SPECIFIED DISCOVERY PLAN OF PLAINTIFF
Case No. C 06-2057 JF
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
C 06-02057 JF
Specified Discovery Plan for Plaintiff KinderStart.com LLC regarding Defendant
Google
1.
The actual frequency and times when PageRank™ for www.kinderstart.com was
internally calculated and recalculated during the period January 1, 2005 to May
31, 2006;
2.
The actual frequency and times when PageRank for www.kinderstart.com was
presented for viewing over the Internet from January 1, 2005 to May 31, 2006;
3.
Source code, specifications, schematics, flow charts, artwork, formulas, or other
internal documentation sufficient to show the operations of any and all aspects
and elements of PageRank;
4.
Any internal prepared engineering, mathematical or statistical analyses, white
papers or specifications relating to the formulation or calculation of PageRank,
including without limitation engineering design and scientific or statistical
modeling using Markov analysis;
5.
Quantitative listing of backlinks as prepared by Google for www.kinderstart.com
at all relevant times;
6.
Raw quantitative inputs for the PageRank as prepared and used by Google for
www.kinderstart.com at all relevant times;
7.
All human, qualitative, or subjective factors, if any, that impinged, directly or
indirectly, on PageRank that resulted in a ‘0’ Page Rank for
www.kinderstart.com, at all relevant times; and
8.
All factors, methods, algorithms or other means by which a Website on the
Internet may receive an assigned PageRank of ‘0’ by Google.
Case 5:06-cv-02057-JF Document 32 Filed 06/16/2006 Page 1 of 1
Kinderstart.Com, LLC v. Google, Inc.
Doc. 32
Dockets.Justia.com