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 ExhiUit A Ref Date Anthox ( s) Recipient ( s) WL Description 1 various NMC 2 various NMC N/A Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document related to litigation involving PricePlay, Document concerning Pzivi^ . ege(s) Claimed A/C, W/P, TPM W/P, TPM 3 various NMC WL ^ A/C, W/P, TPM ', 9 various NMC WL 5 various NMC WL 4^ legal advice and including confidential communications between client and attorney. Doc wnent related to litigation .involving PricePlay. Document cancerning legal advice and including confidential communications between client artd attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation involving PricePlay. A/C, W/P, TFM A/C, w/P, TPM ^^ ^^ Page 1 Exhibit A Ref 6 Date Authoz ( s) NMC WL Recipient(s) Description Document r_oncerning Privilege(s) Claimed various A/C, W/P, TPM 7 various NMC Japanese patent counsel 8 various NMC WL 9 various NMC Korean patent counsel 0 i^ c various NMC N/A legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including r_onfidential communications between client and attorney. Document related to litigation involving PricePlay. Document related to litigation involving PricePlay. A/C, W/P, TPM A/C, W1P, TPM A/C, W/P, TPM W/P, TPM J, ^^ i ! I. F Page 2 Exhibit A Ref 11 Date various Author ( s) NMC WL Recipa , ent(s ) Description Documer^t concerning Privilege(s) Claimed A/C, W/P, TPM 12 06/07/1999 WL NMC 13 06/1(1/1999 10/09/2002 WL, NMC, Sam Stone WL, NMC, Sam Stone 19 06/14/1999 Sam Stone, counsel NMC ^ 5 i^ ^ f r 06/28/1999 WL NMC legal ^Zdvice and including confidential. con^rnunica;.ions between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and .including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential A/C, W/P, TPM A/C, W/P, TPM A/C, W/P, TPM A1C, W/P, `PPM s F `\ C Page 3 Exhibit A Ref Date Author ( s) Recipient ( s) Description communications between client and attorney. Document related to litigation involving PricePlay. Privilege(s) Claimed 16 11/10/1999 NMC WL Document concerning 'legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning A/C, W/P, TPM 17 11/29/1999 - NMC WL A/C, W/P, TPM 05/07/2002 legal advice and including confidential communications between client and attorney. Document related to litigatior, involving PricePlay. 18 12/06/1999 09/10/2001 NMC W1, 19 ^' !^ 12/13/1999 -01/17/2002 NMC WL, Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation involving PricePlay. Document concerning legal advice and including confidential r_·ommuni.cat.ions between client and attorney. Document related to A/C, w/P, TPM A/C, W/P, TPM r r Page 4 C ;^._: Exhibit A Ref Date Author(s) Recipient ( s) Aescription litigation involving PricePlay. Document related to litigation involving PricePlay. 21 12/13/1999 NMC N/A Document related to Privilege(s) Claimed 20 12/13/1999 NMC N/A W/P, TPM W/P, TPM 22 12/14/1999 NMC WL litigation involving PricePlay. Document concerning Iegal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning i ^ _.. ijgpy A/C, W/P, TPM I 23 01/26/2000 - NMC WL A/C, W/P, TPM 09/10/2001 . legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay, 29 02/05/2000 01/29/2001 NMC WL 5 i^ ^^ ;^ ^^. 03/13/2000 09/26/2002 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning Iegal advice and including confidential A/C, W/P, TPM A/C, W/P, 'PPM Page 5 ^^^ Exhibit A ReŁ Aate Authors} Recipient ( s) Aescription communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Pxa.vilege(s} Claimed 26 04/05/2000 09/27/2002 NMG, Japanese patent counsel NMC, Japanese patent counsel A/C, W/P, TPM 27 05/16/2000 -09/26/2002 NMC, WL WT.,, NMC A/C, W/P, TPM 2$ 05/31/2000 10/09/2002 NMC wL (some attorney notes have no recipient) Document concerning legal advice and including confidential conununications between client and attorney. Document related to litigation involving PricePlay. A/C, W/P, TPM 29 09/13/2000 NMC N/A -°^ ;^ ^ ^ 30 -Z 11/01/2001 -10/13/2004 NMC, Korean patent counsel NMC, Korean patent counsel Document related to litigation involving PricePlay. bocument concerning legal advice and including confidential W/P, TPM A/C, W/P, TPM ^ .^ Page 6 Exhibit A Ref Date Author ( s) Recipient ( s) Description communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay._ Privilege(s) Claimed 31 11/l6/2001 09/26/2002 NMC, WL WL, NMC A/C, W/P, TPM 32 10/29/2002 NMC WL A/C, W/P, TPM 33 12/27/2002 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Document zelatad to litigation .i.nvolving PricePlay. Document concerning A/C, w/P, TPM 39 06/12/2003 NMC WL A/C, W/P, TPM ^"7 rn legal advice and including confidential communications between client and attorney. Document related to J t ^^^^^_ ^. Page 7 Exhibit A Ref Date Author ( s) Recipient(s) Description litigation involving PricePlay. 35 07/22/2003 Privilege(s) Claimed WL NMC Document concerning A/C, W/P, TPM 36 12/02/2004 NMC WL legal advice and including confidential communications between client and attorney. 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NMC WL Document concerning A/C, W/P, TPM Privilege(s) Claimed 40 12/13/2004 43 09/17/200509/20/20D5 NMC, WL WL, NMC 42 09/17/200509/23/2005 NMC, WL WL, NMC 43 10/06/2005 NMC N/A .44 ^ m ^ ^ ""°'^ 12/20/2005 WL NMC legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document related to litigation involving PricePlay. Document concerning A/C, W/P, TPM A/C, W/P, TPM W/P, TPM A/r, W/P, TPM Page 9 _^' ^ ts Exhii^it A Ref Date Author ( s) Recipient ( s) Description Privilege(s) Claimed legal advice and including confidential communications between client and attorney. 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Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay, Document concerning legal advice and including confidential communications between rlient and attorney. Document related to litigation involving PricePlay. Document concerning Privilege(s) Claimed 49 02/26/2007 WL NMC A/C, W/P, TPM 50 02/27/2007 WL NMC A/C, W/P, TPM 51 02/27/2007 NMC WL A/C, W/P, TPM 52 03/02/2007 WL NMC i^ legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential cammunications between client and attorney. Document related to litigation involving A/C, W/P, TPM iv _ t Page 1 I Exhibit A Ref Date Author ( s) Recipients} Description PricePlay. Qrivilege(s) C1ai^ed A/C, W/P, TPM 53 03/05/2007 WL NMC j 54 03/06/2007 WL NMC 55 03/06/2007 NMC WL Document concerning legal advice and including confidential communications between client and attorney. Dacument related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. .,` A/C, W/P, TPM f) A/C, W/P, TPM 56 03/07/2007 WL NMC Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. ^7ocument concerning A/C, W/P, TPM 57 03/07/2007 NMC WL A/C, W/P, TPM legal advice and rn ^ Page i2 --^ (^ f Exhibit A ReŁ Date Author ( s) Recipient(s) Description including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between r_lient and attorney. Document related to litigation involving PricePlay. Document r_oncerning Pri.vilege(s} Claimed 58 43/11/2007 NMC WL, LS A/C, W/P, TPM 59 03/7.3/2007 WL NMC, VLS A/C, W/P, TPM 60 03/13/2007 NMC WL legal advice and including confidential communications between r_lient and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney, Document related to litigation involving PricePlay. VLS Document concerning A/C, W/P, TPM 61 03/17/2007 NMC WL, A/C, W/P, TPM ..^ legal advice and including confidential r_ommunications between client and attorney. ^^ Page 13 I Ext^is,it A Ref Date Author(s) Recipient ( s) Description Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning Priviiege(s) Clazmed 62 03/17/2007 WL NMC A/C, w/P, TPM 63 03/7.7/2007 WL NMC, VLS A/C, W/P, TPM J j 69 03/17/2007 NMC WL legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. 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