`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Michelle Callaghan <michelle.callaghan@eriseip.com>
`Thursday, March 15, 2018 8:46 AM
`Becker, Robert
`Stephenson, Faye; eric.buresh@eriseip.com; paul.hart@eriseip.com; sgh@hkw-law.com;
`md@hkw-law.com; Wanger, Christopher; Guardado, Ana; Miller-Phillips, Bridgette;
`Runchey, Dawn; Calendar Dept; Docketing Mailbox
`Re: Ironburg Inventions v. Collective Minds Gaming Co. - USDC Case No. 1:16-cv-04110-
`TWT (48490-063)
`
`Robert,
`
`The common interest/joint defense privilege protects communications between parties who are “part of an on-
`going and joint effort to set up a common defense strategy in connection with actual or prospective litigation.”
`See In re Androgel Antitrust Litigation (No. II), No. 1:09-cv-955-TWT, 2015 WL 9581828 at *2 (N.D. Ga. Dec.
`30, 2015) (internal quotations omitted). Here, the joint defense privilege would protect communications
`between Valve and CMG because they share an identical legal interest – they have both been accused of
`infringement of the same patents. Communications related to the Ironburg suits against these parties, if any,
`would be designed to further that interest.
`
`To be clear, CMG is not currently withholding any documents responsive to Ironburg’s 2nd RFPs on the basis
`of a common interest/joint defense privilege (or any other privilege). However, if documents including
`substantive communications come into existence, they would be covered under this privilege. We have
`therefore noted the objection to preserve the privilege for potential future communications.
`
`
`Best,
`
`Michelle A. Callaghan | Associate
`Erise IP, P.A.
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`(main) 913.777.5600
`(direct) 720.307.6260
`(cell) 484.883.5051
`(fax) 913.777.5601
`michelle.callaghan@eriseip.com
`www.eriseip.com
`
`Confidentiality Statement
`This email message and any attached files are confidential and are intended solely for the use of the addressee(s) named above.
`This communication may contain material protected by attorney-client, work product, or other privileges. If you are not the intended
`recipient or person responsible for delivering this confidential communication to the intended recipient, you have received this
`communication in error, and any review, use, dissemination, forwarding, printing, copying, or other distribution of this email message and
`any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor any communication that is created, received, or sent on
`its network. If you have received this confidential communication in error, please notify the sender immediately by reply email message
`and permanently delete the original message.
`
`On Tue, Mar 13, 2018 at 5:45 PM, Becker, Robert <RBecker@manatt.com> wrote:
`
`1
`
`IRONBURG EX2016, Page 1
`
`

`

`Thank you Michelle. Your responses, in large part, refer to a privilege. We are not aware of any privilege that your
`client would have with Valve. Please let me know what privilege you are referring to so that we can understand your
`responses.
`
`
`
`
`
`Thank you,
`
`Rob
`
`
`
`
`
`Robert Becker
`
`Partner
`
`_______________________
`
`
`
`
`
`Manatt, Phelps & Phillips, LLP
`
`1841 Page Mill Road
`Suite 200
`Palo Alto, CA 94304
`D (415) 291-7616 F (650) 213-0260
`
`
`
`
`
`RBecker@manatt.com
`manatt.com
`
`CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain confidential information that is
`legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying,
`distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED. If you have received this transmission in error, please
`immediately notify us by reply email and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you.
`
`From: Michelle Callaghan [mailto:michelle.callaghan@eriseip.com]
`Sent: Thursday, March 01, 2018 3:12 PM
`To: Stephenson, Faye
`Cc: eric.buresh@eriseip.com; paul.hart@eriseip.com; sgh@hkw-law.com; md@hkw-law.com; Becker, Robert; Wanger,
`Christopher; Guardado, Ana; Miller-Phillips, Bridgette; Runchey, Dawn; Calendar Dept; Docketing Mailbox
`Subject: Re: Ironburg Inventions v. Collective Minds Gaming Co. - USDC Case No. 1:16-cv-04110-TWT (48490-063)
`
`
`
`
`
`Counsel,
`
`
`
`
`
`Please find attached CMG's responses to Ironburg's section set of requests for production.
`
`2
`
`IRONBURG EX2016, Page 2
`
`

`

`
`
`
`Best,
`
`
`
`Michelle A. Callaghan | Associate
`Erise IP, P.A.
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`(main) 913.777.5600
`(direct) 720.307.6260
`(cell) 484.883.5051
`
`(fax) 913.777.5601
`michelle.callaghan@eriseip.com
`www.eriseip.com
`
`
`Confidentiality Statement
`
`This email message and any attached files are confidential and are intended solely for the use of the addressee(s) named above.
`This communication may contain material protected by attorney-client, work product, or other privileges. If you are not the intended
`recipient or person responsible for delivering this confidential communication to the intended recipient, you have received this
`communication in error, and any review, use, dissemination, forwarding, printing, copying, or other distribution of this email message and
`any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor any communication that is created, received, or sent on
`its network. If you have received this confidential communication in error, please notify the sender immediately by reply email message
`and permanently delete the original message.
`
`
`
`
`
`On Tue, Jan 30, 2018 at 6:01 PM, Stephenson, Faye <FStephenson@manatt.com> wrote:
`
`Attached please find Ironburg’s Second Set of Requests for Production. Faye
`
`
`
`
`
`
`
`Faye Stephenson
`
`Senior Paralegal-Case Specialist
`
`_______________________
`
`
`
`
`
`Manatt, Phelps & Phillips, LLP
`
`One Embarcadero Center
`30th Floor
`San Francisco, CA 94111
`
`3
`
`IRONBURG EX2016, Page 3
`
`

`

`D (415) 291-7558 F (415) 291-7660
`
`
`
`
`
`FStephenson@manatt.com
`manatt.com
`
`CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain confidential information that is
`legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying,
`distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED. If you have received this transmission in error, please
`immediately notify us by reply email and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you.
`
`
`
`
`
`Confidentiality Statement
`This email message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. This communication may contain material protected by attorney-client,
`work product, or other privileges. If you are not the intended recipient or person responsible for delivering this confidential communication to the intended recipient, you have received this communication
`in error, and any review, use, dissemination, forwarding, printing, copying, or other distribution of this email message and any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor
`any communication that is created, received, or sent on its network. If you have received this confidential communication in error, please notify the sender immediately by reply email message and
`permanently delete the original message.
`
`
`
`
`
`
`Confidentiality Statement
`This email message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. This communication may contain material protected by attorney-client,
`work product, or other privileges. If you are not the intended recipient or person responsible for delivering this confidential communication to the intended recipient, you have received this communication
`in error, and any review, use, dissemination, forwarding, printing, copying, or other distribution of this email message and any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor
`any communication that is created, received, or sent on its network. If you have received this confidential communication in error, please notify the sender immediately by reply email message and
`
`
`permanently delete the original message.
`
`
`4
`
`IRONBURG EX2016, Page 4
`
`