Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 1 of 9
`Case 5:20-cv-05676—EJD Document 42-13 Filed 12/07/20 Page 1 of 9
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`EXHIBIT K
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`EXHIBIT K
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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 2 of 9
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`DEMARAY LLC,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD (A
`KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC., and
`SAMSUNG AUSTIN SEMICONDUCTOR,
`LLC,
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`Defendants.
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`Case No. 6:20-cv-00636-ADA
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`DEMARAY LLC’S TRANSFER-RELATED INTERROGATORIES TO
`SAMSUNG DEFENDANTS
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00634-ADA)
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`

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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 3 of 9
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`Pursuant to Federal Rules of Civil Procedure 26 and 33, Local Rule 33, the Court’s
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`Standing Order Regarding Venue and Jurisdictional Discovery Limits for Patent Cases, the
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`Court’s Order Governing Proceedings – Patent Case (Version 3.2), and the Court’s Scheduling
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`Order in this case, Plaintiff Demaray LLC (“Demaray”) requests that Defendants Samsung
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`Electronics Co., Ltd. (“SEC”), Samsung Electronics America, Inc. (“SEA”), Samsung
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`Semiconductor, Inc. (“SSI”), and Samsung Austin Semiconductor, LLC (“SAS”) (collectively,
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`“Samsung”) serve a written response and produce for examination, inspection, and copying by
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`Demaray the documents and tangible things in the categories specified below, within fourteen (14)
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`days after service hereof, at the offices of Irell & Manella, LLP, 1800 Avenue of the Stars, Suite
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`900, Los Angeles, CA 90067.
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`DEFINITIONS
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`Each of these definitions and instructions is incorporated into each of the interrogatories to
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`which it pertains.
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`1.
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`“You,” “your,” and “Samsung” mean Samsung, and all predecessors, subsidiaries,
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`parents, and affiliates, and all past or present directors, officers, agents, representatives,
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`employees, consultants, attorneys, entities acting in joint-venture or partnership relationships with
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`Samsung, and others acting on behalf of Samsung.
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`2.
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`“SAS” means Samsung Austin Semiconductor, LLC, and all predecessors,
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`subsidiaries, parents, and affiliates, and all past or present directors, officers, agents,
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`representatives, employees, consultants, attorneys, entities acting in joint-venture or partnership
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`relationships with SAS, and others acting on behalf of SAS.
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`3.
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`The term “Samsung RMS PVD chamber” refers to any reactor chamber used for
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`physical vapor deposition (“PVD”) of a thin film using reactive magnetron sputtering (“RMS”)
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`used in the production of Samsung semiconductor products, or research related thereto, in the last
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`six years from the filing of Demaray’s Complaint.
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`4.
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`The term “Samsung semiconductor products” refers to all Samsung semiconductor
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`products that include at least one layer of material deposited with a Samsung RMS PVD chamber.
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 4 of 9
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`5.
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`The term “person” refers to any natural person, firm, association, organization,
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`partnership, sole proprietorship, business trust, corporation or public entity.
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`6.
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`The terms “document” or “documents” are used herein in their customary broad
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`sense, and mean any kind of printed, recorded, written, graphic, or photographic matter (including
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`tape recordings), however printed, produced, reproduced, coded or stored, of any kind or
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`description, whether sent or received or not, including originals, copies, drafts, and both sides
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`thereof, and including papers, books, charts, graphs, photographs, drawings, correspondence,
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`telegrams, cables, telex messages, memoranda, notes, notations, work papers, routing slips, intra
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`and inter-office communications, electronic mail, affidavits, statements, opinions, court pleadings,
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`reports, indices, studies, analyses, forecasts, evaluations, contracts, computer printouts, data
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`processing input and output, computer programs, microfilms, microfiche, all other records kept by
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`electronic, photographic, or mechanical means, and things similar to any of the foregoing,
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`regardless of their author or origin, or any kind.
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`7.
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`The terms “and” and “or” are terms of inclusion and not of exclusion and are to be
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`construed either disjunctively or conjunctively as necessary to bring within the scope of these
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`requests any documents or responses which might otherwise be construed to be outside their
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`scope.
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`8.
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`Nouns, whether singular or plural herein, shall be construed either as singular or
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`plural as necessary to bring within the scope of these requests any documents or responses which
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`might otherwise be construed to be outside their scope.
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`9.
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`The term “including” means “including without limitation,” as appropriate, so as to
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`bring within the scope of the discovery request all responses that might otherwise be construed to
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`be outside of its scope. The term “all” means “any and all,” as appropriate.
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`INSTRUCTIONS
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`1.
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`In answering the following Interrogatories, you are instructed to furnish all
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`available information, including information in the possession, custody or control of any of
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`Samsung’s attorneys, directors, officers, agents, employees, representatives, associates,
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`investigators, divisions, affiliates, partnerships, parents, subsidiaries and person under Samsung’s
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`

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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 5 of 9
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`control, who have the best knowledge, not merely information known to Samsung based on
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`Samsung’s personal knowledge. Information is within your possession, custody, or control if, as a
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`practical matter, you have the ability, upon request, to obtain the information.
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`2.
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`If you cannot fully respond to the following Interrogatories after exercising due
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`diligence to secure the information requested thereby, so state, and specify the portion of each
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`Interrogatory that cannot be responded to fully and completely. State what efforts were made to
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`obtain the requested information and the facts relied upon that support the contention that the
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`Interrogatory cannot be answered fully and completely; and state what knowledge, information or
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`belief Samsung has concerning the unanswered portion of any such Interrogatory.
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`3.
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`If you produce documents in connection with these Interrogatories:
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`a. The documents produced should be organized and labeled to correspond to
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`the categories in these Interrogatories.
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`b. Alternatively, if documents are produced as they are kept in the usual course
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`of business, you should provide documents sufficient to show that the
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`documents produced have been produced as they are kept in the usual course
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`of business.
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`4.
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`If you withhold any information requested on grounds that it is protected from
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`discovery by the attorney-client privilege, work-product doctrine, or other privilege, you must
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`furnish a log providing the following information for each item of information withheld:
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`a. the reason for withholding the document;
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`b. the type of document;
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`c. the subject matter of the document;
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`d. the date of the document;
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`e. the name, organization, and position, if any, of each author, sender, and
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`recipient of the document;
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`f.
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`the name of the current or last known custodian of each such document; and
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`g. if work-product is asserted, the proceeding for which the document was
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`created.
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 6 of 9
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`5.
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`If Samsung’s response to a particular Interrogatory is a statement that it lacks the
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`ability to comply with that Interrogatory, Samsung shall specify whether the inability to comply is
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`because the particular item or category of information never existed, has been destroyed, has been
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`lost, misplaced or stolen, or has never been or is no longer in Samsung’s possession, custody or
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`control. Samsung shall identify the name and address of any person or entity known or believed by
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`Samsung to have possession, custody or control of that information or category of information.
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`6.
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`If part of any Interrogatory is objected to, please furnish information responsive to
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`the remainder of the Interrogatory.
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`7.
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`These Interrogatories are continuing. Pursuant to Rule 26(e) of the Federal Rules of
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`Civil Procedure, additional documents or information that become known to you at any time
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`hereafter must be furnished to Demaray within a reasonable time.
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`INTERROGATORIES
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`TRANSFER INTERROGATORY NO. 1:
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`Identify each reactor with a Samsung RMS PVD chamber, including, but not limited to:
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`a) the reactor model number and serial number;
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`b) where such reactors are located;
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`c) manufacturer, purchase date, and dates of service of each reactor;
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`d) the number and types of chambers;
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`e) the power source(s) configured to be coupled to the target for each PVD chamber;
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`f)
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`the power source(s) configured to be coupled to the substrate for each PVD chamber;
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`g) any filters configured to be used with the power sources for each PVD chamber; and,
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`h) Samsung’s use of the reactor, including, but not limited to, whether the reactor is used
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`in production of Samsung semiconductor products, for research and development, or
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`for some other purpose.
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`TRANSFER INTERROGATORY NO. 2:
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`Describe the processes run in the Samsung RMS PVD chamber(s) of the reactors identified
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`in response to Interrogatory No. 1, including, but not limited to:
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`a) what processes are run;
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 7 of 9
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`b) where the processes are run;
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`c) the thin-film deposited;
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`d) the target used;
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`e) the substrate used;
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`f) any process or reactive gases;
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`g) any Samsung semiconductor product(s) to which the processes relate; and,
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`h) the geographic areas in which such products are distributed and sold.
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`TRANSFER INTERROGATORY NO. 3:
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`Describe the configuration process of the Samsung RMS PVD chambers in the reactors
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`identified in response to Interrogatory No. 1, including, but not limited to:
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`a) where and how the configuration was chosen and developed;
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`b) where and how the reactor was installed;
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`c) where and how the chamber was initially configured;
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`d) if, where and how the chamber has been reconfigured;
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`e) who participates in each of the above steps, including their name, title, current
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`employer and place of residency; and,
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`f)
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`the types and locations of documents relating to each of the above steps.
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`TRANSFER INTERROGATORY NO. 4:
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`Describe all work at SAS relating to making, using, developing Samsung RMS PVD
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`chambers or the configuration or use of such chambers for any purpose, including, but not limited
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`to:
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`a) a description of such work;
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`b) where such work occurred;
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`c) the persons involved, including their name, title, current employer and place of
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`residency; and,
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`d) the documents associated with such work, including the types and locations of such
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`documents.
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`

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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 8 of 9
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`Dated: December 7, 2020 _____________
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`Irell & Manella LLP
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`By: /s/ C. Maclain Wells
`C. Maclain Wells
`Attorneys for Plaintiff
`Demaray LLC
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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`

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`Case 5:20-cv-05676-EJD Document 42-13 Filed 12/07/20 Page 9 of 9
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`CERITFICATE OF SERVICE
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`On December 7, 2020, I served the foregoing document described as DEMARAY LLC’S
`TRANSFER-RELATED INTERROGATORIES TO SAMSUNG DEFENDANTS on each
`interested party, as follows:
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`X
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`(BY ELECTRONIC MAIL) I caused the foregoing document to be served
`electronically by electronically mailing a true and correct copy through Irell &
`Manella LLP's electronic mail system to the e-mail address(es), as set forth above,
`and the transmission was reported as complete and no error was reported.
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`Executed on December 7, 2020, at Sebastopol, California.
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`/s/ C. Maclain Wells
`C. Maclain Wells
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`10890434.2
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`DEMARAY'S TRANSFER-RELATED INTERROGATORIES
`(NOS. 1-4)
`(Case No. 6:20-cv-00636-ADA)
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