I/P Engine, Inc. v. AOL, Inc. et al
Filing
147
Declaration re 145 Opposition (of Emily O'Brien) in Support of Google Inc.'s Opposition to Plaintiff's Motion to Compel Google's Custodial Document Production by Google Inc.. (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, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y)(Noona, Stephen)
DICKSTEINS HAP
1825
TEL
Eye
202
NW
Street
420-2200
IROLLP
DC 200065403
Washington
202
FAX
420-2201
dicksteinshapiro.com
10 2012
January
Via E-mail
Kammerud Esq
Margaret
Quinn Emanuel Urquhart
LLP
Sullivan
50 California Street 22nd Floor
CA
San Francisco
Re
Googles Proposed
I/P Engine
Inc
Engine
Engine believes
to
responsive
received
Engines
the
requests
5867799
or
664
yet
will
of
majority
not
I/P
result
in
Engines
letter
2012
of January
discovery
that
discovery
requests
is
I/P
adequately
are focused
Googles proposed search terms are limited to nothing more
As we understand your letter Google has
search terms
following
to
The
Google
Inc.s
of the asserted patents
Googles knowledge
agreed
Google
search terms
Googles proposed
11P
upon Googles accused systems
than
and Search Terms
Custodians
Meg
Dear
I/P
94111
5867799
or
799
/2
patent
or
6775664
or 6775664
or 10/045198
420
or
6314420
or 6314420
or 09/204149
pat
w/4
664
appl w/4
I/P
or
198
420
149
or
Engine
Andrew
Donald
demand
scan
/3
Ken
w/3
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Don
w/3
Kosak
or
or
search
search /3
based
content
collaborative
network
or content-based
filter
feedback
filter
data
informon
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content
/2
profile
collaborative
filter
or collaborative
filtering
/10
content
filter
or content
filtering
hybrid
/2
filter
or hybrid
/2
filtering
Wisewire
Los Angeles
New
York
Orange
County
Silicon
Valley
Stamford
Washington
DC
DSMDB-301
7041
IC KSTE
AP IRO
INS
Kammerud Esq
Margaret
10 2012
January
Page
We
note that
incumbent upon
documents
Google
are related to
that
requests
of these search terms
all
virtually
Google
I/P
to
relating
Engines
documents
damages-related
letter asserts
improper and
nothing
that
produce responsive
this litigation
its
Engines
document
in
Engine
limited review
with
comply
its
discovery
in
documents
it
is
moving forward
that
that are requested
which documents
even as
refuses
it
is
search terms
with
by
to
has
an obligation
it
believes
documents
will be helpful
Based on
the parties have held
We
I/P
thus far
expect
Engines
I/P
accept
to
Engine and are relevant
I/P
that
timely
Googles
to
Engine seeks
TIP
in
discovery
Google
and the meet and confers
obligations
it
etc
meaningless
of Googles technical
clear
that
documents
documents
good faith proposed search terms
themselves
Googles production
regarding
broad
believe
comparison
indemnification
have not disputed
and knowledge
requests
We
propose one search term not related
to
You
non-privileged
I/P
based on
to
yet
of the asserted patents
knowledge
to
has
Engines document
I/P
testing documents
documents
the parties
assist
to
manner Google however
for
Engines
I/P
to
search for and produce responsive
to
obligations
requests
marketing
Your January
its
relate
of the asserted patents
knowledge
comply with
to
to
appear
Google
suggested
search terms
With regard
one
to
Mr
of which
advertising
custodian
17 months
suggestion
new
ago
to
the custodian
contemplated
as
reflect
that
processes
44
version
about
factors
to
Ad Words
witnesses
Mr
that
If
is
for
Ad Words
for
to
heavily
to
the basis
the Bright
in
were
Response
Head of
Testing
trial
person as
the 2005
related to
held just
transition
DumbASS
between
to
and
are whether
custodian
however
scope of responsive
documents
and an appropriate
confirm
I/P
that
Google
Engines
see e.g IPE
involved
relevant
is
provide
These two individuals
the transition
in
As
for
for discovery
Mr
that
represents
from persons most
of Googles changes
0000070-79
the design
Googles AdWords systems
and G-IPE-0000078
affirmatively
requests
and quality assessments
Score
his
that
an appropriate
identifying
Please
please
Googles
given
file
custodians
obvious example of an appropriate
testing documents
including
so
for
Huber
his custodial
in
litigation
Googles AdWords system
on Quality
Varian
G-IPE-0001629
this
is
requests
are responsive
the testing
and made
related to
of
knowledge
designates
Mr
to
additional
and development
position
Mr Huber an
Mr Jack Ancone
of an appropriate
has custody
an authority
Googles
relevant
that
engineering
have information
not
applies to
Engines
critical
of responsive
it
it
Engine also proposed an as of yet unidentified
Score
The
knowledgeable
out
TIP
address I/P
Quality
custodians
the period
Engine believes
I/P
overall
Is
Googles most knowledge
SmartASS
degree
during
three reasonable
Engine suggested
led the
Google would
at
similar rationale
as
identified
the
role
position
Huber
from 2003-2011
claims
Engines
for that
Jeff
products
immediate past
I/P
I/P
proposed custodians
Hal Varian
that
are
Google
holds
him
and Googles own documents
development
and decision
See e.g G-IPE-0000378-81
making
G-IPE-0015840-
DSMDB-3017041
DICKSTEINSHAPIROLLP
Kammerud Esq
Margaret
10 2012
January
Page
We
look
forward
these issues
having
hesitate
Best
to
your response
and likewise
meet and confer
to
contact
if
us
hopes
that
I/P
the parties
teleconference
you
Engine remains willing
can work
to
together
on January 11 2012
meet and confer
to
In the
solution
meantime
to
We
resolve
propose
please
do not
have any questions
regard
/7
.-charles
202
Mont
10
Jr
420-5167
MonterioC@dicksteinshapiro.com
CJM/
cc
Stephen
David
Bilsker
Kenneth
Jeffrey
DeAnna
Noona
Brothers
Sherwood
Allen
DSMDB-3017041
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