PA Advisors, LLC v. Google Inc. et al

Filing 298

RESPONSE to Motion re #295 MOTION for Protective Order Modification filed by PA Advisors, LLC. (Attachments: #1 Affidavit of Andrew D. Weiss, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H)(Weiss, Andrew)

EXHIBIT B

____________________________________
Ari Rafilson Telephone: [phone] Fax: [phone] [e-mail] VIA EMAIL TO [e-mail] July 17, 2009 Jason White Howrey LLP 321 North Clark Street, Suite 3400 Chicago, IL 60654 Re: Dear Jason: This letter is further to your email dated July 16, 2009. At the upcoming meet and confer the parties nXn wishes to discuss the following topics: 1. Source Code: The parties will need to discuss details of Yahoo's production of its source code including (1) timeframe, (2) versions of code that will be provided, (3) details on the development environment and tools that will be provided along with the source code, (4) wiki environment and wiki articles that will be provided, and (5) details on the database schema that will be provided. At the meet and confer you committed to provide a status update by July 17. Such an update would help to minimize the amount of time required to discuss this topic. 2. nXn's 30(b)(6) deposition served on June 24, 2009. The deposition was initially scheduled for July 14, but nXn has not received proposed designees or available dates. 3. Depositions of Ivan Markman, Matthew Hall, Sean Suchter and Raymond Ko and whether counsel for Yahoo (1) will represent them, (2) will accept service for them, and (3) dates of availability. Counsel for Yahoo committed to let nXn know when it can expect dates for the above listed individuals by July 17, which may minimize the amount of time required to discuss this topic. nXn Tech, LLC v. Google Inc., et al.

The Rafilson Law Firm, PLLC 1318 Royal Palm Lane, Carrollton, TX 75007

Sincerely,

Ari Rafilson