I/P Engine, Inc. v. AOL, Inc. et al
Filing
606
Response to 206 MOTION to Seal Portions Of Google Inc.s Brief In Support Of Motion To Compel And Various Exhibits To The Declaration Of Jen Ghaussy in Support Thereof Notice of Filing Response to Agreed Order to Maintain Portions of Documents Under Seal filed by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit H (Undreacted, Public Form), # 2 Exhibit I (Unredacted, Public Form), # 3 Exhibit L (Unredacted, Public Form), # 4 Exhibit M (Unredacted, Public Form), # 5 Exhibit N (Unredacted, Public Form), # 6 Exhibit P (Unredacted, Public Form), # 7 Exhibit Q (Unredacted, Public Form), # 8 Exhibit R (Unredacted, Public Form), # 9 Exhibit S (Undredacted, Public Form), # 10 Exhibit T (Unredacted, Public Form), # 11 Exhibit U (Unredacted, Public Form))(Noona, Stephen)
<![CDATA[
(;+,%,77
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
1
6/22/2011
IP00016361
IP00016365
5
Counsel
Dickstein
Shapiro LLP
2
6/6/2011
IP00016366
IP00016370
5
Counsel
Dickstein
Shapiro LLP
3
6/22/2011
IP00016371
IP00016373
3
Counsel
Dickstein
Shapiro LLP
4
6/24/2011
IP00016374
IP00016382
9
Counsel
Dickstein
Shapiro LLP
5
6/22/2011
IP00016383
IP00016387
5
Counsel
Dickstein
Shapiro LLP
6
6/22/2011
IP00016388
IP00016392
5
7
6/21/2011
IP00017428
IP00017444
17
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
8
6/22/2011
IP00017462
IP00017479
18
9
6/22/2011
IP00017480
IP00017497
18
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
Page 1 of 31
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
From:
To:
Description
Basis
10
6/22/2011
IP00017498
IP00017515
18
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Smart Search
Labs, Inc.
Letter communication from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney-Client; Attorney
Work Product
11
6/22/2011
IP00017516
IP00017534
19
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
12
6/7/2011
IP00017535
IP00017536
2
6/15/2011
IP00017537
IP00017550
14
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
13
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
14
6/13/2011
IP00017551
IP00017565
15
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
15
6/15/2011
IP00017583
IP00017597
15
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
16
6/13/2011
IP00017598
IP00017608
11
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
17
6/17/2011
IP00017609
IP00017621
13
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
CONFIDENTIAL OUTSIDE COUNSEL ONLY
Page 2 of 31
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
18
6/22/2011
IP00017622
IP00017640
19
19
6/6/2011
IP00017641
IP00017642
2
20
6/21/2011
IP00017643
IP00017662
20
21
6/15/2011
IP00017663
IP00017678
22
6/17/2011
IP00017679
23
6/12/2011
24
Description
Basis
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
16
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
IP00017697
19
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
IP00017698
IP00017710
13
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
6/12/2011
IP00017711
IP00017726
16
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Draft Letter Agreement from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting Smart Search Labs, Inc.'s seeking of
legal services. This document was prepared in
anticipation of litigation.
Attorney Work Product
25
1/1/1970
IP00017727
IP00017731
5
6/9/2011
IP00017732
IP00017733
2
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Attorney Work Product
26
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Page 3 of 31
To:
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
27
6/10/2011
IP00017734
IP00017734
1
28
6/10/2011
IP00017735
IP00017738
4
29
6/21/2011
IP00017739
IP00017759
21
30
6/10/2011
IP00017760
IP00017763
4
31
6/12/2011
IP00017764
IP00017774
11
32
6/9/2011
IP00017775
IP00017778
4
33
6/13/2011
IP00017779
IP00017789
11
34
6/10/2011
IP00017790
IP00017793
4
35
6/6/2011
IP00017794
IP00017795
2
36
6/20/2011
IP00017796
IP00017814
19
37
6/12/2011
IP00017815
IP00017825
11
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Page 4 of 31
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
38
6/15/2011
IP00017826
IP00017839
14
39
6/13/2011
IP00017840
IP00017851
12
40
6/17/2011
IP00017852
IP00017864
13
41
6/1/2011
IP00017869
IP00017871
3
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
42
12/31/2007
IP00017872
IP00017879
8
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
43
5/20/2011
IP00017880
IP00017882
3
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
44
9/7/2011
IP00018361
IP00018365
5
45
9/1/2011
IP00018371
IP00018376
6
46
9/6/2011
IP00018377
IP00018382
6
47
9/7/2011
IP00018388
IP00018392
5
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement reflecting legal services
from Counsel Dickstein Shapiro LLP to Smart
Search Labs, Inc. This document was prepared
in anticipation of litigation.
Attorney Work Product
Hudson Bay
Capital
Management LP
(Scott Black)
Letter communication from Counsel Bradely D.
Wine at Dickstein Shapiro LLP to Scott Black at
Hudson Bay Capital Management LP reflecting
Hudson Bay's seeking legal services. This
document was prepared in anticipation of
litigation.
Hudson Bay
Letter communication from Counsel Bradely D.
Capital
Wine at Dickstein Shapiro LLP to Yoav Roth at
Management LP Hudson Bay Capital Management LP reflecting
(Yoav Roth)
Hudson Bay's seeking legal services. This
document was prepared in anticipation of
litigation.
Draft Engagement Letter from Counsel
Dickstein Shapiro LLP to Hudson Bay Capital
Management LP reflecting Hudson Bay's
seeking of legal services. This document was
prepared in anticipation of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Page 5 of 31
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
48
9/1/2011
IP00018393
IP00018398
6
49
9/8/2011
IP00018399
IP00018403
5
50
9/12/2011
IP00018404
IP00018409
6
51
9/8/2011
IP00018410
IP00018414
5
52
9/8/2011
IP00018420
IP00018424
5
53
9/7/2011
IP00018425
IP00018430
6
54
9/9/2011
IP00018436
IP00018440
5
55
9/9/2011
IP00018441
IP00018446
6
56
9/9/2011
IP00018447
IP00018452
6
57
9/12/2011
IP00018453
IP00018458
6
58
9/9/2011
IP00018459
IP00018463
5
59
9/12/2011
IP00018464
IP00018469
6
60
9/6/2011
IP00018476
IP00018480
5
61
9/6/2011
IP00018481
IP00018486
6
62
9/12/2011
IP00018487
IP00018492
6
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Page 6 of 31
Basis
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
63
9/12/2011
IP00018493
IP00018498
6
64
9/6/2011
IP00018499
IP00018505
7
65
8/19/2011
IP00019006
IP00019028
23
66
8/28/2011
IP00019134
IP00019142
9
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Dickstein
Shapiro LLP
67
9/12/2011
IP00019160
IP00019189
30
68
9/9/2011
IP00019190
IP00019216
27
69
9/9/2011
IP00019217
IP00019243
27
70
9/9/2011
IP00019244
IP00019244
1
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft PowerPoint presentation reflecting legal
advice and services with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664.
This document was prepared in anticipation of
litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
Basis
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 7 of 31
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
71
9/14/2011
IP00019245
IP00019271
27
72
8/1/2011
IP00019272
IP00019298
27
73
9/13/2011
IP00019299
IP00019325
27
74
9/9/2011
IP00019326
IP00019352
27
75
8/29/2011
IP00019354
IP00019380
27
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood,
Frank C.
Cimino,
DeAnna Allen,
Charles J.
Monterio, Jr.,
Jonathan
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood,
Frank C.
Cimino,
DeAnna Allen,
Charles J.
Monterio, Jr.,
Jonathan
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 8 of 31
To:
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
76
9/13/2011
IP00019381
IP00019407
27
77
8/21/2011
IP00019408
IP00019433
26
78
9/14/2011
IP00019434
IP00019460
27
79
9/13/2011
IP00019461
IP00019487
27
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood,
Frank C.
Cimino,
DeAnna Allen,
Charles J.
Monterio, Jr.,
Jonathan
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood,
Frank C.
Cimino,
DeAnna Allen,
Charles J.
Monterio, Jr.,
Jonathan
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood,
Frank C.
Cimino,
DeAnna Allen,
Charles J.
Monterio, Jr.,
Jonathan
Falkler)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 9 of 31
To:
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
80
9/9/2011
IP00019488
IP00019515
28
81
8/29/2011
IP00019516
IP00019546
31
82
9/9/2011
IP00019547
IP00019573
27
83
8/25/2011
IP00019626
IP00019626
1
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel SNR
Denton US LLP
84
8/18/2011
IP00019642
IP00019647
6
Counsel
Dickstein
Shapiro LLP
(DeAnna Allen)
85
8/18/2011
IP00019648
IP00019652
5
Counsel
Dickstein
Shapiro LLP
86
8/18/2011
IP00019653
IP00019658
6
Counsel
Dickstein
Shapiro LLP
87
6/10/2011
IP00019797
IP00019820
24
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Letter Agreement between I/P Engine,
Inc., Dickstein Shapiro LLP, and Consultant
related to legal support services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between I/P Engine,
Inc., Dickstein Shapiro LLP, and Consultant
related to legal support services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between I/P Engine,
Inc., Dickstein Shapiro LLP, and Consultant
related to legal support services. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between I/P Engine,
Inc., Dickstein Shapiro LLP, and Consultant
related to legal support services. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Page 10 of 31
To:
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
88
6/15/2011
IP00019821
IP00019826
6
Counsel
Dickstein
Shapiro LLP
89
6/13/2011
IP00019827
IP00019851
25
90
6/15/2011
IP00019852
IP00019857
6
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
91
6/15/2011
IP00019858
IP00019863
6
Counsel
Dickstein
Shapiro LLP
92
6/15/2011
IP00019890
IP00019916
27
93
6/15/2011
IP00019942
IP00019945
4
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
94
6/15/2011
IP00019946
IP00019972
27
95
6/15/2011
IP00019973
IP00019977
5
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Page 11 of 31
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
96
6/12/2011
IP00019978
IP00020002
25
97
6/10/2011
IP00020003
IP00020007
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
98
6/12/2011
IP00020008
IP00020012
5
Counsel
Dickstein
Shapiro LLP
99
6/9/2011
IP00020013
IP00020015
3
Counsel
Dickstein
Shapiro LLP
100
6/12/2011
IP00020016
IP00020040
25
101
6/15/2011
IP00020041
IP00020045
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
102
6/13/2011
IP00020046
IP00020048
3
Counsel
Dickstein
Shapiro LLP
103
6/12/2011
IP00020049
IP00020076
28
104
6/15/2011
IP00020077
IP00020103
27
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Page 12 of 31
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
105
6/16/2011
IP00020104
IP00020131
28
106
6/10/2011
IP00020132
IP00020135
4
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
107
6/15/2011
IP00020136
IP00020141
6
Counsel
Dickstein
Shapiro LLP
108
6/15/2011
IP00020142
IP00020168
27
109
6/12/2011
IP00020169
IP00020192
24
110
6/15/2011
IP00020193
IP00020197
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
111
6/15/2011
IP00020198
IP00020201
4
Counsel
Dickstein
Shapiro LLP
112
6/15/2011
IP00020202
IP00020206
5
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Page 13 of 31
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
113
6/8/2011
IP00020207
IP00020229
23
114
6/10/2011
IP00020230
IP00020253
24
115
6/14/2011
IP00020254
IP00020256
3
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
116
6/15/2011
IP00020257
IP00020285
29
117
6/15/2011
IP00020286
IP00020314
29
118
6/15/2011
IP00020315
IP00020321
7
119
6/15/2011
IP00020322
IP00020350
29
120
6/6/2011
IP00020351
IP00020372
22
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Page 14 of 31
Attorney Work Product
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
121
6/15/2011
IP00020373
IP00020398
26
122
6/10/2011
IP00020399
IP00020424
26
123
6/6/2011
IP00020425
IP00020446
22
124
6/13/2011
IP00020447
IP00020449
3
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
125
6/12/2011
IP00020450
IP00020474
25
126
6/15/2011
IP00020475
IP00020478
4
127
6/13/2011
IP00020479
IP00020481
3
Counsel
Dickstein
Shapiro LLP
128
5/16/2011
IP00020490
IP00020494
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Agreement between Hudson Bay Master Fund
Ltd. and Lycos, Inc. This document was
prepared in anticipation of litigation.
Page 15 of 31
Attorney Work Product
Draft Agreement between Hudson Bay Master
Fund, Ltd. and Lycos, Inc. reflecting legal
services and advice. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product;
Common Interest
Privilege
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
129
6/16/2011
IP00020495
IP00020499
5
Counsel
Dickstein
Shapiro LLP
130
5/16/2011
IP00020500
IP00020504
5
131
5/16/2011
IP00020505
IP00020511
7
132
8/25/2011
IP00021574
IP00021575
2
133
8/19/2011
IP00022573
IP00022585
13
134
8/22/2011
IP00022586
IP00022601
16
135
8/21/2011
IP00022602
IP00022616
15
136
9/14/2011
IP00022618
IP00022620
3
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Dickstein
Shapiro LLP
137
9/14/2011
IP00022621
IP00022623
3
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Basis
Attorney Work Product
Draft Letter of Intent from Hudson Bay Master
Fund, Ltd. to Lycos, Inc. reflecting legal services
and advice. This document was prepared in
anticipation of litigation.
Smart Search
Labs, Inc. (Ken
Lang)
Description
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Hudson Bay Master
Fund Ltd. and Lycos, Inc. reflecting legal advice
and services. This document was prepared in
anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
To:
Attorney Work Product
Letter communication from Counsel Jon D.
Grossman at Dickstein Shapiro LLP to Ken
Lang at Smart Search Labs, Inc. reflecting legal
services.
Attorney-Client
Attorney Work Product
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft press release with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft press document with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Page 16 of 31
Attorney Work Product
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
138
9/14/2011
IP00022624
IP00022625
2
Counsel
Dickstein
Shapiro LLP
139
9/14/2011
IP00022626
IP00022628
3
Counsel
Dickstein
Shapiro LLP
140
5/25/2011
IP00025032
IP00025034
3
141
7/19/2011
IP00028929
IP00028936
8
142
9/10/2011
IP00029021
IP00029024
4
143
9/7/2011
IP00029274
IP00029278
5
144
9/1/2011
IP00029284
IP00029289
6
145
9/6/2011
IP00029290
IP00029295
6
146
9/7/2011
IP00029301
IP00029305
5
147
9/1/2011
IP00029306
IP00029311
6
148
9/8/2011
IP00029312
IP00029316
5
Counsel
Dickstein
Shapiro LLP
and Alexander
Berger
Counsel SNR
Denton US LLP
(Michael E.
Zolandz and
Peter G.
Feldman)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft press release with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft press document with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft document reflecting legal advice and
services with respect to enforcing U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
Draft Letter Agreement between I/P Engine,
Inc., Dickstein Shapiro LLP, and Consultant
related to legal support services. This
document was prepared in anticipation of
litigation.
Attorney Work Product
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Page 17 of 31
To:
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
149
9/12/2011
IP00029317
IP00029322
6
150
9/8/2011
IP00029323
IP00029327
5
151
9/8/2011
IP00029333
IP00029337
5
152
9/7/2011
IP00029338
IP00029343
6
153
9/9/2011
IP00029349
IP00029353
5
154
9/9/2011
IP00029354
IP00029359
6
155
9/9/2011
IP00029360
IP00029365
6
156
9/12/2011
IP00029366
IP00029371
6
157
9/9/2011
IP00029372
IP00029376
5
158
9/6/2011
IP00029389
IP00029393
5
159
9/6/2011
IP00029394
IP00029399
6
160
9/12/2011
IP00029400
IP00029405
6
161
9/6/2011
IP00029412
IP00029418
7
162
9/14/2011
IP00029438
IP00029449
12
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Ellenoff
Grossman &
Schole LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Page 18 of 31
Basis
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
163
8/28/2011
IP00030336
IP00030349
14
164
9/10/2011
IP00031341
IP00031344
4
165
9/12/2011
IP00034572
IP00034601
30
166
9/9/2011
IP00034602
IP00034628
27
167
9/9/2011
IP00034629
IP00034655
27
168
9/9/2011
IP00034656
IP00034656
1
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
169
9/14/2011
IP00034657
IP00034683
27
170
8/1/2011
IP00034684
IP00034710
27
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft Executive Summary reflecting legal
services and advice. This document was
prepared in furtherance of litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 19 of 31
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
171
9/13/2011
IP00034711
IP00034737
27
172
9/9/2011
IP00034738
IP00034764
27
173
8/29/2011
IP00034766
IP00034792
27
174
9/13/2011
IP00034793
IP00034819
27
175
8/21/2011
IP00034820
IP00034845
26
176
9/14/2011
IP00034846
IP00034872
27
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 20 of 31
To:
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
177
9/13/2011
IP00034873
IP00034899
27
178
9/9/2011
IP00034900
IP00034927
28
179
8/29/2011
IP00034928
IP00034958
31
180
9/9/2011
IP00034959
IP00034985
27
181
8/28/2011
IP00035014
IP00035022
9
Counsel
Dickstein
Shapiro LLP
(Sherwood,
Cimino, Allen,
Monterio,
Falkler)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
182
8/29/2011
IP00035023
IP00035053
31
183
9/9/2011
IP00035054
IP00035080
27
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft PowerPoint presentation reflecting legal
advice and services with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664.
This document was prepared in anticipation of
litigation.
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
To:
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Page 21 of 31
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
184
8/21/2011
IP00035081
IP00035106
26
185
8/29/2011
IP00035107
IP00035133
27
186
9/9/2011
IP00035134
IP00035161
28
187
6/1/2011
IP00037053
IP00037055
3
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood and
DeAnna Allen)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
188
8/2/2011
IP00037056
IP00037063
8
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
189
5/20/2011
IP00037064
IP00037066
3
Counsel
Dickstein
Shapiro LLP
(Bradely D.
Wine)
190
7/19/2011
IP00037255
IP00037262
8
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Basis
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Draft Complaint reflecting legal services with
respect to enforcing U.S. Patent Nos. 6,314,420
and 6,775,664. This document was prepared
by Dickstein Shapiro LLP in anticipation of
litigation.
Attorney Work Product
Hudson Bay
Capital
Management LP
(Scott Black)
Letter communication from Counsel Bradely D.
Wine at Dickstein Shapiro LLP to Scott Black at
Hudson Bay Capital Management LP reflecting
Hudson Bay's seeking legal services. This
document was prepared in anticipation of
litigation.
Hudson Bay
Letter communication from Counsel Bradely D.
Capital
Wine at Dickstein Shapiro LLP to Yoav Roth at
Management LP Hudson Bay Capital Management LP reflecting
(Yoav Roth)
Hudson Bay's seeking legal services. This
document was prepared in anticipation of
litigation.
Draft Engagement Letter from Counsel
Dickstein Shapiro LLP to Hudson Bay Capital
Management LP reflecting Hudson Bay's
seeking of legal services. This document was
prepared in anticipation of litigation.
Counsel SNR Counsel SNR Labrador Search
Denton US LLP Denton US LLP
Corporation
(Michael E.
(Michael E.
(Alexander R.
Zolandz and
Zolandz and
Berger)
Peter G.
Peter G.
Feldman)
Feldman)
Page 22 of 31
Letter from Counsel Michael E. Zolandz and
Peter G. Feldman at SNR Denton US LLP to
Alexander R. Berger at Labrador Search
Corporation reflecting legal services. This
document was prepared in anticipation of
litigation.
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
Attorney Work Product
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
191
7/19/2011
IP00037263
IP00037270
8
192
8/18/2011
IP00037465
IP00037470
6
193
8/18/2011
IP00037471
IP00037475
5
Counsel
Dickstein
Shapiro LLP
Draft agreement between I/P Engine and
Consultant with respect to enforcing U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
194
8/18/2011
IP00037476
IP00037481
6
Counsel
Dickstein
Shapiro LLP
Draft agreement between I/P Engine and
Consultant with respect to enforcing U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
195
6/22/2011
IP00037896
IP00037900
5
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Attorney Work Product
196
6/6/2011
IP00037901
IP00037905
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
197
6/22/2011
IP00037906
IP00037908
3
Counsel
Dickstein
Shapiro LLP
198
6/24/2011
IP00037909
IP00037917
9
199
6/22/2011
IP00037918
IP00037922
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Attorney Work Product
CONFIDENTIAL OUTSIDE COUNSEL ONLY
Author:
From:
To:
Counsel SNR Counsel SNR Labrador Search
Denton US LLP Denton US LLP
Corporation
(Michael E.
(Michael E.
(Alexander R.
Zolandz and
Zolandz and
Berger)
Peter G.
Peter G.
Feldman)
Feldman)
Counsel
Dickstein
Shapiro LLP
(DeAnna Allen)
Page 23 of 31
Description
Basis
Letter from Counsel Michael E. Zolandz and
Attorney-Client; Attorney
Peter G. Feldman at SNR Denton US LLP to
Work Product; Common
Alexander R. Berger at Labrador Search
Interest Privilege
Corporation reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft agreement between I/P Engine and
Attorney Work Product
Consultant with respect to enforcing U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
200
6/22/2011
IP00037923
IP00037927
5
201
8/19/2011
IP00038012
IP00038024
13
202
8/22/2011
IP00038025
IP00038040
16
203
8/21/2011
IP00038041
IP00038055
15
204
8/2/2011
IP00041889
IP00041891
3
205
6/15/2011
IP00041945
IP00041950
6
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
206
6/15/2011
IP00041976
IP00041981
6
Counsel
Dickstein
Shapiro LLP
207
6/15/2011
IP00041982
IP00041987
6
Counsel
Dickstein
Shapiro LLP
208
6/15/2011
IP00042066
IP00042069
4
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Basis
Attorney Work Product
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Smart Search
Labs, Inc. (Ken
Lang)
Description
Draft Agreement between Counsel Dickstein
Shapiro LLP and Consultant related to legal
support services. This document was prepared
in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
To:
Attorney Work Product
Attorney-Client
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Letter Agreement from Smart Search Lab,
Inc. to Lycos, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Page 24 of 31
Letter communication from Counsel Jon D.
Grossman at Dickstein Shapiro LLP to Ken
Lang at Smart Search Labs, Inc. reflecting legal
services.
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
209
6/15/2011
IP00042097
IP00042101
5
Counsel
Dickstein
Shapiro LLP
210
6/10/2011
IP00042127
IP00042131
5
Counsel
Dickstein
Shapiro LLP
211
6/12/2011
IP00042132
IP00042136
5
212
6/9/2011
IP00042137
IP00042139
213
6/15/2011
IP00042165
214
6/13/2011
215
216
Description
Basis
Draft Letter Agreement from Smart Search Lab,
Inc. to Lycos, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft Agreement between Smart Search Labs,
Inc., Hudson Bay Master Fund, Ltd. and Lycos,
Inc. related to the enforcement of U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
Counsel
Dickstein
Shapiro LLP
Draft Agreement between Smart Search Labs,
Inc., Hudson Bay Master Fund, Ltd. and Lycos,
Inc. related to the enforcement of U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
3
Counsel
Dickstein
Shapiro LLP
Draft Agreement between Smart Search Labs,
Inc., Hudson Bay Master Fund, Ltd. and Lycos,
Inc. related to the enforcement of U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
Attorney Work Product
IP00042169
5
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
IP00042170
IP00042172
3
Counsel
Dickstein
Shapiro LLP
6/10/2011
IP00042256
IP00042259
4
Counsel
Dickstein
Shapiro LLP
Draft Letter Agreement from Smart Search Lab,
Inc. to Lycos, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Draft Agreement between Smart Search Labs,
Inc., Hudson Bay Master Fund, Ltd. and Lycos,
Inc. related to the enforcement of U.S. Patent
Nos. 6,314,420 and 6,775,664. This document
was prepared in anticipation of litigation.
6/15/2011
IP00042260
IP00042265
6
Counsel
Dickstein
Shapiro LLP
Draft Letter Agreement between Smart Search
Labs, Inc., Hudson Bay Master Fund, Ltd. and
Lycos, Inc. related to the enforcement of U.S.
Patent Nos. 6,314,420 and 6,775,664. This
document was prepared in anticipation of
litigation.
Attorney Work Product
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Page 25 of 31
To:
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
217
6/15/2011
IP00042317
IP00042321
5
Counsel
Dickstein
Shapiro LLP
218
5/16/2011
IP00042614
IP00042618
5
219
6/16/2011
IP00042619
IP00042623
5
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
220
8/25/2011
IP00042636
IP00042637
2
221
6/21/2011
IP00042638
IP00042654
17
222
6/22/2011
IP00042672
IP00042689
18
223
6/22/2011
IP00042690
IP00042707
18
224
6/22/2011
IP00042708
IP00042725
18
225
6/22/2011
IP00042726
IP00042744
19
CONFIDENTIAL OUTSIDE COUNSEL ONLY
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
From:
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Description
Basis
Draft Letter Agreement from Smart Search Lab,
Inc. to Lycos, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Agreement between Hudson Bay Master Fund
Ltd. and Lycos, Inc. This document was
prepared in anticipation of litigation.
Smart Search
Labs, Inc.
(Alexander R.
Berger)
To:
Attorney Work Product
Lycos, Inc. (Mark Letter Agreement from Alexander R. Berger at
Blais)
Smart Search Lab, Inc. to Mark Blais at Lycos,
Inc. reflecting legal advice and services. This
document was prepared in anticipation of
litigation.
Smart Search Letter communication from Counsel Jon D.
Labs, Inc. (Ken Grossman at Dickstein Shapiro LLP to Ken
Lang)
Lang at Smart Search Labs, Inc. reflecting legal
services.
Attorney Work Product;
Common Interest
Privilege
Attorney-Client; Attorney
Work Product; Common
Interest Privilege
Attorney-Client
Draft letter agreement between Dickstein
Shapiro LLP and Smart Search Labs, Inc. This
document was prepared in anticipation of
litigation.
Draft letter agreement between Dickstein
Shapiro LLP and Smart Search Labs, Inc. This
document was prepared in anticipation of
litigation.
Smart Search
Labs, Inc.
Page 26 of 31
Attorney Work Product
Draft letter agreement between Dickstein
Shapiro LLP and Smart Search Labs, Inc. This
document was prepared in anticipation of
litigation.
Counsel
Dickstein
Shapiro LLP
(Jon D.
Grossman)
Attorney Work Product
Attorney Work Product
Letter communication from Counsel Jon D.
Grossman at Dickstein Shapiro LLP to Smart
Search Labs, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney-Client; Attorney
Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
226
6/7/2011
IP00042745
IP00042746
2
Counsel
Dickstein
Shapiro LLP
227
6/15/2011
IP00042747
IP00042760
14
228
6/13/2011
IP00042761
IP00042775
15
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
229
6/17/2011
IP00042776
IP00042792
17
230
6/15/2011
IP00042793
IP00042807
15
231
6/13/2011
IP00042808
IP00042818
11
232
6/17/2011
IP00042819
IP00042831
13
233
6/22/2011
IP00042832
IP00042850
19
234
6/6/2011
IP00042851
IP00042852
2
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Basis
Attorney Work Product
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting legal advice and services. This
document was prepared in anticipation of
litigation.
Page 27 of 31
Description
Draft letter agreement between Dickstein
Shapiro LLP and Smart Search Labs, Inc. This
document was prepared in anticipation of
litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
To:
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
235
6/21/2011
IP00042853
IP00042872
20
236
6/15/2011
IP00042873
IP00042888
16
237
6/17/2011
IP00042889
IP00042907
19
238
6/12/2011
IP00042908
IP00042920
13
239
6/12/2011
IP00042921
IP00042936
16
240
5/1/2011
IP00042937
IP00042941
5
241
6/9/2011
IP00042942
IP00042943
2
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
242
6/10/2011
IP00042944
IP00042944
1
243
6/10/2011
IP00042945
IP00042948
4
244
6/21/2011
IP00042949
IP00042969
21
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
To:
Description
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft Letter communication from Counsel Gary
M. Hoffman at Dickstein Shapiro LLP to Smart
Search Labs, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft Letter communication from Counsel Gary
M. Hoffman at Dickstein Shapiro LLP to Smart
Search Labs, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft communication from Counsel Dickstein
Shapiro LLP to Smart Search Labs, Inc.
reflecting legal advice and services. This
document was prepared in anticipation of
litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Page 28 of 31
Basis
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
245
6/10/2011
IP00042970
IP00042973
4
246
6/12/2011
IP00042974
IP00042984
11
247
6/9/2011
IP00042985
IP00042988
4
248
6/13/2011
IP00042989
IP00042999
11
249
6/10/2011
IP00043000
IP00043003
4
250
6/6/2011
IP00043004
IP00043005
2
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Counsel
Dickstein
Shapiro LLP
Counsel
Dickstein
Shapiro LLP
251
6/20/2011
IP00043006
IP00043024
19
252
6/12/2011
IP00043025
IP00043035
253
6/15/2011
IP00043036
IP00043049
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Attorney Work Product
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter communication from Counsel Gary
M. Hoffman at Dickstein Shapiro LLP to Smart
Search Labs, Inc. reflecting legal advice and
services. This document was prepared in
anticipation of litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft Letter communication from Counsel
Jeffrey K. Sherwood at Dickstein Shapiro LLP
to Smart Search Labs, Inc. reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Draft schedule reflecting legal services. This
document was prepared in anticipation of
litigation.
Draft letter agreement between Dickstein
Shapiro LLP and Smart Search Labs, Inc. This
document was prepared in anticipation of
litigation.
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
11
Counsel
Dickstein
Shapiro LLP
(Gary M.
Hoffman)
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney Work Product
14
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney Work Product
Page 29 of 31
To:
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
Doc ID Beg No
Doc ID End No
Pages
Author:
254
6/13/2011
IP00043050
IP00043061
12
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney Work Product
255
6/17/2011
IP00043062
IP00043074
13
Counsel
Dickstein
Shapiro LLP
(Jeffrey K.
Sherwood)
Draft Retainer Agreement Letter from Counsel
Dickstein Shapiro LLP to Smart Search Labs,
Inc. reflecting Smart Search Labs, Inc.'s
seeking of legal services. This document was
prepared in anticipation of litigation.
Attorney Work Product
256
8/19/2011
IP00043279
IP00043301
23
Draft regulatory statement reflecting legal
advice and services. This document was
prepared in anticipation of litigation.
Attorney Work Product
257
9/14/2011
IP00043392
IP00043392
1
Counsel
Ellenoff
Grossman &
Schole LLP
Counsel
Dickstein
Shapiro LLP
Attorney Work Product
258
9/14/2011
IP00043393
IP00043395
3
Counsel
Dickstein
Shapiro LLP
259
9/14/2011
IP00043396
IP00043398
3
Counsel
Dickstein
Shapiro LLP
260
9/14/2011
IP00043399
IP00043400
2
Counsel
Dickstein
Shapiro LLP
Draft press release with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft press release with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft press document with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Draft press release with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Page 30 of 31
To:
Description
Basis
Attorney Work Product
Attorney Work Product
Attorney Work Product
I/P Engine Privilege Log - I/P Engine, Inc. v. AOL, Inc. et al., – CIVIL NO. 2:11-CV-00512 (E.D Va.)
Date Created
261
Doc ID Beg No
Doc ID End No
Pages
Author:
9/14/2011
IP00043401
IP00043403
3
Counsel
Dickstein
Shapiro LLP
CONFIDENTIAL OUTSIDE COUNSEL ONLY
From:
Description
Basis
Draft press document with respect to enforcing
U.S. Patent Nos. 6,314,420 and 6,775,664
reflecting legal services and advice. This
document was prepared in conjunction with
Counsel Dickstein Shapiro LLP in anticipation of
litigation.
Page 31 of 31
To:
Attorney Work Product
]]>
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