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)
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
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1
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