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)

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EXHIBIT 14 Jen Ghaussy From: Sent: To: Cc: Subject: David Perlson Monday, April 09, 2012 10:37 AM Monterio, Charles; QE-IP Engine; 'Noona, Stephen E.'; Alexander, Cortney; 'Burns, Robert'; Bhateja, Rajiv zz-IPEngine RE: I/P Engine v. AOL et al.: 4-5-12 Letter from C. Monterio to D. Perlson Charles, without going through the history here, it appears to us that the following terms or issues are currently in dispute (although Plaintiff has improperly still not provided constructions in relation to all these issues): 1. “relevance to a query” / “relevance to at least one of the query and the first user” / “informons relevant to a query” / “information relevant to a query” 2. “scanning a network” / “a scanning system” 3. “collaborative feedback data” / “[feedback system for] receiving information found to be relevant to the query by other users” 4. “user” / “individual user” / “first user” 5. “combining” 6. “demand search” 7. “informon” 8. Antecedent basis issue for 7 term dyads 9. Separate systems issue 10. Order of steps for ‘420 claim 25 and ‘664 claim 26 Given the state of the parties’ discussions, Plaintiff’s “motion to compel” is clearly moot, to the extent there ever was an issue to be addressed in the first place. Please promptly confirm that Plaintiff will withdraw this Motion by no later than 3:00 p.m. EDT today. Otherwise, we will file our response to Plaintiff’s Motion this evening even though that should not be necessary. David    From: Monterio, Charles [mailto:MonterioC@dicksteinshapiro.com] Sent: Thursday, April 05, 2012 10:17 AM To: QE-IP Engine; 'Noona, Stephen E.'; Alexander, Cortney; 'Burns, Robert'; Bhateja, Rajiv Cc: zz-IPEngine Subject: I/P Engine v. AOL et al.: 4-5-12 Letter from C. Monterio to D. Perlson Counsel, 1 Please see the attached correspondence. Charles J. Monterio, Jr. Associate Dickstein Shapiro LLP 1825 Eye Street NW | Washington, DC 20006 Tel (202) 420-5167| Fax (202) 420-2201 monterioc@dicksteinshapiro.com Confidentiality Statement This e-mail message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. This communication may contain material protected by attorney-client, work product, or other privileges. If you are not the intended recipient or person responsible for delivering this confidential communication to the intended recipient, you have received this communication in error, and any review, use, dissemination, forwarding, printing, copying, or other distribution of this e-mail message and any attached files is strictly prohibited. Dickstein Shapiro reserves the right to monitor any communication that is created, received, or sent on its network. If you have received this confidential communication in error, please notify the sender immediately by reply e-mail message and permanently delete the original message. To reply to our email administrator directly, send an email to postmaster@dicksteinshapiro.com Dickstein Shapiro LLP www.dicksteinshapiro.com 2

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