Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 712

MOTION to Compel DISCOVERY FROM ADOBE SYSTEMS, INC. REGARDING INVESTMENT/LICENSING AGREEMENTS WITH INTELLECTUAL VENTURES' ENTITIES by Eolas Technologies Incorporated. (Attachments: # 1 Declaration of Rosemary Snider, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Text of Proposed Order)(McKool, Mike)

EXHIBIT I

From. DavKl Healey [Healey@f,.oom)

Sent,

Friday, June 10, 2011 5:50 PM

To:

Josh Budwin; [e-mail]; [e-mail]

Cc:

Eolas; [e-mail]; [e-mail]: [e-mail]:[e-mail]; [e-mail];
[e-mail]; Adobe-Eolas; a![e-mail]; [e-mail];Mehta, Sanal

Subject: RE: Eolas: IV and !IF discovery requests

To be clear, we also believe it is also unduly burdensome sinee it is not designed to lead to the

discovery of relevant evidence: It is implausible under Lucent to argue this discovery could lead

to relevant evidence on the basis offered by Eolas, that a patent within a licensed portfolio -­

which itselfis part of a bigger transaction -- might be comparable to one ofthe two Eolas

patents, making the entire transaction relevant or designed to lead to relevant evidence on GP

Factor 2, comparable licenses, or any other GP factor.

This said, we will confirm a time and date shortly.

David Healey

Fish & Richardson

One Houston Center, Suite 2800

Houston, Texas 77010

healev@fLcom

713-385-6566 mobile

713-653-5400 office

From: Josh Budwin [[e-mail]]

Sent: Friday, June 10,2011 5:42 PM

To: [e-mail]; jdoanCtilhaltomdoan.com

Cc: Eolas; yahoo-eolas@weiteom; amazon-eolas@weitcom; ebay-eol.,@weitcom;

[e-mail]; [e-mail]; [e-mail]; Adobe­

Eol.s; [e-mail]; [e-mail]; Mehta, Sonal

Subject: RE: Eolas: IV and !IF discovery requests

Thank you for the call today. We understand the defundants refuse to produce the requested
information because they contend it is not relevant Accordingly, we request that each defendant
or the defendants collectively provide us with a date for a Rule 7 mect and eonfer between
Monday and Wednesday next week.

Josh Thane <[e-mail]> wrote:

All:
Below is dial-in information for our 5:30pm CT call.
Telephone #[phone]
Passcode: 46918

From: Josh Budwin [maiito:[e-mail]]
Senl: Friday, June 10,20112: 12 PM
To: Josh Budwin; Josh Thane; Jennifer Doan
Cc: Eolas; Yahoo-Eolas; Amazon-Eolas; EHay-Eolas; [e-mail];apple­
[e-mail];R&GGroupGoogle;F&RGroup Adobe; [e-mail];
[e-mail]; Mehta, Sonal
Subject: RE: Eolas: IV and IIF discovery requests
Please provide the dial-in numbeL

From: Josh Budwin