`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`In re U.S. Patent No. 6,240,376
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`Trial No.:
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`IPR 2012-00042
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`Atty. Dkt. No.
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`007121.00004
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`Application No.: 09/127,587
`Filed:
`July 31, 1998
`Issued: May 29, 2001
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`Inventors:
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`Alain Raynaud
`Luc M. Burgun
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`Patent Owner: Mentor Graphics
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`Corporation
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`For: METHOD AND
`APPARATUS FOR
`GATE-LEVEL
`SIMULATION OF
`SYNTHESIZED
`REGISTER TRANSFER
`LEVEL DESIGNS WITH
`SOURCE-LEVEL
`DEBUGGING
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`[PROPOSED] PATENT OWNER’S INTERROGATORIES TO
`PETITIONER
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`1
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`MG 2019
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`Patent Owner’s Interrogatories to Petitioner
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`IPR 2012-00042
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`Pursuant to the Board’s authorization, Patent Owner Mentor Graphics
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`Corporation
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`(“Mentor Graphics”) hereby
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`requests
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`that Synopsys,
`
`Inc.
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`(“Synopsys”) respond, separately and fully in writing and under oath, to each of
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`the following interrogatories. Mentor Graphics requests that Synopsys deliver
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`written responses to each of these interrogatories to the offices of Banner &
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`Witcoff, Ltd, 1100 13th Street, NW, Suite 1200, Washington, DC 20005, within
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`fourteen (14) calendar days of the service date hereof.
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`DEFINITIONS
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`As used herein, the following words shall have the meanings indicated:
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`1.
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`“Mentor Graphics” means Patent Owner Mentor Graphics
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`Corporation, as well as its subsidiaries, divisions, affiliates, assigns, present and
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`former officers, directors, employees, related corporations and agents.
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`2.
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`“Synopsys” means Synopsys, Inc. and all of its subsidiaries,
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`divisions, affiliates, assigns, present and former officers, directors, and employees,
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`related corporations and agents.
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`3.
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`“EVE” means Emulation and Verification Engineering, S.A. (now
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`named Synopsys Emulation and Verification S.A.) and EVE-USA, Inc., and all of
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`their subsidiaries, divisions, affiliates, assigns, present and former officers,
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`directors, employees, related corporations and agents.
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`4.
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`“’376 Patent ” means U.S. Patent No. 6,240,376.
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`2
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`Patent Owner’s Interrogatories to Petitioner
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`IPR 2012-00042
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`5.
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`6.
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`“Burgun” means Luc Burgun, named co-inventor of the ’376 Patent.
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` “Communication” means every manner or method of disclosure or
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`transfer or exchange of information, whether orally or by document, and whether
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`face to face, by telephone, mail, email, personal delivery or otherwise. Unless
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`otherwise indicated, a request calling for communications includes internal
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`communications as well as communications with a third person.
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`INSTRUCTIONS
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`In the event any information is withheld on a claim of attorney/client
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`privilege, work product immunity, or any other claim of privilege or immunity,
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`describe the nature and basis for Synopsys’ claim, identify the requested
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`information that is being withheld with sufficient particularity to enable a claim of
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`privilege or immunity to be adjudicated, and cite any authority which Synopsis
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`asserts supports any claim of privilege or immunity. If the contents of a
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`communication are being withheld, then identify the date of the communication, all
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`recipients, and the general subject matter of the communication. If a legal
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`objection based on a claim of privilege or immunity from disclosure applies only to
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`a part of an interrogatory, but not its entirety, state the part to which the claim of
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`privilege or immunity applies and answer the remainder of the interrogatory.
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`3
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`MG 2019
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`Patent Owner’s Interrogatories to Petitioner
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`IPR 2012-00042
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`INTERROGATORIES
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`INTERROGATORY NO. 1:
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`Identify each attorney, agent, officer, or employee of EVE who provided
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`assistance, input or materials used in preparing the inter partes review of the ’376
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`Patent, by providing (i) the name of the attorney, agent, officer, or employee of
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`EVE, (ii) a description of the assistance, input, or materials provided, and (iii) the
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`date on which the assistance, input or materials were provided.
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`INTERROGATORY NO. 2:
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`Separately for each reference identified by Synopsys as providing a statutory
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`ground for the inter partes review of the ’376 Patent, identify whether the
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`reference was identified to Synopsys as relevant to the ‘376 patent by any attorney,
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`agent, officer, or employee of EVE.
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`INTERROGATORY NO. 3:
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`Identify any issues or circumstances that prevented Synopsys and EVE from
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`executing on or before September 26, 2012, the agreement executed on September
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`27, 2012, by which Synopsys and EVE agreed to Synopsis’ acquisition of EVE.
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`INTERROGATORY NO. 4:
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`Identify Burgun’s job title(s) at Synopsys and describe his role and
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`responsibilities from the time when he first became a board member, officer and/or
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`employee of Synopsys to the date of this interrogatory.
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`4
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`INTERROGATORY NO. 5:
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`Identify Burgun’s ownership interest in Synopsys, including, but not limited
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`to, shares of stock, and any options, warrants, and/or any other rights to acquire
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`Synopsys stock that Burgun owns or is entitled to own.
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`INTERROGATORY NO. 6:
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`Identify the date on which Synopsys and EVE first shared a common interest
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`with respect to inter partes review of the ’376 Patent.
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`INTERROGATORY NO. 7:
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`Identify any executive or board level decisions by EVE and/or Synopsys
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`made prior to October 4, 2012, in reliance on the anticipated consummation of
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`Synopsis’ acquisition of EVE, including but not limited to: changes to corporate
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`structure or governance, changes
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`in employees, capital expenditures or
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`commitments to capital expenditures, and leases or purchases of real property.
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`INTERROGATORY NO. 8:
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`Identify all agreements between Synopsys and EVE, or communications,
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`regarding joint business activities predating October 4, 2012 of the two entities
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`relating to the ZeBu line of emulation products.
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`5
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`IPR 2012-00042
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`INTERROGATORY NO. 9:
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`Identify all agreements between Synopsys and EVE or communications
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`regarding joint business activities of the two entities, in 2006 or earlier, relating to
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`the ZeBu line of emulation products.
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`INTERROGATORY NO. 10:
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`Identify when Synopsys actually served a copy of the Petition in the instant
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`inter partes review on Mentor Graphics’ counsel of record Banner & Witcoff, Ltd.
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`at the correspondence address of record for the ‘376 Patent.
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`Dated: March 29, 2013
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`Respectfully submitted,
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`By:
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`Christopher L. McKee
`Registration No. 32,384
`Michael S. Cuviello
`Registration No. 59,255
`Banner & Witcoff, Ltd
`1100 13th Street, NW
`Suite 1200
`Washington, DC 20005
`Tel: (202) 824-3000
`Fax: (202) 824-3001
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`Attorneys for Patent Owner
`Mentor Graphics Corporation
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`6
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`MG 2019
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