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

Filing 118

Memorandum in Support re 117 MOTION to Compel Plaintiff I/P Engine's Motion to Compel Defendant Google, Inc.'s Custodial Document Production filed by I/P Engine, Inc.. (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, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Proposed Order)(Sherwood, Jeffrey)

Exhibit 3 

Page 1 of 1

Chagnon, Armands
From:

Monterio, Charles

Sent:

Friday, December 23, 2011 1:39 PM

To:

'David Perlson'; QE-IP Engine

Cc:

zz-IPEngine; '[e-mail]'

Subject:

I/P Engine v. Google: Proposed Google Custodians and Search Terms

Attachments: DSMDB-#3012026-v1-Proposed_Google_Custodians.DOC

David,
In response to your email of December 20, 2011, I/P Engine expects that Google will comply with its
discovery obligations. To further assist, I/P Engine provides the attached, requested listing of proposed
Google Custodians and Search Terms for Google’s custodial searches. I/P Engine’s proposed
custodians and search terms should not be interpreted as binding and/or exhaustive. I/P Engine’s
proposed custodians and search terms are preliminary and based upon an incomplete review of Google’s
document production. I/P Engine reserves the right to reasonably request additional custodians and/or
search terms based upon information, documents, or things it discovers during a complete review of
Google’s document production, receives during discovery or obtains upon further investigation. Please
do not hesitate to contact us if you have any questions.
Charles J. Monterio, Jr.
Associate
Dickstein Shapiro LLP
1825 Eye Street NW | Washington, DC 20006
Tel [phone]| Fax [phone]
[e-mail]

4/11/2012

Google’s proposed custodians and search terms of its December 20, 2011 email are in
black, while I/P Engine’s additionally proposed custodians and search terms are in blue.
Google Custodians:
Jonathan Alferness, Director, Product Management
Bartholomew Furrow, Software Engineer
Bryan Horling, Software Engineer
Daniel Wright, Software Engineer
Matt Kulick, Product Manager
Jonathan McPhie, Product Manager
Rishi Khaitan, Product Manager
Jack Ancone, Sr. Director, New Business Development
Jeff Huber, Sr. Vice President of Commerce & Local (previously Jeff led overall
engineering & development for Google’s advertising products -- AdWords, AdSense,
DoubleClick (2003-2011))
Unnamed, Head of Testing (2005 transition to the new Quality Score version of
AdWords, including without limitation the transition between DumbASS and SmartASS)
Hal Varian, Chief Economist
Search Terms:
6775664 or 6,775,664 or (664 /2 patent)
6314420 or 6,314,420 or (420 /2 patent)
5867799 or 5,867,799 or (799 /2 patent)
’664 or 6,775,664 or 6775664 or 10/045,198
’420 or 6,314,420 or 6314420 or 09/204,149
pat* w/4 (664 or 420)
appl* w/4 (198 or 149)

DSMDB-3012026

I/P Engine
(Andrew /2 Lang) or (Ken /2 Lang)
Donald /2 Kosak
(Andrew or Ken) w/3 Lang
(Donald or Don) w/3 Kosak
demand search
scan /3 search /3 network
(content based filter) or (content-based filter)
collaborative feedback data
informon
Lycos
content /2 profile
((collaborative filter) or (collaborative filtering)) /10 ((content filter) or (content
filtering))
(hybrid /2 filter) or (hybrid /2 filtering)
Wirewire
(ad or auction) and (CPC or (cost per click))
“Landing page”
(“quality score”) and (“relevant ads”)
(“quality score”) and (CPC or (cost per click))
(Keyword or Query) and (ad or adwords)
((“click through rate”) or CTR)
Relevance
SmartASS or DumbASS

DSMDB-3012026

AdMixer
AdShards
AdWords or AdSense
Ad and revenue
Kansas
“AdWords Select”
Kosak
Lang
“Empirical Media”
Search w/30 (Advertising or ads)
(Search or Adwords or Adsense or Advertising or ads) w/30 (Feedback or collab* or
algo* or rank*)
(Search or Adwords or Adsense) and “User Feedback”
(Click-through or clickthrough or CTR or “click through”) and (Search or Adwords or
Adsense)
“Quality Score”
“Collaborative Data”
(Advertising or ads or Adsense or Adwords) w/30 quality
(Advertisements or Ads or Adwords) w/5 stor*
Overture or Goto.com
Yahoo w/4 “Search Marketing”
Microsoft w/4 AdCenter
AOL w/4 “Sponsored Listings”
(IAC or Ask) w/4 “Sponsored Listings”

DSMDB-3012026