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)

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 (;+,%,74  Ken Lang 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: 1 9/11/1998 IP00000374 IP00000377 4 5/26/1998 IP00007587 IP00002088 2 Counsel Edward F. Possessky Counsel Michael J. Riccio Jr. Ken Lang 2 Counsel Edward F. Possessky Counsel Michael J. Riccio Jr. 3 5/26/1998 IP00009480 IP00009503 24 Counsel Edward F. Possessky 4 2/4/1998 IP00009504 IP00009509 6 Counsel Edward F. Possessky Counsel Susan Hartman 5 2/28/1998 IP00011718 IP00011719 2 6 4/13/1998 IP00013277 IP00013325 49 7 2/6/1998 IP00013597 IP00013636 40 8 2/6/1998 IP00013637 IP00013637 1 9 9/16/2011 VM-CTRL00000016 4 Counsel Edward F. Possessky Counsel Michael J. Riccio, Jr. Counsel Edward F. Possessky Counsel Edward F. Possessky Ken Lang Counsel Edward F. Possessky Counsel Michael J. Riccio, Jr. Counsel Edward F. Possessky Counsel Edward F. Possessky Ken Lang 10 8/22/2011 VM-CTRL00000023 1 Ken Lang Ken Lang Description Facsimile communication from Counsel Attorney-Client; Attorney Edward F. Possessky to Ken Lang reflecting Work Product legal advice and analysis. Walter W. Memorandum Letter from Counsel Michael J. Attorney-Client Buckley, Donald Riccio, Jr. to Walter W. Buckley, Donald F. F. Parman, R. Parman, R. Peter Zimmerman, Paul D. Cohn, Peter Ken Lang and Edward M. Phillip reflecting legal Zimmerman, Paul advice and analysis. D. Cohn, Ken Lang and Edward M. Phillip Ken Lang Facsimile communication from Counsel Attorney-Client; Attorney Edward F. Possessky to Ken Lang reflecting Work Product legal advice and analysis. Draft Memorandum Letter from Counsel Susan Attorney Work Product Hartman and Andrew Sussman to Dennis Ciccone, Rob Frasca, and Ken Lang reflecting legal services. Ken Lang Billing Statement of Counsel Edward F. Attorney-Client Possessky to Ken Lang reflecting legal services. Carl A. Cohen Facsimile communication from Counsel Attorney-Client and Christopher Michael J. Riccio, Jr. to Carl A. Cohen and Bellavia Christopher Bellavia reflecting legal advice. Ken Lang Facsimile communication from Counsel Attorney-Client; Attorney Edward F. Possessky to Ken Lang reflecting Work Product legal advice and analysis. Ken Lang Facsimile communication from Counsel Attorney-Client; Attorney Edward F. Possessky to Ken Lang reflecting Work Product legal advice and analysis. Michelle Rodgers; Email communication from Ken Lang to Attorney-Client Michelle Rodgers reflecting legal advice and cc: Counsel Jeffrey services. This document was prepared in Sherwood; anticipation of litigation. Counsel Charles Monterio Attorney-Client Counsel Email communication from Ken Lang to Jonathan Falkler Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. CONFIDENTIAL OUTSIDE COUNSEL ONLY Page 1 of 3 Basis Ken Lang 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 11 8/23/2011 VM-CTRL00000024 4 12 8/22/2011 VM-CTRL00000027 1 13 8/23/2011 VM-CTRL00000028 12 14 8/22/2011 VM-CTRL00000029 1 VM-CTRL00000030 4 VM-CTRL00000033 1 VM-CTRL00000034 4 VM-CTRL00000037 1 VM-CTRL00000038 10 15 16 8/22/2011 17 18 19 8/22/2011 Doc ID End No Pages Author: From: Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang Ken Lang To: Description Counsel Document communicated as an attachment of Jonathan Falkler Document VM-CTRL00000023 from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Email communication from Ken Lang to Jonathan Falkler Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Document communicated as an attachment of Jonathan Falkler Document VM-CTRL00000027 from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Email communication from Ken Lang to Jonathan Falkler Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Document communicated as an attachment of Jonathan Falkler Document VM-CTRL00000029 from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Email communication from Ken Lang to Jonathan Falkler Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Document communicated as an attachment of Jonathan Falkler Document VM-CTRL00000033 from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Email communication from Ken Lang to Jonathan Falkler Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Counsel Document communicated as an attachment of Jonathan Falkler Document VM-CTRL00000037 from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. CONFIDENTIAL OUTSIDE COUNSEL ONLY Page 2 of 3 Basis Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Ken Lang 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 20 5/9/2012 21 Pages Author: From: To: Description Basis VM-CTRL00000054 1 Ken Lang Ken Lang Counsel David Cohen Attorney-Client 5/9/2012 VM-CTRL00000055 1 Ken Lang Ken Lang Counsel David Cohen 22 5/9/2012 VM-CTRL00000056 1 Ken Lang Ken Lang Counsel David Cohen 23 5/7/2012 VM-CTRL00000057 2 Ken Lang Ken Lang Counsel Charles Monterio 24 3/8/2012 VM-CTRL00000118 1 Ken Lang Ken Lang Counsel Jonathan Falkler 25 1/26/2012 VM-CTRL00000151 1 Ken Lang Ken Lang Counsel Jonathan Falkler 26 11/23/2011 VM-CTRL00000175 3 Ken Lang Ken Lang Counsel Jonathan Falkler Email communication from Ken Lang to Counsel David Cohen reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel David Cohen reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel David Cohen reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel Charles Monterio reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. Email communication from Ken Lang to Counsel Jonathan Falkler reflecting legal advice and services. This document was prepared in anticipation of litigation. CONFIDENTIAL OUTSIDE COUNSEL ONLY Doc ID End No Page 3 of 3 Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client Attorney-Client

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