View Full Version : ITT, i post a confidential e-mail sent to Legal Boi regarding E-Bay lawsuit

Car Key Boi
Jan 13th, 2003, 06:49 PM
From: Pub-Legal Help
Subject: URGENT - Legal Preservation of Documents: Privileged and Confidential
Sent: 1/13/2003 [around 10:00 AM]
Importance: Urgent

Attorney-Client Privileged and Confidential

As you may be aware, a patent infringement lawsuit was recently filed against eBay and a large number of e-commerce companies by Charles E. Hill & Associates, Inc. Hill has alleged that we infringe certain patents generally related to an electronic catalog system, a method for producing information related to a selected product on a remote computer, and a method for updating a remote computer as a means of storing and displaying product data.

As it is important that we preserve and not inadvertently destroy any pertinent evidence or documents related to this litigation, we are sending this email to you to request that you preserve and save all relevant documents. Until further notice, you must save all documents (including but not limited to emails, hard copies, originals, facsimiles, notes, spreadsheets, PowerPoint presentations) that relate to or describe:

Cache management or client side caching of data from our website.

Any interactions, storing or caching between any internet browsers or third party servers and our web servers.

Any expiration-type information, such as "Time to Live," validators (e.g., e-Tags, last modified dates) or freshness indicators in server headers (e.g., expires directives).

The manner in which the servers store, maintain, or transmit any product information, including any graphics or text information.

Charles E. Hill & Associates, its products/services, patents, or this lawsuit.

If you are unsure whether a document falls into one of these categories, you should save that document. As the lawsuit is only in the very early stages, this is our current best estimate of the relevant documents, and we may update this preservation request as the lawsuit progresses. Additionally, the legal team will be contacting certain individuals to begin the document collection process, so if you are contacted, we request that you give the legal team your support and cooperation. However, there is no need to create any documents for this lawsuit, we are simply under an obligation to preserve relevant documents.

In order to give you time to comply with this request, the email move and deletion scheduled for January 8, 2003 will be postponed one month: (1) On February 7, 2003, all emails on or before October 5, 2002 will be moved into your "Deleted Items" folder (you may retrieve deleted emails by moving emails out of your "Deleted Items" folder into a personal folder); (2) on February 14, 2003, all emails on or before October 5, 2002 not in your personal folder will be deleted.

If you have any questions regarding which documents you should be preserving or this document preservation request, please contact Susan Kawaguchi at [removed phone number-CKB] or [removed email address-CKB].

Thank you,

Emily Lau Ward
Senior Patent Counsel

Jay Monahan
Associate General Counsel - Litigation and Intellectual Property