`
`
`
`SEL EXHIBIT NO. 2008
`
`INNOLUX CORP. v. PATENT OF SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
`
`IPR2013-00038
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INNOLUX CORPORATION
`
`Petitioner
`
`V.
`
`PATENT OF SEMICONDUCTOR ENERGY LABORATORY CO., LTD.
`Patent Owner‘
`
`CASE |PR2013—OOO38
`
`PATENT 7,956,978
`
`[PROPOSED] PATENT OWNER’S REQUESTS FOR PRODUCTION
`TO PETITIONER
`
`
`
`Pursuant to the Board’s authorization, Patent Owner Semiconductor
`
`Energy Laboratory Co., Ltd. (“SEL”), requests that Petitioner Chimei Innolux
`
`Corporation (“CMI”)1, deliver written responses and responsiVe documents and
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`things to each of these Requests for Production to Robinson Intellectual Property
`
`Law Office, PC, 3975 Fair Ridge Drive, Suite 20 North Fairfax, Virginia
`
`22033, c/o Eric Robinson, Esq., within fourteen (14) calendar days after the
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`service hereof.
`
`DEFINITIONS
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`As used herein, the folloWing words shall have the meanings indicated:
`
`1.
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`_ The terms “CMI,” “you,” and “your” mean Petitioner Chimei Innolux
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`Corporation and any of its related companies or entities.
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`2.
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`The term “Co—Defendants” means Chi Mei Optoelectronics USA,
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`Inc., Acer America Corporation, ViewSonic Corporation, VIZIO,
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`Inc., and
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`Westinghouse Digital, LLC, collectively.
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`3.
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`The term “communication” means any contact or exchange of
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`information whether written or oral between two or more persons, regardless of
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`the form or medium by which transmitted or on which recorded, including without
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`1 While Patent Owner acknowledges the name change of the Petitioner, Patent
`Owner continues to refer to that party as “Chimei Innolux Corporation” or “CMI”
`in this document.
`
`
`
`limitation e—mail, letters, memoranda, facsimile, face-to-face meetings, telephone
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`conversations, and voice mail.
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`4.
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`The term “document” has its customary broad meaning within the
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`full range allowed by Rules 33 and 34 of the Federal Rules of Civil Procedure and
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`includes without limitation any written, printed, typed, recorded, filmed or graphic
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`matter, and electronic data however produced or reproduced.
`
`5.
`
`The phrase “the ‘978 patent” means US. Patent No. 7,956,978.
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`INSTRUCTIONS
`
`In addition to the above Definitions, the following Instructions shall also
`
`apply to these Requests for Production:
`
`1.
`
`Information requested in these Requests for Production includes
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`information within the knowledge and possession of CMI or any of CMI’s agents,
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`employees, past and present directors, officers, attorneys, and any other persons,
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`firms or entities directly or indirectly subject to CMI’s control.
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`2.
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`If any document, thing, or communication or identification of any
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`document, thing, or communication is withheld under a claim of privilege or any
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`other claim in response to a Request for Production, provide sufficient information
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`to identify the document, thing or communication, and state the basis for any
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`asserted claim of privilege or any other claim within ten (10) calendar days from
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`the date of service of your responses to these Requests for Production.
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`In
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`
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`particular, for each document, thing or communication, alleged to be privileged
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`identify at least the following:
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`(a) its general description;
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`(b) its date;
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`(c) the name and title of its author(s);
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`(d) the name and title of its recipient(s);
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`(e) its subject matter;
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`(f) its number of pages;
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`(g) the nature of the privilege claimed and facts upon Which you rely to
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`support the claim of privilege; and
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`(h) the number of the Request for Production to which the document, thing
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`or communication is responsive.
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`3.
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`If you object to any part of a Request for Production and refuse to
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`produce documents or things responsive to that part, state your objection and
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`respond to the remaining portion of the Request for Production.
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`4.
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`If a document or thing responsive to any Request for Production is
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`in a language other than English and an English translation exists, identify and
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`provide both documents.
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`
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`RES QUESTS FOR PRODUCTION
`
`RE! QUEST NO. 1:
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`Copies of any agreement between CMI and any of the Co—Defendants
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`relating to inter partes review of the ‘978 patent.
`
`REQUEST NO. 2:
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`Copies of any communications between CMI and any of the Co—Defendants
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`relating to any of (i) whether or not to seek inter partes review of ‘978 patent, (ii)
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`the petition for inter partes review that was filed in IPR2013—00038 for the ‘978
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`patent; (iii) any draft or partial draft of the petition filed in IPR2013-00038; (iv) the
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`preparation of the petition filed in IPR2013-0003 8; or (V) any funding for
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`preparing or filing the petition filed in IPR2013—00038 .
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`Dated: May 2, 2013
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`Respectfully submitted,
`
`Eric J. Robinson
`Sean C. Flood
`
`ROBINSON INTELLECTUAL PROPERTY
`
`LAW OFFICE, RC.
`
`3975 Fair Ridge Drive,
`Suite 20 North
`
`Fairfax, Virginia 22033
`(571) 434-6789
`'
`
`Attorneys for Patent Owner
`
`
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