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)

Exhibit 21

Amanda Bonn
From:
Sent:
To:

Cc:
Subject:

Andrea P Roberts <[e-mail]>
Monday, August 18, 2014 5:17 PM
John Lahad; Amanda Bonn; Justin A. Nelson; Shawn Blackburn; Alexander L. Kaplan;
Cyndi Obuz; John Dolan; Kristin Malone; Max L. Tribble; Parker Folse; Stacy Schulze;
Tammie J. DeNio; '[e-mail]'; '[e-mail]';
'[e-mail]'; '[e-mail]'; '[e-mail]'
QE-Google-Rockstar; 'Mark Mann'; 'Blake Thompson'; 'Andy Tindel'
RE: Rockstar v. Google

John,
Thank you for the clarifications in your email below. We have a few follow up questions.
1.
Your July 10 email listed “Google’s indexing systems, including but not limited to Knowledge
Graph.” We have two concerns relating to this “functionality.” First, Search generally is not accused (as
Rockstar has confirmed) and indexing is not covered by the asserted claims. Thus, we do not believe it is
relevant. Second, if by “Knowledge Graph,” Rockstar is referring to a “personalized” Knowledge Graph, then
that will be covered by documents relating to Google’s personalized search services and we will address in
response to Interrogatory No. 2. But, if Rockstar is referring to the “Knowledge Graph” generally, we do not
believe it is covered by the asserted claims and therefore not relevant. We need clarification regarding what
Rockstar is referring to.
2.
As for YouTube Interest Based Advertising, we understand that YouTube is an accused product. And,
thank you for pointing us to the page in Rockstar’s infringement contentions which provides a screen shot of a
web page discussing YouTube interest based advertising. However, as explained in my July 29 letter, interest
based advertising is part of Google’s Content Ads system, not its Search Ads system. Thus, although a screen
shot is included in Rockstar’s claim chart, interest based advertising really isn’t covered by the asserted claims
and thus not relevant.
We are looking into the cite you provided regarding the “__gads cookie.”
Thanks,
Andrea
Andrea Pallios Roberts
Of Counsel,
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5023 Direct
650.801.5000 Main Office Number
650.801.5100 FAX
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message
may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended
recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately
by e-mail, and delete the original message.

1

From: John Lahad [mailto:[e-mail]]
Sent: Wednesday, August 06, 2014 7:44 PM
To: Andrea P Roberts; Amanda Bonn; Justin A. Nelson; Shawn Blackburn; Alexander L. Kaplan; Cyndi Obuz; John Dolan;
Kristin Malone; Max L. Tribble; Parker Folse; Stacy Schulze; Tammie J. DeNio; '[e-mail]';
'[e-mail]'; '[e-mail]'; '[e-mail]'; '[e-mail]'
Cc: QE-Google-Rockstar; 'Mark Mann'; 'Blake Thompson'; 'Andy Tindel'
Subject: RE: Rockstar v. Google

Andrea,
In your July 29, 2014 letter, you had some questions regarding the list of functionalities we
provided. Here are the answers.
1. Regarding Knowledge Graph, you say that search generally is not accused, but you can’t
dispute that the asserted claims contemplate searching. E.g., “searching, based upon the
received search argument, a first database having data network related information to
generate search results.” Is your disagreement focused on the “indexing” aspect?
2. Please see http://googleblog.blogspot.com/2009/10/introducing-google-social-searchi.html regarding social search.
3. YouTube Interest Based Advertising is highlighted in our infringement contentions. See,
e.g., pg. 42 of the ‘969 chart.
4. “___gads” is not a typo. It is an advertising-related cookie described here:
http://www.google.com/policies/technologies/types/
Happy to discuss.
Thanks,
John
John P. Lahad
Susman Godfrey L.L.P.
713-653-7859 (office)
713-725-3557 (mobile)
713-654-6666 (fax)

From: Andrea P Roberts [mailto:[e-mail]]
Sent: Tuesday, July 29, 2014 10:26 PM
To: Amanda Bonn; John Lahad; Justin A. Nelson; Shawn Blackburn; Alexander L. Kaplan; Cyndi Obuz; John Dolan; Kristin
Malone; Max L. Tribble; Parker Folse; Stacy Schulze; Tammie J. DeNio; '[e-mail]';
'[e-mail]'; '[e-mail]'; '[e-mail]'; '[e-mail]'
Cc: QE-Google-Rockstar; 'Mark Mann'; 'Blake Thompson'; 'Andy Tindel'
Subject: Rockstar v. Google

Amanda,
2

Please see attached.
Andrea Pallios Roberts
Of Counsel,
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5023 Direct
650.801.5000 Main Office Number
650.801.5100 FAX
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message
may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended
recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately
by e-mail, and delete the original message.

3