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

Filing 858

Declaration re 857 Memorandum in Support (of Stephen E. Noona) in Support of Defendants' Motion to Compel Deposition of Dr. Becker by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Noona, Stephen)

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EXHIBIT 2 From: Sent: To: Cc: Noona, Stephen E. [senoona@kaufcan.com] Tuesday, January 15, 2013 4:14 PM Brothers, Kenneth; Donald C. Schultz (dschultz@cwm-law.com) Monterio, Charles; 'W. Ryan Snow'; David Perlson; Emily O'Brien; QE-IP Engine Ken: I discussed your counter to our counter on deposing the experts relating to the Motion for Supplemental Post-Judgment Royalties. Unfortunately, that counter is unacceptable as the pending motion should not be moot if the Court determines that it wants to postpone deciding the Post Judgment Royalties issues for all the reasons we have argued. As a result, we will be filing additional motions. In an effort to determine if the a ruling on our expedited motion is imminent, I am going to call Patrice tomorrow morning. I would like to include Ryan Snow or Don Schultz. I plan to call around 10:00 a.m. but will vary the time somewhat to meet their schedule. Just have one of them call so we can work out the details. Thanks,…SEN.     Stephen E. Noona  Kaufman & Canoles, P.C.  150 W. Main Street, Suite 2100  Norfolk, VA 23510-1665    T (757) 624.3239  F (757) 624.3169  senoona@kaufcan.com  www.kaufCAN.com        The information contained in this electronic message is legally privileged and confidential under applicable law, and is intended only for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying or disclosure of this communication is strictly prohibited. If you have received this communication in error, please notify Kaufman & Canoles at (757) 624-3000 or by return e-mail to helpdesk@kaufcan.com, and purge the communication immediately without making any copy or distribution. Disclosure Required by Internal Revenue Service Circular 230: This communication is not a tax opinion. To the extent it contains tax advice, it is not intended or written by the practitioner to be used, and it cannot be used by the taxpayer, for the purpose of avoiding tax penalties that may be imposed on the taxpayer by the Internal Revenue Service. 1

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