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