Mirror Worlds, LLC v. Apple, Inc.

Filing 377

REPLY to Response to Motion re 309 MOTION To Limit the Number of Asserted Claims filed by Apple, Inc.. (Attachments: # 1 Affidavit Supplemental Declaration of Jeffrey G. Randall, # 2 Exhibit I, # 3 Exhibit J)(Randall, Jeffrey)

Download PDF
Mirror Worlds, LLC v. Apple, Inc. Doc. 377 Att. 2 SUPPLEMENTAL DECLARATION OF JEFFREY G. RANDALL EXHIBIT I Dockets.Justia.com Page 1 of 1 From: Sent: To: Cc: Solo, Alex [asolo@stroock.com] Friday, August 20, 2010 11:54 AM Mirror Worlds MW_v_Apple Subject: Meet and Confer Christian, Is anyone from your team available for a short meet and confer this afternoon? As you know, Mirror Worlds is planning on filing a motion to limit Apple's prior art and prior art obviousness combinations to be presented at trial. While we are looking forward to having a fruitful discussion regarding an amicable resolution of these issues on Monday (when we will provide Apple with our proposed claims for trial), Apple's motion to limit claims forces Mirror Worlds to move to preserve our rights in the event that no resolution is reached. Based on our anticipated reduction of claims to about 18, and due to the commonality of disclosure among the Mirror Worlds' patents and the fact that the `999 patent has a single claim, we anticipate moving the court to limit Apple to one primary reference per patent, and three secondary references, with no more than a total of 5 obviousness combinations for all patents. Of course, should the Court restrict Mirror Worlds to fewer claims, we would seek to further limit Apple's prior art. 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 . ============================================================================================ IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS in Circular 230, we in advice contained in this communication (including any attachment that does not explicitly st intended or written to be used, and cannot be used, for the purpose of (i) avoiding penaltie Revenue Code or (ii) promoting, marketing or recommending to another party any transaction o ============================================================================================

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?