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)

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:

[e-mail]; [e-mail]; 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: [phone]
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8/2/2011