Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 815

Opposed MOTION for Leave to File Supplement to its PR 3-1 Infringement Contentions with Respect to Google Music and Google+ by Eolas Technologies Incorporated. (Attachments: # 1 Affidavit Declaration, # 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 Text of Proposed Order Order)(McKool, Mike)

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EXHIBIT 2 Page 1 of 1 From: Christopher J. Mierzejewski Sent: Tuesday, May 10, 2011 1:21 PM To: Rao, Sasha; Ropes Google Group Cc: allengardner@potterminton.com; mikejones@potterminton.com; Eolas Subject: Eolas v. Adobe et al - Google's new release of Google Music. Counsel, It has come to our attention that Google has just released a new infringing product, Google Music. From the information available at http://music.google.com/about/, this is yet another infringing product created by Google. We request that Google supplement its discovery to include this new infringing product, including production of documents related to Google Music and supplementation of Google's Interrogatory Responses to include Google Music. It is also our understanding that Google Music currently requires an invitation from Google in order to access the functionality. Eolas requests invitations be arranged for various attorneys and experts to be designated by Eolas so that the infringing functionality may be examined and Preliminary Infringement Contentions drafted directed towards Google Music. Please advise on when Google will be able to provide this discovery supplementation and invitations. Christopher J. Mierzejewski | McKool Smith 300 W. 6th Street, Suite 1700 | Austin, Texas 78701 telephone: 512.692.8740 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. 8/2/2011

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