PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`DOCKETNO.: 2211726-00161
`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
`WilmerCutler 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 PATENTSINC.
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES, LLC
`Patent Owner
`
`IPR2018-00952
`Patent 9,253,239
`
`PETITIONER’S VOLUNTARY INTERROGATORY RESPONSES
`
`ActiveUS 169439723v.1
`
`
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`DOCKETNO.: 2211726-00161
`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
`WilmerCutler 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 PATENTSINC.
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES, LLC
`Patent Owner
`
`IPR2018-00952
`Patent 9,253,239
`
`PETITIONER’S VOLUNTARY INTERROGATORY RESPONSES
`
`ActiveUS 169439723v.1
`
`
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`Petitioner, Unified Patents Inc., provides the following voluntary
`
`interrogatory responses.
`
`DEFINITIONS
`
`A.
`
`*239 PATENT meansU.S.Patent 9,253,239.
`
`B.|COMMUNICATIONSmeansthetransmission or receipt of information of
`
`any kind through any means(e.g., e-mail, text message, voicemail, audio,
`
`computer readable media, or orally).
`
`C.|MEMBERmeans any companythat participates in UNIFIED’s solution and
`
`MEMBERSmeansall such companies.
`
`IPR meansinter partes review.
`
`|THE INSTANTIPR meansthis proceeding.
`
`D.
`
`E.
`
`F.|PETITION meansthe petition, including the exhibits thereto, for THE
`
`INSTANTIPR.
`
`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 meansthe United States Patent and Trademark Office.
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 2 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`RESPONSES TO INTERROGATORIES
`
`INTERROGATORYNO.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.
`
`RESPONSENO.1:
`
`UNIFIEDstates that no such communicationsexist.
`
`UNIFIEDstates 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 createdafirst-of-its-kind company whosesole purpose is to deter NPElitigation
`
`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 demandletters and
`
`litigation, and industry companies). UNIFIED’s monitoring activities allowsit to
`
`identify patents, perform prior art research, analyze invalidity, and to sometimesfile
`
`reexaminations or IPRs against somepatents.
`
`UNIFIEDstates that it has sole and absolute discretion over its decision to
`
`contest patents through the USPTO’s post-grant proceedings. Based on its own
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`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 decideto challenge a patentin 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 whento bring any challenge.
`
`MEMBERSreceive noprior notice of UNIFIED’s patent challenges. After
`
`filing a post-grant proceeding, UNIFIED retains sole and absolute discretion and
`
`control overall 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, UNIFIEDexercisedits sole discretion and control in
`
`decidingto file this PETITION against the °239 PATENT,including payingfor all
`
`fees and expenses. UNIFIEDshall 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.
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 4 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`INTERROGATORYNO.2:
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 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, orfiling of the PETITION.
`
`RESPONSENO.2:
`
`UNIFIEDstates that no such individuals exist. UNIFIED further states that
`
`no individuals other than UNIFIED’s employees and its counsel had any prior
`
`knowledgeofthe filing of THE INSTANT IPR.
`
`As stated in response to Interrogatory No. 1,
`
`in THE INSTANT IPR,
`
`UNIFIEDexercisedits 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 MEMBERSdo notgetto 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
`
`IPRis filed. In THE INSTANT IPR, none ofUNIFIED’s MEMBERShadanyprior
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 5 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`knowledgeof, or involvement in, the preparation and filing of THE PETITION or
`
`THE INSTANTIPR.
`
`INTERROGATORYNO.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 wasasserted.
`
`RESPONSE NO.3:
`
`UNIFIEDstates that no such paymentsexist.
`
`UNIFIEDstates that its MEMBERSpaya yearly subscription fee to specific
`
`technology zones, and in return, UNIFIED performs its many NPE-deterrent
`
`activities. UNIFIED’s MEMBERSdonot pay any fees designated for IPRs, let
`
`alone for IPRs against specific patents.
`
`It is UNIFIED and UNIFIEDalonethat
`
`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 decisionstofile a
`
`challenge are made independently without the input, assistance, or approvalofits
`
`MEMBERS.
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 6 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`UNIFIEDstates that there are no explicit or implicit agreements with its
`
`MEMBERSabout UNIFIED performinganyparticular deterrent strategy, including
`
`THE INSTANTIPR.
`
`INTERROGATORYNO.4:
`
`Identify any and all relevant NPE Zone(s), as presently and/or previously
`
`identified on the Unified Patents website (www.unifiedpatents.com), that pertain to
`
`the technology that is the subject of the instant IPR.
`
`RESPONSE NO.4:
`
`UNIFIEDstates that THE INSTANT IPRpertains to the “Content Delivery”
`
`NPEZone,as identified on UNIFIED’s website (www.unifiedpatents.com).
`
`INTERROGATORYNO.5:
`
`Identify any and all members orentities who are members of the Zone(s)
`
`identified in response to Interrogatory No. 4.
`
`RESPONSENO.5:
`
`UNIFIEDstates that the following members are members of the “Content
`
`Delivery’
`
`NPE
`
`Zone,
`
`as
`
`identified
`
`on
`
`UNIFIED’s
`
`website
`
`(www.unifiedpatents.com):
`
`UNIFIED MEMBERSlisted belowinitalics are public. The identity of other
`
`UNIFIED MEMBERSishighly confidential business information. PF
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 7 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 VoluntaryInterrogatory Responses
`
`U.S. 9,253,239aa|
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 8 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`ActiveUS 169439723v.1
`
`oo
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 9 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 VoluntaryInterrogatory Responses
`U.S. 9,253,239
`
`ActiveUS 169439723v.1
`
`oO
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 10 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`ary
`
`ActiveUS 169439723v.1
`
`So
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 11 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`ActiveUS 169439723v.1
`
`—
`
`—
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 12 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`4—= x zx©QO>=©zx o Z 9 &
`
`Identify any entity that is both (1) presently a MEMBER and/or has been a
`
`MEMBER atanytime since 2016, and (2) (a) has been sued for patent infringement
`
`ActiveUS 169439723v.1
`
`12
`
`UNIFIED PATENTS EXHIBIT 1032
`
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 13 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`of the ’239 PATENT by Bradium Technologies, LLC or
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`(b) has received
`
`Notice/Licensing letters from Bradium Technologies, LLC (or from GPC).
`
`RESPONSENO.6:
`
`UNIFIEDstates it is not aware of any current or former MEMBERwhohas
`
`been sued by Bradium Technologies, LLC. UNIFIEDfurtherstates that, in general,
`
`it is not aware of licensing activities between third parties, including by any ofits
`
`current or former MEMBERS. UNIFIED furtherstates that it is not aware of any
`
`current or former MEMBER who hasreceived a Notice/Licensing letter from
`
`Bradium Technologies, LLC. UNIFIED further states that it is not aware of any
`
`current or former MEMBERthat has been the subject of licensing or enforeement
`
`by Bradium Technologies, LLC.
`
`INTERROGATORYNO.7:
`
`Identify the date on which Unified Patents first became aware of the °239
`
`PATENT.
`
`RESPONSENO.7:
`
`UNIFIEDstates thatit first became aware of the °239 PATENTonor about
`
`June 17, 2015.
`
`INTERROGATORYNO.8:
`
`Without disclosing privileged information, identify how Unified Patentsfirst
`
`became aware of(a) the 7239 PATENT,(b) Bradium Technologies, LLC, and (c)
`
`ActiveUS 169439723v.1
`
`13
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 14 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`any other patent owned by Bradium Technologies, LLC, including the identity of
`
`any outside parties who may haveprovidednotice or other information concerning
`
`the °239 PATENT to Unified Patents and identify and documentspertaining to parts
`
`(a), (b), or (c).
`
`RESPONSE NO.8:
`
`UNIFIEDstates thatit 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 furtherstates that it has producedthefiling
`
`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. No outside party,
`
`including any MEMBER, made UNIFIED awareof the ’239 PATENT.
`
`INTERROGATORYNO.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.
`
`RESPONSENO.9:
`
`ActiveUS 169439723v.1
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 15 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`As stated in the Response to Interrogatory No. 1, 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 decisionsto 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 groundsraised in the challenge, and whento 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, UNIFIEDstates 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. UNIFIEDfurtherstates thatit 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 169439723v.1
`
`15
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 16 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`secondary marketsales, and other similar available means. UNIFIEDfurtherstates
`
`its practices include legal analysis of the patent, including analysis of the potential
`
`target’s claims and UNIFIED own internal determinationofthe likelihood of success
`
`in an IPR proceeding.
`
`INTERROGATORYNO.10:
`
`Identify the time periods during which the membersorentities identified in
`
`responseto Interrogatory No. 6 have been Unified Patents MEMBERS.
`
`RESPONSENO.10:
`
`UNIFIEDstates it is not aware of any current or former MEMBER who has
`
`been sued by Bradium Technologies, LLC. UNIFIEDfurtherstates that, in general,
`
`it is not aware oflicensing by third parties, including by any of its current or former
`
`MEMBERS. UNIFIEDfurtherstates that it is not aware of any current or former
`
`MEMBERwhohas received a Notice/Licensing letter from Bradium Technologies,
`
`LLC. UNIFIEDfurtherstates thatit 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.
`
`INTERROGATORYNO.11:
`
`Identify all Unified Patents members from the past two years.
`
`RESPONSENO.11:
`
`ActiveUS 169439723v.1
`
`16
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 17 of 23
`
`UNIFIED PATENTS EXHIBIT 1032
`
`PUBLIC REDACTED VERSION
`
`
`
`PUBLIC REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`UNIFIEDobjects to Interrogatory No. 11 as redundant of Interrogatory No.
`
`5. UNIFIED states that it has provided the relevant list of membersofits “Content
`
`Delivery” NPE Zonein its Responseto Interrogatory No.5.
`
`INTERROGATORYNO.12:
`
`Identify payments made to Unified Patents by the entities identified in
`
`response to Interrogatory No.6.
`
`RESPONSENO.12:
`
`UNIFIEDstates that no such paymentsexist.
`
`INTERROGATORYNO.13:
`
`Identify any Board Members, significant shareholders, and any otherentities
`
`or individuals who own orcontrol Unified Patents.
`
`RESPONSENO.13:
`
`UNIFIED states that Kevin Jakel and Shawn Ambwani are the sole
`
`shareholders, owners, and controllers of Unified Patents; UNIFIED further states
`
`that no such otherentities or individuals exist.
`
`INTERROGATORYNO.14:
`
`Identify any law firm(s) Unified Patents has retained or paid in connection
`
`with THE INSTANTIPR.
`
`RESPONSENO.14:
`
`ActiveUS 169439723v.1
`
`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 REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 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 burdensomebecauseits counsel of record
`
`in THE INSTANTIPRis a matter of public record andis 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.
`
`INTERROGATORYNO.15:
`
`Identify (a) the total number of IPRs Unified has filed since 2016 and, ofthat
`
`total, (b) the numberoffiled IPRs related to district court litigation that had already
`
`been filed against Unified membersidentified in the response to Interrogatory No. 5
`
`above.
`
`RESPONSENO.15:
`
`UNIFIEDobjects to part (a) of Interrogatory No. 15 as unduly burdensome
`
`because the total number of IPRs UNIFIEDhas filed since 2016 is a matter of public
`
`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 MEMBERincluded in the Response to
`
`Interrogator No. 5 is now as available to Bradium Technologies, LLC as it is to
`
`UNIFIED. UNIFIEDstates 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 REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`its Response to Interrogatory No. 5 and therefore the number of IPRsfiled by
`
`UNIFIED which arerelated to district court litigation filed against any MEMBER
`
`included in the Response to Interrogator No. 5 is matter of public record andis as
`
`available to Bradium Technologies, LLCas it is to UNIFIED.
`
`INTERROGATORYNO.16:
`
`Identify Unified’s revenue as a percentage by source (e.g., membership fees
`
`versus any other sources of revenue), by year, since 2016.
`
`RESPONSENO. 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 accountfortrivial revenue
`
`sources. Accordingly, the percentages are roundedto the nearest whole number:
`
`Percentage of Unified’s Revenue
`
`
`
`Year
`
`Coming from Member Subscription
`
`Fees
`
`2016||
`
`2017
`a
`|
`
`2018 (1st quarter)
`||
`
`INTERROGATORYNO.17:
`
`ActiveUS 169439723v.1
`
`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 REDACTED VERSION
`
`Identify Unified’s costs/expenses as
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`a percentage by category (e.g.,
`
`expenditures expended on IPRs as a percentageoftotal expenditures), by year, since
`
`2016 and identify the line items included in amounts expended on IPRs.
`
`RESPONSENO.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:
`
`2018 (1st quarter)
`
`Percentage of Unified’s Expenses
`
`Expended on IPRs
`
`
`
`
`
`ActiveUS 169439723v.1
`
`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 REDACTED VERSION
`
`Unified Patents Inc.
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 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
`
`ActiveUS 169439723v.1
`
`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 REDACTED VERSION
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`VERIFICATION
`
`
`I, Kevin Jakel, state that I am CEO of Unified Patents Inc., and that I am
`authorized to make this verification for and on its behalf.
`I certify that I have read
`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 foregoingis true and correct.
`
`By:
`
`ieie,
`
`Kevin Jakél
`
`ActiveUS 169439723v.1
`
`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
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
