Case 1:14-cv-02396-PGG-SN Document 249-10 Filed 04/07/21 Page 1 of 4
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`Exhibit J
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`Exhibit J
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`Case 1:14-cv-02396-PGG-SN Document 249-10 Filed 04/07/21 Page 2 of 4
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`NETWORK-I TECHNOLOGIES, INC.,
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`Plaintiff,
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`- against-
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`14 Civ. 2396 (PGG)
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`GOOGLE, INC., and YOUTUBE, LLC,
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`Defendants.
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`;PLAINTIFF NETWORK-l TECIINOLOGIES, INC.'S FIRST SE'IQF REQUESTS FOR
`PRODUCTION OF DOCUMENTS AND THINGS FROM DEFENDANTS
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`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Network-l
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`Technologies, Inc. ("Network-l ") serves its First Set of Requests for Production of Documents
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`and Things on Defendants Google, Inc. and YouTube, LLC (collectively "Defendants" or
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`"Google"), as follows:
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`I.
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`INSTRUCTIONS AND DEFINITIONS
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`A.
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`INSTRUCTIONS
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`1.
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`Whenever an objection is asserted to a particular request or portion thereof, please
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`produce all responsive documents or parts thereof that are not subject to the objection. Similarly,
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`wherever a document is not produced in full, please state with particularity the reason or reasons
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`it is not being produced in full, and describe, to the best of your knowledge, information and
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`belief and with as much particularity as possible, those portions of the document which are not
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`produced.
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`Case 1:14-cv-02396-PGG-SN Document 249-10 Filed 04/07/21 Page 3 of 4
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`II.
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`REQUESTS FOR DOCUMENTS AND THINGS
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`Documents and things relating or referring to any of the patents-in-suit.
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`Documents and things relating or referring to Ingemar 1. Cox.
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`Documents and things relating or referring to Network-I.
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`Documents and things relating to any contention that you do not directly infringe
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`1.
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`2.
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`3.
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`4.
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`the patents-in-suit.
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`5.
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`Documents and things relating to any of your affirmative defenses and
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`counterclaims.
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`6.
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`Documents and things relating to any contention that any claim of the patents-in-
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`suit is invalid and/or unenforceable due to double-patenting and/or failure to meet one or more of
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`the conditions of patentability and/or patent eligibility specified in Title 35 of the United States
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`Code, including, without limitation, sections 101, 102, 103, and/or 112.
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`7.
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`Documents and things relating to any contention that Network -1 's claims for relief
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`are barred any equitable doctrines.
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`8.
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`9.
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`Documents relating to the level of ordinary skill in the art of the patents-in-suit.
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`Documents relating to alleged prior art to the patents-in-suit.
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`10.
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`Documents relating to any searches performed by you or on your behalf of patents
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`or other prior art relating to the patents-in-suit, including, but not limited to, enforceability
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`searches, infringement searches, validity searches, and prior art searches.
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`11.
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`Documents relating to any opinion, request for opinion, evaluation, analysis,
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`investigation, or search relating to the validity, scope, interpretation, construction, enforceability,
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`unenforceability, or the infringement or potential infringement of any of the claims of the
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`patents-in-suit.
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`12.
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`Documents relating to when you first became aware of the patents-in-suit or any
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`application from which the patents-in-suit issued.
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`6
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`Case 1:14-cv-02396-PGG-SN Document 249-10 Filed 04/07/21 Page 4 of 4
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`13.
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`Documents relating to any planned, potential, or implemented design-around of
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`any claim of the patents-in-suit, including any documents evidencing the cost and/or effects of
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`any such design-around.
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`14.
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`Documents relating to your policies or practices, if any, to avoid infringing
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`patents owned by third parties.
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`15.
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`16.
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`Documents sufficient to identify all versions of each Accused Instrumentality.
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`Documents sufficient
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`to evidence
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`the conception, design, development,
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`implementation, testing, production or operation of each Accused Instrumentality, including
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`documents relating to research, functional specifications, design specifications, operational
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`specifications, other specifications, or similar documents.
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`17.
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`Documents related to the conception, design, development, implementation,
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`testing, and operation of each Accused Instrumentality's algorithm or process related to
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`extracting features from media content, including without limitation, any digital "fingerprints,"
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`vectors, ID files, or other features used by any Accused Instrumentality in used to match
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`reference files to uploaded content.
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`18.
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`Documents related to the conception, design, development, implementation,
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`testing, and operation of each Accused Instrumentality's algorithm or process related to
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`comparing reference files to uploaded files using features extracted from media content,
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`including without limitation any algorithm or process used to compare ID files to uploaded
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`content.
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`19.
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`Source code (e.g., C++, Flash, Java, etc.) for each of the Accused
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`Instrumentalities, including the source code for the functionalities responsible for extracting
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`features from uploaded media content and searching for corresponding reference works in each
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`of the Accused Instrumentalities.
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`20.
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`Documents sufficient to evidence the manuals, guides, instructions, and product
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`documentation for each Accused Instrumentality.
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`7
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