Mirror Worlds, LLC v. Apple, Inc.

Filing 309

MOTION To Limit the Number of Asserted Claims by Apple, Inc.. (Attachments: # 1 Affidavit of Jeffrey G. Randall, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Text of Proposed Order)(Randall, Jeffrey)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 309 Att. 5 EXHIBIT D Dockets.Justia.com Page 1 of 2 Moore, Kim From: Sent: To: Cc: Solo, Alex [asolo@stroock.com] Wednesday, June 30, 2010 11:57 PM Mirror Worlds MW_v_Apple Subject: RE: Mirror Worlds LLC v. Apple Inc. Allan, While we believe that we will be able to find common ground on limiting the number of claims, we also believe the effort is premature at this stage. Mirror Worlds is willing to revisit this discussion after reviewing Apple's positions in its dispositive motions. Regards, Alex _____________________________ Alexander Solo Stroock & Stroock & Lavan LLP 180 Maiden Lane New York, NY 10038 Tel: (212) 806 - 6031 Fax: (212) 806 - 9031 _____________________________ This e-mail is intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or copying of this e-mail or the information herein by anyone other than the intended recipient is prohibited. If you have received this email in error, please: (1) reply to the sender; (2) destroy this communication, including deletion of all associated files from all individual and network storage devices; and (3) refrain from copying or disseminating this communication by any means whatsoever. From: Soobert, Allan M. [mailto:allansoobert@paulhastings.com] Sent: Wednesday, June 30, 2010 5:49 PM To: MW_v_Apple Cc: Mirror Worlds Subject: FW: Mirror Worlds LLC v. Apple Inc. Joe/Alex, We still do not have a response to Jeff Randall's June 24 letter (attached). With motions for summary judgment due tomorrow (July 1), we need to know if Mirror Worlds is willing to limit the number of claims that it intends to pursue going forward, given that the present number (approx. 50 claims) is unwieldy and inappropriate, as explained in Jeff's letter. As we discussed during our meet and confer last Friday (June 25), Apple plans to move the Court to limit the number of claims, if Mirror Worlds is unwilling to do so. While we would appreciate a prompt response to all of the points in Jeff's June 24 letter, please respond today on the issue of the number of asserted claims. Thanks, 7/1/2010 Page 2 of 2 Allan From: Sellars, Jacquelyn Sent: Thursday, June 24, 2010 5:18 PM To: MW_v_Apple@stroock.com Cc: Mirror Worlds Subject: Mirror Worlds LLC v. Apple Inc. Please see attached letter from Jeff Randall. Regards, Jacqui Sellars __________________________________________________________________ Jacqui Sellars, Legal Secretary | Paul, Hastings, Janofsky & Walker LLP | 875 15th Street, N.W., Washington, DC 20005 | direct: 202 551 1324 | main: 202 551 1700 | direct fax: 202 551 1705 | jacquelynsellars@paulhastings.com | www.paulhastings.com Paul Hastings is committed to sustainable practices. Reducing printed waste saves resources. _________________________________________________________ ********************************************************* IRS Circular 230 Disclosure: As required by U.S. Treasury Regulations governing tax practice, you are hereby advised that any written tax advice contained herein was not written or intended to be used (and cannot be used) by any taxpayer for the purpose of avoiding penalties that may be imposed under the U.S. Internal Revenue Code. ********************************************************* This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. For additional information, please visit our website at www.paulhastings.com. ==================================================================================== IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS in Circular 23 advice contained in this communication (including any attachment that does not expli intended or written to be used, and cannot be used, for the purpose of (i) avoiding Revenue Code or (ii) promoting, marketing or recommending to another party any trans ===================== ==================== ===================== ==================== == 7/1/2010

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