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)

Exhibit 1

EXHIBIT 1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
I/P ENGINE, INC.
Civil Action No. 2:11-cv-512
Plaintiff,
v.
AOL, INC., et al.,
Defendants.

PROPOSED ORDER REGARDING PARTIES’ JOINT RESPONSE TO THE COURT’S
ORDER REGARDING OUTSTANDING MOTIONS TO SEAL CASE DOCUMENTS

On this day came the parties, I/P Engine, Inc. (“Plaintiff”) and AOL Inc., Gannett Co.,
Inc., Google Inc., IAC Search & Media, Inc., and Target Corporation (collectively
"Defendants"), by counsel, pursuant to this Court’s Order Regarding Outstanding Motions to
Seal Case Documents (D.N. 886) (“Order Regarding Outstanding Motions to Seal”), and the
Parties’ Joint Response to the Court’s Order Regarding Outstanding Motions to Seal (the
“Response”), and after consideration of that Response and arguments in support of that
Response, and for good cause shown, it is:
ORDERED THAT:
1.

The following pending motions to seal are deemed moot and therefore withdrawn:

Docket Number
355

01980.51928/5172639.1

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

346, 412

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

436
514

687

The Clerk is instructed to return to the parties all previously filed materials relating to these
withdrawn motions.
2.

Based upon the parties’ joint representations and the expectation that both parties

may file an appeal in this matter, the following motions to seal still need to be resolved by the
Court:

Docket Number
280

289, 368
(Corrected D.N. 285)

296

312

01980.51928/5172639.1

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 Third Motion for Discovery
Sanctions Regarding Untimely Discovery Responses along with
Exhibits 1, 4, 5, 6, 7, in support
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

2

316

324

331

338

343
425

429

441
445
449
453
457

462

465

508

01980.51928/5172639.1

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 NonComparable 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 Michael Hochberg
in Support of Plaintiff’s and 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, 3439, 45, 53-54, 56
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

3

517

524

561

567

647

684

706

802
828

01980.51928/5172639.1

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 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 OBrien Declaration
In Support Of Defendants Motion For Sanctions And To Strike
Portions Of Dr. Frieder’s Second Updated Expert Report
MOTION to Seal and Redact Portions of Trial Record
MOTION to Seal (1) Portions Of Defendants Memorandum In
Support Of Renewed Motion For Judgment As A Matter Of Law
On Non-Infringement Or New Trial; (2) Portions Of Defendants’

4

866

873

3.

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

Based upon the parties’ joint representations, the following individual materials

subject to the motions to seal that still need to be resolved by the Court 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

316

323-2, 387

316

323-13, 398

316

321, 402

01980.51928/5172639.1

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
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’

5

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

457

460-11

462

464

462

464-1

01980.51928/5172639.1

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
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’
6

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

4.

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

Additionally, per the parties’ representations in their Response, the parties are

directed to deliver electronic (on a CD-ROM) and hard copies of the following, lesser redacted
materials to Chambers by Friday, February 22, 2013:

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
D.N. 285)
289, 368 (Corrected
D.N. 285)

283-1, 369

01980.51928/5172639.1

283-6, 372
283-7, 373

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
of Third Motion for Sanctions
Exhibit 7 to Plaintiff’s Memorandum in Support
of Third Motion for Sanctions
7

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

425

427-8

425

427-11

01980.51928/5172639.1

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
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
8

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

524

527

01980.51928/5172639.1

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
of Defendants’ Opposition to Plaintiff’s Third
Motion for Sanctions
Defendants’ Reply in Support of Motion for
Summary Judgment
9

561

571-1

567

569-1

567

569-2

647

651-2

684

686-1

684

686-4

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

The Court will review the lesser redacted documents and decide whether each should be
substituted in the place of the originally filed, proposed sealed material to which each relates.
Thereafter, the Court will instruct the Clerk and the parties to substitute the appropriate
documents.

Dated:

, 2013

Entered:

_____/_____/_____

______________________________
United States District Court
Eastern District of Virginia

01980.51928/5172639.1

10

WE ASK FOR THIS:

Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART & SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for AOL Inc., Google Inc., IAC Search & Media, Inc.,
Gannett Co., Inc. and Target Corporation

Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Robert L. Burns
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
Telephone: [phone]
Facsimile: [phone]

01980.51928/5172639.1

11

Cortney S. Alexander
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, GA 94111
Telephone: [phone]
Facsimile: [phone]
Counsel for Defendant AOL Inc.

01980.51928/5172639.1

12

WE ASK FOR THIS:

Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Plaintiff, I/P Engine, Inc.

12218641v1
01980.51928/5172639.1

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