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. 2

Exhibit 2

Dockets.Justia.com

Untitled Document Matt Rappaport
From: Sent: To: Cc: Subject: Hi Anthony, Thanks for your email. Attached is our proposed revision to the term list you provided. Please let us know if this works on your end. Matt Rappaport | Attorney | McKool Smith 300 W. 6th Street, Suite 1700 | Austin, TX 78701 telephone: [phone] | fax: [phone] [e-mail]
NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT and ATTORNEY WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, use or reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail in error, please notify the sender by reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed.

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Matt Rappaport Tuesday, July 27, 2010 4:48 PM 'Anthony S. Gabrielson'; Josh Budwin Thomas L. Duston; Eolas RE: Eolas: CDW ESI Search Terms

Attachments: 2010 07 27 - Eolas - CDW Proposed Search Terms.pdf

From: Anthony S. Gabrielson [mailto:[e-mail]] Sent: Monday, July 26, 2010 5:40 PM To: Josh Budwin; Matt Rappaport Cc: Thomas L. Duston Subject: Eolas: CDW ESI Search Terms Hi Josh & Matt -- further to our conversation last week about ESI search terms, here is a proposed revision on the terms for CDW, modified as we discussed. Please let me know if it is OK from your end. Thanks, Anthony

Anthony S. Gabrielson Marshall, Gerstein & Borun LLP 233 South Wacker Drive 6300 Willis Tower Chicago, IL 60606-6357 Direct: [phone] Firm: [phone] Fax: [phone] [e-mail] www.marshallip.com The material in this transmission may contain confidential information. If you are not the intended recipient, any disclosure or use of this information by you is strictly prohibited. If you have received this transmission in error, please delete it, destroy all copies and notify Marshall, Gerstein & Borun LLP by return e-mail or by telephone at [phone]. Thank you.

7/29/2010

Matt Rappaport
From: Sent: To: Cc: Subject: Anthony S. Gabrielson [[e-mail]] Wednesday, July 21, 2010 2:38 PM Josh Budwin Matt Rappaport RE: Eolas Technologies Inc. v. Adobe Systems, Inc., et al., No. 6:09-cv-446 (E.D. Tex)

Great; talk to you then. Anthony

Thanks.

-----Original Message----From: Josh Budwin [mailto:[e-mail]] Sent: Wednesday, July 21, 2010 2:10 PM To: Anthony S. Gabrielson Cc: Matt Rappaport Subject: RE: Eolas Technologies Inc. v. Adobe Systems, Inc., et al., No. 6:09-cv-446 (E.D. Tex) 3 central works. Matt knows better than I, so I'll rope him in too.

-----Original Message----From: Anthony S. Gabrielson [mailto:[e-mail]] Sent: Wednesday, July 21, 2010 2:06 PM To: Josh Budwin Subject: RE: Eolas Technologies Inc. v. Adobe Systems, Inc., et al., No. 6:09-cv-446 (E.D. Tex) Hi Josh -- If you have a few moments, I'd like to chat with you about the search terms proposals we've exchanged re CDW (I talked with Matt Rappaport while you were away briefly about it also), and was wondering if you're in the office later today, 3-ish maybe? Please let me know. Thanks much, Anthony

Anthony S. Gabrielson Marshall, Gerstein & Borun LLP 233 South Wacker Drive 6300 Willis Tower Chicago, IL 60606-6357 Direct: [phone] Firm: [phone] Fax: [phone] mailto:[e-mail] http://www.marshallip.com/ The material in this transmission may contain confidential information. If you are not the intended recipient, any disclosure or use of this information by you is strictly prohibited. If you have received this transmission in error, please delete it, destroy all copies and notify Marshall, Gerstein & Borun LLP by return e-mail or by telephone at [phone]. Thank you. -----Original Message----From: Josh Budwin [mailto:[e-mail]] Sent: Wednesday, July 21, 2010 1:11 PM To: [e-mail] Cc: Eolas; [e-mail] Subject: Re: Eolas Technologies Inc. v. Adobe Systems, Inc., et al., No. 6:09-cv-446 (E.D. Tex)
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Page 1 of 2 Matt Rappaport
From: Sent: To: Cc: KatieSure, 2pm PT works for tomorrow, assuming we're off the protective order call by then. Thanks. Matt Rappaport Monday, July 19, 2010 5:22 PM 'Riley, Kathryn' '[e-mail]'; Eolas

Subject: RE: Eolas -- OAI's proposed search terms

From: Riley, Kathryn [mailto:[e-mail]] Sent: Monday, July 19, 2010 3:14 PM To: Josh Budwin; Gomez, Ginny; Oracle-Eolas Cc: Eolas Subject: RE: Eolas -- OAI's proposed search terms Josh we can be available at or after 2pm PT tomorrow. It would be helpful if you could give me some insight into your concerns in advance of our call so I can be prepared to address them. In the future, please include [e-mail] on all correspondence. Thanks.

From: Josh Budwin [mailto:[e-mail]] Sent: Monday, July 19, 2010 1:08 PM To: Gomez, Ginny; Riley, Kathryn Cc: Eolas Subject: Eolas -- OAI's proposed search terms Katie Are you available to discuss your proposed search terms this afternoon or tomorrow? We have some concerns. Thanks.

From: Gomez, Ginny [mailto:[e-mail]] Sent: Thursday, July 15, 2010 6:10 PM To: Josh Budwin Cc: Eolas Subject: Attached please find Katie Riley's July 15, 2010 letter to Josh Budwin.

Ginny Gomez

7/29/2010

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Intellectual Property and Technology Legal Secretary to Browning Marean, Rick Mulloy, Kathryn Riley, Erin Gibson, Tiffany Miller and F.P. Crowell DLA Piper LLP (US) 401 B Street, Suite 1700 San Diego, CA 92101-4297
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Please consider the environment before printing this email.
The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole use of the intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please reply to the sender and destroy all copies of the message. To contact us directly, send to [e-mail]. Thank you.

7/29/2010