Case 5:18-md-02834-BLF Document 659-4 Filed 04/26/21 Page 1 of 12
`Case 5:18—md-02834-BLF Document 659-4 Filed 04/26/21 Page 1 of 12
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`EXHIBIT D
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`EXHIBIT D
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`Case 5:18-md-02834-BLF Document 659-4 Filed 04/26/21 Page 2 of 12
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`
`
`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`MELANIE L. MAYER (admitted pro hac vice)
`mmayer@fenwick.com
`TODD R. GREGORIAN (CSB No. 236096)
`tgregorian@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.,
`AMAZON WEB SERVICES, INC., and
`TWITCH INTERACTIVE, INC.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`Case No.: 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
`
`AMAZON.COM, INC., AMAZON WEB
`SERVICES, INC., AND TWITCH
`INTERACTIVE INC.’S FIRST SET OF
`REQUESTS FOR PRODUCTION OF
`DOCUMENTS TO PERSONALWEB
`TECHNOLOGIES, LLC PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
`IN RE: PERSONAL WEB TECHNOLOGIES,
`LLC ET AL., PATENT LITIGATION
`
`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,
`
`Plaintiffs,
`
`v.
`
`TWITCH INTERACTIVE, INC.,
`
`Defendant.
`
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
`
`
`
`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`ATTORNEYS AT LAW
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`FENWICK & WEST LLP
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`

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`Case 5:18-md-02834-BLF Document 659-4 Filed 04/26/21 Page 3 of 12
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`PROPOUNDING PARTY:
`
`Amazon.com, Inc., Amazon Web Services, Inc., and Twitch
`Interactive, Inc.
`
`RESPONDING PARTY:
`SET NO:
`
`
`
`
`
`PersonalWeb Technologies, LLC
`One (Nos. 1–43)
`
`In accordance with Rules 26, 34, and 69 of the Federal Rules of Civil Procedure and
`California Code of Civil Procedure § 708.030, Plaintiffs Amazon.com, Inc., Amazon Web Services,
`Inc., and Twitch Interactive, Inc. request that PersonalWeb Technologies, LLC provide a written
`response to each of the following requests and produce the documents and things described below
`for inspection and copying, in accordance with the following instructions and definitions, at the
`offices of Fenwick & West LLP, 555 California Street, San Francisco, CA 94104, within thirty (30)
`days of service hereof, or at such other time and location as may be mutually agreed upon by the
`parties.
`
`DEFINITIONS
`1.
`The following definitions shall apply to each of the requests contained below.
`Terms not specifically defined below shall have their ordinary and usual meanings.
`2.
`“PersonalWeb” means PersonalWeb Technologies, LLC, and its predecessors,
`parents, subsidiaries, divisions, officers, employees, agents, principals, beneficial owners, and
`attorneys, and each Person acting or purporting to act on its behalf or under its control.
`3.
`“Person” includes any individual, trust, estate, business entity (including but not
`limited to sole proprietorship, partnership, joint venture, company, or corporation), organization,
`association, group, government, or governmental body (including but not limited to any
`governmental agent, representative, agency, bureau, department, committee, or commission).
`4.
`“Document” means any items described in Federal Rule of Civil Procedure 34(a)
`and any “writings” within the meaning of Federal Rule of Evidence 1001, and all preliminary and
`final drafts of any such items.
`5.
`“Concerning” means “evidencing, constituting, comprising, pertaining to, referring
`to, relating to, mentioning, or reflecting.”
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
`
`2
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`ATTORNEYS AT LAW
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`FENWICK & WEST LLP
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`Case 5:18-md-02834-BLF Document 659-4 Filed 04/26/21 Page 4 of 12
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`6.
`The terms “or” and “and” shall be construed in the conjunctive and in the disjunctive
`when they appear, and neither of these words shall be interpreted to limit the scope of these requests.
`7.
`The terms “any” or “each” shall be construed to include and encompass “all,” and the
`term “all” means any and all.
`8.
`The use of a verb in any tense shall be construed as the use of the verb in all other
`
`tenses.
`
`9.
`The singular form of any word shall be construed to include the plural. The plural
`form of any word shall be construed to include the singular.
`
`INSTRUCTIONS
`1.
`In answering the following requests, furnish all available information including
`information in the possession, custody, or control of you or any of your attorneys, agents,
`employees, representatives, associates, investigators, affiliates, partners, partnerships, and persons
`under your control.
`2.
`Selection of Documents from files and other sources and numbering of such
`Documents shall be performed in such a manner as to ensure that the source and order of each
`Document may be determined, if necessary.
`3.
`File folders with tabs or labels or directories of files identifying Documents must be
`produced intact with such Documents.
`4.
`Documents attached to or associated with each other shall be produced together and
`not separated.
`5.
`Documents shall be produced with control numbers permitting identification of
`particular documents and pages by their assigned number.
`6.
`Where a claim of privilege is asserted in responding or objecting to any of these
`requests and information is not provided on the basis of such assertion:
`a.
`the party or attorney asserting the privilege shall in the response or objection
`to the discovery request identify the nature of the privilege (including work product) which is being
`claimed and, if the privilege is being asserted in connection with a claim or defense governed by
`state law, indicate the state’s privilege rule being invoked;
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
`
`3
`
`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`the following information shall be provided in the response or objection,
`b.
`unless divulgence of such information would cause disclosure of privileged information: (i) the
`date of the Document or, if no date is indicated, an estimate of that date; (ii) type (form, format,
`and medium) of the Document; (iii) the subject matter as described on the Document or, if no such
`description appears, then some other description sufficient to identify the subject matter of the
`Document; (iv) the name and address of each person who prepared it; (v) the name and address of
`each person to whom it was addressed, copied, directed, or provided; (vi) the name and address of
`each person for whom it was prepared; (vii) the name and address of each person receiving or
`reviewing it; (viii) the name and address of each person now in possession of any copies or versions
`of the Document; and (ix) the particular request to which such Document is responsive.
`7.
`If your response to a particular Document request is a statement that you lack the
`ability to comply with that request, you must specify whether the inability to comply is because the
`particular Document or category of information never existed; has been destroyed; has been lost,
`misplaced, or stolen; or has never been, or is no longer, in your possession, custody, or control, in
`which case the name and address of any person or entity known or believed by you to have
`possession, custody, or control of that Document or category of information must be identified.
`8.
`If you contend certain Document requests require disclosure of trade secret or other
`confidential research, development, or commercial information, please mark them as such or as
`required by the protective order in this action.
`
`DOCUMENT REQUESTS
`
`REQUEST NO. 1:
`All documents concerning PersonalWeb’s corporate charters, incorporation, qualifications
`to do business, by-laws, and minutes (including but not limited to board and committee minutes
`and resolutions).
`REQUEST NO. 2:
`All documents concerning PersonalWeb’s business licenses in any jurisdiction.
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
`
`4
`
`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`REQUEST NO. 3:
`All documents concerning contracts or agreements to which PersonalWeb is or ever has
`been a party, a beneficiary, a successor in interest, or a predecessor in interest.
`REQUEST NO. 4:
`All documents concerning contracts or agreements ever in the possession of PersonalWeb.
`REQUEST NO. 5:
`All documents concerning contracts or agreements for the benefit of PersonalWeb.
`REQUEST NO. 6:
`All documents concerning employment by PersonalWeb of any person.
`REQUEST NO. 7:
`All documents concerning powers of attorney or an attorney-in-fact concerning
`PersonalWeb.
`REQUEST NO. 8:
`All documents concerning partnerships, limited liability companies, trusts, joint ventures,
`or other entities in which PersonalWeb has ever had an interest or has participated.
`REQUEST NO. 9:
`All documents concerning PersonalWeb’s parent companies, subsidiary companies,
`affiliated companies, companies under common ownership, predecessors in interest, and
`successors in interest.
`REQUEST NO. 10:
`All documents concerning annuities, installment contracts, trusts, or financial accounts in
`which PersonalWeb has ever had any legal, beneficial, or equitable interest.
`REQUEST NO. 11:
`All documents concerning guarantees by, for, or arranged by PersonalWeb.
`REQUEST NO. 12:
`All documents concerning the authority of any person to act on behalf of PersonalWeb
`(including but not limited to authority to sign or execute documents, authority to make payments
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
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`5
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`or transfers, authority to receive or dispose of any item or matter, authority to bind, authority to
`supervise actions, or authority to engage in any conduct).
`REQUEST NO. 13:
`All documents concerning PersonalWeb’s financial statements (including but not limited
`to balance sheets, profit and loss statements, earnings statements, reconciliation reports and
`operating statements).
`REQUEST NO. 14:
`All documents concerning PersonalWeb’s accounting records or bookkeeping records
`(including but not limited to computerized or digital records or data and records maintained in
`non-digital formats or media, including paper).
`REQUEST NO. 15:
`All documents concerning accounts of, or for the benefit of, PersonalWeb or any person
`employed by or in a business relationship with PersonalWeb at any time (including but not
`limited to bank accounts, credit card accounts, brokerage accounts, investment accounts,
`retirement accounts, pension accounts, lease accounts, Internet or other online service accounts,
`utility accounts, alarm or security service accounts, cable or satellite television accounts, domain
`name accounts, mortgages, and lines of credit).
`REQUEST NO. 16:
`All documents concerning PersonalWeb’s taxes or tax filings in any jurisdiction
`(including but not limited to income taxes, withholding, payroll taxes, employment taxes, sales or
`use taxes, business taxes, and occupation taxes; and including but not limited to all schedules,
`extension requests, estimated taxes, transmittals, and tax payments).
`REQUEST NO. 17:
`All documents concerning insurance policies or coverage (including but not limited to
`homeowners insurance, commercial (or comprehensive) general liability insurance, media perils
`insurance, cyber liability insurance, network risk insurance, umbrella or excess insurance, car
`insurance, renters insurance, life insurance, health (including dental and vision) insurance,
`disability insurance, unemployment insurance, long-term care insurance), in which PersonalWeb
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
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`6
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`is an insured (named or additional insured), for which PersonalWeb has paid any premiums, or in
`which PersonalWeb is a beneficiary.
`REQUEST NO. 18:
`All documents evidencing PersonalWeb’s revenues, disbursements, expenses, profits, and
`losses from January 1, 2016 to present.
`REQUEST NO. 19:
`All documents concerning contracts, agreements, receipts, payments, sales, purchases,
`distributions, transfers, loans, leases, pledges, hypothecations, bailments, rentals, leases, loans,
`mortgages, securities, investments, collateral, and other transactions involving, to, by, for, for the
`benefit of, or on behalf of PersonalWeb, regarding anything of value (including but not limited to
`drafts, execution documents, transmittals, communications, records, receipts, bills of sale,
`purchase orders, invoices, letters of credit, loan documents, bank statements, credit card
`statements, bank reconciliation reports, check registers, deposit slips, duplicates, facsimiles,
`photocopies, and cancelled checks) from January 1, 2016 to present.
`REQUEST NO. 20:
`All documents concerning payments or transfers of anything of value by PersonalWeb to
`any person or entity on behalf of, or for the benefit of, any person or entity other than
`PersonalWeb.
`REQUEST NO. 21:
`All documents concerning receipts of anything of value or tokens of anything of value by
`PersonalWeb for the benefit of any other person or entity.
`REQUEST NO. 22:
`All documents concerning values of PersonalWeb’s business or any segment, asset or
`liability of its business (including but not limited to documents concerning formal or informal
`appraisals, valuations, estimates of value, suggested prices or values, market prices, offers or
`demands, proposals, invitations, or pro forma indications or characterizations of value).
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
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`7
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`REQUEST NO. 23:
`All documents concerning assets acquired by any person with proceeds from
`PersonalWeb.
`REQUEST NO. 24:
`All documents concerning the use or disposition (permanent or temporary) of any
`business proceeds of PersonalWeb.
`REQUEST NO. 25:
`All documents concerning any credit of PersonalWeb (including but not limited to credit
`lines, credit limits, retainers, prepayments, and security for payment).
`REQUEST NO. 26:
`All documents any debts of PersonalWeb.
`REQUEST NO. 27:
`All documents concerning any debt collection efforts against or by PersonalWeb.
`REQUEST NO. 28:
`All documents concerning any expenses of PersonalWeb, including prepaid expenses and
`accrued expenses.
`REQUEST NO. 29:
`All documents concerning any accrued or deferred assets, revenue, proceeds, payments,
`expenses, liabilities, or obligations, in relation to PersonalWeb.
`REQUEST NO. 30:
`All documents concerning all credit cards and credit card accounts used by any person or
`entity for the benefit of PersonalWeb.
`REQUEST NO. 31:
`All documents concerning all credit cards and credit card accounts in the name of
`PersonalWeb and used for the benefit of any person or entity.
`
`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
`
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`8
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`REQUEST NO. 32:
`All documents concerning real property owned, occupied, possessed, controlled, leased,
`rented, or used by PersonalWeb (including persons acting as employees, contractors, or agents of
`PersonalWeb) since January 1, 2018.
`REQUEST NO. 33:
`All documents concerning personal property owned, possessed, controlled, leased, rented,
`lent, borrowed, or used by PersonalWeb (including persons acting as employees, contractors, or
`agents of PersonalWeb) since January 1, 2018 (including but not limited to documents concerning
`transactions concerning personal property and locations of personal property).
`REQUEST NO. 34:
`All documents concerning the sending of anything of value by or on behalf of
`PersonalWeb outside the United States.
`REQUEST NO. 35:
`All documents concerning any interests of PersonalWeb in any things of value.
`REQUEST NO. 36:
`All documents concerning any safe or strongbox, or its contents at any other location or
`premises occupied, used, controlled, or available to PersonalWeb or any PersonalWeb employee
`or contractor.
`REQUEST NO. 37:
`All documents concerning any safe deposit box, or its contents, controlled by
`PersonalWeb, used for any PersonalWeb property or purpose, or accessible to any PersonalWeb
`employee or contractor.
`REQUEST NO. 38:
`All documents concerning personal property of any person at any address of property
`occupied or used by PersonalWeb at any time, including but not limited to currency; specie;
`bullion; commodities; gold, silver, or other precious metals; jewelry (including watches) and
`gemstones; securities (including but not limited to bearer securities); certificates (including
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`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
`
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`certificates of deposit); firearms and other weapons; gaming tokens and casino chips; or evidence
`of indebtedness.
`REQUEST NO. 39:
`All documents concerning Bitcoin or other cryptocurrency and PersonalWeb.
`REQUEST NO. 40:
`All documents concerning leases or rentals of personal property (including payments for
`leases or rentals, and including personal property or PersonalWeb or any other person or entity).
`REQUEST NO. 41:
`All documents, not previously produced, concerning copyrights, patents, trademarks,
`domain names, publicity rights, trade secrets, domain names, or other intangible rights or interests
`owned, controlled, administered, managed, possessed, used, commercialized, monetized,
`exploited, transferred, licensed, hypothecated, pledged, or otherwise acted upon by PersonalWeb.
`REQUEST NO. 42:
`All documents concerning communications with any accountant, auditor, tax professional,
`asset protection advisor, financial institution, creditor, debt collector, in relation to PersonalWeb.
`REQUEST NO. 43:
`All documents concerning travel by or on behalf of PersonalWeb outside the United
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`States.
`
`Dated: April 19, 2021
`
`FENWICK & WEST LLP
`
`By:
`/s/ Todd R. Gregorian
`Todd R. Gregorian
`Attorneys for Plaintiffs
`AMAZON.COM, INC.,
`AMAZON WEB SERVICES, INC., and
`TWITCH INTERACTIVE, INC.
`
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`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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`FENWICK & WEST LLP
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`Case 5:18-md-02834-BLF Document 659-4 Filed 04/26/21 Page 12 of 12
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`CERTIFICATE OF SERVICE
`I hereby certify that on this 19th day of April, 2021, 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
`vhedrick@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/ Margaret E. Vertin
`Margaret E. Vertin
`
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`AMAZON’S FIRST SET OF REQUESTS FOR
`PRODUCTION TO PERSONALWEB PURSUANT
`TO FRCP 69 AND CCP § 708.030
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`
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`Case No. 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
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