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)

Jen Ghaussy
From:
Sent:
To:
Cc:
Subject:

David Perlson
Tuesday, December 20, 2011 4:52 PM
David Perlson; Margaret P. Kammerud; Brothers, Kenneth; zz-IPEngine
QE-IP Engine; [e-mail]
RE: I/P Engine v. AOL et. al.

Ken,
Below is our proposal for custodial searching. We propose running custodial searches unrestricted by time, but
subject to reasonable search terms, for each of the individuals listed below. We also have included a proposed
set of search terms below. However, we still need to test these terms on a data set (such as one custodian)
before running on all custodian files. To the extent the tests result in the need to adjust these terms based on the
results (for example if they return an unreasonable number of irrelevant hits) we will let you know.
To the extent that you have other proposed custodians (as we asked Friday) or search terms you would like us to
consider, please do so now. As we have previously stated, we intend to do our custodial collection only once.
If there are additional custodians you would like to add, please promptly identify those custodians so we can
meet and confer about your proposed additions before Google undertakes the collection, review, and production
of custodial documents, not after the process has begun. While we will not preclude additional custodial
searches under limited circumstances later in the case as appropriate, we will likely object to the addition of
custodians of whom you could have known about had you reviewed Google’s extension production of technical
documents already in the case.
David

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

Search Terms: 
6775664 or 6,775,664 or (664 /2 patent)
1

6314420 or 6,314,420 or (420 /2 patent)
I/P Engine
(Andrew /2 Lang) or (Ken /2 Lang)
Donald /2 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)

From: David Perlson
Sent: Friday, December 16, 2011 5:50 PM
To: David Perlson; Margaret P. Kammerud; Brothers, Kenneth; zz-IPEngine
Cc: QE-IP Engine; [e-mail]
Subject: RE: I/P Engine v. AOL et. al.

Ken, as we indicated we will look identify Google custodians. Now that Plaintiff has Google’s initial
production of technical documents Plaintiff should be able to identify propose custodians as well. Please do so.
We want to avoid searching custodial documents and then having Plaintiff come back later and asking for more
custodians as much as possible.

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