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)

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EXHIBIT D ____________________________________ Ari Rafilson Telephone: (214) 789-4035 Fax: (972) 236-5397 VIA EMAIL TO WHITEJ@HOWREY.COM August 10, 2009 Jason White Howrey LLP 321 North Clark Street, Suite 3400 Chicago, IL 60654 Re: Dear Jason: nXn proposes a meet and confer for Tuesday or Wednesday morning. Please advise regarding availability. Ideally such a call with Yahoo would run back-to-back with a call for Bright Response v. Google. nXn would specifically like to discuss (1) dates for nXn's second and third deposition notices to Yahoo, (2) nXn's deposition of Ivan Markman, Matthew Hall, Sean Suchter, and Raymond Ko, and (3) Yahoo's production of source code in the above referenced case. Frankly nXn nXn is puzzled by Yahoo's statements over the past several weeks that code for the above-referenced case should be available promptly as such statements have not resulted in the production of any code. Sincerely, nXn Tech, LLC v. Google Inc., et al. The Rafilson Law Firm, PLLC 1318 Royal Palm Lane, Carrollton, TX 75007 Ari Rafilson

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