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`EXHIBIT 6
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`Case 2:22-md-03034-TGB ECF No. 215-7, PageID.12175 Filed 01/12/24 Page 2 of 6
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`Case 2:22-md-03034-TGB ECF No. 215-7, PageID.12176 Filed 01/12/24 Page 3 of 6
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`REQUEST FOR PRODUCTION NO. 18:
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`All agreements, assignments, or contracts between You and AT&T, Adaptix, Broadstorm
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`Telecommunications, Inc., Waltical Solutions, Walbell Technologies, Inc., Neocific, Inc., and Neo
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`Wireless.
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`REQUEST FOR PRODUCTION NO. 19:
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`All Documents and Communications relating to Your experience with and involvement in
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`the IEEE, including but not limited to your involvement in the IEEE’s efforts to develop the
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`WiMAX standard.
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`REQUEST FOR PRODUCTION NO. 20:
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`All Documents, Communications, and Things referring or relating to the fixed wireless
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`and/or broadband wireless access (BWA) system referred to as “Project Dino,” “Project Angel,”
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`“AT&T Digital Broadband,” “SymmetryOne,” or “SymmetryMX,” including without limitation
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`research or laboratory notebooks, workbooks, or diaries; technical files, drawings, or graphs;
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`presentation materials; testing data, reports, or summaries; and/or notes, descriptions, or
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`memoranda.
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`REQUEST FOR PRODUCTION NO. 21:
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`All Documents and Communications relating to the formation of CFIP NCF, including but
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`not limited to hiring strategies, founding partners, and employee history.
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`REQUEST FOR PRODUCTION NO. 22:
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`All Documents and Communications relating or referring to 3GPP, ETSI, ATIS, and/or
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`IEEE.
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`12
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`Case 2:22-md-03034-TGB ECF No. 215-7, PageID.12177 Filed 01/12/24 Page 4 of 6
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`Case 2:22-md-03034-TGB ECF No. 215-7, PageID.12178 Filed 01/12/24 Page 5 of 6
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`TOPIC NO. 14:
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`Facts and circumstances regarding any analysis, research, or testing that compares the
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`Patented Technology with any Prior Art or any other technology, whether the other technology
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`was created by You or any third party.
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`TOPIC NO. 15:
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`Your contribution to the claimed invention, if any, and the contribution of any Named
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`Inventor to the claimed invention, including but not limited to Your or any Inventor’s diligence in
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`reducing to practice or activities taken to reduce the invention to practice and when.
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`TOPIC NO. 16:
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`Any secondary considerations or other objective indicia of non-obviousness related to each
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`of the Patents-in-Suit, including without limitation commercial success, long-felt need, failure of
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`others, copying and imitation by others, praise by others, skepticism, industry recognition and
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`praise for patented products, simultaneous invention, contemporaneous related technologies and
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`market needs, licensing by others, and unexpected results.
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`TOPIC NO. 17:
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`Your knowledge and understanding of the features, functionality, and/or public availability
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`of any fixed and/or broadband wireless project(s) or product(s) incorporating the project(s) known
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`as “Project Dino,” “Project Angel,” “AT&T Digital Broadband,” “SymmetryMX” or
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`“SymmetryONE,” including Your knowledge and understanding of how said features and
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`functionality changed.
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`TOPIC NO. 18:
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`Facts and circumstances of any fixed and/or broadband wireless project(s) or product(s)
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`incorporating the project(s) known as “Project Dino,” “Project Angel,” “AT&T Digital
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`8
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`Case 2:22-md-03034-TGB ECF No. 215-7, PageID.12179 Filed 01/12/24 Page 6 of 6
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`Broadband,” “SymmetryMX” or “SymmetryONE,” including but not limited to when and how
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`you first became aware of the foregoing projects.
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`TOPIC NO. 19:
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`Facts and circumstances relating to any embodiments, including commercial embodiments,
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`of the Patented Technology or the subject matter claimed in the Patents-in-Suit.
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`TOPIC NO. 20:
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`Facts and circumstances relating to any financial interest You or any Named Inventor of
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`the Patents-in-Suit may have in the outcome of This Action or any Other Action.
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`TOPIC NO. 21:
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`Facts and circumstances relating to any money or consideration paid or given in exchange
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`for any grant of any right or interest in, or any transfer of any of the Patents-in-Suit, Applications,
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`or Patented Technology.
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`TOPIC NO. 22:
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`Facts and circumstances relating to the filing of all patent applications to which the Patents-
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`in-Suit and related Patent Families claim priority, either in whole or in part.
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`TOPIC NO. 23:
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`Facts and circumstances relating to all agreements, assignments, contracts, or non-
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`disclosure agreements between You and AT&T, Adaptix, Broadstorm Telecommunications, Inc.,
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`Waltical Solutions, Inc., Walbell Technologies, Inc., Neocific, Inc., or Neo Wireless, including
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`any subsidiary, predecessor-in-interest, or related entity thereof.
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`TOPIC NO. 24:
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`Facts and circumstances relating to the formation of CFIP NCF, including but not limited
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`to hiring strategies, founding partners, and employee history.
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`9
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