Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 634

MOTION FOR LEAVE TO SUPPLEMENT INFRINGEMENT CONTENTIONS FOR ANDROID 3.0 by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit A.1, # 2 Exhibit A.2, # 3 Exhibit A.3, # 4 Exhibit A.4, # 5 Exhibit A.5, # 6 Exhibit A.6, # 7 Exhibit A.7, # 8 Exhibit A.8, # 9 Exhibit A.9, # 10 Exhibit A.10, # 11 Text of Proposed Order)(McKool, Mike)

EXHIBIT A.6

King & Spalding LLP
1185 Avenue of the Americas
New York, New York 10036-4003
www.kslaw.com

Mark H. Francis
Direct Dial: [phone]
Direct Fax: [phone]
[e-mail]

April 3, 2011

VIA EMAIL
Matt Rappaport
McKool Smith
300 West 6th Street
Suite 1700
Austin, Texas 78701
Re:

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

Dear Matt:
Google opposes Eolas’s attempt to supplement infringement contentions. There is no
good cause to supplement infringement contentions at this late, post-Markman stage in the case.
In addition, Android 3.0 is simply a new version of a pre-existing product that has already been
accused of infringement by Eolas. There is no reason why Eolas could not have identified the
Google Browser and YouTube Player in its initial infringement contention claim charts.

Very truly yours,

/s/ Mark H. Francis
Mark H. Francis

cc:

Eolas Outside Counsel (via e-mail)
Google Outside Counsel (via e-mail)