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; jthane@haltomdoan.com; jdoan@haltomdoan.com
Cc:
Eolas; yahoo-eolas@weil.com; amazon-eoJaS@weil.com: ebay..eofaS@weil.com:apple@emafirm.com; apple..eolaS@sidley.com;
ropesgooglegroup@ropesgray.com; Adobe-Eolas; a!lengardner@potterminton.com; mikejones@potterminton.com;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 [jbudwin@McKoolSmitb.com]
Sent: Friday, June 10,2011 5:42 PM
To: jthane@haltomdoan.com; jdoanCtilhaltomdoan.com
Cc: Eolas; yahoo-eolas@weiteom; amazon-eolas@weitcom; ebay-eol.,@weitcom;
apple@emafirm.eom; apple-eolaS@sidley.eom; ropesgooglegroup@ropesgray.com; Adobe
Eol.s; .1Iengaroner@potterminton.com; mikejones@potterminton.com; 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 wrote:
All:
Below is dial-in information for our 5:30pm CT call.
Telephone #888-889-4952
Passcode: 46918
From: Josh Budwin [maiito:jbudwin@McKooISmith.com]
Senl: Friday, June 10,20112: 12 PM
To: Josh Budwin; Josh Thane; Jennifer Doan
Cc: Eolas; Yahoo-Eolas; Amazon-Eolas; EHay-Eolas; appJe@emafirm.coml;apple
eolas@sidley.com;R&GGroupGoogle;F&RGroup Adobe; allengardner@potterminton.com;
mikejones@potterminton.com; Mehta, Sonal
Subject: RE: Eolas: IV and IIF discovery requests
Please provide the dial-in numbeL
From: Josh Budwin
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