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

Filing 89

Declaration re 88 Memorandum in Support of Margaret Kammerud in Support of Google's Motion to Compel Plaintiff to Provide Conception, Reduction-to-Practice, and Priority Date Infomation for the Patents-in-Suit by Google, Inc.. (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, # 10 Exhibit J, # 11 Exhibit K)(Noona, Stephen)

EXHIBIT K

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www.lycos.com

January 10, 2012
VIA U.S. MAIL
Joshua Sohn, Esq.
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nf Floor
San Francisco, CA 94111

Re:

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

Dear Mr. Sohn:
am attaching two CD's containing documents responsive to the subpoena issued to Lycos dated
November 29, 2011 in the above-captioned litigation.. Other than the documents Lycos
previously produced to you in December, 2011, these are all the documents Lycos could identify
after a reasonably diligent search in its possession, custody or control responsive to the
subpoena.
Please note that Lycos transferred all internal files relating to the patents-in-suit and the rest of
the patents within that family to the buyer of the patents at the time of the sale. Lycos did not
retain any copies of those documents for its records. Thus, discovery of all such documents
would have to go through that party. Second, although Lycos possesses certain electronic file
folders containing imaged documents of Don Kosak himself that it believes includes responsive
documents, Lycos does not possess the technical capability to open those folders and therefore
has been unable to access or view their contents for purposes of production. Nonetheless, per the
request of plaintiff's counsel and Mr. Kosak himself, Lycos provided Mr. Kosak with complete
copies of those folders on a CD a few months ago and believes he was able to access them.
Please work with plaintiff's counsel to obtain whatever documents exist in those folders relevant
to the subpoena.
If you have questions, please don't hesitate to contact me by phone or e-mail.
Sincerely,

Mark 0. Blais
General Counsel
Enclosures
Lycos, Inc.
100 Fifth Avenue
al