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

Filing 783

NOTICE by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation of Lodging of Demonstratives (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Noona, Stephen)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
I/P ENGINE, INC.
Civil Action No. 2:11-cv-512

Plaintiff,
v.
AOL INC., et al.,
Defendants.

DEFENDANTS’ NOTICE OF LODGING OF DEMONSTRATIVES
Defendants Google Inc., AOL, Inc., IAC Search & Media, Inc., Target Corp., and
Gannett Co., Inc. (collectively “Defendants”) hereby lodge the following demonstratives that the
Court excluded as well as the following demonstratives that the Court included over Defendants'
objections:
Ex. A, containing PDX 2, 15, 25, 26, 40, 42-48, and 50 from Plaintiff's opening slides,
which were presented to the jury over Defendants' objections.
Ex. B, containing PDX 51 from Plaintiff's direct examination of Andrew Perlman, which
was presented to the jury over Defendants' objections.
Ex. C, containing PDX 57-58, 60-61, 92-94, 101, 104-105, 107-117, 119-121, 125-128,
133-135, and 139-141 from Plaintiff's direct examination of Ophir Frieder, which were presented
to the jury over Defendants' objections.
Ex. D, depicting boards from Plaintiff's direct examination of Ophir Frieder, which were
presented to the jury and "checked off" over Defendants' objections.
Ex. E, containing PDX 63-65 and 81 from Plaintiff's direct examination of Stephen
Becker,1 which were presented to the jury over Defendants' objections.

1

Plaintiff apparently reused numbers between the Frieder and Becker slides.

01980.51928/5035996.1

1

Ex. F, containing DDX 2.22-2.24 from Defendants' direct examination of Lyle Ungar as
to infringement issues, on which the Court did not permit Dr. Ungar to testify.
Ex. G, containing DDX 3.35 from Defendants' direct examination of Lyle Ungar as to
validity issues, on which the Court did not permit Dr. Ungar to testify.
Ex. H, containing PDX 252 from Plaintiff's cross examination of Lyle Ungar, which was
presented to the jury over Defendants' objections.
Ex. I, containing DDX 15.26 from Defendants' direct examination of Keith Ugone, on
which the Court did not permit Dr. Ugone to testify.

Dated: November 2, 2012
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Google Inc., Target Corporation,
IAC Search & Media, Inc., and Gannett Co., Inc.

01980.51928/5035996.1

2

/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 W. Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
Robert L. Burns
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
Telephone: [phone]
Facsimile: [phone]
Cortney S. Alexander
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, GA 94111
Telephone: [phone]
Facsimile: [phone]
Counsel for Defendant AOL Inc.

01980.51928/5035996.1

3

CERTIFICATE OF SERVICE
I hereby certify that on November 2, 2012, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
the following:
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiff, I/P Engine, Inc.

/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]

12020666v1
01980.51928/5035996.1

4