Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 393

NOTICE by Google Inc., YouTube, LLC 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 and Identification of Related Issues to be Addressed (Attachments: # 1 Declaration of M. Francis, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23)(Jones, Michael)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 393 Att. 3

Exhibit 2

Dockets.Justia.com

KING

&

SPALDING

I 185 Avenue of the Americas New York, New York 10036-4003 www.kslaw.com Christopher C. Carnaval Direct Dial: (2 12) 556-2154 Direct Fax: (2 12 ) 556-2222 [e-mail]

July 12,2010
VIA OVERNIGHT MAIL

Josh Budwin McKool Smith 300 West 6th Street Austin, TX 78701

Re:

Eolas Technologies Inc. v. Adobe Systems, Inc., et al. (Case No. 6:09-cv-446-LED)

Dear Josh: Pursuant to Local P.R. 3-4(a), enclosed is one (1) CD containing electronic copies of the ("Google"), labeled KS _ GOOGLE_00002395 production from Google Inc. KS _ GOOGLE_00007230. This production, and future Google productions, will include the productions of Google's subsidiary, YouTube, LLC. Certain documents in the production have been marked "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS ' EYES ONLY" in accordance with the designations contemplated in the draft Protective Order being negotiated by the parties in this case. However, until such time as the Protective Order is granted, all designated documents should also be treated confidential in accordance with Local P.R. 2-2. Additionally, included in Google's production are fourteen (14) CDs/DVDs of material designated "OPEN SOURCE CODE" in accordance with the designation contemplated in the draft Protective Order being negotiated by the parties in this case:
(1) Google Chrome: Google Chrome source code is available for review online and for download. (See http://www.chromium.org/Home). We have enclosed six (6) DVDs containing the following selected versions for your review:

(a) 1.0.154.53 (b) 2.0.172.8 (c) 3.0.195.38 (d) 4.1.249.1 067 (e) 5.0.396.0

Josh Budwin July 12, 2010 Page 2
(f) 6.0.450.1

(2) Google ChromeOS: Google ChromeOS source code is available for review online and for download. (See http://www.chromium.orglchromium-os/building-chromium-os). We have enclosed a DVD containing a recent version for your review.
(3) Google Android: Google Android source code is available for download. (See http://source.android.com/source/download.html). We have also enclosed four (4) DVDs containing selected versions for your review:

(a) 1.5 ("Cupcake") (b) 1.6 ("Donut") (c) 2.01 .1 ("Eclair") 2 (d) 2.2 ("Fro yo")
(4) Google Closure Library: Google Closure Library source code is available for download. We have enclosed a CD containing the Google Closure Library source code for your review.
(See http://code.google.com/p/closure-Iibrary/source/checkout).

(5) Google Web Toolkit: Google Web Toolkit ("GWT") source code is available for download.
(See http://code.google.com/webtoolkitldownload.html). We have enclosed a CD containing the

GWT source code for your review. (6) Google V8 Engine: Google V8 Engine source code is available for download. (Se e http://code.google.com/apis/v8/build.html). We have enclosed a CD containing the V8 Engine source code for your review. You should also be receiving Defendants' Invalidity Contentions and Local P.R. 3-4(b) productions from counsel for Apple Inc. and other defendants. Google anticipates that it will produce additional documents as discovery continues. Please contact us at your earliest convenient to discuss the availability and location of the inspection of additional, relevant source code. If you have any questions, please let us know.

Christopher C. Carnaval Enclosures