Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 1 of 83
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`Exhibit 6
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 2 of 83
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`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`T-MOBILE USA, INC. and T-MOBILE US,
`INC.,
`
`
`Defendants.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:21-cv-00072-JRG
`§
`(LEAD CASE)
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`ADVANCED GROUND INFORMATION SYSTEMS, INC.’S
`OBJECTIONS AND RESPONSES TO DEFENDANT LYFT, INC.’S
`AMENDED SUBPOENA TO TESTIFY IN A CIVIL ACTION
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`
`
`
`LYFT, INC.,
`
`
`Plaintiff,
`
`v.
`
`Defendant.
`
`
`Case No. 2:21-cv-00024-JRG
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`
`Pursuant to Federal Rule of Civil Procedure 45, non-party Advanced Ground Information
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`Systems, Inc. (“AGIS, Inc.”) hereby provides responses and objections to the Amended Subpoena
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`to Testify (the “Subpoena”) issued in the above-captioned case by Lyft, Inc. (“Defendant” or
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`“Lyft”) to Advance Ground Information Systems, Inc., received on September 21, 2021.
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`

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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 3 of 83
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`GENERAL OBJECTIONS
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`1.
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`AGIS, Inc. objects to the noticed date and time, as listed in the Subpoena, as
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`unduly burdensome. AGIS, Inc. will continue to work with Defendant to determine a mutually
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`convenient time and place for the deposition, subject to these objections.
`
`2.
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`Any statement by AGIS, Inc. that it will designate a witness to testify to the topics
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`contained in the Subpoena does not constitute an admission or representation that AGIS, Inc. has
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`any knowledge or information related to a given topic.
`
`3.
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`AGIS, Inc. objects to the Subpoena to the extent that it seeks disclosure of
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`information and/or communications protected by the attorney-client privilege, the work-product
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`doctrine, or any other applicable privilege or immunity. AGIS, Inc. does not waive, but
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`specifically asserts, the attorney-client privilege, work-product immunity, and any other
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`applicable privileges, even if such privileged information is revealed through oversight,
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`inadvertence, or mistake.
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`4.
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`AGIS, Inc. objects to the Subpoena to the extent that it expands the scope of
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`permissible discovery or seeks to impose discovery obligations that differ from or exceed those
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`set forth in the Federal Rules of Civil Procedure, the Local Rules of this Court, and applicable
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`Court Orders. AGIS, Inc. will respond in accordance with his obligations pursuant to such Rules
`
`and Orders. AGIS, Inc. also objects to the Subpoena to the extent that the burden or expense of
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`responding to the Subpoena outweighs the likely benefits or imposes burdens or expenses on
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`AGIS, Inc. not authorized by the Federal Rules of Civil Procedure, the Local Rules of this Court,
`
`and applicable Court Orders.
`
`5.
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`AGIS, Inc. objects to the Subpoena to the extent that it seeks documents or
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`information that are not relevant to a claim or defense of any party. AGIS, Inc. will not produce
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`2
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 4 of 83
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`such information and specifically reserves the right to redact such information from any
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`document produced in response to the Subpoenas.
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`6.
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`AGIS, Inc. objects to this Subpoena to the extent it seeks confidential, proprietary,
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`or trade secret information of third parties. AGIS, Inc. further objects to this Subpoena to the
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`extent it seeks information received from a third party under a non-disclosure agreement or
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`subject to the common interest privilege, or the content of any part of any agreement between
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`AGIS, Inc. and a third-party that, by its terms, may not be disclosed by AGIS, Inc.
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`7.
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`AGIS, Inc. objects to the Subpoena to the extent it seeks to impose on AGIS, Inc.
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`any obligation beyond or not required by the Federal Rules of Evidence.
`
`8.
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`AGIS, Inc. objects to the Subpoena to the extent it seeks information that is
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`irrelevant, overly broad, unduly burdensome, vague, ambiguous, and/or not reasonably
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`calculated to lead to the discovery of admissible evidence. AGIS, Inc. further objects to the
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`Subpoena to the extent it seeks information that is neither relevant to any claim or defense in this
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`action.
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`9.
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`AGIS, Inc. objects to this Subpoena to the extent it seeks a legal opinion or
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`conclusion.
`
`10.
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`Nothing contained in these statements and objections or contained in any
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`testimony given at any subsequent deposition, is intended to be, or in any way constitutes, a
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`waiver of any such applicable privilege, immunity, or confidentiality obligation.
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`11.
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`12.
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`AGIS, Inc. reserves the right to supplement its objections to the Subpoena.
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`AGIS, Inc. objects to the Subpoena to the extent that it requests the production of
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`documents and testimony that are not within AGIS, Inc.’s possession, custody, or control or are
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`not obtainable through a reasonable and good faith inquiry into his records or knowledge. AGIS,
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`3
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 5 of 83
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`Inc. has no obligation to search for or produce documents or information that are not in his
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`possession, custody, or control, and disclaims any obligation to do so. AGIS, Inc. also objects to
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`the Subpoena to the extent that it purports to impose on AGIS, Inc. the burden of furnishing
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`information that is equally or readily available to Defendant from a source other than AGIS, Inc.
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`13.
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`AGIS, Inc. objects to the Subpoena to the extent that it calls for documents or
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`information that are outside the scope of AGIS, Inc.’s knowledge, possession, custody, or
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`control.
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`14.
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`AGIS, Inc. objects to the Subpoena as overly broad and unduly burdensome to the
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`extent that they seek information or documents not relevant to any party’s claim or defense in
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`this case, not reasonably calculated to lead to the discovery of admissible evidence, or not
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`proportional to the needs of the case, considering the importance of the issues at stake in the
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`action, the amount in controversy, the parties’ relative access to relevant information, the parties’
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`resources, the importance of the discovery in resolving the issues, and whether the burden or
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`expense of the proposed discovery outweighs its likely benefit.
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`15.
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`AGIS, Inc. objects to the Subpoena as overly broad and unduly burdensome to the
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`extent that they fail to provide a reasonable time period for information sought, or otherwise seek
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`information beyond the relevant time frame for discovery in this case.
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`16.
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`AGIS, Inc. objects to the Subpoena as overly broad and unduly burdensome to the
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`extent that they purport to require Li Creative to describe or identify “all,” “every,” “each,” or
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`“any” document, communication, or thing, or use other similarly expansive, infinite, or all-
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`inclusive terms.
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`17.
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`AGIS, Inc. objects to the Subpoena to the extent it requires AGIS, Inc. to create or
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`produce information that it does not maintain in the ordinary course of its business, or to the
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`4
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 6 of 83
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`extent that they seek to require that Li Creative create or produce information in a particular
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`format or at a particular level of detail that Li Creative does not maintain in the ordinary course
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`of its business.
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`18.
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`AGIS, Inc. objects to the Subpoena to the extent it gives meanings to words
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`different from their ordinary English meaning or definitions set forth in applicable statues or
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`rules.
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`19.
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`AGIS, Inc. objects to the Subpoena to the extent that it seeks confidential,
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`proprietary, or trade secret information.
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`20.
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`AGIS, Inc. objects to the definition of “Advanced Ground Information Systems,
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`Inc.,” “You,” and “Your” as overly broad and unduly burdensome. AGIS, Inc. responds on behalf
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`of AGIS, Inc. only.
`
`21.
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`AGIS, Inc. objects to the definition of “Related Patents” as overly broad and unduly
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`burdensome.
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`22.
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`AGIS, Inc. objects to the definition of “AGIS Software Development LLC” and
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`“Plaintiff” as overly broad and unduly burdensome. AGIS, Inc. responds on behalf of AGIS, Inc.
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`only.
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`23.
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`AGIS, Inc. objects to the definition of “LifeRing Product(s)” as overly broad and
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`unduly burdensome.
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`24.
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`AGIS, Inc. objects to the voluminous number of topics as duplicative, designed to
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`harass, vexatious, overly broad, unduly burdensome, and inappropriate for a non-party.
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`Subject to and without waiving the foregoing General Objections, AGIS, Inc. responds as
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`follows:
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`5
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 7 of 83
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`DOCUMENT REQUESTS
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`REQUEST NO. 1
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`Documents sufficient to evidence each discussion with, disclosure to, or other manner of
`providing to a third party, or sale of or offer to sell, each invention claimed in the Asserted
`Patents and Related Patents prior to the filing date identified on the face.
`
`RESPONSE TO REQUEST NO. 1
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
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`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
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`objects to this request to the extent that it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, and/or any other applicable privilege or immunity. AGIS,
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`Inc. objects to this request as vague and ambiguous as to the phrase “other manner of,” “each
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`invention claimed,” and “prior to the filing date identified on the face.”
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`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
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`will produce relevant, responsive, non-privileged documents responsive to this request to the
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`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
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`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
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`REQUEST NO. 2
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`All Documents evidencing the conception, reduction to practice, design, and
`development of each alleged invention in the Asserted Patents and Related Patents.
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`RESPONSE TO REQUEST NO. 2
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`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
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`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 8 of 83
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`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
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`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
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`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
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`REQUEST NO. 3
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`All known prior art to the Relevant Patents and Applications that has not been submitted
`to the Patent Office.
`
`RESPONSE TO REQUEST NO. 3
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
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`7
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 9 of 83
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`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 4
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`Documents and Communications regarding the conveyance of any rights to any of the
`Asserted Patents and Related Patents, and all Documents and communications relating thereto.
`
`RESPONSE TO REQUEST NO. 4
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
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`8
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 10 of 83
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`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
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`REQUEST NO. 5
`
`To the extent not covered by the previous request, Documents and Communications
`regarding the conveyance of any rights to any LifeRing Product(s) and all Documents and
`Communications relating thereto.
`
`RESPONSE TO REQUEST NO. 5
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent that it is cumulative and duplicative of discovery already
`
`obtained in this case. AGIS, Inc. objects to this request to the extent that it seeks information
`
`protected by the attorney-client privilege, the work product doctrine, and/or any other applicable
`
`privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
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`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 6
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`Documents sufficient to show licenses, payments, royalties, technology transfers,
`authorizations to use, or covenants not to sue relating to any of the Asserted Patents and Related
`Patents, including, without limitation, Documents evidencing any efforts by AGIS (successful or
`otherwise) to enter into any such agreement.
`
`RESPONSE TO REQUEST NO. 6
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`9
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 11 of 83
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 7
`
`Documents relating to Your compliance with the marking or notice provisions of 35
`U.S.C. § 287(a) with respect to the Asserted Patents and Related Patents, including, without
`limitation, all Documents relating to compliance with the marking provisions by licensees of the
`Asserted Patents.
`
`RESPONSE TO REQUEST NO. 7
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
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`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`10
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 12 of 83
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`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 8
`
`Documents relating to an analysis or opinion as to the validity, scope, enforceability, or
`infringement of any of the Asserted Patents and Related Patents.
`
`RESPONSE TO REQUEST NO. 8
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`11
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 13 of 83
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`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 9
`
`Documents and Communications prepared by You or on Your behalf, for submission
`and/or provision to an auditor, a governmental agency, or any third party referring or relating to
`any the Asserted Patents and Related Patents.
`
`RESPONSE TO REQUEST NO. 9
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it is cumulative and duplicative of discovery already obtained in this case. AGIS, Inc.
`
`objects to this request to the extent that it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, and/or any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`
`
`12
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 14 of 83
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`REQUEST NO. 10
`
`All Documents concerning any formal or informal valuations and/or appraisals regarding
`any of the Asserted Patents and Related Patents.
`
`RESPONSE TO REQUEST NO. 10
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it is cumulative and duplicative of discovery already obtained in this case. AGIS, Inc.
`
`objects to this request to the extent that it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, and/or any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 11
`
`Documents relating to any analysis regarding actual, contemplated, or potential non-
`infringing alternatives to any of the alleged inventions covered by the Asserted Patents or
`Related Patents.
`
`RESPONSE TO REQUEST NO. 11
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`13
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`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 15 of 83
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`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 12
`
`Documents and Communications relating to any prototypes or products that You contend,
`or have contended at any time, practice, have practiced, or have demonstrated any of the
`Asserted Patents and Related Patents, including information related to marketing, sales, offers
`for sale, and marking of or efforts to mark any such products.
`
`RESPONSE TO REQUEST NO. 12
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`14
`
`

`

`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 16 of 83
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`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 13
`
`All Documents concerning the identification or determination of the Named Inventors of
`any of the Asserted Patents and Related Patents.
`
`RESPONSE TO REQUEST NO. 13
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it seeks information that is more properly sought from the inventors of the Patents-in-
`
`Suit. AGIS, Inc. objects to this request to the extent that it is cumulative and duplicative of
`
`discovery already obtained in this case. AGIS, Inc. objects to this request to the extent that it
`
`seeks information protected by the attorney-client privilege, the work product doctrine, and/or
`
`any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`15
`
`

`

`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 17 of 83
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 14
`
`Documents sufficient to show the actual and projected sales and profitability of the
`LifeRing Product(s).
`
`RESPONSE TO REQUEST NO. 14
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it is cumulative and duplicative of discovery already obtained in this case. AGIS, Inc.
`
`objects to this request to the extent that it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, and/or any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 15
`
`Documents relating to any sales or potential sales of any embodiments of the Asserted
`Patents and Related Patents, including the LifeRing Product(s), including, without limitation, the
`names of customers and potential customers, number of units sold, and financial data related to
`each sale.
`
`
`16
`
`

`

`Case 5:21-cv-04653-BLF Document 123-7 Filed 05/03/22 Page 18 of 83
`
`RESPONSE TO REQUEST NO. 15
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`objects to this request to the extent it seeks information that can be obtained publicly and/or
`
`directly from the parties to the above-captioned matter. AGIS, Inc. objects to this request to the
`
`extent that it is cumulative and duplicative of discovery already obtained in this case. AGIS, Inc.
`
`objects to this request to the extent that it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, and/or any other applicable privilege or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, AGIS, Inc.
`
`will produce relevant, responsive, non-privileged documents responsive to this request to the
`
`extent that such documents exist, are in AGIS, Inc.’s possession, custody, or control, and are
`
`located after reasonable search, and have not been produced by the parties to the above-
`
`captioned case.
`
`REQUEST NO. 16
`
`Documents sufficient to correlate the internal and external name(s) and internal and
`external model number(s) of the LifeRing Product(s) with relevant quarterly sales, revenue, cost,
`profit, and transfer pricing data.
`
`RESPONSE TO REQUEST NO. 16
`
`AGIS, Inc. incorporates by reference its General Objections. AGIS, Inc. objects to this
`
`request as overly broad and unduly burdensome in that it seeks information that can be obtained
`
`from other means of discovery that would be more convenient or less burdensome. AGIS, Inc.
`
`object