Rockstar Consortium US LP et al v. Google Inc

Filing 138

RESPONSE in Opposition re 122 MOTION to Strike Plaintiffs' Patent Rule 3-1 Infringement Contentions filed by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration of Shawn D. Blackburn, # 2 Exhibit 1 - Rockstar's P.R. 3-1 Disclosure of Asserted Claims and Infringement Contentions, # 3 Exhibit 2 - Rockstar's P.R. 3-1 Infringement Claim Chart for '065, # 4 Exhibit 3 - Rockstar's P.R. 3-1 Infringement Claim Chart for '969, # 5 Exhibit 4 - Rockstar's P.R. 3-1 Infringement Claim Chart for '245, # 6 Exhibit 5 - Rockstar's P.R. 3-1 Infringement Claim Chart for '970, # 7 Exhibit 6 - Rockstar's P.R. 3-1 Infringement Claim Chart for '178, # 8 Exhibit 7 - Rockstar's P.R. 3-1 Infringement Claim Chart for '183, # 9 Exhibit 8 - Rockstar's P.R. 3-1 Infringement Claim Chart for '883, # 10 Exhibit 9 - 4-14-14 email between counsel, # 11 Exhibit 10 - 4-18-14 email between counsel, # 12 Exhibit 11 - 7-3-14 email between counsel, # 13 Exhibit 12 - 7-8-14 email between counsel, # 14 Exhibit 13 - 7-24-14 email between counsel, # 15 Exhibit 14 - 8-27-14 email between counsel, # 16 Exhibit 15 - 6-23-14 email between counsel, # 17 Text of Proposed Order)(Blackburn, Shawn)

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EXHIBIT 13 From: Sent: To: Cc: Subject: Andrea P Roberts <andreaproberts@quinnemanuel.com> Thursday, July 24, 2014 6:15 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; 'jrambin@capshawlaw.com'; 'ederieux@capshawlaw.com'; 'ccapshaw@capshawlaw.com'; 'jw@wsfirm.com'; 'claire@wsfirm.com' QE-Google-Rockstar; 'James Mark Mann'; 'Gregory Blake Thompson'; 'Andy Tindel' Rockstar v. Google - Source Code Counsel, I write to advise you that Google source code is available for inspection in Quinn Emanuel’s Los Angeles office. Google expects to make additional code available for inspection, and we will let you know when that code is available. 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 andreaproberts@quinnemanuel.com 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

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