Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 598

Proposed Jury Instructions by Bedrock Computer Technologies, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Appendix A to Exhibit B, #4 Appendix B to Exhibit B, #5 Exhibit C, #6 Exhibit D, #7 Exhibit E, #8 Exhibit F)(Cawley, Douglas)

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Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al Doc. 598 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., CITIWARE TECHNOLOGY SOLUTIONS, LLC, GOOGLE INC., YAHOO! INC., MYSPACE INC., AMAZON.COM INC., PAYPAL INC., MATCH.COM, LLC, AOL LLC, AND CME GROUP INC., Defendants. CASE NO. 6:09-CV-269-LED Jury Trial Demanded JOINT SUBMISSION OF JURY MATERIALS FOR FIRST TRIAL Plaintiff Bedrock Computer Technologies LLC ("Plaintiff") and Google Inc., Inc. ("Defendants"), hereby submit the following jury materials: and Attached as Exhibit A hereto are the parties' Joint Proposed Preliminary Jury Instructions, with bracketed and highlighted individual proposals. Attached as Exhibit B hereto are the parties' Joint Proposed Final Jury Instructions, with bracketed and highlighted individual proposals. Attached as Exhibit C hereto is Plaintiff's Proposed Verdict Form. Attached as Exhibit D hereto is Defendants' Proposed Verdict Form. Attached as Exhibit E hereto is Plaintiff's Proposed Instruction on Willfulness. Attached as Exhibit F is Plaintiff's Proposed Verdict Form on Willfulness. The parties reserve the right to amend, supplement, or modify these proposed jury materials as the case proceeds toward the final pre-trial conference and trial, and as the parties continue to meet and confer regarding these materials. Additionally, the parties do not waive any objections to issues that are the subject of pending motions, including Daubert motions, motions to strike, motions for summary judgment, and motions in limine. 2 Dallas 320120v1 DATED: March 15, 2011. Respectfully submitted, McKOOL SMITH, P.C. /s/ Douglas A. Cawley Douglas A. Cawley, Lead Attorney Texas State Bar No. 04035500 Theodore Stevenson, III Texas State Bar No. 19196650 Rosemary T. Snider Texas Bar No. 18796500 Scott W. Hejny Texas Bar No. 24038952 Jason D. Cassady Texas Bar No. 24045625 J. Austin Curry Texas Bar No. 24059636 Phillip M. Aurentz Texas State Bar No. 24059404 MCKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 (214) 978-4000 (214) 978-4044 FAX Sam F. Baxter Texas State Bar No. 01938000 MCKOOL SMITH, P.C. 104 E. Houston St., Suite 300 Marshall, TX 75670 (903) 923-9000 (903) 923-9099 FAX 3 Dallas 320120v1 Robert M. Parker Texas Bar No. 15498000 Robert Christopher Bunt Texas Bar No. 00787165 PARKER BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, Texas 75702 Telephone: 903-531-3535 Facsimile: 903-533-9687 E-mail: E-mail: ATTORNEYS FOR PLAINTIFF BEDROCK COMPUTER TECHNOLOGIES LLC /s/Claude M. Stern (with permission by Douglas A. Cawley) Claude M. Stern Evette D. Pennypacker Todd M. Briggs QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Telephone: 650-801-5000 Facsimile: 650-801-5100 Michael E. Jones Texas State Bar No. 10929400 POTTER MINTON, P.C. 110 N. College Tyler, Texas 75702 Telephone: 903-597-8311 Fax: 903-593-0845 ATTORNEYS FOR DEFENDANT GOOGLE INC. AND MATCH.COM, INC. 4 Dallas 320120v1 CERTIFICATE OF SERVICE The undersigned certifies, on March 15, 2011, the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). /s/Douglas A. Cawley Douglas A. Cawley 5 Dallas 320120v1

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