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

Filing 512

Declaration re 511 Opposition, of Howard Chen in Support of Defendants' Opposition to Plaintiff's Daubert Motion, and Fourth Motion in Limine to Exclude Lyle Ungar's New Theory of Invalidity and Opinions Regarding Claim Construction by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (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)(Noona, Stephen)

EXHIBIT 3

Jim Grossell
From:
Sent:
To:
Cc:
Subject:

Joshua Sohn
Tuesday, July 17, 2012 3:19 PM
[e-mail]; zz-IPEngine
QE-IP Engine
I/P Engine v. AOL et al.: Google's Interrogatory No. 13

Dear Charles,
Google’s Interrogatory No. 13 asks Plaintiff to identify every claim element that Plaintiff contends is not disclosed in the
prior art references cited in Google’s response(s) to Plaintiff’s Interrogatory No. 8, and explain why Plaintiff contends
that such elements are not disclosed by these prior art references. Plaintiff served its response to Interrogatory No. 13
on March 22, 2012.
On July 2, 2012, Google served its Third Supplemental Response to Plaintiff’s Interrogatory No. 8, identifying three
additional prior art references that Google contends invalidate the asserted claims. Thus, pursuant to the plain terms of
Interrogatory No. 13, Plaintiff has a duty to supplement its response to Interrogatory No. 13 to set forth its contention of
why these new prior art references do not invalidate the asserted claims. To date, we have not received a supplemental
response to Interrogatory No. 13 that addresses these new references.
Given the upcoming expert report deadline, we request that Plaintiff provide a supplemental response to Interrogatory
No. 13 no later than COB this Friday, July 20.
Sincerely,
Josh Sohn

Joshua Sohn
Associate,

Quinn Emanuel Urquhart & Sullivan, LLP
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