I/P Engine, Inc. v. AOL, Inc. et al
Filing
111
Declaration re 109 Memorandum in Opposition, by Joshua Sohn by 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 13
Jen Ghaussy
From:
Sent:
To:
Cc:
Subject:
Joshua Sohn
Sunday, April 08, 2012 5:17 PM
'Monterio, Charles'; 'zz-IPEngine'
QE-IP Engine; 'senoona@kaufcan.com'
I/P Engine v. Google et al.: Claim Construction
Dear Charles,
I write regarding the parties’ continued negotiations over proposed claim constructions. Regarding the order of steps
for ‘420 claim 25, we understand Plaintiff takes the position that the “receiving collaborative feedback data” step must
occur before the “combining pertaining feedback data with the content profile data” step. We agree. Please let us
know whether plaintiff will also agree that the “scanning a network” step must occur before the “receiving the
informons in a content‐based filter system from the scanning system” step as required by the claim language. If not,
please explain why.
Regarding the order of steps for ‘664 claim 26, we understand Plaintiff takes the position that the “combining” step
must occur before the “filtering the combined information” step and that the “receiving information found to be
relevant to the query by other users” step must occur before the “combining” step. We agree. However, we also seek
Plaintiff’s agreement that the “searching for information” step must occur before the “combining” step. The
“combining” step requires combining “the information found to be relevant to the query by other users with the
searched information”. The “searched information” refers to the information obtained through the “searching for
information” step. Thus, the “searching for information” step must occur before the searched information can be
combined with anything else. Please let us know if Plaintiff agrees and, if not, why not.
Sincerely,
Josh
1
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