;

"!T" means Jeff Tekanic, who was at all relevant times an attorney at the law firm, Okada Patent & Trademark Office; "PJE" means Patricia J. English, who was at all relevant times an employee at Cohen, Sakaguchi & English tLP;
"YPY" means Yev-Pyo Yoon, who was at all relevant times an attorney at Honesty & Patent;

P^G E - ^ ^ ^ _..^..

^^

^

"A/C" means a claim of Attorney/Client Privilege; "W/P" means a claim of Work Product; "TPM" means a claim of Trial Preparation Material.

^^^f^l^ ^._F.^ ^aGE ^ ^f - .

Ref 1-1

Date 8/2/2001 NMC

Author( s) WL

Recipient ( sy

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document

Privilege(s) Claimed AC, WP

1-2

8/13/01

NMC

WL

AC, WP

1-3

3/29/01

NMC

WL

AC, WP

1-4

1/12/01

NMC

WL

AC, WP

1-5

Z/20/01

NMC

WL

AC, WP

1-6

2/27/99

NMC

WL

AC, WP

1-7

1/3/01

NMC

WL

AC, WP

1-8

10/1/01

NMC

WL

AC, WP

^' iY ^^
f^ ^

i^ W
^^

Ref

Date

Aathor{s)

Recipient ( s^

Description

Prl^ilege(s) Claimed

related to litigation. 1-9
12/13/00 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications

AC, WP

1-10

11/15/01

NMC

WL

AC, WP

1-li

4/2/01

NMC

WL

AC, WP

1-12

7/2$/00

NMC

WL

AC, WP

between client and attorney. Document
1-13 5/10/01 NMC WL related to litigation, Document concerning Eegal advice and including confidential communications between client and attorney. Document related to litigation. bocument concerning legal advice and including confidersial communications between client and attorney. Document related tp litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legaE advice and including confidential communications between client and attorney. Document AC, WP

1-14

20/14/02

NMC

WL

AC, WP

1-15

8/2/01

NMC

WL

AC, WP

1-16

11/30/00

NMC

WL

AC, WP

^ ^

^ ^

C^

Ref

pate

Author ( s)

ftecipient(sJ

Description

Privilege(s)
Claimed

related to litigation,
1-17 10/27/99 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document AC, WP

related to litigation.
1-18 6/1/00 NMC WL Document concerning legs! advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential commurications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, pocument concerning Eegal advice and including confidential communications between client and attorney. Document related to litigation. AC, WP

1-19

4/18/02

NMC

WL

AC, WP

1-20

10/16/01

NMC

WL

AC, WP

1-21

3/6/02

NMC

WL

AC, WP

1-22

10/9/01

NMC

WL

AC, WP

^.-23

715/00

NMC

WL

AC, WP

1-24

2/18100

NMC

WL

Document concerning legal advice and
including confidential communications between client and attorney. Document

AC, WP

'i ^ ^

rn ^ -^

^ ^

Ref

Date

Author ( sy

Recipient(s)

Description related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including Confidential communications

Privilege(s) Claimed AC, WP

1-25

$/13/01

NMC

WL

1-26

4/17/02

NMC

WL

AC, WP

1-27

7/31/02

WP

2-5

8/2/01

NMC

WL

AC, WP

2-6

8/13/D1

NMC

WL

AC, WP

2-11

3/17/07

NMC

WL

AC, WP

3-1

5/7/02

NMC

WL

AC, WP

between client and attorney. Document 3-2
9/1D/D1 NMC WL related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document AC, WP

;.'^ . C^ .,. .t"^'^! i :"'""^

Ref

Date

Author ( s)

Recipient ( s)

Description related to litigation. Dowment concerning legal advice and including confidential communications between client and attorney. Document related #o litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including con#identiaE communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between Client and attorney. Document related to litigation. Document concerning legal advice and including Confidential communications between client and attorney. Document related to litigation.

Arivilege(s) Claimed AC, WP

3-3

9/10/01

NMC

WL

3-4

8/21/01

NMC

WL

AC, WP

3-5

NMC

WL

AC, WP

3-6

8/21/01

NMC

WL

AC, WP

3-7

S/2/01

NMC

WL

AC, WP

3-8

4/30/41

NMC

WL

AC, WP

3-9

4/23/01

NMC

WL

AC, WP

3-10

4/6/01

NMC

WL

AC, WP

^

_

m oo, ^^

^^

Ref 3-11

Date 4/6/01 NMC

Author ( s) WL

Recipient ( s)

Description Document concerning legal adv'sce and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

Privilege(s) Claimed AC, WP

3-12

4/6/01

NMC

WL

AC, WP

3-13

3/20/01

NMC

WL

AC, WP

3-14

1129/01

NMC

WL

AC, WP

3-15

11/30/00

NMC

WL

AC, WP

3-16

11/13/00

NMC

WL

AC, WP

3-17

].1/6/00

NMC

WL

Document concerning legal advice and
including confidential communications between client and attorney, Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation,

AC, WP

3-IS ^ 7C t"^ ^ °°'..^

11/6/00

NMC

WL

AC, WP

Ref 3-19

Date 10/16/00 NMC

Author ( s) WL

Recipient(s)

Description Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. pocument concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document

Privilege(s) Claimed AC, WP

3-2D

912.8/00

NMC

WL

AC, WP

3-21

9112/DD

NMC

WL

AC, WP

3-2z

6/5/00

NMC

WL

AC, WP

3-23

6/5/00

NMC

WL

AC, WP

related to litigation. 3-24 S/30/OD
NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document

AC, WP

3-25

1/26/OD

NMC

WL

AC, WP

refaced to litigation.
3-26 4/24/00 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. AC, WP

^^ I^ W

Ref 3-27

Date 3/23/40 NMC

Authar ( s}
WL

Recipent(s^

Description Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidentia communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between clent and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. pocument related to litigation, Oacument concerning legal advice and

Privilege(sy Claimed AC, WP

3-28

3/9/00

NMC

WL

AC, WP

3-29

2/9/00

NMC

WL

AC, WP

3-31

1/26/00

NMC

WL

AC, WP

3-33

1/25/00

NMC

WL

AC, WP

3-34

1/17/Op

NMC

WL

AC, WP

3-35

12/6/99

NMC

WL

AC, WP

3-36

11/29/99

NMC

WL

AC, WP

4-1

10/16/01

NMC

WL

AC, WP

rn ^, ^^

`^

Ref

i^a # e

Author ( s)

Recipient { s)

Description including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigatio,,. iacument concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Dacument concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legai advice and including confidential communications between client and attorney. Document related to itigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Dacument related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and

Privilege(s) Claimed

4-2

$/3.4/01

NMC

WL ^

AC, WP

4-3

4/5/01.

NMC

WL

AC, WP

4-4

1/1.9/01

NMC

WL

AC, WP

4-5

6/26/00

NMC

WL

AC, WP

4-6

6/1/00

NMC

WL

AC, WP

4-7

2/15/00

NMC

WL

AC, WP

4-$

12/21/99

NMC

WL

AC, WP

4-9
^ ^ ^ ^ ^ ^ °"'°'^

12/13/99

NMC

WL

AC, WP

Ref

Date

Author{s)

Recipient { s^

Description including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including conidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related tp litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including cpnfidentiai communications between client and attorney. Document related to litigation. Document concerning legal advice and

Privilege(s) CEaimed

S-3.

4/17/02

NMC

WL

AC, WP

5-2

8/13/01

NMC

WL ^

AC, WP

S-3

$/2$/DO

NMC

WL

AC, WP

5-4

b/5/00

NMC

WL

AC, WP

6-1

7/9/D1

NMC

WL

AC, WP

6-2

3/2/01

NMC

WL

AC, WP

6-3

3/2/01

NMC

WL

AC, WP

6-4

7/12/00

NMC

WL

AC, WP

m; ^^

Ref

Date

Author{s^

Recipient ( s)

Description including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including con#idential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation, Document concerning legs{ advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and

Privilege{s) Claimed

6-S

4/11/00

NMC

WL

AC, WP

6-6

4/11/00

NMC

WL

AC, WP

7-1 7-2 7-3 7-4 7-5 7-6
7-7

$-1

1/2/02

NMC NMC NMC NMC NMC NMC NMC NMC

^

HO HD HO HO HO HO HD WL

WP WP WP WP WP WP WP AC, WP

8-2

4/17/02

NMC

WL

AC, WP y

8-3

4/17/02

NMC

WL

AC, WP

$-4

NMC

WL

AC, WP

including confidential communications U [j 'i' ^'7

rn ^:. _^ ^^

Ref

Date

Authors}

Recipient ( s^

Description l7etween client and attorney. Document related to litigation. Document concerning legs! advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document related to litigation. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidentia! communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning fega! advice and including confidential communications between client and attorney, Document related to litigation.

Privilege(s) Claimed

8-5

4/17/02

NMC

WL

AC, WP

8-6

^1/25/OZ

NMC

Wl_

AC, WP

g-1 9-Z 10-1

12/14/01 3/21/00

NMC NMC NMC

YPY YPY WL

WP WP AC, WP

10-7

3/21/00

NMC

WL

AC, WP

10-3

12/13/99

NMC

WL f

AC, WP

10_4

11/10/99

NMC

WL

AC, WP

10-5

9/28/99

NMC

WL

AC, WP

^ ^ m

^ ^ W

Ref 10-6

Oate 9/26/99 NMC

Author {sJ WL

Recipient { s)

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including conidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confiden.:z! communications between client and attorney. Document related tp iitigatian. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential tommunications between client and attorney, Document related to litigation.

Privilege{s) Claimed AC, WP

1Q-7

9/24/49

NMC

WL

AC, WP

11-1

3/17/07

NMC

WL

AC, WP

11-3

7/5/DO

NMC

WL

AC, WP

11'4

7/1/04

NMC

WL

AC, WP

11-5

5/4/00

NMG

WL

AC; WP

11-6

5/13/DO

NMC

WL

AC, WP

11-7

5/13/DD

NMC

WL

AC, WP

^ ^

^ ^

m^

Ref 11-8

Date 2/16/00 NMC

Authar ( s} WL

Rec pient(s}

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation involving PricePlay Document concerning lega advice and including con#idential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between clent and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning egal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communicatons between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and

Privileges} Claimed AC, WP

11-9 11-9

2/10/00 12/31/99

NMC NMC

Trademarfc attorney in Taiwan WL

WP AC, WP

11-9

12/14/99

NMC

WL

AC, WP

11-10

11/7.0/99

NMC

WL

AC, WP

11-11

9/27/99

NMC

WL

AC, WP

11-12

9/28/99

NMC

WL

AC, WP

12

6/14/99

SS

WL, NMC

AC, WP

13

06/10/1999 -

WL, NMC, S5

' WL, NMC, SS

A/C, W/P, TPM

·;^ ^

°^ ^_ ^

10/04/2002

including confidential communications

-^ ^/'^

Ref

Date

Authors}

Recipient(s)

Description between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confider*^al communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. bocument related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. bocument concerning legal advice and including confidential communications

Privilege(s)

Claimed

14

06/14/1999

SS

NMC

A/C, W/P, TPM

1S

06/28/1999

WL

NMC

A/C, W/P, TPM

16

11/10/1999

NMC

WL

A/C, W/P, TPM

_ AC, WP

17-1

5/7/02

NMC

WL

17-2

9/19/01

NMC

WL

AC, WP

17-3

8/21/01

NMC

WL

AC, WP

17-4

4/30/01

NMC

WL

AC, WP

17-5
f^'^^-^;

4/6/01

NMC

WL

AC, WP

w..,,,,,

i^t

^.JkJ

Ref

Da#e

Author ( s)

Recipient(s)

Description between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legs[ advice and including con#identia! communications between cEient and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related To ]itigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between cEient and attorney, Document related to litigation. Document concerning legal advice and including Confidential communications

Pri^ilegets)

Claimed

17-5

3/20/01

NMC

WL

AC, WP

17-7

9/28/00

NMC

WL

AC, WP

17-$-9

6/5/00

NMC

WL

AC, WP

17-10

4/24/00

NMC

WL

AC, WP

17-1112

3/13/00

NMC

WL

AC, WP

17-1315

2/16/00

NMC

WL

AC, WP

17-1619

1/17/00

NMC

WL

AC, WP

17-^0 i-^ ^^ Fr'r! W °'m^^

11/29/99

NMC

WL

AC, WP

Ref

Date

Author ( sj

Recipient(s)

Description between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including Confidential communications between client and attorney. Document related to litigation.

Privilege(s) Claimed

18-1

9/10101

NMC

WL

AC, WP

18-2

4/23/01

NMC

WL

AC, WP

1$-3

4/6/01

NMC

WL

AC, WP

18-4-5

11/6/00

NMC

WL

AC, WP

18-6-7

3/13/00

NMC

WL

AC, WP

18-811

2/16/00

NMC

WL

Document concerning legal advice and
including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications

AC, WP
Y

1$-1z14

1/26100

NMC

WL

AC, WP

1$-15-

12/6/99

NMC

WL

AC, WP

^^ f"r`i W

1 f

Ref

pate

Author ( s)

Recipient(s)

Description between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications

Privilege(s) Claimed

19

12/13/1999 01/17/2002

NMC

WL

A/C, W/P, TPM

z0 21 22

1x/13/1999 12/13/1999 12/14/1999

NMC NMC NMC

N/A N/A WL

W/P, TPM W/P, TPM A/C, W/P, TPM

23-1

9/10/01

NMC

WL

A/C, W/P, TPM

23-2

4/23/01

NMC

WL

A/C, W/P, TPM

23-3

4/6/01

NMC

WL

A/C, W/P, TPM

between client and attorney. Document
23-4-5 11/6/00 NMC WL related to litigation. Datument concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. A/C, W/P, TPM

23-6-7

3/13/00

NMC

WL

A/C, W/P, TPM

^ ^

^ ^

f

Ref 23-8

Date 3/9/00 NMC

Author(s) WL

Recipient ( sy

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related tv litigation. Document concerning legal advice and including confidential corr3munications between client and attorney. Document

Rri^ilege(s) Claimed A/C, W/P, TPM

23-9li

2/16/00

NMC

WL

A/C, W/P, TPM

23-1214

1/26/00

NMC

WL

A/C, W/P, TPM

24-1

1/29/01

NMC

WL

A/C, W/P, TPM

related to litigation. 24-2
11/30/00 NMC

WL

24-3-4

6/5/00

NMC

WL

24-5

3/23/00

NMC

WL

2^t-6-7

3/13/00

NMC

WL

i._.1^.^ `°: ^-^ ^ i['^`^ ^ i ^°^-·3

Document concerning legal advice and including con#idential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

A/C, W/P, TPM

A/C, W/P, TPM

A/C, W/P, TPM

A/C, W/P, TPM

Ref Z4-8-^.0

date 2/16/00 NMC

Autfior ( s)
WL

Recipient [ s^

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. pocument related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. .

Privilege(s)
Claimed A/C, IN/P, 7PM

24-11-13

2/9/Op

NMC

WL

A/C, W/P, TPM

24-14-15

2/5/00

NMC

WL

A/C, W/P, TPM

24-15

2/5/00

NMC

WL

A/C, W/P, TPM

25-1

9/26/02

NMC

WL

AC, WP, TPM

25-Z

7/9/01

NMC

WL

AC, WP, TPM

Z5-3

3/2/01

NMC

WL

AC, WP, TPM

25-4

7/12/00

NMC

WL

AC, WP, TPM

^ ^^ I-F"i ^ °-°'^^

Ref

Date 4/11/00 NMC

Author (s) WL

Recipient(s)

Description Document concerning legal advice and including Confidential communications between Client and attorney. Document related to litigation. Document concerning legs{ advice and including confidential communications between Client and attorney. Document related to litigation. Document concerning legal advice and including confider.*.^al communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications

Privilege(s)

Claimed 25-5
AC, WP, TPM

25-6-7

3/13/00

NMC

WL

AC, WP, TPM

25-8

10/8/02

NMC

JT, WL

AC, WP, TPM

Z6-1

9/27/02

NMC

JT, Wl.

AC, WP

between client and attorney. Document 26-2-3
9/26/02 NMC JT, WL related to litigation. Document concerning {ego] advice and including confidential communications between client and attorney. Document related to iitigation. Document related to litigation. Document related to litigation. Document related to litigation, Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. AC, WP

26-4

26-5
26-6-7 26-$-9

26-1011 26-1214 26-1516 26-17-

7/2/01 3/2/01 2/28/01 7/12/00 7/4/00 7/5/00 6/22/00 6/21/00

HO JT NMC NMC HO HO HO NMC

NMC NMC Flo HO NMC NMC NMC HO

WP WP WP WP WP WP WP WP

18 ^ ^ ^ ^

N ^^

Ref 26-1918

Date 6/21/00 6/21/00 9/x6/02 NMC NMC NMC

Author { s)
HO

Recipient ( s)

Description bocument related to litigation. WP WP

Privilege{s) Claimed

' HO i WL Document concerning legal advice and including confidential communications A/C, W/P, TPM Document related to litigation.

26-1718 27-1

between client and attorney, bocument
27-2 8/21/01 NMC WL related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and atkflrney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigatbn. Document concerning legal advice and including confidential communications bekween client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. A/C, W/P, TPM

27-3-4

11/14/01

WL

NMC

A/C, W/P, TPM

27-5

5/2/01

NMC

WL

A/C, W/P, TPM

27-6

11/13/00

NMC

WL

A/C, W/P, TPM

27-7

10/16/00

NMC

WL

A/C, W/P, TPM

x7-8

9/12/00

NMC

WL

A/C, W/P, TPM

.^ }C ^^ ^^

t

Ref

Date 5/30/00 NMC

Author(s) WL

RECipient ( s^

Description Document concern ing legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and

27-9

Privileges} Claimed A/C, W/P, TPM

27-10

5/16/00

WL

NMC

A/C, W/P, TPM

including confidential communications
between client and attorney, Document related to litigation. Document concerning IegaE advice and including con#idential communications between cl'sent and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to fitigatian. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidentiaE communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

28-1

10/4/02

NMC

WL ^

A/C, W/P, 1'PM

28-2

9/30/02

NMC

WL

A/C, W/P, TPM

28-3

9/28/02

NMC

WL

A/C, W/P, TPM

28-4

4/17/02

NMC

WL

A/C, W/P, TPM

28-5

8/13/03.

NMC

WL

A/C, W/P, TPM

28-6

8/28/00

NMC

WL

A/C, W/P, TPM

^^ a^ ^ (^-' ^^ 3 ^L

Ref 28-7

i7ate 6/5/00

Authors} NMG
WL

Recipients}

gescription Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, bocument related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document related to litigation, Document related to litigation. Document related to li#igation.

I?ri^ilege(s}

Claimed
A/C, W/P, TPM

28-8

5/31/OD

NMC

WL

A/C, W/P, TPM

29-1

9/13/00

NMC

WL

AC

29-2

9/13/00

NMC

WL

AC

30-1 30-2 30-3 30-4

10/13/04 7.0/11/04 10/i3/04 10/6/04

30-5
30-6.7

10/19/02 10/18/02

Honesty & Patent Honesty & Patent PJE 5e-Chang Kang , Korean patent counsel NMC NMC

PJE P1E Honeslty & Patent NMC '

WP WP WP WP

YPY YPY, WL

30-8-9

10/17/02

NMC

YPY, WL

30-1011 30-12^ ^ ^ ^ ^ W

1D/17/02 9/26/02

YPY NMC

NMC YPY, WL

bocument related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document related to litigation. Document concerning legal advice and

WP WP

AC

WP AC, WP

`^ (J ^ ' U

Ref 13

Date

Author(s^

Reclpient(s^

gescriptian including confidential communications between client and attorney. Document related to litigation. Document related to litigation. Document related to litigation, Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation. Document related to litigation, pvcument related to litigation. Document related to litigation, Document related to litigation. Document related to litigation, Document related to litigation. Document related to litigation. Document related to litigation, Document Concerning legal advice and including Confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

Privilege(s) Claimed

30-14 30-15 30-16

30-1719 30-2030-21 30-2Z23 30-24 30-2526 30-2732 30-33-

7/29/02 7/29/02 4/17/02 12/29/01 12/26/01 32/25/01 12/24/01 12/14/01 12/14/01 12/9/01 11/!5101 11/15/01 11/14/01 11/1/01 10/4/02 ^

YPY YPY YPY YPY Honest & Patent YPY NMC NMC NMC NMC YPY YPY NMC Honest & Patent NMC

NMC NMC NMC NMC NMC NMC YPY YPY YPY YPY NMC NMC ^ Honest & Patent NMC WL

WP WP WP WP WP WP WP WP WP WP WP WP WP WP A/C, W/P, TPM

34
30-3537 30-38 30-39-

40 31-1

31-2

9/30/02

NMC

WL

A/C, W/P, TPM

^ ^ ^

^^ ^ Z C^

!

^-^^ `_C' ^

Ref 31-3

Date 9/26/02 NMC

Author (s) WL

Recipient ( s)

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. C]acument related to litigation.

Privilege(s) Claimed A/C, W/P, TPM

31-4

4/17/02

NMC

WL

A/C, W/P, TPM

31-5

8/13/01

NMC

WL

A/C, W/P, TPM

31-6

8/28/00

NMC

WL

A/C, W/P, TPM

31-7

3.0/4/02

NMC

WL

A/C, W/P, TPM

31-8

b/5/02

NMC

WL

A/C, W/P, TPM

31-8

5/31/01

NMC

Wl.

A/C, W/P, TPM

32

10/29/2002

NMC

WL ^

A/C, W/P, TPM

., .^ ^ :^ :^ i^ ^

Ref 33

Date
12/27/2D02 NMC

Aut3lor ( s) WL

Recipient ( s)

Description
Document Concerning legal advice and including confiden#ial communications between client and attorney. Document related to litigation, DoCUrnent car,cerning legal advice and including confidential cornmunicatians between client and attorney. Document related to litigation. Document concerning legal advice and including confidential Communications between client and attorney. Document related to litigatio^^^. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including Confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document Concerning legal advice and including Confidential communications between Client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

Privilege(s) Claimed
A/C, W/P, TPM

34

06/12/2003

NMC

WL

A/C, W/P, TPM

35

07/22/2D03

WL

NMC

A/C, W/P, TPM

36

12/02/2004

NMC

WL

A/C, W/P, TPM

37

12/03/2004

NMC, WL

WL, NMC

A/C, W/P, TPM

38

12/03/2004

WL

NMC

A/C, W/P, TPM

39

12/03/200A

NMC, WL

WL, NMC

A/C, W/P, TPM

40

12/13/2004

NMC

WL

A/C, W/P, TPM

i-n C7^

^i^

Ref
41

t7ate 09/17/200509/20/2005

Author { s)
NMC, WL

Recipient ( sy
WL, NMC

Description
Document concerning legal advice and including confiders#ial communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document _ related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document

Priviiege(s^ Claimed
A/C, W/P, TPM

42

09/17/200509/23/2005

NMC, WL

WL, NMC

A/C, W/P, TPM

43 44

10/06/2045 12/20/2005

NMC WL

N/A NMC

W/P, TPM A/C, W/A, TPM

45

12/22/2005

NMC, WL

WL, NMC

A/C, W/P, TPM

46

Oz/02/2005

NMC

WL

A/C, W/P, TPM

47

D2/O8/2006

NMC, WL

WL, NMC

A/C, W/P, TPM

48-1

3/3/07

NMC

WL

A/C, W/P

4$-2

2/26/07

NMC

WL

A/C, W/P

i. r!^ ^ l^ ll^J
'--^-I ^-^ ^ ^-'^ i

Ref

Date

Author { s)

Reciplent ( sj

Description related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential [ommunications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document __ related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between [lient and attorney. Document related to litigation. Document concerning legal advice and including confidentia3 communications between client and attorney. Document related to litigation. Document [ancerning legal advice and including confidential communications between client and attorney. Document

Privilege{sy Claimed A/C, W/P

48-3

2/26/07

NMC

WL

49-1

2126/07

WL

NMC

A/C, W/P

49-2

2/26/07

WL

NMC

A/C, W/P

49-3

2/26/07

WL

NMC

A/C, W/P

50-1

2/27/07

WL

NMC

A/C, W/P

SO-2

2/27/07

WL

NMC

A/C, W/P

50-3

2/27/07

WL

NMC

A/C, W/P

51

02/27/2007

NMC

WL

A/C, W/P, TPM

^t ^ ^ _W '^ V^ 1 f^^

Ref

Date

Authar ( s}

Recipient ( sy

Description related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including con#idential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document

Privileges} Gaimed A/C, W/P, TPM

52

03/02/2007

WL

NMC

53

D3/05/2D07

WL

NMC

A/C, W/P, TPM

54

D3/D6/2D07

WL

NMC

A/C, W/P, 7PM

55

03/Db/2007

NMG

WL

A/C, W/P, TPM

_ A/C, W/P, TPM

55

03/07/2007

WL

NMC

57

03/07/2007

NMC

WL

A/C, W/P, 7PM

58

03/11/2007

NMC

WL, VLS

A/C, W/P, TPM

59-1

3/13/07

WL

NMC

A/C, W/P

^J ^ 6 ^"I C^ ^^. s
E i ^ l

Ref

17ate

Authors}

Recipient ( sy

>7escrfptlon related to litigation. bocument concerning legal advice and including confidential communications between client and attorney, Document reiated to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legai advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidentiaE communications between client and attorney. Document

Privilege(s^ Claimed A/C, W/P

59-Z

3/13/07

WL

NMC

b0-1

3/13/07

NMC

WL

A/C, W/P

60-2

3/13/07

NMC

WL

A/C, W/P

61-1

3/17/07

NMC

WL, VLS

A/C, W/P

61-Z

3/7.7/07

NMC

WL, VLS

A/C, W/P

62

03/17/2007

WL

NMC

A/C, W/P, TPM

63

03/17/2007

WL

NMC, VLS

A/C, W/P, TPM

64

03/17/20D7

NMC

WL

A/C, W/P, TPM

^^ ^'7 ^

^^^

`^#

}tef

Date

Author(s)

Reclpient ( sy

Description related to litigation. Document Concerning legal advice and including confidential communications between client and attorney. Document rekated to litigation. Document concerning legal advice and including confidential Communications between client and attorney. Documen# related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document [oncerning legal advice and including confidential [ommunications between client and attorney. Document rekated to litigation. Document concerning legaE advice and

Privilege(s) Claimed A/C, W/P, TPM

65

03/17/2007

NMC

WL

66

03/20/2007

WL

NMC, VLS

A/C, W/P, TPM

67

03/20/2007

NMC

WL

A/C, W/P, TPM

68

03/21/2007

WL

NMC, VLS

A/C, W/P, TPM

69

03/26/2007

NMC

WL, VLS

A/C, W/P, TPM

70

03/26/2007

WL

NMC, VL5

A/C, W/P, TPM

including confidential communications
between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

71

03/2$/2007

WE.

NMC, VLS

A/C, W/P, TPM

72
73-1 %-C ^ ^

03/29/2007
3/13/07

JLL
NMC

NMC
WL

Document related to litigation.
Document concerning legal advice and including confidential communications

W/P, TPM A/C, W/P

^ ^

Ref

f72te

Author { s)

Recipient ( s^

pescriptian between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client anu attorney. Document

Privilege(s) Claimed

73-Z

NMC

WL

A/C, W/P

73-3

NMC

WL

A/C, W/P

73-4

NMC

WL

A/C, W/P

related to litigation. 73-5
NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidentiak communications between client and attorney. Document related to litigation. bocument concerning legal advice and including confidential communications between client and attorney, Document related to litigation, Document concerning legal advice and including conidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidentiak Communications A/C, W/P

73-6

3/17/07

NMC

WL

A/C, W/P

73-7-8

NMC

WL

A/C, W/P

74

03/30/2007

NMC

WL

A/C, W/P, TPM

75 ..^ X ^^ !^ ^

03/30/2007

NMC

WL, VLS

A/C, W/P, TPM

Ref

pate

Author ( s)

Recipient { s)

Description between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to I'stigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation . Document related to litigation . Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

Privilege(s)

Clairt^ed

76

03 / 30/2007

WL

NMC, VLS

A/C, W/P, TPM

77

03/ 30/2007

NMC

WL, VLS, 1LL

A /C, W/P, TPM

78

03 /30/2007

WL

NMC, VLS, 1LL

A/C, W/P, TPM

79

D3 /30/2007

NMC

WL

A /C, W/P, TPM

SO 81 82

03 / 30/2007 03 / 30%2007 05 /01/2007

NMC NMC WL

VLS, JLL N/A NMC

W/P, TPM W/P, TPM A/C, W/P, TPM

83

05 / O1/20D7

NMC

WL

A/C, W/P, TPM

84

05 / 03/2007

NMC

WL

A /C, W/P, TPM

uai ^_ ^^

^^

I ^^

Ref SS

Da#e 05/04/2007 WL

Authors)

Recipients}
NMC

Description Document concerning legal advice and including confidential communications between Client and attorney. Document related to I'stigation. Document concerning legal advice and including confidential communications

Pri^ilege[s) Claimed A/C, W/P, TPM

86

OS/18/2007

NMC

WL

A/C, W/P, TPM

`
87 07/O^i/2447 NMC WL.

between client and attorney, Document
related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between cl'sent and attorney. Document A/C, W/P, TPM

88

10/02/2007

NMC

WL

A/C, W/P, TPM

89

10/02/2007

WL

NMC

A/C, W/P, TPM

90

10/03/2007

WL

NMC

A/C, W/P, TPM

91

10/05/2007

NMC

WL

A/C, W/P, TPM

92

10/OS/2007

WL

NMC

A/C, W/P, TPM

related to litigation, .^ ^ C ^^

^E ^`^ ^

ite# 93

Date 12/17/2007 NMC

Authar[ s)
WL

Recipient [sy

Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. document concerning legal advice and including confider.;i4l communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation.

Privileges) Claimed A/C, WJP, TPM

94

06/11/2008

WL

NMC

A/C, W/P, 'fPM

95

06/14/200$

NMC

WL

A/C, W/P, TPM

i 96 10/26/ZOp$ Christin Cho NMC

A/C, W/P, TPM

97

10/27/2008

WL

NMC

A/C, W/P, TPM

^ ^ ^ T` ^ ^

k

,