Software Rights Archive, LLC v. Google Inc. et al

Filing 198

Opposed MOTION Granting Defendants Leave to Amend and Supplement Invalidity Contentions by IAC Search & Media, Inc., Lycos, Inc.. (Attachments: # 1 Dec of Mark D. Baker, # 2 Exhibit A to Dec of Mark D. Baker, # 3 Exhibit B to Dec of Mark D. Baker, # 4 Exhibit C to Dec of Mark D. Baker, # 5 Exhibit D to Dec of Mark D. Baker, # 6 Exhibit E to Dec of Mark D. Baker, # 7 Exhibit F to Dec of Mark D. Baker, # 8 Exhibit G to Dec of Mark D. Baker, # 9 Text of Proposed Order Granting Defendants Leave to Amend and Supplement Invalidity Contentions)(Maloney, Collin)

Software Rights Archive, LLC v. Google Inc. et al

Doc. 198 Att. 6

EXHIBIT E

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MO RRI SO N & F O E RST E R L LP N E W YO RK , SAN F RAN C I SCO , L O S A N G E L E S, P A L O A L T O , SAN D I E G O , WASH I N G T O N , D .C . N O RT H E RN VI RG I N I A, D E N VE R, SAC RAME N T O , WAL N U T C RE E K T O K YO , LO N D O N , BE I JI N G , SH AN G H AI , H O N G K O N G , SI N G A P O R E , BRU SSE L S

September 29, 2009

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Via Electronic Mail Victor G. Hardy DiNovo Price Ellwanger & Hardy LLP 7000 N. MoPac Expressway, Suite 350 Austin, Texas 78731 Re: Software Rights Archive, LLC v. Google Inc., et al., No. 07-CV-511 (E.D. Tex.)

Dear Victor: Thanks again for last week's productive discussion about discovery. As we noted in our prior letters of March 27th and July 16th, we would like SRA to amend its Infringement Contentions to clarify how each of the accused Yahoo! products and services allegedly infringes. To date, Yahoo! has produced in excess of 33,000 pages -- the great majority of this being technical documents. These documents should assist SRA's amendment of its contentions. SRA's cooperation with this would go a long way toward helping the parties narrow the issues and meaningfully respond to each other's discovery requests. We look forward to SRA's updated contentions. As always, if it would be productive to discuss these issues, please give either Rich or me a call. Sincerely, /s/ Rebecca Snavely Saelao Rebecca Snavely Saelao

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