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

Filing 127

Memorandum in Opposition re 104 MOTION to Compel Plaintiff to Supplement its Infringement Contentions (REDACTED PUBLIC VERSION) 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 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25)(Sherwood, Jeffrey)

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Exhibit 16  DICKSTEI NS HAP I ROLLP 1825 Eye Street NW I Washington, DC 20006-5403 (202) 420-2200 I FAX (202) 420-2201 I dicksteinshapiro.com TEL March 14,2012 Via E-mail Emily C. O'Brien, Esq. Quinn Emanuel Urquhart & Sullivan, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Re: lIP Engine's Infringement Contentions Dear Emily: In your March 13, 2012 letter regarding lIP Engine's infringement contentions, Google claims that it is "left with no option but to seek intervention from the Court." During yesterday's meet and confer, however, we discussed the parties' positions with regard to supplementing the parties' various contentions. To be clear, IIP Engine intends to supplement its infringement contentions. From IIP Engine's perspective, there is nothing to compel on this issue. If Google disagrees, please advise, as we remain willing to further meet and confer. Bm>" :!1J ~tJr I£harles J. (202) 420-5167 MonterioC@dicksteinshapiro.com CJM/ cc: Stephen E. Noona David Bilsker Kenneth W. Brothers Jeffrey K. Sherwood DeAnna Allen Los Angeles I New York I Orange County I Silicon Valley I Stamford I Washington, DC DSMDB-3039507

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