Free Objection to Exhibit List - District Court of Federal Claims - federal

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiffs-Counterdefendants, ) ) V. ) ) THE UNITED STATES, ) ) Defendant-Counterplaintiff. ) _________________________________________________________ ) ROBERT B. DIENER ) and MICHELLE S. DIENER, ) ) Plaintiffs-Counterdefendants, ) ) V. ) ) THE UNITED STATES, ) ) Defendant-Counterplaintiff. ) _________________________________________________________ ) HOTELS.COM, INC. and Subsidiaries (f/k/a ) HOTEL RESERVATIONS NETWORK, INC.), ) ) Plaintiffs, ) ) V. ) ) THE UNITED STATES, ) ) Defendant. ) DAVID S. LITMAN and MALIA A. LITMAN,

No. 05-956T

No. 05-971T

No. 06-285T (Judge Christine O.C. Miller)

PLAINTIFFS-COUNTERDEFENDANTS, DAVID S. LITMAN, MALIA A. LITMAN, ROBERT B. DIENER, AND MICHELLE S. DIENER'S OBJECTIONS TO HOTELS.COM'S EXHIBIT LIST Plaintiffs-Counterdefendants, David S. Litman, Malia A. Litman, Robert B. Diener, and Michelle S. Diener file these Objections to Hotels.com's Exhibit List (these "Objections") pursuant to ¶ 14(a)(3) of Appendix A of the Rules of the Court of Federal Claims (the "Rules") and the Court's Order dated February 21, 2007. In support of these Objections,

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Plaintiffs make the following objections to the exhibits listed on Hotels.com's Exhibit List for the reasons stated: Exhibit No. 21 -- Plaintiffs object to the document Bates-labeled BAJAJ2092 BAJAJ2098 regarding pre-open prices on the grounds that it lacks proper foundation and to all of the information in the Exhibit (prices on February 25, 2000 for HRN stock) as irrelevant. Exhibit No. 3 -- Plaintiffs object to these articles and other documents on the grounds that they contain hearsay, constitute hearsay, and/or lack proper foundation. Exhibit No. 10 -- Plaintiffs object to this Amendment to the Amended Asset Purchase Agreement on the grounds that it is irrelevant, as it relates to post-valuation date events. See, e.g., Grill v. U.S., 303 F.2d 922, 927 (Ct. Cl. 1962) ("the valuation for income tax purposes must be made as of the relevant date, without regard to events occurring subsequently"). Exhibit No. 11 -- Plaintiffs object to this news article on the grounds that it contains hearsay, constitutes hearsay, and is irrelevant. Exhibit No. 15 -- Plaintiffs object to this correspondence on the grounds that it is irrelevant. Exhibit No. 27 -- Plaintiffs object to this document (the table of contents to the closing binder for the sale at issue) on the grounds that it is hearsay and irrelevant. Exhibit No. 51 -- Plaintiffs object to this document (apparently produced by Mukesh Bajaj) on the grounds that it lacks proper foundation. Exhibit No. 52 -- Plaintiffs object to this document (apparently produced by Mukesh Bajaj) on the grounds that it lacks proper foundation.
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Exhibit numbers are those provided in Hotels.com's Exhibit List. Plaintiffs reserve the right to object to any proposed exhibit at trial on the grounds that a proper foundation has not been laid.

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Exhibit No. 63 -- Plaintiffs object to this spreadsheet on the grounds that it constitutes hearsay, contains hearsay, and lacks proper foundation. Exhibit No. 64 -- Plaintiffs object to this spreadsheet on the grounds that it constitutes hearsay, contains hearsay, and lacks proper foundation. Exhibit No. 65 -- Plaintiffs object to this document titled "HRN Pricing Analysis" on the grounds that it constitutes hearsay, contains hearsay, and lacks proper foundation. Exhibit No. 66 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 67 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 68 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 69 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 70 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 71 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 72 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 73 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay.

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Exhibit No. 74 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 76 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 77 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 78 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 79 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 80 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 81 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 82 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 83 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 84 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 85 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 86 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 96 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 97 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 103 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 104 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 105 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 114 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 115 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 117 -- Plaintiffs object to the 2003 United States Income Tax Return for TMF Liquidating Trust on the grounds that it is irrelevant. Exhibit No. 122 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 123 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 124 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 125 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 127 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 133 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 134 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 135 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 136 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 137 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 138 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 139 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 140 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 141 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 142 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 143 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 144 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 145 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 146 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 147 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 148 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 149 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 156 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 157 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay.

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Exhibit No. 158 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 159 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 160 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 163 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 164 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 167 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 168 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 169 -- Plaintiffs object to this document related to a charitable donation on the grounds that it is irrelevant. Exhibit No. 170 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 171 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 172 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay.

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Exhibit No. 173 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 174 -- Plaintiffs object to this email on the grounds that it is irrelevant. Exhibit No. 176 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 177 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 178 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 179 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 180 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 181 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 183 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 184 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 185 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 186 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 191 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 192 -- Plaintiffs object to this document on the grounds that it is irrelevant. * * *

The following are objections to documents Hotels.com may rely on at trial: Exhibit No. 220 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 221 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 222 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 223 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 238 -- Plaintiffs object to this document on the grounds that it lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 253 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 255 -- Plaintiffs object to this document related to Andy Pells on the grounds that it is irrelevant to the only issue in Plaintiffs' case to which Hotels.com is a party -the fair market value of the HRN Restricted Shares.

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Exhibit No. 256 -- Plaintiffs object to this document related to Andy Pells on the grounds that it is irrelevant to the only issue in Plaintiffs' case to which Hotels.com is a party -the fair market value of the HRN Restricted Shares. Exhibit No. 257 -- Plaintiffs object to this document related to Andy Pells on the grounds that it is irrelevant to the only issue in Plaintiffs' case to which Hotels.com is a party -the fair market value of the HRN Restricted Shares. Exhibit No. 258 -- Plaintiffs object to this document related to Andy Pells on the grounds that it is irrelevant to the only issue in Plaintiffs' case to which Hotels.com is a party -the fair market value of the HRN Restricted Shares. Exhibit No. 260 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 261 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 275 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 276 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 277 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 278 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 279 -- Plaintiffs object to this document related to Viren Ghandhi on the grounds that it is irrelevant.

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Exhibit No. 280 -- Plaintiffs object to this document related to Viren Ghandhi on the grounds that it is irrelevant. Exhibit No. 281 -- Plaintiffs object to this document related to Viren Ghandhi on the grounds that it is irrelevant. Exhibit No. 282 -- Plaintiffs object to this document related to Viren Ghandhi on the grounds that it is irrelevant. Exhibit No. 283 -- Plaintiffs object to this document related to Viren Ghandhi on the grounds that it is irrelevant. Exhibit No. 285 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 286 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 304 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 305 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 306 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 307 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 316 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 319 -- Plaintiffs object to this document on the grounds that it lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 323 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 325 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 326 -- Plaintiffs object to this document on the grounds that it is irrelevant and lacks proper foundation. Exhibit No. 327 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 328 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 329 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 330 -- Plaintiffs object to this document on the grounds that it is irrelevant, lacks proper foundation, contains hearsay, and constitutes hearsay. Exhibit No. 358 -- Plaintiffs object to this draft memorandum on the grounds that it is irrelevant and based on the rule of completeness. Exhibit No. 359 -- Plaintiffs object to this valuation of TMF, Inc. in 1994 and 1997 on the grounds that it is irrelevant. Exhibit No. 360 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 376 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 377 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 378 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 379 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 380 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 381 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 382 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 383 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 384 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 385 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 390 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 391 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 400 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 401 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 402 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 413 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 414 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 415 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 416 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 417 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 423 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 424 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 426 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 427 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 428 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 429 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 430 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 431 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 432 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 433 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 435 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 438 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 439 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 440 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 441 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 442 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 443 -- Plaintiffs object to this document as it is a duplicate of Exhibit 436. Exhibit No. 444 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 445 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 446 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 447 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 448 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 449 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 450 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 451 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 452 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 453 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 454 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 455 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 456 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 457 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 458 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 459 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 460 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 461 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 463 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 464 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 465 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 466 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 467 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 468 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 469 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 470 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 471 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 472 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 473 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 475 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 476 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 477 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 478 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 482 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 483 -- Plaintiffs object to this compilation of news articles on the grounds that they contain hearsay and constitute hearsay. Exhibit No. 484 -- Plaintiffs object to this compilation of news articles on the grounds that they contain hearsay and constitute hearsay. Exhibit No. 487 -- Plaintiffs object to this invoice from Brian Lidji on the grounds that it is irrelevant. Exhibit No. 488 -- Plaintiffs object to this invoice from Brian Lidji on the grounds that it is irrelevant. Exhibit No. 489 -- Plaintiffs object to this invoice from Brian Lidji on the grounds that it is irrelevant. Exhibit No. 492 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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Exhibit No. 493 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 494 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 496 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 497 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 498 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 499 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 500 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 508 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 533 -- Plaintiffs object to this document on the grounds that it is irrelevant. Exhibit No. 536 -- Plaintiffs object to this document on the grounds that it is irrelevant.

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WHEREFORE, for the foregoing reasons, Plaintiffs respectfully request the Court sustain its objections to the above-listed exhibits proposed by Hotels.com. Respectfully submitted, BAKER BOTTS L.L.P. Dated: April 2, 2007 By: John W. Porter John W. Porter Attorney of Record 3000 One Shell Plaza 910 Louisiana Houston, Texas 77002 (713) 229-1597 (713) 229-1522 (FAX) J. Graham Kenney (Of Counsel) COUNSEL FOR PLAINTIFFSCOUNTERDEFENDANTS

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