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`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
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` naveen.modi@finnegan.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`RPX CORPORATION
`Petitioner
`v.
`VIRNETX INC.
`Patent Owner
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`Case IPR2014-00176
`Patent 7,418,504
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`Patent Owner’s Interrogatories to RPX Corporation
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`VIRNETX EXHIBIT 2024
`RPX v. VirnetX
`Trial IPR 2014-00176
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`Page 1 of 5
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`Case No. IPR2014-00176
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`Patent Owner VirnetX Inc. requests that RPX Corporation serve written
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`responses to these interrogatories.
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`INSTRUCTIONS
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`In responding to these interrogatories, please comply with the instructions in
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`the Office Patent Trial Practice Guide.
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`1.
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`Please timely amend your responses if you learn that your response is
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`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.
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`3.
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`If you object to a portion or an aspect of any interrogatory, state the grounds
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`of your objection with specificity and respond to the remainder of the
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`interrogatory.
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`4.
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`If, in answering these interrogatories, you encounter any ambiguities when
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`construing a request, 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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`5.
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`For any information sought by an interrogatory that you withhold based
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`upon a claim of privilege, please identify the ground of the asserted privilege and
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`provide a privilege log according to the requirements of Federal Rule of Civil
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`Procedure 26.
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`1
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`Page 2 of 5
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`Case No. IPR2014-00176
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`DEFINITIONS
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`1.
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`The terms “document” and “thing” have the broadest meaning prescribed in
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`Federal Rule of Civil Procedure 34, including ESI and any physical specimen or
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`tangible item, in your possession, custody, or control.
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`2.
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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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`3.
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`The terms “you” and “RPX” mean RPX Corporation and includes any
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`agents, representatives, privies, or others authorized to act on your behalf.
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`4.
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`“Apple” means Apple, Inc. and includes any agents, representatives, privies,
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`or others authorized to act on Apple’s behalf.
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`5.
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`“RPX IPRs” refers to inter partes review Case Nos. IPR2014-00171,
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`IPR2014-00172,
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`IPR2014-00173,
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`IPR2014-00174,
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`IPR2014-00175,
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`IPR2014-00176, and IPR2014-00177.
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`6.
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`“Sidley Austin” means Sidley Austin LLP and includes any agents,
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`representatives, privies, or others authorized to act on Sidley Austin’s behalf.
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`7.
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`“Howison & Arnott” means Howison & Arnott LLP and includes any
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`agents, representatives, privies, or others authorized to act on Howison & Arnott’s
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`behalf.
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`2
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`Page 3 of 5
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`Case No. IPR2014-00176
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`8.
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`“Ashe” means “Ashe, P.C.” and includes any agents, representatives,
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`privies, or others authorized to act on Ashe’s behalf.
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`INTERROGATORY
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`INTERROGATORY NO. 1
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`Identify communications and/or agreements in Request for Production Nos.
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`2-4 of Exhibit 2002 that were not reduced to writing.
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`INTERROGATORY NO. 2
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`INTERROGATORY NO. 3
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`Identify communications between you and Sidley Austin regarding the RPX
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`IPRs, including communications relating to the challenging of U.S. Patent Nos.
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`6,502,135; 7,418,504; 7,490,151; and 7,921,211 at the United States Patent and
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`Trademark Office and assistance with, filing, and/or preparation of any papers
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`related to the RPX IPRs.
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`INTERROGATORY NO. 4
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`To the extent you do not produce materials from Sidley Austin, Howison &
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`Arnott, or Ashe in response to Request for Production No. 5 of Exhibit 2002,
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`3
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`Case No. IPR2014-00176
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`identify for that firm: each attorney that performed the work relating to the RPX
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`IPRs, the number of hours spent by that attorney, and when that work was
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`performed.
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`4
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`Page 5 of 5