Case 2:12-cv-02830-JPM-tmp Document 37-3 Filed 01/29/13 Page 1 of 3 PageID 303
`Case 2:l2—cv—O2830—JPM—tmp Document 37-3 Filed 01/29/13 Page 1 of 3 Page|D 303
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`EXHIBIT G
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`EXHIBIT G
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`

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`Case 2:12-cv-02830-JPM-tmp Document 37-3 Filed 01/29/13 Page 2 of 3 PageID 304
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`Mayer Brown LLP
`1999 K Street, N.W.
`Washington, D.C. 20006-1101
`
`Main Tel +1 202 263 3000
`Main Fax +1 202 263 3300
`www.mayerbrown.com
`
`Brian A. Rosenthal
`Direct Tel +1 202 263 3446
`Direct Fax 202 263 5318
`brosenthal@mayerbrown.com
`
`November 12, 2012
`
`VIA EMAIL
`
`Craig Robert Kaufman
`Freitas Tseng & Kaufman, LLP
`100 Marine Parkway
`Suite 200
`Redwood Shores, CA 94065
`
`Re:
`
`B.E. Technology, Inc. v. Google Inc., Case No.
`2:12-cv-02830-JPM-cgc
`
` B.E. Technology, Inc. v. Motorola Mobility
`Holdings LLC, Case. No. 2:12-cv-02866
`
`Dear Mr. Kaufman:
`
`I write regarding the complaints recently filed against our clients Google Inc. and
`Motorola Mobility Holdings LLC (“Motorola”) in the Western District of Tennessee by your
`client B.E. Technology, Inc. While B.E. Technology accuses Google of infringing both U.S.
`Patent Nos. 6,628,314 (“the ‘314 Patent) and 6,771,290 (“the ‘290 Patent”) and accuses
`Motorola of infringing the ‘290 Patent, B.E. Technology has failed to identify the specific
`products or services that are accused of infringing those patents as well as the accused
`functionalities and features for those products and services.
`
`Specifically, B.E. Technology’s complaint against Google only states that “Google has
`infringed the ’314 patent by using a method of providing demographically targeted advertising
`that directly infringes at least Claim 11 of the ’314 patent either literally or under the doctrine of
`equivalents.” This statement is too vague and provides no identification of the products or
`services B.E. Technology contends infringe the ‘314 Patent. Google requests that B.E.
`Technology immediately identify any and all Google products or services, specifically, by
`product/service name, number or other identifying information, accused of infringing claim 11 of
`the ‘314 Patent along with the accused functionalities and features for those products and/or
`services.
`
`In addition, B.E. Technology states only that “Google has infringed at least Claim 2 of
`the ’290 patent by using, selling, and offering to sell in the United States tablet computer
`products that directly infringe at least Claim 2 of the ’290 patent either literally or under the
`doctrine of equivalents. The accused products include Google Nexus products.” Again, B.E.
`Technology’s statement is too vague and provides insufficient identification of the products
`accused of infringing claim 2 of the ‘290 Patent. It is unclear what Nexus products B.E.
`
`Mayer Brown LLP operates in combination with other Mayer Brown entities with offices in Europe and Asia
`and is associated with Tauil & Chequer Advogados, a Brazilian law partnership.
`
`

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`Mayer Brown LLP
`Case 2:12-cv-02830-JPM-tmp Document 37-3 Filed 01/29/13 Page 3 of 3 PageID 305
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`Craig Robert Kaufman
`November 6, 2012
`Page 2
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`Technology is accusing of infringement or whether there are additional Google products B.E.
`Technology also accuses. Moreover, B.E. Technology has failed to identify the accused features
`or functionalities of the Nexus products. Google requests that B.E. Technology immediately
`identify any and all Google products, specifically, by product name, number or other identifying
`information, accused of infringing claim 2 of the ‘290 Patent along with the accused
`functionalities and features for these products.
`
`B.E. Technology’s complaint against Motorola identifies “Motorola tablets: Xyboard and
`Xoom tablets; [and] Motorola smartphones: Atrix, Electrify 2, Defy XT, Photon Q 4G LTE” as
`infringing the ‘290 Patent, but fails to identify the accused functionalities and features of these
`products. Motorola requests that B.E. Technology immediately identify all accused
`functionalities and features of the tablets and smartphones identified in its complaint.
`
`We request this information no later than November 16, 2012. Please advise whether
`such information will be forthcoming.
`
`Sincerely,
`
`Brian A. Rosenthal
`
`cc:
`
`John A. Mancini
`Ann Marie Duffy