`Filed: December 14, 2015
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`THE MANGROVE PARTNERS MASTER FUND, LTD.
`Petitioner
`
`v. VIRNETX
`
`INC.
`Patent Owner
`
`Case IPR2015-01047
`Patent 7,490,151
`
`[Petitioner’s Proposed Revisions of]
`Patent Owner’s Interrogatories
`
`Page 1 of 4
`
`MANGROVE EX. 1026
`Mangrove v. VirnetX
`Trial IPR2015-01047
`
`
`
`Patent Owner requests that Petitioner serve written responses to these
`
`interrogatories.
`
`INSTRUCTIONS
`
`In responding to these interrogatories, please comply with the instructions in
`
`the Office Patent Trial Practice Guide.
`
`1. Please timely amend your responses if you learn that your response is
`
`incomplete or additional responsive information is found.
`
`2. Whenever you are asked to identify a communication, please: (a) summarize
`
`the subject matter of the communication; (b) state the date and location of the
`
`communication; and (c) identify the parties to the communication.
`
`3. If you object to a portion or an aspect of any interrogatory, state the grounds
`
`of your objection with specificity and respond to the remainder of the
`
`interrogatory.
`
`4.
`
`If, in answering these interrogatories, you encounter any ambiguities when
`
`construing a request, instruction, or definition, your response shall set forth the
`
`matter deemed ambiguous and the construction used in responding.
`
`5.
`
`For any information sought by an interrogatory that you withhold based
`
`upon a claim of privilege, please identify the ground of the asserted privilege and
`
`provide a privilege log according to the requirements of Federal Rule of Civil
`
`Procedure 26.
`
`Page 2 of 4
`
`
`
`Case No. IPR2015-01046
`
`DEFINITIONS
`
`1. The terms “document” and “thing” have the broadest meaning prescribed in
`
`Federal Rule of Civil Procedure 34, including ESI and any physical specimen or
`
`tangible item, in your possession, custody, or control.
`
`2. “Communications” shall mean the transmission or receipt of information of
`
`any kind through any means (e.g., email, voicemail, audio, computer readable
`
`media, or orally).
`
`3.
`
`The term “Mangrove Entities” includes The Mangrove Partners Master
`
`Fund, Ltd., Mangrove Partners, The Mangrove Partners Fund, L.P., The Mangrove
`
`Partners Fund (Cayman), Ltd., Mangrove Capital, any of their present and former
`
`investors, and any of
`
`their present and former employees,
`
`representatives,
`
`consultants, contractors, attorneys, agents, and all other persons or entities acting
`
`or purporting to act on behalf of any of the foregoing, such as Nathaniel August,
`
`Ward Dietrich, Jeffrey Kalicka, Brian Steck, Philp Lee, David Bree, and Kevin
`
`Phillip.
`
`4. “Mangrove IPRs” refers to inter partes review Case Nos. IPR2015-01046
`
`and IPR2015-01047.
`
`5. “VirnetX Patents” refers to U.S. Patent No. 6,502,135 and U.S. Patent No.
`
`7,490,151.
`
`Page 3 of 4
`
`2
`
`
`
`Case No. IPR2015-01046
`
`INTERROGATORY
`
`INTERROGATORY NO. 1
`
`Identify communications and/or agreements in Request for Production Nos.
`
`1-34 of Exhibit 2039 that were not reduced to writing.
`
`INTERROGATORY NO. 2
`
`Identify persons and entities,
`
`including any of the Mangrove Entities,
`
`involved in the preparation and filing of the petitions or other papers in the
`
`Mangrove IPRs, including persons and entities involved in any suggestions of prior
`
`art, patentability challenges, and decisions to pursue inter partes review challenges
`
`of VirnetX Patents.
`
`INTERROGATORY NO. 3
`
`To the extent not covered by Interrogatory No. 2, identify persons and
`
`entities, including any of the Mangrove Entities, that control the Mangrove IPRs,
`
`including anyone who controlled or had the ability to control the preparation and
`
`filing of the petitions in the Mangrove IPRs.
`
`INTERROGATORY NO. 4
`
`Identify persons and entities, including any of the Mangrove Entities, that
`
`provide or receive funding, directly or indirectly, for the Mangrove IPRs.
`
`25003/1/3390812.1
`
`Page 4 of 4
`
`3
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