`
`
`
`April 24, 2023
`
`VIA ELECTRONIC-FILING
`
`
`The Honorable Jennifer L. Hall
`U.S. District Court for the District of Delaware
`J. Caleb Boggs Federal Building
`844 N. King Street
`Wilmington, DE 19801
`
`
`
`Re:
`
`Arendi S.A.R.L. v. Google LLC, C.A. No. 13-919-JLH
`
`
`Dear Judge Hall:
`
`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`David E. Moore
`Partner
`Attorney at Law
`dmoore@potteranderson.com
`302 984-6147 Direct Phone
`
`
`
`We write to advise the Court that Google has the following disputes to present before the
`presentation of the following demonstratives and exhibits on Monday, April 24.
`
`Issue/Document
`
`Witness
`
`Anticipated presentation
`time
`
`Opening Statement
`
`Monday morning
`
`Opening Statement
`
`Monday morning
`
`Opening Statement
`
`Monday morning
`
`Arendi Opening Slides 42-46
`– Google objects to these
`slides on the basis set forth in
`its pending motion at D.I. 479
`
`Arendi Opening Slides 44-45
`– These slides additionally
`reflect highly confidential
`information about the number
`of downloads of Google apps
`and device revenue. Google
`requests that, if Arendi is
`going to show or disclose
`these numbers in its opening
`statement, that the courtroom
`be sealed for that discussion.
`
`Arendi Opening Slide 48 –
`Google objects to this slide
`that purports to provide a
`timeline
`of
`the
`IPR
`proceedings.
` The
`IPR
`
`
`
`
`
`Case 1:13-cv-00919-JLH Document 483 Filed 04/24/23 Page 2 of 2 PageID #: 50973
`
`The Honorable Jennifer L. Hall
`April 24, 2023
`Page 2
`
`
`Issue/Document
`
`Witness
`
`proceedings are not relevant
`and highly prejudicial. The
`timeline
`itself
`is
`also
`misleading and prejudicial.
`
`Anticipated presentation
`time
`
`
`
`Google further notes that Google does not object to PX-393 and Hedloy Slide 4, which
`shows PX-393, being used as part of the invention story. Arendi represented that this is the only
`way in which it intends to use this document. Google objects to this document and slide being
`used in any way to suggest a priority date.
`
`Respectfully,
`
`/s/ David E. Moore
`
`David E. Moore
`
`DEM:nmt/10770824/12599.00040
`
`cc:
`
`Clerk of the Court (via hand delivery)
`Counsel of Record (via electronic mail)
`
`
`
`
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