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)

Exhibit 20 

quinn emanuel trial lawyers | san francisco
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WRITER'S INTERNET ADDRESS
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February 13, 2012
Charles Monterio Jr.
Dickstein Shapiro LLP
1825 Eye Street NW
Washington, DC 20006
Re:

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

Dear Charles:
I am writing in regards to your February 7, 2012 letter inquiring “whether Google Search uses
click-through rates or data to rank/return search results.” While not entirely clear, it appears that
you are asking us to essentially confirm that Google never uses in any way historical data
regarding how users interact with search results, in relation to the return of search results. We
are not able to confirm that. However, we do not see how this requested confirmation is
necessary for Plaintiff to drop any infringement allegation as to Google Search, an allegation that
should never have been brought in the first place.
Very truly yours,

David A. Perlson

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