`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`Polygroup Limited (MCO)
`
`Petitioner
`
`v.
`
`Willis Electric Company, Limited
`
`Patent Owner
`
`_________________________
`
`Case IPR2016-01613
`
`Patent 9,044,056
`
`_________________________
`
`DISCOVERY REQUESTS
`
`Willis Electric Co., Ltd.
`EXHIBIT 2023
`Polygroup v. Willis
`IPR2016-01613
`Page 1
`
`
`
`Willis Electric requests Polygroup produce the following documents and
`information within 14 days:
`Request for Production No. 1: Please produce documents relating to
`transition of industry and Polygroup from old pre-lit designs to adoption of One
`Plug designs/commercial success/nexus with the claimed design including
`POLY_MN_00065045, POLY_MN_00067250, POLY_MN000066904,
`POLY_MN000066075, POLY_MN000063612.
`Request for Production No. 2: Please produce documents relating to price
`premium charged for Quick Set or EZ Connect features, including
`POLYNC00040815; POLYNC00040814; POLYNC00040814.
`Request for Production No. 3: Please produce documents relating to
`copying Willis designs or patents including POLY_MN_00067880,
`POLY_MN_00067879, POLY_MN_67878, POLY_MN_00067606, and
`POLY_MN_00063480 POLY_MN_00066253; POLY_MN_00067236;
`POLY_MN_00064640; POLY_MN_00064642; POLY_MN_00064636;
`POLY_MN_00065059; POLY_MN_00063496; POLY_MN_00063498;
`POLY_MN_0006339; POLY_MN_00063487; and tend to show nexus between
`Polygroup and Willis Electric’s designs.
`
`1
`
`Willis Electric Co., Ltd.
`EXHIBIT 2023
`Polygroup v. Willis
`IPR2016-01613
`Page 2
`
`
`
`Respectfully submitted,
`
`Date: April 14, 2017
`
`s/Larina A. Alton
`Larina A. Alton
`Reg. No. 72,750
`Counsel for Patent Owner
`FOX ROTHSCHILD LLP
`222 South Ninth Street, Suite 2000
`Minneapolis, MN 55402
`(612) 607-7000
`
`2
`
`Willis Electric Co., Ltd.
`EXHIBIT 2023
`Polygroup v. Willis
`IPR2016-01613
`Page 3
`
`
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