EMG Technology, LLC v. Apple, Inc.

Filing 216

REPLY to Response to Motion re 199 MOTION to Vacate 100 Order, 99 Order The Deadlines In The Docket Control And Discovery Orders And For A Case Management Conference MOTION to Vacate 100 Order, 99 Order The Deadlines In The Docket Control And Discovery Orders And For A Case Management Conference filed by Apple, Inc.. (Attachments: # 1 Affidavit Declaration of John R. Lane ISO Apple Inc.'s Reply, # 2 Exhibit A to Lane Declaration, # 3 Exhibit B to Lane Declaration, # 4 Exhibit C to Lane Declaration, # 5 Exhibit D to Lane Declaration, # 6 Exhibit E to Lane Declaration, # 7 Exhibit F to Lane Declaration, # 8 Exhibit G to Lane Declaration, # 9 Exhibit H to Lane Declaration, # 10 Exhibit I to Lane Declaration, # 11 Exhibit J to Lane Declaration, # 12 Exhibit K to Lane Declaration, # 13 Exhibit L to Lane Declaration, # 14 Exhibit M to Lane Declaration, # 15 Exhibit N to Lane Declaration, # 16 Exhibit O to Lane Declaration, # 17 Exhibit P to Lane Declaration)(Healey, David)

EMG Technology, LLC v. Apple, Inc.

Doc. 216 Att. 11

Exhibit J

Dockets.Justia.com

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From: Sent: To: Subject:

Gibson, Stan [[e-mail]] Sunday, August 09, 2009 3:29 PM John Lane RE: EMG v. Apple et al. - proposed email search terms and protective order

Attachments: Protective Order.pdf John, Here are some comments on the protective order: 1. On the prosecution bar, we believe that it should not apply to re-examination and we would like to make that clear in the protective order. The prosecution bar should also be reciprocal to defense attorneys who receive and review EMG's protected materials. 2. For the attorneys' eyes only provision, because we do not have an in-house counsel, we believe that either EMG should be able to designate one, non-attorney to review the materials or that neither side should be able to have internal personnel review AEO materials. 3. Finally, in terms of the review of source code, we would prefer to use the provisions from the attached protective order. Please let me know if you have any questions. _______________________________________ Stanley M. Gibson of JMBM | Jeffer, Mangels, Butler & Marmaro LLP 1900 Avenue of the Stars, 7th Floor Los Angeles, California 90067 [phone] [phone] (fax) [e-mail] JMBM.com

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From: John Lane [mailto:[e-mail]] Sent: Thursday, July 16, 2009 12:44 PM To: Gibson, Stan; Hansen, Shawn Cc: David Healey; Garland Stephens Subject: EMG v. Apple et al. - proposed email search terms and protective order

Stan and Shawn ­ Below are Apple's proposed search terms for email. The terms in the list titled "Accused Instrumentalities (AI)" are not search terms by themselves; they are the list of terms to combine with other terms in the list titled "Search Terms" where it says "AI" in that list.

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Also, the draft protective order I sent you last week is attached. Does EMG have any comments on it? Thanks, John
Accused Instrumentalities (AI) 1. 2. 3. 4. 5. 6. 7. iPhone Safari iPod Touch Safari Bloomberg App AppleTV iTunes Store Front Row iTunes Store iPhone iTunes Store Ruby on Rails

Search Terms 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. (Gottfurcht or (Albert-Michel Long) or (Teague McKnight) or Beltran or Woesner or Marinuzzi or Dukeshire) (7,441,196 or 7441196 or (196 patent) or ('196 patent)) (7,194,698 or 7194698 or (698 patent) or ('698 patent)) (7,020,845 or 7020845 or (845 patent) or ('845 patent)) (6,600,497 or 6600497 or (497 patent) or ('497 patent)) AI and (simplified or simplify) and web AI and (grid or matrix) (AppleTV or (Apple TV)) and ((remote) or (control)) AI and (sister site) AI and (mobile ((web site) or site or (website))) (Bloomberg or Bloomberg.com) ((American Airlines) or aa.com) ((Continental Airlines) or continental.com) (UPS or (United Parcel Service) or ups.com) AI and (transcode or transcoding) and (web or HTML or XHTML) AI and (reformat or reformatting) and (web or HTML or XHTML) MallTV

John R. Lane

~Fish & Richardson P.C.
One Houston Center 1221 McKinney, Suite 2800 Houston, Texas 77010 713-654-5307 Email: [e-mail]

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