`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`Polygroup Limited (MCO)
`
`Petitioner
`
`v.
`
`Willis Electric Company, Limited
`
`Patent Owner
`
`_________________________
`
`Case IPR2016-00802
`
`U.S. Patent No. 9,044,056
`
`_________________________
`
`DISCOVERY REQUESTS
`
`Willis Electric Company, Ltd.
`EXHIBIT 2003
`IPR2016-00802
`Polygroup v. Willis
`Page 1
`
`
`
`Willis Electric requests Polygroup produce the following documents and
`information within 14 days:
`Interrogatory No. 1: Please describe and identify sales and financial information
`on all pre-lit artificial trees from 2008 to the present, including the following:
`identification of pre-lit artificial trees without Quick Set, identification of pre-lit
`artificial trees with Quick Set (the latter category including those identified by
`Polygroup in Willis Electric v. Polygroup, 0:15-cv-03443 on Poly_Mn_00009282),
`and number of the units sold, gross sales, any applicable adjustments to calculate
`net sales and the volume of net sales, costs of goods sold, gross revenues, gross
`profits, measures of any costs (other than “costs of goods sold” that you contend
`vary with sales), gross profit margins, customers, and date of sale for each such
`product.
`
`Request for Production No. 1: Please produce an excel spreadsheet that identifies
`sales and financial information on all pre-lit artificial trees from 2008 to the
`present, including the following: identification of pre-lit artificial trees without
`Quick Set, identification of pre-lit artificial trees with Quick Set (including those
`identified in Willis Electric v. Polygroup 0:15-cv-03443 and identified on
`Poly_Mn_00009282), and the units sold, gross sales, gross revenues, gross profits,
`gross profit margins, customer(s) sold to, and date of sale for each such product.
`
`Request for Production No. 2: Please produce documents containing
`POLY_MN_00065045, POLY_MN_00067250, POLY_MN_00062884,
`POLY_MN_00027610, POLY_MN_00068394, which relate to transition of
`
`Willis Electric Company, Ltd.
`EXHIBIT 2003
`IPR2016-00802
`Polygroup v. Willis
`Page 2
`
`
`
`industry and Polygroup from old pre-lit designs to adoption of One Plug
`designs/commercial success/nexus with the claimed design.
`Request for Production No. 3: Please produce documents containing
`POLY_MN_00067880, POLY_MN_00067879, POLY_MN_67878,
`POLY_MN_0006339, and POLY_MN_00063487, which relate to Polygroup’s
`purchase of Willis Electric’s tree in connection with filing fast-track application
`14/090,470 filed November 26, 2013 and tend to show nexus between Polygroup
`and Willis Electric’s designs.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`Date: December 22, 2016
`
`
`
`
`
`By: s/Larina A. Alton
`
`
`Larina A. Alton
`
`
`
`Reg. No. 72,750
`
`
`Counsel for Patent Owner
`CHRISTENSEN FONDER P.A.
`33 South Sixth Street, Suite 3950
`Minneapolis, MN 55402
`
`(612) 315-4102
`
`
`
`
`
`Willis Electric Company, Ltd.
`EXHIBIT 2003
`IPR2016-00802
`Polygroup v. Willis
`Page 3
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