Rockstar Consortium US LP et al v. Google Inc

Filing 126

MOTION to Compel by Rockstar Consortium US LP. (Attachments: # 1 Appendix of Exhibits ISO Motion to Compel, # 2 Affidavit of Amanda Bonn ISO Motion to Compel, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Exhibit 12, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 19, # 22 Exhibit 20, # 23 Exhibit 21, # 24 Text of Proposed Order Granting Motion to Compel)(Bonn, Amanda)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,
Civil Action No. 2:13-cv-893

Plaintiff,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

INDEX OF ATTACHMENTS TO
PLAINTIFFS’ MOTION TO COMPEL DISCOVERY FROM GOOGLE INC.
Exhibit 1

True and correct copy of a letter from counsel for Plaintiffs to counsel for Google
Inc. requesting the production of documents, dated April 30, 2014.

Exhibit 2

True and correct copy of a letter from counsel for Google Inc. to counsel for
Plaintiffs responding to Plaintiffs’ document requests, dated June 18, 2014.

Exhibit 3

True and correct copy of a letter from counsel for Plaintiffs to counsel for Google
Inc. regarding Plaintiffs’ document requests and Google Inc.’s objections thereto,
dated July 1, 2014.

Exhibit 4

True and correct copy of an email from counsel for Plaintiffs to counsel for
Google Inc. regarding the parties’ meet-and-confer efforts, dated July 9, 2014.

Exhibit 5

True and correct copy of an email from counsel for Plaintiffs to counsel for
Google Inc. regarding the parties’ meet-and-confer efforts, dated July 10, 2014.

3289272V1/013149

1

Exhibit 6

Exhibit 7

True and correct copy of is a true and correct copy of is a true and correct copy of
a letter from counsel for Google Inc. to counsel for Plaintiffs regarding the
parties’ meet-and-confer efforts, dated July 16, 2014.
True and correct copy of an email from counsel for Plaintiffs to counsel for
Google Inc. regarding the parties’ meet-and-confer efforts, dated July 25, 2014.

Exhibit 8

True and correct copy of a letter from counsel for Google Inc. to counsel for
Plaintiffs regarding the parties’ meet-and-confer efforts, dated July 29, 2014.

Exhibit 9

True and correct copy of a letter from counsel for Google Inc. to counsel for
Plaintiffs dated August 6, 2014.

Exhibit 10

True and correct copy of Plaintiffs’ Preliminary Infringement Contentions, dated
March 24, 2014.

Exhibit 11

True and correct copy of Exhibit B to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,236,969 against the Accused
Instrumentalities.

Exhibit 12

True and correct copy of Exhibit C to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,469,245 against the Accused
Instrumentalities.

Exhibit 13

True and correct copy of Exhibit D to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,672,970 against the Accused
Instrumentalities.

Exhibit 14

True and correct copy of Exhibit E to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,895,178 against the Accused
Instrumentalities.

Exhibit 15

True and correct copy of Exhibit F to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,895,183 against the Accused
Instrumentalities.

3289272V1/013149

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Exhibit 16

Exhibit 17

True and correct copy of Exhibit G to Plaintiffs’ Preliminary Infringement
Contentions charting U.S. Patent No. 7,933,883 against the Accused
Instrumentalities.
True and correct copy of certain demonstrative exhibits from the trial in I/P
Engine, Inc. v. AOL, Inc., et al., No. 11-cv-512 (E.D. Va.).

Exhibit 18

True and correct copy of a Reuters.com article titled “Google, Samsung, Huawei
sued over Nortel patents,” dated October 31, 2013, and accessed online on August
18, 2014, at http://www.reuters.com/assets/print?aid=USBRE99 U1EN20131031.

Exhibit 19

True and correct copy of a print-out from Google Inc.’s website regarding the
company’s founding, accessed online on August 18, 2014, at
https://www.google.com/about/company.

Exhibit 20

True and correct copy of a print-out from Google Inc.’s website regarding
AdSense for content, accessed online on August 18, 2014, at
https://support.google.com/adsense/answer/17470?hl=en.

Exhibit 21

True and correct copy of an email from counsel for Google Inc. to counsel for
Plaintiffs dated August 18, 2014.

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CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to
electronic service, are being served this 18th day of August, 2014 with a copy of this document
via the Court’s CM/ECF system per Local Rule CD-5(a)(3).

/s/ Amanda K. Bonn____
Amanda K. Bonn