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 19

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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.

• Documents and other data sufficient to show the direct incremental revenue and costs
associated with the implementation and of accused products/features by U.S. stapleslink.com
customers.
• Documents and other data sufficient to show the extent to which Staples has implemented
accused products/features on stapleslink.com.

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

• Documents and other data sufficient to show the direct incremental revenue and costs
associated with the implementation and use of accused products/features by U.S. eway.com
customers.

Deleted:

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

Deleted: pertaining

• 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:

Deleted: pertaining to the

Deleted: to

• Microsoft Internet Explorer;
• Apple Safari;
• Google Chrome;
• Mozilla;
• Firefox;
• Any other Internet Browser not identified.
• 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:
• Microsoft Internet Explorer;
• Apple Safari;
• Google Chrome;
• Mozilla;
• Firefox;
• Any other Internet Browser not identified.