doc. 2 att. 2 dockets.justia.com x... · representation that you have the information that shows...

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http://dockets.justia.com/docket/court-cacdce/case_no-2:2009cv06283/case_id-452887/

http://docs.justia.com/cases/federal/district-courts/california/cacdce/2:2009cv06283/452887/2/2.html

http://dockets.justia.com/

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IN THE UNITED STATES DIS 'PRTCT CaURT

FOR THE EASTERN DISTRICT OF TExAS

MARSHALL DIVISION

PERFORMANCE PRICING, INC.,

Pla^.nta.ff ,

vs. No_ 2:07-CV-432 {LEDsGOOGLE , INC., AOL LLC,

MICROSOFT CORPORATION,

YAHOO ! INC., IAC SEARCH

& MEDIA , INC_, and A9.COM,INC.,

Defendants.

^^

DEPOSITION OF HEAL M. COHEN

Irvine, Califarna^a

Wednesday, February I1, 20Q9

Reported by:

DENISE BARD5LEY

CSR No . 1124].

JOB No . IQSD88

EXHIBIT _' ___PAGE^^.^

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vz/î/ogNEAL M. COHEN

to presume for right now, for the sake of simplicity,

the '253 is the one I worked an and take your

representation that you have the information that

shows that I did that.

Q Yeah.

A If that's true, it might have even been this

`253 patent --

Q O'^ây . _

A -- that I talked to him about.

Q Okay. So in the last year, when you've

spoken to him, why -- have you billed him for your

time, Mr. Lin?

A I believe I did. I didn't say it was a^n the

last year, though.

Q Okay. You sa^.d --- I' m kind of waving an to a

different set of communications. I understand that

wasn 't clear.

Yau previously indicated that within the past

year you've had seveacal attorney-client communications

with Mr. Lin, right?

A I didn't say " several ," but T have had some,

Î YeS -

Q .And have you charged Mr. Lin for those

communications?

A I darx't recall, but I don't believe I did.

^.9

SARNOFF COURT REPORTERS AND LEGAL TECîn,Q^,^^^

^._..___877.955.3855 tt^^hh

NEAT. M. COHEN D2/].1/09

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Q Okay. Why not?

A I'm not going to ansv^rer that question because

I believe that would reveal attorney-client privileged

information.

Q How does that involve revealing attorney--

client ---

A Well, I believe any communications I have had

with Mz. l,in have been attorney-client privileged, and

what you're asking rote now is why I didn't bill him for

my communication?

Q Yes.

A I think that is a privileged information.

Q Haw does that represent an attorney-client

privilege?

A I'm claiming that as privileged information

and I'm going to refuse to answer based on that claim.

Q Okay. Well, we can address that at a later

point.

Have you worked on any litigation involving

Mr. Lin or any of his entities that he owns?

A Have I worked on any litigation? Again, just

to give your woard "work" a broad definition, Y mean, I

consider what I' m doing right now work even though I'm

not getting paid for it. This is related to his

entity, sa, in that respect, yes.

2Q

SARNOFF COURT REPORTERS AND I .EGAl. TECHNOLOGIES

^^ ^` ^ ^ ^

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l^fEAL M . COHEN 02/11/09

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Q Okay.

A I know, if you want to ask a mare specific

question, maybe ---

Q Sure.

Well, separate and apart from appearing at

the deposition today, have you done any work for

Mr. Lin in connection with any litigation brought by

Mr_ Lin or any of his entit^.es?

A Not that I know of, no.

Q Okay. Fiad you prepared any materials in

anticipation of any litigation far Mr. Lin?

A T believe so, yes.

Q dkay. Which apes would those be?

A Specifically the documents?

Q Yes.

A T think almost everything T did for him was

prepared in anticipation of litigation when T was

working for hire.

Q So in your view, preparing patent prosecution

documents is done in anticipation of litigation?

A When you say "patent prosecution documents,'0

do you mean , ^'or example, drafting the patent

application?

Q Sure.

A Tt can be. Tn a sense it is, yes_

21

SARNO^^ COURT R^pORTERS AND LEGAL 7'ECliNOLOGEES,877.955.8855 ^/\^ ^ ^ ^ @ ^ _^,^..^_

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Q Well ---- okay. So it is your position that

the documentation yatx prepared xn connection with the

prosecution of patents fvr Mr. Lin was done in

anticipation of litigation?

A In general, they can be. In my case, if

you're asking me when 1 was preparing the patent

application for Mr. Lin, was that done in anticipation

of litigation ---

Q That's my question.

A Is that the specific question you're asking?

Q Yes.

A I believe that it was, yes_

Q What litigation?

A There was no litigation in place at the time,

Q Well, what litigation was it done in

anticipation of?

A xt was in anticipation of some litigation.

Q Aga^.nst who?

A 1 don't know that there was a specific entity

in mind at the time .

Q Okay.

MR. ANDERSON: Microsoft would request that

Mr. Cohen and plaintiff's counsel reconsider theix

assertion of work product in light of that statement.

BY MR. PERLSON:

22

SARNOFF COURT R^PORT 'FRS AND ^..FGALT^CHTlOLOGiIES877.955.3$55 ^^^ ^ ^ ^^

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i{{iili^^11;1f1î^^tl^l trialla^^crs;sQt^tranciscaaY : !^`^^ ^,ii _ a .i I'i:n r. ti:!tt €`rai^î.^^,. i...îl]lrlv,! 'J•31 i E ... -.. ; ^^^^_,,, ^.. : z'•. . 4s ^?:-,.:-:;;,

March I6, 2009

VIA ELEtCTRONfC MAIL

Christin ChoDovel & Luner LI.P201 Santa Monica ôulevard_ Suite 600Santa Monica_ C,^ 9001

Re: Performance Pricin>t. Inc. v. Google Inc. et al.

Dear Christin:

I write to summarize our telephone conference of March 13, 2009_

First; we discussed the HomeGopher server currently stored in Vti'ayne Lin's garage. You stated _...-.that the server was prepared for sale in 2002, and that as a result of this preparation Mr. Linbelieves there is no information on the server. However, Mr. Lin does not have the capabilitiesto confirm this. Therefore; you will have a data recovery service look at the server, to see if anyinformation can be recovered. You stated that Mr. Lin is currently out of to^^^n anti! March 23,but you are working to get access to the server in advance of his return. Please keep us updatedon the status of the data recovery service's work on the server, including the efforts used torecover data from the server.

Second, you stated that you now had the cellular phone containing an embodiment of U_S. PatentNo. b,978,253 that was created for Mr. Lin. You indicated that this phone ^+âs a Nokia. but didnot have any additional model information. You are working on finding a charger for the phone.If you are unable to do so; you stated that you could then send the phone to your data recoveryservice, to work on recovering the program from the phone. Please keep us updated on yoursearch for a charger, and if necessary the data recovery service's work on the phone.

t^k3{hli L' ITtiifl[iEEUEQIlh3r ! Uî4I^t & ^Y8dIJS5.11^1

..^ .`\ i ,... !^^!' ^>-` ....,, , r}'! es ):.... nits s . Rs!^-: K!:i tif;,,,._.... :L:!;'.5' ... ti!:. ... .. ... .. ! &î. . !,t^'

n: :':Aan6a : ,. ^^ t;•:: r; \ . is i::, :, ;•W !^^,,. .. f?^:[_ j^.dsaia '_d'!snu:c. ^4in 5:c^1.r. ^.- ^,•Q - - -8^ ^' .`.:-b]-.?l] .. t! ? i5:.:-]-._

51305l2836fj63,1^ .., ::!::1 : I+•,,.. - . :^!_:, ^^r- ,:..r t uid.. ... --lh.:^ct, .,, . , fit.

Third, you are working on gaining access to Mr. Lin's tEnancial documents. However. youstated that Mr. Lin is out ofto^^^n until March 23. Therefore. you have not yet been able to gainaccess to these documents. Please let us kno^v° ^^°hen you have gained access to the documents.and after you have completed your review of them.

Fourth, you stated that you have an original of the notarized document produced as part of thedocuments at P00036$-400. You agreed to send us a better copy of this document, withappropriate page break. However. you stated that you cannot make better copies of the otherdocuments in the range P000368-400, as you do not have originals of the handwritten drawings.I explained that we may v^ânt to send someone to inspect these documents at a lacer time.

Fifih_ we discussed the issue of documents related the E-Dvnamix Software. You stated that theE-Dynamix Softv<âre package was never created. and that there are no documents related to 1;-Dynamix Sol^vare.

Sixth, eve discussed the general issue ofthe extent of Mr. Lin's search of his garage for materialsresponsive to the subpoenas served on him and PricePlay. You stated that }'ou did ask him tosearch his garage again.

Seventh, we discussed Neal Cohen's planned revisions to his privilege log produced in thismatter. You stated that Mr. Cohen would address the first issue raised in my February 24 Fetter,revising entries that improperly claimed work product protection. You also stated that Mr.Cohen would address the third issue raised, separately logging each document rather thangrouping documents together on the log. You also stated that Mr. Cohen would address thefourth issue I had raised, regarding entries without any apparent "client."

With regard to the second issue raised, you indicated that }ôu believed some of the Defendants'privilege log descriptions were similar to those used by Mr. Cohen, and therefore askedDefendants to reconsider their position on this issue. We do not have the other Defendants'privilege logs, but do not believe there is any inconsistency in our position. However, we wi IIlook at Mr. Cohen's revised privilege log after the other issues have been addressed, and thenconsider whether additional revisions need to be made to the descriptions.

With regard to the fifth issue raised, you stated that you had not yet considered this issue, andpromised to get back to me after discussing with Mr. Cohen. As pointed out in my February 24letter, you had agreed during the deposition of Mr. Cohen to provide us with the information thatwould be on a privilege !og far the retention agreement between Mr. Cohen and Dovel & Luner.We therefore expect to see this information on Mr. Cohen's revised privilege log.

5134512836663 .1 ^-y , ^ ^ ^ ^ ^ ^^ ^ry- •

^^^^ ^ -

r'",^"^

As always, we remain willing to meet and confer to resolve any discovery issues, and hope thatyou similarly remain willing to work together on these issues in a timely and efficient manner. Ifyou believe that a live discussion would be helpful, we are available to do so.

Cordially.

Is/ Emily C_ O'Brien

Errlily C. O'Brieni13051?8366b^s.l

51305fdS35663 .1 ^ V

UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXAS

Performance Pricing, Inc.

Plaintiff,

v.

Google, Inc. et al.,

Defendants.

2:p7-cv-432 (LED}

REVI5ED PRIVILEGE LOG CORRESPONDING TO: 1}

SUBPOENA COMMANDING NON-PARTY NEAL M.

COHEN TO PRODUCE DOCUMENTS; AND 2}

SUBPOENA COMMANDING NON-PARTY VISTA IP

LAW GROUP LLP TO PRODUCE DOCUMENTS

The Revised Privilege Log attached hereto as Exhibit A is being Produced in

connection with: 1) RESPONSE TO SUBPOENA COMMANDING NON-PARTY NEAL M. COHEN

TO PRODUCE DOCUMENTS ; and 2} RESPONSE TO SUBPOENA COMMANDING NON-PARTY

VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS. Ail documents identified in said

Privilege Log are being withheld on the bases identified, and are not being produced.

Abbreviations used in the Privilege Log:

"NMC" means Neai M . Cohen;

"W L" means Wayne Lin;

"VLS" means Valerie L. Sarigumba, who was at ail relevant times an associate

attorney at Vista iP Law Group;

"JLL" means Jocelyn L. Lee, who was at al[ relevant times a senior paralegal at Vista IP

Law Group;

"HO" means Hidehiko Okada, who was at all relevant times an attorney at the law

firm, Okada Patent & Trademark Office;

"SS" means Samuel B. Stone, who was at all relevant times a partner at Lyon & Lyon

LLP;

"!T" means Jeff Tekanic, who was at all relevant times an attorney at the law firm,

Okada Patent & Trademark Office;

"PJE" means Patricia J. English, who was at all relevant times an employee at Cohen,

Sakaguchi & English tLP;

"YPY" means Yev-Pyo Yoon, who was at all relevant times an attorney at Honesty &

Patent;

P^G E - ^ ^ ^ _..^..

^^ ^

"A/C" means a claim of Attorney/Client Privilege;

"W/P" means a claim of Work Product;

"TPM" means a claim of Trial Preparation Material.

^^^f^l^ ^._F.^^aGE ^ ^f - .

^' iY ^^f^ ^i^ W

^^

Ref Date Author(s) Recipient ( sy Description Privilege(s)Claimed

1-1 8/2/2001 NMC WL Document concerning legal advice and AC, WP

including confidential communications

between client and attorney. Documentrelated to litigation.

1-2 8/13/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


including confidential communicationsbetween client and attorney. Documentrelated to litigation.


1-5 Z/20/01 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney, Documentrelated to litigation.



1-7 1/3/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

1-8 10/1/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

Ref Date Aathor{s) Recipient (s^ Description Prl^ilege(s)Claimed

related to litigation.1-9 12/13/00 NMC WL Document concerning legal advice and AC, WP



1-li 4/2/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1-12 7/2$/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

1-13 5/10/01 NMC WL Document concerning Eegal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1-14 20/14/02 NMC WL bocument concerning legal advice and AC, WPincluding confiders€ial communicationsbetween client and attorney. Documentrelated tp litigation.

1-15 8/2/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

1-16 11/30/00 NMC WL Document concerning legaE advice and AC, WPincluding confidential communications

between client and attorney. Document

^ ^^ ^

C^

'i^ ^^ ^rn ^

-^

Ref pate Author (s) ftecipient(sJ Description Privilege(s)Claimed

related to litigation,1-17 10/27/99 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Document

related to litigation.1-18 6/1/00 NMC WL Document concerning legs! advice and AC, WP




1-21 3/6/02 NMC WL Document concerning legal advice and AC, WPincluding confidential commuricationsbetween client and attorney. Documentrelated to litigation.

1-22 10/9/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

^.-23 715/00 NMC WL pocument concerning Eegal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1-24 2/18100 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

;.'^ .C^ .,.

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Ref Date Author (sy Recipient(s) Description Privilege(s)Claimed

related to litigation.1-25 $/13/01 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Documentrelated to litigation,


1-27 7/31/02 Document concerning legal advice and WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


2-6 8/13/D1 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


3-1 5/7/02 NMC WL Document concerning legal advice and AC, WPincluding Confidential communications


3-2 9/1D/D1 NMC WL Document concerning legal advice and AC, WPincluding confidential communications

between client and attorney, Document

^ _

m oo,^ ^

^^

Ref Date Author (s) Recipient (s) Description Arivilege(s)Claimed

related to litigation.3-3 9/10/01 NMC WL Dowment concerning legal advice and AC, WP


between client and attorney. Documentrelated #o litigation.


3-5 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney.


3-7 S/2/01 NMC WL Document concerning legal advice and AC, WP

including con#identiaE communicationsbetween client and attorney, Documentrelated to litigation.


3-9 4/23/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communications

between Client and attorney. Documentrelated to litigation.

3-10 4/6/01 NMC WL Document concerning legal advice and AC, WPincluding Confidential communicationsbetween client and attorney. Documentrelated to litigation.

t"^ ^

°°'..^

Ref Date Author (s) Recipient (s) Description Privilege(s)Claimed

3-11 4/6/01 NMC WL Document concerning legal adv'sce and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.



3-14 1129/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.



3-17 ].1/6/00 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney, Documentrelated to litigation,

3-IS 11/6/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communications

^ between client and attorney. Document

7C related to litigation,

^ ^I^ W

Ref Date Author (s) Recipient(s) Description Privilege(s)Claimed



3-2D 912.8/00 NMC WL pocument concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

3-21 9112/DD NMC WL Document concerning legal advice and AC, WP


3-2z 6/5/00 NMC WL Document concerning legal advice and AC, WP



related to litigation.3-24 S/30/OD NMC WL Document concerning legal advice and AC, WP


3-25 1/26/OD NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney, Documentrefaced to litigation.



Ref Date Authar ( s} Recip€ent(s^ Description Privilege(syClaimed


3-28 3/9/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communications





including confidential communicationsbetween client and attorney.


including confidentia€ communicationsbetween client and attorney. Documentrelated to litigation.

3-34 1/17/Op NMC WL Document concerning legal advice and AC, WP



including confidential communicationsbetween cl€ent and attorney. Documentrelated to litigation,

3-36 11/29/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. pocumentrelated to litigation,

4-1 10/16/01 NMC WL Oacument concerning legal advice and AC, WP

`^rn ^,

^^

Ref i^a#e Author (s) Recipient {s) Description Privilege(s)Claimed


4-2 $/3.4/01 NMC WL ^ Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

related to litigatio,,.4-3 4/5/01. NMC WL iacument concerning legal advice and AC, WP


4-4 1/1.9/01 NMC WL Dacument concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

4-5 6/26/00 NMC WL Document concerning legai advice and AC, WP

including confidential communicationsbetween client and attorney. Documentrelated to €itigation.



including confidential communicationsbetween client and attorney. Dacumentrelated to litigation.

4-$ 12/21/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,


^ ^^ ^

^ ^°"'°'^

Ref Date Author{s) Recipient { s^ Description Privilege(s)CEaimed


S-3. 4/17/02 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

5-2 8/13/01 NMC WL Document concerning legal advice and AC, WPincluding con€idential communications

^ between client and attorney. Documentrelated to litigation.

S-3 $/2$/DO NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

5-4 b/5/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated tp litigation.

6-1 7/9/D1 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


6-3 3/2/01 NMC WL Document concerning legal advice and AC, WPincluding cpnfidentiai communicationsbetween client and attorney. Documentrelated to litigation.


m ;

^^

Ref Date Author{s^ Recipient ( s) Description Privilege{s)Claimed


6-S 4/11/00 NMC WL Document concerning legal advice and AC, WPincluding con#idential communicationsbetween client and attorney. Documentrelated to litigation.


7-1 NMC HO Document related to litigation. WP7-2 NMC HD Document related to litigation. WP7-3 NMC ^ HO Document related to litigation. WP7-4 NMC HO Document related to litigation. WP7-5 NMC HO Document related to litigation. WP7-6 NMC HO Document related to litigation. WP7-7 NMC HD Document related to litigation, WP$-1 1/2/02 NMC WL Document concerning legs{ advice and AC, WP




$-4 NMC WL Document concerning legal advice and AC, WPincluding confidential communications

U [j 'i'

^'7 ^:.rn_ ^

^^

y

^ ^^ ^

m W

Ref Date Authors} Recipient ( s^ Description Privilege(s)Claimed

l7etween client and attorney. Documentrelated to litigation.

8-5 4/17/02 NMC WL Document concerning legs! advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

8-6 ^1/25/OZ NMC Wl_ Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

g-1 NMC YPY Document related to litigation. WP9-Z 12/14/01 NMC YPY Document related to litigation, WP10-1 3/21/00 NMC WL Document concerning legal advice and AC, WP



10-3 12/13/99 NMC WL f Document concerning legal advice and AC, WPincluding confidentia! communicationsbetween client and attorney. Documentrelated to litigation.

10_4 11/10/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

10-5 9/28/99 NMC WL Document concerning fega! advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

^ ^^ ^

m ^

Ref Oate Author {sJ Recipient {s) Description Privilege{s)Claimed



1Q-7 9/24/49 NMC WL Document concerning legal advice and AC, WPincluding con€idential communicationsbetween client and attorney. Documentrelated to litigation,



11-3 7/5/DO NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

11'4 7/1/04 NMC WL Document concerning legal advice and AC, WP


11-5 5/4/00 NMG WL Document concerning legal advice and AC; WPincluding confiden.:z! communicationsbetween client and attorney. Documentrelated tp iitigatian.

11-6 5/13/DO NMC WL Document concerning legal advice and AC, WP


11-7 5/13/DD NMC WL Document concerning legal advice and AC, WPincluding confidential tommunicationsbetween client and attorney, Documentrelated to litigation.

•-;^

^_^ ^

-^^/'^

Ref Date Authar (s} Rec € pient(s} Description Privileges}Claimed


11-9 2/10/00 NMC Trademarfc attorney Document related to litigation involving WP

in Taiwan PricePlay11-9 12/31/99 NMC WL Document concerning lega€ advice and AC, WP

including con#idential communicationsbetween client and attorney. Documentrelated to litigation.

11-9 12/14/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween cl€ent and attorney. Documentrelated to litigation.

11-10 11/7.0/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

11-11 9/27/99 NMC WL Document concerning €egal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

11-12 9/28/99 NMC WL Document concerning legal advice and AC, WPincluding confidential communicat€onsbetween client and attorney. Documentrelated to litigation.

12 6/14/99 SS WL, NMC Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

' related to litigation.

13 06/10/1999 - WL, NMC, S5 WL, NMC, SS Document concerning legal advice and A/C, W/P, TPM

°^ 10/04/2002 including confidential communications

Ref Date Authors} Recipient(s) Description Privilege(s)Claimed


14 06/14/1999 SS NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1S 06/28/1999 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confider*^al communicationsbetween client and attorney. Documentrelated to litigation.

16 11/10/1999 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation. _




17-3 8/21/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. bocumentrelated to litigation.


17-5 4/6/01 NMC WL bocument concerning legal advice and AC, WPincluding confidential communications

f^'^^-^;

w..,,,,,i ^ t

^.JkJ

^ ^Fr'r! W

°'m^^

Ref Da#e Author(s) Recipient(s) Description Pri^ilegets)Claimed




17-$-9 6/5/00 NMC WL Document concerning legs[ advice and AC, WPincluding con#identia! communicationsbetween cEient and attorney. Documentrelated to litigation.

17-10 4/24/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated To ]itigation,

17-11- 3/13/00 NMC WL Document concerning legal advice and AC, WP12 including confidential communications

between client and attorney. Documentrelated to litigation,



17-16- 1/17/00 NMC WL Document concerning legal advice and AC, WP

19 including confidential communicationsbetween cEient and attorney, Documentrelated to litigation.

17-^0 11/29/99 NMC WL Document concerning legal advice and AC, WPi-^ including Confidential communications

^ ^f"r`i

W

1f

Ref Date Author (sj Recipient(s) Description Privilege(s)Claimed


18-1 9/10101 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


related to litigation.

1$-3 4/6/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

18-4-5 11/6/00 NMC WL Document concerning legal advice and AC, WP


between client and attorney, Documentrelated to litigation.

18-6-7 3/13/00 NMC WL Document concerning legal advice and AC, WP

including Confidential communications


18-8- 2/16/00 NMC WL Document concerning legal advice and AC, WP

11 including confidential communicationsbetween client and attorney. Documentrelated to litigation.

1$-1z- 1/26100 NMC WL Document concerning legal advice and AC, WP


1$-15- 12/6/99 NMC WL Document concerning legal advice and AC, WP


Y

Ref pate Author ( s) Recipient(s) Description Privilege(s)Claimed


19 12/13/1999 - NMC WL Document concerning legal advice and A/C, W/P, TPM01/17/2002 including confidential communications


z0 1x/13/1999 NMC N/A Document related to litigation. W/P, TPM21 12/13/1999 NMC N/A Document related to litigation. W/P, TPM22 12/14/1999 NMC WL Document concerning legal advice and A/C, W/P, TPM


23-1 9/10/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

23-2 4/23/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

23-3 4/6/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communications


23-4-5 11/6/00 NMC WL Datument concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

23-6-7 3/13/00 NMC WL Document concerning legal advice and A/C, W/P, TPM


^ ^^ ^

f

`°:^-^ ^i['^`^ ^

i ^°^-•3

Ref Date Author(s) Recipient ( sy Description Rri^ilege(s)Claimed

23-8 3/9/00 NMC WL Document concerning legal advice and A/C, W/P, TPM


23-9- 2/16/00 NMC WL Document concerning legal advice and A/C, W/P, TPM

li including confidential communicationsbetween client and attorney. Documentrelated to litigation.

23-12- 1/26/00 NMC WL Document concerning legal advice and A/C, W/P, TPM

14 including confidential communicationsbetween client and attorney. Documentrelated tv litigation.


including confidential corr3municationsbetween client and attorney. Documentrelated to litigation.


including con#idential communicationsbetween client and attorney. Documentrelated to litigation.

24-3-4 6/5/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.



2^t-6-7 3/13/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

i._.1^.^ related to litigation.

^ ^I-F"i

^

°-°'^^

Ref date Autfior (s) Recipient [ s^ Description Privilege(s)Claimed

Z4-8-^.0 2/16/00 NMC WL Document concerning legal advice and A/C, IN/P, 7PMincluding confidential communicationsbetween client and attorney. Document

related to litigation.24-11-13 2/9/Op NMC WL Document concerning legal advice and A/C, W/P, TPM


24-14-15 2/5/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

24-15 2/5/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communications


25-1 9/26/02 NMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney. pocumentrelated to litigation.

25-Z 7/9/01 NMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

Z5-3 3/2/01 NMC WL Document concerning legal advice and AC, WP, TPM


25-4 7/12/00 NMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communications

between client and attorney. Document^ related to litigation. .

Ref Date Author (s) Recipient(s) Description Privilege(s)Claimed

25-5 4/11/00 NMC WL Document concerning legal advice and AC, WP, TPM

including Confidential communicationsbetween Client and attorney. Documentrelated to litigation.

25-6-7 3/13/00 NMC WL Document concerning legs{ advice and AC, WP, TPM

including confidential communicationsbetween Client and attorney. Documentrelated to litigation.

25-8 10/8/02 NMC JT, WL Document concerning legal advice and AC, WP, TPM

including confider.*.^al communicationsbetween client and attorney, Documentrelated to litigation.

Z6-1 9/27/02 NMC JT, Wl. Document concerning legal advice and AC, WP


26-2-3 9/26/02 NMC JT, WL Document concerning {ego] advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to iitigation.

26-4 7/2/01 HO NMC Document related to litigation. WP

26-5 3/2/01 JT NMC Document related to litigation. WP

26-6-7 2/28/01 NMC Flo Document related to litigation, WP

26-$-9 7/12/00 NMC HO Document related to litigation. WP

26-10- 7/4/00 HO NMC Document related to litigation. WP

11


14


16

26-17- 6/21/00 NMC HO Document related to litigation. WP

18

^ ^^ ^

N ^^

Ref Date Author { s) Recipient (s) Description Privilege{s)Claimed

26-19- 6/21/00 NMC HO bocument related to litigation. WP18 '

26-17- 6/21/00 NMC HO Document related to litigation. WP18 i

27-1 9/x6/02 NMC WL Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney, bocumentrelated to litigation.



27-3-4 11/14/01 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.


including confidential communicationsbetween client and atkflrney. Documentrelated to litigation.

27-6 11/13/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigatbn.

27-7 10/16/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbekween client and attorney. Documentrelated to litigation.

x7-8 9/12/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

.^ }C

^ ^^ ^

t

Ref Date Author(s) RECipient ( s^ Description Privileges}Claimed

27-9 5/30/00 NMC WL Document concern ing legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

27-10 5/16/00 WL NMC Document concerning legal advice and A/C, W/P, TPM


28-1 10/4/02 NMC WL Document concerning IegaE advice and A/C, W/P, 1'PMincluding con#idential communications

^ between cl'sent and attorney. Documentrelated to litigation.


including confidential communicationsbetween client and attorney. Documentrelated to fitigatian.






28-5 8/13/03. NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidentiaE communicationsbetween client and attorney. Documentrelated to litigation.

28-6 8/28/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

^ ^a^ ^

(^-'^^

3 ^L

Ref i7ate Authors} Recipients} gescription I?ri^ilege(s}Claimed

28-7 6/5/00 NMG WL Document concerning legal advice and A/C, W/P, TPM


28-8 5/31/OD NMC WL Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney, bocumentrelated to litigation.

29-1 9/13/00 NMC WL Document concerning legal advice and AC


29-2 9/13/00 NMC WL Document concerning legal advice and ACincluding confidential communicationsbetween client and attorney.

30-1 10/13/04 Honesty & Patent PJE Document related to litigation, WP

30-2 7.0/11/04 Honesty & Patent P1E Document related to litigation, WP

30-3 10/i3/04 PJE Honeslty & Patent Document related to litigation. WP

30-4 10/6/04 5e-Chang Kang , NMC ' Document related to li#igation. WP

Korean patent

counsel

30-5 10/19/02 NMC YPY bocument related to litigation. WP

30-6.7 10/18/02 NMC YPY, WL Document concerning legal advice and WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

30-8-9 10/17/02 NMC YPY, WL Document concerning legal advice and ACincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

30-10- 1D/17/02 YPY NMC Document related to litigation. WP

11

30-12- 9/26/02 NMC YPY, WL Document concerning legal advice and AC, WP

^ ^^ ^^ W

`^(J ^ 'U

^^^ ^^ Z

^ C^

^-^-^ `_C'! ^

Ref Date Author(s^ Reclpient(s^ gescriptian Privilege(s)

Claimed


30-14 7/29/02 YPY NMC Document related to litigation. WP

30-15 7/29/02 YPY NMC Document related to litigation, WP


30-17- 12/29/01 YPY NMC Document related to litigation. WP

1930-20- 12/26/01 Honest & Patent NMC Document related to litigation. WP


30-2Z- 12/24/01 NMC YPY Document related to litigation, WP

23

30-24 12/14/01 NMC YPY pvcument related to litigation. WP

30-25- 12/14/01 NMC YPY Document related to litigation, WP

26

30-27- 12/9/01 ^ NMC YPY Document related to litigation. WP

32

30-33- 11/!5101 YPY NMC Document related to litigation, WP

3430-35- 11/15/01 YPY NMC ^ Document related to litigation. WP

37

30-38 11/14/01 NMC Honest & Patent Document related to litigation. WP

30-39- 11/1/01 Honest & Patent NMC Document related to litigation, WP

4031-1 10/4/02 NMC WL Document Concerning legal advice and A/C, W/P, TPM

including Confidential communicationsbetween client and attorney. Documentrelated to litigation.



Ref Date Author(s) Recipient ( s) Description Privilege(s)Claimed










31-7 3.0/4/02 NMC WL Document concerning legal advice and A/C, W/P, TPM


31-8 b/5/02 NMC WL Document concerning legal advice and A/C, W/P, TPM


31-8 5/31/01 NMC Wl. Document concerning legal advice and A/C, W/P, TPM


32 10/29/2002 NMC WL ^ Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney. C]acumentrelated to litigation.

.,.^ ^:^ :^i^ ^

Ref Date Aut3lor (s) Recipient (s) Description Privilege(s)Claimed

33 12/27/2D02 NMC WL Document Concerning legal advice and A/C, W/P, TPM

including confiden#ial communications


34 06/12/2003 NMC WL DoCUrnent car,cerning legal advice and A/C, W/P, TPM

including confidential cornmunicatiansbetween client and attorney. Document


35 07/22/2D03 WL NMC Document concerning legal advice and A/C, W/P, TPM

including confidential Communicationsbetween client and attorney. Document

related to litigatio^^^.

36 12/02/2004 NMC WL Document concerning legal advice and A/C, W/P, TPM


37 12/03/2004 NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM

including Confidential communicationsbetween client and attorney. Document


38 12/03/2004 WL NMC Document concerning legal advice and A/C, W/P, TPM


39 12/03/200A NMC, WL WL, NMC Document Concerning legal advice and A/C, W/P, TPM

including Confidential communicationsbetween Client and attorney. Documentrelated to litigation,



i-n C7^

i

Ref t7ate Author {s) Recipient (sy Description Priviiege(s^Claimed

41 09/17/2005- NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM

09/20/2005 including confiders#ial communicationsbetween client and attorney. Documentrelated to litigation.

42 09/17/2005- NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM

09/23/2005 including confidential communicationsbetween client and attorney. Documentrelated to litigation.

43 10/06/2045 NMC N/A Document related to litigation. W/P, TPM

44 12/20/2005 WL NMC Document concerning legal advice and A/C, W/A, TPM


45 12/22/2005 NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM


_ related to litigation.

46 Oz/02/2005 NMC WL Document concerning legal advice and A/C, W/P, TPM


47 D2/O8/2006 NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM


48-1 3/3/07 NMC WL Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

4$-2 2/26/07 NMC WL Document concerning legal advice and A/C, W/P


i.

r!^ ^

l^ ll^J'--^-I

^-^ ^ ^-'^i

Ref Date Author {s) Reciplent ( sj Description Privilege{syClaimed

related to litigation,

48-3 2/26/07 NMC WL Document concerning legal advice and A/C, W/P



49-1 2126/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential [ommunicationsbetween client and attorney, Documentrelated to litigation.

49-2 2/26/07 WL NMC Document concerning legal advice and A/C, W/P



including confidential communicationsbetween client and attorney. Documentrelated to litigation. __



SO-2 2/27/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween [lient and attorney. Documentrelated to litigation.


including confidentia3 communicationsbetween client and attorney. Documentrelated to litigation.

51 02/27/2007 NMC WL Document [ancerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

^t

^ ^

_W

'^

V^ 1f^^

Ref Date Authar (s} Recipient (sy Description Privileges}Gaimed




53 D3/05/2D07 WL NMC Document concerning legal advice and A/C, W/P, TPM

including con#idential communicationsbetween client and attorney, Document


54 D3/D6/2D07 WL NMC Document concerning legal advice and A/C, W/P, 7PM


55 03/Db/2007 NMG WL Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney. Documentrelated to litigation. _



57 03/07/2007 NMC WL Document concerning legal advice and A/C, W/P, 7PM


58 03/11/2007 NMC WL, VLS Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.



^J ^

6 ^"I C^

^^.s

E ^i l

Ref 17ate Authors} Recipient ( sy >7escrfptlon Privilege(s^Claimed


59-Z 3/13/07 WL NMC bocument concerning legal advice and A/C, W/P

including confidential communicationsbetween client and attorney, Documentreiated to litigation.

b0-1 3/13/07 NMC WL Document concerning legal advice and A/C, W/P




61-1 3/17/07 NMC WL, VLS Document concerning legai advice and A/C, W/P


61-Z 3/7.7/07 NMC WL, VLS Document concerning legal advice and A/C, W/P




63 03/17/2007 WL NMC, VLS Document concerning legal advice and A/C, W/P, TPM


64 03/17/20D7 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidentiaE communicationsbetween client and attorney. Document

^ ^^'7

^

`^#^^^

}tef Date Author(s) Reclpient ( sy Description Privilege(s)Claimed


65 03/17/2007 NMC WL Document Concerning legal advice and A/C, W/P, TPM


rekated to litigation.


including confidential Communicationsbetween client and attorney. Documen#related to litigation,





69 03/26/2007 NMC WL, VLS Document [oncerning legal advice and A/C, W/P, TPM

including confidential [ommunicationsbetween client and attorney. Documentrekated to litigation.

70 03/26/2007 WL NMC, VL5 Document concerning legaE advice and A/C, W/P, TPM


71 03/2$/2007 WE. NMC, VLS Document concerning legal advice and A/C, W/P, TPM


72 03/29/2007 JLL NMC Document related to litigation. W/P, TPM



%-C^ ^

^ ^

Ref f72te Author {s) Recipient ( s^ pescriptian Privilege(s)Claimed


73-Z NMC WL Document concerning legal advice and A/C, W/P


73-3 NMC WL Document concerning legal advice and A/C, W/P



including confidential communicationsbetween client anu attorney. Documentrelated to litigation.




73-6 3/17/07 NMC WL Document concerning legal advice and A/C, W/Pincluding confidentiak communicationsbetween client and attorney. Documentrelated to litigation.

73-7-8 NMC WL bocument concerning legal advice and A/C, W/P



including con€idential communicationsbetween client and attorney. Documentrelated to litigation.

75 03/30/2007 NMC WL, VLS Document concerning legal advice and A/C, W/P, TPM

including confidentiak Communications

..^ X^ ^!^ ^

Ref pate Author (s) Recipient { s) Description Privilege(s)Clairt^ed


76 03 /30/2007 WL NMC, VLS Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney. Documentrelated to I'stigation.

77 03/30/2007 NMC WL, VLS, 1LL Document concerning legal advice and A/C, W/P, TPM


78 03/30/2007 WL NMC, VLS, 1LL Document concerning legal advice and A/C, W/P, TPM


79 D3 /30/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


SO 03/30/2007 NMC VLS, JLL Document related to litigation . W/P, TPM

81 03/30%2007 NMC N/A Document related to litigation . W/P, TPM



83 05/O1/20D7 NMC WL Document concerning legal advice and A/C, W/P, TPM




u a i

^_

^^

^^I ^^

Ref Da#e Authors) Recipients} Description Priîlege[s)Claimed

SS 05/04/2007 WL NMC Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween Client and attorney. Document

related to I'stigation.

86 OS/18/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


` between client and attorney, Documentrelated to litigation.

87 07/Oî/2447 NMC WL. Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney, Document










92 10/OS/2007 WL NMC Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween cl'sent and attorney. Documentrelated to litigation,

.^ ^ C

^ ^

^^`Ê ^

ite# Date Authar[s) Recipient [sy Description Privileges)Claimed

93 12/17/2007 NMC WL Document concerning legal advice and A/C, WJP, TPM


94 06/11/2008 WL NMC Document concerning legal advice and A/C, W/P, 'fPM


95 06/14/200$ NMC WL Document concerning legal advice and A/C, W/P, TPM


i related to litigation.

96 10/26/ZOp$ Christin Cho NMC document concerning legal advice and A/C, W/P, TPM

including confider.;i4l communicationsbetween client and attorney. Documentrelated to litigation.



^ ^^ T`

^ ^

k ,

Emily O'Brien ,.^_.

Flom : Bache[ Kim [rachel@dove!law.com]Sent: Thursday, April 16, 2009 2:26 PMTo: [email protected]; [email protected]; [email protected]; [email protected];

[email protected]; [email protected]; .3ennifer A Kash; [email protected];Emily O'Brien; David Perlson; Antonio 5istos; Charles K Verhoeven;[email protected]; [email protected]; [email protected]; jwmcbride@sid[ey.com;[email protected]; [email protected]; jgi[[email protected]; Google-performancePricing

Cc: charley@pbatyler_com; [email protected]; [email protected];[email protected]; christin@davel[aw.com; [email protected];risaac@caps hawlaw. com

Subject : Performance Pricing v. Googie, et a[.- Neal CohenNista 1P Law DocumentsAttachments: NMC-002.fxt; NMC-001.1og

Counsel,

pease find attached two documents ^ogged as Entry ZO on the Neal Cohen and Vista i[' Law Privilege tog that werepreviously withheld. A revised privilege fog w!f[ be circulated slZOrtly.

Do not hesitate to contact me with any questions.

Rachel lCim

Legal Assistant

Dovel & Luner, LLP

(31fl} 556-7056

201 Santa Monica l3vld.Suite 600Santa Monica, CA 90401

^^

Emily U'Brienr ^ rr^i n i rrrrr^ rn^.n^^ ^

From: Rachel Kim [[email protected]]Sent: Tuesday, April 2'f, 2008 3:34 PMTO: [email protected]; [email protected]; eftndlay@rameyf[oclc.com; [email protected];

mjacobs@mat'o.com; [email protected]; Jennifer R Kash; [email protected];Emily O'Brien; David Perlson; Antonio Sistos; Charles K Verhoeven;mrichardson@brsfirm_com; [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; Goggle-PerformancePricing

Cc: [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];risaac@ca ps hawlaw.com

Subject: Performance Pricing v. Google, et al_- Nea[ CohenNisfa IP Law DocumentsAttachments: Singfe_pg VIP02.zip; Multi^g VlP02.zip; Privilege Log(REVISEt7} 4'2'I'09.pdf

Counsel,

Please find attached a revised Privilege Log for the documents produced by Neat Cohen and Vista IP Law along withdocuments previously withheld.

Do not hesitate to contact me with any questions.

Racket KimLegal AssistantDovel & Luner, LLP(310)_ 656-706620i Santa Monica Bvld.Suite f00Santa Monica, CA 90401

PaG E ^^^.r

UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXAS

Performance Pricing, fnc.

Plaintiff,

v.Google, Enc. et al.,

Defendants.

2:DT-ev-432 {Lf"©)

REVISED PRIVILEGE LOG CORRESPONDING TO: 1}

SUBPOENA COMMANDING NON-PARTY NEAT. M.CDHEN TO PRODUCE DOCUMENTS; AND 2)

SUBPOENA COMMANDING NOIV-PARTY VISTA IP

LAW GROUP LLP TD PRODUCE DOCUMENTS

The Revised Privilege Log attached hereto as Exhibit A is being produced in

connection with: ].} RESPONSE TO SUBPC`ElVA COMMANDING NON-PARTY NEAT M. COHEN

TO PRODUCE DOCUMENTS; and 2} RESPONSE 70 SUBPOENA COMMANDING NON-PARTY

VISTA IP LAW GROUP LLP TO PRODUCE DOCUMENTS. AI! documents identified in said

Privilege Log are being withheld on the bases identified, and are not being produced.

Abbreviations used in the Privilege Lag:

"NMC" means Nea! M. Cohen;

"W L" means Wayne Lin;

"VLS" means Valerie L. Sarigumba, who was at all relevant times an associate

attorney at Vista IP Law Group;

"J LL" means Jocelyn L. Lee, who was at al! relevant times a senior paralegal at Vista IP

Law Group;

"HO" means l-iidehika Okada, wha was at ail relevant times an attorney at the law

.firm, Okada Patent & Trademark Office;

"SS" means 5amuei B. Stone; who was at all relevant times a partner at Lyon & Lyon

LLP;

"JT" means Jeff Tekanic, who was at all relevant times an attorney at the taw firm,

Okada Patent & Trademark Office;

"PJE" means Patricia J. English, who was at all relevant tunes an employee at Cohen,

Sakaguchi & English LLP;

"YPY" means Yeo-Pyo Yaon, who was at ail relevant times an attorney at Honesty 8e

Patent;

EXHIBIT _- ^ --.PAGE -l^__

^^

"AJC" means a claim of AttarneyJClient Privilege;

"WJl'" means a claim of Work Product;

"TPM" means a claim of Trial Preparation Materiai.

E^^#(^(PACE ..^._^^ .^...

i^

.Ref .^^ Date ,... ^.. Quthô.r{s) Recipêrit{s^' Descrrpti,on '^ Prrvi[^ge(s)

_ CiatrnedJ: 1 8/2/2Q01 NMC

_ _Wl Document concerning legal advice and AC, WP

including confidential communicationsBetween client and attorney. Documentrelated tp litigation.

1-Z 8/13/Q1 NMC_

WL Document concerning legal advice and AC, WPincluding confidential communications

. between client and attorney. Documentrelated to litigation.

1-3 3/29/01 NMC Wi. Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

'1-4 1/12/Ql NMC Wi_ Dacumen# concerning legal advice and AC, WPinclud€ng confldential communicationsbetween client and attorney. Documentrelated to litigation,

1-5 2/20/Q1 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney, Document srelated to litigation. i

^:1-6 2/27/99 NMC WL Document concerning legal advice and AC, WP încluding confldential communications.between client and attorney. Document Irelated to litigation. _ __._.`

1-7 1/3/01 NMC

_

WL Document concerning legal advice and AC, WPincluding confidential commcnicationsbetween client and attorney. Documentrelated to litigation.

^ 1..g 10/1/Q1 NMC WE. Document Concerning legal advice and AC, WPincluding confidential communications ,

^ l umentli ttornt db ocetween c en an a ey.

"-T,3 '

^7^ ^

=^

^^,^-1

ftef: Date ^ ^ AutFiot{s}..., . . Rec^^Pieht {'s) .. Description Pfivilege{s)

. ^ Claimed.. ^ .._ ..related to litigation.

1-9 12/13/00 NMC WLw

Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1-1D 11/15/01 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated tv litigation.

1-11 4/2/01 NMC WL Document concerning legal advice and AL, WPincluding confidential communicationsbetween cffent and attorney. Documentrelated tv litigation.

1-12 7/28/00 NMC WL Document concerning legal advice and AC, WPincluding confident^^^ rommunlcativnsbetween c[lent and attorney. Documentrelated to litigation.

1-13 5]10/41 NMC__

WL Document concerning legal advice and_

AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

1-14 10/14/02 NMC WL Document concerning legal advice and AC, WPinc€uding confidential communications

` between client and attorney. Documentrelated to iitigatian.

1-15 $/2/01 NMC WL ! Document concerning legal advice and AC, WP^ including confidential communications


1-16 11/$0/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

1

'"t7 1^^

^^

Ref. Date"

Au#Ii'ar(6)° ^^ ^ . Recipient{s) ^ Descrlption^ PriviEege(s),. .. Claimed

_ . related to lltigation.3-17 10/27/99 NMC

_ .WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Darumentrelated to litigation. _


including confidentia [ communicationsbetween client and attorney. 1)oCumentrelated to litigation.

1-19 4/18/0? NMC WL Document concerning legal advice and AC, WP

including confidentia! eommunica#ionsbetween client and attorney . Documentrelated to litigation. _

1-20 10/16/01 NMC WL T Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Documentrelated to litigation,_

1-21^ _

^/6/OZ NMC WL Documert concerning legal advice and AC, WPincluding confidential Communicationsbetween client grid attorney. Documentrelated to litigation.



including Confidential communicationsbetween client and attorney . Documentrelated to litigation.

-24 2/18/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and at#orney . Document

i

i

ei

^ ^^ ^

'Kef.

..,.:^: pate ^^i Auti^or(s) ' ^

- ` Recipient(s) ^_

^ Description ^ Privilege(s7_

.. :^Clalrned.

_ related to litigation^-25 8/13/01 NMC WL Document concerning legal advice and AC, WP

including conf:dential communicationsbetween client and attorney. documentrelated to litigation.

1-26 4/17/02 NMC WL ^_

Document concerning legal advice and AC, WPincluding co,fidential communicationsbetween client and attorney. Documentrelated t_o litigation.

1-Z7 7/31/02 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

Z-5 8/2/01 NMC 4U[. Document concerning legal advice and AC, WP


__ related to litigation. _Z-6 8/7.3/01 NMC WL Document concerning legal advice and AC, WP

including con€idential communicationsbetween client acrd attorney. Documentrelated [o litigation, _

2-11 3/17/07 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigat'€an,

3.1 5/7/02 NMC WC Document conwrning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

related to litigation,

3-2 9/10/01 NMC WL Document concerning legal advice and AC, WPincluding confidentia[ communicationsbetween client and attorney. Document

^ ^^ `__

^ ^

it

^: ••Eief .. ".Date Aut^ar (s} ^' :Recipient(s) ^ Description >:: P.tivifege(sy•Ciaimed


including can €identiaf communicationsbetween client and attorney. Documentrelated to litigation.


3-5 NMC WL !Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attarney.

3-6 8/21/01 NMC Vt^L Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

related to litigatiprs.'3-7 5/Z/D1 NMC WL Document concerning legal advice and AC, WP


^_ related to litigation.

3-$ 4/30)01 NMC WL Document concerning legal adults and AC, WPincluding can€identia{ communicationsbetween client and attorney. Documentrelated to litigation.

3-9 4/23/01 NMC WL Document concerning legal advice and_

AC, WP

including confidential communicationsbetween client and attorney . Documentrelated to litigation.

3-10 4/6/01 NMC WL Document concerning 1egaE advice and_

AC, WPincluding canfidentia! communicationsbetween client and attarney. Documentrelated to litigation.

,^

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3-11 4/6/01 NMC WL Documen# concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

3-1Z 4/5/01 NMC WL Document concerning legal advice and AC, WPincluding confidentia# communicationsbetween client and attorney. Document

_ _ related to litigation.3-13 3/x0/01 NMC

^WL Document concerning legal advice and AC, WP

including confidential communicationsbetween cEient and attorney. Document

_^_ related to litigation.3-14 1 1j29/01 NMC WL Document concerning legal advice and AC, WP

11 including confidential communications^ between client and attorney. Document' _ related to litlp^ation.

3-15 ^ 11/30/00_ _

NMC wL_

Document concerning legal advice and AC, WPincluding confidential communicationsbetween client aid attorney. Documentrelated to liti at'son.


including confidential communicationsbetween client and attorney. Documentrelated to iiti anon.

3-17 11/6/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. bocumentrelated to litigation.

3-18 11/S/00 NMC^.

WL Document concerning legal advice and AC, WPincluding confidentiaE communicationsbetween client and attorney. Documentrelated to litigation.

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3-19 10/16/00 NMC WL_

Document concerning legal advice and AC, WPincluding confidentiu; communications

' between client and attarney. Documentrelated to litigation.

3-ZD 9/Z8/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation. _

3-Z1 9/12/00 NMC WL Document concerning legaE advice and qC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

3-ZZ 6/5/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document ^related to litigation. I

3-23 6/5/00 NMC WL Document concerning legal advice and AC, WPincluding confidentia[ communicationsbetween client and attorney. Documentrelated to litigation.

3-24 5/30/00 NMC WL Document to^ZCerning legal advice and AC, WP

including confidential cammunicationsbetween client and attorney. Documentrelated to litigation. _

3-Z5 1/25/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attarney. Documentrelated to litigation.


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3-27 3/23/00 NMC WL_ __

Document concerning legal adults and AC, WP.including confidential communicationsbetween client and attorney. Documentrelated to litigation.


3-29 2/9/00 NMC_

WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

3-31 1/26/OD NMC WL Document concerning legal advice and AC, WP


3-33 1/26/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney, Documentrelated to litigation,

^3-34 1/17/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,



Q-1 10/16/01 NMC WL document concerning legal advice and AC, WP

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including confidential communicationsbetween client and attorney. Dncument

_'

related to Eitigation•4-Z 8/14/01 NMC WL Document concerning legal advice and

_

AC, WP

including cnnfdential communicationsbetween client and attorney. Document

. related to litigation.4-^ 4/5/01 NMC

_._WL ^ ^ Document concerning legal advice and AC, WP


^. related to litigation, __4-4 1/19/01 NMC WL Document concerning legal advice and AC, WP

Encluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

4-5 5/26/00

_NMC WL Document concerning legal advice and AC, WP

Including confidential communicationsbetween client and attorney, Documentrelated to Eitigation.

4-6 6/1/00 NMC WL Document concerning legal advice and AC, WPincluding cnnfidential communicationsbetween client and attorney. Documentrelated to litigation.

4-7 2/15/00 NMC WL Document concerning IegaE advice and AC, WP

including confidential communicationsbetween cilent^and attorney. Documentrelated to Eitigation.


49 12/13/99 NMC WL Document concerning legal advice and AC, WP

l^

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S-^ 4/17102 ^ NMC Wt, Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


.. _ related to litigation.5-3 8/28/00 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween c[ient and attorney. Documentreiaeed to litigation.

5-4 6/5/00 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigatian.

5-1 7/9/07. NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


6-3 3/2701 NMC WL Document concerning legal advice and AC, WPincluding Confidential communicationsbetween client and attorney. Documentrelated to litigation.

6-^€ 7/12/00 NMC WL boCUment concerning legal advice and AC, WP^

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_ related to iitigatian.6-S 4/11/00 NMC WL Document concerning legal advice and AC, WP


_ related to litigation.5-6 4/11/00 NMC WL Document concerning legal advice and AC, WP

includirg confidential communications. between client and attorney. Document

related to IitigaEion. _7-1 NMC Hd Document related to litigation. WP

7-2 NMC_

HO Document related to litigation. WP7-3 NMC HO Document related to litigation. WP7-4 NMC HO Document related to litigatian, WP

7-5 NMC HO Document related to litigation. WP

7-6 ^ NMC ti. HO Document related to litigation, _ WP7-7

_ .NMC

_HO Document related to litigation. WP


8-2 4/17/02 NMC WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to likigation. _

8-3 4/17/02 NMC WL Documenk concerning legal advice and AC, WP

including co^ofidential communicationsbetween client and attorney. Documentrelated to litigation.

8-4 NMC WE. Document concerning legal advice and AC, WP-T including confidential communications ^^

^ ^

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8-5 4/17/02 NMC WL Dacument concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

_ related to litigation.8-6 4/25/02 NMC WL Dacument concerning legal advice and AC, WP


! related to I'stigatian•9-1 NMC

_YPY Document related to litigation. WP

9-2 _ 12/14/01 NMC _ YPY^

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^ including confidential communicationsbetween client and attorney. Dacumentrelated to litigation.

-14-2 3/21/00 NMC W1_ Document concerning legal advice and AC, WP

^ including confidential communlcations3 between client and attorney. Dacument



__._ related to litigation.

10-4 11/10/99 NMC_

Wt Document concerning [egai advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated tv litigation.

10-5 9/28199 NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Dacumentrelated to litigation.

^ ^^ ^E^ ^

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`^tef Date ` • ^ ^ Authar(^s} _ . Reci,pient(s} Dirscription `Privilege{s}Claimed

10.6 9/26/99 NMC_

WL_

Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to [itigation.

10-7 9/24/99 NMC WL Document concerning legal advice and AC, WPincluding confiidential communicationsbetween client and attorney. Document

_ __ related to litigation.11-1 3/17/07 NMC

_WL

_Document concerning legal advice and

_AC, WP


13.-3 7/5/00 NMC WL ^ Document concerning legal advice and AC, WPincluding con#identiaE comrnunicatiansbetween client and attorney. Document

related to Eitlgatian.1f-4 7/1/00 NMC WL Document concerning legal advice and AC, WP

including con#idential communications• between client and attorney. Document



including confidential communicationsbetween client and attorney. Documentrelated to IiCsgation.


Z1-7 5/13/00 NMC WL Dacument concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney. Documentrelated to liti anon.

1

^ ^^ ^

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Ref : < :ate Auttlo^(s^ 'Recipient(s.) ::` ^ ^ !]escription' Privileges} ..Claimed

3.1-8 x/15/00 NMC_

WL Document concerning lega3 advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

17-9 2/10/nn NMC Trademark attorney Document related to litigation involving WPin Taiwan PricePlay

13.-9 1Z/31/99 NMC WL Document concerning legal advice and AC, WPincluding confdential communicationsbetween client and attorney. Documentrelated to litigation.

11-9 12/34/59 NMC WL nocument concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Document

_ _ _ related to litigation,11-3.0 11/to/99

_

NMC

__

WL_ _

Document concerning legal advice and

_

AC, WP


11-11 9/27/99 IyMC

_WL ^ Document concerning legal advice and AC, WP


^11-12 9/28/99 NMC WL Document concerning legal advice anti AC, WPincluding confidential communicationsbetween Client and attorney. Documentrelated to litigation.

12 6/14/99 SS WL, NMC Document Concerning legal advice and AC, WPinclud€ng confidential communicationsbetween client and attorney. Documentrelated to litigation.

13 Q6/10/1999 - WL, NMC, 55 WL, NMC, SS Document concerning legal advice and A/C, W/P, TPM

10/04/2002 including confidential communications

iti

.^

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Ref" Date ^ Author(s) ^ }^ectpienf( s] ^-^ Desci•Eption^ ^ Privilege(s)... -- - Claimed


^related to litigation.

14 06/14/1999 55 NMC ^ Document concerning legal advice and A/C, W/P, TPMincluding Confidential communicationsbetween client and attorney. Documentrelated to litigation.

15 06/28/1999 WL NMC Document concerning legal advice and A/C, W/P, TPMircluding confidential communicationsbetween client and attorneY• Documentrelated to litigation.

16 11/10/1999 NMC WL DQCUment concerning legal advice and A/C, W/P, TPM

including confidential eammunieationsbetween client and attorney, Document

_ _ _ related to litigation.-17 -1 5/7/02 NMC WL

_ _

Document Concerning legal advice and

_

AC, WP

including confidentia! communicationsbetween client and attorney. Documentrelated to litigation,

17-2 9/19/01 NMC WL Document concerning legal advice and AC, Wpincluding confidential communicationsbetween client and attorney. Documentrelated to iitigation.

17-3 8/21/01 NMC Wt Document concerning legal advice and AC, WPincluding confidential wmmunicatiansbetweers client and attorney . Documentrelated to litigation. _


I including confidential communicationsbetween Client and attorney. Documentrelated to litigation.

17-5 4/6/01 NMC WL Document concerning legal advice and AC, WPincluding confiderstial communications

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between client and attorney, Document_

__ related to litigation.17-6 3/20/01 NMC WL

_Document concerni^^ legal advice and

_AC, WP


17-7 9/28JD0 NMC WL Document concerning legal advice. and AC, WPincluding confidential communicationsbetween client and attorney. Document

__ related to litigation.7.7-5-9 6/5/OD NMC

^WL Document concerning legaE advice and AC, WP

including confidential communicationsbetween client and attorney , Document

_ related to litigation.17-10 4/24/00 NMG

_ _WL Document Concerning legal advice and

_

AC, WP




between cllent and attorney . Documentrelated to litigation.

17-13- 2/16/00 NMC Wl_ Document concerning legal advice and AC, WP

15 including confidential communicationsbetween client and attorney.l7ocumenirelated to litigation.

17-16- 1/17/DO NMC WL Document concerning legs! advice and AC, WP19 including confidential communications


17-20 12/29/99 NMC WL Document concerning legal advice and AC, WPIncluding confidential communications

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^ ^^ ^^ ^

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Authdr (s}•. .

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,: ...'Cla irned


related to litigation,18-1 9/10/Q1 NMC WL

_Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

18-2 4/23/07. NMC WL Document concerning legal advice and AC, WPinduding confidential communicationsbetween client and attorney. Document

- related to litigation.18-3 4/6/pl NMC WL Document concerning legal advice and AC, WP

including confidential communicationsbetween client and attorney , Documentrelated to litigation.

18-4-5 1].16/00 NMC WL Document concerning legal advice and AC, WP


1$-6-7 3/13/Qi] NMC WL Document cancernina Isgal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

18-8- 2/16/Oq NMC WL_

Document concerning legal advice and AC, WP11 including confidential communications


18-12- 1/2fi/00 NMC WL Document concerning legal advice and AC, WP14 including confidential communications

between client and attorney. Documentrelated tv litigation.

18-15- 12/6/99 NMC WL Document concerning legal advice and AC, WPt^ including confidential communications

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Ref ' Date ':. A^uthor(sj :• ^ Reciplent^s ). ^ .....

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39 12/13/1999 - NMC^

WL Document concerning legal advice and A/C, W/1', ^'PM01/17/2002 including confidential communications


21 12/13/1999 NMC N/A Document re€ated to litigation. W/P, TPM22 32/14/3999 NMC T WL Document concerning legal advice and A/C, W/P, TPM

lndud 'sng confidential communicationsbetween , client and attorney . Documentrelated to litigation.

23-1 9/10/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsBetween client and attorney. 1ocumentrelated to litigation.

23-2 4/23/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween cliern and attorney . Documentrelated to litigation.

23-3 4/6/01 NMC Wl. Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Document

_ __ related to litigation, __23-g-5 11/6/00 -^ NMC WL Document concerning legal advice and A/C, W/P, TPM


_^._ related to [itigation.

23-5-7 3/13/00 NMC_

WL Document concerning legal advice and A/C, W/P, TPM' including confidential communications

between client and attorney , Documentre€ated to litigation.

23-8 3/3/04 ^- J NMC^.

WL Document concerning legal advice and A/C, W/P, TPM

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including confidential communicat€onsI between client and attorney. Document

related to litigation.23-9- 2/],6/00 NMC

_W!. Document concerning legal advice and A/C, W/P, TPM

11 including confidential communications


23-1.2- 1/26/00 NMC WL Dacument concerning legal advice and A/C, W/P, TPM14 inciuding con#idential communicatians


24-1 1129/01 NMC WL Document concerning legal advice and A/C, W/P, TPMincludingconfidentlal communicationsbetween client and attorney. Document

_ reiated to litigation.Z4-2 11/30/00 NMC WL Document concerning legal advice and A/C, W/P, TPM


24-3-4 615/00NMC _____-.....

WL Document concerning legai advice and A/C, W/P, TPMincluding confidential communicatiansbetween client and attorney, Documentrelated to litigation. _

24-5 3/23/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Dacumentrelated to litigation.

24_6-7 3/13/00 NMC WL Document concerning legal advice and A/C, W/P, TPM'sncluding canfidentiai Communicationsbetween client and attorney. Dacumentrelated to litigation,

24-8-10 2/x6/00 NMC WL Dacument concerning legal advice and A/C, W/P, TPM _^

,^

,^^ ,

["^ ^

itef. ^.^^^ DaCe AU41ior(s} ^'. liecipient{s) ^ . ^ Description ^ Y Privilege{s).... Claimed.

including confidential communicationsbetween client and attorieey. Documentrelated to litigation.

24-11-13 2/9/00 NMC WL Document concerning legal advice and A/C, W/P, TPMinc€uding confidential communicationsbetween G[ient and attorney. Documentrelated to litigation.

24-14-15 2/5/Otl NMC WL Document concerning legal advice and A/C, W/P, 7PMincluding confidential communicationsbetween client and attorney. Document

___ related to litigation. _24-16 2/5/04

_

NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to lltlgatlon.

25-1 9/26/02 1VMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

^25-Z 7/9/01 NMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney, Document

_ related to lltlgatlon.

25-3 3/Z/Ol NMC ^ WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

25-Q 7/1x/00 NMC WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

Z5-S 4/17./00 NMC WL Document concerning legal advice and AC, WP, 7PM

_,

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25-6-7 3/13/00 NMC WL Document concerning legal advice and AC, WP, 7PMincluding confidential communicationsbetween client and attomey. Documentre#ated to litigation.

25-$ ,10/$/02 NMC Jfi, WL Document concerning legal advice and AC, WP, TPMincluding confidential communicationsbetween client and attorney. Document

_ related to litigation,26-1 9/27/02 NMC 1T, WL Document concerning legal advice and

__ _

AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

26-2-3 9/26/07. NMC JT, WL Document concerning legal advice and AC, WPincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

26-4 7/2/01 HQ NMC Document related to litigation. WP26-5 3/2/01 Ji' NMC Document related to litigation. WP26-6-7 2/28/01 NMC HO Document related to litigation. WP26-8-4 7/12/00 NMC HO Document related to litigation, WPZ6-10- 7/4/00 HO NMC Document related to litigation. WP1S

26-12- 7/5/00 Hp NMC Document related to litigation. WP14

6-i5- . 6/22/00 HO NMC Document related to litigation. WP6 _^6-17- 6/z1/^ NMC HO

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$6-19- 6/21/00

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--`-26-17- 6/21/00 NMC I-10 Document related to litigation. WP1&

27-1 9/26/07_ NMC WL Document concerning Eegal advice and A/C, W/P, TPMincluding confidenti :.: _ommunicatiansbetween client and attorney. Documentrelated to litigation.

27-2 S/21/01 NMC_

WL T Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

27-3-4 1 11/14/01 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

I related to litigation.27-5 S/2/01 NMC WL Document concerning legal advice and A/C, WJP, TPM


27.6 11/13/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicat'r'onsbetween client and attorney. Documentrelated to litigation,

27-7 10/16/00 NMC WL Document concerning legal advice and_

A/C, W/P, T'PMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

' 27-8 9/12/00 NMC WL Document concerning legal advice and A/C, W/P, TPM^ including confidential communications^ between c€ient and attorney . Document^ _ related to litigation.

^Z7-9 5/30/00 NMC WL Document concerning legal advice and A/C, W/P, TPM

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Ref :? Date '^' Author{sJ Rec 's^pient ( s) ^.^ ^-^^ Description ^ Rriv^lege(s) ... .. ,. .. ^.^ _ CJaimed^^:.... ._

includin ronfldeniial communicationsbetween client and attorney , Documentrelated to litigation.

27-10 5/16/00 WL NMC Document concerning Icgal advice and A /C, W/i^, 7PM,including confidential communicationsbetween client and attorney. Documentrelated to litigation. .

28-1 10/4/OZ NMC WL Document concerning legal advice and A/C, W/P, TpMincluding confidential communicationsbetween client and attorney. Dacurnent

' _ related to litigation.28-2 9/30/02

_ _NMC WL Document concernint; legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney . Documentrelated to ]itigatian.

28-3 9/28/02_

NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential comnlunitationsbetween client and attorney . Documentrelated to litigat'san.

28-4 4/17/02 NMC WL Document concerning legal advice and A/C, WJP, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

28-5 8/13/01 NMC WL Document concerning legal advice and A/C, W/P, FPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

Z8-6 8/28/00 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.


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Y . _ related tv litigation,2i3,$ 5/31/00 NMC WL Document concerning legal advice and A/C, W/P, TPM


29-1 9/13/00 NMC WL Document concerning legal advice and ACincluding cvrsfidential communications

^ between client and attorney.Z9-2 4/13/00 NMC WL

_Document concerning legal advice and ACincluding con#idential communicationsbetween client and attorney.

30-1 10/13/04 Honesty & Patent PJE__

Document related to litigation, WP30-z 10/11/04 Honesty & Patent PJE Document related to litigation, WP303 10/13/04 PJE Honesty & Patent Document related to litigation, WP30-4 10/6/04 5e-Chang Kang, NMC Document related to litigation. WP

Korean patentCounsel

30-5 10/19/02 NMC YPY Document related to litigation. WP30-5-7 10/18/02 NMC YPY, WL Document concerning legal advice and WP


30-8-9 10/17/02 NMC YPY, WL Document concerning legal advice and ACincluding confidential communicationsbetween client and attorney, Documentrelated to litigation,

34-10- 20/17/02 YPY NMC Document related to litigation, WP11

30-12- 9/25/02 NMC YPY, WL Document concerning legal advice and AC, WP13 including confidential communications

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•itef Date ^°,. Author(s) ^ • ^ Recipient(s) ^ >]escription^ ^ Prlvilege(s} .. .. ^ Claimed .


30-14 7/x9/02 YPY NMC

__Document related to lirigation. WP

30-15 7/7.9/02 YPY NMC __ Document related td litigation. __

WP30-16 4/17/02 YPY T NMC Document related to litigation.

__

WP -

30-17- 12/29/01 YPY NMC Document related to litigation. WP19

30-20- 12/26/01 Honest & Patent_ NMC' Document related to litigation.^

WP30-21 1x/25/01

__YPY NMCi Document related to litigation. WP

30-22- 12/24/01 NMC YPY Documentrefatedtofitigatlan._

WPZ330-24 12/14/01 NMC YPY Document related to Iltigation. _

RWP

30-25• 12/14/07._

NMC^

YPY_

Document related to litigation. A WP2&

30-27- IZJ9/01 NMC YPY Document related to litigation. WP3230-33- 11/15/01 YPY NMC Document related to litigation, WP

3430-35- 13/15/01 YPY NMC Document related to litigation. WP

37 . .30-38 11/14/01

_.NMC

__Honest & Patent Document related to litigation. WP

30-39- 11/1/01 Honest & Patent NMC Document related to litigation. WP

40 -^31-1 10/4/02 NMC

-Wl Document concerning legal advice and A/C, W/P, TPM


31-Z 9/30/02 NMC Wl. Document concerning legs! advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document irelated to Iltigation.

31.3 9/26/02 NMC WL Document concerning legal advice and A/C, W/P, TPM

:.^

t

1

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including confidential communicationsbetween client and attorney. Document Irelated to litigation,

31-4 9/17/02 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. qowmentrelated to litigation.

31=5 8/13/01 NMC Wi Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

^. related to litigation. _ _31-6 8/28/00 NMC WL Document concerning legs[ advice and A/C, W/P, TPM

including confidential communicationsk^etween client and attorney. Documentrelated to litigation. _

31 -7 10/4/02 NMC WL ^ Document concerning legal advice and

_

A/C, W/P, TPM


31-$ 6/5/02 NMC WL Document concerning fegai advice and A/C, W/P, rPMincluding confidential communicationsbetween client and atiarney. Document


31-5 5/31/07. NMC WI_ Document concerning legal advice and A/C, W/P, TPMincluding Confidential communicationsbetween client and attorney, Documentrelated to liti anon.

32 10/29/2002 NMC WL Document concerning legal advice and A/C, W/P, TpM


33 12/27/2002 NMC W[. Documen# concerning legal advice and A/C, W/p, TPM

^ X^ ""^""'

^ ^

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1

^Ref^. ^ ^^ Date ' ^ ^ Author (sj Rec^pierit( s^.^ Uescriptidn : ^^ ^ ^ Ri•ivifege(sJ.. .` Cla^mecE^_ _


_ related to litigation.34 06/12/2003 NMC WL Document concerning legal^advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney . Document

_ _ refated to litigation,35 07/22/2003 WL NMC

_Document concerning legal advice and A/C, W/P, TPMincluding confidential communieat'sonsbetween client and attorney , Document

_^ refated to litigation,36 12/02/2044 NMC WL ^ Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney . Documentrefated to litigation,

37 12/03/2004 NMC, WL WL, NMC Document concerning legal advice and A/C, LN/P, TPMincluding confidential communicationsbetween client and attorney. Documentrefated to litigation.

38 12/03/2004 WL NMC . Document concerning legal advice and A/C, W/P, TPMincluding confidential communications

_ between client and attorney. Documentrelated to litigation.

39 12/03/2004 NMC, WL WL, MC Oacument concerning legal advice and A/C, W/P, TAMincluding con€idential communicationsbetween client and attorney. Documentrelated to litigation.

40 12/13/2004 NMC WL Document concerning legal advice and Af C, W/P, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

41 09/17/x005- NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM

i

i

^ ^

Ref ^ ^ :• pate ^ . Author(s) Recipient (s) description Privilege (s) ^ . -.I

Clamed - ^09/20/2005 including Confidential communications

.


42 09/17/2005- NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPM09/23/2005 including confidential communications

i between client and attorney. Documentrelated to litigation.

43 10/06/2005 NMC N/A Document related to litigation . W/P, FPM44 } 12/20/2005 WL

_NMC Document concerning legal advice and A/C, W/P, TPM


45 1 1Z/22/Z005 NMC, WL WL, NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

i related to litigation.46 ^ 02/02/2006 NMC WL Document =oncerning legal advice and A/C, W/P, TPM

including confidentia! communicationsbetween client and attorney. Documentrelated to litigation.

47 OZ/08/2006 NMC, WL_

WL, NMC_

Document concerning legal advice and A/C, W/P, TAMinc€uding confidential communicationsbetween client and attorney. Oacumentrelated to litigation.

4&1 3/3/07 NMC WL Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney, Document

^_ _ _`___ related to litigation.48-2 2/26/07 NMC WL pacument concerning legal advice and A/C, W/P

including confidentia! communicationsbetween client and attorney. Documentrelated to litigation.

°^ m

!^ ^

€^ ^

t ^^

V

Ref . Aate . Author(s) Recipient (s) Description ` .. ^ Prlvllege^s}.,;.:....... ^ Claimed

4$-3 2/Z6/07 NMC WL Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Document

u _ related to litigation.49.1 2J2b/07 ^ WL NMC Document concerning legal advice and A/C, W/P


_ related to Ittigation. _49-2 2/26/07 WL .NMC Document concerning legal advice and

__

A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated tolitigation. -

49-3 2/2b/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween silent and attorney. Documentrelated to litigation.

50-1 2/27/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

50-2 2/27/07 WL NMC bacument concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated tolitigation.

SO-3 i 2/27/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney, Documentrelated tolitigation.

5^ 02/27/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


s

°°^^

^ ^

Ref ^ D^t'E^^ ^ ^ ^Authar(s) Recipient ( s) ^ ^ Description. `Privilege(s) T ^^^. - : ' .. ..^ : , ^ Claimed

sx 03JDZ/x007 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney, Documentrelated to litigation.

53 03/05/x007 WL NMC Document ronrerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

5^4 03/Q6/2007 WL NMC_ _

Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

55 03/06/2007 NMC_

WL Document concerning legal advice and .A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

related to litigation. _

56 03/07/2007 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

57 03/Q7/x007 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

related to litigation.58 03/11/x007 NMC WL, VI.S Document concerning legal advice and A/C, WJP, TPM


59-1 3/13/07 WL NMC Document concerning legal advice and A/C, W/P ,

including confidential communications •.between client and attorney, Documentrelated to litigation.

a^'^

^` ^

i^ ^

. Ref ^ bate ..^

Author(s). ,...,

^ Retip^ent ( s^' _ ..Description 'Atiy^lege(s}`:..

,^

.. ,... GlaE^ned^: ..

59-2 3/3.3/07 WL NMC Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated to litigation,

50-1 3/13/07 NMC WL Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Documentrelated to litigation. _

50-2 3/13/07 NMC WL

_Document concerning legal advice and A/C, W/P


61-1 3/17/07 NMC WL, VLS Document concerning legal advice and A/C, W/Pincluding confidential communicationsbetween client and attorney. Document

w -^related to litigation.

61-2 3/17/07 NMC WL, VL5 Document concerning legal advice and A/C, W/P

including confidential communicationsbetween client and attorney. pocument

_ related to litigation.62 43/17/Z007 WL NMC Document concerning legal advice and A/C, W/P, TPM

' including confidential communicationsbetween client and attorney, Document


63 03/17/2007 WL NMC, VLS Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

54 43/17/2007 NMC WL Document concerning legal advlCe and A/C, W/P, TPM


,^

' Ref ^ .^ ^ Date ', Author,'(s^^^^ Recipient {s^ , Description =, ^ Privilege{sJ

65 03/S7/2007 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

66 03/20/2007 WL NMC, VI_S Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

__ related to litigation.67 03J20/2007 NMC WL Document concerning legal advice and

_A/C, W/P, TPM

including Confidential communicationsbetween client and attorney. Documentrelated to litigation.

68 43/21/2.007 WL NMC, VL5 Document concerning legal advice and A/C, W/P, TPM


69 03/26/2007 iVMC WL, VLS Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

70 03/26/2007 WL NMC, VL5 Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney. Documentrelated to Eitigation,

71 03/28/2007 WL NMC, VL5 Document concerning legal advice and A/C, W/P, TPMinc€uding confidentia € communicationsbetween client and attorney . Document

' re{ated to litigation.72 03/29/2007 JLL NMC Document related to litigation . W/P, TPM74 03/30/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


r--^-^4

.^ ^ ]

.^

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itl

Ref ^:^^ ^,...Uate ^ ^ AdtE^or(s) Recipient (s).: D.escrlptinn Privilege(s) ^: .

Claimed; ._related to litigation.

^

75 03/30/2007 NMC WL, VL5 Document cancerning legal advice and_A/C, W/P, TPM


76 03/30/x007 WL NMC, VLS Document cancerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Documentrelated to litigation.

77 03/30/2007 NMC WL, VLS, JLL Document concerning legal advice and A/C, W/P, TPM€nclud 'sng confidential communicationsbetween client and attorney. pacumentrelated to litigation.

78 03/30/2007 WL NMC, VLS, JLL.

_Document cancerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

79 03/30/x007 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney . Document

___ related to litigation.80 03/30/2007 NMC VLS, JLL Document related to litigation . W/P, TPM82 05/01/2007 WL NMC Document concerning legal advice and A/C, W/P, TPM

including confidential communications1}etween client and attorney . Documentrelated to litigation.

^83 05/01/2007 NMC WL_

Document concerning legal advice and A/C, W /P, TPMincluding confidential communications

^ between client and attorney . Document


84 OS /03/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM^ including confidential communications

^ ^f;"^ ^

i

^ 1

' Ref :' ':^nate Author (s) ^^ ^ Re[ipient ( sj; Description Pri^ilege(sj

. ., ^ . : .

between client and attorney, Document

related to litigation.85 05/09/Z007 WL NMC Document concern "sng legal advice and A/C, W/P, TPM

including confidentia€ communicationsbetween client and attorney . Rocumentrelated to l itigation.

$5 05/18/2007 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and ..t^arney. Dacumentrelated to litigation.

87 07/04/Z007 NMC WL Rocument concerning legal advice and A/C, W/P, TPMincluding confidentiaE communicationsbetween client and attorney . Document

_ related to litigation.__88 10/02 /2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


84 10/D2/2007 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential comrnunlcationsbetween client and attorney . Documentrelated to litigation,

9D 10/03/2007 WL NMC pocument concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Documentrelated to litigation.

9J, 1D/05/2007 NMC WL Document concerning legal advice and A/C, W/P, TPMIncluding confidential communicationsBetween client and attorney . Rocumentrelated to litigation.

92 10/05/2007 WL NMC Document concerning legal advice and A/C, W/P, TPMincluding confidential communications

Ref Date Author (s) • ^ Recipient(s) D"escription. ^ Priwiege{s). ...

''.Claimedbetween client and attorney . Documentrelated to litigation.

93 1Z/17/2007 NMC WL Document concerning legal advice and A/C, W/P, TPM


94 06/11/Z 008 WL NMC Document concerning legal advice and A/C, W/P, TPM


95 06/14/20D8 NMC WL Document concerning legal advice and A/C, W/P, TPMincluding confidential communicationsbetween client and attorney. Document

_ related to €itigatian.

95 10/26/Z008 Christin Ciao NMC Document concerning legal advice and A/C, W/P, TPM

including confidential communicationsbetween client and attorney . Documentrelated to litigation•

97 10/Z7/Z008 WL NMC Document concerning legal advice and A/C, W/P, TPM


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