Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 1 of 13
`Case 5:18—md-02834-BLF Document 320-3 Filed 12/11/18 Page 1 of 13
`
`EXHIBIT 3
`
`EXHIBIT 3
`(REDACTED VERSION
`(REDACTED VERSION
`OF DOCUMENT SOUGHT
`TO BE SEALED)
`TO BE SEALED)
`
`OF DOCUMENT SOUGHT
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 2 of 13
`
`
`
`
`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`TODD R. GREGORIAN (CSB No. 236096)
`tgregorian@fenwick.com
`PHILLIP J. HAACK (CSB No. 262060)
`phaack@fenwick.com
`RAVI R. RANGANATH (CSB No. 272981)
`rranganath@fenwick.com
`CHIEH TUNG (CSB No. 318963)
`ctung@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Counsel for AMAZON.COM, INC.
`and AMAZON WEB SERVICES, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`IN RE: PERSONALWEB TECHNOLOGIES,
`LLC ET AL., PATENT LITIGATION
`
` Case No. 5:18-md-02834-BLF
`
` Case No.: 5:18-cv-00767-BLF
`
`FIRST SUPPLEMENTAL
`RESPONSES AND OBJECTIONS OF
`AMAZON.COM, INC. AND AMAZON
`WEB SERVICES, INC. TO FIRST SET
`OF INTERROGATORIES OF
`PERSONALWEB TECHNOLOGIES,
`LLC (NOS. 1-11)
`
`HIGHLY CONFIDENTIAL -
`ATTORNEYS’ EYES ONLY
`
`
`
`
`
`
`AMAZON.COM, INC., and AMAZON WEB
`SERVICES, INC.,
`Plaintiffs,
`v.
`
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC,
`Defendants.
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC,
`Counterclaimants,
`
`v.
`
`AMAZON.COM, INC., and AMAZON WEB
`SERVICES, INC.,
`Counterdefendants.
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES TO
`PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 3 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Amazon.com, Inc. and
`Amazon Web Services, Inc. (collectively, “Amazon”), by and through counsel, hereby supplements
`its responses to the First Set of Interrogatories of Personal Web Technologies, LLC
`(“PersonalWeb”) as follows:
`
`GENERAL OBJECTIONS
`The following general objections are stated with respect to each and every interrogatory
`whether or not specifically identified in response thereto. To the extent any of these general
`objections are not raised in any particular response, Amazon does not waive those objections.
`1.
`Amazon objects to each and every definition that purports to define a term by
`referring to out of context and irrelevant statements made by counsel during case management
`conferences. Such definitions are vague, ambiguous, irrelevant, not proportional to the needs of
`the case and improper.
`2.
`Amazon objects to each and every definition and interrogatory as overly broad,
`unduly burdensome, and not proportional to the needs of the case because they are not limited to a
`specific geographic area. Amazon will only provide discovery with respect to the United States.
`3.
`Amazon objects to the definitions of “You,” “Your,” or “Amazon” because it seeks
`to broaden the scope of allowable discovery and seeks information that is not within the possession,
`custody, or control of Amazon, but is in the possession of third-parties and non-parties to this
`lawsuit. Amazon further objects to the definition of these terms to the extent it includes Amazon’s
`attorneys and patent agents and seeks privileged and attorney-work product information. Amazon
`will interpret these terms as referring to Amazon.com, Inc. and Amazon Web Services, Inc. only.
`4.
`Amazon objects to the definition of “S3 System” as vague and ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case, as it does not identify the
`products, services, or features with specificity. Amazon will interpret this term as the Simple
`Storage Service (S3).
`5.
`Amazon objects to the definition of “Website Operator Sued by PersonalWeb” as
`overly broad, unduly burdensome, and not proportional to the needs of this case. The cases
`PersonalWeb has filed against Amazon’s customers are currently stayed (In re: PersonalWeb
`1
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 4 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`Technologies, LLC et al., Patent Litigation, No. 18-md-02834-BLF, Dkt. No. 157) and discovery
`from or relating specifically to those customers, or PersonalWeb’s claims in those cases, is outside
`the scope of this declaratory judgment action.
`6.
`Amazon objects to the definition of “Website Operator Customer” as vague and
`ambiguous, overly broad, unduly burdensome, and not proportional to the needs of the case.
`PersonalWeb’s definition does not identify the relevant entities or persons with specificity. Instead,
`PersonalWeb states that this term includes entities that Amazon considers to be customers without
`clarifying a time frame or whether this refers to just S3 customers or all customers for any of
`Amazon’s products. Amazon will interpret this term to refer to those customers who used S3 from
`January 8, 2012 through December 26, 2016.
`7.
`Amazon objects to the definition of “Customer” as vague and ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case, as it does not identify the
`relevant entities with specificity. In addition, the cases PersonalWeb has filed against Amazon’s
`customers are currently stayed (In re: PersonalWeb Technologies, LLC et al., Patent Litigation,
`No. 18-md-02834-BLF, Dkt. No. 157) and discovery from or relating specifically to those
`customers, or PersonalWeb’s claims in those cases, is outside the scope of this declaratory judgment
`action. Amazon will interpret this term to refer to those customers who used S3 from January 8,
`2012 through December 26, 2016.
`8.
`Amazon objects to the definition of “Webpage File” as vague and ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case, as it does not identify the
`item or feature with specificity. Amazon incorporates by reference its objections to the definitions
`of the terms “Webpage Base File” and “Webpage Asset File.” Amazon will interpret this term as
`a file served via HTTP.
`9.
`Amazon objects to the definition of “Webpage Base File” as vague and ambiguous,
`overly broad, unduly burdensome, and not proportional to the needs of the case, as it does not
`identify the item or feature with specificity. Amazon incorporates by reference its objection to the
`definition of the term “Webpage File.” Amazon will interpret this term as an HTML file.
`10.
`Amazon objects to the definition of “Webpage Asset File” as vague and ambiguous,
`2
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 5 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`overly broad, unduly burdensome, and not proportional to the needs of the case, as it does not
`identify the item or feature with specificity. Amazon incorporates by reference its objection to the
`definition of the term “Webpage File.” Amazon will interpret this term as a file served via HTTP.
`11.
`Amazon objects to the definition of “Content-Based ETag” as vague and
`ambiguous, overly broad, unduly burdensome, and not proportional to the needs of the case, as it
`does not identify the item or feature with specificity. Amazon will interpret this term as an ETag
`calculated based on contents of a corresponding file.
`12.
`Amazon objects to the definition of “Fingerprint” as vague and ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case, as it does not identify the
`item or feature with specificity. Amazon will interpret this term as a Ruby on Rails fingerprint or
`a similar value that is calculated via a hash algorithm and that renders the name of a file dependent
`on the contents of the file.
`13.
`Amazon objects to the definition of “Relevant Time Period” as vague and
`ambiguous, overly broad, unduly burdensome, and not proportional to the needs of the case.
`Amazon will interpret this term as referring to the time period January 8, 2012 through December
`26, 2016 only.
`14.
`Amazon objects to the definition of “Indemnified” or “Indemnification” as vague
`and ambiguous, overly broad, unduly burdensome, and failing to describe the information sought
`with reasonable particularity. Amazon will interpret this term to refer to the legal concept of
`indemnification. Amazon will interpret this term to refer to the time period of January 8, 2012 to
`December 26, 2016.
`15.
`Amazon objects to the definition of “Describe in Detail” as overbroad, unduly
`burdensome, oppressive, and not proportional to the needs of the case. Amazon will interpret this
`term as “provide an explanation.”
`16.
`Amazon objects to the definition of “Meeting” as overly broad and unduly
`burdensome, vague and ambiguous, not proportional to the needs of this case, and failing to
`describe the information sought with reasonable particularity.
`17.
`Amazon objects to the definition of “Identify” and “Identity” as overly broad and
`3
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 6 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`unduly burdensome, vague and ambiguous, not proportional to the needs of this case, and failing
`to describe the information sought with reasonable particularity. Amazon will interpret these terms
`as “List the person, entity, or document” and “the name, term, or number referring to the person,
`entity, or document,” respectively.
`18.
`Amazon objects to the interrogatories and definitions contained therein to the extent
`that they seek to impose duties beyond those required by the Federal Rules of Civil Procedure and
`the Local Rules of this district. Amazon’s responses shall be made only in accordance with the
`applicable rule(s).
`19.
`Amazon objects to the interrogatories to the extent that they seek information
`equally available to PersonalWeb in the public domain or that is already in the possession, custody,
`or control of PersonalWeb.
`20.
`Amazon objects to the interrogatories to the extent that they seek information that
`is in the possession, custody, or control of parties over whom Amazon has no control.
`21.
`Amazon objects to each and every instruction, definition, and interrogatory to the
`extent that it seeks the disclosure of information protected by the attorney-client privilege, the
`attorney work-product doctrine, or any other applicable privilege, immunity, or protection, as
`provided by any applicable law. Amazon does not intend to disclose such privileged or protected
`information. Amazon’s inadvertent disclosure of any such information should not be deemed a
`waiver of any privilege, immunity, or protection, and Amazon expressly reserves the right to object
`to the introduction at trial or to any other use of such information that may be inadvertently
`disclosed. Amazon objects to discovery of attorney-client privileged communications after the
`filing of this lawsuit and to discovery of work-product materials generated after the filing of this
`lawsuit. Per the parties’ Joint Preliminary Pretrial Conference Statement, Amazon will not identify
`these privileged or protected materials in a privilege log.
`22.
`The responses given herein shall not be deemed to waive any claim of privilege or
`immunity Amazon may have as to any response, document, or thing, or any question or right of
`objection as to authenticity, competency, relevancy, materiality, admissibility, or any other
`objection Amazon may have as to a demand for further response to these or other Interrogatories,
`4
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 7 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`or to any objection to the use of such information, documents, or things in any other proceeding
`filed after the production of such information or documents.
`23.
`Nothing contained herein may be construed as an admission relative to the existence
`or non-existence of any information, and no response may be construed as an admission with
`respect to the relevancy or admissibility in evidence of any statement or characterization contained
`in the interrogatories or respecting the authenticity, competency, relevancy, materiality, or
`admissibility of any information, document or thing referenced by the interrogatories.
`Discovery in this matter is ongoing and Amazon reserves the right to revise or supplement
`any response herein.
`These General Objections are applicable to and are incorporated in each specific response
`herein without further reference. The inclusion of specific objection(s) in response to any
`interrogatories shall not be construed as a waiver of such objection(s), or any of these objections,
`in any other response.
`
`RESPONSES AND OBJECTIONS
`Subject to the foregoing General Objections, which are incorporated by reference as if set
`forth fully in each and every response, Amazon also specifically responds and objects to the
`Interrogatories as follows:
`INTERROGATORY NO. 2:
`Please Identify every Website Operator Customer for which You are obligated to provide
`Indemnification for any infringement of any patent asserted by PersonalWeb.
`RESPONSE TO INTERROGATORY NO. 2:
`Amazon incorporates by reference its General Objections as if fully set forth herein. To the
`extent this interrogatory seeks information protected by the attorney-client privilege, attorney work-
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Amazon objects to it and will not provide any such
`information in response. If any information responsive to this interrogatory is subject to any
`confidentiality obligations owed by Amazon to any third party, Amazon will provide such
`information only after it complies with those obligations, and, if necessary, only after it obtains the
`5
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 8 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`required permission to do so from the third party. Amazon objects to this interrogatory as unduly
`burdensome to the extent it seeks information that is already known to PersonalWeb.
`Amazon objects to the terms Identify, You, Indemnification, and Website Operator
`Customer, on the bases identified in the General Objections above and incorporates those bases
`herein. Amazon will interpret these phrases to refer to “list the person, entity, or document,”
`“Amazon.com, Inc. and Amazon Web Services, Inc.,” “the legal concept of indemnification,” and
`“customers who used S3 during January 8, 2012 through December 26, 2016,” respectively.
`Amazon also objects to the undefined term “obligated” as vague and ambiguous. Amazon objects
`to the interrogatory to the extent it seeks not facts or contentions in this case, but a legal opinion or
`legal conclusion regarding legal obligations or contractual interpretations. Amazon will interpret
`this interrogatory as seeking identification of entities whose requests for indemnification Amazon
`accepted.
`Amazon objects to this interrogatory as it appears to be an attempt to seek discovery relating
`to the claims in PersonalWeb’s cases that are currently stayed (In re: PersonalWeb Technologies,
`LLC et al., Patent Litigation, No. 18-md-02834-BLF, Dkt. No. 157); such discovery is outside the
`scope of this case, is not proportional to the needs of this case, and is improper. Accordingly,
`Amazon does not intend to provide such discovery in response.
`Subject to and without waiving any objections, Amazon responds as follows: Amazon
`identifies the following entities that, as of November 1, 2018, Amazon is indemnifying with respect
`to PersonalWeb’s claims of infringement:
`Airbnb, Inc.; Atlas Obscura, Inc.; Atlassian, Inc.; BDG Media, Inc.; Bitly, Inc.; Blue Apron,
`Inc.; Braze, Inc.; Brooklyn Brewery Corporation; Buzzfeed, Inc.; Centaur Media USA and
`eConsultancy, Ltd.; Cloud Warmer, Inc.; Cloud 66, Inc.; Curebit, Inc.; Curious.com, Inc.;
`Dictionary.com, LLC; Dollar Shave Club, Inc.; Doximity, Inc.; Fab Commerce & Design, Inc.;
`Our Film Festival d/b/a Fandor, Inc.; FanDuel, Inc. and FanDuel Limited; Fiverr International Ltd.;
`Food52, Inc.; Goldbely, Inc.; Goodreads, LLC; GoPro, Inc.; Imgur, Inc.; Intuit, Inc.; Karma
`Mobility, Inc.; Leap Motion, Inc.; Lesson Nine GmbH; Match Group, LLC and Match Group, Inc.;
`Mavenlink, Inc.; Melian Labs, Inc.; MyFitnessPal, Inc.; NRT LLC and NRT New York LLC d/b/a
`6
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 9 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`Citi Habitats; Panjiva, Inc.; Patreon, Inc.; PayPal, Inc.; Peek Travel, Inc.; Quotient Technology,
`Inc.; Roblox Corporation; ShareFile, LLC; Slack Technologies, Inc.; Spokeo, Inc.; Spongecell,
`Inc.; Square, Inc.; StitchFix, Inc.; TastyTrade, Inc.; Teespring, Inc.; Tophatter, Inc.; Treehouse
`Island, Inc.; TripAdvisor LLC; Twitch Interactive, Inc.; Urban Dictionary, LLC; Vice Media, LLC;
`Vimeo, Inc.; Vox Media, Inc.; Webflow, Inc.; WeddingWire, Inc.; Wework Companies, Inc.; and
`Yotpo Ltd.
`Investigation and discovery are ongoing, and Amazon reserves the right to supplement,
`amend, or modify its response to this interrogatory as additional facts are learned and as otherwise
`appropriate.
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 2 (NOVEMBER 30, 2018):
`Subject to and without waiving any of the objections above or the General Objections, Amazon
`supplements its response as follows: As of November 30, 2018, in addition to the entities identified
`above, Amazon is indemnifying Kongregate, Inc., Strava, Inc., Upwork Global, Inc., and Ziff
`Davis, Inc. with respect to PersonalWeb’s claims of infringement.
`Investigation and discovery are ongoing, and Amazon reserves the right to supplement,
`amend, or modify its response to this interrogatory as additional facts are learned and as otherwise
`appropriate.
`INTERROGATORY NO. 3:
`Please Describe In Detail the full scope of acts covered in the Indemnification identified in
`Interrogatory No. 2, including any acts that are excluded from Indemnification.
`RESPONSE TO INTERROGATORY NO. 3:
`Amazon incorporates by reference its General Objections as if fully set forth herein. To the
`extent this interrogatory seeks information protected by the attorney-client privilege, attorney work-
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Amazon objects to it and will not provide any such
`information in response. If any information responsive to this interrogatory is subject to any
`confidentiality obligations owed by Amazon to any third party, Amazon will provide such
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`7
`
`
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 10 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`information only after it complies with those obligations, and, if necessary, only after it obtains the
`required permission to do so from the third party.
`Amazon objects to the terms Describe in Detail and Indemnification on the bases identified
`in the General Objections above and incorporates those bases herein. Amazon will interpret these
`phrases to refer to “provide an explanation” and “the legal concept of indemnification,”
`respectively. Amazon objects to the interrogatory because rather than seeking facts or contentions
`in this case, it instead seeks a legal opinion or legal conclusion regarding legal obligations or
`contractual interpretations. Amazon objects to this interrogatory as vague and ambiguous as it does
`not define “acts.” Amazon objects to this interrogatory as seeking information not relevant to any
`claim or defense in this action and not proportional to the needs of the case, especially in light of
`information sought by Interrogatory No. 2.
`Investigation and discovery are ongoing, and Amazon reserves the right to supplement,
`amend, or modify its response to this interrogatory as additional facts are learned and as otherwise
`appropriate.
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 3 (NOVEMBER 30, 2018):
`Subject to and without waiving any of the objections above or the General Objections and subject
`to PersonalWeb’s agreement that Amazon’s production of information in response to this
`interrogatory will not waive any applicable privilege, immunity, doctrine or protection (see, e.g.,
`emails from Sandy Seth dated November 26, 2018 and November 27, 2018), Amazon supplements
`its response as follows: Amazon is indemnifying its customers identified in response to
`Interrogatory No. 2 with respect to PersonalWeb’s claims of infringement pursuant to Section 9.2
`of the Amazon Web Services Customer Agreement. Amazon has produced that agreement with
`Bates numbers AMZ_PWT_00006681-6693.
`
`
`
`
`
`
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`8
`
`
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 11 of 13
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`
`
`
`
`
`
`
`
`Investigation and discovery are ongoing, and Amazon reserves the right to supplement,
`amend, or modify its response to this interrogatory as additional facts are learned and as otherwise
`appropriate.
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`9
`
`
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`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
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 12 of 13
`
`
`Dated: November 30, 2018
`
`FENWICK & WEST LLP
`
`Respectfully submitted,
`
`
`
`By: /s/ Saina S. Shamilov
`J. David Hadden (CSB No. 176148)
`Saina S. Shamilov (CSB No. 215636)
`Todd R. Gregorian (CSB No. 236096)
`Phillip J. Haack (CSB No. 262060)
`Ravi R. Ranganath (CSB No. 272981)
`Chieh Tung (CSB No. 318963)
`
`Counsel for AMAZON. COM, INC. and
`AMAZON WEB SERVICES, INC.
`
`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
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`10
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`
`
`

`

`Case 5:18-md-02834-BLF Document 320-3 Filed 12/11/18 Page 13 of 13
`
`
`CERTIFICATE OF SERVICE
`
` I
`
` hereby certify that on this 30th day of November, 2018, a true and correct copy of the
`foregoing document was served on each party through their counsel of record via email.
`
`Michael A. Sherman
`masherman@stubbsalderton.com
`Jeffrey F. Gersh
`jgersh@stubbsalderton.com
`Sandeep Seth
`sseth@stubbsalderton.com
`Wesley W. Monroe
`wmonroe@stubbsalderton.com
`Stanley H. Thompson
`sthompson@stubbsalderton.com
`Viviana Boero Hedrick
`vedrick@stubbsalderton.com
`STUBBS ALDERTON & MARKILES, LLP
`15620 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`
`Counsel for PersonalWeb Technologies, LLC
`
`
`
`Theodore S. Maceiko
`ted@maceikoip.com
`MACEIKO IP
`420 2nd Street
`Manhattan Beach, CA 90266
`
`Counsel for PersonalWeb Technologies, LLC
`
`
`
`/s/ Melanie Mayer
`Melanie Mayer
`
`
`
`
`
`AMAZON’S FIRST SUPPLEMENTAL RESPONSES
`TO PERSONALWEB’S FIRST INTERROGATORIES
`
`11
`
`CASE NO.: 5:18-cv-02834-BLF
`CASE NO.: 5:18-cv-00767-BLF
`
`
`
`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
`
`