I/P Engine, Inc. v. AOL, Inc. et al

Filing 1005

Declaration re 1003 Opposition, (of Joshua L. Sohn) in Support of Defendants' Opposition to Plaintiff's Motion for Leave to File Supplemental Memorandum Regarding Motion to Show Cause and Motion to Strike Plaintiff's Supplemental Memorandum by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Noona, Stephen)

EXHIBIT 4

Joshua Sohn

Subject:

Monterio, Charles [[e-mail]]
Monday, September 23, 2013 6:48 PM
QE-IP Engine; Stephen E. Noona ([e-mail])
Donald C. Schultz ([e-mail]); zz-IPEngine; W. Ryan Snow ([e-mail])
I/P Engine v. Google

Follow Up Flag:
Flag Status:

Follow up
Completed

From:
Sent:
To:
Cc:

David,
Following Mr. Furrow’s deposition, we request that Google immediately produce (by Tuesday, September 24th):



The textual descriptions in change lists associated with change list numbers for all produced source code files
(accessible by at least the Critique and Perforce systems); and
The Launch Cal entry for disabling off and promotion off.

During his deposition, Mr. Furrow confirmed that these documents exist and are clearly relevant to the changes in the
AdWords system. They should have been produced by Google long ago.
Charles J. Monterio, Jr.
Associate
Dickstein Shapiro LLP
1825 Eye Street NW | Washington, DC 20006
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