`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC
`Patent Owners
`____________
`
`Case IPR2014-00702
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`Patent 5,978,791
` ____________
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`PETITIONER'S VOLUNTARY INTERROGATORY RESPONSES
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 1 of 6
`IPR2014-00702
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`Petitioner, Unified Patents
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`Inc., provides
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`the
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`following voluntary
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`interrogatory responses.
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`DEFINITIONS
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`A. ‘791 PATENT means U.S. Patent No. 5,978,791.
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`B. PERSONALWEB means PersonalWeb Technologies, LLC and Level 3
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`Communications, LLC.
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`C. COMMUNICATIONS means the transmission or receipt of information of
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`any kind through any means (e.g., email, text message, voicemail, audio,
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`computer readable media, or orally).
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`D. MEMBER means any company that participates in UNIFIED’S solution.
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`E. IPR means IPR2014-00702.
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`F. PETITION means the petition, including the exhibits thereto, for inter partes
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`review of the ‘791 PATENT filed in the USPTO on behalf of UNIFIED in
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`connection with the IPR.
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`G. UNIFIED means Unified Patents, Inc. and includes any shareholder, officer,
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`director, employee, agent, representative, privies, intermediaries or other
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`individual authorized to act on behalf of Unified Patents, Inc.
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`H. USPTO means the Unites States Patent and Trademark Office.
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`1
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 2 of 6
`IPR2014-00702
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`RESPONSES TO INTERROGATORIES
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`INTERROGATORY NO. 1:
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`Identify COMMUNICATIONS between UNIFIED and any MEMBER relating to
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`the financing, preparation, editing, prior review, or approval of the PETITION.
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`RESPONSE TO INTERROGATORY NO. 1:
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`Unified Patents states that no such communications exist.
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`INTERROGATORY NO. 2:
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`Identify any individuals acting for or on behalf of any MEMBER that participated
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`or assisted in any way with the financing, preparation, editing, prior review,
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`approval, or filing of the PETITION.
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`RESPONSE TO INTERROGATORY NO. 2:
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`Unified Patents states that no such individuals exist.
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`INTERROGATORY NO. 3:
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`Identify payments by any MEMBER to UNIFIED relating to the financing of the
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`IPR.
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`2
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 3 of 6
`IPR2014-00702
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`RESPONSE TO INTERROGATORY NO.3:
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`Unified Patents states that no such payments exist.
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`Dated: June 12, 2014
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`Customer Number
` 22850
`Tel. (703) 413-3000
`Fax. (703) 413-2220
`(OSMMN 02/10)
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`Respectfully submitted,
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`OBLON SPIVAK
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Reg. No. 38,939
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`3
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 4 of 6
`IPR2014-00702
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`VERIFICATION
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`I declare under penalty of perjury that the foregoing is true and correct.
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`
`I, Kevin Jakel, state that I am CEO of Unified Patents Inc., and that I am
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`authorized to make this verification for and on its behalf. I certify that I have read
`the foregoing voluntary interrogatory responses, and that the responses are true and
`accurate to the best of my own knowledge, information and belief. Further, I make
`this verification with the knowledge that willful false statements and the like so
`made are punishable by fine or imprisonment, or both, under Section 1001 of Title
`18 of the United States Code and that such willful false statements may jeopardize
`the results of these proceedings.
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`By:
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`Kevin Jakel
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`4
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 5 of 6
`IPR2014-00702
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a true copy of the foregoing
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`PETITIONER'S VOLUNTARY INTERROGATORY RESPONSES was
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`served on counsel for the Patent Owner, on this 12th day of June, by sending same
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`via e-mail, to:
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`Joseph A. Rhoa
`NIXON & VANDERHYE, PC
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203
`JAR@NixonVan.com
`
`
`
`
`
`By:
`
`/Michael L. Kiklis/
`Michael L. Kiklis
`Reg. No. 38,939
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`
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`Dated: June 12, 2014
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`5
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`UNIFIED V PERSONAL WEB; LEVEL 3 COMM - EXH 1009 -Page 6 of 6
`IPR2014-00702
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