Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 1 of 28 PageID #: 22562
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ELM 3DS INNOVATIONS, LLC,
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`
`
`Plaintiff,
`
`
`v.
`SAMSUNG ELECTRONICS CO., LTD.., et al.,
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`
`
`Defendants.
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`
`
`
`C.A. No. 14-cv-1430-LPS
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`JURY TRIAL DEMANDED
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`
`
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`
`
`
`ELM’S THIRD NOTICE OF DEPOSITION OF SAMSUNG PURSUANT TO
`FEDERAL RULE OF CIVIL PRODUCEURE 30(b)(6) (TOPIC NOS. 24-108)
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`Please take notice that Plaintiff Elm 3DS Innovations, Inc., (“Elm”) will take the deposition
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`of one or more persons designated by Defendants Samsung Electronics Co., Ltd., Samsung
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`Semiconductor, Inc., Samsung Electronics America, Inc. and Samsung Austin Semiconductor, LLC
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`(collectively “Samsung”), under Federal Rules of Civil Procedure 26 and 30, regarding the topics set
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`forth below. Such deposition or depositions will commence on a date and time and in a location
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`determined by the parties. The deposition will continue from day to day thereafter and shall be taken
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`before an officer qualified to administer oaths under the Federal Rules of Civil Procedure. The
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`examination will be recorded by stenographic means, LiveNote or similar functionality, and/or by
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`videotape, and will continue from day to day until completed.
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`Under Federal Rule of Civil Procedure 30(b)(6), Defendants are required to designate one or
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`more officers, directors, or managing agents or other persons who consent to testify on their behalf
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`regarding the topics below. Failure to designate a person who is prepared to provide full and
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`complete testimony regarding these topics may be treated as a failure to comply with this deposition
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`notice and may be treated as a contempt of court or bar the introduction of evidence in subsequent
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`proceeding and at trial.
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`

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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 2 of 28 PageID #: 22563
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`DEFINITIONS
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`1.
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`The terms “Elm” and “Elm 3DS” refer to the Plaintiff in these actions and all
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`parents, subsidiaries, affiliates, assignees, predecessors, employees, and agents thereof.
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`2.
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`The terms “You” and “Your” mean the Samsung Defendants in these actions and
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`their parents, subsidiaries, divisions, affiliates, predecessors, assignees, successors, and acquired assets
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`of business units, and any of their present or former officers, directors, trustees, employees, agents,
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`representatives, attorneys, patent agents, and all other persons acting on their behalf.
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`3.
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`The term “Document(s)” has the broadest meaning ascribed to it by Rule 34(a) of
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`the Federal Rules of Civil Procedure and encompasses any writing of any kind, including originals
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`and non-identical copies (whether different from the original by reason of any notation made on
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`such copies or otherwise). The term “Document(s)” includes without limitation the following items,
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`whether printed or reproduced by any process, or written or produced by hand or stored in
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`computer memory, magnetic or hard disk, or other data storage medium, and whether or not
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`claimed to be privileged, confidential, or otherwise excludable from discovery, including without
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`limitation: patents, patent applications, articles, publications, presentations, posters, slides, electronic
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`presentations, notes, letters, correspondence, communications, e-mail, telegrams, memoranda,
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`summaries or records of telephone conversations, summaries or records of personal conversations
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`or meetings, diaries, reports, laboratory and research reports and notebooks, recorded experiments,
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`charts, plans, drawings, diagrams, schematic diagrams, HDL, Verilog, source code or other computer
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`code, illustrations, product descriptions, labels, product inserts, product analyses, requests for
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`proposals, documents related to proposals or actual product improvements or changes, user manuals
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`or guides, installation guides or manuals, technical descriptions or specifications, product repair
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`manuals or guides, photographs, video images, software flow charts or descriptions or specifications,
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`product functional descriptions or specifications, minutes or records of meetings, summaries of
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`2
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`

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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 3 of 28 PageID #: 22564
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`interviews, reports, or investigations, opinions or reports of consultants, reports of patent searches,
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`patent appraisals, opinions of counsel, agreements, reports or summaries of negotiations, brochures,
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`pamphlets, advertisements, circulars, trade letters, press releases, drafts of documents, and all other
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`material fixed in a tangible medium of whatever kind.
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`4.
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`Where used in these Requests, the singular also encompasses the plural and vice
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`versa, the words “and” and “or” shall be conjunctive and disjunctive, the words “all” or “any” shall
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`mean “all and any,” and the word “including” means “including without limitation.”
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`1.
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`The term “Accused Product(s)” means any stacked semiconductor product that is sold
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`by you, or incorporated into a product that is sold by you, that contains a semiconductor layer with a
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`thickness of 50 microns or less. For the avoidance of doubt, “Product(s)” include all types of
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`semiconductor products that meet the above definition, regardless of their function (e.g., memory,
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`image sensor, control, etc.). In addition, although Elm expects that there may be Products that are not
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`included in the following documents, the term Product(s) specifically includes each Product listed in,
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`or included in other products listed in, the following documents: the Elm v. Samsung Representative
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`Products Spreadsheet that Samsung served on October 26, 2020, SAMSUNG-ELM-000025176 –
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`SAMSUNG-ELM-000050134, SAMSUNG-ELM-000052678 – SAMSUNG-ELM-000054791,
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`SAMSUNG-ELM-000054792 – SAMSUNG-ELM-000054799, SAMSUNG-ELM-000054967 –
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`SAMSUNG-ELM-000054969,
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`SAMSUNG-ELM-000058542,
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`SAMSUNG-ELM-000062355,
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`SAMSUNG-ELM-000062356,
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`SAMSUNG-ELM-000062357,
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`SAMSUNG-ELM-000062358,
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`SAMSUNG-ELM-000062359,
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`SAMSUNG-ELM-000062363,
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`SAMSUNG-ELM-000062366,
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`SAMSUNG-ELM-000062367,
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`SAMSUNG-ELM-000062368,
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`SAMSUNG-ELM-000062369,
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`SAMSUNG-ELM-000062370,
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`SAMSUNG-ELM-000062371,
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`SAMSUNG-ELM-000062372,
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`SAMSUNG-ELM-000062373,
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`SAMSUNG-ELM-000062374,
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`SAMSUNG-ELM-000206023,
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`SAMSUNG-ELM-000206024,
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`SAMSUNG-ELM-000206025,
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`SAMSUNG-ELM-000206026,
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`3
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 4 of 28 PageID #: 22565
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`SAMSUNG-ELM-000206027,
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`SAMSUNG-ELM-000206028,
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`SAMSUNG-ELM-000220359,
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`SAMSUNG-ELM-000220360,
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`SAMSUNG-ELM-000220458,
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`SAMSUNG-ELM-000220460,
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`SAMSUNG-ELM-000633785, AND SAMSUNG-ELM-000633786. For further avoidance of doubt,
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`the “semiconductor layer with a thickness of 50 microns or less” term above refers only to the
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`thickness of the semiconductor substrate, and not to the dielectric, metal, or other material that may
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`be deposited on the die (including, to Elm’s current understanding of Samsung’s terminology, the
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`“active layer” and “polyimide layer” whose thickness should not be included in the thickness of the
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`semiconductor layer thickness).
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`5.
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`The term “yield” means the percentage of products that successfully undergo all
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`assembly-related process steps. In other words, your yield is equal to the number of products exiting
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`the assembly process with no assembly defects, divided by the number of products that started the
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`assembly process. For the avoidance of doubt, the Yields addressed in these requests relate only to
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`full-scale production after the assembly process has passed any needed qualification tests. Moreover,
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`the yields addressed in these topics relate only to yields associated with assembly process steps such
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`as wafer thinning, die attach, wirebonding, molding, etc.; parts with defects associated with non-
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`assembly processes such as wafer fab should not be factored into your yield calculations.
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`6.
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`The term “material properties” means every known, estimated, or measured
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`property of the material, including each of the following:
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`i. Young’s modulus
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`ii. Shear modulus
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`iii. Poisson’s ratio
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`iv. Coefficient of thermal expansion
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`v. Density
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`vi. Heat capacity
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`4
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 5 of 28 PageID #: 22566
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`vii. Thermal conductivity
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`7.
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`The term “stress target” means a desired level or range of stress for a given entity,
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`such as a die or a dielectric layer within a die.
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`8.
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`The use and definition of any of these words or terms is not contingent on the
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`capitalization or lack of capitalization of those terms as used below. Some terms may be capitalized,
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`including without limitation at the beginning of a sentence, or not capitalized—regardless, the above
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`definitions should be considered to apply
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`DEPOSITION TOPICS
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`Your search for and production of sales data.
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`Your databases containing sales information for the Accused Products.
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`Your databases containing profit and loss data for the Accused Products.
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`Your databases containing shipment data for the Accused Products, including dates,
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`customers’ names and locations, unit prices, unit quality, location shipped from, location shipped to,
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`location selling from, and location selling to.
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`Your sales and marketing activities in the United States relating to the Accused Products.
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`Your offers to sell the Accused Products in the United States, including offers that did and
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`did not ultimately lead to sales.
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`5
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`

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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 6 of 28 PageID #: 22567
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`
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`All meetings, discussions, or communications between Samsung and Glenn Leedy.
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`All meetings, discussions, or communications between Samsung and Elm, including any
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`agent or representative of Elm.
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`Samsung’s analysis or evaluation of any patent or patent application (including both U.S. and
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`foreign) owned by or licensed to Glenn Leedy or Elm, including but not limited to the Asserted
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`Patents in this case.
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`All procedures and methods Samsung has used to measure or evaluate dielectric stress in its
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`products, including the Accused Products.
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`All procedures and methods Samsung has used to measure or evaluate stress of any kind in
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`its products, including the Accused Products.
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`Any stress targets or targets that are related to stress for any Samsung products, including
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`the Accused Products.
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`Reports or analyses in which Samsung concluded that it could not accurately measure the
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`stress of a dielectric, including any dielectric in the Accused Products.
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`6
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 7 of 28 PageID #: 22568
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`Reports or analyses in which Samsung measured or estimated dielectric stress using a six-
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`component tensor with principal stress components in three dimensions and shear stress
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`components in three dimensions.
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`Reports or analyses in which Samsung measured or estimated a single value for dielectric
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`stress.
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`Reports or analyses in which Samsung used RAMAN scattering for the determination of
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`stress, and the conclusions reached in such reports or analyses.
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`Reports or analyses in which Samsung has used curvature/stress analyses (by whatever
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`method, e.g., optical, laser, etc.) for the determination of stress, and the conclusions reached in such
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`reports or analyses.
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`Reports or analyses in which Samsung has used Zygo measurements for the determination
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`of stress, and the conclusions reached in such reports or analyses.
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`Reports or analyses in which Samsung has used FEA models for the determination of stress,
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`and the conclusions reached in such reports or analyses.
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`Reports or analyses in which Samsung has used Stoney’s equation (or any modification or
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`variant thereof) to estimate stress.
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`7
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 8 of 28 PageID #: 22569
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`Reports or analyses in which Samsung concluded that Stoney’s equation was not an
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`appropriate tool or metric for estimating stress.
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`The importance of dielectric stress to the manufacturing process for Samsung’s products.
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`The importance of stress of any kind to the manufacturing process for Samsung’s products.
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`The thickness of the Accused Products, including the thickness of every layer in each
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`Accused Product.
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`The target thickness of the Accused Products, including the target thickness of every layer in
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`each of the Accused Products.
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`The maximum allowable thickness of the Accused Products, including the maximum
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`allowable thickness of every layer in each of the Accused Products.
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`Your databases containing information regarding the actual, target, and/or maximum
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`allowable thickness of the Accused Products, including the thickness of every layer in each of the
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`Accused Products.
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`Your search for and production of the data underlying and documents relating to sales
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`figures and revenue information you have produced in this case, including but not limited to the
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`8
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 9 of 28 PageID #: 22570
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`Representative Product Charts and the documents cited in each of Samsung’s responses to
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`Interrogatory Nos. 3-5 and Common Interrogatory Nos. 2, 4, 5, and 6.
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`Documents disclosing your sales figures and revenue information you have produced in this
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`case, including but not limited to the Representative Product Charts and the documents cited in each
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`of Samsung’s responses to Interrogatory Nos. 3-5 and Common Interrogatory Nos. 2, 4, 5, and 6.
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`Your database(s) or other underlying sources from which the sales figures or revenue
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`information that you have produced in this case were derived, including but not limited to the
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`Representative Product Charts and the documents cited in each of Samsung’s responses to
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`Interrogatory Nos. 3-5 and Common Interrogatory Nos. 2, 4, 5, and 6.
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`For each Accused Product, your revenues, costs, price, units sold, gross profit, net profit, and
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`profit margin.
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`Sales and shipment data for each Accused Product, including dates, customers’ names and
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`locations, unit price, unit quantity, location shipped from, location shipped to, location selling from,
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`and location selling to.
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`Your policies or practices for retaining physical samples of semiconductor products,
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`including the Accused Products.
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`Your policies, procedures, or practices for retaining physical samples of the Accused
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`Products after the date this lawsuit began.
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`9
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 10 of 28 PageID #: 22571
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`The materials you have made available to Elm to review on a standalone computer.
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`Your process flow documents, including the PRP documents you have made available to
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`Elm to review on a standalone computer.
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`The Elm Correlation Chart you provided to Elm on January 7, 2019, the documents
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`contained therein, the process used to create the chart, the people who participated in creating the
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`chart, and the availability of similar information for other nodes.
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`The following information concerning the nodes used to make each of the Accused
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`Products:
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` When the node first began production;
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` Whether the node is still being used to manufacture products;
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`
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`If it has ceased production, the date on which it ceased production;
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` The types of products produced on the node;
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`
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`If a memory product node, the memory density of the products produced on the
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`node;
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` The location(s) of the node; and
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` The dielectric deposition equipment included and/or used in the node.
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`The following information concerning the packaging of each of the Accused Products:
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` Whether the product is packaged by a Samsung affiliate or a third party; and
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` Where the product is packaged.
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`10
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 11 of 28 PageID #: 22572
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`Any differences between the dielectrics included in products that are produced on the same
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`node.
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`node.
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`Any differences between dielectric stress between products that are produced on the same
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`The “active layer” included in each Accused Product, as that term was used in your letter
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`dated November 6, 2020.
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`The “polyimide layer” included in each Accused Product, as that term was used in your letter
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`dated November 6, 2020.
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`Your efforts to locate physical samples of the Accused Products.
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`Your efforts to locate physical samples of the Accused Products listed in Exhibit A to this
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`notice.
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`The last time You were in possession of physical samples of the Accused Products listed in
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`Exhibit A to this notice.
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`Samsung’s contentions regarding the factors that would inform a hypothetical negotiation
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`between the parties for a license to the Asserted Patents, including but not limited to the factors set
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`forth in Georgia-Pacific Corp. v. United States Plywood Corp., 318 F. Supp. 1116 (S.D.N.Y. 1970).
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`11
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 12 of 28 PageID #: 22573
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`Your communications with Micron or SK Hynix regarding Elm, the Asserted Patents, or this
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`litigation.
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`Your communications with Apple, Micron, SK Hynix, Dell EMC Corp., NetApp Inc., HP
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`Inc., and NVIDIA Corp. related to the Accused Products.
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`Your communications with Irvine Sensors, Tezzaron, and/or current or former employees
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`of either company in connection with this litigation.
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`Your knowledge of all communications with Irvine Sensors, Tezzaron, and/or current or
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`former employees of either company in connection with this litigation by any other Defendant.
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`Your effort(s) to research and develop the processes used to deposit dielectric layers in
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`semiconductor die fabricated according to the process nodes and/or flows and/or process
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`technologies and/or process travelers used to manufacture any Accused Product.
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`Your effort(s) to set target specifications for the dielectric layers in semiconductor die
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`fabricated according to the process nodes and/or flows and/or process technologies and/or process
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`travelers used to manufacture any Accused Product.
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`Your effort(s) to minimize or otherwise control the target stress levels for the dielectric
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`layers in semiconductor die fabricated according to the process nodes and/or flows and/or process
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`technologies and/or process travelers used to manufacture any Accused Product.
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`12
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 13 of 28 PageID #: 22574
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`Your effort(s) to minimize or otherwise control the wafer warpage induced by depositing
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`dielectric layers in semiconductor die fabricated according to the process nodes and/or flows and/or
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`process technologies and/or process travelers used to manufacture any Accused Product.
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`Your target yields and actual yields for the Accused Products, including any target or actual
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`wafer yields or product yields after assembly.
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`The dielectric stress values for any semiconductor product You have manufactured since
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`1994.
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`All equipment and material you use to deposit or otherwise form dielectrics used in each of
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`the Accused Products.
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`How the equipment and/or materials you use to deposit or otherwise form dielectrics is
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`configured, and where such configurations are recorded or stored.
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`The composition and dimensions of all structures and materials in and around any dielectric
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`adjacent to the substrate.
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`Documents reflecting the composition and dimensions of all structures and materials in and
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`around any dielectric adjacent to the substrate.
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`The chemical composition of the dielectrics used in each of the Accused Products.
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`13
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 14 of 28 PageID #: 22575
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`The material properties of the dielectrics used in each of the Accused Products.
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`The chemical composition of the metal contained in each of the Accused Products.
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`The material properties of the metal contained in each of the Accused Products.
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`The physical dimensions of the metal contained in each of the Accused Products.
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`Every wafer warpage measurement taken of wafers used to make the Accused Products.
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`Any documents or databases containing wafer warpage data, including but not limited to
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`warpage measurements taken of wafers used to make the Accused Products.
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`Your analyses of chip, wafer, or substrate breakage or fracture in the Accused Products,
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`including any such breakage or fracture that occurred during the development of the Accused
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`Products.
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`The core technical data you have produced for each of the Accused Products.
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`The processes used to thin, smooth, and/or polish the chip, wafer, or substrate in each of
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`the Accused Products, including each process step, the order in which each process step is
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`conducted, the equipment used in each process step, and the instructions, configurations, and
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`settings related to each process step.
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`14
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 15 of 28 PageID #: 22576
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`All backgrinding processes to which the Accused Products are subjected, and the parameters
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`for backgrinding, including all instructions, configurations, and settings related to the target
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`thickness to be achieved.
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`The processes used to stack the die used in each of the Accused Products, including but not
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`limited to the following:
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`a) Whether the die are stacked before or after dicing (in other words, whether individual die
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`or wafers are stacked);
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`b) Whether the die are stacked before or after thinning;
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`c) Whether, when the die are stacked, they are attached to a rigid carrier;
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`d) The tool(s) you use to pick up and/or move die (or wafers) for stacking; and
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`e) The tool(s) and processes you use to bond from one level of die to the next level of die
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`in the stack.
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`Your knowledge and/or analysis of the downstream uses of each of the Accused Products,
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`including but not limited to the products in which they are incorporated.
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`Your knowledge and/or analysis of the extent to which each of the Accused Products sold
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`outside the United States are ultimately imported into the United States.
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`Your knowledge and/or analysis of the extent to which each of the Accused Products sold
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`outside the United States are ultimately incorporated into products sold by Apple Inc., Dell EMC
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`Corp., NetApp Inc., HP Inc., Intel, Google Inc., and/or Sony.
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`15
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 16 of 28 PageID #: 22577
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`The die attach and/or bonding material used in stacking the die in each of the Accused
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`Products, including the following:
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`a) The chemical composition of the material;
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`b) The equipment and processes used to deposit, place, or otherwise form the material; and
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`c) The portion of the surface of the die covered by the material.
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`All dielectrics used to insulate the TSVs in each of the Accused Products that include TSVs,
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`including the following:
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`a) The chemical composition of the material;
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`b) The equipment and processes used to deposit or otherwise form the material;
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`c) The material properties of the dielectric; and
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`d) All measurements or estimates of the stress of the dielectric.
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`The following information related to the semiconductor substrates used in each of the
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`Accused Products:
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`a) Their chemical composition (e.g., silicon);
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`b) Whether they are monocrystalline;
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`c) Whether they are polycrystalline;
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`d) Whether they are formed from a single piece of material; and
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`e) Whether they are formed from a wafer.
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`The following information related to the circuitry in each of the Accused Products:
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`a) Whether it includes polycrystalline circuitry;
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`16
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`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 17 of 28 PageID #: 22578
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`b) Whether it includes reconfiguration circuitry; and
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`c) Whether it includes passive circuitry.
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`The following information concerning the wirebonds used in each of the Accused Products
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`that do not include TSVs:
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`a) How they are formed;
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`b) The equipment used to form the wirebonds;
`
`c) The equipment used to hold the die in place during wirebonding;
`
`d) The chemical composition of the wirebonds;
`
`e) The material properties of the wirebonds; and
`
`f) The extent to which the process of forming the wirebonds has led to breakage and/or
`
`fracture of the Accused Products.
`
`
`
`
`
`The passivation layers used in each of the Accused Products, including their chemical
`
`composition and their location in or on the Accused Products.
`
`
`
`
`
`Die coatings, polymer layers, or other dielectric materials added above the passivation layer
`
`used in each of the Accused Products before assembly, including their chemical composition and
`
`their location in or on the Accused Products.
`
`
`
`
`
`Your responses to Interrogatory Nos. 1-15 and Common Interrogatory Nos. 1-15.
`
`
`
`17
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 18 of 28 PageID #: 22579
`
`
`
`
`
`
`
`The patent licensing agreements you have produced in this case, including the terms of said
`
`agreements, the royalty rate for such agreements, the patented technology licensed pursuant to such
`
`agreements, and the amount of payments made or received pursuant to such agreements.
`
`
`
`
`
`The job titles and responsibilities of all individuals identified in any of Samsung’s Rule 26
`
`disclosures.
`
`
`
`
`
`
`
`
`
`
`
`18
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 19 of 28 PageID #: 22580
`
`
`
`Respectfully submitted,
`
`FARNAN LLP
`
`/s/ Michael J. Farnan
`Brian E. Farnan (#4089)
`bfarnan@farnanlaw.com
`Michael J. Farnan (#5165)
`mfarnan@farnanlaw.com
`919 North Market Street
`12th Floor
`Wilmington, DE 19801
`Tel: (302) 777-0300
`Fax: (302) 777-0301
`
`Matthew R. Ford (pro hac vice)
`matthew.ford@bartlit-beck.com
`BARTLIT BECK LLP
`54 W. Hubbard Street, Suite 300
`Chicago, IL 60654
`Tel: (312) 494-4400
`Fax: (312) 494-4440
`
`John M. Hughes (pro hac vice)
`john.hughes@bartlit-beck.com
`Katherine L.I. Hacker (pro hac vice)
`kat.hacker@bartlit-beck.com
`Nosson Knobloch (pro hac vice)
`nosson.knobloch@bartlit-beck.com
`Daniel C. Taylor (pro hac vice)
`daniel.taylor@bartlit-beck.com
`BARTLIT BECK LLP
`1801 Wewatta Street, Suite 1200
`Denver, CO 80202
`Tel: (303) 592-3100
`Fax: (303) 592-3140
`
`Adam K. Mortara (pro hac vice)
`adam@mortaralaw.com
`125 South Wacker Dr., Suite 300
`Chicago, IL 60606
`Tel: (773) 750-7154
`
`Counsel for Plaintiff
`ELM 3DS INNOVATIONS, LLC
`
`
`
`Dated: November 13, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`19
`
`
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 20 of 28 PageID #: 22581
`
`Exhibit A
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 21 of 28 PageID #: 22582
`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 21 of 28 PageID #: 22582
`
`K3PE0E000M-XGC10EX
`K3PEOE000M-XGC10EX
`KLUBG4G1BD-E0B10Y2
`KLUBG4G1BD-EOB10Y2
`KLMBG4GE2A-A001004
`KLMBG4GE2A—A001004
`K9MDG08U5M-PCB0T00
`K9MDG08U5M-PCBOT00
`KMR210008M-A8050Y0
`KMR210008M-A8050Y0
`KLUCG8G1BD-E0B10Y2
`KLUCGSGlBD-EOBlOYZ
`KLMAG1JETD-B0410Y0
`KLMAGUETD-B0410YO
`K9UUGY8S7M-1CK0TP1
`K9UUGYSS7M-1CKOTP1
`KLMCG4JENB-B041T07
`KLMCG4JENB-B041TO7
`MMB3R32GUACA-2GEMK (KKRBG8YMEA-UGR9MMK)
`MMB3R32GUACA—2GEMK (KKRBGSYMEA—UGR9MMK)
`KLMBG8FE4B-B0010Y6
`KLMBGSFE4B—B0010Y6
`K9ACGD8U0B-W000000
`K9ACGD8UOB—WOOOOOO
`KLMAG1JENB-B0310Y3
`KLMAGleNB-B0310Y3
`KMQ310006A-B4190Y0
`KMQ310006A—B4190Y0
`KLMBG2JENB-B0410YG
`KLMBGZJENB-BO410YG
`MMBTR32GUBCA-2ABTN (KKRBG8XTRB-UGQ1MTN)
`MMBTR32GUBCA—2ABTN (KKRBGSXTRB—UGQIMTN)
`K4P6G304EB-AGC1TTN
`K4P6G304EB—AGC1TTN
`KMR210008A-A8090Y0
`KMR210008A-A8090Y0
`KEH01400TM-UG00T00
`KEH01400TM-UGO0T00
`KLMDG8JENB-B041T07
`KLMDGSJENB-B041T07
`K3RG2G20BM-CGCH000
`K3RG2G20BM—CGCH000
`KLUCG8G1BD-E0B20Y3
`KLUCGSGlBD-EOB20Y3
`KLUCG4J1ED-B0C10Y0
`KLUCG4J1ED-BOC10Y0
`KLMCG8GEND-B031001
`KLMCGSGEND-B031001
`KLMAG4FEAB-B0020Y0
`KLMAG4FEAB—B0020Y0
`KLMCG8GEAC-B001003
`KLMCGSGEAC-B001003
`K9UHGY8U7A-HCK0000
`K9UHGY8U7A—HCKOOOO
`K9UHGY8U7A-HCK0000
`K9UHGY8U7A—HCKOOOO
`KLUDGAG1BD-E0B10Y2
`KLUDGAGlBD-EOBlOYZ
`MBMGCGUFODGW-FKK00 (KDACK8HWHD-UKQ1M00)
`MBMGCGUFODGW—FKKOO (KDACKSHWHD-UKQlMOO)
`KMRH60014A-B614T05
`KMRH60014A—B614T05
`KMRH60014A-B614T05
`KMRH60014A—B614T05
`MBMB8GMCQDDA-DFC02 (KEH0140T8D-UG00M00)
`MBMBSGMCQDDA—DFCOZ (KEH014OT8D-UGO0MOO)
`KMQ31000SM-B4170Y0
`KMQ310008M—B4170Y0
`MBMCEGVHOMGU-TQK00 (KDEEK8QWTM-UKQ0M00)
`MBMCEGVHOMGU-TQKOO (KDEEKSQWTM—UKQOMOO)
`MBMCDGVGHDJU-2QJ00 (KDEDKAVW2D-UJQ2M00)
`MBMCDGVGHDJU-ZQJOO (KDEDKAVWZD-UJQZMOO)
`KLMDGAWEBD-B031000
`KLMDGAWEBD-B031000
`MBSB2GMAGMAA-N0B10 (UNK)
`MBSBZGMAGMAA—NOBlO (UNK)
`KMRC10014M-B809T07
`KMRC10014M-B809T07
`KMRC10014M-B809T01
`KMRC10014M-B809T01
`KMRC10014M-B809006
`KMRC10014M-B809006
`KMRC10014M-B809T18
`KMRC10014M-B809T18
`KMRC10014M-B8090YC
`KMRC10014M-B8090YC
`KMRC10014M-B809007
`KMRC10014M-B809007
`KMRC10014M-B809001
`KMRC10014M-B809001
`KMRH60014M-B614T02
`KMRH60014M-B614T02
`KMRH60014M-B614T05
`KMRH60014M-B614T05
`KMRH60014M-B614002
`KMRH60014M-B614002
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 22 of 28 PageID #: 22583
`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 22 of 28 PageID #: 22583
`
`KMRH60014M-B614001
`KMRH60014M—B614001
`KMRH60014M-B614005
`KMRH60014M-B614005
`KMRH60014M-B614TS5
`KMRH60014M-B614TSS
`KMRX10014M-B614T07
`KMRX10014M—B614T07
`KMRX10014M-B614T01
`KMRX10014M-B614T01
`KMRX10014M-B6140Y0
`KMRX10014M-B6140Y0
`KMRX10014M-B614007
`KMRX10014M—B614007
`KMRX10014M-B614006
`KMRX10014M—B614006
`KMRX10014M-B614TSM
`KMRX10014M—B614TSM
`KMRX10014M-B614001
`KMRX10014M-B614001
`KMRX10014M-B614T15
`KMRX10014M-B614T1 5
`KMRX10014M-B614015
`KMRX10014M—B614015
`KLAEG8KWAM-I0T3T00
`KLAEGSKVVAM—IOT3T00
`K4X4G643GC-1GC80P0
`K4X4G643GC—1GC80P0
`KB100D00WM-A453000
`KB 1 00DO0W—A453000
`KB100D00ZM-A453000
`KB 1 00DO0ZM—A453000
`KB100D00YM-A453000
`KB 1 00DO0YM—A453000
`KBU24000HM-A439000
`KBU24000HM—A439000
`KB100L002A-A4590TN
`KB 1 00L002A—A4590TN
`KBN00X00XM-A4390JP
`KBNO0X00XM—A439OJP
`KB100D011M-A453000
`KB100D011M-A453000
`KBN00X00XM-A999000
`KBNOOXOOXM-A999000
`KBU24000HM-A999000
`KBU24000HM—A999000
`KMQX10013M-B419T07
`KMQX10013M—B419T07
`KMQX10013M-B419007
`KMQX10013M—B419007
`KMQ31001AM-A4190Y0
`KMQ31001AM—A4190Y0
`KMQX10013M-B4190Y0
`KMQX10013M—B4190Y0
`KMQ31001AM-A999000
`KMQ31001AM-A999000
`KMR21000AM-A8050Y0
`KMR21000AM—A8050Y0
`KLMAG2GE4A-A001005
`KLMAGZGE4A—A001 005
`KLMAG2GE4A-A001TSN
`KLMAGZGE4A—A001TSN
`KLMAG2GE4A-A001021
`KLMAGZGE4A—A001 021
`KLMAG2GE4A-A001TSM
`KLMAGZGE4A—A001TSM
`KLMAG2WE4A-A0020Y2
`KLMAGZWE4A—A0 02 0Y2
`KLMAG2WE4A-A001004
`KLMAGZWE4A—A001 004
`KLMAG2GE4A-A002019
`KLMAGZGE4A—A00201 9
`KLMAG2GE4A-A001TNO
`KLMAGZGE4A—A001TNO
`KLMAG2WE4A-A001TSN
`KLMAGZWE4A—A001TSN
`KLMAG2WE4A-A001T04
`KLMAGZWE4A—A00 1 T04
`KLMAG2GE4A-A001020
`KLMAGZGE4A—A001 020
`K5W4G2GACA-AL54TNO
`K5W4G2GACA—AL5 4TNO
`K5W2G1GACI-AL60TNO
`K5W2G1 GACI—AL6 OTNO
`K5W2G1GACP-AL60TNO
`K5W2G1 GACP—AL60TNO
`K5W2G2GACM-AL54TSN
`KSWZGZGACM—ALS 4TSN
`K5W4G2GACC-AL500JP
`K5W4G2GACC-AL5 OOJP
`K5W2G2GACM-AL54TSM
`K5W2G2GACM-AL54TSM
`K5W2G2GACD-AL54TSN
`KSWZGZGACD -AL5 4TSN
`K5W4G2GACA-AL54T00
`K5W4G2GACA—AL5 4T00
`
`

`

`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 23 of 28 PageID #: 22584
`Case 1:14-cv-01430-LPS Document 368 Filed 11/13/20 Page 23 of 28 PageID #: 22584
`
`K5W2G1GACI-AL60T00
`K5W2G1GACI—AL60TOO
`K5W2G2GACM-AL54000
`K5W2G2GACM-AL54000
`K5W2G1GACP-AL60T00
`K5W2G1GACP-AL60TOO
`K5W2G2GACM-AL54T00
`K5W2G2GACM-AL54TOO
`K5W2G1GACP-AL60000
`K5W2G1GACP-AL60000
`K5W1G13ACJ-AL60T00
`K5W1G13ACJ-AL60TOO
`K5W1G13ACJ-A0DS000
`K5W1G13ACJ-AODSOOO
`K5W2G1GACI-AL60000
`K5W2G1GACI—AL60000
`K5W2G1GACP-A0DBT00
`KSWZGlGACP-AODBTOO
`K5W1G13ACJ-A0DST00
`K5W1G13ACJ-AODST00
`K5W2G1GACI-AL600TN
`K5W2G1GACI—AL600TN
`K5A4G4GQCB-B0190SO
`K5A4G4GQCB—B019OSO
`K5W1G13ACJ-A0DBT00
`K5W1G13ACJ-AODBT00
`K5W1G13ACJ-AL60000
`K5W1G13ACJ-AL60000
`KLMCG8GE4A-A001006
`KLMCGSGE4A—A001006
`KLMCG8GE4A-A001024
`KLMCGSGE4A—A001024
`KLMCG8GE4A-A001000
`KLMCGSGE4A—A001000
`KLMCG8GE4A-A001021
`KLMCGSGE4A—A001021
`KLMCG8GE4A-A0010Y3
`KLMCGSGE4A—A001OY3
`KLMCG8GE4A-A0010LM
`KLMCGSGE4A—A0010LM
`KLMCG8GE4A-A001T06
`KLMCGSGE4A—A001T06
`KLMCG8GE4A-A001018
`KLMCGSGE4A—A001018
`KLMCG8GE4A-A001004
`KLMCGSGE4A—A001004
`KLMCG8GE4A-A001022
`KLMCGSGE4A—A001022
`KLMCG8GE4A-A001005
`KLMCGSGE4A—A001005
`KLMCG8GE4A-A001012
`KLMCGSGE4A—A001012
`KAT00F00NM-AE77T00
`KATOOFOONM-AE77T00
`KAT00F00NM-A999T00
`KATOOFOONM-A999