Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 714

MOTION to Compel PRODUCTION OF SOURCE CODE FROM EBAY INC. AND AMAZON.COM, INC. by Eolas Technologies Incorporated. (Attachments: # 1 Declaration of Joshua Budwin, # 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, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Text of Proposed Order)(McKool, Mike)

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EXHIBIT 27 Page 1 of 3 From: To: "Matt Rappaport" <mrappaport@McKoolSmith.com> "Matt Rappaport" <mrappaport@McKoolSmith.com>; "Perito, Andrew" <andrew.perito@weil.com>; "Jennifer Polleys" <jpolleys@McKoolSmith.com> Cc: "Eolas" <Eolas@McKoolSmith.com>; "Amazon-Eolas" <Amazon-Eolas@weil.com>; "EBay-Eolas" <eBayEolas@weil.com>; "Yahoo-Eolas" <Yahoo-Eolas@weil.com> Sent: Friday, April 15, 2011 3:36 PM Subject: RE: Eolas v. Adobe et al. - Amazon.com, eBay, and Yahoo! Counsel for Amazon, eBay, and Yahoo, As you know, Eolas will be inspecting Amazon, eBay and Yahoo's source code beginning on Monday April 18. Despite repeated requests for a response, none of Amazon, eBay or Yahoo have indicated whether they will be producing the code Eolas detailed in its March 30 correspondence to each of these defendants. I ask once again for a response to my correspondence to each of Amazon, eBay, and Yahoo from March 30. Thank you. From: Matt Rappaport Sent: Wednesday, April 13, 2011 4:32 PM To: Perito, Andrew; Jennifer Polleys Cc: Eolas; Amazon-Eolas; EBay-Eolas; Yahoo-Eolas Subject: RE: Eolas v. Adobe et al. - Amazon.com, eBay, and Yahoo! Thanks Andrew. Please further advise regarding Amazon, eBay, and Yahoo's production of source code, as detailed in my March 30 correspondence separately sent to each of Amazon, eBay and Yahoo. These issues have been outstanding for two weeks. As inspection of source code will occur next week your prompt attention to this matter is required. Best, Matt From: Perito, Andrew [mailto:andrew.perito@weil.com] Sent: Thursday, April 07, 2011 7:20 PM To: Matt Rappaport; Jennifer Polleys Cc: Eolas; Amazon-Eolas; EBay-Eolas; Yahoo-Eolas Subject: RE: Eolas v. Adobe et al. - Amazon.com, eBay, and Yahoo! Matt, we will make available for inspection the previously produced source code for Amazon, eBay and  Yahoo! on April 18‐22 at our Silicon Valley offices.   We are looking into your requests for supplemental  source code from each of the parties and will get back to you regarding those requests.   Our paralegal Joanna Lahtinen (joanna.lahtinen@weil.com, 650.802.3107) will be your reviewers'  contact for the inspection.   Best, Andrew   Andrew Perito 6/20/2011 Page 2 of 3   Weil, Gotshal & Manges LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065-1134 andrew.perito@weil.com +1 650 802 3993 Direct +1 650 802 3100 Fax   From: Matt Rappaport [mailto:mrappaport@McKoolSmith.com] Sent: Thursday, April 07, 2011 2:02 PM To: Jennifer Polleys; Reines, Edward Cc: Eolas; Amazon-Eolas Subject: RE: Eolas v. Adobe et al. - Amazon.com Counsel for Amazon, Please advise, as we have yet to hear from Amazon in response to my correspondence of March 30, 2011. In particular, please respond to indicate whether Amazon will produce the source code requested in my correspondence for Eolas’ inspection on April 18-22. Please also respond to provide an on-site contact for our reviewers during their inspection. Thank you. Matt Rappaport | Attorney | McKool Smith 300 W. 6th Street, Suite 1700 | Austin, TX 78701 telephone: 512/692-8754 | fax: 512/692-8744 mrappaport@mckoolsmith.com NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT and ATTORNEY WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, use or reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail in error, please notify the sender by reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed. From: Jennifer Polleys Sent: Wednesday, March 30, 2011 3:06 PM To: 'edward.reines@weil.com' Cc: Eolas; 'Amazon-Eolas@weil.com' Subject: Eolas v. Adobe et al. - Amazon.com Please see the attached correspondence from Matt Rappaport. Jennifer J. Polleys Legal Assistant | Software Support McKool Smith, P.C. | 300 W. 6th Street, Suite 1700 | Austin, Texas 78701 512/853-8439 | jpolleys@mckoolsmith.com NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT and ATTORNEY WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, use or reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail in error, please notify the sender by reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed. The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email 6/20/2011 Page 3 of 3 (postmaster@weil.com), and destroy the original message. Thank you. 6/20/2011

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