I/P Engine, Inc. v. AOL, Inc. et al
Filing
898
Response to 886 Order,,, (Parties' Joint Response to the Court's Order Regarding Outstanding Motions to Seal Case Documents) filed by AOL Inc., Gannett Company, Inc., Google Inc., I/P Engine, Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1)(Noona, Stephen)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
I/P ENGINE, INC.
Plaintiff,
Civil Action No. 2:11-cv-512
v.
AOL INC., et al.,
Defendants.
PARTIES’ JOINT RESPONSE TO THE COURT’S ORDER REGARDING
OUTSTANDING MOTIONS TO SEAL CASE DOCUMENTS
Per the Court’s Order Regarding Outstanding Motions to Seal Case Documents (“Order
on Outstanding Motions to Seal”) (D.N. 886), the parties, I/P Engine, Inc. (“Plaintiff”) and AOL
Inc., Gannett Co., Inc., Google Inc., IAC Search & Media, Inc., and Target Corporation
(collectively, “Defendants”), reviewed all outstanding motions to seal case records, then met and
conferred. As ordered by the Court, the parties have identified below all outstanding motions to
seal case records that are now moot, may be withdrawn, or otherwise able to be dismissed as
well as all outstanding motions to seal case records that still should be resolved by the Court
based upon the parties’ joint representations and the expectation that both parties may file an
appeal in this matter.
In addition to complying with the Court’s Order Regarding Outstanding Motions to Seal,
the parties have determined that given the presentation of evidence in public during trial, certain
individual documents subject to outstanding motions to seal case records that still should be
resolved by the Court may be filed publicly or may be filed with less material redacted than
originally requested. The parties have identified these exhibits below and will deliver additional
copies to the Court in hard copy and electronic form (on CD-ROM) by Friday, February 22,
2013.
Accordingly, the parties identify the following categories of materials:
1) Motions to seal case records that are now moot, withdrawn, or otherwise able to be
dismissed:
Docket Number
355
346, 4121
436
514
687
Motion Name
MOTION to Seal Exhibit 1 to its Memorandum in Support of Plaintiff I/P
Engines Daubert Motion, and Fourth Motion in Limine, to Exclude Lyle
Ungar’s New Theory of Invalidity and Opinions Regarding Claim
Construction
MOTION to Seal Documents and Close the Courtroom During
Presentation of Confidential Material at Trial
Joint MOTION to Amend/Correct 346 MOTION to Seal Documents and
Close the Courtroom During Presentation of Confidential Material at Trial
Joint Motion and Memorandum in Support of Joint Motion To
Amend/Modify Scheduling Order to Provide Briefing Schedule for Motion
to Seal and Close Courtroom
MOTION to Seal Plaintiff I/P Engine, Inc.’s Opposition to Defendants’
Motion in Limine #1 along with Exhibits 5-6 and 11-12
MOTION to Seal Exhibits 1 and 2 to its Response to Defendants Motion to
Seal Documents and Close the Courtroom During Presentation of
Confidential Materials at Trial
MOTION to Seal Portions of the Order on the Final Pretrial Conference
2) Motions to seal case records that should be resolved by the Court:
Docket Number
280
289, 368
(Corrected D.N. 285)
1
Motion Name
MOTION to Seal Plaintiff I/P Engine, Inc.’s Second
Motion for Discovery Sanctions Regarding Untimely
Discovery Responses along with Exhibits 2, 4, 5, 7, 8,
9, 13, and 14 in support
MOTION to Seal [CORRECTED MOTION]
Memorandum in Support of Plaintiff I/P Engine, Inc.’s
Notes
Defendants hereby withdraw the Motion to Seal Documents and Close the Courtroom
During Presentation of Confidential Material at Trial (D.N. 346, 412) as Moot and request that
the Court withdraw the motion and Plaintiff’s response thereto (D.N. 516) as well as any
supporting documents.
Third Motion for Discovery Sanctions Regarding
Untimely Discovery Responses along with Exhibits 1,
4, 5, 6, 7, in support
296
312
316
324
331
338
343
425
2
Sealed Memorandum in Support of THIRD 285
MOTION to Seal Memorandum in Support of Plaintiff
I/P Engine, Inc.’s Third Motion for Discovery
Sanctions Regarding Untimely Discovery Responses
along with Exhibits 1, 4, 5, 6, 7, in support
MOTION to Seal Portions of Defendants’
Memorandum in Support of Motion in Limine No. 3
to Exclude Marketing and High-Level Non-Technical
Matters Related to Historical Click-Through Rate, and
Exhibits F, H, I and J to the Declaration of Joshua L.
Sohn in Support of the Defendants’ Various Motions
in Limine
MOTION to Seal Exhibit 3 to the Memorandum in
Support of Plaintiff I/P Engine’s First Motion in
Limine to Exclude Inadmissible Evidence
MOTION to Seal Portions of Memorandum in
Support of Defendants’ Motion to Exclude Testimony
from Stephen L. Becker and Certain Materials Filed in
Support Thereof
MOTION to Seal Portions of Memorandum in
Support of Defendants’ Motion to Preclude Dr. Ophir
Frieder from Testifying Regarding Untimely Opinions
that were Not Disclosed in his Original Expert Report
and Opinions that he Now Concedes are Incorrect, and
Certain Materials Filed in Support Thereof
MOTION to Seal the Memorandum in Support of
Plaintiff I/P Engine, Inc.’s Second Motion in Limine
to Preclude Non-Comparable License Agreements
along with Exhibits 1 and 2
MOTION to Seal the Memorandum in Support of
Plaintiff I/P Engine, Inc.’s Motion to Exclude
Opinions and Testimony of Keith R. Ugone along
with Exhibits 1 and 2
MOTION to Seal Portions of the Declaration of
Not affected by
Michael Hochberg in Support of Plaintiff’s and
limitations2
Defendants’ Motions to Seal
MOTION to Seal its Opposition to Defendants Motion
for Summary Judgment along with Exhibits 8, 11-19,
22-24, 27-32, 34-39, 45, 53-54, 56
Documents subject to motions with this annotation are not included in the charts
below, and therefore should be decided in full as originally filed.
429
441
445
449
453
457
462
465
508
517
MOTION to Seal (1) Portions of Defendants’
Opposition to Plaintiff I/P Engine’s First Motion in
Limine to Exclude Inadmissible Evidence; (2)
Portions of Defendants’ Opposition to Plaintiff I/P
Engine’s Second Motion in Limine to Preclude
License Agreements, and (3) Exhibits E and K to the
Declaration of Margaret P. Kammerud in Support of
Defendants’ Opposition to Plaintiff’s Motions in
Limine
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants’ Motion in Limine #2 along
with Exhibits 1 and 2
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants’ Motion in Limine #3 along
with Exhibits 3-11
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants’ Motion in Limine #4 along
with Exhibits 1 and 2
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants’ Motion in Limine #5 along
with Exhibits 1 and 2
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants’ Motion to Exclude the
Testimony of Stephen L. Becker along with Exhibits
1-5, 7-8, and 10-11
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants Motion to Preclude Dr.
Frieder from Testifying Regarding Untimely Opinions
along with Exhibits 1-3 and 5
MOTION to Seal Defendants’ Memorandum in
Support of Their Opposition to Plaintiff I/P Engine,
Inc.’s Motion to Exclude Opinions and Testimony of
Keith R. Ugone
MOTION to Seal (1) Portions of Defendants’
Opposition to Plaintiff’s Daubert Motion, and Fourth
Motion in Limine, to Exclude Lyle Ungar’s New
Theory of Invalidity and Opinions Regarding Claim
Construction and (2) Exhibits 10 and 12 to the
Declaration of Howard Chen in Support of
Defendants’ Memorandum in Opposition to Plaintiff’s
Daubert Motion, and Fourth Motion in Limine, to
Exclude Lyle Ungar’s New Theory of Invalidity and
Opinions Regarding Claim Construction
MOTION to Seal (1) Portions of Defendants’
Memorandum in Opposition to Plaintiff’s Second
Motion for Discovery Sanctions; (2) Portions of
524
561
567
647
684
706
802
828
Defendants’ Memorandum in Opposition to Plaintiff’s
Third Motion for Discovery Sanctions; (3) Portions of
the Declaration of Margaret Kammerud in Support of
Defendants’ Opposition to Plaintiff’s Third Motion for
Discovery Sanctions; (4) Portions of Exhibits A-E, G,
I-K to the Declaration of Jennifer Ghaussy in Support
of Defendants’ Opposition to Plaintiff’s Second
Motion for Discovery Sanctions; and (5) Exhibits L-Q
to the Declaration of Margaret Kammerud in Support
of Defendants’ Opposition to Plaintiff’s Third Motion
for Discovery Sanctions
MOTION to Seal Portions of the Reply in Support of
Defendants’ Motion for Summary Judgment, and
Exhibits 34 and 36 to the Declaration of Joshua L.
Sohn in Support of Defendants’ Reply in Support of
Defendants’ Motion for Summary Judgment
MOTION to Seal (1) Portions of Defendants’ Reply
Brief in Support of Their Motion to Preclude Dr.
Ophir Frieder from Testifying Regarding Untimely
Opinions that were not Disclosed in his Original
Expert Report and Opinions that he Now Concedes
are Incorrect; (2) Portions of Defendants’ Reply Brief
in Support of their Motion to Exclude the Testimony
of Stephen L. Becker; and (3) Portions of Exhibit I to
the Declaration of Howard Chen in Support of
Defendants’ Reply Brief in Support of their Motion to
Preclude Dr. Ophir Frieder
MOTION to Seal Plaintiff I/P Engine, Inc.’s Reply in
Further Support of its Motion to Exclude Opinions
and Testimony of Keith R. Ugone along with Exhibits
1-3
MOTION to Seal Plaintiff I/P Engine, Inc.’s Reply in
Further Support of its Third Motion for Discovery
Sanctions along with Exhibits 1 and 2
MOTION to Seal Exhibits 1 and 4 to its Opposition to
Defendants Motion to Dismiss All Claims Against
AOL, Inc., Gannett Co., Inc., IAC Search & Media,
Inc., and Target Corporation
MOTION to Seal Portions Of Exhibit 1 To The
Not affected by
OBrien Declaration In Support Of Defendants Motion limitations
For Sanctions And To Strike Portions Of Dr. Frieder’s
Second Updated Expert Report
MOTION to Seal and Redact Portions of Trial Record Not affected by
limitations
MOTION to Seal (1) Portions Of Defendants
Not affected by
Memorandum In Support Of Renewed Motion For
limitations
866
873
Judgment As A Matter Of Law On Non-Infringement
Or New Trial; (2) Portions Of Defendants’
Memorandum In Support Of Renewed Motion For
Judgment As A Matter Of Law On Damages Or New
Trial; And (3) Certain Exhibit To The Declaration Of
Joshua L. Sohn In Support Of Defendants Renewed
Motions For Judgment As A Matter Of Law On
Damages, Invalidity And Non-Infringement Or New
Trial
MOTION to Seal Portions of Defendants’
Memorandum in Opposition to Plaintiff’s Rule 59
Motion for a New Trial on the Dollar Amount of
Damages and Exhibit 2 to the Declaration of Margaret
P. Kammerud Filed in Support Thereof
MOTION to Seal Plaintiff I/P Engine, Inc.’s
Opposition to Defendants Renewed Motion for
Judgment as a Matter of Law on Non-Infringement or
New Trial
Not affected by
limitations
Not affected by
limitations
3) Documents subject to motions to seal case records that should be resolved by the Court
that may be filed publicly:
Docket Number of
Motion to Be Ruled
Upon
280
Docket Number
of Document at
Issue
278, 342
280
278-14, 366
289, 368 (Corrected
D.N. 285)
289, 368 (Corrected
D.N. 285)
289, 368 (Corrected
D.N. 285)
296
283
304, 380
296
310-6, 381
296
310-8, 382
296
310-9, 383
283-4, 370
283-5, 371
Document Description
Plaintiff’s Memorandum in Support of Second
motion for Sanctions
Exhibit 14 to Plaintiff’s Memorandum in
Support of Second motion for Sanctions
Plaintiff’s Memorandum in Support of Third
Motion for Sanctions
Exhibit 4 to Plaintiff’s Memorandum in Support
of Third Motion for Sanctions
Exhibit 5 to Plaintiff’s Memorandum in Support
of Third Motion for Sanctions
Defendants’ Memorandum in Support of Motion
in Limine 3
Exhibit F to Defendants’ Memorandum in
Support of Motion in Limine 3
Exhibit H to Defendants’ Memorandum in
Support of Motion in Limine 3
Exhibit I to Defendants’ Memorandum in
Exhibit I to Support of Motion in Limine 3
316
323-2, 387
316
323-13, 398
316
321, 402
324
329-8, 379
338
341, 420
425
427-19
425
427-29
429
439
445
447
445
447-3
445
447-4
445
447-7
445
447-8
445
447-9
445
447-10
445
447-11
449
451
449
451-2
453
455
453
455-2
457
460
457
460-1
457
460-4
Exhibit 2 to O’Brien Declaration in Support of
Defendants’ Motion to Exclude Becker
Exhibit 13 to O’Brien Declaration in Support of
Defendants’ Motion to Exclude Becker
Fox Declaration in Support of Defendants’
Motion to Exclude Becker
Exhibit H to Defendant’s Motion to Exclude
Frieder
Plaintiff’s Memorandum in Support of Motion to
Exclude Ugone
Exhibit 45 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 56 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Defendants’ Opposition to Plaintiff’s Motion in
Limine 1
Plaintiff’s Opposition to Defendants’ Motion in
Limine 3
Exhibit 3 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 4 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 7 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 8 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 9 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 10 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Exhibit 11 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 3
Plaintiff’s Opposition to Defendants’ Motion in
Limine 4
Exhibit 2 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 4
Plaintiff’s Opposition to Defendants’ Motion in
Limine 5
Exhibit 2 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 5
Plaintiff’s Opposition to Defendants’ Motion to
Exclude Becker
Exhibit 1 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Becker
Exhibit 4 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Becker
457
460-11
462
464
462
464-1
462
464-5
508
511
508
512-10
517
522-9
517
522-10
517
523
517
523-1
517
523-3
524
528-1
567
568
Exhibit 11 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Becker
Plaintiff’s Opposition to Defendants’ Motion to
Exclude Frieder
Ex. 1 to Plaintiff’s Opposition to Defendants’
Motion to Exclude Frieder
Ex. 5 to Plaintiff’s Opposition to Defendants’
Motion to Exclude Frieder
Defendants’ Opposition to Plaintiff’s Motion to
Exclude Ungar
Exhibit 10 to Defendants’ Opposition to
Plaintiff’s Motion to Exclude Ungar
Exhibit I to Ghaussy Declaration in Support of
Defendants’ Opposition to Plaintiff’s Second
Motion for Sanctions
Exhibit J to Ghaussy Declaration in Support of
Defendants’ Opposition to Plaintiff’s Second
Motion for Sanctions
Kammerud Declaration in Support of
Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit L to Kammerud Declaration in Support
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit N to Kammerud Declaration in Support
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit 34 to Defendants’ Reply in Support of
Motion for Summary Judgment
Plaintiff’s Reply in Support of Motion to
Exclude Ugone
4) Documents subject to motions to seal case records that should be resolved by the Court
that may be filed with less material redacted than originally requested:
Docket Number of
Motion to Be Ruled
Upon
280
Docket Number
of Document at
Issue
278-7, 362
289, 368 (Corrected
D.N. 285)
289, 368 (Corrected
283-1, 369
283-6, 372
Document Description
Exhibit 7 to Plaintiff’s Memorandum in Support
of Second motion for Sanctions
Exhibit 1 to Plaintiff’s Memorandum in Support
of Third Motion for Sanctions
Exhibit 6 to Plaintiff’s Memorandum in Support
D.N. 285)
289, 368 (Corrected
D.N. 285)
296
310-10, 384
312
315-3, 416
316
320, 385
316
323-1, 386
324
328, 375
324
329-2, 377
331
331
331
338
338
425
334, 417
334-1, 418
334-2, 419
341-1, 421
341-2, 422
427
425
427-2
425
427-2
425
427-2
425
427-2
425
427-5
425
427-5
425
427-5
425
427-5
425
427-5
425
427-8
425
427-8
283-7, 373
of Third Motion for Sanctions
Exhibit 7 to Plaintiff’s Memorandum in Support
of Third Motion for Sanctions
Exhibit J to Defendants’ Memorandum in
Support of Motion in Limine 3
Exhibit 3 to Plaintiff’s Memorandum in Support
of Motion in Limine 3
Defendants’ Memorandum in Support of Motion
to Exclude Becker
Exhibit 1 to O’Brien Declaration in Support of
Defendants’ Motion to Exclude Becker
Defendants’ Memorandum in Support of Motion
to Exclude Frieder
Exhibit B to Defendants’ Memorandum in
Support of Motion to Exclude Frieder
Plaintiff’s Motion in Limine 2
Exhibit 1 to Plaintiff’s Motion in Limine 2
Exhibit 2 to Plaintiff’s Motion in Limine 2
Exhibit 1 to Plaintiff’s Motion to Exclude Ugone
Exhibit 2 to Plaintiff’s Motion to Exclude Ugone
Memorandum in Support of Plaintiff’s
Opposition to Defendant’s Motion for Summary
Judgment
Exhibit 3 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 4 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 5 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 8 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 19 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 11 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 14 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 17 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 18 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 22 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 23 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
425
427-8
425
427-11
425
427-11
425
427-27
441
443
441
443-1
441
443-2
449
451-1
457
460-5
457
460-7
462
464-2
465
466
465
468-4
465
468-5
508
512-12
517
522-7
517
521
517
523-2
517
523-4
517
523-5
517
523-6
Exhibit 24 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 27 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 29 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Exhibit 54 to Plaintiff’s Opposition to
Defendant’s Motion for Summary Judgment
Plaintiff’s Opposition to Defendants’ Motion in
Limine 2
Exhibit 1 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 2
Exhibit 2 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 2
Exhibit 1 to Plaintiff’s Opposition to
Defendants’ Motion in Limine 4
Exhibit 5 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Becker
Exhibit 7 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Becker
Exhibit 2 to Plaintiff’s Opposition to
Defendants’ Motion to Exclude Frieder
Defendants’ Opposition to Plaintiff’s Motion to
Exclude Ugone
Exhibit D to Defendants’ Opposition to
Plaintiff’s Motion to Exclude Ugone
Exhibit E to Defendants’ Opposition to
Plaintiff’s Motion to Exclude Ugone
Exhibit 12 to Declaration of Howard Chen in
Support of Defendants’ Opposition to Plaintiff’s
Motion to Exclude Ungar
Exhibit G to Ghaussy Declaration in Support of
Defendants’ Opposition to Plaintiff’s Second
Motion for Sanctions
Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit M to Kammerud Declaration in Support
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit O to Kammerud Declaration in Support
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit P to Kammerud Declaration in Support
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Exhibit Q to Kammerud Declaration in Support
524
527
561
571-1
567
569-1
567
569-2
647
651-2
684
686-1
684
686-4
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Defendants’ Reply in Support of Motion for
Summary Judgment
Exhibit I to Defendants’ Reply in Support of
Motion to Exclude Frieder
Exhibit 1 to Plaintiff’s Reply in Support of
Motion to Exclude Ugone
Exhibit 2 to Plaintiff’s Reply in Support of
Motion to Exclude Ugone
Exhibit 2 to Plaintiff’s Reply in Support of Third
Motion for Sanctions
Exhibit 1 to Plaintiff’s Opposition to
Defendants’ Motion to Dismiss Claims against
AOL, Gannett, IAC, and Target
Exhibit 4 to Plaintiff’s Opposition to
Defendants’ Motion to Dismiss Claims against
AOL, Gannett, IAC, and Target
To streamline the Court’s efforts in resolving the pending motions to seal, the parties
propose delivering to the Court in hard copy and in electronic form (on CD-ROM) the referenced
now public and lesser redacted documents by Friday, Feb. 22, 2013. Should the Court deem the
lesser redacted documents appropriate, the parties will work with the clerk’s office to substitute
or refile those exhibits and public versions of the exhibits in category three above. The parties
attach a Proposed Order for the Court’s consideration as Exhibit 1.
Dated: February 19, 2013
Respectfully submitted,
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
senoona@kaufcan.com
Counsel for AOL Inc., Google Inc., IAC Search &
Media, Inc., Gannett Co., Inc. and Target
Corporation
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
davidbilsker@quinnemanuel.com
davidperlson@quinnemanuel.com
Counsel for Google Inc., IAC Search & Media, Inc.,
Gannett Co., Inc. and Target Corporation
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
senoona@kaufcan.com
Robert L. Burns
FINNEGAN, HENDERSON, FARABOW, GARRETT &
DUNNER, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
Telephone: (571) 203-2700
Facsimile: (202) 408-4400
Cortney S. Alexander
FINNEGAN, HENDERSON, FARABOW, GARRETT &
DUNNER, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, GA 94111
Telephone: (404) 653-6400
Facsimile: (415) 653-6444
Counsel for Defendant AOL Inc.
/s/Donald C. Schultz
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: (757) 623-3000
Facsimile: (757) 623-5735
dschultz@cwm-law.cm
wrsnow@cwm-law.com
sstancliff@cwm-law.com
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: (202) 420-2200
Facsimile: (202) 420-2201
sherwoodj@dicksteinshapiro.com
brothersk@dicksteinshapiro.com
Counsel for Plaintiff, I/P Engine, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on February 19, 2013, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
the following:
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: (757) 623-3000
Facsimile: (757) 623-5735
dschultz@cwm-law.cm
wrsnow@cwm-law.com
sstancliff@cwm-law.com
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: (202) 420-2200
Facsimile: (202) 420-2201
sherwoodj@dicksteinshapiro.com
brothersk@dicksteinshapiro.com
Counsel for Plaintiff, I/P Engine, Inc.
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
senoona@kaufcan.com
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