`
`PILLSBURY WINTHROP SHAW
`PITTMAN LLP
`Steven A. Moore, SBN 232114
`steve.moore@pillsburylaw.com
`Nicole S. Cunningham, SBN 234390
`nicole.cunningham@pillsburylaw.com
`501 West Broadway, Suite 1100
`San Diego, CA 92101-3575
`Telephone: 619-234-5000
`Facsimile: 619-236-1995
`
`Kecia J. Reynolds (pro hac vice)
`kecia.reynolds@pillsburylaw.com
`1200 Seventeenth Street, NW
`Washington, DC 20036
`Telephone: 202-663-8000
`Facsimile: 202-663-8007
`
`
`
`Attorneys for Plaintiff
`
`
`
`FOX ROTHSCHILD LLP
`Andrew S. Hansen (pro hac vice)
`ahansen@foxrothschild.com
`Archana Nath (pro hac vice)
`anath@foxrothschild.com
`Elizabeth A. Patton (pro hac vice)
`epatton@foxrothschild.com
`Lukas D. Toft (pro hac vice)
`ltoft@foxrothschild.com
`222 South Ninth Street, Suite 2000
`Minneapolis, MN 55402
`Telephone: 612-607-7000
`Facsimile: 612-607-7100
`
`Ashe P. Puri, SBN. 297814
`apuri@foxrothschild.com
`10250 Constellation Blvd., Suite 900
`Los Angeles, CA 90067
`Telephone: 310-598-4150
`Facsimile: 310-556-9828
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`EASTERN DIVISION
`
`SLEEP NUMBER CORPORATION,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`SIZEWISE RENTALS, LLC,
`
`
`Defendant.
`
`
`
`
`
`SLEEP NUMBER CORPORATION,
`
`
`Plaintiff,
`
`
`AMERICAN NATIONAL
`MANUFACTURING, INC.,
`
`
`v.
`
`Defendant.
`
`
`
`
`
`
`
`
`
`Case No. 5:18–cv–00356 AB (SPx)
`
`5:18–cv–00357 AB (SPx)
`
`
`PLAINTIFF’S FIRST
`SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF
`INTERROGATORIES (NOS. 1-9)
`
`
`-1-
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 1
`
`

`

`
`
`repositories has been and is being searched through the use of search terms and
`
`custodians in an effort to locate responsive documents and information that Plaintiff
`
`has agreed to produce or provide in this action. In addition, Plaintiff has contacted
`
`third parties, including the inventors of the patents-in-suit and source code vendors,
`
`to obtain relevant documents and information. With respect to Plaintiff’s search for
`
`source code specifically, Plaintiff refers Defendants to the Declaration of Paul James
`
`Mahoney dated November 21, 2018 (SN_0026378), the Declaration of James Edwin
`
`Gifft dated November 21, 2018 (SN_0026394), the Declaration of Cory Grabinger
`
`dated December 19, 2018 (SN_0026396), and the Declaration of Elizabeth A. Patton
`
`dated December 18, 2018 (SN_0026380), which collectively detail Plaintiff’s efforts
`
`at locating and providing source code for Defendants’ inspection and review.
`
`
`
`INTERROGATORY NO. 3: For each claim or defense you assert in this lawsuit
`
`(including for your contention(s) that the patents-in-suit are infringed, valid, and
`
`enforceable), describe in detail on an element-by-element basis your factual and legal
`
`bases, including the identification of all facts and documents that support or contradict
`
`your contentions and all persons with knowledge of the same; and all your factual and
`
`legal bases related to the authenticity and admissibility of such documents. At
`
`minimum, your initial response should describe at least your Rule 11 basis (including
`
`describing all testing evaluation, analysis, or examination of any product that you
`
`accuse of infringement) and, after reasonable discovery, your supplemental response
`
`should describe all evidence that you may rely to oppose, e.g., a no-evidence motion
`
`for summary judgment.
`
`
`
`RESPONSE:
`
`Plaintiff incorporates by reference each of the General
`
`Objections and specifically objects to this Interrogatory as comprising multiple
`
`discrete subparts, which shall count as multiple Interrogatories under Federal Rule of
`
`Civil Procedure 33(a)(1). Plaintiff further objects that this Interrogatory is a
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-8-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 2
`
`

`

`
`
`contention interrogatory posed early in the litigation. Defendants have not set forth
`
`the need for early contention interrogatories, or how an earlier response to a
`
`contention interrogatory assists the goals of discovery. Additionally, some of the
`
`information required in order to respond to this contention interrogatory is in the
`
`custody of Defendants or third parties. Further, early contention interrogatories, such
`
`as this one, call for attorney-client privileged and work-product protected materials
`
`and information as well as information that will be the subject of expert testimony
`
`and expert reports.
`
`
`
`Subject to and without waiving the foregoing General or Specific Objections,
`
`and subject to Plaintiff’s understanding that this Interrogatory relates to Plaintiff’s
`
`pending claims and affirmative defenses, Plaintiff responds as follows: Plaintiff
`
`conducted a pre-suit investigation and analysis that provided it with the factual and
`
`legal basis for the claims it has asserted against Defendants. Additionally, with
`
`respect to the ‘172 Patent, Plaintiff’s factual and legal basis also arises from
`
`information, documents, and expert testimony regarding Defendants’ products
`
`obtained during the course of the International Trade Commission (“ITC”) action it
`
`initiated against Defendants, the determinations made by the ITC regarding
`
`infringement by Defendants’ products, and the determinations made by the United
`
`States Patent and Trademark Office with respect to validity and enforceability of the
`
`‘172 Patent, including the fact that it previously survived both a Reexamination and
`
`an Inter Partes Review. With respect to the ‘154 and ‘747 Patents, Plaintiff’s factual
`
`and legal basis also arises from information, documents, and expert testimony
`
`regarding Defendants’ products obtained during the course of the ITC action as well
`
`as the Declaration of John Abraham dated September 5, 2017, Bates number
`
`SN_0008944. With respect to Plaintiff’s affirmative defenses, Plaintiff refers
`
`Defendant to each of the foregoing and incorporates by reference its response to
`
`Interrogatory No. 4 below, its briefing in support of its motion to dismiss, and the
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-9-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 3
`
`

`

`
`
`presumption of validity for each of the patents-in-suit set forth in 35 U.S.C. § 282. In
`
`addition, Plaintiff states that Defendants’ counterclaims are barred by various
`
`equitable doctrines, including equitable estoppel barring their inequitable conduct and
`
`civil conspiracy counterclaims and related affirmative defenses.
`
`
`
`Pursuant to Federal Rule of Civil Procedure 33(d), Plaintiff has produced and
`
`will produce documents that support its claims and affirmative defenses. Plaintiff
`
`also incorporates by reference its Amended Complaint and its Disclosure of Asserted
`
`Claims and Infringement Contentions and accompanying Exhibits, which contain
`
`element-by-element descriptions of Defendants’ infringement and which will be
`
`supplemented after an inspection of Defendants’ source code as stipulated between
`
`the Parties and after Defendants make a fulsome document production.
`
`
`
`Discovery is on-going and Plaintiff acknowledges its duty to supplement its
`
`response to this interrogatory and will do so in accordance with the Court’s scheduling
`
`order and the local rules.
`
`FIRST SUPPLEMENTAL RESPONSE:
`
`
`
`Plaintiff
`
`incorporates by reference the foregoing Response, including
`
`objections, and further responds as follows:
`
`
`
`Plaintiff’s counsel, Nigel Jones, and George Edwards performed an inspection
`
`of Defendants’ source code on October 9-11, 2018 and November 7, 2018. As a result
`
`of those inspections, Plaintiff determined that various source code utilized in
`
`Defendants’ products supports infringement of the ‘172, ‘152, and ‘747 Patents and
`
`therefore Plaintiff supplemented its claim charts. Plaintiff refers Defendants to the
`
`Exhibits to its Infringement Contentions served on December 5, 2018, which contain
`
`an element-by-element basis for Plaintiff’s claims of infringement. The persons
`
`knowledgeable about the factual and legal bases for Plaintiff’s claims include those
`
`identified in response to Interrogatory No. 1. The documents supporting the factual
`
`and legal bases for Plaintiff’s claims have been and are being produced in this action,
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-10-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 4
`
`

`

`
`
`including by Plaintiff, Defendants, and third parties. Plaintiff also intends to rely upon
`
`deposition testimony, including expert testimony. In addition, Plaintiff intends to rely
`
`upon expert reports, but because a different deadline for those disclosures have been
`
`ordered by the Court, a longer period for responding to these requests has been
`
`ordered by the Court. See Fed. R. Civ. P. 33(b)(2)(“A shorter or longer time [for
`
`responding to Interrogatories] may be… ordered by the court.”). Plaintiff will produce
`
`the information requested in this interrogatory in accordance with the Court’s orders
`
`and the local patent rules and hereby incorporates those future disclosures by
`
`reference.
`
`
`
`Discovery is still on-going and Plaintiff acknowledges its duty to further
`
`supplement its response to this interrogatory and will do so in accordance with the
`
`Court’s scheduling order and the local rules.
`
`
`
`INTERROGATORY NO. 4: For each affirmative defense and counterclaim
`
`asserted in this lawsuit, describe in detail on an element-by-element basis your factual
`
`and legal bases for opposing each defense or counterclaim, including the
`
`identification of all facts and documents that support or contradict your contention
`
`and all persons with knowledge of the same; and all your factual and legal bases
`
`related to the authenticity and admissibility of such documents. At minimum, your
`
`initial response should describe at least your Rule 11 basis and, after reasonable
`
`discovery, your supplemental response should describe all evidence that you may rely
`
`to oppose, e.g., a no-evidence motion for summary judgment.
`
`RESPONSE: Plaintiff incorporates by reference each of the General Objections and
`
`specifically objects to this Interrogatory as comprising multiple discrete subparts,
`
`which shall count as multiple Interrogatories under Federal Rule of Civil Procedure
`
`33(a)(1). Plaintiff further objects that this Interrogatory is a contention interrogatory
`
`posed early in the litigation. Defendants have not set forth the need for early
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-11-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 5
`
`

`

`
`
`contention interrogatories, or how an earlier response to a contention interrogatory
`
`assists the goals of discovery. Additionally, some of the information required in order
`
`to respond to this contention interrogatory is in the custody of Defendants or third
`
`parties. Further, early contention interrogatories, such as this one, call for attorney-
`
`client privileged and work-product protected materials and information as well as
`
`information that will be the subject of expert testimony and expert reports.
`
`
`
`Subject to and without waiving the foregoing General or Specific Objections,
`
`and subject to Plaintiff’s understanding that this Interrogatory relates to Defendants’
`
`pending counterclaims and affirmative defenses, Plaintiff responds as follows: With
`
`respect to Defendants’ non-infringement and invalidity counterclaims and related
`
`affirmative defenses, Plaintiff incorporates by reference its response to Interrogatory
`
`No. 3 above and also the presumption of validity for each of the patents-in-suit set
`
`forth in 35 U.S.C. § 282. With respect to Defendants’ inequitable conduct and civil
`
`conspiracy counterclaims and related affirmative defenses, Plaintiff incorporates by
`
`reference its briefing in support of its motion to dismiss such claims. With respect to
`
`Defendants’ remaining affirmative defenses, Plaintiff refers Defendant to each of the
`
`foregoing and states that discovery is ongoing. Pursuant to Federal Rule of Civil
`
`Procedure 33(d), Plaintiff has produced and will produce documents that support its
`
`opposition of Defendants’ counterclaims and affirmative defenses.
`
`
`
`Discovery is on-going and Plaintiff acknowledges its duty to supplement its
`
`response to this interrogatory and will do so in accordance with the Court’s scheduling
`
`order and the local rules.
`
`FIRST SUPPLEMENTAL RESPONSE:
`
`
`
`Plaintiff
`
`incorporates by reference the foregoing Response, including
`
`objections, and further responds as follows:
`
`
`
`
`
`Plaintiff’s counsel, Nigel Jones, and George Edwards performed an inspection
`
`of Defendants’ source code on October 9-11, 2018 and November 7, 2018. As a result
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-12-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 6
`
`

`

`
`
`of those inspections, Plaintiff determined that various source code utilized in
`
`Defendants’ products supports infringement of the ‘172, ‘152, ‘747 Patents and
`
`therefore Plaintiff supplemented its claim charts. Plaintiff refers Defendants to the
`
`Exhibits to its Infringement Contentions served on December 5, 2018, which contain
`
`an element-by-element basis supporting Plaintiff’s opposition to Defendants’
`
`counterclaims of non-infringement. The persons knowledgeable about the factual and
`
`legal bases for Plaintiff’s opposition to Defendants’ counterclaims and affirmative
`
`defenses include those identified in response to Interrogatory No. 1. In addition,
`
`Bruce Mindt, an engineer with Colder Products Co. (“Colder”), has knowledge
`
`regarding facts relevant to Plaintiff’s opposition to Defendants’ affirmative defenses
`
`for derivation and lack of standing. With respect to those affirmative defenses
`
`specifically, Plaintiff states that Plaintiff approached Colder in approximately 1996
`
`regarding a specific valve it desired Colder to manufacture for use in Plaintiff’s air
`
`controllers (which Colder had not previously manufactured or sold), that Plaintiff
`
`worked alone and/or in combination with Colder Products on the specifications,
`
`design, and testing of that valve, and that Plaintiff first began selling a product with
`
`that valve when it incorporated it into its ECFS and CFCS air controllers in
`
`approximately September 1997 and into its UFCS3 air controller in approximately
`
`June 1998 (see, e.g., SN_0017437). The documents supporting the factual and legal
`
`bases for Plaintiff’s opposition to Defendants’ counterclaims and affirmative defenses
`
`have been and are being produced in this action, including by Plaintiff, Defendants,
`
`and third parties (including Colder). Plaintiff also intends to rely upon deposition
`
`testimony, including expert testimony. In addition, Plaintiff intends to rely upon
`
`expert reports, but because a different deadline for those disclosures have been
`
`ordered by the Court, a longer period for responding to these requests has been
`
`ordered by the Court. See Fed. R. Civ. P. 33(b)(2)(“A shorter or longer time [for
`
`responding to Interrogatories] may be… ordered by the court.”). Plaintiff will produce
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-13-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 7
`
`

`

`
`
`the information requested in this interrogatory in accordance with the Court’s orders
`
`and the local patent rules and hereby incorporates those future disclosures by
`
`reference.
`
`
`
`Discovery is still on-going and Plaintiff acknowledges its duty to further
`
`supplement its response to this interrogatory and will do so in accordance with the
`
`Court’s scheduling order and the local rules.
`
`
`
`INTERROGATORY NO. 5: Separately for each materially different version of
`
`each air mattress system product that you have sold, offered for sale, or publicly
`
`disclosed since January 1, 1993: identify the product’s product number and name and
`
`describe the product; identify by name and model number any pump or air controller
`
`sold with the product; identify the date of first sale or public disclosure, whichever is
`
`first; identify the supplier of each component comprising the product and describe
`
`each such component; identify (by Bates number) all schematics, drawings, source
`
`code, marketing materials, product manuals, user manuals, assembly instructions, and
`
`the like for each product; and identify the three persons most knowledgeable about
`
`design, development, and first sale or disclosure of the product.
`
`AMENDED RESPONSE: Plaintiff incorporates by reference each of the General
`
`Objections and specifically objects that this Interrogatory seeks information not
`
`relevant to the subject matter of the present case or proportional to the needs of the
`
`case in view of the importance of the issues at stake, the parties’ resources, the
`
`importance of the discovery to resolving the issues, and the burden and expense of
`
`the proposed discovery. Plaintiff further specifically objects that this Interrogatory is
`
`not reasonably limited in time or in scope and is both overly broad and unduly
`
`burdensome given the breadth of information requested for each product.
`
`Subject to and without waiving the foregoing General or Specific Objections,
`
`Plaintiff responds as follows: Since 1993, Plaintiff has sold thousands of air mattress
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-14-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 8
`
`

`

`
`
`
`s/Elizabeth A. Patton
`FOX ROTHSCHILD LLP
`Elizabeth A. Patton (admitted pro hac vice)
`epatton@foxrothschild.com
`222 South Ninth Street, Suite 2000
`Minneapolis, MN 55402
`Telephone: 612-607-7000
`Facsimile: 612-607-7100
`Attorneys for Plaintiff
`SLEEP NUMBER CORPORATION
`
`Dated: December 21, 2018 By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-26-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 9
`
`

`

`
`
`PROOF OF SERVICE
`
`I am employed in the County of Hennepin, State of Minnesota. I am over the
`age of 18 years and not a party to this action; my business address is 222 South
`Ninth Street, Suite 2000 Campbell Mithun Tower, Minneapolis, MN 55402-3338.
`
`On the date specified below, I served PLAINTIFF’S FIRST
`SUPPLEMENTAL RESPONSES TO DEFENDANTS’ FIRST SET OF
`INTERROGATORIES (NOS. 1-9) on the interested party(ies) in this action
`pursuant to an agreement between the parties regarding electronic service by
`emailing true copies thereof to the following:
`
`Thomas J. Daly, Esq.
`Drew Wilson, Esq.
`Lewis Roca Rothgerber Christie LLP
`655 North Central Avenue, Ste. 2300
`Glendale, CA 91203-1445
`tdaly@lrrc.com
`dwilson@lrrc.com
`
`Jaspal S. Hare, Esq.
`Spencer Fane LLP
`5800 Granite Parkway, Suite 800
`Plano, TX 75024
`jhare@spencerfane.com
`
`
`Kyle L. Elliott, Esq.
`Kevin S. Tuttle, Esq.
`Spencer Fane LLP
`1000 Walnut Street, Suite 1400
`Kansas City, MO 64106
`kelliott@spencerfane.com
`ktuttle@spencerfane.com
`
`Alison M. Rowe, Esq.
`Spencer Fane LLP
`2200 Ross Avenue, Suite 4800 West
`Dallas, TX 75201
`arowe@spencerfane.com
`
`(cid:1) [FIRST-CLASS MAIL] I caused said document(s) to be deposited in a
`(cid:1)
`(cid:1)
`
`facility regularly maintained by the United States Postal Service on the
`same day, in a sealed envelope, with postage paid, addressed to the above
`listed person(s) on whom it is being served for collection and mailing on
`that date following ordinary business practices.
`[OVERNIGHT DELIVERY] I caused said document(s) to be deposited in
`a facility regularly maintained by an overnight mail service provider on the
`same day, in a sealed envelope, with fees and postage paid, addressed to
`the above listed person(s) on whom it is being served.
`[HAND-DELIVERY/PERSONAL SERVICE]: I caused said documents(s)
`to be personally delivered by a courier to each addressee.
`[EMAIL] I electronically served the above document(s) from
`dengle@foxrothschild.com to the email address of the addressee(s) listed
`above in accordance with the parties’ agreement to electronic service under
`Federal Rule of Civil Procedure 5(b)(2)(E).
`
`
`
`(cid:1)
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-27-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 10
`
`

`

`
`
`
`I declare under penalty of perjury under the laws of the United States of
`America that the foregoing is true and correct and that I am employed in the
`office of a member of the bar of this Court at whose direction the service was
`made.
`
`DATED: December 21, 2018
`
`
`
`
`
`
`s/Devonia Engle
`Devonia Engle
`
`
`
`
`
`5:18-cv-00356 AB (SPx)
`5:18-cv-00357 AB (SPx)
`
`-28-
`PLAINTIFF’S FIRST SUPPLEMENTAL RESPONSES TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-9)
`
`1 2 3 4 5 6 7 8 9
`1 2 3 4 5 6 7 8 9
`
`10
`10
`
`11
`11
`
`12
`12
`
`13
`13
`
`14
`14
`
`15
`15
`
`16
`16
`
`17
`17
`
`18
`18
`
`19
`19
`
`20
`20
`
`21
`21
`
`22
`22
`
`23
`23
`
`24
`24
`
`25
`25
`
`26
`26
`
`27
`27
`
`28
`28
`
`American National Manufacturing, Inc.
`EXHIBIT 1030
`IPR2019-00500
`Page 11
`
`