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

Filing 438

Declaration re 433 Opposition, 432 Opposition, 434 Opposition, of Margaret P. Kammerud in Support of Defendants' Opposition to Plaintiff's Motions in Limine 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, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M)(Noona, Stephen)

EXHIBIT M

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Volume I

Pages 1 - 157

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Exhibits 1 - 20

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF VIRGINIA

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NORFOLK DIVISION

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********************

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I/P ENGINE, INC.,

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Plaintiff,

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Civil Action No.

Vs.

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2:11-cv-512

AOL, INC., et al.,

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Defendants.

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********************

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AUDIO/VISUAL DEPOSITION of LYCOS, INC.,

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by and through its designee MARK BLAIS

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Tuesday, July 31, 2012 at 9:00 a.m.

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Goulston & Storrs

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50 Rowes Wharf, 7th Floor

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Boston, Massachusetts

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------ Jacqueline P. Shields, RPR, CSR ------

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Job No. CS409539

Veritext Corporate Services
800-567-8658

973-410-4040

Page 57
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A.

I don't recall what they were.

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Q.

Why did Lycos offer a lump sum amount to

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license the '799 and '214 patents?
A.

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If I remember correctly -- sorry.
MS. ALBERT:

A.

Objection.

Misconstrues.

If I remember, we may have offered them two

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scenarios, one a lump sum and part for the past and

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running royalty going forward.

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models, I just don't recall specifically whether we

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offered both or not.
Q.

At the time did Lycos have a preference for

one of the two models?

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I know we did two

MS. ALBERT:
A.

Objection.

Vague.

There were some preferences for a running

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royalty to create a revenue stream, but it wasn't

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strong.

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Q.

How about in 2006, do you know if Lycos had

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any preferences in licensing out its patents for a

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lump sum versus a running royalty?

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MS. ALBERT:

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A.

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Q.

Vague.

preferences.

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Objection.

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I wouldn't say there was really any

And similarly, do you know if Lycos had any

preference in licensing out its patents in 2005 as

Veritext Corporate Services
800-567-8658

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