PA Advisors, LLC v. Google Inc. et al
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)
T h e Rafilson Law Firm, PLLC The 1 3 1 8 Royal Palm Lane, Carrollton, TX 75007 1318
Ari Rafilson Telephone: (214) 789-4035 Fax: (972) 236-5397 firstname.lastname@example.org VIA EMAIL TO WHITEJ@HOWREY.COM September 22, 2009 Jason White Howrey LLP 321 North Clark Street, Suite 3400 Chicago, IL 60654 Re: nXn Tech, LLC v. Google Inc., et al. Dear Jason: This letter memorializes our discussion of earlier today. As an initial matter, nXn appreciates that Yahoo will be making code available for nXn's inspection tomorrow in the above-referenced case at 8:00 am at Fulbright & Jaworski's Dallas office. That being said, nXn has the several concerns related to Yahoo's compliance with the Protective Order as set forth below: 1. Computers: As discussed, per ¶ 1.c.ii of the Protective Order, Yahoo is to provide its source code for inspection on two stand-alone computers. During the call you mentioned that Yahoo had currently only provided a single computer for said inspection. 2. Printer: As also discussed, Yahoo is to provide a laser printer for on-site printing during the inspection of its code per ¶ 1.c.iii(3). During the call you mentioned that Yahoo had not currently provided a printer. Perhaps Yahoo can work with Fulbright to provide the printer. 3. Internet Access: As also discussed, Yahoo is to provide internet access per ¶ 1.c.ii of the Protective Order. Of course the computers provided by Yahoo for source code review will not have such access as provided by ¶ 1.c.iii(1). Although nXn will begin its inspection of Yahoo's code Wednesday morning, it expects these issues to be resolved by Thursday at noon central time at the latest. To the extent that
Yahoo refuses to comply with the terms of the protective order as set forth above, please confirm that Yahoo's counsel will arrange to meet with Mr. Spangler on Wednesday or Thursday to satisfy the in-person meet and confer requirement so that nXn may file a motion to compel. Of course nXn wishes to avoid the need for such action and seeks the cooperation of Yahoo and its counsel in this matter. Sincerely,
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