Rockstar Consortium US LP et al v. Google Inc

Filing 276

REPLY to Response to Motion re 220 MOTION to Amend/Correct Invalidity Contentions filed by Google Inc. (Attachments: # 1 Affidavit of Lance Yang, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Perlson, David)

EXHIBIT D

Lance Yang
From:
Sent:
To:

Cc:
Subject:

Andrea P Roberts
Thursday, October 23, 2014 3:18 PM
Justin A. Nelson; Amanda Bonn; John Lahad; Shawn Blackburn; Meng Xi; Alexander L.
Kaplan; Cyndi Obuz; John Dolan; Tammie J. DeNio; '[e-mail]';
'[e-mail]'; '[e-mail]'; '[e-mail]';
'[e-mail]'; Max L. Tribble; Parker Folse; Stacy Schulze
QE-Google-Rockstar; James Mark Mann; Andy Tindel; Gregory Blake Thompson
Rockstar v. Google - Expedited Briefing

Justin,
I write regarding the parties’ planned expedited discovery motions. Yesterday, you suggested that the parties
file them tomorrow, Friday, October 24. That is acceptable to us. We propose that responsive briefs be due on
November 5. As the parties discussed, there will be no replies or sur-replies. And we propose that opening and
responsive briefs be 30 pages each. Please let us know your thoughts.
In terms of outstanding correspondence, I believe we owe you responses to two emails sent on the afternoon of
October 21, regarding custodial searches and our technical document production. We are conferring with the
client on those and expect to get back to you before the end of the day and hopefully sooner. And, with respect
to revised email search terms, we’re still working on putting together the document listing all of the proposed
revisions Rockstar suggested on our meet and confer yesterday afternoon for Rockstar’s review before we run
further tests. We hope to get that to you today as well, although given the number of search terms and proposed
revisions, it is a time-consuming task.
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
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