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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 6 of 19 PageID #: 2519
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`
`
`
`Case No. 17-cv-868-CFC-SRF
`
`
`
`Plaintiffs,
`
`Defendant.
`
`UNIVERSITY OF MASSACHUSETTS
`and CARMEL LABORATORIES, LLC,
`
`
`
`v.
`
`L’ORÉAL USA, INC.,
`
`
`
`
`
`
`
`
`
`UNIVERSITY OF MASSACHUSETTS AND CARMEL LABORATORIES, LLC’S
`FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT
`L’OREAL USA, INC.
`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiffs University
`
`of Massachusetts (“UMass”) and Carmel Laboratories, LLC (“Carmel Labs”) hereby request that
`
`Defendant L’Oréal USA, Inc. (“L’Oréal”) produce the following documents and things at the
`
`office of Susman Godfrey L.L.P., 1301 Avenue of the Americas, 32nd Floor, New York, NY
`
`10019, or at such other mutually agreed upon place, within 30 days hereof and in the manner
`
`required by the Federal Rules of Civil Procedure.
`
`DEFINITIONS
`
`1.
`
`The term “UMass” refers to the University of Massachusetts, including any of its past
`
`and present affiliates, operating divisions, campuses, subsidiaries, directors, officers,
`
`agents, employees, representatives, and all persons acting on its behalf.
`
`2.
`
`The term “Carmel Labs” refers to Carmel Laboratories, LLC, including any of its past
`
`and present affiliates, operating divisions, parent corporations, subsidiaries, directors,
`
`officers, agents, employees, representatives, and all persons acting on its behalf.
`
`1
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 7 of 19 PageID #: 2520
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`3.
`
`The terms “Defendant,” “You,” “Your,” or “L’Oréal” shall refer to defendant L’Oréal
`
`USA, Inc., and shall include L’Oréal S.A. as well as L’Oréal USA Inc.’s parent,
`
`subsidiaries, affiliates, divisions, successors or assignees, and their respective
`
`officers, directors, employees, consultants, representatives, and agents.
`
`4.
`
`The term “Present Lawsuit” refers to the case styled University of Massachusetts, et
`
`al. v. L’Oréal USA, Inc., Case No. 1:17-cv-00868-CFC-SRF, pending in the United
`
`States District Court for the District of Delaware.
`
`5.
`
`The term “Document” or “Documents” is used in the broadest sense permitted by the
`
`Federal Rules of Civil Procedure and means the original (or any copy when originals
`
`are not available) and any drafts or non-identical copies thereof, whether different
`
`from the original because of interlineations, receipt stamp, notation of copy sent or
`
`received or otherwise, of any email, instant message, voicemail, book, pamphlet,
`
`periodical, letter, report, note, memorandum, record, minutes, calendar or diary entry,
`
`transcript, study, compilation, analysis, tabulation, map, diagram, drawing, plan,
`
`picture, summary, working paper, chart, paper, graph index, data sheet, data
`
`processing card, computer printout, summary of a computer printout, tape, contract,
`
`agreement, lease, ledger, journal, balance sheet, account, invoice, purchase order,
`
`receipt, billing record, financial data, financial statement, file, diary, film, trip tickets,
`
`telex, teletype or other messages, telegram, expense vouchers, instructions, bulletins
`
`or any other writing or recording of information, as well as all tape recordings,
`
`computer tapes, discs and other electronic or mechanical recordings, however
`
`produced, maintained or reproduced, including information stored in or generated by
`
`a computer whether or not ever printed out or displayed, within the possession,
`
`2
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 8 of 19 PageID #: 2521
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`custody or control of Defendant or any of its officers, directors, employees, attorneys,
`
`or other agents and/or representatives.
`
`6.
`
`The term “Person” means natural person, corporation, firm, company, sole
`
`proprietorship, partnership, joint venture, association, institute, or other business,
`
`legal or governmental entity or association, including any directors, officers,
`
`employees, agents or representatives thereof.
`
`7.
`
`8.
`
`The term “Agreement” means a contract, agreement, arrangement, or understanding,
`
`formal or informal, oral or written, between two or more persons.
`
`The term “Communication” refers to any transfer of information, oral or written, be it
`
`in the form of facts, ideas, inquiries, opinions or otherwise, by any means, at any time
`
`or place, under any circumstances, and is not limited to transfers between persons, but
`
`includes other transfers, such as records and memoranda to the file.
`
`9.
`
`The phrase “Relating To” means discussing, describing, referring to, pertaining to,
`
`containing, analyzing, studying, reporting on, commenting on, evidencing,
`
`constituting, setting forth, considering, recommending, concerning, or pertaining to,
`
`in whole or in part.
`
`10.
`
`The terms “Asserted Patents” and “Patents-in-Suit” shall mean United States Patents
`
`No. 6,423,327 and 6,645,513.
`
`The term “’327 Patent” refers to U.S. Patent No. 6,423,327.
`
`The term “’513 Patent” refers to U.S. Patent No. 6,645,513.
`
`The term “Prior Art” means any evidence qualifying as prior art to the Patents-in-Suit
`
`11.
`
`12.
`
`13.
`
`under 35 U.S.C. § 102 and/or 35 U.S.C. § 103.
`
`14.
`
`The terms “all” and “each” shall be construed as “and,” “each,” and “and/or.”
`
`3
`
`
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 9 of 19 PageID #: 2522
`
`15.
`
`The term “any” should be understood in either its most or least inclusive sense as will
`
`bring within the scope of the topic all responses that might otherwise be construed to
`
`be out of its scope.
`
`16.
`
`17.
`
`The term “including” shall mean including but not limited to.
`
`The terms “relate,” “relating,” or “related” mean in any way, directly or indirectly, in
`
`whole or part, relating to, concerning, referring to, discussing, mentioning, regarding,
`
`pertaining to, describing, reflecting, containing, analyzing, studying, reporting on,
`
`commenting on, evidencing, constituting, setting forth, considering, recommending,
`
`modifying, amending, confirming, endorsing, representing, supporting, qualifying,
`
`terminating, revoking, refuting, undermining, canceling, contradicting or negating.
`
`18.
`
`The terms “and” and “or” shall be construed disjunctively or conjunctively as
`
`necessary to bring within the scope of these topics all information which might
`
`otherwise be construed to be outside their scope.
`
`19.
`
`References to the singular shall include the plural, and references to the plural shall
`
`include the singular as may be appropriate to construe the individual document
`
`requests in their broadest form.
`
`20.
`
`The masculine form of a noun or pronoun shall be considered to include within its
`
`meaning the feminine form of the noun or pronoun, and vice versa as may be
`
`appropriate to make the individual document requests inclusive rather than exclusive.
`
`INSTRUCTIONS
`
`1.
`
`Responsive documents shall be produced as they have been kept in the usual course
`
`of business and shall not be shuffled or otherwise rearranged. Alternatively, you may
`
`produce responsive documents organized and labeled to correspond to the enumerated
`
`4
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 10 of 19 PageID #: 2523
`
`requests of this demand. If any portion of any document is responsive to any request,
`
`then the entire document must be produced. Documents that are found stapled,
`
`clipped, or otherwise fastened together shall be produced in such form. If there is no
`
`document responsive to any particular category, you shall so state in writing.
`
`2.
`
`If any portion of a document is responsive to an individual document request, then the
`
`entire document shall be produced. If the document contains privileged material,
`
`produce the entire document with the privileged material redacted, noting the
`
`redactions on the face of the document.
`
`3.
`
`If information stored in, or accessible through, computer or other data retrieval
`
`systems is produced, it must be accompanied with instructions and all other materials
`
`4.
`
`5.
`
`necessary to use or interpret such data.
`
`All documents which cannot be legibly copied should be produced in their original
`
`form.
`
`Each individual document request set forth herein shall be construed independently
`
`and not with reference to any other request for purposes of limitation unless a
`
`particular request so specifies.
`
`6.
`
`Where specific documents are listed as part of a general category of documents, then
`
`such listed documents as well as all other documents falling within such general
`
`category shall be produced. If any responsive document is withheld under a claim of
`
`privilege, You shall furnish a list specifying each such document and setting forth the
`
`following information: (i) the date of the document; (ii) the number of pages of the
`
`document; (iii) the name and last known address of each person who prepared or
`
`participated in the preparation of the document; (iv) the name and last known address
`
`5
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 11 of 19 PageID #: 2524
`
`of each addressee or other person to whom the document, or any part thereof, was
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`sent or to whom the document or its contents, or any part thereof, was disclosed; (v) a
`
`summary of the general subject matter of the document (and such other information
`
`as is necessary to identify the document such as whether the document is a letter or
`
`memorandum); (vi) a statement of the basis upon which the asserted privilege is
`
`claimed; and (vii) the individual document request herein to which the document is
`
`responsive. If no documents are withheld under a claim of privilege, so state. Any
`
`document or part of a document withheld under a claim of privilege must be
`
`preserved.
`
`7.
`
`If any document responsive to this request once existed but has been destroyed or
`
`discarded, or is otherwise not capable of being produced, You shall furnish a list
`
`specifying each such document and setting forth the following information: (i) the
`
`date of the document; (ii) a description of the subject matter of the document; (iii) the
`
`name and last known address of each person who prepared or participated in the
`
`preparation of the document; (iv) the name and last known address of each addressee
`
`or other person to whom the document, or any part thereof, was sent or to whom the
`
`document or its contents, or any part thereof, was disclosed; (v) the name and last
`
`known address of any person not covered by items (iii) and (iv) who had possession,
`
`custody or control of the document or a copy thereof; (vi) the date on which the
`
`document was destroyed or discarded and a statement of the reasons why the
`
`document was destroyed or discarded or why such document is not capable of being
`
`produced; and (vii) the individual document request herein to which the document is
`
`responsive.
`
`6
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 12 of 19 PageID #: 2525
`
`8.
`
`9.
`
`Unless otherwise specified, the documents requested herein are documents prepared,
`
`written, sent, dated, received, or in effect at any time on or after October 26, 1998.
`
`This request for documents shall be deemed continuing in nature so as to require
`
`prompt supplemental responses in accordance with Rule 26(e) of the Federal Rules of
`
`Civil Procedure in the event You become aware of, or acquire within Your
`
`possession, custody, or control, additional responsive documents at any time
`
`hereafter.
`
`REQUESTS FOR PRODUCTION
`
`REQUEST FOR PRODUCTION NO. 1: All documents mentioning or concerning the Patents-
`
`in-Suit or their applications, including parent, divisional, continuation, or continuation-in-part
`
`applications, whether or not they mature into patents.
`
`REQUEST FOR PRODUCTION NO. 2: All documents concerning Your knowledge or
`
`awareness of the Patents-in-Suit, including documents indicating when You (including any
`
`employee, contractor, representative, or agent) became aware of the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 3: All documents and things on which You rely or
`
`intend to rely to assert or establish that Your infringement of the Patents-in-Suit is not willful.
`
`REQUEST FOR PRODUCTION NO. 4: All documents concerning Your policies or practices
`
`concerning patent clearances, right-to-use opinions, or other mechanisms to avoid Your
`
`infringement of patents.
`
`REQUEST FOR PRODUCTION NO. 5: All documents relating to the methodology used by
`
`You to determine value or royalty rates for patents or other proprietary technology, for licensing,
`
`tax, accounting or any other purpose.
`
`REQUEST FOR PRODUCTION NO. 6: All documents and things created or gathered prior to
`
`7
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`
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 13 of 19 PageID #: 2526
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`the filing of Plaintiffs’ Complaint concerning the results of any prior art search directed to, or
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`relating to, or containing the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 7: All documents relating to searches or investigations
`
`relating to the scope, validity, infringement, or enforceability of the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 8: All documents concerning any analysis, opinion, or
`
`inquiry regarding potential infringement of any claims of the Patents-in-Suit, including but not
`
`limited to any documents concerning or relating to pre-litigation investigations performed by or
`
`on behalf of You or Your partners, licensors, customers, resellers, or affiliates, relating to the
`
`potential infringement by any products made, used, offered for sale, or sold by You or Your
`
`partners, licensors, customers, resellers, or affiliates.
`
`REQUEST FOR PRODUCTION NO. 9: All correspondence with counsel and other
`
`documents expressing opinions on or concerning validity, invalidity, infringement, non-
`
`infringement, enforceability, non-enforceability, or licensing (whether express or implied) of the
`
`Patents-in-Suit; any affirmative defense listed in Your Answer to Plaintiffs’ Complaint; or any
`
`other affirmative defense under Fed. R. Civ. P. Rules 8 or 9. Identify any documents responsive
`
`to this Request withheld on grounds of privilege or on any other basis according to Instruction 6.
`
`REQUEST FOR PRODUCTION NO. 10: Any and all documents concerning any analyses or
`
`efforts by You to design any products around the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 11: All documents relating to any communications with
`
`Your sales force, agents, dealers, wholesalers, retailers, representatives, distributors, the press,
`
`any news wire, or any other third party concerning the Patents-in-Suit, Carmel Labs, UMass, or
`
`this lawsuit.
`
`REQUEST FOR PRODUCTION NO. 12: All documents received by You from any third
`
`8
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`
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 14 of 19 PageID #: 2527
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`party that were requested from such third party as part of this litigation, that relate to this
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`litigation, and/or that are responsive to any outstanding request for production served on You as
`
`part of this litigation, including (but not limited to) any documents received pursuant to a
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`subpoena.
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`REQUEST FOR PRODUCTION NO. 13: All documents reflecting communications between
`
`You and/or Your counsel and any third party relating to this lawsuit, the Patents-in-Suit, and/or
`
`Plaintiffs.
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`REQUEST FOR PRODUCTION NO. 14: All documents relating or referring to the
`
`indemnification or offer to indemnify, or request for indemnification by, any of Your customers,
`
`prospective customers, or third-parties with respect to the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 15: All documents furnished to or shown to any third-
`
`party fact witness contacted, interviewed, or consulted by You or Your agents or attorneys in
`
`connection with the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 16: All documents that refer or relate to any document
`
`that You believe is relevant to the construction or interpretation of any claim of any of the
`
`Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 17: All documents that support or relate to any
`
`affirmative defense or counterclaim You have asserted.
`
`REQUEST FOR PRODUCTION NO. 18: All documents concerning Your contentions on
`
`reasonable royalties pursuant to 35 U.S.C. § 284 for any infringement of the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 19: All documents that refer or relate to any prior art
`
`reference that You believe anticipates or renders obvious of the Patents-in-Suit.
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`REQUEST FOR PRODUCTION NO. 20: All documents that set forth Your document
`
`9
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`
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 15 of 19 PageID #: 2528
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`destruction and retention policies.
`
`REQUEST FOR PRODUCTION NO. 21: For the years 2009 to the present, all of Your annual
`
`reports, required financial filings and other financial statements, including but not limited to
`
`statements of operations, profit and loss statements, income statements, balance sheets,
`
`statements of changes in retained earnings, and internal management reports and notes thereto,
`
`whether the notes are for internal or external report purposes.
`
`REQUEST FOR PRODUCTION NO. 22: All documents that refer or relate to U.S. Patent
`
`Application No. 10/701,495, 11/152,707, 12/649,367.
`
`REQUEST FOR PRODUCTION NO. 23: All documents that refer or relate to U.S. Patents
`
`No. 9,018,177; 9,023,826; 9,072,919; and 9,107,853.
`
` REQUEST FOR PRODUCTION NO. 24: All documents relating to any communications
`
`between You and Carmel Labs, UMass, or the inventors of the Patents-in-Suit.
`
`REQUEST FOR PRODUCTION NO. 25: All documents relating to any testing You have
`
`performed regarding penetration of adenosine into the skin.
`
`REQUEST FOR PRODUCTION NO. 26: All Your issued patents or patent applications that
`
`relate or refer to adenosine.
`
`REQUEST FOR PRODUCTION NO. 27: All documents in Your possession or control
`
`relating or referring to adenosine, including but not limited to documents related to Your
`
`decision to include adenosine as an ingredient in Your products.
`
`REQUEST FOR PRODUCTION NO. 28: All documents relating to any testing You have
`
`performed relating to or regarding adenosine, including but not limited to any communications
`
`referring or relating to the results of such testing.
`
`REQUEST FOR PRODUCTION NO. 29: All documents relating to Plaintiffs’ Interrogatories.
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`10
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 16 of 19 PageID #: 2529
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`REQUEST FOR PRODUCTION NO. 30: For each product identified in response to
`
`Interrogatory No. 3, provide a sample of that product as well as the product packaging, any
`
`instruction that are provided to consumers with that product, and any marketing materials related
`
`to that product.
`
`REQUEST FOR PRODUCTION NO. 31: All documents referring or relating to your efforts to
`
`market and/or sell products containing adenosine.
`
`REQUEST FOR PRODUCTION NO. 32: All documents referring or relating to any benefit
`
`from using adenosine on human skin.
`
`REQUEST FOR PRODUCTION NO. 33: All documents relating or referring to an article
`
`entitled “Formulation, characterization, and efficacy of an adenosine-containing dissolvable film
`
`for a localized anti-wrinkle effect,” by J.Y. Legendre, I. Schnitzler, Q-Y. Li, C. Hausen, M.
`
`Huart, G. S. Luengo, M. L. Abella, and M. Roreger.
`
`REQUEST FOR PRODUCTION NO. 34: All documents relating or referring to an article
`
`entitled “Evaluation of anti-wrinkle efficacy of adenosine-containing products using the FOITS
`
`technique,” by M.L. Abella.
`
`DATED: July 15, 2019
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`Of Counsel:
`William Christopher Carmody
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`FARNAN LLP
`
`
`
`
`/s/ Brian E. Farnan
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`Telephone: (302) 777-0300
`Facsimile: (302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw,com
`
`
`
`
`11
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`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 17 of 19 PageID #: 2530
`
`Tamar E. Lusztig
`Beatrice C. Franklin
`SUSMAN GODFREY L.L.P.
`1301 Avenue of the Americas, 32nd Floor
`New York, NY 10019
`Telephone: (212) 336-8330
`Facsimile: (212) 336-8340
`bcarmody@susmangodfrey.com
`tlusztig@susmangodfrey.com
`bfranklin@susmangodfrey.com
`
`Justin A. Nelson
`SUSMAN GODFREY L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Telephone: (713) 651-9366
`Facsimile: (713) 654-6666
`jnelson@susmangodfrey.com
`
`
`
`
`
`Matthew B. Lowrie
`FOLEY & LARDNER LLP
`111 Huntington Avenue, Suite 2600
`Boston, MA 02199
`Telephone: (617) 342-4000
`Facsimile: (617) 342-4001
`mlowrie@foley.com
`
`
`
`
`COMMONWEALTH OF MASSACHUSETTS,
`
`By its attorney,
`
`MAURA HEALEY
`ATTORNEY GENERAL
`
`By: William Christopher Carmody
`William Christopher Carmody
`Special Assistant Attorney General
`SUSMAN GODFREY L.L.P.
`
`
`
`
`
`12
`
`Attorneys for University of Massachusetts
`and Carmel Laboratories, LLC
`
`Attorneys for Carmel Laboratories, LLC
`
`
`
`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 18 of 19 PageID #: 2531
`
`1301 Avenue of the Americas, 32nd Floor
`New York, NY 10019
`Telephone: (212) 336-8330
`Facsimile: (212) 336-8340
`bcarmody@susmangodfrey.com
`
`
`
`
`Attorney for University of Massachusetts
`
`13
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`
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`Case 1:17-cv-00868-CFC-SRF Document 93-1 Filed 02/20/20 Page 19 of 19 PageID #: 2532
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`CERTIFICATE OF SERVICE
`
`
`
`I, Brian E. Farnan, hereby certify that on July 15, 2019, a copy of University of
`
`Massachusetts and Carmel Laboratories, LLC’s First Set of Requests for Production of
`
`Documents to Defendant L’Oreal USA, Inc. was served on the following as indicated:
`
`Via E-Mail
`Frederick L. Cottrell, III
`Jeffrey L. Moyer
`Katharine L. Mowery
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, Delaware 19801
`cottrell@rlf.com
`moyer@rlf.com
`mowery@rlf.com
`
`Attorneys for Defendant L’Oreal USA, Inc.
`
`Via E-Mail
`Dennis S. Ellis
`Katherine F. Murray
`Serli Polatoglu
`Naveen Modi
`Joseph E. Palys
`Paul Hastings LLP
`dennisellis@paulhastings.com
`katharinemurray@paulhastings.com
`serlipolatoglu@paulhastings.com
`naveenmodi@paulhastings.com
`josephpalys@paulhastings.com
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`Attorneys for Defendant L’Oreal USA, Inc.
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`/s/ Brian E. Farnan
`Brian E. Farnan (Bar No. 4089)
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