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)

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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; ''; ''; ''; ''; ''; 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 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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