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

Filing 106

Declaration re 105 Memorandum in Support of Emily O'Brien by Google Inc., IAC Search & Media, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Noona, Stephen)

EXHIBIT O

DICKSTEINSHAPI
1825
TEL

Eye

202

NW

Street

ROLLP
DC 20006-5403

Washington

420-2200

29

202

tax

2012

February

420-2201

dicksteinshapiro.com

Via E-mail

David Perison Esq
Quinn Emanuel Urquhart

Sullivan

LLP

50 California Street 22nd Floor

CA

San Francisco

Re

94111

Contentions

Supplemental Infringement

Engines

I/P

Dear David

In response

you

I/P

your February

to

Engine

I/P

documents

portions
support

for

Engines

I/P

that

claim

for

420

incorrect

is

To

claims

to

response

I/P

Defendants should

Engines

664

and

supplement

interrogatories

and

that

Engines

their

accordance

in

opinion

for

contentions

and

each

and cited public and
identified the relevant
substantial

Google

or any

other defendant
of

understanding

Google

contentions

non-infringement

in

Meg

Ken

Infringement

and provides

litigation

the extent
or I/P

patents

Engine has

I/P

by the present

implicated

infringement

the

between

current infringement

its

contentions

those

support

forth

set

emails

Engines Supplemental

I/P

any of the claim limitations are missing

believes

system

to

Ad Words

of Google

and the subsequent

letter

Engine has

claim limitation of each asserted
confidential

2012

your allegations

rejects

are deficient

Contentions

27

with Defendants

in

ongoing discovery

obligations

to

Contrary

your implication
of

sufficiency

I/P

infringement

alleged

evidence

in

support

New

York

contrary to

of certain infringement

prior art onto

the parties

Contentions

does

its

regarding

not

limit

First Defendants have asserted

of their counterclaims

Second

contentions

explanation

Los Angeles

invalidity

Infringement

contentions

between

of invalidity and bear the burden of supporting

counterclaims

Defendants

further

Engines Supplemental
of their

supplementation

judgment

any difference

are

not

your assertions

contentions

are

dependent

Defendants

declaratory

those assertions

on

your request

not necessary

the

for

I/P
for

Engines
I/P

Google

Engines
to

read any

interpretation of the claims

Orange

County

Silicon

Valley

Stamford

Washington

DC
DSMDB-303487

DICKSTEINS HAP

IROLLP

David Perison Esq
February

29

2012

Page

Contrary
Listings

to

your

letter

Engine continues

I/P

of infringing the

420

and

664

to

patents

accuse
as I/P

Google

Search

Engine has

and

asserted

IACs Ask
in

its

Sponsored

infringement

contentions

Best regards

harles

202

Monte

io

Jr

420-5167

[e-mail]

CJM
cc

Stephen

Noona

David Bilsker
Kenneth
Jeffrey

DeAnna

Brothers

Sherwood
Allen

DSMDB-303487