POL00041259
POL00041259
Message
From: Parsons, Andrew [/ "3
Sent: 27/07/2016 19:
To: Jane MacLeod Mark Underwoo: Angela
Van-Den-Boger ;
Patrick Bourke! _______5 Mark R Davies
homas P Moran
I; Rodric Williams
ce: Prime, Amy { }; Porter, Tom
Subject: Letter of Response [BD-4A.FID26859284]
Attachments: _DOC_33467063(3)_MASTER Final Form - Letter of Response (27 July 2016).DOCX
All
Please find attached the final version of the Letter of Response that we intend to send tomorrow.
The only outstanding point is Tony's approval of the Remote Access wording (he's going to look at this first thing
tomorrow).
We have now had comments from Fujitsu — the general theme of their comments is that they would like us to phrase the
case more positively to say that Horizon accurately records all transactions and that all bugs would be detected due to the
design of the system. I've not seen enough evidence to say whether this is correct and, in any event, it creates too much
of a risk of hostage to fortune, so we won't be adopting this suggestion.
In light of the Amended Claim Form, we have added a new para 2.4 to make clear that the letter proceeds on the basis of
the 91 original claims and that POL's position is reserved on the 107 new claims.
If you would like sight of any of the documents that we are intending to disclose with the LOR (see Schedule 1), please let
us know and we can provide them (they are too large to attach to an email in one go).
The letter will also get one more proof read tomorrow (for formatting glitches and that one typo that always slips through!)
Kind regards
Andy
Andrew Parsons
Partner
www.bonddickinson.com
POL-0037741