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 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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