`
`
`
`
`
`DRAGON INTELLECTUAL PROPERTY, LLC’S
`FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`DRAGON INTELLECTUAL PROPERTY, LLC
`Patent Owner
`___________
`
`Case IPR2014-01252
`Patent 5,930,444
`
`Before ANDREW KELLOGG, Trial Paralegal
`
`Unified Patents Inc. Ex. 1016, pg. 1
`Unified v. Dragon
`IPR2014-01252
`
`
`
`
`
`On September 4, 2014, counsel for Unified Patents Inc. (“Unified Patents”)
`
`offered to provide discovery on an expedited basis regarding Unified Patents’
`
`status as the real party in interest in the above captioned inter partes review
`
`proceedings. The parties met and conferred regarding discovery, and agreed that
`
`Dragon Intellectual Property, LLC (“Dragon”) would provide Unified Patents with
`
`discovery requests, which Dragon did on September 30, 2014. The parties met and
`
`conferred on October 2, 2014. During that conversation, counsel for Unified
`
`Patents stated that Unified Patents would not respond to written discovery requests
`
`that sought information about members of Unified Patents that were suppliers to
`
`defendants in the Dragon Litigation (defined below) on the basis that Unified
`
`Patents does not know whether (or if) any of its members are suppliers of DVR
`
`devices or software for DVR devices to defendants in the Dragon Litigation.
`
`Unified Patents also stated that it would not provide written responses to discovery
`
`requests that sought information about the facts and circumstances under which
`
`Unified Patents became aware of Dragon or the Dragon patent that is the subject of
`
`this proceeding, or communications with parties other than members of Unified
`
`Patents regarding Dragon or the Dragon patent that is the subject of this litigation.
`
`The discovery requests below are requests to which Unified Patents has agreed to
`
`respond, and reflect Unified Patents’ edits to the original discovery requests
`
`Dragon provided on September 30, 2014.
`
`
`
`-1-
`
`Unified Patents Inc. Ex. 1016, pg. 2
`Unified v. Dragon
`IPR2014-01252
`
`
`
`
`
`Pursuant to Unified Patents’ proposal to provide responses by October 13,
`
`2014, the parties’ agreement, and pursuant to 37 C.F.R. § 42.51, Dragon serves
`
`these discovery requests.
`
`DEFINITIONS
`
`“Dragon Litigation” in the following discovery requests refers to the
`
`following matters, individually and collectively, each of which was filed on or
`
`about December 20, 2013 in the United States District Court for the District of
`
`Delaware:
`
` Dragon Intellectual Prop. LLC v. Apple Inc. (C.A. No. 13-2058-RGA)
`
` Dragon Intellectual Prop. LLC v. AT&T Services, Inc. (C.A. No. 13-2061-
`
`RGA)
`
` Dragon Intellectual Prop. LLC v. Charter Commc’ns Inc. (C.A. No. 13-2062-
`
`RGA)
`
` Dragon Intellectual Prop. LLC v. Comcast Cable Commc’ns LLC (C.A. No. 13-
`
`2063-RGA)
`
` Dragon Intellectual Prop. LLC v. Cox Communications Inc. (C.A. No. 13-
`
`2064-RGA)
`
` Dragon Intellectual Prop. LLC v. DirecTV LLC (C.A. No. 13-2065-RGA)
`
` Dragon Intellectual Prop. LLC v. DISH Network LLC (C.A. No. 13-2066-RGA)
`
`-2-
`
`Unified Patents Inc. Ex. 1016, pg. 3
`Unified v. Dragon
`IPR2014-01252
`
`
`
`
`
` Dragon Intellectual Prop. LLC v. Sirius XM Radio Inc. (C.A. No. 13-2067-
`
`RGA)
`
` Dragon Intellectual Prop. LLC v. Time Warner Cable Inc. (C.A. No. 13-2068-
`
`RGA)
`
` Dragon Intellectual Prop. LLC v. Verizon Commc’ns Inc. (C.A. No. 13-2069-
`
`RGA)
`
`DOCUMENT REQUESTS
`
`1.
`
`All agreements or other materials memorializing the terms of
`
`membership in Unified Patents by any Defendant in the Dragon Litigation.
`
`2.
`
`All correspondence between Unified Patents Inc. and any member that
`
`discusses or references Dragon Intellectual Property, LLC or United States Patent
`
`5,930,444. Papers filed with the United States Patent and Trademark Office,
`
`Patent Trial and Appeal Board in connection with IPR2014-01252 may be
`
`excluded from this response.
`
`
`
`Dated: October 6, 2014
`
`
`
`
`
`By:/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
`Counsel for Patent Owner
`
`
`
`-3-
`
`Unified Patents Inc. Ex. 1016, pg. 4
`Unified v. Dragon
`IPR2014-01252
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`It is certified that a copy of the foregoing has been served on Petitioner via
`
`electronic mail transmission addressed to the person(s) at the address below:
`
`Michael L. Kiklis
`Scott McKeown
`OBLON SPIVAK
`cpdocketkiklis@oblon.com
`cpdocketmckeown@oblon.com
`
`
`
`Date: October 6, 2014
`
`/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
`Counsel for Patent Owner
`
`
`
`
`
`-4-
`
`Unified Patents Inc. Ex. 1016, pg. 5
`Unified v. Dragon
`IPR2014-01252
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