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 3
DICKSTEINS HAP
1825
TEL
Eye
202
NW
Street
420-2200
IROLLP
DC 20006-5403
Washington
FAX
202
420-2201
dicksteinshapiro.com
March 15 2012
Via E-mail
David Perison Esq
Quinn Emanuel
LLP
Sullivan
Urquhart
50 California Street 22nd Floor
CA
San Francisco
94111
Esq
Alexander
Cortney
Farabow
Henderson
Finnegan
Garrett
LLP
Dunner
3500 SunTrust Plaza
303 Peachtree
GA
Atlanta
Re
Street
NE
30308
Defendants
Claim Terms
Proposed
be Construed
to
Dear Counsel
The
16b
Rule
than ten
10
construed
included
Scheduling
terms
Order
those four terms
limitations for potential
than
30 terms
or phrases
Engine proposes that
defendants
identify
Friday March
Los Angeles
New
in their
in
list
construction
Order
It
in
clear
original
Engine believes
of analysis
unreasonable
the Court has
addition
additional
makes
case
to
the
claim
for
and
I/P
that
that
fails to
all
terms
to
limited
parties
combining
comply
limitations by no later than
also
than 30 additional
of claim terms
spirit
constructions
for
construction
have
be
is
of the
with the
exchange
its
list
to
defendants
more
identified
defendants
no more
will construe
Engine proposed
and
the parties
expressly
terms
the Court
that
Defendants additionally
I/P
lack
is
when
this
informon relevance
reflects
duplicative
Courts Scheduling
for
emphasis
at
network
scanning
unfocused
Order
agreed
to
upon
10
for
terms
more
I/P
construction
p.m EDT tomorrow
16 2012
York
Orange
County
Silicon
Valley
Stamford
Washington
DC
DSMDB-3040085
DICKSTEINSHAPI
ROLLP
David Perison Esq
Alexander
Cortney
Esq
March 15 2012
Page
We
further note
Section
1126
to
defendants
that
as
seek
did not identify any
expressly required
by the Rule
any means-plus-function
any
rights
We
remain willing
to
meet and confer
limitations to be construed
16b
Order and
under
thus defendants
have waived
constructions
on these issues
jIhar1es
202
420-5167
MonterioC@dicksteinshapiro
.com
CJM/
cc
Stephen
Noona
David Bilsker
Kenneth
Jeffrey
DeAnna
Brothers
Sherwood
Allen
DSMDB-3040085
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