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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W x y Dockets.Justia.com PERFORMANCE PRICING, INC. v. GOGGLE, INC., ET AL, PrieePlay's Privilege Lag (as of May 29, 2009) 9 Key: AC =attorney-client privilege WP =work product privilege MF =misfiled "trial"=trial in Performance Pricing, Inc. v. Google , Inc., et al.; "litigation "= Performance Pricing, Inc. v. Google, Inc., et al.; "patent "= US Patent Na. G,978,253; F^ mW Z C^ W Ld TS =trade secret Date AutltnrlSencler Recipient # of a es P 21941 2194$ Bates Labeled in Error. Description Bates # Privilege Asserted 3/19/2407 Wayne Lin Henry Bunsow and Denise DeMary of 11 Email thread concerning patent prosecution and infringement related to litigation for the P 2395521366 AG, WP 1·fiowrey, LLP not dated Wayne Lin purpose of legal advice and including confidential communications between client and attorne . Neel Chatterjee of Orrick Wayne Lin and Henry Bunsow 3 Letter cancerning patent prosecution for the P 21967AC purpose a Eegal advice and including 13 confidential communications between client and attorne . Email thread concerning patent prosecution for the purpose of legal advice and including confidential communications between client 21969 P 2197021982 AC fl 3/28/2007 Denise DeMory and attorne , 9128105 Wayne Lin Ron 5choenbaum of Knobbe Martin 9 Email thread concerning patent assignment for the purpose of legal advice and including confidential communications between client and attorne . P 2198321993 AC P 2200322019 Bates Labeled in Error. 512 512 0 0 7 Cheryl Watson of Orrick Neel Chatterjee Wayne Lin; cc Mark Sheen of Orrick Wayne Lin 2 Email thread concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorne . Email thread cancerning litigation representation by Orrick Herrington 8, Sutcliffe LLP for the purpose of legal advice and 'tncludin confidential communications P 2202222023 P 2202422025 AC 41!012007 2 AC i --^ PERFORMANCE PRICING, INC. v. GOOGLE, INC., ET AL. PricePiay's Privilege Log (as of May 29, 2009) Date Author/Sender Recipient # of h e5 Description Bates # Privilege Asserted M rn }--^ ^W ^ C^ ^^ t_.I....1 L^..._ between client and attorney, 411 012 0 0 7 Wayne Lin reel Chatterjee 2 Email thread concerning patent litigation for the purpose of legal advice and including P 2202622D27 AC, WP conidential communications between client and attorne , P 22028Bates Labeled in Error, 2122!2007 Mark Shears Wayne Lin 1 Email thread concerning patent prosecution far the purpose of legal advice and Including confidential communications between client 22D36 P 22037 AC and attorne . 1D/312DD6 Cheryl Watson Wayne Lin; cc Mark Skean 3 Email thread concerning patent prosecution for the purpose of legal advice and including confidential communications between client and attorne , P 22038· 22D4D AC 517/20D6 Wayne L'sn Mark Skean 3 EmaiE thread concerning patent prosecu#ion for the purpose of legal adv'sce and including confidential communications between client and attorne , P 22D6$22070 P 2207122099 P 22115· 22918 AC Sates Labeled 'sn Error. 21712DD7 Neel Chatterjee Wayne Lin 2 Email thread concerning patent litigation for the purpose of legal advice and including confidential communications between client and attorne , AC, WP 1 11312 0 0 6 Mark Skean Wayne Lin 3 9/7/2006 1 7/1712D06 Cheryl Watson Wayne Lin; cc Mark Skean Wayne Lin 2 Ema':I thread concerning patent prosecution for the purpose of legal advice and including confidential communicat'sons between client and attorne , Email thread concerning foreign patent application for the purpose of legal advice and including confidential communications between client and att me , P 2211722119 P 22120· 22121 P 2272222127 AC AC Mark Skean 6 Email thread concerni g foreign pa#ent a lication for the ur ose of le al advice AC PERFORMANCE PRICING, INC, v, GOOGLE, INC., ET AL. i'ricePi^y's Privilege Log (as of May 29, 2409} Date AutiiorlSender Recipient # aF a es Description Bates # Privilege Asserted 8/15/20D6 Mark Shean Wayne Lin; cc Neel Chatterjee 2 and including confidential communications between client and attorne , Email thread concerning licensing for the purpose of legal advice and including confidential communications between client l^ W P 22128· 22129 AC Z C `^ W f^ 711312pD8 Mark Shean Wayne Iris and Neel Chatterjee 1 and attarne , Emai3 thread concerning licensing for the purpose of legal advice and including confidential communications between client and attorne . Email thread concerning licensing and patent prosecution for the purpose of legal advice and including confidential communications between client and attorne . P 2213D AC 6!212006 Karen Mudurian of Orrick Neel Chatterjee, Wayne Lin; cc Mark Shean and Mitchell Zuklie of Orrick 5 P 2213122135 AC 5123!2006 Nee[ Chatterjee Wayne Lin and Mark Shean Neel Chatterjee, Mark Shean ; ec Wayne Lin Neet Chatterjee and Mark Shean 2 Email thread concerning licensing for the purpose of legal advice and including confiders # ial communications between client P 2216822187 P 22170 AC and attarne . 5/3/2006 Karen Mudurian of Orrick 1 Email thread concerning licensing for the purpose of legal advice and including confidential communications between client and attorne . Email thread concerning licensing far the purpose of legal advice and including AC _._.. 4/24/2006 Wayne Lin 1 P 22198 AC confidential communications between client 4/24/2006 Wayne Lin Neel Chatterjee ^ and attorne . Document concerning licensing for the P 22199AC purpose of legal advice and including confidential communications between client and attorne . 4/2412DD6 Wayne Lin Neel Chatterjee 3 222Q5 P 2220822266 AC Document concerning'licensing far the purpose of legal advice and including con{idential communications between client and attorne , PERFORMANCE PRICING, INC. v, GOOGLE, INC., ET AL. l'ricePlay's Privilege Log (as of May 29, 2009} Date 4/24/2006 Author/ Sender ^ Recipient Wayne Lin Neel Chatterjee 1 # of a es Description Document cancern'sng licensing for the purpose of legal advice and i ncluding confidential communications between client Bates # P 22269 Privilege Asserted AC r^ H_ ~^ W ^ C,^ :=C ^C ^ r^ and attorne , 4118/2006 Karen Mudurian Mark Shean , Neel 1 Email thread concerning licensing far the P 22255 AC Chatterjee ; cc Wayne Lin 4/18/2006 Mark Shean Wayne Lin 4 purpose of legal advice and inc#uding confidential communications between client and attorne , Email thread concerning patent prosecution ^' 22266AC or the purpose of legal advice and including 4/12/2006 Caren Mudurian Wayne Lin, Neel Chatterjee; cc Mark Shean Wayne Lin, Neel 2 confidential communications between client and attorne . Email thread concerning licensing for the purpose of legal advice and including confidential communications between client and attorne , Email thread concerning licensing for the 22269 P 2227022271 AC 4/12/2006 c Karen Mudurian 5 P 22281- AC Chatterjee, Mark Shean 4/6/2006 Neel Chatterjee Wayne Lin and Mark Shean 3 purpose o Segal advice and including confidential communications between cl'sent and attorne , Ernail thread concerni g licensing for the purpose of legal advice? and including confidential communications between client and attorne Email thread concerning licensing for the 22285 P 2228622288 AC 4!412008 Karen Mudurian Neel ChatterJee , Mask 1 P 22289- AC Shean , Mary Smith of Orrick ; cc Wayne Lin ;4!4!2006 Mark Shean Wayne Lin 1 purpose of legal advice and including confidential communications between client and attorne , Email thread concerning licensing for the 22294 P 22295 AC purpose of legal advice and including confidential communications between client and attorne . Mark Shean Wayne Lin 2 Document concerning licensing far the purpose of legal advice and including confidential communications between client and attorne , P 2229622297 AC f PERFGRMANCE PRICING, INC. v. GOGGLE, INC., ET AL. PricePlay's f'rivilage Log (as of May 2^1, 2U09) Date Author/Sender Recipient # of a eS ^-'""" Description Bates # Privilege Asserted J M Email thread concerning licensing and patent prosecution for the purpose of legal advice and including confidential corrtmunications between client and P 2228822300 AC l^ W = C^ ^^ L..LI r^ 4141200& Mark Sheen Wayne Lin 3 attorne , 212 812 0 0 6 S_ Neel Chatterpee Wayne Lin 1 Email thread concerning licensing far the purpose of legal advice and including confidential communications between client and attorne . P 22309 3/27/2006 Mark Sheen Wayne Lin 10 Email thread concerning patent prosecution for the purpose of legal advice and including Ganfidentldl COmmUniGatiOnS between Cl'sent P 22308 AC Bates Labeled in Error. AC P 2231022319 and attorne , 3/15/2006 Mark 5hean Wayne L'sn and Nees Chatterjee 3 Email ttsread concerning patent prosecution and licensing for the purpose of legal advice and including confidential communications between client and attorne . P 2231222319 P 2232022322 Bates Labeled in Error. AC 3!2712006 Mark Sheen Wayne Lin 2 Email thread concerning patent prosecution for the purpose of legal advice and including P 2232322324 AC confidentiaE communications between client and attorne . P 22325414/2006 Karen Mudurian Wayne Lin, Mark Shear, Neai Chatterjee 1 Email thread concerning licensing for the purpose of legal advice and including confidential communications between client 22341 P 22377 Bates Labeled in Error, ^ AG 211 512 0 0 6 Karen Mudurian Wayne Lin; cc Neei Chatterjee, Mark 2 and attorne . Email thread concem'tng licensing for the purpose of legal advice and including P 2238122382 AC Sheen confidential communications between client and attorne , P 22403Bates labeled in Error, . ^ PI~RF4RMANCE nRl'CENG, ING v. GOOGI.,E, INC., ET AL. PricePlay`s Privilege Log (as of May 29, 2448) Date Autllur/Senc#er Recipient # ui' a es Description Bates # Privilege Asserted 22425 P 2241622425 bates Labeled in Error, ^\ F--mW Z C.^ XQ L.^i GL Bates Labeled in Error, AC, WP . 2!11!200& _. reel ChatterEee Wayne Lin; cc Mitchell Zuklie, Jim Black and Mark Shean of Orrick Wayne Lin 13 Email thread concerning patent litigation and licensing for the purpose of legal advice and including confidential communications between client and atiorne , Email thread concerning foreign patent P 2244622455 P 2249822508 P 22579- l-iiroyuki Kurihara 4 AC application for the purpose of legal advice and including confidential communications between client and attorne . 2 22582 P 22602Bates labeled in error- 22603 c Irrelevant. ,^ ^' a ^4

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