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

Filing 123

Declaration re 122 Claim Construction Brief of Joshua Sohn in Support of Defendants' Opening Claim Construction Brief by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Noona, Stephen)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION

I/P ENGINE, INC.
Plaintiff,
v.

Civil Action No. 2:11-cv-512

AOL, INC., et al.,
Defendants.

DECLARATION OF JOSHUA SOHN IN SUPPORT OF DEFENDANTS’ OPENING
CLAIM CONSTRUCTION BRIEF
I, Joshua Sohn, declare as follows:
1.

I am an attorney in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP and

am counsel for Defendants IAC Search & Media, Inc., Gannett Co., Inc., Target Corporation,
and Google Inc. in the above-captioned case. I provide this declaration upon personal
knowledge and, if called upon as a witness, would testify competently as to the matters recited
herein.
2.

Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No.

6,314,420 (“the ‘420 Patent”).
3.

Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No.

6,775,664 (“the ‘664 Patent”).

4.

Attached hereto as Exhibit C is a true and correct copy of Plaintiff’s Preliminary

Proposed Claim Terms and Proposed Constructions, dated March 21, 2012.
5.

Attached hereto as Exhibit D is a true and correct copy of Plaintiff’s Objections

and Responses to Google’s Third Set of Interrogatories, dated March 22, 2012.
6.

Attached hereto as Exhibit E is a true and correct copy of an email from

Plaintiff’s counsel Charles Monterio to Defendants’ counsel, dated April 11, 2012.
7.

Attached hereto as Exhibit F is a true and correct copy of another email from

Plaintiff’s counsel Charles Monterio to Defendants’ counsel, dated April 11, 2012.
8.

Attached hereto as Exhibit G is a true and correct copy of a letter from Plaintiff’s

counsel Charles Monterio to Defendants’ counsel David Perlson, dated April 5, 2012.
9.

Attached hereto as Exhibit H is a true and correct copy of an excerpt from the

prosecution history of the ‘420 Patent.
10.

I declare under penalty of perjury of the laws of the United States that the

foregoing is true and correct.

Dated: April 12, 2012
Joshua Sohn

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DATED: April 12, 2012

/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Google Inc.,
Target Corporation,
IAC Search & Media, Inc.,
Gannet Co., Inc. and AOL, Inc.
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Google Inc.,
Target Corporation,
IAC Search & Media, Inc.,
Gannet Co., Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on April 12, 2012, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
the following:
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiff, I/P Engine, Inc.

Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Google Inc.,
Target Corporation,
IAC Search & Media, Inc.,
Gannet Co., Inc. and AOL, Inc.

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/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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