CoreLogic Exhibit 1026
`CoreLogic, Inc. v. Boundary Solutions, Inc.
`Trial IPR2015-00228
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`Page 1 of 14
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`CoreLogic’s subsidiaries, affiliates, parents, divisions, joint ventures, licensees, franchisees,
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`assigns, predecessors and successors in interest, and any other legal entities, whether foreign or
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`domestic, that are owned or controlled by CoreLogic and all predecessors and successors in
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`interest to such entities.
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`2.
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`"Person" or "Persons" means any natural person, individual, firm, association,
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`corporation, partnership, foundation, proprietorship, joint venture, organization or entity,
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`including all governmental entities, agencies, officers and departments, and its agents,
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`representatives and employees.
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`3.
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`“Accused Products” means CoreLogic's Parcel Mapping Products and Services as
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`identified in Plaintifl‘s Amended Disclosure of Asseited Claims and Infringement Contentions,
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`dated September 22, 2014.
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`4.
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`“lnformation" means information in any form, including but not limited to
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`documentary, electronic, graphical, or tabular, and communicated by any means, including but
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`not limited to orally, in writing, or via electronic communication.
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`5.
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`6.
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`7.
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`8.
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`"Any" means any or all.
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`"Each“ means each and every.
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`"Include" and "including" mean including but not limited to.
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`"Relate to," "Related to," "Relating to," or "Concerning" means constituting,
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`containing, embodying, reflecting, describing, involving, supporting, contradicting, evidencing,
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`analyzing, identifying, mentioning, stating, referring directly or indirectly to, dealing with, or in
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`anyway pertaining to, whether in whole or in part.
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`9.
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`"Concerning," "relating to," "relate to,“ "relates to," "related to," "referring or
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`relating to," "referring to,“ "regarding," and "refer or relate to" mean in whole or in any part
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`alluding to, responding to, concerning, relating to, collected with, involving, commenting on, in
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`respect of, about, associated with, discussing, evidencing, showing, describing, reflecting.
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`analyzing, summarizing, memorializing, consisting of, constituting, identifying, stating, tending
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`to support, tending to discredit, referring to, or in any way touching upon.
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`PI,AlNTlFF’S FIRST SET OF REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO CORELOGIC, INC.
`(NOS I-62)
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`- 2 -
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`CASE NO. C-l4—0076l PSG
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`l0.
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`"Communication" means any transmission of information in any context or
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`situation by or between two or more persons by any means or medium whatsoever, whether in
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`the form of an original, a draft, or a copy, whether stored in hard copy, electronically or digitally,
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`or on tape, either orally or in writing, including but not limited to conversations; correspondence;
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`electronic mails; telexes; facsimile transmissions; telecopies; recordings in any medium of oral,
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`written, or typed communications; telephone or message logs; notes or memoranda relating to
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`written or oral communications; and any translation thereof.
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`l 1.
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`"Document," "documents," "thing," or "things" means the full range of meanings
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`prescribed by Federal Rule of Civil Procedure 34 and include the terms "writings and
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`recordings," "photographs," "originals," and "duplicate" as defined in Federal Rule of Evidence
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`1001 and mean any and all documents or things in the possession, custody or control of
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`CoreLogic or its counsel, known to Corelsogic or its counsel, and is used in its customarily broad
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`sense to include the following items, whether printed, recorded, microtilmed, or reproduced by
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`any process, or written or produced by hand, and whether or not claimed to be privileged or
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`confidential or personal: letters; memoranda; reports; records; agreements; working papers;
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`communications (including intradepartmcntal and interdepartmental communications);
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`correspondence; summaries or records of personal conversations; diaries; forecasts; statistical
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`statements; graphs; laboratory or research reports and notebooks; charts; minutes or records of
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`conferences; expressions or statements of policy; lists of persons attending meetings or
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`conferences; reports of or summaries of interviews; reports of or summaries of investigations;
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`opinions or reports of consultants; patent appraisals; opinions of counsel; reports of or
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`summaries ofeither negotiations within or without the corporation or preparations for such;
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`brochures; manuals; pamphlets; advertisements; circulars; press releases; drafts of any
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`documents; memoranda; books; instruments; accounts; bills of sale; invoices; tapes; electronic
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`communications including emails; telegraphic communications and all other material of any
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`tangible medium of expression; and original or preliminary notes. Any comment or notation
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`appearing on any document, and not a part of the original text, is to be considered a separate
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`document.
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`l’LAlt\"'l‘Il“F’S FIRST SET or REQUESTS FOR
`PRODUCTION or DOCUMENTS To CORFIDGIC; INC
`(NOS. l—62)
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`- 3 -
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`CASE NO. C-14-00761 PSG
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`Page 3 of 14
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`Page 3 of 14
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`l2.
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`As used herein, the singular form ofa term shall be interpreted to include the
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`plural and vice versa.
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`l3.
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`As used herein. the masculine form ofa term shall be interpreted to include the
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`feminine and vice versa.
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`14.
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`Except where the context does not permit, the term "including" shall be without
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`limitation.
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`I5.
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`"And" and "or" as used herein shall be construed both conjunctively and
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`disjunctively and each shall include the other whenever such construction will serve to bring
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`within the scope of these requests any document that would otherwise not be brought within their
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`scope.
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`INSTRUCTIONS
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`A.
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`To the extent any definition or instruction herein conflicts with any other relevant
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`definition or instruction, interpret the definition or instruction broadly, as necessary to bring
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`within the scope of these Requests any documents or things that might otherwise be construed to
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`be outside their scope.
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`B.
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`These Requests shall apply to all documents and things in CoreLogic’s
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`possession, custody or control at the present time or coming into its possession, custody or
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`control prior to the date of the production. lf CoreLogic knows of the existence, past or present,
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`of any documents or things requested below, but is unable to produce such documents or things
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`because they are not presently in its possession, custody or control, CoreLogic shall so state and
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`shall identify such documents or things, and the person who has possession, custody or control of
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`the documents or things.
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`C.
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`If no documents or things are responsive to a particular Request, C0reLogic is to
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`state that no responsive documents or things exist.
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`D.
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`For any responsive documents or things that have been lost, destroyed. withheld
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`from production based on any ground, or are no longer in CoreLogic’s possession, custody, or
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`control, CoreLogic shall provide a written statement setting forth:
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`(0
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`the identity ofthe document or thing;
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`Pl.AINTlFF’S l"ll{S'l’ SETOF REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO CORFLOGIC, INC.
`(N()S.l~6'.l)
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`- 4 -
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`CASE NO. C—l4—0076l PSG
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`»;_vn42,«—~A\\v>%A\vn1A\VPA~»exp»/rJWMMHvvdt&1/~V:’i‘4¢>¢/R’:/»<&‘~vW;<V»¢x\>‘I~a‘XA7.7‘;9~4&¢fl-9A3rf«%»v;¢<74'Q':/‘('17/\K9V;¢/L‘¢k\7‘54)\@&l~V/S>’V~¢z*<>k%~:?<m<‘~A«%\*/IDVA./é4é€:/fix\'¢\X\¥$$\&o&‘2y#V4><~'U%)‘2'n};Xvm*>tX%V\$<’)\§«iv"3:9%&%2\Av‘fl'5‘¢AVpM&% £%~¥»%f%J%W&%%?M*%J mm;
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`(ii)
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`the nature of the document (e.g., letter, memorandum, chart) or thing;
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`(iii)
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`the identity ofthe person(s) who received copies ofthe document or
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`thing;
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`(iv)
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`identity ofthe person(s) who prepared or created the documents or
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`thing;
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`(V)
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`the date of creation of the document or thing;
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`(vi)
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`a brief description of the subject matter of the document or thing; and
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`(vii)
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`the circumstances and date ofthe loss of possession, custody, or
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`control or the circumstances and date of the destruction of the document or
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`thing and any fact, statute, rule or decision upon which CoreLogie relies in
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`withholding the document or thing.
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`lfa Request calls for a document or thing that CoreLogic declines to produce, in
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`whole or in part, based on a claim of privilege or any other claim, provide a privileged document
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`list which identifies each document separately and specifies for each document at least the
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`following:
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`(i)
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`(ii)
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`the date;
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`the authors, creators, and sender(s) identified by position and entity
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`with which they are employed or associated and, if any author or sender is
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`an attorney, a statement so stating and, ifany sender is a Foreign patent
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`agent, a statement so stating and a statement as to whether the laws of the
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`agent's country grant privileged status to a patent agent's communications;
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`(iii)
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`the recipient(s), including copy recipients, identified by position and entity
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`with which they are employed or associated and, if any recipient is an
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`attorney, a statement so stating and, if any recipient is a foreign patent
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`agent, a statement so stating and a statement as to whether the laws of the
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`agent's country grant privileged status to a patent agent's communications;
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`(iv)
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`the general subject matter ofthe document or thing;
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`(V)
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`the portions ofthe document as to which privilege is claimed; and
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`PLAlN’l‘lI<‘F’S FIRST SET or REQUESTS FOR
`PRODUCTION or DOCUMENTS TO CORELOUIC, INC.
`(NOS. I -62)
`
`— 5 —
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`CASE NO. C-14-00761 PSG
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`(vi)
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`the type of privilege asserted as well as a certification that all elements
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`of the claimed privilege have been met and not waived.
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`F.
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`These Requests seek all responsive documents in their original language and, if
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`such original language is not English, these Requests also seek all English-language translations
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`that may exist for any such documents.
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`REQUESTS FOR PRODUCTION
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`Request No.1:
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`Documents sufficient to describe the corporate structure, both inter— and intra—entity,
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`and including ownership and control, of Defendant, and any corporate parents, subsidiaries,
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`affiliates, predecessors or successors thereof.
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`Request No.2:
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`Documents sufficient to show the current organizational structures of Defendant,
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`including, the research and/or development unit(s), department(s), and division(s) thereof.
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`Request No. 3:
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`Documents identifying all customers that have bought or licensed any Accused Product,
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`since February 2008.
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`Request No.4:
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`Source code, software, and/or documents correlating to source code or software that relate
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`to or are used in connection with the Accused Products. Such documents shall include any data
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`dictionaries, schema, and include the names of tables, fields, relationships, views, indexes,
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`packages, procedures, functions, queues, triggers, types, sequences, materialized views,
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`synonyms, database links, directories, XML schemas, and other elements.
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`Request No. 5:
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`Documents sufficient to show the design, development, and implementation of the
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`features and functionality used by the Accused Products, including, but not limited to, any
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`documents that discuss or describe CoreLogic’s decision to include those features in the products
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`or services.
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`Request No.6:
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`PLAINTIFPS FIRST SET or REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO COREL()(ilC, INC.
`(NOS. I-62)
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`— 6 -
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`CASE NO. C-14-0076] PSG
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`Documents sufficient to describe Defendant's policies, procedures and practices regarding
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`the storage and maintenance of documents (including, but not limited to, schematics, circuit
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`diagrams, laboratory notebooks, process flows, data sheets, manuals, and technical specifications)
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`that relate to any Accused Products.
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`Request No. 7:
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`Documents sufficient to describe Defendant's document retention policies.
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`Request No.8:
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`All presentations made, and any materials and things provided,
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`to any third patty
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`by Defendant that refer or relate to any Accused Product.
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`Request No. 9:
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`Documents sufficient to identify all entities, including any third parties, that are involved
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`in providing products or services that form a part of any Accused Product.
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`Request N0. 10:
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`Documents sufficient to identify the respective roles(s), functions, and obligations ofall
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`entities, including any third parties, that are involved in providing any part of any Accused
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`Product to any end user.
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`Request N0. 11:
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`All agreements between Defendant and any third paity(ies) regarding the useof any
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`technology that is a part of any Accused Product.
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`Request No. 12:
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`All contracts and agreements (including, but not limited to, indemnity agreements),
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`between Defendant, on one hand, and any other entity(ies), on the other hand, that relate to any
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`Accused Product.
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`Request No. 13:
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`All documents that refer or relate to any contract or agreement, between Defendant, on
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`one hand, and any other entity(ies), on the other hand,
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`that relate to any Accused Product.
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`Request No. 14:
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`Documents sufficient to identify the date(s) that Defendant began offering each ofthe
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`Pl,AINTlFF‘S FIRST SET or l{EQUl:‘STS FOR
`PRODUCTION or DOCUMENTS TO CORELOGIC, INC
`(NOS I-62)
`
`- 7 —
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`CASE No. 014-00761 PSG
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`Page 7 of 14
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`Accused Products, including documents sufficient to identify the date of the first design and use
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`ofthe features and functionality used by the Accused Products that BS1 has alleged infringe the
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`Patents-in—Suit.
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`Request N0. 15:
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`Documents sufficient to identify, on aquarterly and annual basis since Defendant
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`began offering any of the Accused Products, the total number of those products sold, the total
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`revenues for these products, and the costs incurred and profits received by Defendant in
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`connection with each of these products.
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`Request No. 16:
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`All End User License Agreements (EULA) used in connection with any Accused Product.
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`Request No. 17:
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`All instructions, manuals, guides, or other documentation for the features and
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`functionality used by the Accused Products.
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`Request N0. 18:
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`Documents sufficient to identify, on a monthly or quarterly basis since Defendant
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`began offering any of the Accused Products, the total revenues and profits received, and
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`costs/expenses incurred, by Defendant in connection with Defendant's business operations in the
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`United States.
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`Request No. 19:
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`Documents sufficient to identify persons with knowledge about the design,
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`development, testing, manufacturing, operation, and marketing ofthe Accused Products.
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`Request N0. 20:
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`Documents sufficient to identify the individuals who contributed to, oversaw, or were
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`otherwise involved in the design, development, or implementation ofthe features and
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`functionality available in CoreLogic’s Parcel Point data repository.
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`Request No. 21:
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`All documents that refer or relate to the Patents—in—Suit, or any related patents or patent
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`applications in the same family as the Patents—in—Suit.
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`Pl,/\lNTlFF'S FIRST SET or REQUESTS FOR
`PRODUCTION or DOCUMENTS TO CORELOGIC, INC.
`(NOS 1-62)
`
`- 8 -
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`CASE NO. C-14—00761 PSG
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`Page 8 of 14
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`Request No. 22:
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`All documents that refer or relate to the validity, or alleged invalidity, ofthe Patents-in-
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`Suit.
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`Request N0. 23:
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`All documents that refer or relate to infringement or alleged non-infringement of the
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`Patents—in—Suit.
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`Request N0. 24:
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`All documents that refer or relate to the enforceability, or alleged unenforceability, ofthe
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`Patents-in—Suit.
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`Request N0. 25:
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`All opinions, reports, or evaluations concerning the infringement or validity of the
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`Patents—in—Suit, or any related patents or patent applications in the same family as the Patents—in—
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`Suit.
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`Request No. 26:
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`All documents that refer or relate to any process, method, or structure identified by
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`Defendant as prior art to the Patents-in-Suit.
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`Request N0. 27:
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`All documents that refer or relate to Plaintiff BS1.
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`Request No. 28:
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`All documents that refer or relate to the inventor ofthe Patents-in-Suit, Dennis Klein.
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`Request N0. 29:
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`All documents reflecting, referring to, or relating to, any communications between
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`Defendant, on one hand, and Plaintiffon the other hand.
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`Request No. 30:
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`All documents that mention or discuss the Patents—in—Suit, or its inventors, including, but
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`not limited to, any publications, patents, articles or presentations in which any ofthe inventors
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`are either an author, co-author, inventor or co—inventor.
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`Request N0. 31:
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`PLAINTIFPS FIRST SE1" OF Rl:'QUES'l‘S FOR
`PRODUCTION OF DOCUMENTS TO CORELOGIC, INC.
`(lV()S.l—62)
`
`- 9 -
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`CASE ND. C— l4-00761 PSG
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`All documents concerning correspondence or other communications between Defendant
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`and any third parties regarding the Patents—in-Suit, the subject matter thereof, or this lawsuit.
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`Request No. 32:
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`All documents that refer or relate to any communication between Defendant and any
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`person and/or third party concerning Plaintiff.
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`Request No. 33:
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`All
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`licenses, including patent
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`licenses, relating to methods and/or technology that for
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`any mapping or GIS solution to which Defendant is or has been party.
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`Request N0. 34:
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`All licenses or other agreements that Defendant contends confer any rights to them under
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`the Patents-in—Suit.
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`Request No. 35:
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`All documents regarding negotiations involving any licenses,
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`including patent
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`licenses, relating to methods and/or technology for any mapping or GIS solution to which the
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`Defendant has been a party.
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`Request N0. 36:
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`All licenses, including patent licenses, relating to Defendant's products or methods for any
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`mapping or GIS solutions.
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`Request No. 37:
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`All Documents relating to any analysis, review, consideration, evaluation, inspection,
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`report, or copying of any BS1 product, feature, or functionality, including but not limited to
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`any comparisons between any BS1 product, feature, or functionality and any actual or
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`contemplated features or functionality CoreLogic included or considered including in its
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`products or services.
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`Request No. 38:
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`All documents constituting or
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`relating to communications with any third-party
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`regarding the Patents—ln—Suit or any related patents or patent applications in the same family as
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`the Patents~in—Suit.
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`PLAlNTlFi~“S rn<s'r sur or REQUESTS FOR
`PRODUCTION or DOCUMENTS TO CORELOGIC, INC
`(NOS.l—62)
`
`- 10 -
`
`CASE NO. C—l4—00761 PSG
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`/,.m.M.MW..,,..W.,,.,,.,,~,,ms, ..,_,.,,e..w.,.ws,-.M..,WMN.a..,M.mMWM.~“W, MAM.MweWwWKW..s,~,m.we.vMa»x..¢a.MWwse«wwW/uamW~,a~aWNW.w»»wAew«We~wm.mmesssiw-+M.sau,_Wa»e.,ausw,¢s 4}» 7
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`Request N0. 39:
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`All documents concerning the factual basis for Defendant's contention that any claims of
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`the Patents-in—Suit are invalid.
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`Request No. 40:
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`Documents sufficient to identify Defendant's first awareness of any ofthe Patents-in-Suit,
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`or any related patents or patent applications in the same family as the Patents-in-Suit.
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`Request N0. 41:
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`All documents relating to any efforts taken by Defendant to avoid infringing the Patents-
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`in—Suit or any related patents or patent applications in the same family as the Patents-in-Suit.
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`Request No. 42:
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`All documents that refer or relate to any opinions, studies, reviews, analyses, or
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`investigation done at any time, regarding the interpretation or construction of any claim term in
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`the Patents-in-Suit or any related patents or patent applications in the same family as the Patents~
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`in-Suit.
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`Request N0. 43:
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`All documents concerning Defendant's potential liability or non~liability with respect to
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`the Patents-in-Suit or any related patents or patent applications in the same family as the Patents-
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`in-Suit.
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`Request N0. 44:
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`All documents relating to the value of the Patents-in-Suit or any related patents or patent
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`applications in the same family as the Patents-in-Suit., potential damages for infringement ofthe
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`Patents-in-Suit or any related patents or patent applications in the same family as the Patents-in-
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`Suit, or potential royalties for a license to the Patents—in—Suit or any related patents or patent
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`applications in the same family as the Patents-in-Suit..
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`Request No. 45:
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`All documents that refer or relate to the calculation ofa reasonable royalty fora license
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`under the Patents—in—Suit.
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`Request N0. 46:
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`Pl./\lNTIFF'S FIRST SET or Reoui:s'rs FOR
`PRODUCTION or DOCUMENTS TO CORELOGIC, we
`(NOS I-62)
`
`- l I —
`
`CASE NO. 0 14-00761 PSG
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`All documents identified in Defendant's Fed. R. Civ. P. 26(a)(l) Initial Disclosures.
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`///
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`Request No. 47:
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`All documents that relate to the aflirmative defenses and counterelaims pled by Defendant
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`in this lawsuit, regardless of whether such documents tend to support, or conflict with, the
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`positions taken by Defendant in this lawsuit.
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`Request No. 48:
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`All documents referred to, referenced, considered, or relied upon, by Defendant in
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`preparing their responses to each ofthe interrogatories served by Plaintiff on Defendant in this
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`lawsuit.
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`Request No. 49:
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`All communications between Defendant and any other person regarding or relating to any
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`lawsuit, or the substance thereof, filed by Plaintiff.
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`Request N0. 50:
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`All documents and communications produced by any third-party to Defendant, whether or
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`not produced pursuant to a subpoena, that relate to the Patents-in—Suit or the subject matter of this
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`lawsuit.
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`Request No. 51:
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`All indemnity or insurance agreements that relate to the subject matter of this lawsuit, and
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`all documents and communications which refer or relate to such indemnity or insurance
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`agreements.
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`Request N0. 52:
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`All Documents relating to the importance of, or the consumer demand for, the
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`features and functionality used by the CoreLogic that BS1 has alleged infringe the Patents-
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`in-Suit. Such Documents shall include, but are not limited to, any consumer study, consumer
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`demand analysis, survey, report, or other analysis.
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`Request N0. 53:
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`Documents sufficient to identify the market in which the Accused Products compete.
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`l’LAlN'l'll<‘l“‘S Hnsr srsr or REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO CORF.l,OG|(‘, INC.
`(NOS.l-02)
`
`— l2 -
`
`CASE NO. C-14-00761 PSG
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`Request No. 54:
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`Documents sufficient to identify the respective market share of each product that competes
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`with an Accused Product in any market
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`Request No. 55:
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`All Documents relating to CoreLogic's strategy to acquire market share for the Accused
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`Products
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`Request No. 56:
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`Documents sufficient to show CoreI.ogic's business plans and marketing strategies for the
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`Accused Products and for any other CoreLogic product incorporating any ofthe features or
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`functionality used by the CoreLogic that BS1 has alleged infringe the Patents—in-Suit, Such
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`Documents shall include, but are not limited to, market surveys or studies relating to buyer loyalty
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`and comparisons between the CoreLogic Accused Products and any other product.
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`Request No. 57:
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`All Documents relating to any customer surveys. studies, analyses or investigations
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`regarding the Accused Products.
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`Request No. 58:
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`All Documents relating to any customer surveys, studies, analyses or investigations
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`regarding the Accused Products.
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`Request No. 59:
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`Documents sufficient to show CoreLogic‘s actual sales and market share for the
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`Accused Products, in terms of both revenue and unit volume. on a monthly, quarterly, and
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`annual basis, from the time the those products were first released,
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`through trial.
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`Request No. 60:
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`Documents sufficient to show CoreLogic's projected sales and market share for the
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`Accused Products in terms of both revenue and unit volume, on a monthly, quarterly, and
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`annual basis, for any period of time for which any such projections were prepared.
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`All Documents considered or relied upon by any expert that CoreLogic retains in
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`connection with this case.
`
`PLAINTIFPS FIRST SET or REQUESTS FOR
`PROI)UCTl()N or D()CU.\/lt:‘N'l‘S TO CORELOGIC, INC.
`(NOS.l-62)
`
`— 13 —
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`CASE NO. C-14-00761 PSG
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`Page13of14
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`Page 13 of 14
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`Request N0. 61:
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`All Documents relating to marketing of the Accused Products including copies of an
`
`advertisements or other promotional materials, marketing plans, market surveys, focus
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`group studies, or other Documents related to testing of marketing messaging.
`
`Request No. 62:
`
`All documents that Defendant intends to rely upon during the trial in this matter.
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`Dated: September 26, 2014
`
`Respectfully submitted,
`
`»/‘
`HAUSFELD LLP
`
`
`
`By:
`
`BRUCE V»/ECKER (CA Bar NO. 078530)
`bwecl<er@hausfeldllp.com
`
`Attorneys for Plaintzjf
`BOUNDARY SOLUTIONS INC.
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`PLAINTIFFS FIRST set or REQUESTS FOR
`PRODUCTION or DOCUMENTS TO CORELOGIC, INC
`(NOS l-62)
`
`- 14 -
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`CASE NO. C~14-00761 PSG
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`Page 14 of 14