PUBLIC REDAC TED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`DOCKET NO.: 221 1726-00161
`
`Filed on behalf of Unified Patents Inc.
`
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Jonathan E. Robe, Reg. No. 76,033
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`Jonathan Stroud, Reg. No. 72,518
`Roshan S. Mansinghani, Reg. No. 62,429
`Unified Patents Inc.
`
`1875 Connecticut Ave. NW, Floor 10
`
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES, LLC
`Patent Owner
`
`IPR2018-00952
`
`Patent 9,253,239
`
`PETITIONER’S VOLUNTARY INTERROGATORY RESPONSES
`
`ActinS l69439723v.l
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`
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
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`Page 1 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`DOCKET NO.: 221 1726-00161
`
`Filed on behalf of Unified Patents Inc.
`
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Jonathan E. Robe, Reg. No. 76,033
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`Jonathan Stroud, Reg. No. 72,518
`Roshan S. Mansinghani, Reg. No. 62,429
`Unified Patents Inc.
`
`1875 Connecticut Ave. NW, Floor 10
`
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES, LLC
`Patent Owner
`
`IPR2018-00952
`
`Patent 9,253,239
`
`PETITIONER’S VOLUNTARY INTERROGATORY RESPONSES
`
`ActinS l69439723v.l
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
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`Page 1 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDAC TED VERSION
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`lPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`Petitioner, Unified Patents Inc., provides the following voluntary
`
`interrogatory responses.
`
`DEFINITIONS
`
`A.
`
`’239 PATENT means U.S. Patent 9,253,239.
`
`B.
`
`COMMUNICATIONS means the transmission or receipt of information of
`
`any kind through any means (e.g., e-mail, text message, voicemail, audio,
`
`computer readable media, or orally).
`
`C. MEMBER means any company that participates in UNIFIED’s solution and
`
`MEMBERS means all such companies.
`
`D.
`
`IPR means inter partes review.
`
`B.
`
`F.
`
`THE INSTANT IPR means this proceeding.
`
`PETITION means the petition, including the exhibits thereto, for THE
`
`INSTANT IPR.
`
`G.
`
`UNIFIED means Unified Patents Inc. and includes any shareholder, officer,
`
`director, employee, agent, representative, privies, intermediaries, or other
`
`individual authorized to act on behalf of Unified Patents Inc.
`
`H.
`
`USPTO means the United States Patent and Trademark Office.
`
`ActiveUS 169439723\'.I
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`Page 2 of 23
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`PUBLIC REDACTED VERSION
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`PUBLIC REDAC TED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`RESPONSES TO INTERROGATORIES
`
`INTERROGATORY NO. 1:
`
`Identify any COMMUNICATIONS between UNIFIED and any entity other
`
`than its counsel relating to the financing, preparation, editing, prior review, or
`
`approval of the PETITION.
`
`RESPONSE N0. 1:
`
`UNIFIED states that no such communications exist.
`
`UNIFIED states that it was founded by intellectual property professionals
`
`over concerns with the increasing risk of non-practicing entities (NPEs) asserting
`
`patents of poor quality against strategic technologies and industries. The founders
`
`thus created a first-of-its-kind company whose sole purpose is to deter NPE litigation
`
`by protecting technology sectors. Companies in a technology sector subscribe to
`
`UNIFIED’s technology-specific deterrence, and in turn, UNIFIED performs many
`
`NPE-deterrent activities, such as analyzing the technology sector and monitoring
`
`patent activity (including patent ownership and sales, NPE demand letters and
`
`litigation, and industry companies). UNIFIED’s monitoring activities allows it to
`
`identify patents, perform prior art research, analyze invalidity, and to sometimes file
`
`reexaminations or IPRs against some patents.
`
`UNIFIED states that it has sole and absolute discretion over its decision to
`
`contest patents through the USPTO’s post-grant proceedings. Based on its own
`
`ActichS 169439723»: 1
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`Page 3 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDAC TED VERSION
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`analysis, UNIFIED determines which patents are worth pursuing in terms of
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`IPR2018-00952 Voluntary lnterrogatory Responses
`US. 9,253,239
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`searching for prior art or taking action,
`
`including filing an IPR. UNIFIED’s
`
`decisions to file an IPR are made independently without the input, assistance, or
`
`approval of its MEMBERS. Should UNIFIED decide to challenge a patent in a post-
`
`grant proceeding, UNIFIED controls every aspect of such a challenge, including
`
`controlling which patent and claims to challenge, which prior art to apply and the
`
`grounds raised in the challenge, and when to bring any challenge.
`
`MEMBERS receive no prior notice of UNIFIED’s patent challenges. Afier
`
`filing a post-grant proceeding, UNIFIED retains sole and absolute discretion and
`
`control over all strategy decisions (including any decision to continue or terminate
`
`UNIFIED’s participation). UNIFIED is also solely responsible for paying for the
`
`preparation, filing, and prosecution of any post-grant proceeding, including any
`
`expenses associated with the proceeding.
`
`In THE INSTANT IPR, UNIFIED exercised its sole discretion and control in
`
`deciding to file this PETITION against the ’239 PATENT, including paying for all
`
`fees and expenses. UNIFIED shall exercise sole and absolute control and discretion
`
`of the continued prosecution of THE INSTANT IPR (including any decision to
`
`terminate UNIFIED’s participation) and shall bear all subsequent costs related to
`
`THE INSTANT IPR.
`
`ActichS l69439723vJ
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
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`Page 4 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDAC TED VERSION
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`INTERROGATORY N0. 2:
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`Identify any individuals acting for or on behalf of any entity other than
`
`UNIFIED’s counsel that participated or assisted in any way with the financing,
`
`preparation, editing, prior review, approval, or filing of the PETITION.
`
`RESPONSE NO. 2:
`
`UNIFIED states that no such individuals exist. UNIFIED further states that
`
`no individuals other than UNIFIED’s employees and its counsel had any prior
`
`knowledge of the filing of THE INSTANT IPR.
`
`As stated in response to Interrogatory No. 1,
`
`in THE INSTANT IPR,
`
`UNIFIED exercised its sole discretion and control in deciding to file the PETITION
`
`against the ’239 PATENT, including paying for all fees and expenses. UNIFIED
`
`shall exercise sole and absolute control and discretion of the continued prosecution
`
`of THE INSTANT IPR (including any decision to terminate UNIFIED’s
`
`participation) and shall bear all subsequent costs related to THE INSTANT IPR.
`
`UNIFIED further states that its MEMBERS do not get to participate in any
`
`way in UNIFIED’S deterrent activities. UNIFIED does not receive input from its
`
`MEMBERS, and does not give them an opportunity to participate in or an
`
`opportunity to even know that UNIFIED is contemplating filing an IPR before the
`
`IPR is filed. In THE INSTANT IPR, none of UNIFIED’s MEMBERS had any prior
`
`Active! IS l69439723v.l
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`UNIFIED PATENTS EXHIBIT 1032
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`PUBLIC REDACTED VERSION
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`knowledge of, or involvement in, the preparation and filing of THE PETITION or
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`lPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`THE INSTANT IPR.
`
`INTERROGATORY N0. 3:
`
`Identify payments by any entity to UNIFIED in connection with (1) THE
`
`PETITION and/or (2) any other IPR and/or patent infringement proceedings in
`
`which Bradium Technologies, LLC is a party and the ’239 PATENT was asserted.
`
`RESPONSE NO. 3:
`
`UNIFIED states that no such payments exist.
`
`UNIFIED states that its MEMBERS pay a yearly subscription fee to specific
`
`technology zones, and in return, UNIFIED performs its many NPE-deterrent
`
`activities. UNIFIED’s MEMBERS do not pay any fees designated for IPRs, let
`
`alone for IPRs against specific patents.
`
`It is UNIFIED and UNIFIED alone that
`
`determines how to spend its money. UNIFIED independently selects which patents
`
`to challenge based on the perceived deterrent value to a technology zone. Based on
`
`its own analysis, UNIFIED determines which patents are worth pursuing in terms of
`
`filing a challenge or performing some other activity. UNIFIED’S decisions to file a
`
`challenge are made independently without the input, assistance, or approval of its
`
`MEMBERS.
`
`ActiveUS l69439723v.l
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`Page 6 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDAC TED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`US 9,253,239
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`UNIFIED states that there are no explicit or implicit agreements with its
`
`MEMBERS about UNIFIED performing any particular deterrent strategy, including
`
`THE INSTANT IPR.
`
`INTERROGATORY N0. 4:
`
`Identify any and all relevant NPE Zone(s), as presently and/or previously
`
`identified on the Unified Patents website (www.mifiedpatents.com), that pertain to
`
`the technology that is the subject of the instant IPR.
`
`RESPONSE NO. 4:
`
`UNIFIED states that THE INSTANT IPR pertains to the “Content Delivery”
`
`NPE Zone, as identified on UNIFIED’s website (www.unifiedpatents.com).
`
`INTERROGATORY NO. 5:
`
`Identify any and all members or entities who are members of the Zone(s)
`
`identified in response to Interrogatory No. 4.
`
`RESPONSE NO. 5:
`
`UNIFIED states that the following members are members of the “Content
`
`Delivery”
`
`NPE
`
`Zone,
`
`as
`
`identified
`
`on
`
`UNIFIED’s
`
`website
`
`(www.unifiedpatents.com):
`
`UNIFIED MEMBERS listed below in italics are public. The identity of other
`
`UNIFIED MEMBERS is highly confidential business information.—
`
`Active US l69439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
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`1PR2018-00952 Voluntary lnlcrrogatory Responses
`U.S. 9.253.239
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`,C. ; f 3C
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`l
`C -
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`,
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`\I
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`[PR2018-00952 Voluntary lnterrogatory Responses
`US. 9,253.239
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`\clhel‘S l(yU-!39723\
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`I
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`II’R2018-00953 Voluntary lnterrogatory Responses
`U.S. 9.253.239
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`“\cllwl‘S 16‘)v13‘)723\.]
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`O
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`lPR2018—00952 Voluntary lnterrogator) Responses
`US. 9.253.239
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`|"'"I'||'|"'|'||"IIIIII|II'I
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`\xl'wi K VFW—1‘01)“ l
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`l0
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
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`[PR2018-00952 Voluntary lnterrogatory Responses
`US. 9.253.239
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`«\cliwl S lthJ—SR‘J’IM l
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`._.
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`_.
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`UNIFIED PATENTS EXHIBIT 1032
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`INTERROGATORY N0. 6:
`
`Identify any entity that is both (1) presently a MEMBER andi’or has been a
`
`MEMBER at any time since 2016. and (2) (a) has been sued for patent infringement
`
`'M‘fivel rs MWW’UM .l
`
`I7
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
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`Page 13 of 23
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`of the ’239 PATENT by Bradium Technologies, LLC or
`
`(b) has received
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`IPR2018-00952 Voluntary lnterrogatory Responses
`US. 9,253,239
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`Notice/Licensing letters from Bradium Technologies, LLC (or from GPC).
`
`RESPONSE NO. 6:
`
`UNIFIED states it is not aware of any current or former MEMBER who has
`
`been sued by Bradium Technologies, LLC. UNIFIED further states that, in general,
`
`it is not aware of licensing activities between third parties, including by any of its
`
`current or former MEMBERS. UNIFIED further states that it is not aware of any
`
`current or former MEMBER who has received a Notice/Licensing letter from
`
`Bradium Technologies, LLC. UNIFIED further states that it is not aware of any
`
`current or former MEMBER that has been the subject of licensing or enforcement
`
`by Bradium Technologies, LLC.
`
`INTERROGATORY N0. 7:
`
`Identify the date on which Unified Patents first became aware of the ’239
`
`PATENT.
`
`RESPONSE NO. 7:
`
`UNIFIED states that it first became aware of the ’239 PATENT on or about
`
`June 17, 2015.
`
`INTERROGATORY NO. 8:
`
`Without disclosing privileged information, identify how Unified Patents first
`
`became aware of (a) the ’239 PATENT, (b) Bradium Technologies, LLC, and (c)
`
`Active US l69439723v.l
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`13
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`any other patent owned by Bradium Technologies, LLC, including the identity of
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`any outside parties who may have provided notice or other information concerning
`
`the ’239 PATENT to Unified Patents and identify and documents pertaining to parts
`
`(a), (b), or (e).
`
`RESPONSE NO. 8:
`
`UNIFIED states that it first became aware of Bradium Technologies, LLC and
`
`patents it owns, including the ’239 PATENT, via a filing subscription service e-mail
`
`and Bradium’s public website. UNIFIED further states that it has produced the filing
`
`subscription service e-mail, dated June 17, 2015, which has been marked with the
`
`identifiers UP-000001 through UP-000010. UNIFIED further states there are no
`
`other non-privileged documents pertaining to Interrogatory No. 8. N0 outside party,
`
`including any MEMBER, made UNIFIED aware of the ’239 PATENT.
`
`INTERROGATORY NO. 9:
`
`Without disclosing privileged information,
`
`identify any written policies
`
`and/or practices that Unified Patents uses when (1) identifying and/or evaluating
`
`potential targets for challenge before the USPTO, and (2) selecting and pursuing
`
`particular patents for challenge before the USPTO and identify any documents
`
`pertaining to such policies and/or practices.
`
`RESPONSE N0. 9:
`
`ActiveUS 169439723v.l
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`l4
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`PUBLIC REDAC TED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`As stated in the Response to Interrogatory No.
`
`l, UNIFIED has sole and
`
`absolute discretion over its decision to contest patents through the USPTO’s post-
`
`grant proceedings. Based on its own analysis, UNIFIED determines which patents
`
`are worth pursuing in terms of searching for prior art or taking action, including
`
`filing an IPR. UNIFIED’s decisions to file an IPR are made independently without
`
`the input, assistance, or approval of its MEMBERS. Should UNIFIED decide to
`
`challenge a patent in a post-grant proceeding, UNIFIED controls every aspect of
`
`such a challenge, including controlling which patent and claims to challenge, which
`
`prior art to apply and the grounds raised in the challenge, and when to bring any
`
`challenge.
`
`To the extent that Interrogatory No. 9 relates to non—privileged material and
`
`solely to internal legal decision-making and in the interest of avoiding delay and
`
`without waiving any applicable privilege, UNIFIED states that there are no written
`
`policies UNIFIED uses when (1) identifying and/or evaluating potential patents for
`
`challenge before the USPTO, and (2) selecting and pursuing particular patents for
`
`challenge before the USPTO. UNIFIED further states that it has internal discussions
`
`between UNIFIED’S employees and outside counsel that include no third party.
`
`UNIFIED further states its practices include identifying current patents to target
`
`based on publicly available information obtained solely through UNIFIED’s own
`
`independent search of publicly available legal databases, assignment records,
`
`ActiveUS l69439723v.l
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`15
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`secondary market sales, and other similar available means. UNIFIED further states
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
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`its practices include legal analysis of the patent, including analysis of the potential
`
`target’s claims and UNIFIED own internal determination ofthe likelihood of success
`
`in an IPR proceeding.
`
`INTERROGATORY NO. 10:
`
`Identify the time periods during which the members or entities identified in
`
`response to Interrogatory No. 6 have been Unified Patents MEMBERS.
`
`RESPONSE N0. 10:
`
`UNIFIED states it is not aware of any current or former MEMBER who has
`
`been sued by Bradium Technologies, LLC. UNIFIED further states that, in general,
`
`it is not aware of licensing by third parties, including by any of its current or former
`
`MEMBERS. UNIFIED further states that it is not aware of any current or former
`
`MEMBER who has received a Notice/Licensing letter from Bradium Technologies,
`
`LLC. UNIFIED further states that it is not aware of any current or former MEMBER
`
`which was or will be the subject of potential licensing or enforcement by Bradium
`
`Technologies, LLC.
`
`INTERROGATORY N0. 11:
`
`Identify all Unified Patents members from the past two years.
`
`RESPONSE NO. 11:
`
`ActiveUS 169439723v. I
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`16
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`US. 9,253,239
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`UNIFIED objects to Interrogatory No. 11 as redundant of Interrogatory No.
`
`5. UNIFIED states that it has provided the relevant list of members of its “Content
`
`Delivery” NPE Zone in its Response to Interrogatory No. 5.
`
`INTERROGATORY NO. 12:
`
`Identify payments made to Unified Patents by the entities identified in
`
`response to lntenogatory No. 6.
`
`RESPONSE N0. 12:
`
`UNIFIED states that no such payments exist.
`
`INTERROGATORY N0. 13:
`
`Identify any Board Members, significant shareholders, and any other entities
`
`or individuals who own or control Unified Patents.
`
`RESPONSE NO. 13:
`
`UNIFIED states that Kevin Jake] and Shawn Ambwani are the sole
`
`shareholders, owners, and controllers of Unified Patents; UNIFIED further states
`
`that no such other entities or individuals exist.
`
`INTERROGATORY NO. 14:
`
`Identify any law firm(s) Unified Patents has retained or paid in connection
`
`with THE INSTANT IPR.
`
`RESPONSE NO. l4:
`
`ActichS 169439723v.|
`
`l7
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`Page 18 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDAC TED VERSION
`
`lPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`UNIFIED objects to the extent that Interrogatory No. 14 seeks privileged
`
`information.
`
`To the extent
`
`that
`
`Interrogatory No.
`
`14 seeks non-privileged
`
`information, UNIFIED objects as unduly burdensome because its counsel of record
`
`in THE INSTANT IPR is a matter of public record and is therefore as available to
`
`Bradium Technologies, LLC as it
`
`is to UNIFIED. No other counsel has been
`
`retained or paid in connection to this matter.
`
`INTERROGATORY NO. 15:
`
`Identify (a) the total number of IPRs Unified has filed since 2016 and, of that
`
`total, (b) the number of filed lPRs related to district court litigation that had already
`
`been filed against Unified members identified in the response to Interrogatory No. 5
`
`above.
`
`RESPONSE N0. 15:
`
`UNIFIED objects to part (a) of Interrogatory No. 15 as unduly burdensome
`
`because the total number of IPRs UNIFIED has filed since 2016 is a matter ofpublic
`
`record and is therefore as available to Bradium Technologies, LLC as it is to
`
`UNIFIED. UNIFIED objects to part (b) of Interrogatory No. 15 as unduly
`
`burdensome because the number of IPRs filed by UNIFIED which are related to
`
`district court litigation filed against any MEMBER included in the Response to
`
`Interrogator No. 5 is now as available to Bradium Technologies, LLC as it is to
`
`UNIFIED. UNIFIED states that it has provided the relevant list of MEMBERS in
`
`ActiveUS 169439723v.1
`
`18
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
`
`Page 19 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDAC TED VERSION
`
`its Response to Interrogatory No. 5 and therefore the number of IPRs filed by
`
`IPR20l 8—00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`UNIFIED which are related to district court litigation filed against any MEMBER
`
`included in the Response to Interrogator No. 5 is matter of public record and is as
`
`available to Bradium Technologies, LLC as it is to UNIFIED.
`
`INTERROGATORY N0. 16:
`
`Identify Unified’s revenue as a percentage by source (e.g., membership fees
`
`versus any other sources of revenue), by year, since 2016.
`
`RESPONSE N0. 16:
`
`UNIFIED states that
`
`the following table presents the percentage of
`
`UNIFIED’S revenue that was derived from member subscription fees, annually,
`
`since 2016. These figures are approximate and do not account for trivial revenue
`
`sources. Accordingly, the percentages are rounded to the nearest whole number:
`
`
`Percentage of Unified’s Revenue
`
`Year
`
`Coming from Member Subscription
`
`Fees
`
`
`2016
`
`-
`
`
`
`
`2017
`2018 (lst quarter)
`
`
`
`-
`-
`
`_J
`
`INTERROGATORY NO. 17:
`
`ActiveUS l69439723v.l
`
`19
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
`
`Page 20 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDAC TED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`Identify Unified’s costs/expenses as
`
`a percentage by category (e.g.,
`
`expenditures expended on IPRs as a percentage of total expenditures), by year, since
`
`2016 and identify the line items included in amounts expended on IPRs.
`
`RESPONSE NO. 17:
`
`UNIFIED states following table presents the percentage of UNIFIED’s
`
`expenses which was expended on IPRs, annually since 2016. These figures are
`
`rounded to the nearest whole number:
`
`Percentage of Unified’s Expenses
`
`Expended on IPRs
`
`2018 (lst quarter)
`
`
`
`
`
`ActiveUS I694 39723v.l
`
`20
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
`
`Page 21 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDAC TED VERSION
`
`Unified Patents Inc.
`
`lPR2018-00952 Voluntary lnterrogatory Responses
`US. 9,253,239
`
`/Daniel V. Williams/
`By:
`Daniel V. Williams, Reg. No. 45,221
`Wilmer Cutler Pickering Hale and Dorr
`LLP 1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Daniel.Williams@wilmerhale.com
`
`AclichS l69439723ul
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018—00952
`
`Page 22 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDAC TED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`VERIFICATION
`
`
`1, Kevin Jake] state that I am CEO of Unified Patents Inc., and that I am
`
`I certify that I have read
`authorized to make this verification for and on its behalf.
`the foregoing Interrogatory responses, and that the responses are true and accurate
`to the best of my own knowledge, information. and belief. Further, I make this
`verification with the knowledge that willful false statements and the like so made
`are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of
`the United States Code and that such willful false statements may jeopardize the
`results of these proceedings.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`By; KWKevin Jflél
`
`ActichS l69439723v.l
`
`22
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`Page 23 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
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