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 D

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Today's high-tech products ctm (ontain hundreds or thous,mos. of patented

IV Customers:

invimticns resultlng jn Invention Gap'" exposure for technology companies. The
invention Gi.lp-t~e difference between t~ inventIon rights companies own and

VAL:JEADDE:.l J'lfWDUCn

the intellectua! property (Ipj ilSsetS they use~represents a strategic risk and

CONT AC LICENSING

potentially substantial financla! liability. According to PricewaterhouseCOOp€f5

lLP, over the past 15 years, Ihc annuaf median damages av.t;)!d for patent

Current licensef'$ include
many of the world's most
successful Fortune SOO
companies from the software,
consumer electrOnics,

litigation in the U.s. hilS ranged from $2AM to $1O.5M-with sIngle initial

financial services, mobile

ludgments as high as $1,86. Together with our customers, Intellectual Ven!:Jres

(lv<t) j,~ Bridging the Invention GapTI" by $lgt\ifical'tly reducing their liabilities ana
providing access to valuable invention right!;,

phone. <lnu eCommerce
indust"ies, including

HTC, Sam sung. and SAP.

Since our inception, we have joined with many of the world's top innovative

IV Invention Portfolio:

tec':nology companies to actively minimize the liabifty resulting from their
InventIOn Gap exposure, Intellectual Ventures offers licenses to

our extensive

portfolio of invention rights to reduce these near-term risk<; whi:e providing

Braod Techflology Market

Coverage: Agriculture,

long-term value ti'roughou{ the IP lifu><:ycie. 6enefits:IV's licensees receive include:
Competitive advantage by 'ever<;lging of one of the Industr{5largert and

autOMotive, communication5,
computer hardw;)re,

fastest-growing patent portfolios

con:;truction, conSUO'Ier

Efficient sour<:ing of valuable ~nVffltion nghts-now "H1d in the future

electronics, eCommel ce,
energy, fin<;lncial services,

Reduced expOSJre to costly, !;'me-Consuming litigation

health technologies,
IV believes that relationships reduce fisk and create value. We also recognize the

il)form;)tion technology, Ilfe

investment our customers make in licensing nUf portfolio, and are committed to

sciences, rrateria!:; science,

ensuring that Yalu€ is protected. Because Ideas and il'lv«ltions are Y;;Iluable, when

medical devic~,

required, we wili rigoroU5Jy defend our invention tights in order to continue

nanotechnology, physical

to

provide strOltegic OInd financlOlI benefits 10 our customent
But t~e v<;Ijue customers re<:o!'jye extends beyond licensing our portfolio of mo'e
than 30,OCO patent asse:s.IV also offers unique value-;;Idded prooucts and services
that further enable companies to M;;Iximile the re!ur'O on their licensing
iOvestment

sciences, security,
semiconductors, and

software

leamMore:
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