Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 375

RESPONSE in Opposition re 367 Opposed MOTION Adobe Systems Incorporated's Opposed Motion Requesting Case Management Conference To Address Plaintiff Eolas's Infringement Contentions Or, In The Alternative, To Strike Those Contentions and Motion For Expedited Consideratio filed by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3A, # 4 Exhibit 3B, # 5 Exhibit 3C, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10)(McKool, Mike) (Additional attachment(s) added on 8/5/2010: # 13 Text of Proposed Order) (kls, ).

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 375 Att. 1

Exhibit 1

Dockets.Justia.com

Eolas: response re your July 19 letter
Matt Rappaport
From: Sent: To: Cc: Joseph P. Reid [[e-mail]] Tuesday, July 27, 2010 3:40 PM Josh Budwin Eolas; Joseph P. Reid

Page 1 of 1

Subject: Eolas: response re your July 19 letter

Josh: During our call with you about discovery issues on July 14, you suggested that, to narrow the number of document custodians, we could begin by identifying the people who work on the accused products with respect to how they interact and interface with browser programs such as Internet Explorer, Safari, etc. That process is underway and, once we have those people identified, we will be following up with you regarding search terms. Unfortunately, we are at a loss when it comes to harmonizing the approach above with your letter dated July 19, requesting materials regarding Scene7 and the socalled "third party website design vendors." As you did on July 14, can you please provide us with some clarification of what you actually need with respect to Scene7 and the other entities identified in your letter (as opposed to "[a]ll documents and things"), or is there a time for us to have a call along the lines of our previous one to discuss how we should approach these requests? Please let me know. As a final matter, your team indicated to ours during the meet and confers regarding Adobe's motion for a case management conference that Eolas would be dropping its allegations against Adobe's authoring tools. Can you please send us a letter confirming that? Thanks, Joe
Joseph P. Reid Fish & Richardson P.C. 12390 El Camino Real San Diego, CA 92130 Tel: [phone] Fax: [phone] Cell: 858-205-3411

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7/29/2010