Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 325

MOTION for Protective Order by Staples, Inc.. (Attachments: # 1 Affidavit Declaration of Alexandra McTague, # 2 Exhibit Exhibit 1 to McTague Declaration, # 3 Exhibit Exhibit 2 to McTague Declaration, # 4 Text of Proposed Order)(Richardson, Michael)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Eolas Technologies Incorporated, Plaintiff, vs. Adobe Systems Inc., Amazon.com, Inc., Apple Inc., Blockbuster Inc., CDW Corp., Citigroup Inc., eBay Inc., Frito-Lay, Inc., The Go Daddy Group, Inc., Google Inc., J.C. Penney Company, Inc., JPMorgan Chase & Co., New Frontier Media, Inc., Office Depot, Inc., Perot Systems Corp., Playboy Enterprises International, Inc., Rent-A-Center, Inc., Staples, Inc., Sun Microsystems Inc., Texas Instruments Inc., Yahoo! Inc., and YouTube, LLC Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 6:09-cv-446

DECLARATION OF ALEXANDRA MCTAGUE IN SUPPORT OF DEFENDANT STAPLES, INC.'S MOTION FOR A PROTECTIVE ORDER I, Alexandra McTague, declare: 1. I am an attorney at Wilmer Cutler Pickering Hale and Dorr LLP, counsel for

Defendant Staples Inc. in this action. I submit this declaration in support of the Motion for Protective Order by Defendant Staples Inc. 2. Attached as Exhibit 1 is a true and correct copy of an email from Kate Hutchins,

of Wilmer Cutler Pickering Hale and Dorr LLP, to Josh Budwin, of McKool Smith, dated June 16, 2010, stating, in part, "Nevertheless, if there is particular information from the declarations filed on Monday by Staples that you would like clarified, or other information that you believe you need despite our earlier agreement, then please let us know promptly."

3.

Attached as Exhibit 2 is a true and correct copy of an email from Matt Rappaport

of McKool Smith to Mark Matuschak of Wilmer Cutler Pickering Hale and Dorr LLP dated May 25, 2010, stating, in part, "The declaration is acceptable, once we receive an executed version Eolas will withdraw its venue-related discovery as to Staples." I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 18, 2010 New York, NY

/s/ Alexandra McTague

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