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)

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. Match.com, 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.

Dockets.Justia.com

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.

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DATED: March 15, 2011.

Respectfully submitted, McKOOL SMITH, P.C. /s/ Douglas A. Cawley Douglas A. Cawley, Lead Attorney Texas State Bar No. 04035500 [e-mail] Theodore Stevenson, III Texas State Bar No. 19196650 [e-mail] Rosemary T. Snider Texas Bar No. 18796500 [e-mail] Scott W. Hejny Texas Bar No. 24038952 [e-mail] Jason D. Cassady Texas Bar No. 24045625 [e-mail] J. Austin Curry Texas Bar No. 24059636 [e-mail] Phillip M. Aurentz Texas State Bar No. 24059404 [e-mail] MCKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 [phone] [phone] FAX Sam F. Baxter Texas State Bar No. 01938000 [e-mail] MCKOOL SMITH, P.C. 104 E. Houston St., Suite 300 Marshall, TX 75670 [phone] [phone] FAX

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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: [phone] Facsimile: 903-533-9687 E-mail: [e-mail] E-mail: [e-mail] ATTORNEYS FOR PLAINTIFF BEDROCK COMPUTER TECHNOLOGIES LLC

/s/Claude M. Stern (with permission by Douglas A. Cawley) Claude M. Stern [e-mail] Evette D. Pennypacker [e-mail] Todd M. Briggs [e-mail] QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Telephone: [phone] Facsimile: 650-801-5100 Michael E. Jones [e-mail] Texas State Bar No. 10929400 POTTER MINTON, P.C. 110 N. College Tyler, Texas 75702 Telephone: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANT GOOGLE INC. AND MATCH.COM, INC.

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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

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