Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 968

MOTION to Compel LOG-IN INFORMATION FOR STAPLESLINK.COM AND EWAY.COM FROM STAPLES INC. by Eolas Technologies Incorporated. (Attachments: # 1 Attachment A, # 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 Text of Proposed Order)(McKool, Mike)

EXHIBIT 15

Gretchen Curran
From:
Sent:
To:
Cc:
Subject:

Tom Fasone III
Saturday, August 20, 2011 8:56 AM
Matuschak, Mark; Hutchins, Kate; [e-mail]; Williams, Daniel V.; Hardt,
Jonathan; Ewenstein, Richard I
Eolas; Gretchen Curran; John B. Campbell; Josh Budwin; Bob Kramer
Eolas/Staples: LR7 CONFERENCE AGENDA

Counsel
Please be prepared to fully address each of the discovery issues identified below during our LR7 Conference on
Monday.
Regards,
Tom
AGENDA ITEMS FOR AUGUST 22, 2011 LR7 CONFERENCE
(1) COMPLETE SUPPLEMENTAL RESPONSE TO COMMON ROG NO. 6 BY A DATE CERTAIN
(2) COMPLETE SUPPLEMENTAL RESPONSES TO SPECIFIC ROG NOS. 1, 6, AND 7 BY A DATE
CERTAIN
(3) DEPOSITION OF STEVE BUSSBERG BY A DATE CERTAIN AND COMPLETE PRODUCTION OF
HIS CUSTODIAL DOCUMENTS WELL IN ADVANCE OF HIS DEPOSITION
(4) DEPOSITION OF ADAM CHASE BY A DATE CERTAIN AND COMPLETE PRODUCTION OF HIS
CUSTODIAL DOCUMENTS WELL IN ADVANCE OF HIS DEPOSITION
(5) ACCESS TO INSPECT AND RUN REPORTS ON WEB ANALYTICS TOOLS/METRICS
DATABASES, INCLUDING SITESPECT, TEALEAF, AND TEST AND TARGET BY A DATE CERTAIN
AND ACCESS TO OR PRODUCTION OF USER MANUALS/GUIDES FOR EACH ANALYTICS TOOL
WELL IN ADVANCE OF THE INSPECTION
(6) MOTION FOR LEAVE TO ADD B2B SITES (STAPLESLINK.COM AND EWAY.COM (PROJECT
NEW WAY))
(7) COMPLETE PRODUCTION OF SPECIFIC DOCUMENTS IDENTIFIED BY STAPLES' DEPONENTS
OR CERTIFICATION STATING THAT A REASONABLE SEARCH HAS BEEN CONDUCTED FOR THE
REQUESTED DOCUMENTS AND THAT NO SUCH DOCUMENTS EXIST, BY A DATE CERTAIN. TO
THE EXTENT PRODUCTION OF SUCH DOCUMENTS HAS/WILL BE MADE, THE PRODUCTION
DATES AND BATES NUMBERS IDENTIFYING THE REQUESTED DOCUMENTS WITHIN THE
PRODUCTION.
(8) CUSTODIAL INFORMATION BY BATES NUMBERS AND PRODUCTION DATES FOR ALL
SCHEDULED DEPONENTS
(9) CORPORATE RELATIONSHIP BETWEEN STAPLES, INC. AND QUILL.COM
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