Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 1 of 9 PageID #: 51322
`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 1 of 9 PagelD #: 51322
`
`EXHIBIT 2
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 2 of 9 PageID #: 51323
`
`From:
`Sent:
`To:
`
`Cc:
`
`Subject:
`Attachments:
`
`John Lahad <jlahad@SusmanGodfrey.com>
`Sunday, April 23, 2023 10:55 PM
`Unikel, Robert; Kalpana Srinivasan; Failla, Melissa J.; Max Straus; Seth Ard; Rachel Solis;
`Kemper Diehl; Richard Wojtczak; dtaylor@skjlaw.com; nbelgam@skjlaw.com;
`smb@skjlaw.com
`Hamlin, Shannon J.; vinny.ling@mto.com; Palapura, Bindu A.; Moore, David E.;
`ginger.anders@mto.com; Google-Arendi; Susan M. Betts; Neal C. Belgam
`[EXT] RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`2023-04-23 Proposed Stip .docx
`
`** This email originated from outside of Potter Anderson’s network. Please exercise caution before clicking links,
`opening attachments, or responding to this message. **
`
`
`
`Rob:
`The proposal you sent does not work. It is inaccurate in some places, overly argumentative in
`others, and raises legal points. We think the goal of the stipulation is to be a replacement for the
`documents (eg petition, institution decision, etc) and should provide a sufficiently fulsome
`recitation of the facts. Your proposal does not do that. Attached is a proposed stipulation that
`states just facts. If you think something in this is not a fact, let us know.
`
`As to the limiting instruction, we don’t think one is necessary at this time. Any instructions can be
`incorporated into the final jury instructions.
`
`Thank you.
`
`John P. Lahad
`Partner |Susman Godfrey LLP
`Houston | New York | Los Angeles |Seattle
`713.653.7859 (o) 713.725.3557 (m)
`
`From: Unikel, Robert <robertunikel@paulhastings.com>
`Sent: Sunday, April 23, 2023 8:59 PM
`To: Kalpana Srinivasan <ksrinivasan@SusmanGodfrey.com>; John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa
`J. <melissafailla@paulhastings.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`EXTERNAL Email
`
`1
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 3 of 9 PageID #: 51324
`
`Arendi Team,
`Sorry to press, but it is getting pretty late. When can we expect your response on my email and compromise proposal
`below? Thanks.
`
`Rob
`
`
`From: Unikel, Robert
`Sent: Sunday, April 23, 2023 7:36 PM
`To: 'Kalpana Srinivasan' <ksrinivasan@SusmanGodfrey.com>; John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa
`J. <melissafailla@paulhastings.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`Kalpana,
`
`We continue to believe that the only correct course is for the parties to agree, or the Court to order, that the parties will
`not present any evidence, testimony or argument concerning the IPR proceedings to the jury. In light of the absence of
`any invalidity ground based on Pandit, there is no relevance to those proceedings in this case, and no justification for
`introducing such confusing and unduly prejudicial materials to the jury. If Arendi does not so agree, then we currently
`plan to ask for an appropriate order from the Court.
`
`Should the Court disagree and allow some mention of the IPR proceedings to the jury, then we agree with you that the
`only way to at least partially minimize the prejudice and error is to present the IPR proceedings through a neutral and
`balanced stipulation and limiting instruction. Attached is Google’s counterproposal to Arendi’s proposed stipulation and
`limiting jury instruction regarding evidence relating to IPRs. It includes some of Arendi’s proposed language combined
`with Google’s in what we hope is a fair compromise that would minimize jury confusion and potential prejudice at
`trial. If we can agree on the language of the stipulation and proposed limiting instruction, and can agree that (1) the
`Court would read and/or provide a hard copy of the stipulation to the jury when one of the parties first asks for it at a
`relevant time during trial; and (2) the parties would not introduce any other evidence regarding the IPR to the jury or
`make any arguments that contradict the stipulation to the jury, then Google likely will agree not to proceed with its
`planned motion.
`
`Please let us know by 9:30 pm tonight if Arendi accepts this compromise.
`
`I’ll note that Arendi’s proposal in the limiting instruction that the jury could consider the IPR evidence to determine
`whether “Google has persuaded you by clear and convincing evidence that the Asserted Claims of the ’843 Patent are
`invalid” without sufficient guardrails about the differences and limitations with IPR is particularly problematic. We all
`know that is an incomplete and misleading instruction and highly prejudicial, and it demonstrates once again that Arendi
`is trying to present IPR evidence to the jury for improper purposes.
`
`Rob
`
`
`
`
`
`2
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 4 of 9 PageID #: 51325
`
`From: Kalpana Srinivasan <ksrinivasan@SusmanGodfrey.com>
`Sent: Sunday, April 23, 2023 3:20 PM
`To: Unikel, Robert <robertunikel@paulhastings.com>; John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa J.
`<melissafailla@paulhastings.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: [EXT] RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`
`--- External Email ---
`
`
`
`Rob – Your proposal is based on the incorrect premise that the IPR evidence is
`permissible only if Google wants to use it. Google has already conceded that IPR
`evidence is relevant in its filing to the Court Thursday night as it intended to use that
`evidence to argue about its beliefs regarding invalidity as a defense to
`willfulness. Google included exhibits from the IPR proceeding on its exhibit list. But
`now Google suddenly says the jury will be confused even though Google intended to
`rely on the IPR proceedings as of a few days ago. Pandit doesn’t change the equation
`– and only highlights that Google wanted to use the IPR proceedings to shore up its
`invalidity position in this case. Google’s one-sided position is wrong.
`
`
`As we already said, IPRs are relevant not solely to defend against willfulness but to
`rebut any defense of willfulness and the IPRs are also relevant to other issues which
`we have identified in our letter to the Court.
`
`
`As you requested on our call last night, we attach a proposed Stipulation and Limiting
`Instruction that is edited from what you sent us earlier this week. In light of the
`foregoing, please let us know if Google agrees.
`
`Kalpana
`
`From: Unikel, Robert <robertunikel@paulhastings.com>
`Sent: Sunday, April 23, 2023 6:26 AM
`To: John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana Srinivasan
`<ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`
`3
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 5 of 9 PageID #: 51326
`
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`EXTERNAL Email
`Arendi Team,
`I know you are planning to send us today your proposal for how to deal with the IPR proceedings issues at trial. As I
`mentioned yesterday (by email and on our call), we believe that with the removal of Pandit from the invalidity grounds
`there is not even an arguable basis for presenting the IPR proceedings to the jury.
`
`In case it was not clear from our call, Google will not be presenting the Pandit reference, or any obviousness
`combinations including the Pandit reference, at trial. Further, as indicated on our call, because presentation of the IPR
`proceedings to the jury will only confuse the jurors and taint the proceedings, Google has no intention of affirmatively
`introducing the IPR proceedings to the jury.
`
`In light of the foregoing, it seems that the correct and simplest path forward would be to jointly agree that the parties
`will not present any evidence, testimony or argument concerning the IPR proceedings to the jury. Such agreement will
`also allow us to eliminate one additional dispute for the Judge to resolve, which I am certain she will appreciate.
`
`Please let us know if Arendi agrees.
`
`Rob
`
`
`From: John Lahad <jlahad@SusmanGodfrey.com>
`Sent: Saturday, April 22, 2023 12:08 PM
`To: Unikel, Robert <robertunikel@paulhastings.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana
`Srinivasan <ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: [EXT] RE: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`
`--- External Email ---
`
`
`
`Rob
`Thanks for this. We decline your proposal re Pandit/IPR, and we disagree with your implication
`that IPRs may be used only to defend against a claim of willfulness. It is clear from even Google’s
`proposed jury instruction that is not the case. Beyond that, we refer to the letter we filed with
`respect to other reasons the IPRs remain relevant. Google never sought to move in limine on use
`of the IPRs before this point – and intended to explicitly rely on them. We oppose.
`
`Regarding willfulness, nothing has changed since yesterday. Moving the date of first infringement
`forward does not change the inquiry of willfulness under the law and the proposed instructions as
`to what Google knew when it released STS and whether its conduct was willful. Your argument,
`4
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 6 of 9 PageID #: 51327
`
`with which we disagree, would equally have applied to content detectors and contextual search
`quick actions technology. This is the first time you have raised this position (even though you could
`have long ago).
`
`We will not be dropping our willfulness case. We are available to confer, if needed.
`
`Thanks
`
`
`
`John P. Lahad
`Partner |Susman Godfrey LLP
`Houston | New York | Los Angeles |Seattle
`713.653.7859 (o) 713.725.3557 (m)
`
`From: Unikel, Robert <robertunikel@paulhastings.com>
`Sent: Saturday, April 22, 2023 7:18 AM
`To: John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana Srinivasan
`<ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: Invalidity Grounds, IPR Proceedings Issue and Wilfullness
`
`EXTERNAL Email
`Arendi team,
`As per the Court’s directive, and based and conditioned on the assumption that we are able to present the CyberDesk
`System at trial (as preliminarily indicated by the Judge), then we disclose the following invalidity grounds that Google
`will present at trial.
`
`Anticipation based on CyberDesk
`Obviousness based on CyberDesk + Apple Data Detectors; CyberDesk + Microsoft Word 97; Apple Data Detectors +
`Word 97; and Pandit + CyberDesk and Pandit + Apple data detectors (subject to proposal below).
`
`We are willing to remove, and not present at trial, the two obviousness combinations based on Pandit – Pandit +
`CyberDesk and Pandit + Apple Data Detectors – if, and only if, the parties agree that no evidence, argument or testimony
`will be presented to the jury concerning the IPR proceedings (including any and all aspects of those proceedings and the
`related appeals). Please advise by noon today, Saturday, whether we have an agreement on this; or we will need to
`find another path to provide the Court (either together or separately) with potential options for addressing the juror
`confusion and potential error that is likely to result if the IPR proceedings are introduced at trial.
`
`Separately, now that you have dropped all infringement claims as to Chrome using Content Detectors and Quick Actions,
`we assume that Arendi will be dropping its post-complaint willfulness allegation as well. Suit was filed in 2013 and there
`is now no product accused of infringing from the date of filing until end of 2017. More importantly, STS – the only
`accused functionality left in the suit – was not even first accused of infringement by Arendi until after the ‘843 Patent
`had expired. Thus, any willfulness charge is without a reasonable basis. Please confirm that you will no longer be
`
`5
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 7 of 9 PageID #: 51328
`
`proceeding on willfulness. If you are, please explain the basis for that charge in light of the new contours of your
`infringement claim.
`
`Rob
`
`
`From: John Lahad <jlahad@SusmanGodfrey.com>
`Sent: Friday, April 21, 2023 10:53 PM
`To: Unikel, Robert <robertunikel@paulhastings.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana
`Srinivasan <ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: [EXT] RE: Meet and Confer Concerning IPR Proceedings Issue
`
`
`--- External Email ---
`
`
`
`Rob-
`Confirmed as to CD and CSQA.
`
`Arendi will present a total damages figure of $45.5 million at trial.
`
`
`This is reached by taking Exhibits 1B and 2B to Mr. Weinstein’s supplemental reply report and
`excluding (i) all units of the News app; (ii) units of the Chrome app from before August 21, 2017;
`and (iii) all Pixel 1 / Pixel XL units.
`
`
`These exhibits are re-attached here for convenience. The units now being excluded from the
`damages figure are highlighted. The Chrome units for 2017 are pro-rated in the same manner as
`the other apps, such that the accused Chrome units in 2017 are now 38,482,216.
`
`Thank you.
`
`John P. Lahad
`Partner |Susman Godfrey LLP
`Houston | New York | Los Angeles |Seattle
`713.653.7859 (o) 713.725.3557 (m)
`
`From: Unikel, Robert <robertunikel@paulhastings.com>
`Sent: Friday, April 21, 2023 8:03 PM
`To: John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana Srinivasan
`<ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`6
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 8 of 9 PageID #: 51329
`
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: RE: Meet and Confer Concerning IPR Proceedings Issue
`
`EXTERNAL Email
`John,
`At the end of our call a bit ago, you stated that Arendi is dropping it infringement claim against Chrome using Content
`Detectors and Contextual Search Quick Actions. Please confirm that this is correct by reply email ASAP.
`
`When I asked you what Arendi’s new damages demand is, you did not have a number readily available, but promised to
`send that number, along with your method of calculating that number, tonight so that we can consider the impact of
`this withdrawal on the case.
`
`Rob
`
`
`
`From: John Lahad <jlahad@SusmanGodfrey.com>
`Sent: Friday, April 21, 2023 6:33 PM
`To: Unikel, Robert <robertunikel@paulhastings.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana
`Srinivasan <ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: [EXT] RE: Meet and Confer Concerning IPR Proceedings Issue
`
`
`--- External Email ---
`
`
`
`How about 8 pm eastern? Can you circulate a dial-in please?
`
`
`John P. Lahad
`Partner |Susman Godfrey LLP
`Houston | New York | Los Angeles |Seattle
`713.653.7859 (o) 713.725.3557 (m)
`
`From: Unikel, Robert <robertunikel@paulhastings.com>
`Sent: Friday, April 21, 2023 4:42 PM
`To: John Lahad <jlahad@SusmanGodfrey.com>; Failla, Melissa J. <melissafailla@paulhastings.com>; Kalpana Srinivasan
`<ksrinivasan@SusmanGodfrey.com>; Max Straus <MStraus@susmangodfrey.com>; Seth Ard
`<sard@susmangodfrey.com>; Rachel Solis <RSolis@susmangodfrey.com>; Kemper Diehl
`7
`
`

`

`Case 1:13-cv-00919-JLH Document 489-2 Filed 04/25/23 Page 9 of 9 PageID #: 51330
`
`<KDiehl@susmangodfrey.com>; Richard Wojtczak <rwojtczak@susmangodfrey.com>; dtaylor@skjlaw.com;
`nbelgam@skjlaw.com; smb@skjlaw.com
`Cc: shamlin@Potteranderson.com; vinny.ling@mto.com; bpalapura@potteranderson.com;
`dmoore@potteranderson.com; ginger.anders@mto.com; Google-Arendi <Google-Arendi@paulhastings.com>; Susan M.
`Betts <SMB@skjlaw.com>; Neal C. Belgam <NCB@skjlaw.com>
`Subject: Meet and Confer Concerning IPR Proceedings Issue
`
`EXTERNAL Email
`
`Arendi team,
`
`Per the Court’s instruction, we would like to schedule a meet and confer call with you tonight to discuss
`potential paths to resolve the IPR proceedings issue. Please let us know when you are available.
`
`Thanks,
`
`Rob
`
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`and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com.
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`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
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`If you reply to this message, Paul Hastings may collect personal information including your name, business name
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`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.
`If you reply to this message, Paul Hastings may collect personal information including your name, business name
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`8
`
`