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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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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