UNITED STATES PATENT AND TRADEMARK OFFICE
`
`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 1116
`RPX v. AIT
`IPR2015-01752
`
`
`
`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 1116
`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.
`
`INSTRUCTIONS
`
`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.
`
`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
`
`responsive documents of which RPX is aware but cannot produce because they
`
`have been lost or destroyed or are no longer in Petitioner’s possession, custody, or
`
`control.
`
`2.
`
`If RPX finds the meaning of any term in the Requests unclear, RPX
`
`should assume a reasonable meaning, state what the assumed meaning is, and
`
`produce documents and things on the basis of that assumed meaning.
`
`Unless otherwise stated, the requests seek documents and things created
`
`from 2013 to the present.
`
`
`
`2
`
`
`
`DEFINITIONS
`
`1.
`
`“Document” has the broadest meaning accorded to it by FED. R.
`
`CIV. P. 34.
`
`2.
`
`3.
`
`The term “Salesforce” means salesforce.com, inc.
`
`The term “Related IPR Proceedings” means Case Nos. IPR2015-
`
`01750, IPR2015-01751 andIPR2015-01752.
`
`4.
`
`The term “Challenged Patents” means the following patents which
`
`are the subject of the IPR proceedings: U.S. Patent Nos. 7,356,482 and 8,484,111.
`
`5.
`
`The term “Salesforce Litigation” means
`
`the litigation styled
`
`Applications in Internet Time LLC v. Salesforce.com, Inc., No. 3:13-cv-628-RCJ-
`
`VPC (D. Nev.).
`
`6.
`
`The term “communications” means the transmission or receipt of
`
`information of any kind through any means (e.g. email, voicemail, audio, computer
`
`readable media, or orally).
`
`7.
`
`The term ParkerVision means Farmwald v ParkerVision, Inc., Case
`
`IPR2014-00946, Case IPR2014-00947 and Case IPR2014-00948 (February 20,
`
`2015).
`
`REQUESTSFORPRODUCTION
`
`Request No. 1: Documents sufficient to show Salesforce’s relationship
`
`toany agreement between RPX, such as membership or client agreements, and
`
`
`
`3
`
`
`
`renewals and Salesforce obligating RPX to pursue the Related IPR Proceedings.
`
`Request No. 2: Documents sufficient
`
`to show RPX’s annual billings to
`
`Salesforce and the services associated with those billings.
`
`Request No. 32: Communications between RPX and Salesforce, and
`
`whether directly or through their respective attorneys and agents, relating to the
`
`Challenged Patents, the Related IPR Proceedings, or the Salesforce Litigation,
`
`whether by name, code name or euphemism.
`
`Request No. 4: Documents sufficient to show the names, dates, locations
`
`and times of any meetings or communications between Salesforce and RPX, or
`
`their attorneys, after the Salesforce Litigation began, unless produced under a prior
`
`request herein.
`
`Request No. 5: Communications between RPX or its attorneys and any
`
`third party, dated prior to the filing of the petitions in the Related IPR Proceedings
`
`and related to the Challenged Patents. Excluded third parties: Salesforce,
`
`Salesforce’s attorneys, and prospective expert witnesses.
`
`Request No. 6: All documents showing why RPX decided to challenge the
`
`Challenged Patents, unless produced under a prior request herein.
`
`Request No. 73: Documents, such as invoices, sufficient to show all funds
`
`or consideration provided to RPX with the purpose of funding the Related IPR
`
`Proceedings, including dates and source of funds, unless produced under a prior
`
`
`
`4
`
`
`
`request herein.
`
`Request No. 8: Documents sufficient to show how Sanford R. Robertson
`
`separates his
`
`fiduciary duties
`
`to RPX and Salesforce despite
`
`serving
`
`simultaneously as a Board Member of RPX and as a Board Member of Salesforce.
`
`Request No. 9: Those
`
`portions
`
`of
`
`any
`
`deposition
`
`transcripts
`
`in
`
`ParkerVision relating to the issue of real party in interest (e.g., Mr. Brodsky).
`
`Request No. 10: Documents discussing any efforts by RPX to shield its
`
`clients from being named as real parties in interest in inter parte reviews and
`
`covered business method patent reviews, after the Board denied the petitions in
`
`RPX Corp. v. VirnetX, Inc., IPR2014-00171 (June 23, 2014) and before the filing
`
`of the petitions in the Related IPR Proceedings.
`
`Date:
`
`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
`
`
`
`5
`
`
`
`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:
`
`By:
`
`
`
`6
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