`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`ARRIS GROUP, INC.
`Petitioner
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`v.
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`C-CATION TECHNOLOGIES, LLC
`Patent Owner
`____________________
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`CASE IPR2015-00635
`Patent 5,563,883
`____________________
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`
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`C-CATION TECHNOLOGIES, LLC’S PROPOSED DISCOVERY
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`REQUEST TO ARRIS GROUP, INC.
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`C-Cation 2001
`Arris Group, Inc. v. C-Cation Technologies, LLC
`IPR2015-00635
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`1
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`
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`Patent Owner C-Cation Technologies, LLC requests that petitioner Arris
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`Group, Inc. respond and produce the following documents and things.
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`INSTRUCTIONS
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`1.
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`In responding to and producing documents and things responsive to
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`this request, the responding party shall comply with the instructions in the Patent
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`Trial Practice Guide.
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`2.
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`A responding party shall timely amend its response upon learning that
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`its response is incomplete or if additional responsive information is found.
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`3.
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`All responsive documents must be produced as they are kept in the
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`usual course of business.
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`DEFINITIONS
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`1.
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`The term “document” has the broadest meaning prescribed in Federal
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`Rule of Civil Procedure 34, including ESI in the responding party’s possession,
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`custody, or control.
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`2.
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`The term “Arris” means Arris Group, Inc. and includes any
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`employees, agents, counsel, representatives, or others authorized to act on Arris’s
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`behalf.
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`3.
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`The term “Texas Litigation” means the lawsuit entitled C-Cation
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`Techs., LLC v. Comcast Corp., et al., Case No. 2:11-cv-00030-JRG-RSP, filed by
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`2
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`C-Cation Technologies, LLC in the United States District Court for the Eastern
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`District of Texas.
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`4.
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`The term “Comcast” means Comcast Corporation, Comcast Cable
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`Communications, LLC, and Comcast of Houston LLC, and includes any
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`employees, agents, counsel, representatives, or others authorized to act on behalf of
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`those entities.
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`3
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`REQUEST FOR PRODUCTION
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`Request for Production No. 1
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`Agreement(s) between Arris and Comcast under which Comcast requested
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`indemnification for the claims brought against Comcast in the Texas Litigation that
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`reference (or are contingent on) Arris’s ability to control the litigation.
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`4