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

Filing 865

Declaration re 863 Opposition (of Dave Nelson) in Support of Defendants' Opposition to Plaintiff's Motion for Judgment Under Rule 52(B) and a New Trial Under Rule 59 on Laches by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Noona, Stephen)

EXHIBIT A

From:
Sent:
To:
Cc:
Subject:

Jen Ghaussy
Wednesday, October 31, 2012 2:46 PM
'Brothers, Kenneth'
'zz-IPEngine'; QE-IP Engine; 'W. Ryan Snow'; 'Donald C. Schultz ([e-mail])';
'Noona, Stephen E.'
I/P Engine v. AOL et al.

Ken:
In light of the Court’s ruling today, please let us know (1) what evidence concerning the royalty base Plaintiff intends to
rely on during closing, (2) what arguments Plaintiff intends to make regarding the amount of any running royalty
damages, and (3) what curative jury instruction Plaintiff proposes the Court give with respect to the damages period.
Given the time frame, please let us know by 7:30 PM.
Thank you,
Jen

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