United States et al v. Google LLC Document 368: Memorandum in opposition, Attachment 1

Virginia Eastern District Court
Case No. 1:23-cv-00108-LMB-JFA
Filed August 31, 2023

Memorandum in Opposition re [317] MOTION for Judgment on the Pleadings or to Strike as to Google's Tenth and Thirteenth Affirmative Defenses, or in the Alternative for a Protective Order filed by Google LLC. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2 SEALED, # (3) Exhibit 3 SEALED, # (4) Exhibit 4 SEALED, # (5) Exhibit 5 SEALED, # (6) Exhibit 6 SEALED, # (7) Exhibit 7 SEALED, # (8) Exhibit 8 SEALED, # (9) Exhibit 9 SEALED, # (10) Exhibit 10 SEALED, # (11) Exhibit 11 SEALED, # (12) Exhibit 12 SEALED, # (13) Exhibit 13 SEALED, # (14) Exhibit 14, # (15) Exhibit 15 SEALED, # (16) Exhibit 16 SEALED, # (17) Exhibit 17 SEALED, # (18) Exhibit 18 SEALED, # (19) Exhibit 19 SEALED, # (20) Exhibit 20 SEALED, # (21) Exhibit 21, # (22) Exhibit 22, # (23) Exhibit 23, # (24) Exhibit 24)(Reilly, Craig)

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Page 1 PageID#
EXHIBIT
Page 2 PageID# Kanter, Jonathan S
Friday, July 24, 2020 5:40 PM
Shores, Ryan (ODAG)
RE: Athey Presentation
From:
Sent:
To:
Subject:
Great. Talk then.
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW I Washington, DC 20006-
I ».'».''#.:.P.~~.!~.~-i-~-~..-~9.D'.l.
From: Shores, Ryan (ODAG)
Date: Friday, Jul 24, 2020, 5:40 PM
To: Kanter, Jonathan S
Subject: Re: Athey Presentation
Great - please call me then at
On Jul 24, 2020, at 5:35 PM, Kanter, Jonathan S
wrote:
How about 1:30?
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW I Washington, DC 20006-
I ~.'#..'#.,.P.~.Y.1.».'.e.!~~,.c;:g_r:D
From: Shores, Ryan (ODAG)
Date: Friday, Jul 24, 2020, 5:33 PM
To: Kanter, Jonathan S
Subject: Re: Athey Presentation
Great. Can we have a brief touch base on Monday? I can do between 12:30 and 2 or between and 4:30 if those times work.
On Jul 24, 2020, at 3 :48 PM, Kanter, Jonathan S
Highly Confidential
wrote:
DOJ-ADS-8-0000001123
Page 3 PageID# Hi. Susan is confirmed for 3:00pm ET on 7/31 .
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW I Washington, DC 20006-
I www.paulweiss.com
From: Shores, Ryan (ODAG)
Date: Thursday, Jul 23 , 2020, 9:02 PM
To: Kanter, Jonathan S
Subject: Re: Athey Presentation
We can do after 2:30 on July 31 . Please let us know what works for you. Best, Ryan
On Jul 23, 2020, at 6:24 PM, Kanter, Jonathan S
wrote:
Great. Will stand by.
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW I Washington, DC 20006-
I Y:-'..Y:-'.~,P~-~!~~-!~~,~-°-!:D
From: Shores, Ryan (ODAG)
Date: Thursday, Jul 23, 2020, 5:14 PM
To: Kanter, Jonathan S
Subject: Re: Athey Presentation
Thanks Jonathan. That should work but let me confirm tomorrow. Best,
Ryan
On Jul 23, 2020, at 12:28 PM, Kanter, Jonathan S
wrote:
Hi, Ryan. Susan is happy to speak. She proposed a
75-minute window on 7/31. Does that work for you and
is that soon enough?
Highly Confidential
DOJ-ADS-8-0000001124
Page 4 PageID# For this call, Susan and I will each participate on our
behalf (not for any specific client).
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW I Washington, DC 20006-
I www.paulweiss.com
From: Shores, Ryan (ODAG)
Date: Wednesday, Jul 22, 2020, 2:41 PM
To: Kanter, Jonathan S
Subject: RE: Athey Presentation
Great, thanks.
And yes, it was informative and appreciated.
Best,
Ryan
From: Kanter, Jonathan S
Sent: Wednesday, July 22, 2020 2:38 PM
To: Shores, Ryan (ODAG)
Subject: RE: Athey Presentation
Hi. I am working with Susan's folks to propose a few times. We'll
try to get this arranged ASAP.
Thanks again for the time today. I hope it was informative.
Best,
Jonathan
Jonathan S. Kanter I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
I Washington, DC 20006-I www.paulweiss.com
From: Shores, Ryan (ODAG)
Sent: Wednesday, July 22, 2020 2:33 PM
To: Kanter, Jonathan S
Subject: Athey Presentation
Hi Jonathan, I am just checking in on potential timing for a
presentation by Athey on scale issues. Thanks, Ryan
Highly Confidential
DOJ-ADS-8-0000001125
Page 5 PageID#
This message is intended only for the use of the Addressee and may
contain information that is privileged and confidential. If you are not the
intended recipient, you are hereby notified that any dissemination of this
communication is strictly prohibited. If you have received this
communication in error, please erase all copies of the message and its
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