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, ).

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x y Dockets.Justia.com ^^ r Emily^ U'Brien rr^i s i rrrrr^ r s ^. s ^^ ^ From: Sent: TO: Rachel Kim [rachel@doveUaw.com] Tuesday, April 2'f, 2008 3:34 PM dbeck@brSfirm.COm; rebunt@pbatyler.com; eftndlay@rameyf[oclc.com; rhung@rnofo.corn; mjacobs@mat'o.com; mikejones@potterminton.com; Jennifer R Kash; rlcrevans@moio.com; Emily O'Brien; David Perlson; Antonio Sistos; Charles K Verhoeven; mrichardson@brsfirm_com; Ilcalb@sidley.com; dpritikin@sidley.corn; jwmcbride@sidley.cam; rcederolh@sidiey.com; jahnbufe@potterminton.com; jgilfoil@mofo.com; Goggle-Performance Pricing Cc: Subject: Attachments: charley@pbatyler.com; ccapshaw@capshawlaw.com; ederieux@capshawlaw.com; greg@davellaw.com; christin@dovellaw.com; cheery@capshawlaw.com; risaac@ca ps hawlaw.com Performance Pricing v. Google, et al_- Nea[ CohenNisfa IP Law Documents Singfe_pg VIP02.zip; Multi^g VlP02.zip; Privilege Log(REVISEt7} 4'2'I'09.pdf Counsel, Please find attached a revised Privilege Log for the documents produced by Neat Cohen and Vista IP Law along with documents previously withheld. Do not hesitate to contact me with any questions. Racket Kim Legal Assistant Dovel & Luner, LLP (310)_ 656-7066 20i Santa Monica Bvld. Suite f00 Santa Monica, CA 90401 PaG E ^^^.r UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS Performance Pricing, fnc. Plaintiff, v. Google, Enc. et al., Defendants. 2:DT-ev-432 {Lf"©) REVISED PRIVILEGE LOG CORRESPONDING TO: 1} SUBPOENA COMMANDING NON-PARTY NEAT. M. CDHEN TO PRODUCE DOCUMENTS; AND 2) SUBPOENA COMMANDING NOIV-PARTY VISTA IP LAW GROUP LLP TD PRODUCE DOCUMENTS The Revised Privilege Log attached hereto as Exhibit A is being produced in connection with: ].} RESPONSE TO SUBPC`ElVA COMMANDING NON-PARTY NEAT M. COHEN TO PRODUCE DOCUMENTS; and 2} RESPONSE 70 SUBPOENA COMMANDING NON-PARTY VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS. AI! documents identified in said Privilege Log are being withheld on the bases identified, and are not being produced. Abbreviations used in the Privilege Lag: "NMC" means Nea! M. Cohen; "W L" means Wayne Lin; "VLS" means Valerie L. Sarigumba, who was at all relevant times an associate attorney at Vista IP Law Group; "J LL" means Jocelyn L. Lee, who was at al! relevant times a senior paralegal at Vista IP Law Group; "HO" means l-iidehika Okada, wha was at ail relevant times an attorney at the law .firm, Okada Patent & Trademark Office; "SS" means 5amuei B. Stone; who was at all relevant times a partner at Lyon & Lyon LLP; "JT" means Jeff Tekanic, who was at all relevant times an attorney at the taw firm, Okada Patent & Trademark Office; "PJE" means Patricia J. English, who was at all relevant tunes an employee at Cohen, Sakaguchi & English LLP; "YPY" means Yeo-Pyo Yaon, who was at ail relevant times an attorney at Honesty 8e Patent; EXHIBIT _- ^ --. PAGE -l^_ _ ^^ "AJC" means a claim of AttarneyJClient Privilege; "WJl'" means a claim of Work Product; "TPM" means a claim of Trial Preparation Materiai. E^^#(^( PACE ..^._^^^.^... .Ref J: 1 .^^ Date 8/2/2Q01 ,... ^.. NMC Quth^o.r{s) Wl Recip^erit{s^' __ _ Descrrpti ,on 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. Dacumen# concerning legal advice and includng confldential communications between client and attorney. 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Document concerning legal advice and including confidential communications between client and attorney. Document Pfivilege{s) Claimed AC, WP 1-9 12/13/00 NMC 1-1D 11/15/01 NMC WL AC, WP 1-11 4/2/01 NMC WL AL, WP 1-12 7/28/00 NMC WL AC, WP 1-13 5]10/41 NMC WL _ AC, WP 1-14 10/14/02 NMC WL AC, WP ` 1-15 $/2/01 NMC WL ! ^ 1 AC, WP "-T,3 ' ^7 ^^ =^ 1-16 11/$0/00 NMC WL AC, WP ^^,^-1 Ref. ," Date Au # Ii'ar(6)° ^^ ^ . _ Recipient{s) . WL 3-17 10/27/99 NMC 1-18 6/1/00 NMC WL 1-19 4/18/0? NMC WL 1-20 10/16/01 NMC WL _^ _ 1-21 ^/6/OZ NMC WL 1-22 10/9/01 NMC WL 1-23 7/5/00 NMC WL '"t7 1 ^^ ^^ -24 2/18/00 NMC WL ^ Descrlption^ .. _ .. related to lltigation. Document concerning legal advice and including confidential communications between client and attorney. Darument related to litigation. Document concerning legal advice and including confidentia [ communications between client and attorney. 1)oCument related to litigation. 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'Kef . :^i: pate ^^ - Auti^or(s) '^ _ _ ` Recipient(s) .. . ^ _ ^ Description ^ Privilege(s7 :^Clalrned ^-25 8/13/01 NMC WL 1-26 4/17/02 NMC WL ^ 1-Z7 7/31/02 NMC WL Z-5 8/2/01 NMC 4U[. __ Z-6 8/7.3/01 NMC WL 2-11 3/17/07 NMC WL 3.1 5/7/02 NMC WC related to litigation Document concerning legal advice and including conf:dential communications between client and attorney. document related to litigation. _ Document concerning legal advice and including co,fidential communications between client and attorney. Document related t_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 related to litigation. _ Document concerning legal advice and including conidential communications between client acrd attorney. 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AC, WP AC, WP _ AC, WP _ AC, WP ^ ^ i t Ref ^ ^ 3-11 ^ Date ^' . `' ^^Author:(s) NMC WL Recipient (s)'':. ^ Description ^ Documen# 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 cEient and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document _ _ related to litlp^ation. Document concerning legal advice and including confidential communications between client aid attorney. Document related to liti at'son. Document concerning legal advice and including confidential communications between client and attorney. Document related to iiti anon. 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AC, WP _ AC, WP AC, WP Ref 3-27 date 3/23/00 ^ NMC Autbar{s) . , ...... WL Recipient{s) ... - 3-28 3/9/00 NMC WL _ 3-29 2/9/00 NMC WL 3-31 1/26/OD NMC WL 3-33 1/26/00 NMC WL 3-34 1/17/00 NMC WL 3-35 12/6/99 NMC WL 3-36 11/29/99 NMC WL ^ ^ i!. Z Q-1 W , ^E 10/16/01 NMC WL Description. _ __ ' Document concerning legal adults 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. 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Reciplerit(s} ^ ^ 'a'escriptian . ^" .Ariuilege{s} _ 4-Z 8/14/01 NMC 'WL 4-^ 4/5/01 NMC WL 4-4 1/19/01 NMC WL _ 4-5 5/26/00 NMC WL 4-6 6/1/00 NMC WL 4-7 2/15/00 NMC WL 4-8 ^ ^. ^ ^ w..:^g 49 12/21/99 NMC WL 12/13/99 NMC WL including confidential communications between client and attorney. Dncument related to Eitigation· Document concerning legal advice and including cnnfdential 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 Encluding 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 Eitigation. Document concerning legal advice and including cnnfidential communications between client and attorney. 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" S-^ 4/17102 ^ NMC Wt, AC, WP 5-2 8/13/01 NMC WL AC, WP ,^ .. 5-3 _ 8/28/00 NMC WL AC, WP 5-4 6/5/00 NMC WL 5-1 7/9/07. NMC WL 6-2 3/2/01 NMC WL 6-3 3/2701 NMC WL l^ ^ 6-^ 7/12/00 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigatian. 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. boCUment concerning legal advice and AC, WP AC, WP AC, WP ,^ AC, WP AC, WP =^ f2e^F.^^ ..: .: .:Date R'u #Har^s) Reclplerit(s) _. .__ _ ^ l7escrEpt[ors;..... ` .. ^' including confidential communications between client and attorney. Document related to iitigatian. 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Document concerning legal advice and including confidential communications between client and attorney. Document related to likigation. Documenk concerning legal advice and including co^ofidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications WP WP WP WP WP WP WP AC, WP AC, WP _ AC, WP AC, WP ^^ Ref ' ' ^' Date Author(s) ^. { Recipient(s) ·.,. ", .^ Descriptidn^ :. Privifege(s^ Claimed.. 8-5 4/17/02 NMC WL _ 8-6 4/25/02 NMC WL ! 9-1 9-2 10-1 _ ^ 12/14/01 3/21/00 NMC NMC NMC _ YPY YPY WL _ ^ 14-2 ^ 3 10-3 3/21/00 NMC W1_ 12/13/99 NMC WL __._ _ 10-4 11/10/99 NMC Wt 10-5 9/28199 NMC WL ^ ^ ^^ between client and attorney, Document related to litigation. Dacument concerning legal advice and including confidential communications between client and attorney. Document related to litigation. 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Reci,pient(s} _ WL Dirscription _ Document concerning legal advice and `Privilege{s} Claimed AC, WP 10-7 9/24/99 NMC WL _ 11-1 3/17/07 NMC WL _ __ 13.-3 7/5/00 NMC WL ^ including confidential communications between client and attorney. Document related to [itigation. Document concerning legal advice and including confiidential 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 con#identiaE comrnunicatians between client and attorney. Document AC, WP _ AC, WP AC, WP 1f-4 7/1/00 NMC · WL related to Eitlgatian. Document concerning legal advice and including con#idential communications between client and attorney. Document related to litigation. AC, WP 11-5 5/4/00 NMC WL 11-6 5/13/00 NMC WL Z1-7 ^^ ^^ E^ ^ ^. 5/13/00 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to IiCsgation. Document 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 liti anon. AC, WP AC, WP AC, WP 1 Ref : < 3.1-8 :ate x/15/00 NMC Auttlo^(s^ 'Recipient(s.) ::` _ WL ^ ^ !]escription' 17-9 13.-9 2/10/nn 1Z/31/99 NMC NMC Trademark attorney in Taiwan WL Document concerning lega3 advice and including confidential communications between client and attorney. Document related to litigation. Document related to litigation involving PricePlay Document concerning legal advice and including confdential communications between client and attorney. Document related to litigation. nocument concerning legal advice and Privileges} .. Claimed AC, WP WP AC, WP i ti .^ 11-9 12/34/59 NMC WL AC, WP _ 11-3.0 11/to/99 NMC _ __ WL __ _ including confidential communications between client and attorney. Document related to litigation, _ Document concerning legal advice and AC, WP _ including confidential communications between client and attorney. Document 11-11 9/27/99 IyMC _ WL ^ related to litigation. Document concerning legal advice and AC, WP 11-12 9/28/99 NMC WL 12 6/14/99 SS WL, NMC 13 ^ ^ ^ ^ ^,.^-.d Q6/10/1999 10/04/2002 WL, NMC, 55 WL, NMC, SS including confidential communications between client and attorney, Document related to litigation. Document concerning legal advice anti including confidential communications between Client and attorney. Document related to litigation. Document Concerning legal advice and includng confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications AC, WP ^ 'R i AC, WP A/C, W/P, TPM Ref" ... -- Date ^ Author(s) ^ }^ectpienf ( s] - ^-^ Desci·Eption^ ^ Privilege(s) Claimed 14 06/14/1999 55 NMC ^^ 15 06/28/1999 WL NMC 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 ircluding confidential communications between client and attorneY· Document related to litigation. DQCUment concerning legal advice and A/C, W/P, TPM A/C, W/P, TPM . A/C, W/P, TPM ,,^ 16 11/10/1999 NMC WL __ 17 -1 5/7/02 NMC WL _ including confidential eammunieations between client and attorney, Document _ related to litigation. Document Concerning legal advice and _ AC, WP _ - 17-2 9/19/01 NMC WL 17-3 8/21/01 NMC Wt 17-4 4/30/01 NMC WL I r^ ^ ^ ^ .----^ t ^} ^^ 17-5 4/6/01 NMC WL 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 iitigation. Document concerning legal advice and including confidential wmmunicatians betweers 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 confiderstial communications AC, Wp AC, WP AC, WP AC, WP Etef ^ Date. ^^^. . ^ I AuxEi^^r (s) ,' ' ^ Recipient(5^ .. ^ Description ^ between client and attorney, Document Privilege(s) Claimed .^ ^ _ __ 17-6 3/20/01 NMC WL 17-7 9/28JD0 NMC WL __ 7.7-5-9 6/5/OD NMC WL ^ _ related to litigation. Document concerni^^ 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 legaE advice and including confidential communications between client and attorney , Document _ AC, WP AC, WP \,_.. AC, WP 17 -10 _ 4/24/00 __ NMG WL related to litigation. Document Concerning legal advice and including confidential communications _ AC, WP 17-1122 3/13/00 NMC WL 17-13- 2/16/00 NMC Wl_ 15 17-1619 1/17/DO NMC WL E"-P"i 17-20 ""^ 12/29/99 NMC WL between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between cllent and attorney . Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney.l7ocumeni 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 AC, WP AC, WP AC, WP AC, WP 1 vl a i ^^ Ref ^ ^ ^ 'Date :... . . ·. Authdr ( s} . . .. Recipient(sj ^:. _ ^. Description - ,: . ^^ Pr'iviiege^sj ..'Cla irned between client and attorney. Document 18-1 9/10/Q1 NMC WL 18-2 4/23/07. NMC WL 18-3 4/6/pl NMC WL 18-4-5 1].16/00 NMC WL 1$-6-7 3/13/Qi] NMC WL 18-811 2/16/Oq NMC WL 18-1214 ^ ^ ^ ^ ^ ^ 1/2fi/00 NMC WL 18-15t^ 12/6/99 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 induding 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 cancernina Isgal 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 communications AC, WP AC, WP AC, WP AC, WP AC, WP AC, WP AC, WP AC, WP Ref ' Date ':. A^uthor (sj :· ^ Reciplent^s ). ^ . .... .: Descr^ptian :^. 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 reated to litigation. Document concerning legal advice and lndud 'sng confidential communications between , client and attorney . Document related to litigation. Document concerning legal advice and including confidential communications Between client and attorney. 1ocument related to litigation. Document concerning legal advice and including confidential communications between cliern 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 [itigation. Privilege{s^' .. =CEaimed. ^ 39 12/13/1999 01/17 /2002 NMC WL A /C, W/1', ^'PM 21 22 12/ 13/1999 32/ 14/3999 NMC NMC N/A T WL 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 _ __ 23-g-5 11/6/00 -^ NMC WL __ A/C, W/P, TPM _^._ _ 23-5-7 ' ^^ ""^^ ^ 3 / 13/00 NMC WL ^. 23-8 3/3/04 ^J NMC WL -^ Document concerning legal advice and including confidential communications between client and attorney , Document reated to litigation. Document concerning legal advice and A/C, W/P, TPM A/C, W/P, TPM J 1^^ i f ' Ref i^ ^, :. ^ , ^ : ..:;... I Date ^ :° .. '^ Author(5j . .. ^ ·Ftecipiei^t( s}·' Descri^tian^^ '.^ . : ^ _ .. :.: ... . ;,: ^^ .:: ' ..,.. :. including confidential communicatons between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications Privilege{s)` . G#ai cried,:. _ 23-911 2/],6/00 NMC W!. A/C, W/P, TPM 23-1.214 1/26/00 NMC WL 24-1 1129/01 NMC WL _ Z4-2 11/30/00 NMC WL NMC _____-..... 24-3-4 615/00 WL 24-5 3/23/00 NMC WL 24_6-7 3/13/00 NMC WL ^ ^ 24-8-10 2/x6/00 NMC WL between client and attorney, Document related to litigation. Dacument concerning legal advice and inciuding con#idential communicatians between client and attorney. Document related to litigation. Document concerning legal advice and includingconfidentlal 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 legai advice and including confidential communicatians 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 'sncluding canfidentiai Communications between client and attorney. Dacument related to litigation, Dacument concerning legal advice and A/C, W/P, TPM ,^ A/C, W/P, TPM A/C, W/P, TPM A/C, W/P, TPM A/C, W/P, TPM ,^^ , A/C, W/P, TPM A/C, W/P, TPM _^ i . (^I ^^ V E itef. ^.^^^ DaCe .... AU41ior(s} ^'. liecipient{s) ^. ^ Description ^ Y Privilege{s) Claimed. 24-11-13 2/9/00 NMC WL 24-14-15 2/5/Otl NMC WL _ 24-16 2/5/04 NMC WL ___ 25-1 9/26/02 1VMC WL 25-Z 7/9/01 NMC WL 25-3 3/Z/Ol NMC _ ^ WL 25-Q 7/1x/00 NMC WL ["^ ^ Z5-S 4/17./00 NMC WL including confidential communications between client and attorieey. Document related to litigation. Document concerning legal advice and incuding confidential communications between G[ient 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 lltlgatlon. 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 lltlgatlon. 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 A/C, W/P, TPM A/C, W/P, 7PM _, _ A/C, W/P, TPM AC, WP, TPM ^ AC, WP, TPM AC, WP, TPM AC, WP, TPM AC, WP, 7PM R;wf '1]'2te '.^ ^ Authsir( s) ^ ^ :Recipient ( s) ^ Description ^ . ,.. ... _ :`Privilege{sJ . , Claimed __ 25-6-7 3/13/00 NMC WL 25-$ ,10/$/02 NMC Jfi, WL _ 26-1 9/27/02 NMC 1T, WL 26-2-3 9/26/07. NMC JT, WL .^ i"^ 26-4 26-5 26-6-7 26-8-4 Z6-101S 26-1214 6-i56 6-17$ 6-19- 7/2/01 3/2/01 2/28/01 7/12/00 7/4/00 7/5/00 . 6/22/00 6/z1/^ 6/21/00 HQ Ji' NMC NMC HO NMC NMC HO HO NMC NMC NMC _^ HO _ HO including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including confidential communications between client and attomey. Document re#ated 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 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 related to litigation. AC, WP, 7PM AC, WP, TPM _, l __ _ AC, WP AC, WP WP WP WP WP WP WP WP WP WP Hp HO NMC NMC ^1 i 1 ^ 1 S ^Ref.^ 18 l]at2^ ^-:. ^. Author^sJ : ... . .Recipient(sj: .._. : ^ Desc^ip#ian . ___...... 26-17 1& 27-1 6/21/00 9/26/07_ NMC NMC I-10 WL P.rivilege(s) Clainietl --`WP A /C, W/P, TPM Document related to litigation. Document concerning Eegal advice and including confidenti :.: _ ommunicatians between client and attorney. Document _ related to litigation. T 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 communicat'r'ons 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 cient and attorney. Document related to litigation. Document concerning legal advice and 27-2 S /21/01 NMC WL A /C, W/P, TPM 27-3-4 1 11/14/01 WL NMC A /C, W/P, TPM I 27-5 S /2/01 NMC WL A/C, WJP, TPM 27.6 11/ 13/00 NMC WL A /C, W/P, TPM 27-7 10/ 16/00 NMC WL _ A/C, W/P, T'PM ' 27-8 ^ ^ l^ ^ ^ Z7-9 9 /12/00 NMC WL A /C, W/P, TPM _ 5 / 30/00 NMC WL A /C, W/P, TPM P ^^ . i Ref :? .. Date .. ,. .. '^' Author{sJ ^... ^. . _ ._ Rec 's^pient ( s) ^.^ ^-^^ Description ^ Rriv^lege(s) . CJaimed^^: 27-10 5/16/00 WL NMC 28-1 10/4/OZ NMC WL 28-2 9/30/02 ' NMC _ __ WL includin ronfldeniial communications between client and attorney , Document related to litigation. Document concerning Icgal 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. Dacurnent related to litigation. Document concernint; legal advice and including confidential communications between client and attorney . Document related to ]itigatian. A /C, W/i^, 7PM, A/C, W/P, TpM A /C, W/P, TPM _ 28-3 9 / 28/02 NMC WL 28-4 4/ 17/02 NMC WL 28-5 8 /13/01 NMC WL Z8-6 ^ ^ ^ ^ ,,^ .. 28-7 ^- ^^/^ i 8 /28/00 NMC WL 6 / 5/00 NMC WL Document concerning legal advice and including confidential comnlunitations between client and attorney . Document related to litigat'san. 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 A /C, W/P, TPM A /C, WJP, TPM A/C, W/P, FPM A/C, W/P, TPM A /C, W/P, TPM ^. Ref ^ ^I)ate Author(s) Recipierif(s). ^^ Descriptldn :. ^ Privilege(s) Y 2i3,$ ._ NMC WL 5/31/00 29-1 9/13/00 NMC ^ WL Z9-2 4/13/00 NMC WL 30-1 30-z 303 30-4 10/13/04 10/11/04 Honesty & Patent Honesty & Patent PJE PJE including con#identiai communications between client and attorney. Document related tv litigation, Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning legal advice and including cvrsfidential communications between client and attorney. _ Document concerning legal advice and including con#idential communications between client and attorney. __ Document related to litigation, Document related to litigation, r A/C, W/P, TPM AC AC WP WP 10/13/04 10/6/04 30-5 30-5-7 10/19/02 10/18/02 PJE 5e-Chang Kang, Korean patent Counsel NMC NMC Honesty & Patent NMC Document related to litigation, Document related to litigation. WP WP YPY YPY, WL 30-8-9 10/17/02 NMC YPY, WL L. ^^^ ^^ ^^ i°^^i ^ -^..^ 34-1011 30-1213 20/17/02 9/25/02 YPY NMC NMC YPY, WL 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 concerning legal advice and including confidential communications WP WP AC WP AC, WP ·itef D,ate . ^° . Author( s) ^ · ^ Recipient(s) ^ >]escription^ .. ^ ^ Prlvilege(s} . Claimed . 30-14 30-15 30-16 30-1719 30-20- 7/x9/02 7/7.9/02 4/17/02 12/29/01 12/26/01 1x/25/01 12/24/01 12/14/01 12/14/07. IZJ9/01 YPY YPY YPY YPY NMC T NMC __ NMC NMC NMC' NMCi YPY YPY YPY YPY NMC NMC between client and attorney, Document related to litigation. __ Document related to lirigation. Document related td litigation. Document related to litigation. Document related to litigation. ^ Document related to litigation. Document related to litigation. Documentrefatedtofitigatlan. Document related to Iltigation. Document related to litigation. Document related to litigation. Document related to litigation, Document related to litigation. WP _ _ WP WP __ - WP WP WP WP 30-21 30-22- Honest & Patent__ _ YPY NMC NMC NMC NMC YPY YPY _ Z3 30-24 30-25· 2& 30-2732 30-33^_ __ RA WP WP WP WP WP 11/15/01 13/15/01 34 30-3537 30-38 30-3940 31-1 _. . 11/14/01 11/1/01 10/4/02 NMC Honest & Patent NMC Honest & Patent NMC -Wl __ . 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 legs! advice and including confidential communications between client and attorney. Document related to Iltigation. Document concerning legal advice and WP WP ^ A/C, W/P, TPM ^^ ^^ ^^ r'°^°`1 ^ 31-Z 9/30/02 NMC Wl. A/C, W/P, TPM i A/C, W/P, TPM 31.3 9/26/02 NMC WL Ref Date ,... ^ Author(s) _ , ^ ,.^ ^l^ecipient (s) ^flescriptian 31-4 9/17/02 NMC WL 31=5 8/13/01 NMC Wi ^. 31-6 8/28/00 NMC WL ^ including confidential communications between client and attorney. Document related to litigation, Document concerning legal advice and including confidential communications between client and attorney. u owment 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 confidential communications k^etween client and attorney. Document related to litigation. Document concerning legal advice and __ Privileges} `Claimed I A/C, W/P, TPM A/C, W/P, TPM __ A/C, W/P, TPM 31 -7 10/4/02 NMC WL ^ __ A/C, W/P, TPM 31-$ 6/5/02 NMC WL 31-5 5/31/07. NMC WI_ ^ 32 10/29/2002 NMC WL 33 :.^ t 12/27/2002 NMC W[. including confidential communications between client and attorney. Document related to litigation, Document concerning fegai advice and including confidential communications between client and atiarney. Document related to litigation. Document concerning legal advice and including Confidential communications between client and attorney, Document related to liti anon. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Documen# concerning legal advice and A/C, W/P, rPM A/C, W/P, TPM A/C, W/P, TpM A/C, W/p, TPM 1 ^Ref^. ^ ^^ Date ' ^ . ^ _ Author ( sj Rec^pierit( s^.^ _ Uescriptidn : ^^ ^ ^ Ri·ivifege(sJ .` Cla^mecE^ _ 34 06 / 12/2003 NMC WL 35 07/22/2003 _ WL _ NMC including confidential communications between client and attorney. Document related to litigation. Document concerning legal^advice and including confidential communications between client and attorney . Document refated to litigation, Document concerning legal advice and including confidential communieat'sons between client and attorney , Document A/C, W/P, TPM _ A/C, W/P, TPM 36 12 / 02/2044 _^ NMC WL ^ 37 12/ 03/2004 NMC , WL WL, NMC 38 12 / 03/2004 WL NMC . _ 39 12 / 03/2004 NMC, WL WL, MC 40 ^X ^ ""^""' ^ ^ :,^ 41 12 / 13/2004 NMC WL 09/17/x005- NMC, WL WL, NMC refated to litigation, Document concerning legal advice and including confidential communications between client and attorney . Document refated to litigation, Document concerning legal advice and including confidential communications between client and attorney. Document refated to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. Oacument 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 A /C, W/P, TPM A /C, LN/P, TPM A/C, W/P, TPM A /C, W/P, TAM Af C, W/P, TPM i i A/C, W/P, TPM 1 Ref ^ ^ :· pate 09/20/2005 ^ . 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 related to litigation . Document concerning legal advice and including confidential communications between client and attorney. Document I Privilege ( s) Clamed - ^ . ^ . -. 42 i 43 44 09/17/200509/23/2005 NMC, WL WL, NMC A/C, W/P, TPM 10/06/2005 } 12/20/2005 NMC WL N/A _ W/P, FPM A/C, W/P, TPM NMC 45 1 1Z/22/Z005 NMC, WL WL, NMC 46 i ^ 02/02/2006 NMC WL _ 47 OZ/08/2006 NMC, WL WL, NMC 4&1 3/3/07 NMC WL ^_ _ _`___ 48-2 ^ ^ 2/26/07 NMC WL 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 confidentia! communications between client and attorney. Document related to litigation. Document concerning legal advice and incuding confidential communications between client and attorney. Oacument related to litigation. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. pacument concerning legal advice and including confidentia! communications between client and attorney. Document related to litigation. A/C, W/P, TPM A/C, W/P, TPM _ A/C, W/P, TAM A/C, W/P A/C, W/P Ref . 4$-3 Aate . .,;.:....... 2/Z6/07 NMC Author ( s) WL Recipient ( s) Description ` .. ^ ^ u 49.1 2J2b/07 ^ WL NMC _ 49-2 2/26/07 WL _ .NMC 49-3 2/2b/07 WL NMC 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 Ittigation. _ Document concerning legal advice and including confidential communications between client and attorney. Document related tolitigation. Document concerning legal advice and including confidential communications between silent and attorney. Document Prlvllege^s} Claimed A/C, W/P A/C, W/P __ A/C, W/P s A /C, W/P 50-1 2/27/07 WL NMC 50-2 2/27/07 WL NMC SO-3 i 2/27/07 WL NMC °^ m !^ ^ t ^ ^ ^^ related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation, bacument concerning legal advice and including confidential communications between client and attorney. Document related tolitigation. Document concerning legal advice and including confidential communications between client and attorney, Document related tolitigation. Document concerning legal advice and A/C, W/P A/C, W/P A/C, W/P 5^ 02/27/2007 NMC WL A/C, W/P, TPM including confidential communications between client and attorney. Document related to litigation. V Ref ^ D^t'E^^ ^ ^ ^Authar( s) .. ..^ WL :, sx .-:' 03 JDZ/ x007 Recipient ( s) ^ ^ ^ Description. NMC 53 03/05/x007 WL NMC 5^4 03/Q6/2007 WL NMC 55 03/06/2007 NMC _ WL Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation. Document ronrerning 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 A/C, W/P, TPM T ^^^ A/C, W/P, TPM A /C, W/P, TPM .A/C, W/P, TPM 56 03/07/2007 WL NMC 57 03/Q7/x007 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 A/C, W/P, TPM A/C, W/P, TPM 58 03/11/x007 NMC WL, VI.S °°^^ 59-1 ^ ^ 3/13/07 WL NMC 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, WJP, TPM A/C, W/P , ·. a ^'^ . Ref ^ .. bate ^ 3/3.3/07 .. , ^ .. WL Author ( s) . ,..., ^ Retip^ent ( s^' _ ,. NMC ..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 59-2 'Atiy^lege(s}`: GlaE^ned^: A/C, W/P .. 50-1 3/13/07 NMC WL A/C, W/P ,^ A /C, W/P _ _ 50-2 3/13/07 NMC WL 61-1 3/17/07 NMC WL, VLS A/C, W/P 61-2 3/17/07 NMC w -^ WL, VL5 A/C, W/P _ 62 43/17/Z007 ' WL NMC A/C, W/P, TPM 63 03/17/2007 WL NMC, VLS ^ 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 advlCe and A/C, W/P, TPM ^` ^ i^ ^ 54 43/17/2007 NMC WL A/C, W/P, TPM including confidential communications between client and attorney, Document related to litigation. ' Ref ^ .^ 65 ^ Date ', Author,'( s^^^^ NMC WL Recipient { s^ , Description =, ^ Privilege{sJ A /C, W/P, TPM 03 / S7/2007 66 03/20/2007 WL NMC, VI_S __ 67 03J20/ 2007 NMC WL 68 43 / 21/2.007 WL NMC, VL5 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. A /C, W/P, TPM _ A/C, W/P, TPM .^ A /C, W/P, TPM 69 03/26/2007 iVMC WL, VLS 70 03/26/2007 WL NMC, VL5 71 03/28/2007 WL NMC, VL5 ' 72 74 03 / 29/2007 03 /30/2007 JLL NMC 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 Eitigation, Document concerning legal advice and incuding confidentia communications between client and attorney . Document re{ated to litigation. Document related to litigation . Document concerning legal advice and including confidential communications between client and attorney. Document A/C, W/P, TPM A/C, W/P, TPM A /C, W/P, TPM W/P, TPM A/C, W/P, TPM r--^-^4 .^ ^ ] Ref ^:^^ ^,...Uate ^ ^ AdtE^or( s) Recipient ( s).: D.escrlptinn _^ related to litigation. Document cancerning legal advice and including confidential communications between client and attorney . Document related to litigation. Document cancerning legal advice and including confidential communications between client and attorney . Document related to litigation. Document concerning legal advice and nclud 'sng confidential communications between client and attorney. pacument related to litigation. _ Document cancerning 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 including confidential communications 1}etween 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; A/C, W/P, TPM . 75 03/30/2007 NMC WL, VL5 76 03/30/x007 WL NMC, VLS A/C, W/P, TPM 77 03/30/2007 NMC WL, VLS, JLL A/C, W/P, TPM 78 03/30/2007 WL NMC, VLS, JLL. A /C, W/P, TPM 79 03/30/x007 NMC WL A/C, W/P, TPM 80 82 03 /30/2007 05 /01/2007 NMC WL VLS, JLL NMC W/P, TPM A/C, W/P, TPM ^83 ^ ^ 05 /01/2007 NMC WL A/C, W/P, TPM ^'E 84 OS /03/2007 NMC WL A /C, W/P, TPM ^ tl i ' Ref . :' ':^nate Author ( s) ^^ ., ^ .;: ^ Re[ipient ( sj Description between client and attorney, Document . Pri^ilege(sj 85 05 /09/Z007 WL NMC $5 05/18/2007 NMC WL 87 07/04/Z007 NMC WL __ 88 10/02 /2007 NMC WL _ 84 10 /D2/2007 WL NMC 9D 10/03/2007 WL NMC 9J, 1D/05/2007 NMC WL ^^ f;"^ ^ 92 10 /05/2007 WL NMC related to litigation. Document concern "sng legal advice and including confidentia communications between client and attorney . Rocument related to l itigation. Document concerning legal advice and including confidential communications between client and ..t^arney. Dacument related to litigation. Rocument 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. Document concerning legal advice and including confidential comrnunlcations 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 . Rocument related to litigation. Document concerning legal advice and including confidential communications A/C, W/P, TPM A/C, W/P, TPM A /C, W/P, TPM A/C, W/P, TPM A /C, W/P, TPM A/C, W/P, TPM A/C, W/P, TPM A/C, W/P, TPM i ^1 Ref Date . Author ( s) ·^ Recipient(s) ... D"escription. between client and attorney . Document related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. ^ Priwiege{s) ''.Claimed 93 1Z / 17/2007 NMC WL A/C, W/P, TPM 94 06/11/Z 008 WL NMC 95 06 / 14/20D8 NMC WL _ 95 10/26/Z008 Christin Ciao NMC 97 10/ Z7/Z008 WL NMC 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 itigatian. 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 i ^_ ^^ ^^

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