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

Filing 771

NOTICE by I/P Engine, Inc. Proffer of Evidence Related to Laches (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 PX 176, # 10 PX 408, # 11 PX 409, # 12 PX 410, # 13 PX 411, # 14 PX 412, # 15 PX 413, # 16 PX 414, # 17 PX 415, # 18 PX 416, # 19 PX 417 I, # 20 PX 417 II, # 21 PX 418, # 22 PX 419 I, # 23 PX 419 II, # 24 PX 421, # 25 DX 21, # 26 DX28, # 27 DX 255)(Sherwood, Jeffrey)

Exhibit H

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF VIRGINIA

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NORFOLK DIVISION

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I/P ENGINE, INC.,
Plaintiff,

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v.
AOL, INC., et al.,

Civil Action No.

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2:11-cv-512

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Defendants.

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CONFIDENTIAL - OUTSIDE COUNSEL ONLY

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Videotaped Deposition of GANNETT COMPANY,Inc.,

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By and through its Corporate Designee,

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STEPHEN MICHAEL KURTZ

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Tuesday, June 26, 2012

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9:06 a.m.

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Job No.: 21660

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Pages: 1 - 76

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Reported by: Debra A. Whitehead

CONFIDENTIAL VIDEOTAPED DEPOSITION OF STEPHEN MICHAEL KURTZ

CONDUCTED ON TUESDAY, JUNE 26, 2012
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use Google AdSense for Search.
Q

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09:33:32

Is there a way you could get a list of all

the websites that use that?

09:33:34
09:33:39

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A

Yeah, I imagine we could.

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Q

And how would you put together that list?

09:33:44

MS. O'BRIEN:

09:33:51

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A

A

I can't answer that definitively, beyond

USA Today.

09:33:58
09:34:02
09:34:03
09:34:33
09:34:38
09:34:43

Q

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Is it correct there are some websites of

Gannett that use Google AdSense for Search?

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Probably through the ad operations

Q

09:33:43

09:33:52

department, could put together that list.

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Calls for

speculation.

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Objection.

Yes.

But USA Today does use Google AdSense for

Search?

09:34:44
09:34:50

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A

It does.

09:34:50

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Q

When did Gannett first start using AdSense

09:34:51

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for Search?

09:35:06
MS. O'BRIEN:

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Objection.

Vague.

09:35:06

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A

To the best of my knowledge, March of 2009.

09:35:13

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Q

Is that when Gannett signed an agreement

09:35:15

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with Google?

CONFIDENTIAL - OUTSIDE COUNSEL ONLY
PLANET DEPOS | 888.433.3767 | WWW.PLANETDEPOS.COM

09:35:24