`FOR THE NORTHERN DISTRICT OF ILLINOIS
`
`e OCEAN TOMO, LLC,
`
`Plaintiff and Counter-defendant,
`
`v.
`
`JONATHAN BARNEY and
`PATENTRATINGS, LLC,
`
`Defendants and Counter-plaintiffs.
`
`\./\.z\/\/\./\/\/\/\J\J
`
`No. 12 c 8450
`
`‘Hon. Joan B. Gottschall
`
`Hon. Mary Rowland
`
`DEFENDANT AND COUNTER-PLAINTIFF
`PATENTRATINGS LLC’S SECOND SET OF INTERROGATORIES
`,
`
`thirty (30) days of service hereof.
`
`DEFINITIONS AND INSTRUCTIONS
`
`contractors, agents, attorneys, representatives, successors, assigns, and any other person or entity
`that has acted or is acting on their behalf.
`
`2342766.]
`
`Ocean Tomo Ex. 100,6-001
`
`Ocean Tomo Ex. 1006-001
`
`
`
`contractors, agents, attorneys, representatives, successors, assigns, and any other person or entity
`that has acted or is acting on their behalf.
`1
`
`D.
`“License Agreement” refers to the License Agreement between PatentRatings and
`Ocean Tomo dated as of September 1, 2004, as amended and supplemented by the Letter
`Agreement dated December 31, 2004, the Amendment to Licensing Agreement dated Mayi2,
`2005, the Supplemental License Agreement dated May 18, 2006, and the Amendment dated July
`
`19, 2007.
`
`“Challenged Patents” refers to U.S. Pat. Nos. 6,556,992; 7,657,476 7,716,226;
`E.
`7,949,581; 7,962,511; 8,131,701; 8,504,560 and 8,818,996.
`
`“Ocean Tomo Ratings Systems” refers to the Ocean Tomo RatingsTM systems
`F.
`identified and described at hfip://wvvw.oceantomo.com/ratings/.
`
`G.
`
`Unless otherwise indicated, these requests call for the disclosure of information
`
`relating to acts or events after June 30, 2004.
`
`These requests call for the disclosure of all information within Ocean Tomo’s
`H.
`possession or control, including
`not limited to information in the possession and control ofits
`
`attorneys.
`
`I.
`
`If any information responsive to these interrogatories is claimed to be privileged,
`
`to constitute work-product, or otherwise exempt fiom discovery, state the basis of the claim, and
`
`include a brief description of the subject matter of the information withheld, the identity of all
`
`persons by whom and to whom the information has been communicated, and ifthe information is
`
`contained or referenced in a document,.the identity ofthe docmnent.
`
`Ocean Tomo Ex. 1006-002
`
`Ocean Tomo Ex. 1006-002
`
`
`
`INTERROGATORIES
`
`Identify each and every product or service currently offered or sold by Ocean
`1.
`Tomo that: (a) is covered by, or 03) but for the License Agreement would infringe, any claim
`(whether valid, invalid, or otherwise) ofthe Challenged Patents.
`
`Identify each and every software, system or method operated or practiced by
`_
`2.
`Ocean Tomo that: (a) is covered by, or (b) but for the License Agreement would infringe, any
`claim (whether valid, invalid or otherwise) ofthe Challenged Patents.
`
`Dated: March 23, 2015
`
`E
`I
`
`PATENTRATINGS, LLC
`By:
`0!/(/-»’;éQ C
`_One ofits attorneys
`
`David C. Layden
`JENNER & BLOCK LLP.
`353 North Clark Street
`Chicago, Illinois 60654
`(312) 222-9350
`(312) 840-7796 (fax)
`
`0 Ocean Tomo Ex. 1006-003
`
`Ocean Tomo Ex. 1006-003
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