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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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. 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
A/C, W/P, TPM
37
12/03/2069
NMC, WL
wL, NMC
A/C, W/P, TPM
38
12/03/2004
WL
NMC
^ ^
_ ^ ^..-°^
39
12/03/2009-
NMC, WL
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
A/C, w/P, TPM
A/C, W/P, TPM
r^^^^. s
Exhibit A
Red Aate 12/09/2009 Author ( s) Recipient ( s) Description legal advice and including confidential communications betwees7 client and attorney. Document related to litigation involving PricePlay.
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. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving
PricePlay.
95
12/20/200512/22/2005
NMC, WL
WL, NMC
A/C, W/P, TPM
96
02/02/2006
NMC
WL
Dar_ument concerning legal advice and including confidential communications between client and attorney.
Document r?fated to
A/C, W/P, TPM
47
02/08/2006
NMC, WL
WL, NMC
98
02/26/2007
NMC
WL
"^C; i
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
A/C, W/P, TPM
A/C, W/P, TPM
i-r-i ^
S^ ^
^^ N
Page 10
ExhiUit A
Ref Date Author( s) Recipient ( s) Description 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 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. Document concerning
^
A/C, W/P, TPM
65
x3/17/2007
NMC
WL
A/C, W/P, TPM
legal. advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay.
F
^^
}
Page 14
Exhibit A
Author ( s) Recipient ( s) Description
Ret 66
Date
Privi^.ege{s) Claimed
A/C, w/P, TPM
03/20/2007
WL
NMC, VLS
67
03/20/2007
NMC
WL
68
03/21/2007
WL
NMC, VLS
i I 69 03/26/2007 NMC WL, VLS
70
En
03/26/2007
WL
NMC, VLS
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 Price Play. Document r_oncerning legal advice and including confidential communications between client and attorney. Document related to litigation involving Price Play. Document concerning legal advice and including confidential
A/C, W/P, TPM
_...^
A/C, W/P, TPM
A/C, W/P, TPM
A/C,, W/P, TPM
^^
Page 15
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,
Privilege{s) Claimed
71
03/28/2007
WL
NMC, VLS
A/C, W/P, TPM
72
03/29/2007
JLL
NMC
Document related to litigation involving
PricePlay.
W/P, TPM
73
03/17/2007 03/30/2007 03/30/2007
NMC
N/A
79
NMC
WL
' 75 03/30/2007 NMC
WL, AILS
E""^"t
Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communica^.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.
W/P, TPM _
A/C, W/P, TPM
A/C, W/P, TPM
^^ P
Page 1 C
i
Exhibit A
Ref 76
Da '^e
Author { s) WL
Rec^. pient ( s)
NMC, VLS
Description
Document concerning
Privilege{s) Claimed
A/C, W/P, TPM
03/30/2007
77
03/30/2007
NMC
WL,
VLS, JLL
7$
03/30/2007
WL
NMC, VLS, JLL-
79
03/30/2007
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. 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
A/C, W/P, TPM
A/C, W/P, TPM
A/C, W/P, TPM
80
03/30/2007
NMC
VLS,'. JLL
W/P, TPM
litigation involving PricePlay. ^ ^C ^^ ^^
°^ ,^
Page 17
exhibit A
Red 81 Date 03/30/2067 Author ( s) NMC Recipient(s) N/A 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
Privilege(s) CYaimed W/P, TPM
82
05/01/2007
WL
NMC
A/C, W/P, TPM
83
05/01/2007
NMC
WL
A/C, W/P, TPM
legal advice and including confidential communications between client and attorney. Document related Lo litigation involving PricePlay.
89 05/03/2007 NMC
WL
Document concerning legal advice and
A/c', W/P, TPM
including confidential communications between client and attorney. Document related to litigation involving 85
05/09/2007 WL NMC PricePlay, Document concerning A/C, W/P, TPM
""T7
^
legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay.
.^ ^1^ `s
Page ] 8
Exhibit A
Ref 86 Date 05/18/2007 Author ( s) NMC WL Recipient(s) Description Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay.
Document concerning
Privilege(s) Claimed
A/C, W/P, TPM
87
07/04/2007
NMC
WL
A/C, W/P, TPM
legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay.
68 10 /02/2007 NMC WL Document concerning
A/C, W/P, TPM
89
10/02/2007
WL
NMC
legal advir_·e 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
A/C, W/P, TPM
90
10/03/2007
WL
NMC
A/C, W/P, TPM
legal advice and including confidential
x ^^ r-^ ^
^.,..^. Page 19
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.
Privilege(s) Claimed
91
10/05/2007
NMC
WL
A/C', W/P, TPM
92
10/05/2007
WL
NMC
93
12/17/2007
NMC
WL
99
06/11/2008
WL
NMC
:1,^
Document concerning legal advice and including confidential communications between client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and inclt^dinq confidential communications betwa_en client and attorney. Document related to litigation involving PricePlay. Document concerning legal advice and including confidential communications between client and attarney. Dacument related to
A/C, W/P, TPM
A/G, W/P, TPM
A/C, W/P, TPM
f
^ a
Page 20
i;
,^
Exhibit A
Ref bate Author ( s) Recipient ( s) Description litigation involving
PricePlay.
Privilege(s) Claimed
95
06/14/200E
NMC
WL
96
10/26/2x08
Christin Cho
NMG
97
10/27/2008
WL
NMC
Document concerning Legal advice and including confidential communications between client and attorney. Document related to litigatio,^ involving PricePlay. Document concerning legal advice and including confidential communications between cliettt 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
,^ A/C, W/P, TPM l
A/C, w/P, TPM
^^
^_ ^ °-^^
^^ ^ ^
Page 21
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