`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`ARRIS GROUP, INC.
`Petitioner
`
`v.
`
`C-CATION TECHNOLOGIES, LLC
`Patent Owner
`____________________
`
`CASE IPR2014-00746
`Patent 5,563,883
`____________________
`
`
`
`
`
`C-CATION TECHNOLOGIES, LLC’S PROPOSED DISCOVERY
`
`REQUEST TO ARRIS GROUP, INC.
`
`
`
`
`
`1
`
`
`
`
`
`Patent Owner C-Cation Technologies, LLC (“C-Cation Tech”) requests that
`
`petitioner Arris Group, Inc. respond and produce the following documents and
`
`things.
`
`INSTRUCTIONS
`
`1.
`
`In responding to and producing documents and things responsive to
`
`this request, the responding party shall comply with the instructions in the Patent
`
`Trial Practice Guide.
`
`2.
`
`A responding party shall timely amend its response upon learning that
`
`its response is incomplete or if additional responsive information is found.
`
`3.
`
`All responsive documents must be produced as they are kept in the
`
`usual course of business.
`
`DEFINITIONS
`
`1.
`
`The term “document” has the broadest meaning prescribed in Federal
`
`Rule of Civil Procedure 34, including ESI in the responding party’s possession,
`
`custody, or control.
`
`2.
`
`The term “Arris” means Arris Group, Inc. and includes any
`
`employees, agents, counsel, representatives, or others authorized to act on Arris’s
`
`behalf.
`
`
`
`1
`
`
`
`
`
`2
`
`
`
`
`
`3.
`
`The term “Texas Litigation” means the lawsuit entitled C-Cation
`
`Techs., LLC v. Comcast Corp., et al., Case No. 2:11-cv-00030-JRG-RSP, filed by
`
`C-Cation Tech in the United States District Court for the Eastern District of Texas.
`
`4.
`
`The term “Comcast” means Comcast Corporation, Comcast Cable
`
`Communications, LLC, and Comcast of Houston LLC, and includes any
`
`employees, agents, counsel, representatives, or others authorized to act on behalf of
`
`those entities.
`
`
`
`
`
`
`
`2
`
`
`
`
`
`3
`
`
`
`
`
`REQUESTS FOR PRODUCTION
`
`Request for Production No. 1
`
`Agreement(s) between Arris and Comcast under which Comcast requested
`
`indemnification for the claims brought against Comcast in the Texas Litigation that
`
`reference (or are contingent on) Arris’s ability to control the litigation.
`
`
`
`
`
`3
`
`
`
`
`
`4
`
`