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 Q
APIRO
IC KSTE IN
1825
TCL
Eye
202
NW
Street
March
DC 20006-5403
Washington
202
ix
420-2200
LLP
420-2201
dicksteinshapiro.com
2012
Via E-mail
Kammerud Esq
Margaret
Quinn Emanuel
LLP
Sullivan
Urquhart
50 California Street 22nd Floor
CA
San Francisco
Re
Googles March
2012 Letter
Meg
Dear
Engine writes
I/P
94111
2012 which was
correct
to
received
With respect
to
where
contentions
that
you
in
the
as
discussed
that
of documents
aware of additional
supplement
contentions
infringement
request
to
stated
you
I/P
I/P
stand on
contentions
statements
of March
Brothers
answer
that
to
responses
collaborative
to
I/P
their
I/P
that
by supplemental
not
reiterated
its
response
interrogatory
to
contrary
with
engage
We
current infringement
are sufficient
position
that
request
to
accurate
further
when any
that
party
seasonably
Google
Google
We
the ongoing
or defenses the party should
claims
Thus
its
is
and analyze
receive
to
reiterated
Engine
its
contentions
its
In response
substantively
That
Engine stands on
I/P
Engine
to
you point out
that
filtering
contentions
Engine continues
I/P
asked
stated
and also refused
Engine believes
relating
Plaintiff
that
Engine did not agree
mischaracterization
to
Ken
explain
its
acknowledged
your characterizations
I/P
non-
that
Engine did
engage
Additionally
claims
letter to
your
you
infringement
and explained
but offered no further response
not refuse
to
by Defendants
facts
discovery
its
contentions
Engines
continuing
is
discovery
refused
I/P
As we explained
production
is
we
that
issue at length
this
contentions
noted
infringement
any issue related to
in
720 p.m EST
you think you have pointed
stated
question you
to
at
Engines
I/P
included
characterizations
to
declined
within
statement
of the
and overgeneralization
current infringement
its
such
its
contentions
to further characterize
infringement
collaborative
that
agreed
required
indeed your statement
claims
repeatedly
the claims
contentions
is
filtering
is
the call I/P
During
referred you
to
the
Engine elected
language of the
of the patents-in-suit beyond
and declined
to
engage
in
by the
its
arguments over
claim
construction
I/P
Engine also did not refuse
IACs Ask
Sponsored
Los Angeles
New
York
to
Listings
Orange
County
supplement any of
Consistent
Silicon
with
Valley
I/P
its
contentions
Engines
Stamford
on Google
position
Washington
that
Search andlor
supplementation
was
DC
DSMDB-3035976
DICKSTEINSHAPIROLLP
Kammerud Esq
Margaret
March
2012
Page
party had
when
appropriate
as to
contentions
infringement
new
Search
the parties
of Google
Search
and
regarding
Google
Search
Google
to
IACs Ask
to
respect
we
As
contentions
Once Google
now
to
move
that
so
I/P
discussions
in
its
Sponsored
amend
Google
does
review them
Search
IACs Ask
and
interrogatory
supplement
respect
responses
With
response
its
were only recently
the infringement
remain accused
Listings
Sponsored
With
its
the functionality
regarding
its
of supplementing
the purposes
for
supplement
Listings
may
Engine
to
right
most of those technical documents
Listings
Google
IACs Ask
and
have engaged
previously
to
Engine reserves
I/P
disclose
Search
Google
Sponsored
for
to
have requested
and we continue
produced
facts
products
As
to
threat
your
basis for such
response
to
supplement
regarding
To
motion
their
supplement
the parties
them
2012
for
I/P
January
24
Engine believes
We
understand
however
invalidity
to
needed
If
from your
defendants
were
contentions
aware of additional
letter
each term
Engines
is
Google
when
on March
I/P
relevant
to
not in
Defendants
to
have had no meet and confer
their
to
obligated
Engine
is
for Defendants
abide by their
to
have been pled
contentions
I/P
agreement
agreement
are inadequate
contentions
e.g relevance
Engine proposed
I/P
defendants
more
contentions
invalidity
exchange
failure
Defendants
agreement
and are
in detail
the present
and cited
litigation
fully
are standing
by
their
explain
on
they
relying upon defendants
prior art related to the asserted
please
their
agreement
why
we
refer
the search terms
requires any further explanation
letter that
was done
also obligated
the
and statements
relevant
nonetheless
each of the asserted claims
not
contentions
Defendants
I/P
in
proposed search terms
Engines
In that
letter
based upon
the infringement
Rule 11
contentions
to supplement their
failing
infringement
that
We
2012
compel
to
by Googles own documents
why
document
move
invalidity contentions
from claiming
Regarding support
where
its
that
do not understand
interrogatory
agreement by
supplement
to
their
supported
I/P
contention
to
an agreement
to
on March
contentions
invalidity
Regarding your reference
fully
but pursuant
we
contentions
of infringement
supplementation
Defendants intend
Engine agreed
precludes
The
any infringement
the extent
further infringement
compel
an interrogatory
have breached
to
to
to
let
you
to
our
explained
sample Google
know
previously
supplement
believe
we
identified
the prior art reads
representation
art
their
that
they
on
are
claims
DSMDB-3035976
DICKSTEINSHAPI
Margaret
March
ROLLP
Kammerud Esq
2012
Page
We
remain willing
Best regards
harles
202
discuss
to
these issues
//
////
MoiiterkLJr
420-5167
MonterioC@dicksteinshapiro.com
CJM/
cc
Stephen
Noona
David Bilsker
Kenneth
Jeffrey
DeAnna
Brothers
Sherwood
Allen
DSMDB-3035976
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