Free Letter - District Court of Delaware - Delaware

Case 1:06-cv-00414-SLR Document 52 Filed 10/25/2007 Paget of 2
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October 25, .2007
VIA EJFILIN G
The Honorable Sue L, Robinson
United States District Court
District of Delaware
844 King Street _
Wilrnington, DE l980l l
Re: Oracle Corp. v. epicReain1 Licensing, L.P., Case N0. 06-414-SLR
QuinStreet, Inc. v. epicRealm Licensing, LJ)., Case No. 06~—495—SLR
Dear Judge Robinson:
QuinStreet writes this letter to briefly outline the pending motions and discovery disputes
between QuinStreet and Oracle and epicRealm in anticipation of next Monday’s hearing.
With respect to QuinStreet’s Motion for Leave:
QuinStreet’s Revised Motion for Leave to File Amended Comglaint. This motion is
now fully briefed and the parties can address any issues the Court may have pertaining to the
motion.
With respect to epicRealm:
egieRealn1’s Response to Qui11Street’s Proposal For Staged Discovery or
Bifurcation. This Court previously ordered a first stage of discovery requiring QuinStreet to
produce configuration files and source code for its tive identified software platforms by
October 15, 2007. All such materials in QuinStreet’s possession have been ]D1"OClLlC€Ci to
epicRealn1.
QuinStreet realizes that even given its production that epicReal1n is not prepared to
identify which platforms it accuses or to state why under the allegations of its counterclaimr
In order to avoid the issue of "who goes first" as this Court previously did by ordering a
tirst stage of production, QuinStreet has proposed that discovery be further staged to complete
intiingernent discovery before proceeding with damages discovery
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Case 1:06-cv-00414-SLR Document 52 Filed 10/25/2007 Page 2 of 2
The Honorable Sue L. Robinson
October 25, .2007
Page 2
egicRcalm’s Production of Documents to QuinStreet. As of the date document
production was due, epicliealm had not produced any requested documents to QuinStreet.
e]gicRealm’s Response to interrogatories of QuinStreet. Epicllealm has not provided
full and complete interrogatory answers including its contentions of infringement.
Respectfully,
Anne Shea Gaza
(#4093)
ASG/afg
cc: Richard L. Horwitz, Esquire (via electronic mail and e—tiling)
Larry D. Carlson, Esquire (via electronic mail)
Mary B, Graham, Esquire (via electronic mail and e—tiling)
James G, Gilliland, Esquire (via electronic mail)
Robert Beiser, Esquire (via electronic mail)
Ludwig Kolman, Esquire (via electronic mail)
David Doyle, Esquire (via electronic mail)
J eflrey L. Moyer, Esquire (via electronic mail)
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