`
`
`Filed on behalf of: VirnetX Inc.
`By:
`Joseph E. Palys
`
`Naveen Modi
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, L.L.P.
`11955 Freedom Drive
`Reston, VA 20190-5675
`Telephone: 571-203-2700
`Facsimile: 202-408-4400
`E-mail: joseph.palys@finnegan.com
`
` naveen.modi@finnegan.com
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`
`RPX CORPORATION
`Petitioner
`v.
`VIRNETX INC.
`Patent Owner
`
`
`
`Case IPR2014-00173
`Patent 7,490,151
`
`
`
`
`
`Patent Owner’s Request for Deposition of Apple, Inc.
`
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`VIRNETX EXHIBIT 2026
`RPX v. VirnetX
`Trial IPR 2014-00173
`
`Page 1 of 3
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`Case No. IPR2014-00173
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`Patent Owner VirnetX
`
`Inc.
`
`requests
`
`that Apple,
`
`Inc. provide a
`
`knowledgeable witness to testify to the deposition topic listed below. To the extent
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`Apple prefers to respond to this topic in writing instead of providing a witness,
`
`effectively treating the topic as a deposition by written question or an
`
`interrogatory, Apple may do so subject to the instructions and definitions following
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`the topic.
`
`DEPOSITION TOPIC
`
`Communications in Request for Production No. 1 and/or 2 of Exhibit 2004
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`that were not reduced to writing, including identifying those communications.
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`1
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`Page 2 of 3
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`Case No. IPR2014-00173
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`INSTRUCTIONS AND DEFINITIONS
`
`If Apple prefers to respond to this deposition topic in writing instead of
`
`providing a witness, effectively treating the topic as a deposition by written
`
`question or an interrogatory, please follow these instructions in addition to
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`complying with the Board’s instructions in the Office Patent Trial Practice Guide:
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`1.
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`Please timely amend your response if you learn that your response is
`
`incomplete or additional responsive information is found.
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`2. Whenever you are asked to identify a communication, please: (a) summarize
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`the subject matter of the communication; (b) state the date and location of the
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`communication; and (c) identify the parties to the communication.
`
`3.
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`If, in responding to this this topic, you encounter any ambiguities when
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`construing the topic, instruction, or definition, your response shall set forth the
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`matter deemed ambiguous and the construction used in responding.
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`4.
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`For any information sought that you withhold based upon a claim of
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`privilege, please identify the ground of the asserted privilege and provide a
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`privilege log according to the requirements of Federal Rule of Civil Procedure 26.
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`5.
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`“Communications” shall mean the transmission or receipt of information of
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`any kind through any means (e.g., email, voicemail, audio, computer readable
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`media, or orally).
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`2
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`Page 3 of 3
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