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`EXHIBIT 2502
`EXHIBIT 2502
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`RIMON LAW
`.’."R'EJ).i'i‘z‘A-‘fr‘ii/ZUW. {71.5117
`
`January 15, 2019
`
`VIA EMAIL
`
`James M. Glass
`
`Quinn Emanuel Urquhart & Sullivan, LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 1001
`
`Re:
`
`Cavium, LLC v. Alacritech, Inc. 5 Case IPR2018-00401: Objections to Reguests for
`Production
`
`Dear James:
`
`I write in response to Patent Owner’s Document Requests to Petitioner, IPR2018-00401, Ex.
`2400 with respect to Petitioner, Cavium, LLC (“Cavium”).
`
`Cavium generally objects to each of PO’s requests to the extent that they are vague, overly
`broad, unduly burdensome, or seek irrelevant or duplicative information. Cavium also objects to any
`request that seeks to impose requirements that are broader than the requirements set forth in the Office
`Patent Trial Practice Guide, the Federal Rules of Civil Procedure, and/or the Board’s Decision on
`Motion for Additional Discovery, IPR2018-00401, Paper 24 (Nov. 20, 2018) (“Board Order”) regarding
`discovery in this proceeding. Cavium further objects to each request to the extent that it seeks any
`information protected by the attomey-client privilege, work product privilege, common interest
`privilege, or any other applicable privilege and/or that seeks information that is proprietary business
`information that is otherwise irrelevant to the issues of privity or real-party-in-interest as it relates to this
`Petition. Cavium will not produce any communications between Cavium and its outside counsel.
`Cavium also objects to these requests to the extent that they seek discovery that is not relevant to any
`party’s claims or defenses, proportional to the needs of the case, and/or reasonably calculated to lead to
`the discovery of admissible evidence. In addition, Cavium objects to the requested discovery to the
`extent that it exceeds the scope of permissible discovery in inter partes review proceedings.
`
`With respect to Request No. 1, this Request seeks information that is not within Cavium’s
`possession, custody or control—specifically, documents and communications relating to the
`indemnification and defense obligations, rights and interests between Intel and Dell, Intel and Wistron,
`and Intel and Century Link—and Cavium objects to the production of any such documents or
`communications. Cavium is not involved in any joint defense relationship or indemnification
`relationship with either Wistron or Century Link and, therefore, there are no documents to produce.
`Cavium also objects to this Request as vague, ambiguous, overly broad, and not reasonably calculated to
`lead to the discovery of admissible evidence relevant to the issues of privity or real-party—in-interest.
`Cavium further objects to this request to the extent it seeks information protected by the attorney—client
`
`
`
`KARINEH Ifi‘rnram'rounr.w ; 2479 E. BAYSHORE ROAD. SUITE 210, PALO ALTO, CA 94383
`13265022357785 l P: 800.?36.?271 x364 | F: 650.223.?785 f karineh.iihachatourian@rimonlawxoni
`P.O. Exhibit 2502.001
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`P.O. Exhibit 2502.001
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`

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`RIMON LAW
`.........,-W”,1;th g‘m‘(
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`privilege, work product privilege, common interest privilege, or any other applicable privilege. Subject
`to these objections, and the general objections set forth above, and to the extent that Cavium understands
`PO’s request, Cavium will produce relevant, non-privileged documents relating to indemnification and
`defense obligations, rights and interests between Cavium and Dell relating to Alacritech’s patents
`asserted in the District Court litigations, if they exist.
`
`With respect to Request No. 2, this Request also seeks information that is not within Cavium’s
`possession, custody or control—namely, documents and communications relating to any representations
`or warranties made by Intel to Dell, Wistron and/or Century Link about indemnity and defense
`obligations, rights and interests relating to Alacritech’s patents—wand Cavium objects to the production
`of such information. Cavium also objects to this Request as vague, ambiguous, overly broad, and not
`reasonably calculated to lead to the discovery of admissible evidence relevant to the issues of privity or
`RPI. Subject to these objections, and the general objections set forth above, and to the extent that
`Cavium understands PO’S request, Cavium will produce relevant documents and communications
`between Cavium and Dell regarding Cavium’s indemnification and defense obligations to Dell relating
`to Alacritech’s patents asserted in the District Court cases, to the extent they exist.
`
`Regarding Request No. 3, Cavium objects to this Request as vague, ambiguous, overly broad,
`and not reasonably calculated to lead to the discovery of admissible evidence relevant to the issues of
`privity or RP]. Cavium further objects to this Request to the extent that it seeks information protected
`by the attorney-client privilege (including communications with outside litigation counsel), work
`product privilege, common interest privilege, or any other applicable privilege. Cavium will not
`produce documents in response to this Request.
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`Finally, with respect to Request No. 4, Cavium also objects to this Request as vague, ambiguous,
`overly broad, and not reasonably calculated to lead to the discovery of admissible evidence. Further, as
`you are aware, the PTAB limited this request to documents that relate to Alacritech’s patents, to these
`proceedings, or to the indemnification or defense agreements relevant to the same, if they exist.
`Consistent with the PTAB’S limitations, and subject to Cavium’s objections, Cavium will produce non-
`privileged, relevant documents and communications memorializing the relationship between Cavium
`and Dell related to Alacritech’s patents, these proceedings, or to the indemnification or defense
`agreements relevant to the same, if any exist.
`
`Very truly yours,
`
`RIMON P.C.
`
`
`
`KK21mb
`
`law
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`P. 0. Exhibit 2502. 002
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`P.O. Exhibit 2502.002
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