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 C

Joshua Sohn
From:
Sent:
To:
Cc:
Subject:

Brothers, Kenneth [[e-mail]]
Monday, December 19, 2011 2:57 PM
David Perlson; Margaret P. Kammerud
QE-IP Engine; [e-mail]; zz-IPEngine
RE: I/P Engine v. AOL et. al.

David:
I am disregarding your pejorative characterizations, which which I do not agree. When you did not raise the issues in
Meg's letter during our meet and confer on Friday, Dec. 16, despite my specific inquiry of whether you wanted to discuss
any other issues, I had understood that you were not pursuing the matter at that time. Frankly, I assumed that defendants
had elected to not pursue the priority date issue until and unless defendants set forth their invalidity analysis an
demonstrated the relevance of an earlier priority date. Once defendants make a prima facia showing that a priority date
earlier than the date identified in plaintiff's interrogatory response is relevant, plaintiff will review and supplement as
appropriate. If you want to meet and confer, I am available on Thursday, Dec. 22, between 2 pm and 5 pm ET.
Ken

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From: David Perlson [mailto:[e-mail]]
Sent: Monday, December 19, 2011 4:25 PM
To: David Perlson; Margaret P. Kammerud; Brothers, Kenneth; zz-IPEngine
Cc: QE-IP Engine; '[e-mail]'
Subject: RE: I/P Engine v. AOL et. al.

Ken when is Plaintiff available to meet and confer on this.
From: David Perlson
Sent: Friday, December 16, 2011 5:45 PM
To: Margaret P. Kammerud; Brothers, Kenneth; zz-IPEngine
Cc: QE-IP Engine; [e-mail]
Subject: RE: I/P Engine v. AOL et. al.

Ken, on Tuesday Meg sent the attached letter detailing insufficiencies in Plaintiff’s responses to Google’s first
set of interrogatories. The letter requested a response no later than Thursday, but Plaintiff has failed to respond.
Your bluster today regarding Google’s interrogatory responses rings especially hollow when you do not respond
to the issues we raise, including Plaintiff’s failure to provide a straight answer on Plaintiff’s claimed priority
date. We expect a response no later than Monday morning.

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From: Margaret P. Kammerud
Sent: Tuesday, December 13, 2011 3:24 PM
To: Brothers, Kenneth; zz-IPEngine
Cc: QE-IP Engine; [e-mail]
Subject: I/P Engine v. AOL et. al.

Counsel:
Please see the attached correspondence.
Regards,
Meg
Margaret P. Kammerud

Quinn Emanuel Urquhart & Sullivan, LLP
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