IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`LUFKIN DIVISION
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`E-WATCH, INC, a Nevada Corporation,
`and
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`e-WATCH CORPORATION,
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`a Texas Corporation,
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`Plaintiffs,
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`V.
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`March Networks Corporation
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`Defendant.
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`Civil Action No. 9:06-cv-00025~RHC
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`E-WAT
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`E—Wateh, Inc. makes these supplemental responses to March Networks
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`Corporation’s First Set of Interrogatories as follows:
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`INTERROGATORY N0. 5:
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`For each claim of the patents~in~suit, describe fully the history and process
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`leading to the alleged invention of each such claim, including: (a) identifying the dates E-
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`Watch contends that claim was conceived and first reduced to practice; (b) describing the
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`circumstances of such alleged conception, first reduction to practice, and any diligence
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`there-between; (c) identifying all persons involved in such alleged conception, diligence,
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`and reduction to practice; and ((1) identifying all facts, information, documents, and
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`things that E—Watch contends corroborates such alleged conception, diligence, and
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`reduction to practice.
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`RESPONSE:
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`(a) The claims of the patents in suit were first conceived between August IS, 1995
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`and August 14, 1996. The claims were first reduced to practice on February 25, 1999
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`except for the claims of the ‘ 183 and ‘692 patents which were first reduced to practice on
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`January 1, 1998.
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`(b) David Monroe and his staff at PhotoTelesis Corporation developed a military
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`airborne image transmission system that transmitted still images from a military aircraft
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`to the ground over secure Government circuits. Texas Instruments asked Monroe to think
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`about commercial applications that might be derived from the military technology. As a
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`result, David Monroe came up with the inventions disclosed in the patents in suit.
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`The first patent application was filed October 28, 1996 and that Patent Number 5,798,458
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`was issued on August 25, 1998. During this time period, David Monroe continued to
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`think about these matters and refinements were made during this period with the resulting
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`patents being the patents—in-suit, filed in February 1999. Almost all of these refinements
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`were made in the continuing thought process of David Monroe. The first reduction to
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`practice of the inventions covered by the patents—imsuit is the respective filing date of
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`each of the inventions. In late 1997 , Mr. Monroe began formulating a system for
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`comprehensive multi-media security and surveillance for buildings, campuses and other
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`installations as well as the earlier vehicular systems. This resulted in the disclosure
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`document dated January 1, 1998. This disclosure was ultimately incorporated in the
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`application which is now the ‘183 patent. Between the conception date of January 1,
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`1998 and the filing date of June 14, 2000, Mr. Monroe continued to refine this idea while
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`being heavily involved in marketing the products and systems disclosed in the other
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`patents in suit.
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`(c) David Monroe and Bob Curfiss.
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`(d) This information is contained in Plaintiff’s original claim charts and original
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`and supplemental Rule 3.1 and 3.2 disclosures, the addendum to the PRR. 3 .1(c) chart,
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`and the supplemental PR. 3.1 (f) chart and in the documents delivered to March
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`Networks stamped MN 1 through 12676.
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`INTERROGATORY N0. 6:
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`For each claim of the patents-in—suit, identify the relevant art to which it belongs,
`and describe fully the level of knowledge, schooling, experience, expertise, or relevant
`technical information of a person having ordinary skill in that art (as this phrase is used in
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`EUSC. §103) as of the date of filing of the patent in which such claim appears.
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`RESPONSE:
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`The relevant art includes both security and surveillance systems for commercial
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`transports and intemet protocol based security and surveillance systems. Plaintiff does
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`not know the answer with regard to the second part of the question.
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`INTERROGATORY NO. 7:
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`Identify all prior art of which E—Watch is aware that concerns, discloses,
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`describes, or claims any alleged invention.
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`RESPONSE:
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`None.
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`INTERROGATORY N0. 8:
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`Identify all facts, information, documents, and things relevant to any contention
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`by E—Watch that secondary considerations or other objective evidence exist supporting or
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