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 17

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STAPLESLINK.COM AND EWAY.COM DAMAGES DISCOVERY REQUEST
Separately for stapleslink.com and eway.com, the date upon which each accused product/feature was first
made available to online customers.

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For the period beginning with Staples’ first use of an accused product/feature on stapleslink.com through
the present: Monthly or quarterly U.S. revenue generated from the sale of products over stapleslink.com.

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For the period beginning with Staples’ first use of an accused product/feature on stapleslink.com through
the present: on a monthly or quarterly basis, the number of products sold in the U.S. over stapleslink.com.

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For the period beginning with Staples’ first use of an accused product/feature on stapleslink.com through
the present: on a monthly or quarterly basis, costs Staples incurred through the sale of products in the U.S.
over stapleslink.com.

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For the period beginning with Staples’ first use of an accused product/feature on eway.com through the
present: monthly or quarterly U.S. revenue generated from the sale of products over eway.com.

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For the period beginning with Staples’ first use of an accused product/feature on eway.com through the
present: on a monthly or quarterly basis, the number of products sold in the U.S. over eway.com.

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For the period beginning with Staples’ first use of an accused product/feature on eway.com through the
present: on a monthly or quarterly basis, the costs Staples incurred through the sale of products in the U.S.
over eway.com.

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Presentations, memoranda, correspondence, or other internal documents pertaining to Staples’ use, or its
anticipated use of the accused products/features on stapleslink.com.

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Presentations, memorandums, correspondence, or other internal documents pertaining to Staples’ use, or
its anticipated use of the accused products/features on eway.com.

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Documents and other data pertaining to use of accused products/features by U.S. stapleslink.com
customers.

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Documents and other data pertaining to the extent to which Staples has implemented accused products/
features on stapleslink.com.

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Documents and other data pertaining to the use of accused products/features by U.S. eway.com customers.

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Documents and other data pertaining to the extent to which Staples has implemented accused products/
features on eway.com.

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For the period beginning with Staples’ first use of an accused product on stapleslink.com through the
present: the number and percentage of users, customers, or other visitors that accessed stapleslink.com
utilizing the following Internet browsers:
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Microsoft Internet Explorer;
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Apple Safari;
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Google Chrome;
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Mozilla;
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Firefox;
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Any other Internet Browser not identified.

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For the period beginning with Staples’ first use of an accused product on eway.com through the present:
the number and percentage of users, customers, or other visitors that accessed eway.com utilizing the
following Internet browsers:
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Microsoft Internet Explorer;
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Apple Safari;
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Google Chrome;
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Mozilla;
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Firefox;
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Any other Internet Browser not identified.