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)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 309 Att. 6

EXHIBIT E

Dockets.Justia.com

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Moore, Kim
From: Sent: To: Cc: Solo, Alex [[e-mail]] Wednesday, July 07, 2010 10:08 PM Mirror Worlds MW_v_Apple

Subject: RE: Mirror Worlds LLC v. Apple Inc.

Allan, 3PM EST works for us. We will respond to the remaining points of the June 24 letter tomorrow. Regards, Alex

From: Soobert, Allan M. [mailto:[e-mail]] Sent: Wednesday, July 07, 2010 5:23 PM To: Solo, Alex Cc: MW_v_Apple; Mirror Worlds Subject: RE: Mirror Worlds LLC v. Apple Inc. Alex, There are several other issues raised in Jeff Randall's June 24 letter, beyond the issue of the number of claims that Mirror Worlds plans to assert at trial. None of these other issues are addressed in your June 30 email. Please respond to those issues today, so that we can have a meaningful discussion tomorrow. Thanks, Allan

From: Solo, Alex [mailto:[e-mail]] Sent: Wednesday, July 07, 2010 5:16 PM To: Mirror Worlds Cc: MW_v_Apple Subject: RE: Mirror Worlds LLC v. Apple Inc.

Allan, Our position is the same as in our June 30 email response. We are willing to cut down the claims, but we believe that the effort is premature at this stage. We will be happy to revisit this discussion after the Summary Judgment briefing. Best regards, Alex
_____________________________ Alexander Solo Stroock & Stroock & Lavan LLP 180 Maiden Lane New York, NY 10038

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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 e-mail 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:[e-mail]] Sent: Wednesday, July 07, 2010 2:55 PM To: Solo, Alex Cc: MW_v_Apple; Mirror Worlds Subject: FW: Mirror Worlds LLC v. Apple Inc. Alex, It's been two weeks and we still do not have a response to Jeff Randall's June 24 letter. I understand the parties have been busy, but we need a response. Please respond in writing by the close of business today, so that we can understand your position prior to tomorrow's meet and confer. For tomorrow's meet and confer, please let us know if 3 pm EST works for you and your team. Thanks, Allan

From: Soobert, Allan M. 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, Allan

From: Sellars, Jacquelyn Sent: Thursday, June 24, 2010 5:18 PM

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To: [e-mail] 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: [phone] | [e-mail] | www.paulhastings.com Paul Hastings is committed to sustainable practices. Reducing printed waste saves resources.

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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.

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8/13/2010