Case 5:18-md-02834-BLF Document 504-1 Filed 08/23/19 Page 1 of 13
`Case 5:18—md-02834-BLF Document 504-1 Filed 08/23/19 Page 1 of 13
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 5:18-md-02834-BLF Document 504-1 Filed 08/23/19 Page 2 of 13
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`MICHAEL A. SHERMAN (SBN 94783)
`masherman@stubbsalderton.com
`JEFFREY F. GERSH (SBN 87124)
`jgersh@stubbsalderton.com
`SANDEEP SETH (SBN 195914)
`sseth@stubbsalderton.com
`WESLEY W. MONROE (SBN 149211)
`wmonroe@stubbsalderton.com
`STANLEY H. THOMPSON, JR. (SBN 198825)
`sthompson@stubbsalderton.com
`VIVIANA BOERO HEDRICK (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS, ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`
`Attorneys for PersonalWeb Technologies, LLC
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`CASE NO.: 5:18-md-02834-BLF
`IN RE PERSONAL WEB TECHNOLOGIES,
`LLC, ET., AL., PATENT LITIGATION
`
`
` Plaintiffs,
`
`PERSONALWEB TECHNOLOGIES, LLC,
`et., al.,
`
`v.
`TWITCH INTERACTIVE, INC.,
`
` Defendant.
`
`
`
`
`
`Case No.: 5:18-cv-05619-BLF
`NOTICE OF TAKING DEPOSITION OF
`TWITCH INTERACTIVE, INC.
`PURSUANT TO FED.R.CIV.P. 30(b)(6)
`
`
`Date: June 24, 2019
`Time: 9:00 a.m.
`Place: FENWICK & WEST, LLP
` 1191 Second Avenue, 10th Floor
`
` Seattle, Washington 98101
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`Case 5:18-md-02834-BLF Document 504-1 Filed 08/23/19 Page 3 of 13
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`PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
`Procedure, Plaintiff PersonalWeb Technologies, LLC (“PersonalWeb”), will take the deposition of
`Defendant Twitch Interactive, Inc. (collectively, “Twitch”), through one or more officers, directors,
`managing agents or other representatives, designated to testify on Twitch’s behalf regarding all
`information known or reasonably available to Twitch, with respect to the subject matters identified in
`Exhibit A hereto.
`PersonalWeb requests that Twitch provide written notice at least three (3) business days before
`the deposition of the name(s) and employment position(s) of the individual(s) designated to testify on
`Twitch’s behalf.
`This deposition shall commence on June 24, 2019 at 9:00 a.m. at the offices of Fenwick &
`West LLP, located at 1191 Second Avenue, 10th Floor, Seattle, Washington, 98101, or at such other
`time and location as agreed upon by the parties, and shall be taken before a duly certified court reporter
`and notary public or other person authorized by law to administer oaths. The deposition will be
`recorded by stenographic means and by videotape. Provisions for real time monitoring via Live Note
`or similar facility may also be used. This deposition will continue from day to day, weekend and
`holidays excluded, until completed or adjourned by the attorney conducting the deposition.
`
`Dated: June 14, 2019
`
`STUBBS, ALDERTON & MARKILES, LLP
`
`
`
`By: /s/ Michael A. Sherman
`Michael A. Sherman
`Jeffrey F. Gersh
`Sandeep Seth
`Wesley W. Monroe
`Stanley H. Thompson, Jr.
`Viviana Boero Hedrick
`
`Attorneys for PersonalWeb Technologies, LLC
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`Case 5:18-md-02834-BLF Document 504-1 Filed 08/23/19 Page 4 of 13
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`Dated: June 14, 2019
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`MACEIKO IP
`Theodore S. Maceiko (SBN 150211)
`ted@maceikoip.com
`MACEIKO IP
`420 2nd Street
`Manhattan Beach, California 90266
`Telephone:
`(310) 545-3311
`Facsimile:
`(310) 545-3344
`Attorney for Plaintiff
`PERSONALWEB TECHNOLOGIES, LLC
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`EXHIBIT A
`INSTRUCTIONS
`Unless otherwise specified, all topics are limited to the Relevant Time Period, as defined
`
`below.
`
`In addition to the Federal Rules of Civil Procedure and the Local Rules of this Court, the
`following instructions apply:
`If You believe You encounter any ambiguities when construing a topic or subtopic,
`1.
`instruction, or definition, You should inform us at least three days before the deposition of the matter
`deemed ambiguous and the construction you will be using.
`Where knowledge or information in Your possession is requested, the request extends
`2.
`to knowledge or information in the possession of Your officers, directors, agents, members,
`employees, servants, representatives, and, unless privileged, attorneys.
`If the deponent needs to refer to a document or documents to testify on a topic, that
`3.
`document or those documents should be produced ahead of the deposition and not only brought to
`the deposition.
`
`DEFINITIONS
`Each of these definitions and instructions is incorporated into each of the topics or
`1.
`subtopics to which it pertains. Notwithstanding any definition below, each word, term, or phrase used
`in these interrogatories is intended to have the broadest meaning permitted under the Federal Rules of
`Civil Procedure. The definitions listed herein apply to each defined term regardless of whether the
`first letter of the defined word(s) is or is not capitalized.
`The terms "You," "Your", or "AWS" shall refer to Amazon Web Services, Inc. and (i)
`2.
`any parent, subsidiary (either wholly or partly-owned), subcontractor, division, branch or department
`of AWS; (ii) any entity under control of AWS; (iii) the present and former directors, officers,
`accountants, affiliates, attorneys, agents, employees, in-house and outside counsel or other persons
`under the control of AWS, regardless of their affiliation or employment; and (iv) any other person
`acting or purporting to act on behalf of AWS.
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`The term “Twitch” means Twitch Interactive, Inc. and its Predecessor in interest,
`3.
`Justin.tv, Inc. and (i) any subsidiary (either wholly or partly-owned), division, branch or department
`thereof; (ii) any entity under the control thereof; (iii) the present and former directors, officers,
`accountants, affiliates, attorneys, agents, employees, in-house and outside counsel or other persons
`under the control thereof, regardless of their affiliation or employment; and (iv) any other person
`acting or purporting to act on behalf thereof.
`The term “Predecessors” means any business entity, whether or not incorporated, which
`4.
`had all or some of its assets purchased by Defendant or came to be acquired by Defendant whether by
`merger, consolidation, or other means.
`The term “Subsidiaries” means any business entity, whether or not incorporated, which
`5.
`is or was in any way owned or controlled, in whole or in part by Defendant or its predecessors.
`The term “Any” means “one or more” and includes and encompasses “each” and “all.”
`6.
`7.
`The term “’791 patent” means U.S. Patent No. 5,978,791.
`8.
`The term “’442 patent” means U.S. Patent No. 6,928,442.
`9.
`The term “’310 patent” means U.S. Patent No. 7,802,310.
`10.
`The term “’544 patent” means U.S. Patent No. 7,954,544.
`11.
`The term “’420 patent” means U.S. Patent No. 8,099,420.
`12.
`The term “patents-in-suit” means, collectively, the ‘791 patent, the ‘442 patent, the
`‘310 patent, the ‘544 patent, and the ‘420 patent. Requests referring to “each of the patents-in-suit”
`(or each asserted claim in the patents-in-suit”) require responsive documents for each of the ‘791
`patent, the ‘442 patent, the ‘310 patent, the ‘544 patent, and the ‘420 patent.
`The term “asserted claims” means the claims of the patents-in-suit identified in
`13.
`PersonalWeb’s infringement contentions served in this action.
`The term “S3 System” is used herein to refer to the same system identified at paragraph
`14.
`13 of Your First Amended Complaint filed in Case No. 5:18-cv-00767-BLF which states: “Amongst
`these products and services is the Amazon Simple Storage Service (‘S3’). S3 is a web storage offering.
`By using S3, developers can access highly scalable, reliable, fast and inexpensive data storage
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`infrastructure similar to what Amazon itself uses to run its own global network of websites.”
`The term “Twitch platform” is used herein to refer to the live streaming video platform
`15.
`owned by Twitch Interactive, a subsidiary of Amazon, which currently focuses on video gaming; live
`streaming, including broadcasts of small eSports competition in addition to music broadcasts; creative
`content; and, more recently, ”in real life” screens which can be viewed either live or via video on
`demand. Twitch services includes all sources of monetization of the Twitch platform, including via
`subscription, advertising, or otherwise.
`The Term “HTTP” means Hypertext Transfer Protocol 1.1.”
`16.
`17.
`The term “HTTP GET Request” means a GET request under the HTTP 1.1 protocol.
`18.
`The term “Conditional HTTP GET Request” means a conditional GET request under
`the HTTP 1.1 protocol such as a GET message with an “IF-NONE-MATCH” header with an ETag
`value.
`
` The term “HTTP 200” message means a 200 message under the HTTP 1.1 protocol.
`19.
`The term “HTTP 304” message means a 304 message under the HTTP 1.1 protocol.
`20.
`The term “Relevant Time Period” means from January 8, 2012 to December 26, 2016.
`21.
`The term “Document,” is synonymous in meaning and equal in scope to the usage of
`22.
`the phrase, “documents and tangible things,” in Rules 26 and 34 of the Federal Rules of Civil
`Procedure. A draft or a non-identical is a separate document within the meaning of this term. The
`term includes documents that are now or were formerly in Your possession, custody, or control of
`Defendant and include, by way of example only, any memorandum, request envelope, correspondence,
`electronic mail, report, note, Post-It, message, telephone message, telephone log, diary, journal,
`appointment calendar, calendar, group scheduler calendar; drawing, painting, accounting paper,
`minutes, working paper, financial report, accounting report, work papers, drafts, facsimile, facsimile
`transmission report, contract, invoice, record of sale or purchase, Teletype message, chart, graph,
`index, directory, computer directory, computer disk, computer tape, or any other written, printed,
`typed, punched, taped, filmed, or graphic matter however produced or reproduced. Documents also
`include the file, folder tabs, and labels appended to or containing Any Document or Things.
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`The term “Person” includes natural persons, firms, partnerships, associations, joint
`23.
`ventures, corporations, and any other form of business organization or arrangement, as well as officers,
`directors, shareholders, employees, agents, attorneys and contractors thereof.
`The term “Meeting” means any act or process of persons coming together for the
`24.
`purpose of discussing and/or acting upon some matter, whether such gathering was formal or informal,
`in person or through other means.
`The term “Thing” refers to any tangible object, other than a document, and includes
`25.
`objects of every kind and nature, including, but not limited to, prototypes, models, and specimens.
`The term “Communication” means any oral, written, electronic, or other exchange of
`26.
`words, thoughts, information, or ideas to another person or entity, whether in person, in a group, by
`telephone, by letter, by Telex, by facsimile, or by any other process, electric, electronic, or otherwise.
`All such communications in writing shall include, without limitation, printed, typed, handwritten, or
`other readable documents, correspondence, memoranda, reports, contracts, drafts (both initial and
`subsequent), computer discs or transmissions, e-mails, instant messages, tape or video recordings,
`voicemails, diaries, log books, minutes, notes, studies, surveys and forecasts, and any and all copies
`thereof.
`The term “Agreement’ means a contract, arrangement, or understanding, formal or
`27.
`informal, oral or written, between two or more persons.
`The term “Any” means one or more.
`28.
`29.
`The term “Cache-Busting” means indicating to a browser that a different version of a
`file than it may have cached is valid and available.
`The term “DI License” means the License Agreement Between Kinetech, Inc. and
`30.
`Digital Island, Inc., dated September 1, 2000, produced in this case with control numbers
`PERSONALWEB006795-6816.
`The term “Level 3 Field of Use” means the “DI Field of Use” as defined in Schedule
`31.
`1.2 of the DI License.
`Any word not specifically defined above is to be given its meaning as contained in the
`32.
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
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`most recent edition of the American Heritage Dictionary, published by the Houghton Mifflin
`Company.
`The definitions stated above shall also apply to other grammatical forms of the word
`33.
`defined, such as singular or plural, masculine or feminine, and various verb tenses.
`
`MATTERS FOR EXAMINATION PURSUANT TO FED.R.CIV.P. 30(B)(6)
`Pursuant to Fed.R.Civ.P. 30(b)(6), AWS is required to designate one or more of its officers,
`directors, managing agents or other representatives to testify on its behalf as to information known or
`reasonably available to Amazon, on the following topics:
`The Inception of the Twitch Platform and Services
`1.
`How you came to Your decision to offer the Twitch platform and the services
`(a)
`you provide via the Twitch platform.
`All the financial and business reasons why You chose to offer the Twitch
`(b)
`platform and services.
`Your projected revenues, profits, and anticipated or projected changes in the
`(c)
`value of Amazon.com, Inc. or AWS from offering the Twitch platform and services when You decided
`to sell them to Amazon.
`The Twitch platform and Related Services
`2.
`(a) What services You offer via the Twitch platform.
`How much you charge for the use of the Twitch platform and services.
`(b)
`(c) What revenue streams are generated directly or indirectly from the Twitch
`platform and services, including but not limited to through advertising and subscriptions.
`The Commercial Success of the Twitch Platform and Services
`3.
`Your current valuation of the Twitch platform and services.
`(a)
`(b)
`All revenue sources derived from the Twitch platform and services.
`(c)
`The total revenues You have generated the Twitch platform and services.
`The Use of Content-Based Identifiers in the Twitch Platform & Services
`How the Twitch platform stores and serves webpage files, whether in
`(a)
`
`4.
`
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
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`conjunction with CloudFront servers or other servers;
`How and why content-based identifiers such as content-based ETags or
`(b)
`fingerprints are generated and used in the Twitch platform;
`The type of operations or transactions in which they are used;
`(c)
`(d)
`The parameters of such operations or transactions;
`(e)
`The purposes of such operations or transactions;
`(f)
`How such operations or transactions are controlled by Twitch;
`(g)
`How the Twitch platform processes HTTP GET requests and conditional HTTP
`GET requests for webpage files;
`How and when content-based ETags are used in such requests and in processing
`(h)
`HTTP GET requests and conditional HTTP GET requests for webpage files;
`The parameters used in controlling how and when such HTTP GET requests
`(i)
`and conditional HTTP GET requests for webpage files are made or processed;
`The purposes of such parameters;
`(j)
`(k)
`How You control such parameters;
`(l)
`The names of the servers, code functions/routines/modules involved in the
`generation or use of content-based identifiers including content-based ETags and fingerprints and the
`processing thereof in HTTP GET requests and conditional HTTP GET requests by the Twitch
`platform;
`
`The use of content-based ETags or fingerprints in connection with cache
`(m)
`busting or cache control features;
`The manner in which such features use ETags or fingerprints to implement
`(n)
`cache busting or cache control features;
`The benefits of such use of ETags and fingerprints;
`(o)
`(p)
`How Twitch control for how long of a duration a web browser can access a file
`served from CloudFront without receiving any further HTTP; and
`(q) What kinds of HTTP messages a web browser first must receive from Twitch
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`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
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`before it authorized to reuse a cached file.
`Revenue Streams From The Twitch platform and Related Services
`5.
`How Twitch calculates charges to third parties who use the Twitch platform or
`(a)
`
`services;
`
`platform;
`
`(b)
`(c)
`
`The total direct and indirect gross and net revenues generated by Twitch;
`All revenue streams derived from your acquisition and operation of the Twitch
`
`6.
`
`The total revenues generated therefrom; and
`(d)
`Twitch revenue forecasts.
`(e)
`Avoidance of Infringement
`Your policies to avoid infringement of the intellectual property right of third-
`(a)
`parties, including specifically third-party patent rights;
`(b) When you first had knowledge of any of the patents-in-suit;
`(c) Whether You investigated any of the patents-in-suit in connection with Your
`development of the accused instrumentality;
`(d) What steps You took to investigate whether any claims of the patents-in-suit
`were infringed by Your accused instrumentality (e.g., freedom to operate analysis);
`The persons involved in and the documents reflecting such review and/or
`(e)
`
`investigation;
`
`(f) What steps You took, if any, to develop, review and/or investigate any alternate
`system or service other than Your accused instrumentality because of Your knowledge of the patents-
`in-suit;
`
`The benefits of Your customers or end users from Your use of content-based
`(g)
`ETags generated by the Twitch platform or the S3 system;
`How Your website operator customers use and control the use by browsers of
`(h)
`content-based ETags generated by the Twitch platform or the S3 system; and
`How website operator customers interface with Amazon’s Twitch platform,
`(i)
`
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`including the identity of the software code that interfaces the website operator customers with
`CloudFront software.
`Identity of Witnesses
`7.
`Who the persons are within the Twitch organization that have had the most knowledge
`at various times regarding: (a) technology development as it relates to cache control/cache busting; (b)
`any alternative to the cache control/cache busting technology that was used; (c) the various uses of
`content-based identifiers within CloudFront and generation of content-based identifiers by CloudFront
`(if any); and (d) each topic in this notice.
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`PROOF OF SERVICE
`
`I declare as follows:
`
` I
`
` am employed in the office of a member of the bar of this court at whose direction the service
`was made within the County of Los Angeles, State of California. I am over the age of 18 and not a
`party to the within action. My business address is 15260 Ventura Blvd., 20th Floor, Sherman Oaks,
`California 91403.
`
`On June 14, 2019, I served the documents described as: NOTICE OF TAKING
`DEPOSITION OF TWITCH INTERACTIVE, INC. PURSUANT TO FED.R.CIV.P. 30(b)(6)
`on the interested parties in this action as follows:
`
`
`Todd R. Gregorian
`tgregorian@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`FENWICK & WEST LLP
`NDCA Case No. 5:18-cv-00767-BLF
`Attorney for Defendant Twitch Interactive, Inc.
`
`BY U.S. MAIL: By depositing for collection and mailing in the ordinary course of
`business. I am “readily familiar” with the firm’s practice of collection and processing
`correspondence for mailing. Under that practice it would be deposited with U.S. Postal
`Service on the same day with postage thereon fully prepaid at Sherman Oaks,
`California in the ordinary course of business. I am aware that on motion of the party
`served, service is presumed invalid if postal cancellation date or postage meter date is
`more than one day after date of deposit for mailing on affidavit.
`BY ELECTRONIC MAIL: Pursuant to stipulation for e-mail service reached with
`counsel of record, I served the above documents to the emails listed in the service
`caption above. A true and correct copy of the transmittal will be produced if requested
`by any party or the court.
`
`
`
`
`
` I
`
` declare under penalty of perjury under the laws of the United States of America that the
`above is true and correct.
`
`Executed on June 14, 2019, at Sherman Oaks, California.
`
`
`
`
`
`
`/s/ Elizabeth Saál de Casas
` Elizabeth Saal de Casas
`
`
`
`
`NOTICE OF TAKING 30(B)(6) DEPOSITION OF
`TWITCH INTERACTIVE, INC.
`
`11
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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