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)

quinn emanuel

trial lawyers | san francisco

50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL: [phone] FAX: [phone]

March 13, 2012

Charles Monterio
[e-mail]

Re:

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

Dear Charles:
I write in response to your March 9, 2012 letter regarding Google’s non-infringement
contentions. Google is currently working on a second supplemental response to Plaintiff’s
Interrogatory No. 6. While Google is supplementing its non-infringement contentions, this does
not absolve I/P Engine of its failure to provide sufficient infringement contentions in the first
instance. Although we have endeavored in good faith to resolve our differences on the
contentions, it appears that you are unwilling to further supplement your contentions and that we
have reached an impasse. As a result, we are left with no option but to seek intervention from
the Court. The remainder of your letter does not warrant a response.

Sincerely,

Emily C. O’Brien
cc:
[e-mail]
[e-mail]
quinn emanuel urquhart & sullivan, llp
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