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 x Dockets.Justia.com UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS Performance Pricing, Inc. Plaintiff, v. Googie, Inc. et al., Defendants. 2:07-cv-432 (LEDj REVISED PRIVILEGE LOG CORRESPONDING T0:1) SUBPOENA COMMANDING NON-PARTY NEAL M. GOHEN TO PRODUCE DOCUMENTS;.AND 2} SUBPOENA COMMANDING NON-PARTY VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS 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. Ali 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 Neal M. Cohen; "WL" means Wayne Lin; "VLS" means Valerie L. Sarigumba, wha was at al) relevant times an associate attorney at Vista--IF-Eaw Group; "JLL" means Jocelyn L. Lee, who was at all 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 , wha was at a!I relevant times a partner at Lyon & Lyon LLP; "JT" 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, 5akaguchi & English LLP; "YPY" means Yeo-Pyo Yoon, who was at all relevant times an attorney at Honesty & Patent; PAG E ^..^?Z._ ^^^^ ^^ "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. EXHIBIT __J^ PRGE _-. ^^^ . Ref 1-1 bate 8/2/2001 NMC Author ( s) WL Recipient(sy Description Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between Privilege(s) Claimed A/C 1-2 8/13/01 NMC WL A/C 1-3 3/29/01 NMC WL client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for A/C 1-4 1/12/01 NMC WL A/C the purpose of legal advice and including confidential communications between 1-5 2/20/01 NMC WL client anrf attorney. Letter concerning patent prosecution for , A/C the purpose of legal advice and including confidential communications between client and attorney. 1-5 2/27/99 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including A/C confidential communications between client and attorney. 1-7 1/3/01 NMC WL Letter concerning patent prosecu#ion for the A/C 1-8 10/1/01 NMC WL purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client A/C ^ ^ ^ C'^7 ^ .^. ^^ Re# Date Author ( s) Recipient ( s) and attorney. Description Privilege(s) Claimed A/C 1-9 12/13/00 NMC WL Letter concerning patent prosecution for the 1-10 11/15/03. NMC WL purpose of Segal advice and including confidential communications between client and attorney, Letter concerning patent prosecution for the purpose of legal advice and including AJC 1-11 4/2/01 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C confidential communications between client and attorney. 1-12 7/28/00 NMC WL Letter concerning patent prosecution for the A/C purpose of legal advice and including confidential communications between client and attorney. 1-13 5/SO/01 NMC WL ' 1-14 10/14/02 NMC WL I Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C A/C 1-15 8/2/01 NMC WL 1-16 11/30/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client _ A/C A/C .^ ;;a^^ ^^ ^ ^" ^^ i' Re# Date Authors} Recipient(s) Description Privilege(s) Claimed 1-17 .10/27/99 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C 1-18 6/7,/00 NMC WL confidentia! communications between client and attorney, Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. A/C 1-19 4/18/02 NMC WL 1-20 10/16/01 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. A/C A/C 1-21 3/6/02 NMC WL 1-22 7.0/9/01 NMC WL 1-23 7/5/00 NMC WL 'r Letter concerning patent prosecution for the purpose of legal advice and including confidentia[ communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal aavice and including confidential communications between client A/C A/C A/C 1-2^} 2/18/00 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C "^ E.^ ^^ ^ n1 W ^^ °..'^ .:. Ref` bate Author { s) Recipient ( s) Description Privilege{s} Claimed A/C 1-25 8/13/01 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including 1-26 4/17/02 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. A/C 1-27 7/31/02 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C 2-5 8/2/01 NMC WL 2-6 8/13/01 NMG WL 2-11 3/1.7/07 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C, W/P A/C, W/P A/C, W/P 3-1 S/7/02 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the A/C 3-2 9/10/01 NMC WL A/C purpose of legal advice and including confidential communications between client ^"7 ^ rn ^ ^' ^c Ref bate Author(s) Recipient ( s^ Description and attorney. Letter concerning paten# prosecution for the purpose of legal advice and including co nfidentia[ communications between client and attorney. Privilege(s) Claimed A/C 3-3 x/10/01 NMC WL 3-4 8/21/41 NMC WL Letter concerning patent prosecution forthe purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the A/C 3-5 NMC WL A/C purpose of legal advice and including confidential communications between client 3-6 $/21/01 NMC WL 3-7 5/2/01 NMC WL 3-8 4/30/02 NMC WL and attorney. Letter concerninb patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. _ Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution forthe purpose of legal advice and including A/C A/C A/C 3-9 4/3/01 NMC WL 3-10 4/6/01 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C A/C confidential communications between client ^' ^7 ^ ^^ °^ 11. Ref Date Author (sj Recipient ( s) Description and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidentia[ communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidentia! communications between Client and attorney. Privilege(s) Claimed A/C 3-11 4/6/0#. NMC WL 3-1z 4/6/01 NMC WL A/C 3-13 3/z0/01 NMC WL A/C 3-14 1 /z^ /a 1 NMC WL A/C 3-15 11/30/00 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution far the A/C 3-16 11/13/00 NMC WL A/C purpose of legal advice and including confidential communications between client and attorney. 3-17 11/S/00 NMC WL Letter concerning patent prosecution for the A/C purpose of legal advice and including confidential communications between client and attorney. 3-18 11/6/00 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C ^ rn^ T^ _ Ref Date A^thar ( s} Recipients] İescription Privileges} Claimed A/C 3-19 1p/^6/00 NMC WL and attorney, Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the 3-20 9/28/00 NMC WL A/C purpose of legal advice and including confidential communications between client 3-2^ 9/12/00 NMC WL 3-22 6/5/00 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including A/C A/C 3-23 6/5/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C 3-24 x/30/00 NMC WL 3-25 1/76/00 NMC WL 3-26 4/24/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney, Let#er concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C A/C A/C confidential communications between client [^"'1 ^' ^ ^ ^_ ^W ^---- ^ ^' . Ref Date Author ( s) Recipient(s^ Description and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney, Letter concerning patent prosecution for the purpose of legal advice and including Privilege(sj Claimed 3/23/00 NMC WL A/C 3-27 3-28 3/9/00 NMC WL A/C 3-29 2/9/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C confidential communications between client and attorney. 3-3 ]. 1/26/00 NMC WL 3-33 1/26/00 NMC WL Letter concerning foreign patent rights for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent rights for the purpose of legal advice and including confidential communications between client A/C A/C 3-34 3/17/00 NMC WL 3-35 12/6/99 NMG WL and attorney. Letter concerning foreign patent rights for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C A/C 3-36 11/29/99 NMC WL A/C confidential communications between client l^ ^ m^ ,^;^, ^6 I Ref Date AutEtor ( s} Recipients} Description and attorney. Letter concerning foreign patent^application for the purpose of legal advice and including confidential communications between client and attorney. Privileges} Claimed A/C ^F-1 10/1b/01 NMC WL 4-2 $/14/01 NMC WL 4-3 4/5/01 NMC WL Letter Concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application A/C A/C 4-4 1/19/01 NMC WL A/C 4-5 6/2&/00 NMC WL for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application A/C 4-6 6/1/00 NMC WL A/C 4-7 2/15/00 NMC WL for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including A/C 4-8 12/21/99 NMC WL Confidential comm^^nications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential Communications between client A/C ^ ^ ^ Z W °"^ i^ Ref Date Author ( s) Recipient(s) Description and attorney, Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between clierst l^ri^ilege(s) Claimed A/C 4-9 12/13/99 NMC WL 5-1 4/17/02 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. A/C 5-2 8/13/07. NMC WL Letter concerning patent prosecution for the A/C 5-3 8/28/00 NMC WL purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney, Letter concerning patent prosecution for the purpose of legal advice and including A/C 5-^ 6/5/Ofl NMC WL A/C confidential communications between client and attorney. b-1 7/9/01 NMC WL Letter concerning Japanese patent application far the purpose of legal advice and including confidential communications between client and attorney. A/C 6-2 3/2/01 NMC WL Letter concerning Japanese patent application for the purpose of legal advice and including confidential communications between client and attorney. A/C 6-3 3/z/O1 NMC WL Letter concerning Japanese patent application for the purpose of legal advice and including confidential communications A/C ^ ^ m ^, -^--- ^ Ref Date Author(s) Recipient { s) i ` WL Description between client and attorney. Letter concerning Japanese patent application for the purpose of legal advice and including confidential communications Privilege{s) Claimed A/C 6-4 '7/12/00 NMC 6-5 ^/11/00 NMC WL 6-6 4/iz/00 NMC WL between client and attorney. Letter concerning Japanese patent application for the purpose of legal advice and 'sncluding confidential communications between client and attorney, Letter concerning Japanese patent application for the purpose of legal advice and including confidential communications A/C A/C 7-1 NMC NMC NMC NMC NMC NMC ^/Z7/00 1/Z/OZ NMC NMC HO HO HO HO HO HO HO WL 7-2 7-3 7-4 between client and attorney. Document related to Japanese patent application. Document related to Japanese patent application. A/C A/C A/C A/C A/C A/C Document related to Japanese patent application. 7-5 7-6 7-7 8-1 Document related to Japanese patent application. Document rela#ed to Japanese patent application. 8-2 ^ ^ ^ ^. ""^^ ^ ^ W °^ 4/17/OZ NMC WL Document related to Japanese patent application. Letter related to Japanese patent application. Letter concerning Korean patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning Korean patent application A/C A/C A/C Ref Date Author ( s) Reciplent ( s^ Description for the purpose of legal advice and including confidential communications between Client and attorney. Pri^iiege(s^ Claimed $-3 4/17/02 NMC WL Letter concerning Korean patent application A/C for the purpose of legal advice and including confidential communications between client and attorney, 8-4 NMC WL Document concerning Korean patent A/C application far the purpose of legal advice and including confidential communications between client and attorney. ... 8-5 4/17/02 NMC WL Letter concerning Korean patent application for the purpose of legal advice and including A/C $-5 4/25/02 NMC WL confidential communications between client and attorney. Letter concerning Korean patent application for the purpose of legal advice and including confidential communications between client and attorney. Document related to Korean patens A/C 9-1 9-2 NMC YPY A/C 7.2/14/01 3/2.1/00 NMC NMG YPY WL application. Document related to Korean patent application. Document concerning legal advice and A/C A/C 10-1 10-2 3/21/00 NMC WL including confidential communications between client and attorney. Document concerning legal advice and including confidential communications A/C 10-3 12/13/99 NMC WL between clien# and attorney. Dacumen# concerning legal research for the purpose of legal advice and including confidential communications between client A/C ^ ^ ^ Z mw ^^ ^ ^^ Re# Date Author(s) Recipient ( s) and attorney. Description Privilege(s) Claimed A/C 10-4 11/10/99 NMC WL Document concerning licensing for the purpose of legal advice and including confidential communications between client and attorney. 10-5 9/28/99 NMC WL Document Concerning licensing for the A/C ' 10-6 9/25/99 NMC WL purpose of legal advice and including confidential communications between client and attorney. Document concerning assignment far the purpose of legal advice and including confidential communications between client and attorney. Document concerning licensing for the A/C 10-7 9/24/99 NMC WL A/C 11-1 3/17/07 NMC WL 11-3 7/S/00 NMC WL purpose of legal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidential communications between client and attorney. Document concerning legal invoices including confidential communications A/C A/C 11-4 7/1/00 NMC WL between client and attorney. Document concerning legal invoices including confidential communications A/C 11-5 5/4/00 NMC WL 11-6 ._.. 7r .^C ^7 = P"r'I ^ ^^ .-^ 3/13/00 NMC WL between client and attorney. Document concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney, Document concerning legal advice and including confidential communications A/C A/C Ref Date Author (s) _ Recipient(s) Description between client and attorney. _ Privilege(s) Claimed 11-7 3/13/00 NMC WL 11-8 2/16/00 NMC WL Document concerning #areign patent application for the purpose of legal advice and including confidential communications between client and attorney. Document concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Document related to Taiwanese patent application. A/C A/C 11-9 2/10/00 NMC Trademark attorney in Taiwan A/C 11-10 12/31/99 NMC WL Document concerning legal invoices including confidential communications A/C between client and attorney. 11-11 12/14/99 NMC WL Letter concerning research for the purpose A/C Ik 17.-12 11/10/94 NMC WL of legal advice and including confidential communications between client and attorney, Letter concerning licensing for the purpose of legal advice and including eonfidential communications between Client and attorney. A/C 11-13 9/27/99 NMC WL 1i-14 9/28/99 NMC WL 12 6/14/99 X ^ 55 WL, NMC Document concerning representation far the purpose of legal advice and including confidential communicatians between client and attarney. Letter concerning assignments for the purpose of Segal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidential communications A/C A/C A/C, W/P ^ ^ rn w, ('' 1 ` Ref Date Author ( s) Recipients} Description between client and attorney. Document concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Document related to litigation. Document concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Document Privileges} Claimed A/C, W/P 13 06/10/1999 10/04/2002 WL, NMC, SS WL, NMC, 5S 14 06/14/1999 SS NMC, WL A/C, W/P "^ _. 15 Ofi/28/1999 WL NMC related to litigation. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation. A/C, W/P ^^ 16 11/10/1999 NMC WL Document concerning legal advice and including confidential communications between client and attorney. DOCUrIIEnt A/C, W/P 17-1 5/7/02 NMC WL related to litigation, Letter concerning patent prosecution for the A/C 17-2 9/19/01 NMC WL 17-3 8/21/01 NMC WL purpose of legal advice and including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning Natent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution far the ' A/C A/C 17-4 ^' ^ ^^ {T='^4 W 1 ^ 4/30/01 NMC WL A/C ^, ^-_ c Ref Date Author ( s) Recipients ) Description purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client Privilege(s) Claimed 17-5 4/6/01 NMC WL A/C 17-6 3/20/01 NMC WL 17-7 9/28/00 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidentiaE communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. A/C A/C 17-8-9 6/5/00 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C and attorney. 17-10 4/24/00 NMC WL Letter concerning patent prosecution for the A/C _ purpose of legal advice and including confidentiaE communications between client and attorney. 17-11- 3/13/00 NMC WL 12 Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C and attorney. 17-1315 2/15/00 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including A/C confidential communications between client and attnrney. 17-16_°^ Ii ^ iC 1/17/00 NMC WL Letter concerning patent prosecution for the A/G, W/P ^ ^ _ ^ 1 '. Ref 1g Date Author { s) Recipient ( s) Destriptian purpose of legal advice and including confidential communicatians between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communicatians between client and attorney. Letter concerning patent prosecution for the purpose of legak advice and including confidential communications between client Privilege(s) Claimed 17-20 11/29/94 NMC WL A/C 1$-1 9/10/01 NMC WL A/C and attorney. 18-2 4/23/01 NMC WL Letter concerning patent prosecution for the A/C purpose of legal advice and including confidential communications between client 18-3 4/6/01 NMC WL and attorney, Letter concerning patent prosecution for the purpose of legal advice and including confidential communicatians between client and attorney. A/C 18-4-5 11/6/00 NMC WL 18-6-7 3/13/00 NMC WL 18-811 2/16/00 NMC WL 18-12- 1/26/00 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including tanfidential communications between client and attorney, Letter concerning foreign patent application or the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the A/C A/C A/C A/C t^ ^ t"^'1 ^ r Ref 14 Date Author ( s) Recipient(s) Description purpose of legal advice and including confidential communications between client and attorney. Privilege(sj Claimed 1$-1517 12/6/99 NMC WL Letter concerning patent prosecution forthe purpose of legal advice and including A/C 19 12/13/1999 01/17/2002 NMC WL confidential communications between client and attorney. Document concerning patent prosecution for the purpose of legal advice and including confidential communications A/C 22 12/14/1959 NMC WL between client and attorney. Letter concerning legal research for the purpose of legal advice and including confidential communications between A/C, W/P client and attorney. Document related to litigation, 23-1 9/3.0/01 NMC WL Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between A/C 23-2 4/23/01 NMC WL client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C 23-3 4/6/01 NMC WL 23-4-5 11/6/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning toreign patent application for the purpose of legal advice and including confidential communications between client and A/C A/C "^' ^"`1 ^r ^^ I^ `^' °°'--9 ^'I^` 1 Ref ]ate Author ( s) Recipient ( s) Description attorney. Letter concerninb `oreign patent Privileges} Claimed A/C 23-6-7 3/13/00 NMC WL application for the purpose of legal advice and including confidential 23-8 3/9/00 NMC WL communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent A/C 23-9- 2116/00 NMC WL A/C 11 application for the purpose of legal advice and induding confidential communications between client and attorney. Letter concerning patent prosecution for 23-12- 1/26/00 NMC WL A/C 14 the purpose of legal advice and including confidential communications between 1/29/01 NMC WL client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C Z4-1 24-2 11/30/00 NMC WL 24-3-4 6/S/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C A/C 24-5 ^' `^s 7 = m^ ..... ^^ ^ ^{ 3/23/00 NMC WL confidential communications between client and attorney. Letter concerning patent prosecution for the A/C Ref Date Author ( s) Recipient(s) Description Privilege(s) Claimed purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application forthe purpose of legal advice and including confidential communications between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including 24-6-7 3/13100 NMC WL A/C 24-$-10 2/16/00 NMC WL A/C 24-11-13 2/9/00 NMC WL A/C confidential communications between client and attorney. 24-14-15 2/5/00 NMC WL Email chain concerning patent prosecution A/C 24-16 2/5100 NMC WL for the purpose of legal advice and including confiden#ial communications between client and attorney, _ Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client _ A/C 25-1 9/26/02 NMC WL 25-2 7/9/01 NMC WL and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney, Letter concerning Japanese patent application for the purpose of legal advice and including confidential communications A/C A/C 25-3 ^' ^ ^ __ ^W ^.. ^ 3/2/01 NMC WL between client and attorney. Letter concerning Japanese patent A/C Ref date AutE^or ( s^ Recipient(s) Description application for the purpose of legal advice and including confidentiaE communications between client and attorney. Letter concerning Japanese patent application for the purpose of legal advice Privilege(s^ Claimed 25-4 7/12/00 NMC WL A/C 25-5 4/7.1/00 NMC WL 25-6-7 3/13/00 NMC WL and including confidential communications between client and attorney. Letter concerning Japanese patent application for the purpose of legal advice and including confidential communica#ions between client and attorney. Letter concerning foreign patent application for the purpose of legal advice and including confidential communications between client and attorney. Email concerning Japanese patent A/C A/C 25-8 10/$/02 NMC JT, WL A/C 26-1 9/27/02 NMC Ji', WL 26-2-3 9/26/02 NMC JT, WL 26-4 2fi-5 26-6-7 ^' ^'7 = 1-r'l ^ °,....^ 7/2/0 3/2/01 2/28/01 HO JT NMC NMC NMC WO application for the purpose of legal advice and including confidential communications between client and attorney. Email concerning Japanese patent application for the purpose of legal advice and including confidential communications between client and attorney. Email concerning lapanese paten# application for the purpose of [ega[ advice and including confidential communications between client and attorney. Letter concerning Japanese patent application. Emai[ concerning lapanese patent application. A/C A/C A/C A/C A/C Document concerning Japanese patent Ref Date Author ( s) Recipients} application. Description Pri^iiege(s) Claimed A/C A/C A/C A/C 26-8-9 26-1011 26-1214 26-1516 7/12/00 7//x/00 7/5/00 6/22/00 6/21/00 4/21/00 4/21/00 4/21/00 4/17/00 4/11/00 4/7/00 4/11/OD 4/11/00 NMC HO HO HO NMC NMC HO HO NMC NMC HO HO HO HO NMC NMC NMC HO HO NMC NMC HO HO NMC NMC NMC Document conce^ icing Japanese patent application. Document concerning Japanese patent application. Document concerning Japanese patent application, Letter concerning Japanese patent application. 26-1718 26-14 26-20 26-21 Document concerning Japanese patent application, Letter concerning Japanese patent application, Document concerning Japanese patent application. A/C A/C A/C Letter concerning Japanese patent appiication. A/C A/C A/C A/C 26-22 26-2324 26-25 26-26 Letter concerning Japanese patent application. Letter concerning Japanese patent application. Letter concerning Japanese patent application. Letter concerning Japanese patent application. Letter concerning Japanese patent A/C A/C 26-27 26-2829 26-30 26-31- 4/7/00 4/7/00 4/5/00 NMC HO NMC HO NMC HO application. Letter concerning Japanese patent application. Letter concerning Japanese patent application, Letter concerning Japanese patent A/C A/C ^. A/C ^7 Z lm ,^ Ref 33 27-1 Date Author{s) Recipient(s) Description Privilege(s) Claimed A/C application. 9/26/02 NMC WL Leiter concerning trademark application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning trademark application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning trademark application for the purpose of legal advice and including confidential communications between client and attorney. 27-2 $/21/07. NMC WL A/C 27-3-4 11/7.4/07. WL NMC A/C 27-5 5/2/01 NMC WL Letter concerning trademark application for the purpose of legal advice and including A/C 27-6 11/13/00 NMC WL confidential corrimunications between client and attorney. Letter concerning trademark application for the purpose of legal advice and including confidential communications between client A/C 27-7 10/16/00 NMC WL 27-8 9/7.2/00 NMC WL 27-9 5/30/00 NMC WL and attorney. Letter concerning trademark application far the purpose of legal advice and including confidential communications between client and attorney, Letter concerning trademark application for the purpose of legal advice and including confidential communications between client and attorney. Letter concerning trademark application for the purpose of legal advice and including confidential communications between client A/C A/C A/C ^^ ^ ".r. _^ "'.,^ o^ r Ref Date Author ( s) R tipient ( s) Description and attorney, Letter concerning trademark application for the purpose of legal advice and including confidential communications between client and attorney. Privilege(s) Claimed A/C 27-10 5/1b/00 WL NMC 28-1 10/4/02 NMC WL 28-2 9/30/02 NMC WL Email concerning trademark and patent applications for the purpose of legal advice and including canfidential Communications between client and a#torney. Email concerning trademark and patent applications for the purpose of legal advice and including canfidential Communications A/C A/C between client and attorney. 28-3 9/28/02 NMC WL Email concerning trademark and patent A/C applications far the purpose of legal advice and including confidential communications between client and attorney. 28-4 4/17/02 NMC WL 28-5 8/13/01 NMC WL 28-6 8/28/00 NMC WL 28-7 6/5/00 NMC WL Latter concerning patent application for the purpose of legal advice and including confidential communications between client and attorney.. Letter concerning patent application far the purpose of legal advice and including Confidential communications between client and attorney, Letter concerning patent application for the purpose of legal advice and including confidential cnmmunicatians between client and attorney. Email concerning patent application for the purpose of legal advice and including A/C A/C A/C A/C ^z r-n ^ x a ^' ^^ Ref Date Author { s) Recipient ( s) Description confidential communications between client and attorney. Privilege{s) ^, Claimed 28-8 5/31/00 NMC WL Document concerning patent application including confidential communications between client and attorney. A/C 29-1 9/13/00 NMC WL 29-2 9/1.3/00 NMC WL 30-1 30-2 30-3 30-4 10/13/O^l 10/11/04 10/13/04 10/6/04 Honesty & Patent Honesty & Patent PJE 5e-Chang Kang, Korean patent PJE PJE Honesty & Patent NMC Document concerning legal advice and including confidential communications between client and attorney. Document concerning legal advice and including confidential communications between client and attorney. Email concerning Korean patent application, Email concerning Korean patent application. Email concerning Korean patent application. Letter concerning Korean paten# application. A/C ' A/C A/C AJC A/C A/C I I counsel 30-5 30-6-7 10/1.9/02 10/1$/OZ NMG NMC YPY YPY, WL Email concerning Korean patent application, Email concerning Korean patent application for the purpose of legal advice and including confidential communications between client and attorney. Document related to litigation. A/C A/C , A/C 30-$-9 1.0/7.7/02 NMC YPY, WL Email concerning Korean patent application for the purpose of legal advice and including confidential communications between client and attorney. Document related to 30-1011 30-1213 10/17/02 9/26/02 YPY NMC NMC YPY, WL litigation. Letter concerning Korean patent application. Email concerning Korean patent application for the purpose of legal advice and including A/C A/C i;'7 Z li"^ ^ 10^ ^ }Zef Date Author ( s) Recipient(s) Description confidential communications between client and attorney, Document related to litigation. Pri^iiege(s) Gaimed 30-14 30-15 30-16 30-1719 30-2030-21 30-2223 30-24 30-2526 30-2732 7/29/02 7/29/02 4/17/02 12/29/01 12/26/01 YPY YPY YPY YPY Honest & Patent NMC NMC NMC NMC NMC Letter concerning Korean patent application. Letter concerning Korean patent application. Letter concerning Korean patent application, Letter concerning Korean patent application. Letter concerning Korean patent application. A/C A/C A/C A/C A/C 12/25/01 12/24/01 1Z/14/01 YPY NMC NMC NMC NMC YPY NMC ^ YPY YPY YPY YPY NMC 12/14/01 12/9/01 11/15/07. Letter concerning Korean patent application. Document concerning Korean patent application. Letter concerning Korean patent application. Letter concerning Korean patent application. Email chain conc^:^ ^^ing Korean patent application. Letter concerning Korean patent application. A/C A/C A/C A/C A/C _ A/C 30-3334 30-35 30-3637 30-38 30-3940 31-1 11/15/01 11/15/01 11/14/01 YPY YPY NMC NMC NMC Honest & Patent Email concerning Korean patent application. Letter concerning Korean patent application, Email concerning Korean patent application. A/C A/C A/C A/C A/C 11/1/01 10/4/02 Honest & Patent NMC NMC WL Letter concerning Korean patent application. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. 31-2 rn ^^ ^7 = ^W ^_ ^ ^6 i ^^ 9/30/02 NMC WL Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C Ref pate Author ( s^ Reciplent(sJ I)escriptian and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client Privilege(s) Claimed A/C 31-3 9/26/02 NMC WL 31-4 4/17/42 NMC WL and attorney. Letter concerning patent prosecution for the purpose of legal advice and including confidential communications between Client and attorney. Letter concerning patent prosecution for the A/C .,^ ti 31-5 8/13/01 NMC WL A/C 31-6 $/28/44 NMC WI_ ^ purpose of legal advice and including confidential communications between client and attorney. Letter concerning patent prosecution for the purpose of legal advice and including A/C 31-7 6/5/02 NMC WL 31-8 5/31/01 NMC WL confidential communications between client and attorney. Email chain concerning patent prosecution far the purpose of legal advice and including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice and including confidential A/C A/C communications between client and attorney. 3z 10/29/2002 NMC WL Email concerning patent prosecution including confidential communications A/C 33 ^^ ^] ^ ^^ 12/27/2402 NMC WL between client anp attorney. Email concerning patent prosecution and legal invoices including confidential A/C I Ref Date Author(s) Recipient ( s) Description communications between client and attorney. Email concerning Natent prosecution including confidential communica#ions between client and attorney. Email Concerning legal invoices including confidentia! communications between Pri^iiege(s) Claimed 34 Ob/12/2003 NMC WL A/C 35 07/22/2003 WL NMC A/C 36 12/OZ/2004 NMC WL client and attorney. Email concerning patent prosecution far the purpose of legal advice and including confidentia! communications between A/C I client and attorney. 37 I A/C 12/03/2004 NMC, WL WL, NMC Email concerning patent prosecution for 38 1x/03/2004 WL NMC 39 12/03/2004 NMC, WL WL, NiYiC the purpose of legal advice and including confidential Communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal _ A/C A/C advice and including confidential communications between client and 40 12/7,3/2004 NMC WL attorney, Email concerning patent prosecution including confidential communications A/C 41 09/17/200509/2D/2005 NMC, WL WL, NMC between client and attorney. Email concerning patent prosecution far the purpose of legal advice and including confidentia! Communications between Client and attorney. A/C "t^ ^1 ^i 'a ^ i^ U^ l^l i^ !^- Ref 42 Date 09/17/200509/23/2005 Author ( s) NMC, WL Recipient ( s) WL, NMC Description 1=mail chain concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney, Document concerning patent prosecution for the purpose of legal advice and A/C Privilege(s) Claimed 43 10/06/2005 NMC WL AC 44 12/20/2005 WL NMC including confidentia! communications between client and attorney. Email concerning patenE prosecution for the purpose of legal advice and including confidential communications between A/C 45 12/22/2005 NMC, WL WL, NMC ^ 46 02/02/2006 NMC WL client and attorney. Email chain concerning licensing far the purpose of legal advice and including confidential com'municatians between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including A/C, W/P A/C confidential communications between client and attorney. _ A/C 47 02/08/2006 NMC, WL WL, NMC Email chain concerning patent prosecution and licensing for the purpose of legal advice and including con#idential communications between client and attorney. 48-1 3/3/07 NMC WL Email concerning legal invoices including A/C 48-2 x/26/07 NMC WL conidential communications between client and attorney. Email concerning legal invoices and patent prosecution including confidential A/C communications between client and ^^ ^^ i'T'1 W ^ ;^ i Ref Date Authar ( s^ Recipient ( s) Description attorney. Email concerning legal invoices and patent prosecution including confidential communications between client and attorney, Email concerning legal invoices and patent prosecution including confidential communications between client and attorney. Email concerning legal invoices and patent prosecution including confidential communications between client and Privilege(s) Claimed A/C 48-3 2/26/07 NMC WL 49-1 2/26/07 WL NMC A/C 49-2 2/2b/07 WL NMC A/C attorney. 49-3 2/26/07 WL NMC Email concerning legal invaiees and patent A/C 50-1 2/27/07 WL NMC 50-2 2/27/07 WL NMC prosecution including confidential communications between client and attorney. Email concerning legal invoices and patent prosecution including confidential communications between client and attorney. Email concerning legal invoices and patent prosecution including confidential communications between client and attorney. A/C, W/P A/C, W/P 50-3 2/27/07 WL NMC Email concerning licensing and patent prosecution including confidential communications between client and A/C, W/P 51 -^^ ^^ C'"^^ W 02/27/2007 NMC WL ^ attorney, Email concerning patent prosecution and legal invoices including confidential A/C communications between client and 1^ Ref Date Author(s) Recipient(s) Description attorney. Email Concerning Natent prosecution and legs[ invoices including canfidentia! Privi[ege(s^ Claimed A/C 52 03/02/2007 WL NMC 53 03/05/2007 WL NMC communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email concerning patent prosecution for A/C _ ,,^ A/C 54 03/06/2007 WL NMC 55 03/Ofi/2007 NMC WL the purpose of legal advice including confidential communications between client and attorney. Email concerning patent prosecution far the purpose of legal advice including A/C Sfi 03/07/2007 WL NMC confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice including A/C 57 03/07/2007 NMC WL confidential communications between client and attorney, Email concerning patent prosecution far the purpose of legal advice including confidential communications between client and attorney. A/C SS 03/11/2007 NMC WL, VLS 59-1 3/13/07 WL NMC Email concerning patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email concerning prior art for the purpose of legal advice and including confidential communications between client and A/C A/C, W/P ^^ ^7 ^ ^ ^ f 1 ^P ^ ^^ Ref Date Author ( s). Recipient ( s^ Descrip #ian attorney. Email Concerning patent prosecution for the purpose of legal advice and including canfidentiaE cammunications between client Privilegs(s3 Claimed A/C 59-2 3/13/07 WL NMC 60-1 3/13/07 NMC WL 60-2 3/13/07 NMC WL 61-1 3/17/07 NMC WL, VLS 61-2 3/17/07 NMC WL, VLS 62 03/17/2007 WL NMC 63 03/17/2007 WL NMC, VLS and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legaE advice and including confidential communications between client and attorney, Email concerning patent prosecution for the purpose of legal advice and including confidential cammunications between client and attorney. Email concerning patent prosecution for the purpose of legal advice including canfidentiaE communications between client and attorney. Email concerning patent prosecution for the purpose of legaE advice including confidential communications between client and attorney. Letter concerning representation A/C, W/P A/C, W/P _^ i ^ A/C A/C A/C A/C 64 03/17/2007 NMC WL A/C --^ ; ^^ ^^ ^ l^ ^ ^^^ d ^^ i including confidential communications between client and attorney. Ref 65 Date 03/17/2007 NMC Author(s) WL Recipient(s) Description Letter concerning representation including confidential communications between client and attorney. Email chain concerning representation and patent prosecution for the purpose of legal advice including confidential Privilege(s) Claimed A/C 66 03/20/2007 WL NMC, VLS A/C C7 03/20/2007 NMC WL communications between client and attorney. Email chain concerning representation and patent prosecution for the purpose of legal advice including confidential Communications between client and A/C 68 03/21/2007 WL NMC, VLS 59 03/26/2007 NMC WL, VLS attorney. Email chain concerning licensing and patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email concerning infringement for the purpose of legal advice and including A/C, WP A/C, W/P confidential communications between client and attorney. _ 70 03/26/2007 WL NMC, VLS Email concerning infringement for the purpose of legal advice and including A/C, W/P 71 03/28/2007 WL NMC, VLS confidential communications between client and attorney. Email concerning infringement for the purpose of legal advice and including Confidential communications between client and attorney. _ A/C, W/P 72 .. ^ ;^C ^^ [""^I W .^ 03/29/2007 JLL NMC Email concerning patent prosecution including confidential communications A/C ^^ Ref Date Author ( s) Recipient ( s) Description between client and attorney. Email chain concerning licensing for the purpose of legal aavke including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential Communications between client and attorney. _ Privilege(s) Claimed A/C 74 03/30/2007 NMC WL 75 03/34/2007 NMC WL, VLS A/C 76 03/30/2007 WL NMC, VL5 A/C 77 03/30/2007 NMC WL, VLS, JLL A/C _ 7$ 03/30/2007 WL NMC, VLS, JLL Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorney. Email concerning patent prosecution for A/C 79 03/30/2007 NMC WL A/C, W/' 80 03/30/2007 NMC VLS, JLL 82 _,^ m ^^ iii ^ N 05/01/2007 WL NMC the purpose of legal advice and including confidential communications between client and attorney. Emaif concerning patent prosecution including confidential communications between client and attorney. Email concerning patent prosecution for the purpose of legal advice and including confidential communications between client A/C A/C, W/P ._.. ^^ Ref Date Author ( sy Recipient(s^ Description and attorney. Email chain concerning patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Emall chain concerning patent prosecution far the purpose of legal advice including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice including confidential Pri^i[ege(s) Claimed A/C 83 05/01/2007 NMC WL 84 05/03/2007 NMC WL A/C 85 05/09/2007 WL NMC A/C communications between client and 86 05/1$/2007 NMC WL attorney, Email chain concerning patent prosecution far the purpose of legal A/C 87 07/04/2007 NMC WL advice including confidential communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email chain concerning patent A/C 88 10/02/2007 NMC WL A/C 89., t..d Fes'/^ /'^ ' ^ ^ '`y ^ -.^6.-.. 10/02/2007 WL NMC prosecution for the purpose of legal advice including confidential communications between client and attorney. Email chain concerning patent A/C ^r E Ref Date Author( s) Recipient(sj Description Privilege(s) Claimed prosecution for the purpose of legal advice including confidential communications between client and attorney. 90 10/03/2007 WL NMC Email chain concerning patent prosecution for the purpose of legal advice including confidential A/C 91 10/05/2007 NMC WL communications between client and attorney. Emaii chain concerning patent prosecution for the purpose of legal advice including confidential communications between client and A/C 92 10/OS/2007 WL NMC attorney, Email chain concerning patent prosecution for the purpose of legal advice including confidential A/C 93 12/17/2007 NMC WL communications between client and attorney. Email chain concerning patent prosecution for the purpose of legal advice including confidential A/C 94 06/11/2008 WL NMC 95 06/14/2008 NMC WL communications between client and attorney. Email concerning representation and patent prosecution for the purpose of legal advice including confidential communications between client and attorney. Email concerning representation and patent prosecution for the purpose of legal advice including confidential A/C A/C ^ ]C i^ ^ m ^ W -^ ^ ^ ^r EZef Date Author( s) Recipient ( s) Description Privilege(s) ^ Claimec4 communications between client and attorney. Email concerning discovery related to the litigation. Email chain concerning representation and patent prosecution for the purpose 96 97 10/25/2008 10/27/2008 Christie Cho WL NMC NMC W/P, TPM A/C, W/P of legal advice including confidential communications between client and attorney. .^ ^7 ^ t^ ^ ^^

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