`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RPX CORPORATION,
`Petitioner
`
`v.
`
`APPLICATIONS IN INTERNET TIME LLC,
`Patent Owner.
`
`Case IPR2015-01750
`US Patent No. 8,484,111
`
`Case IPR2015-01751
`Case IPR2015-01752
`Patent 7,356,482 B2
`
`PATENT OWNER’S REQUESTS FOR PRODUCTION TO RPX CORP.
`
`
`
`1
`
`RPX Exhibit 1115
`RPX v. AIT
`IPR2015-01752
`
`
`
`Patent Owner Applications in Internet Time LLC (“AIT”) requests that
`
`Petitioner RPX Corporation (“RPX”) produce the following documents and
`
`things.
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`INSTRUCTIONS
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`In responding to and producing documents and things responsive to these
`
`Requests, RPX must comply with the instructions in the Office Patent Trial Practice
`
`Guide.
`
`1.
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`If RPX is aware of any responsive documents but cannot produce
`
`them because they have been lost or destroyed or are no longer in RPX’s
`
`possession, custody, or control, RPX should identify those documents. Identify any
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`responsive documents of which RPX is aware but cannot produce because they
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`have been lost or destroyed or are no longer in Petitioner’s possession, custody, or
`
`control.
`
`2.
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`If RPX finds the meaning of any term in the Requests unclear, RPX
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`should assume a reasonable meaning, state what the assumed meaning is, and
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`produce documents and things on the basis of that assumed meaning.
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`Unless otherwise stated, the requests seek documents and things created
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`from 2013 to the present.
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`
`
`2
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`
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`DEFINITIONS
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`1.
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`“Document” has the broadest meaning accorded to it by FED. R.
`
`CIV. P. 34.
`
`2.
`
`3.
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`The term “Salesforce” means salesforce.com, inc.
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`The term “Related IPR Proceedings” means Case Nos. IPR2015-
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`01750, IPR2015-01751 andIPR2015-01752.
`
`4.
`
`The term “Challenged Patents” means the following patents which
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`are the subject of the IPR proceedings: U.S. Patent Nos. 7,356,482 and 8,484,111.
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`5.
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`The term “Salesforce Litigation” means
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`the litigation styled
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`Applications in Internet Time LLC v. Salesforce.com, Inc., No. 3:13-cv-628-RCJ-
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`VPC (D. Nev.).
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`6.
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`The term “communications” means the transmission or receipt of
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`information of any kind through any means (e.g. email, voicemail, audio, computer
`
`readable media, or orally).
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`7.
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`The term ParkerVision means Farmwald v ParkerVision, Inc., Case
`
`IPR2014-00946, Case IPR2014-00947 and Case IPR2014-00948 (February 20,
`
`2015).
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`REQUESTSFORPRODUCTION
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`Request No. 1: Documents sufficient to show any agreement between
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`RPX and Salesforce obligating RPX to pursue the Related IPR Proceedings.
`
`
`
`3
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`
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`Request No. 2: Communications between RPX and Salesforce, whether
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`directly or through their respective attorneys and agents, relating to the Related IPR
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`Proceedings, whether by name, code name or euphemism.
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`Request No. 3: Documents, such as invoices, sufficient to show all funds
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`or consideration provided to RPX with the purpose of funding the Related IPR
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`Proceedings, including dates and source of funds, unless produced under a prior
`
`request herein.
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`Date:
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`Respectfully Submitted,
`
`By:
`Steven Sereboff (Reg. No. 37,035)
`ssereboff@socalip.com
`M. Kala Sarvaiya (Reg. No. 58,912)
`ksarvaiya@socalip.com
`SoCal IP Law Group LLP
`310 N. Westlake Boulevard, Suite 120
`Westlake Village, CA 91362
`Telephone: (805) 230-1350
`Fax: (805) 230-1355
`
`Attorneys for Applications In Internet
`Time LLC
`
`
`
`4
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`
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of this “PATENT OWNER’S REQUESTS
`FOR PRODUCTION TO RPX CORP.” has been served via Express Mail on
`, upon
`the following:
`
`Richard F. Giunta
`Elisabeth H. Hunt
`Randy J. Pritzker
`Wolf, Greenfield & Sacks, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`
`Rgiunta-PTAB@wolfgreenfield.com
`
`Dated:
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`By:
`
`
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`5