1N THE UNITED STATES PATENT AND TRADEMARK. OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS (70., L'I‘If).,
`
`Petitioner,
`
`BLACK HHLS MEDIA, LLC,
`Patent Owner.
`
`IPRQO 1 4-007 1 7
`
`Patent NO. 6,108,686
`
`PETITIONER’S RESPONSE TO ORDER GRANTINGw]N~PART MOTION
`
`FOR ADDITIONAL DISCOVERY UNDER 37 (1FR § 42.51(B)(2)
`
`1
`
`BHM 2012
`
`1
`
`BHM 2012
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS (70., L'I‘If).,
`
`Petitioner,
`
`BLACK HHLS MEDIA, LLC,
`Patent Owner.
`
`IPRQO 1 4-007 1 7
`
`Patent NO. 6,108,686
`
`PETITIONER’S RESPONSE TO ORDER GRANTINGw]N~PART MOTION
`
`FOR ADDITIONAL DISCOVERY UNDER 37 (1FR § 42.51(B)(2)
`
`1
`
`BHM 2012
`
`1
`
`BHM 2012
`
`
`
`lPR2014~007l '7
`
`032449.00329USOI
`
`I.
`
`INTRODUCTION
`
`Petitioner Samsung Electronics (30., Ltd. (“Petitioner”) provides the
`
`following responses pursuant to the Board’s Order Granting—in—Part Motion for
`
`Additional Discovery Pursuant to 37 CPR. § 42.51 (b)(2) (Paper 17) with respect
`
`to the Proposed Discovery Requests by Patent Owner (Ex. 2001).
`
`II. DISCOVERY RESPONSES
`
`INTERROGATORIES
`
`IN.llfiBQDALQBXHQL Identity the “petsons or. entities that (Eoogle or its
`
`counsel directed Petitioner or Petitioner‘s counsel to provide with at copy of one or
`
`more draits of.” the Petition”i for inter partes review for US. Patent No. 6, l 08,686
`
`prior to the tiling of the petition on or about May it 2014.
`
`RTSPQNfiI Neither Cioogde 1’10] its counsel directed Petitioner or Petitioner s
`
`counsel to provide a eopy ofono or more drafts of the Petition to any person or
`
`entity.
`
`iNkllRRDIPSZWm) :Withinttlite mopedmtiihedmi;(D(immttt ed
`
`“Real i:any iniHLCIC‘sl or Privy)olthe {)iliee Patent ’l‘iJitl Praetiee Guide... describe
`
`“the mixture atrial/oi” degree of invoivementi” ifiy each. inelivitiuei not eitipioyed by
`
`.
`M
`.
`.
`..
`1
`u
`,
`, -(
`l
`' Elie quoted let’ig'iqiage is item the lrflourdis {litter Pegfieif i f? p it},
`
`2
`
`2
`
`
`
`IPRZO l 4~OO7 l 7
`
`()32449.0032~l_.lSOl
`
`Petitioner or Petitioner’s counsel of record for IPR2014—007l72 in the filing of the
`
`Petition in this proceeding.
`
`
`RESPONSE: There was no involvement by any individual not employed by
`
`Petitioner or Petitioner’s counsel of record for IPR2014—007l7 in the filing of the
`
`Petition in this proceeding.
`
`other financial transactions made or agreed upon in relation to the indemnification
`
`provisions of“ the MADA, or a MADA that may have become effective after
`
`December 3 l, 2012, and related to [PRZO 1 4—007] 7:, received by or agreed to be
`
`provided to Petitioner or Petitionercounsei of record
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`2 Petitioner interprets the pliraee “en’iployed by Petitioner or Petiti4:me.r”s cmiriaei of
`
`recordt tr)ll’RiZOl 400.714” to rimmpass andmeiude 42.4w expert retained by
`
`Petitioner or 'i3*etitioner’:4 couriael {or iPRZZDi 'i ()t7i7
`
`3 Pages; 8 and it) oiitlie i‘3oardi’s (firder (_Paper l7) iii‘nitsi the discovery antiglit in
`
`lnterrogaiory No, 3 “to transactions; related to {Plat} i4-~-00735 and EPREiM 4~~<i€i7i 7 l
`
`View or agreeri 44:34:41; in r434iati444:"i totireiziiie r4444" ritior; prov won Hr“ ia/iAili/i.) or
`
`a 'M'Aifm iiiiatrnay have iiieroine iriiliaictiveatterihc:emiier ii, filliljla’44
`
`deniieeaii
`
`otherdiscoveryeoigigl'itniiiiittiriwitoiy N42*3
`
`3
`
`
`
`ll’R20l4~0(l"/l7
`
`0324490032~USOl
`
`
`RESPONSE: There are no payments, credits, refunds, or any other financial
`
`transactions made or agreed upon in relation to the indemnification provisions of the
`
`MADA, or a MADA that may have become effective after December 31, 2012, and
`
`related to IPR2014~00717 received by or agreed to be provided to Petitioner or
`
`Petitioner’s counsel of record.
`
`
`
`UESTS FOR PRODUCTIOl‘l4
`
`
`
`RiEg"‘gUEST NOS. 2 and 3: Please provide a copy of each document(s)
`
`“constituting or concerning notifications [of a claim by Petitioner] under any
`
`agreement between Petitioner and Google (Requea‘t No. 2) and responses to such
`
`notifications (Request No. 3'), relating to the challenges tn patentability in lPRZOl4~
`
`00717.“
`
`nglemNSl: 'l‘here are no documents eonetitntlng or concerning notifications
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`o‘fa elain‘i by Petitioner; or responses; tn such notifieatlone, under any agreement
`
`between ‘Petitiener and Gnogle relating; to the challenges; to patentahility in WRZO l4~
`
`00717,
`
`‘”‘ ‘l’éeq‘neat No l
`
`is; denied. ("Paper 1% n; W).
`
`5" lira. genteel language ie than the ‘éii'fitteti'tiia tinder {Pager '3 7., en. it}? it whieh tilenied
`
`the reqneate fer production ni‘all other dninnnenta milder Redeem New / and l “the
`
`bracketed language is; from lintent (fjlwnerle Request {Ext 200‘}; flil":lfilil“l§lST Milk CZ)‘
`
`4
`
`
`
`IPR2014~00717
`
`032449.00324U801
`
`Date: October 10, 2014
`
`
`
`
`
`
`Andrea G. Reisterg‘
`Registration N6; 36,253
`Gregory S. Discher
`Registration No. 42,488
`COVINGTON & BURLING LLLP
`
`1201 Pennsylvania Avenue, NW
`Washington, DC 2000442401
`(202') 662—6000
`Attorneys for Petiticmer
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 CLFR. § 42.6, I hereby certify that on this 10th day of October 2014,
`
`the foregoing Petitioner’s Response to Order Granting~in~Part Motion for Additional
`
`Discovery under 37 C.F.R. § 42.51(b)(2), was served Via electronic mail by
`
`agreement of the parties on the following counsel of record for Petitioner.
`
`N. Andrew C rain
`
`Robert Gravois
`
`Kenneth Knox
`
`Thomas l-lorstemeyer LLP
`Andrew.Crain@thomashorstemeyercom
`Robert.Gra\/ois@thomashorstemeyercom
`Kenny.Knox@thomashorstemeyer.com
`
`Date: October '1, (l, 20 l 4
`
`6
`
`
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