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

Filing 96

Declaration re 95 Reply to Response to Motion of Margaret Kammerud in Support of Google's Reply in Support of Motion to Compel Plaintiff to Provide Conception, Reduction-to-Practice, and Priority Date Information for the Patents-in-Suit by Google Inc.. (Attachments: # 1 Exhibit L, # 2 Exhibit M, # 3 Exhibit N, # 4 Exhibit O, # 5 Exhibit P, # 6 Exhibit Q)(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.

DECLARATION OF MARGARET KAMMERUD IN SUPPORT OF GOOGLE'S REPLY
IN SUPPORT OF MOTION TO COMPEL PLAINTIFF TO PROVIDE CONCEPTION,
REDUCTION-TO-PRACTICE, AND PRIORITY DATE INFORMATION FOR THE
PATENTS-IN-SUIT
I, Margaret P. Kammerud, declare as follows:
1.

I am an attorney in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP and am

counsel for Defendant Google Inc. in the above-captioned case. I provide this declaration upon
personal knowledge and, if called upon as a witness, would testify competently as to the matters
recited herein.
2.

Attached hereto as Exhibit L is a true and correct copy of the document produced by

Plaintiff under Bates range IPEL0001270-1273.
3.

Attached hereto as Exhibit M is a true and correct copy of the document produced by

Plaintiff under Bates range IPEL0001395-1399.

01980.51928/4636514.1

4.

Attached hereto as Exhibit N is a true and correct copy of the document produced by

Plaintiff under Bates range IPEL0001557-1567.
5.

Attached hereto as Exhibit 0 is a true and correct copy of an email from Plaintiff's

counsel Charles Monterio to defense counsel, dated March 1, 2012.
6.

Attached hereto as Exhibit P is a true and correct copy of the document produced by

Plaintiff's counsel on behalf of named inventor Andrew "Ken" Lang under Bates range
LANG0007021-7028.
7.

Attached hereto as Exhibit Q is a true and correct copy of letter from Google's counsel

David Perlson to Plaintiff's counsel Ken Brothers, dated January 5, 2012.
8.

I declare under penalty of perjury of the laws of the United States that the foregoing is

true and correct.

Dated: March 5, 2012
Margaret P. Kammerud

01980.51928/4636514.1

DATED: March 5, 2012

/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: [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]
Attorneys for Google Inc.

CERTIFICATE OF SERVICE
I hereby certify that on March 5, 2012, 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:
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
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]
Counsel for Plaintiff, I/P Engine, Inc.

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]
Counsel for Google Inc.,
Target Corporation,
IAC Search & Media, Inc., and
Gannet Co., Inc.

2

/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: [phone]
Facsimile: [phone]
[e-mail]
11464104_1.DOC

3