`
`
`
`SEL EXHIBIT NO. 2009
`
`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 IPR2013-OOO38
`
`PATENT 7,956,978
`
`[PROPOSEDI PATENT OWNER’S INTERROGATORIES TO
`PETITIONER
`
`
`
`Pursuant to the Board’s authorization, Patent Owner Semiconductor
`
`Energy Laboratory Co., Ltd. (“SEL”), requests that Petitioner Chimei Innolux
`
`Corporation (“CMI”)1, provide answers to the following written Interrogatories
`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 service hereof.
`
`DEFINITIONS
`
`As used herein, the following words shall have the meanings indicated:
`
`1.
`
`The terms “CMI,” “you,” and “your” mean Petitioner Chimei InnoluX
`
`Corporation and any of its related companies or entities.
`
`2.
`
`The term “Co—Defendants” means Chi Mei Optoelectronics USA,
`
`. Inc., Acer America Corporation, ViewSonic Corporation, VIZIO,
`
`Inc., and
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`Westinghouse Digital, LLC, collectively.
`
`3.
`
`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
`
`limitation e—mail, letters, memoranda, facsimile, face—to—face meetings, telephone
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`conversations, and voice mail.
`
`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.
`
`
`
`4.
`
`The term “document” has its customary broad meaning within the
`
`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
`
`matter, and electronic data however produced or reproduced.
`
`5.
`
`The phrase “the ‘978 patent” means US. Patent No. 7,956,978.
`
`INSTRUCTIONS
`
`In addition to the above Definitions, the following Instructions shall also
`
`apply to these Interrogatories:
`
`1.
`
`Information requested in these Interrogatories includes information
`
`within the knowledge and possession of CMI or any of CMI’s agents, employees,
`
`past and present directors, officers, attorneys, and any other persons, firms or
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`entities directly or indirectly subject to CMI’s control.
`
`2.
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`If any information called for by an Interrogatory is withheld under a
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`claim of privilege or any other claim protecting against disclosure in response to
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`an Interrogatory, state the basis for any asserted claim of privilege or other claim
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`within ten (10) calendar days from the date of service of your responses to these
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`Interrogatories. In particular, for each document, thing or communication, alleged
`
`to be privileged identify at least the following:
`
`(a) its general description;
`
`(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;
`
`(if)
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`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 Interrogatory to which the document,
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`thing or
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`communication is responsive.
`
`3.
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`If you object to any part of an Interrogatory, state your objection
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`and respond to the remaining portion of the Interrogatory.
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`INTERROGATORIES
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`INTERROGATORY NO. 1:
`
`I For each attorney, agent, officer, or employee of any of the Co-Defendants
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`who provided assistance, comments, suggestions, materials or funding, or who
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`communicated with CMI, in connection with the preparation of the inter partes
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`review petition in IPR2013—0003 8, provide (i) the name of such attorney, agent,
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`officer, or employee of the Co—Defendant, (ii) the name of such Co—Defendant,
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`(iii) a description of the assistance, comments, suggestions, materials or funding
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`provided, or of such communication, and (iv) the date on which the assistance,
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`
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`comments, suggestions, materials or funding were provided or communication
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`occurred.
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`INTERROGATORY NO. 2:
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`Separately for each reference identified by CMI as providing an alleged
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`statutory ground for invalidity in IPR2013—00038, state whether the reference
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`was identified to CMI as relevant to the ‘978 patent by any attorney, agent,
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`officer, or employee of any of thepCo-Defendants, and if so, the name of each
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`such attorney, agent, officer, or employee and of each such Co—Defendant.
`
`INTERROGATORY NO. 3:
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`For each attorney, agent, officer, or employee of any of the Co-
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`Defendants who was provided with a copy of the inter partes review petition in
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`IPR20 13—0003 8, including but not limited to any draft or partial draft of such
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`petition, before November 6, 2012, provide (i) the name of each such attorney,
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`agent, officer, or employee of each such Co—Defendant, (ii) the name of each
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`such Co-Defendant, and (iii) the date(s) on which such copy was provided to
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`each such attorney, agent, officer, or employee of each such Co-Defendant.
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`
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`Dated: May 2, 2013
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`Respectfully submitted,
`
`Eric J. Robinson
`
`Sean C. Flood
`
`ROBINS ON INTELLECTUAL PROPERTY
`
`LAW OFFICE, RC.
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`3975 Fair Ridge Drive,
`Suite 20 North
`
`Fairfax, Virginia 22033
`(571) 434-6789
`
`Attorneys for Patent Owner
`
`
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