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)

EXHIBIT 4

September 3, 2010

VIA EMAIL
Josh W. Budwin
McKool Smith
300 West Sixth Street, Suite 1700
Austin, TX 78730

Re;

Eolas Technologies Incorporated v. Adobe
Svstems Incorporated et aL~ Case No. 09-cv-446

Dear Josh:

I write in response to your September 3, 2010 letter stating that
Amazon.corn Inc. ("Amazon") "[h]as produced no source code." Pursuant to the
applicable rules and orders of the Court, Amazon’s source code is ready for inspection
and was available for inspection upon providing the notice required by the agreed portion
of the Protective Order as of September 1, as was required by the Court’s August 12
Extension Order. Amazon will make its code available for inspection at the Silicon
Valley office of Weil, Gotshal & Manges LLP at 201 Redwood Shores Parkway,
Redwood Shores, CA 94065 once it receives sufficient notice under the agreed portion of
the Protective Order.
Amazon designates its source code made available for inspection as
CONFIDENTIAL - ATTORNEYS’ EYES ONLY - SOURCE CODE pursuant to the
agreed portion of the Protective Order filed Friday, September 3, 2010 and Patent Local
Rule 2-2.
Please contact me if you have any further questions.

PCA:lab

September 3, 2010

VIA EMAIL
Josh W. Budwin
McKool Smith
300 West Sixth Street, Suite 1700
Austin, TX 78730

Re:

Eolas Technologies Incorporated v. Adobe
S~stems Incorporated et al.~ Case No. 09-cv-446

Dear Josh:
I write in response to your September 3, 2010 letter stating that eBay Inc.
("eBay") "[h]as produced no source code." Pursuant to the applicable rules and orders of
the Court, eBay’s source code is ready for inspection and was available for_inspection
upon providing the notice required by the agreed portion of the Protective Order as of
September 1, as was required by the Court’s August 12 Extension Order. eBay will make
its code available for inspection at the Silicon Valley office of Weil, Gotshal & Manges
LLP at 201 Redwood Shores Parkway, Redwood Shores, CA 94065 once it receives
sufficient notice under the agreed portion of the Protective Order.
eBay designates its source code made available for inspection as
CONFIDENTIAL - ATTORNEYS’ EYES ONLY - SOURCE CODE pursuant to the
agreed portion of the Protective Order filed Friday, September 3, 2010 and Patent Local
Rule 2-2.
Please contact me if you have any further questions.
Sincerely~ ~

PCA:lab