`GODO KAISHA IP BRIDGE 1,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.
`
`
`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 1 of 31 PageID #: 3113
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-290 (MN)
`
`
`
`
`
`
`
`Defendant.
`
`
`
`DECLARATION OF CHIJIOKE E. OFFOR
`
`I, Chijioke E. Offor, make this declaration and certify as follows:
`
`1.
`
`My name is Chijioke E. Offor. I am more than twenty-one years old, of sound mind,
`
`and fully capable of making this declaration. I am a graduate of the University of Michigan,
`
`College of Engineering at Ann Arbor, Michigan and the University of Wisconsin Law School at
`
`Madison, Wisconsin, and I received my law license from the State Bar of Texas in
`
`November 2008. I am a partner at the law firm of Shore Chan DePumpo LLP in Dallas, Texas,
`
`and I am one of the attorneys representing plaintiff Godo Kaisha IP Bridge 1 in the action styled
`
`Godo Kaisha IP Bridge 1 v. OmniVision Technologies, LLC, No. 1:16-cv-00290 (MN), in the
`
`United States District Court for the District of Delaware. I have personal knowledge of the facts
`
`set forth in this declaration and am competent to testify thereto.
`
`2.
`
`A true and correct copy of each of the documents identified in the table below is
`
`attached hereto (in Exhibits 1-8).
`
`Exhibit 1 A summary, prepared by IP Bridge’s counsel, of OmniVision’s responses to IP
`Bridge Interrogatory Nos. 1 and 13 and RFP Nos. 44, 48-52, 74, 76, and 78,
`excluding OmniVision’s objections and boilerplate reservations of rights.
`Exhibit 2 A summary, prepared by IP Bridge’s counsel, of OmniVision’s responses to IP
`Bridge Interrogatory Nos. 11-12 and RFP Nos. 53-73, excluding OmniVision’s
`objections and boilerplate reservations of rights.
`
`
`
`
`1
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 2 of 31 PageID #: 3114
`
`Exhibit 3 A summary, prepared by IP Bridge’s counsel, of OmniVision’s responses to IP
`Bridge RFP Nos. 45-47, excluding OmniVision’s objections and boilerplate
`reservations of rights.
`Exhibit 4 A summary, prepared by IP Bridge’s counsel, of OmniVision’s responses to IP
`Bridge RFP Nos. 13-40, excluding OmniVision’s objections and boilerplate
`reservations of rights.
`Exhibit 5 Mori et al., A 1/4in 2M pixel CMOS image sensor with 1.75 transistor/pixel,
`2004 IEEE Int’l Solid-State Circuits Conf., San Francisco, CA, 2004, pp. 110-
`111 Vol. 1 (Conf. Date: 15-19 Feb. 2004)
`EXCERPTS from H. Rhodes et. al., CMOS imager technology shrinks and image
`performance, 2004 IEEE Workshop on Microelec. and Electron Devices, Boise,
`ID, USA, 2004, pp. 7-18 (Conf. Date: 16 April 2004)
`EXCERPTS from “CMOS Image Sensor Pixel Design and Optimization,” a
`keynote presentation by OmniVision’s Chief Technology Officer Boyd Fowler,
`dated February 1, 2017, available at http://www.image-sensors.org/2017.php (last
`visited Nov. 28, 2018 at 2:56 p.m. CST)
`EXCERPTS from OmniVision Technologies, Inc., H. Rhodes, D. Tai, Y. Qian,
`D. Mao, V. Venezia et al., “The Mass Production of BSI CMOS Image sensors,”
`available at http://imagesensors.org/2009-papers/ (last visited Nov. 28, 2018 at
`3:02 p.m. CST)
`
`Exhibit 6
`
`Exhibit 7
`
`Exhibit 8
`
`
`
`I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 the foregoing is true and
`
`correct to the best of my knowledge. Executed on November 28, 2018 in Dallas, Texas.
`
`
`
`
`
`
`
`
`
`
`
`Chijioke E. Offor
`
`
`
`
`2
`
`

`

`
`GODO KAISHA IP BRIDGE 1,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.
`
`
`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 3 of 31 PageID #: 3115
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-290 (MN)
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`IP BRIDGE’S SUMMARY OF OMNIVISION’S RESPONSES TO
`ROG NOS. 1 AND 13 AND RPF NOS. 44, 48-52, 74, 76, AND 78
`
`OmniVision Response1
`3/5/2018 OmniVision Response: OmniVision
`is willing to meet and confer regarding the
`scope of this request.
`
`
`10/25/2018 OmniVision Response: Pursuant
`to Fed. R. Civ. P. 33(d), OmniVision identifies
`the following documents in which information
`responsive to this interrogatory may be
`ascertained: IPB1-OMNI 00033164.
`
`IP Bridge Discovery Requests
`INTERROGATORY NO. 1: Provide a spreadsheet or
`listing showing every OmniVision Product made or
`sold by you or at your direction since 2010, and for
`each product identify: (1) OmniVision’s position as to
`whether each product is sold in the United States,
`(2) OmniVision’s categorization of said product (i.e.
`OmniBSI, OmniBSI-2, PureCel, PureCel-S, and
`PureCel Plus-S), (3) all internal part numbers used for
`said product, and (4) all third-party devices of which
`OmniVision is aware that include said product.
`INTERROGATORY NO. 13: Identify each
`individual unit of each OMNIVISION PART
`manufactured or supplied with OmniVision’s
`authorization since April 22, 2008 by stating for each
`such unit: (a) the unique identifier(s) for the unit; (b)
`the part identifier; (c) the mask identifier; (d) the date
`and country of manufacture; (e) the purchase order
`number; (f) the name and address of the entity that
`issued the purchase order; (g) the name and address of
`each entity identified in or on the purchase order; (h)
`the internal order number; (i) the internal order date; (j)
`the unit price; (k) the unit cost; (l) the actual shipment
`date; (m) the shipment tracking number; (n) the name
`and address of the entity to which the unit has been
`shipped; (o) the name and address of each entity to
`which notice of shipment was given; (p) the rebate
`number; (q) the name and address of each known END
`CUSTOMER of such unit; and (r) any internal
`identifier for each such END CUSTOMER.
`
`1 OmniVision’s purported objections and boilerplate reservations of rights are not reproduced.
`
`10/26/2018 OmniVision Response: Pursuant
`to Fed. R. Civ. P. 33(d), OmniVision identifies
`the following document from which
`information responsive to this interrogatory
`may be ascertained: IPB1-OMNI 00033164.
`
`
`
`
`
`1
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 4 of 31 PageID #: 3116
`
`IP Bridge Discovery Requests
`RFP NO. 44: Documents sufficient to show the sales,
`revenue, cost, and profits for each Accused Product
`from April 22, 2010 to present.
`
`RFP NO. 48: For the TIME FRAME, all agreements
`concerning the actual or contemplated purchase of an
`OMNIVISION PART.
`
`RFP NO. 49: For the TIME FRAME, all agreements
`concerning the actual or contemplated price of an
`OMNIVISION PART.
`RFP NO. 50: For the TIME FRAME, all agreements
`concerning the actual or contemplated supply of an
`OMNIVISION PART.
`
`RFP NO. 51: For the TIME FRAME, all agreements
`concerning an actual or contemplated rebate related to
`an OMNIVISION PART.
`
`RFP NO. 52: For the TIME FRAME, all agreements
`concerning the actual or contemplated manufacture of
`an OMNIVISION PART. 
`
`RFP NO. 74: Documents sufficient to show the total
`number of units of each OMNIVISION PART that
`have been manufactured since April 22, 2010.
`
`
`OmniVision Response1
`10/19/2018 OmniVision Response:
`OmniVision has already produced documents
`sufficient to show the U.S. sales, revenue, cost,
`and profits for each Accused Product from
`April 2010 to present in its custody,
`possession, and control. OmniVision will not
`be producing additional documents in response
`to this Request.
`10/22/2018 OmniVision Response:
`OmniVision has already produced agreements
`relating to U.S. sales of the accused products in
`its custody, possession, and control.
`OmniVision will not be producing additional
`documents in response to this Request.
`10/22/2018 OmniVision Response:
`OmniVision will not be producing any
`documents in response to this Request.
`10/22/2018 OmniVision Response:
`OmniVision has already produced agreements
`relating to U.S. sales of the accused products in
`its custody, possession, and control.
`OmniVision will not be producing additional
`documents in response to this Request.
`10/22/2018 OmniVision Response:
`OmniVision has already produced agreements
`relating to U.S. sales of the accused products in
`its custody, possession, and control.
`OmniVision will not be producing additional
`documents in response to this Request.
`10/22/2018 OmniVision Response:
`OmniVision has already produced agreements
`relating to U.S. sales of the accused products in
`its custody, possession, and control.
`OmniVision will not be producing additional
`documents in response to this Request. 
`10/22/2018 OmniVision Response:
`OmniVision has already produced documents
`sufficient to show the total number of units of
`each OMNIVISION PART that have been
`manufactured and relate to U.S. sales since
`April 22, 2010. OmniVision will not be
`producing additional documents in response to
`this Request.
`
`
`
`
`2
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 5 of 31 PageID #: 3117
`
`IP Bridge Discovery Requests
`RFP NO. 76: Documents sufficient to show the total
`number of units of each OMNIVISION PART that
`have been supplied to a third party since April 22,
`2010.
`
`
`RFP NO. 78: Documents sufficient to show the
`revenue, cost, and profit for each unit of each
`OMNIVISION PART that has been supplied to a third
`party since April 22, 2010.
`
`
`OmniVision Response1
`10/22/2018 OmniVision Response:
`OmniVision has already produced documents
`sufficient to show the total number of units of
`each OMNIVISION PART that have been
`supplied to a third party and relate to U.S. sales
`since April 22, 2010. OmniVision will not be
`producing additional documents in response to
`this Request.
`10/22/2018 OmniVision Response:
`OmniVision has already produced documents
`sufficient to show the revenue, cost, and profit
`for each unit of each OMNIVISION PART that
`has been supplied to a third party in the U.S.
`since April 22, 2010. OmniVision will not be
`producing additional documents in response to
`this Request.
`
`
`
`
`
`
`3
`
`

`

`
`GODO KAISHA IP BRIDGE 1,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.
`
`
`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 6 of 31 PageID #: 3118
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-290 (MN)
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`IP BRIDGE’S SUMMARY OF OMNIVISION’S RESPONSES TO
`ROG NOS. 11-12 AND RFP NOS. 53-73
`
`IP Bridge Discovery Requests
`INTERROGATORY NO. 11: State the name and
`address of every importer, seller, marketer, distributor,
`or manufacturer of any smartphone, tablet, mobile
`device, digital still camera, automobile component,
`automobile, medical device, wearable technology,
`robotics application, machine vision application,
`security camera, surveillance system, PC, notebook,
`web camera, or other imaging application that
`integrates or otherwise includes an OMNIVISION
`PART manufactured or supplied with OmniVision’s
`authorization on or after April 22, 2008.
`
`OmniVision Response1
`10/26/2018 OmniVision Response:
`OmniVision has no direction or control over
`the disposition of its image sensors
`following the sale of its image sensors. As a
`result, OmniVision does not have possession,
`custody, or control of information that is
`responsive to this interrogatory.
`
`
`1 OmniVision’s purported objections and boilerplate reservations of rights are not reproduced.
`
`
`
`
`1
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 7 of 31 PageID #: 3119
`
`IP Bridge Discovery Requests
`INTERROGATORY NO. 12: Separately, for each
`OMNIVISION PART manufactured or supplied with
`OmniVision’s authorization on or after April 22, 2008,
`state the three persons most knowledgeable about, and
`the person(s) having direct responsibility for, each of
`the following: (a) the identity of each END
`CUSTOMER of each such OMNIVISION PART; (b)
`actions taken by OmniVision in the United States to
`promote such OMNIVISION PART to each END
`CUSTOMER; (c) actions taken by OmniVision in the
`United States to design, customize, or otherwise
`modify such OMNIVISION PART for integration into
`END CUSTOMER products; (d) the manufacturing in
`the United States of such OMNIVISION PART; (e) the
`importation into the United States of samples of such
`OMNIVISION PART; (f) the testing or operation in
`the United States of samples of such OMNIVISION
`PART; (g) the agreements concerning any END
`CUSTOMER and such OMNIVISION PART; (h)
`electronic, written, and/or in-person communications
`with each END CUSTOMER concerning the actual or
`contemplated development, design, features, testing, or
`performance of such OMNIVISION PART; (i)
`electronic, written, and/or in-person communications
`with each END CUSTOMER concerning the actual or
`contemplated manufacture, purchase, price, or supply
`of such OMNIVISION PART; and (j) electronic,
`written, and/or in-person communications with each
`END CUSTOMER concerning an actual or
`contemplated rebate, refund, or discount related to such
`OMNIVISION PART
`RFP NOS. 53-58: [REQUESTING, FOR RAY
`CISNEROS, THE INFORMATION REQUESTED IN
`RFP NOS. 59-64]
`RFP NO. 59: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI concerning the actual or
`contemplated purchase of an OMNIVISION PART.
`RFP NO. 60: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI concerning the actual or
`contemplated price of an OMNIVISION PART.
`RFP NO. 61: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI concerning the actual or
`contemplated supply of an OMNIVISION PART.
`
`
`
`
`2
`
`OmniVision Response1
`10/26/2018 OmniVision Response:.
`OmniVision incorporates by reference its
`Initial Disclosures served pursuant to Fed. R.
`Civ. P. 26(a)(1), dated October 30, 2017; and
`Initial Disclosures served pursuant to the
`District of Delaware’s Default Standard for
`Discovery, dated November 17, 2017.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 8 of 31 PageID #: 3120
`
`IP Bridge Discovery Requests
`RFP NO. 62: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI concerning an actual or
`contemplated rebate related to an OMNIVISION
`PART.
`RFP NO. 63: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI concerning the actual or
`contemplated manufacture of an OMNIVISION PART.
`RFP NO. 64: For the TIME FRAME, all
`communications and documents received, sent, or
`possessed by JOHN LI that concern an OMNIVISION
`PART and contain one or more of the following terms:
`“supply” or “purchase” or “purchases” or “buy” or
`“deliver” or “delivery” or “deliveries” or “purchase
`order” or “manufacturing agreement” or “long term
`agreement” or “long term contract” or “supply
`agreement” or “supply contract” or “negotiation” or
`“negotiations” or “volume” or “quantity” or “lead
`time” or “shipment” or “order” or “price” or “pricing”
`or “credit” or “rebate” or “reduction” or “return” or
`“refund” or “manufacture” or “fabrication” or
`“commercialization” or “strategic relationship” or
`“strategic cooperation” or “forecast” or “projection” or
`“project” or “projected” or “import”.
`RFP NOS. 65-70: [REQUESTING, FOR VINCENT
`CHEW, THE INFORMATION REQUESTED IN RFP
`NOS. 65-70]
`
`OmniVision Response1
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`RFP NO. 71: For the TIME FRAME, all versions of
`all policies and procedures concerning marketing and
`promotion of any OmniVision product.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`RFP NO. 72: For the TIME FRAME, all versions of
`all policies and procedures concerning selling and/or
`supplying any OmniVision product.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`RFP NO. 73: For the TIME FRAME, all versions of
`all policies and procedures concerning rebates for any
`OmniVision product.
`
`10/22/2018 OmniVision Response:.
`OmniVision will not be producing any
`documents in response to this Request.
`
`
`
`
`
`
`3
`
`

`

`
`GODO KAISHA IP BRIDGE 1,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.
`
`
`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 9 of 31 PageID #: 3121
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-290 (MN)
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`IP BRIDGE’S SUMMARY OF OMNIVISION’S RESPONSES TO RFP NOS. 45-47
`
`IP Bridge Discovery Requests
`RFP NO. 45: All documents produced by
`OmniVision in the action Godo Kaisha IP Bridge
`1 v. OmniVision Technologies, Inc., No. 5:17-cv-
`00778 (N.D. Cal.).
`
`RFP NO. 46: An unredacted copy of the
`transcription of, and unredacted copies of all
`exhibits to, each deposition taken in the action
`Godo Kaisha IP Bridge 1 v. OmniVision
`Technologies, Inc., No. 5:17-cv-00778 (N.D.
`Cal.).
`RFP NO. 47: An unredacted copy of, and
`unredacted copies of all Bates labeled documents
`cited in, OmniVision’s responsive damages
`contentions, served on or about February 23, 2018
`pursuant to Patent Local Rule 3-9, in the action
`Godo Kaisha IP Bridge 1 v. OmniVision
`Technologies, Inc., No. 5:17-cv-00778 (N.D.
`Cal.).
`
`OmniVision Response1
`10/18/2018 OmniVision Response:
`[D]ocuments responsive to this Request
`has been produced. OmniVision will not be
`producing additional documents in
`response to this Request.
`10/18/2018 OmniVision Response:
`OmniVision will not be producing
`documents in response to this Request.
`
`10/18/2018 OmniVision Response:
`[D]ocuments responsive to this Request
`has been produced. OmniVision will not be
`producing additional documents in
`response to this Request.
`
`
`1 OmniVision’s purported objections and boilerplate reservations of rights are not reproduced.
`
`
`
`
`1
`
`

`

`
`GODO KAISHA IP BRIDGE 1,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.
`
`
`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 10 of 31 PageID #: 3122
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 16-290 (MN)
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`IP BRIDGE’S SUMMARY OF OMNIVISION’S RESPONSES TO RFP NOS. 13-40
`
`IP Bridge Request
`RFP No. 13: An unredacted copy of all portions of
`OmniVision’s invalidity contentions and claim charts
`that concern the MORI ’796 PATENT in the action
`Collabo Innovations, Inc. v. OmniVision Technologies,
`Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 14: An unredacted copy of all portions of
`OmniVision’s invalidity contentions and claim charts
`that concern the MORI ’431 PATENT in the action
`Collabo Innovations, Inc. v. OmniVision Technologies,
`Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 15: An unredacted copy of all portions of
`OmniVision’s invalidity contentions and claim charts
`that concern the MORI ’401 PATENT in the action
`Collabo Innovations, Inc. v. OmniVision Technologies,
`Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 16: An unredacted copy of all portions of
`OmniVision’s invalidity contentions and claim charts
`that concern the MORI ’861 APPLICATION in the
`action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 17: An unredacted copy of all portions of
`OmniVision’s invalidity contentions and claim charts
`that concern the MORI ’010 PATENT in the action
`Collabo Innovations, Inc. v. OmniVision Technologies,
`Inc., No. 1:16-cv-00197 (D. Del.).
`
`OmniVision’s Response1
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request at this time.
`
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request at this time.
`
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request at this time.
`
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request at this time.
`
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request at this time.
`
`
`1 OmniVision’s purported objections and boilerplate reservations of rights are not reproduced.
`
`
`
`
`1
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 11 of 31 PageID #: 3123
`
`IP Bridge Request
`RFP No. 18: An unredacted copy of all statements
`made to, or received from, any third party that concern
`the MORI ’796 PATENT in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 19: An unredacted copy of all statements
`made to, or received from, any third party that concern
`the MORI ’431 PATENT in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 20: An unredacted copy of all statements
`made to, or received from, any third party that concern
`the MORI ’401 PATENT in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 21: An unredacted copy of all statements
`made to, or received from, any third party that concern
`the MORI ’861 APPLICATION in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 22: An unredacted copy of all statements
`made to, or received from, any third party that concern
`the MORI ’010 PATENT in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 23: An unredacted copy of all portions of all
`documents provided to, or received from, any third
`party that concern the MORI ’796 PATENT in the
`action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 24: An unredacted copy of all portions of all
`documents provided to, or received from, any third
`party that concern the MORI ’431 PATENT in the
`action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 25: An unredacted copy of all portions of all
`documents provided to, or received from, any third
`party that concern the MORI ’401 PATENT in the
`action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`
`OmniVision’s Response1
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`
`
`
`2
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 12 of 31 PageID #: 3124
`
`IP Bridge Request
`RFP No. 26: An unredacted copy of all portions of all
`documents provided to, or received from, any third
`party that concern the MORI ’861 APPLICATION in
`the action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`
`OmniVision’s Response1
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`RFP No. 27: An unredacted copy of all portions of all
`documents provided to, or received from, any third
`party that concern the MORI ’010 PATENT in the
`action Collabo Innovations, Inc. v. OmniVision
`Technologies, Inc., No. 1:16-cv-00197 (D. Del.).
`
`10/10/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`RFP No. 28: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of VINCENT VENEZIA in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 29: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of DULI MAO in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 30: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of T.J. DAI in the action Collabo Innovations,
`Inc. v. OmniVision Technologies, Inc., No. 1:16-cv-
`00197 (D. Del.).
`RFP No. 31: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of PETER LEE in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 32: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of CHENWEI LU in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`RFP No. 33: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of RUI WANG in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`
`
`
`3
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 13 of 31 PageID #: 3125
`
`IP Bridge Request
`RFP No. 34: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of DAJIANG YANG in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 35: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of SOHEI MANABE in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 36: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of KEIJI MABUCHI in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 37: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of TRUEMAN PANG in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 38: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of DYSON TAI in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`RFP No. 39: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of CHAD (CHAO-HUNG) LIN in the action
`Collabo Innovations, Inc. v. OmniVision Technologies,
`Inc., No. 1:16-cv-00197 (D. Del.).
`RFP No. 40: An unredacted copy of the transcript of,
`and unredacted copies of all exhibits to, the deposition
`of each of GEOFFREY WANG in the action Collabo
`Innovations, Inc. v. OmniVision Technologies, Inc., No.
`1:16-cv-00197 (D. Del.).
`
`OmniVision’s Response1
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`10/11/2018 OmniVision Response:
`OmniVision will not be producing documents
`in response to this Request as they are untimely
`pursuant to this Court’s Scheduling Order. See
`Dkt. No. 72.
`
`
`
`
`
`
`4
`
`

`

`Case 1:16-cv-00290-MN Document 129-1 Filed 11/28/18 Page 14 of 31 PageID #: 3126
`
`290-IPB-OVT031325
`
`by subtracting the Sig.1 (Sig.2) reference voltage level generated
`at the first step from the signal voltage level of the M3-1 (M3-2)
`output. In the third step, the conversion signal of the M3-1 (M3-
`2) transistor is isolated from the signal lines by cutting off the
`M4-1 (M4-2) transistor. From the fourth step to the sixth step,
`the photo-charges in the PD-2 (PD-4) region are read out by the
`same principle of operation. Thus, within the pixel unit consist-
`ing of the four photodiodes (PD-1-4), the signal read-out opera-
`tion is made by transferring photo-charges from a pair of the
`photodiodes in the odd columns followed by transferring photo-
`charges from another pair of the photodiodes in the even
`columns. It is noted that, for reading the charges of PD3 and
`PD4, the floating diffusion region lo