throbber
IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-cv-372-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.’S FIRST SET OF REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO DEFENDANT APPLE INC.
`
` Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Fintiv, Inc.
`
`(“Plaintiff” or “Fintiv”) hereby requests that Defendant Apple Inc. (“Defendant” or “Apple”) serve
`
`Fintiv with its written responses to these requests for production and produce copies of the
`
`documents and things requested below, pursuant to the definitions and instructions set forth herein,
`
`at the law offices of Mann Tindel Thompson located at 913 Franklin Ave., Suite 201, Waco, TX
`
`76701. These requests for documents and things are continuing in nature. If, after producing the
`
`requested documents and things, Apple obtains or becomes aware of any further responsive
`
`documents or things, Apple must produce to Fintiv such additional documents and things, as
`
`required by Federal Rule of Civil Procedure 26(e).
`
`The following definitions and instructions shall apply to all requests herein:
`
`IPR2020-00019
`Fintiv EX 2028 Page 1
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-CV-372-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANT APPLE INC.’S FIRST SET OF
`REQUESTS FOR PRODUCTION TO FINTIV, INC. (NOS. 1-28)
`
`Pursuant to Rules 26 and 34 of the Federal Rule of Civil Procedure, and the Local Rules
`
`of this Court, Defendant Apple Inc. (“Defendant” or “Apple”) in the above-captioned action
`
`requests that Plaintiff Fintiv, Inc. (“Plaintiff” or “Fintiv”) produce the documents and things
`
`requested below that are in its possession, custody, or control, in accordance with the Definitions
`
`and Instructions below. Production shall take place within thirty (30) days of service at the
`
`Silicon Valley office of Orrick, Herrington & Sutcliffe LLP, or any other location mutually
`
`agreed by the Parties. These requests are continuing and impose upon Plaintiff the obligations
`
`set forth in Federal Rule of Civil Procedure 26.
`
`The following definitions apply to the instructions and requests set forth below.
`
`DEFINITIONS
`
`1.
`
`2.
`
`The “Asserted Patent” or “The ’125 Patent” means U.S. Patent No. 8,843,125.
`
`The “Asserted Claims” means the claims of the Asserted Patent that Fintiv alleges
`
`have been infringed by Apple, individually and collectively as set forth in Fintiv’s Initial
`
`IPR2020-00019
`Fintiv EX 2028 Page 2
`
`

`

`RESTRICTED N 5HHCFB9KGQ 9K9G CB@K
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-CV-372-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANT APPLE =B7)QS REPONSES AND OBJECTIONS TO
`PLAINTIFF :=BH=J' =B7)QG FIRST SET OF
`REQUESTS FOR PRODUCTION OF DOCUMENTS (NOS. 1-37)
`
`Pursuant to Rules 26 and 34 of the Federal Rule of Civil Procedure, Defendant Apple Inc.
`
`%r;WXW`VS`fs ad r8bb^Ws& hereby objects and responds to Plaintiff Fintiv, Inc.te %rG^S[`f[XXtes ad
`
`r=[`f[htes& first set of requests for production of documents (Nos. 1-37).
`
`PRELIMINARY STATEMENT
`
`Apple has made a reasonable investigation for information responsive to =[`f[hte requests
`
`TSeWV gba` 8bb^Wte UgddW`f ]`ai^WVYW' [`Xad_Sf[a`' S`V TW^[WX) 8bb^Wte [`hWef[YSf[a` [e
`
`a`Ya[`Y) 8bb^Wte dWeba`eWe SdW _SVW i[fZagf bdW\gV[UW fa [fe d[YZf fa dWh[eW' Uadrect,
`
`supplement, or clarify its responses at any time pursuant to Federal Rule of Civil Procedure
`
`26(e). Apple reserves the right to make any use of, or to introduce at any hearing or trial,
`
`information responsive to these requests that was discovered after the date of this response.
`
`By providing responses, Apple does not concede the relevancy of the subject matter of
`
`any request. Apple reserves all objections or other questions as to the competency, relevance,
`
`materiality, privilege, or admissibility in any proceeding or trial for any purpose whatsoever of
`
`IPR2020-00019
`Fintiv EX 2028 Page 3
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-CV-1238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.’S RESPONSES AND OBJECTIONS
`TO DEFENDANT APPLE INC.'S
`FIRST SET OF REQUESTS FOR PRODUCTION TO FINTIV, INC. (NOS. 1-28)
`
`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Fintiv, Inc.
`
`(“Fintiv” or “Plaintiff”) responds to Defendant Apple Inc.’s (“Apple” or “Defendant”) First Set of
`
`Requests for Production (Nos. 1-28) as follows:
`
`GENERAL OBJECTIONS
`
`1.
`
`All General Objections are hereby incorporated into each specific response. Any
`
`objection or lack of objection to any portion of a request is not to be deemed an admission.
`
`2.
`
`Fintiv objects to each and every definition, instruction, and/or request to the extent
`
`that it purports to impose duties or obligations upon Fintiv in excess of or different from the rules
`
`and obligations imposed by the Federal Rules of Civil Procedure, the Local Rules for the Western
`
`District of Texas, and any other rules or applicable law.
`
`3.
`
`Fintiv objects to each and every definition, instruction, and/or request as overly
`
`broad, unreasonably burdensome, and oppressive to the extent that it seeks, individually or
`
`IPR2020-00019
`Fintiv EX 2028 Page 4
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-CV-372-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANT APPLE INC.’S SECOND SET OF
`REQUESTS FOR PRODUCTION TO FINTIV, INC. (NO. 29)
`
`Pursuant to Rules 26 and 34 of the Federal Rule of Civil Procedure, and the Local Rules
`
`of this Court, Defendant Apple Inc. (“Defendant” or “Apple”) in the above-captioned action
`
`requests that Plaintiff Fintiv, Inc. (“Plaintiff” or “Fintiv”) produce the documents and things
`
`requested below that are in its possession, custody, or control, in accordance with the Definitions
`
`and Instructions below. Production shall take place within thirty (30) days of service at the
`
`Silicon Valley office of Orrick, Herrington & Sutcliffe LLP, or any other location mutually
`
`agreed by the Parties. These requests are continuing and impose upon Plaintiff the obligations
`
`set forth in Federal Rule of Civil Procedure 26.
`
`The following definitions apply to the instructions and requests set forth below.
`
`1.
`
`The “Asserted Patent” or “The ’125 Patent” means U.S. Patent No. 8,843,125.
`
`DEFINITIONS
`
`IPR2020-00019
`Fintiv EX 2028 Page 5
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-CV-01238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.’S RESPONSES AND OBJECTIONS
`TO DEFENDANT APPLE INC.'S
`SECOND SET OF REQUESTS FOR PRODUCTION TO FINTIV, INC. (NO. 29)
`
`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Fintiv, Inc.
`
`(“Fintiv” or “Plaintiff”) responds to Defendant Apple Inc.’s (“Apple” or “Defendant”) Second Set
`
`of Requests for Production (No. 29) as follows:
`
`GENERAL OBJECTIONS
`
`1.
`
`All General Objections are hereby incorporated into each specific response. Any
`
`objection or lack of objection to any portion of a request is not to be deemed an admission.
`
`2.
`
`Fintiv objects to each and every definition, instruction, and/or request to the extent
`
`that it purports to impose duties or obligations upon Fintiv in excess of or different from the rules
`
`and obligations imposed by the Federal Rules of Civil Procedure, the Local Rules for the Western
`
`District of Texas, and any other rules or applicable law.
`
`3.
`
`Fintiv objects to each and every definition, instruction, and/or request as overly
`
`broad, unreasonably burdensome, and oppressive to the extent that it seeks, individually or
`
`collectively, information that is not relevant to any claim or defense of the case and therefore not
`
`IPR2020-00019
`Fintiv EX 2028 Page 6
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-cv-01238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, :?5'\D SECOND SET OF REQUESTS FOR
`PRODUCTION OF DOCUMENTS TO DEFENDANT APPLE INC.
`
`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Fintiv, Inc.
`
`%lG[PX]cXUUm ^a l=X]cXem& WTaTQh aT`dTbcb cWPc ;TUT]SP]c 8__[T @]R) %l;TUT]SP]cm ^a l8__[Tm& bTaeT
`
`Fintiv with its written responses to these requests for production and produce copies of the
`
`documents and things requested below, pursuant to the definitions and instructions set forth herein,
`
`at the law offices of Mann Tindel Thompson located at 913 Franklin Ave., Suite 201, Waco, TX
`
`76701. These requests for documents and things are continuing in nature. If, after producing the
`
`requested documents and things, Apple obtains or becomes aware of any further responsive
`
`documents or things, Apple must produce to Fintiv such additional documents and things, as
`
`required by Federal Rule of Civil Procedure 26(e).
`
`The following definitions and instructions shall apply to all requests herein:
`
`DEFINITIONS
`
`1.
`
`l8__[T'm l;TUT]SP]c'm lO^dm ^a lO^dam \TP]b P]S X]R[dSTb ;TUT]SP]c 8__[T @]R)'
`
`and all subsidiaries and affiliates thereof, all affiliates, related entities, parents, branches,
`
`IPR2020-00019
`Fintiv EX 2028 Page 7
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-cv-372-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.’S FIRST SET OF INTERROGATORIES TO
`DEFENDANT APPLE INC.
`
`PLEASE TAKE NOTICE that, Rules 26 and 33 of the Federal Rules of Civil Procedure,
`
`and the Local Rules of this Court, Plaintiff Fintiv, Inc. (“Plaintiff” or “Fintiv”), hereby requests
`
`that Defendant Apple Inc. (“Defendant” or “Apple”) answer the following interrogatories in
`
`accordance with the Definitions and Instructions set forth below, in writing and under oath within
`
`thirty (30) days of service hereof. These interrogatories are continuing in character so as to require
`
`Apple to serve supplemental responses whenever it obtains different or additional information
`
`relating to these interrogatories, as required by Federal Rule of Civil Procedure 226(e).
`
`The following definitions and instructions shall apply to all requests herein.
`
`DEFINITIONS
`
`1.
`
`“Apple,” “Defendant,” “You” or “Your” means and includes Defendant Apple Inc.,
`
`and all subsidiaries and affiliates thereof, all affiliates, related entities, parents, branches,
`
`subsidiaries, divisions, predecessors, successors, and assigns, and all present and past officers,
`
`directors, employees, agents, consultants, attorneys, accountants, administrators, representatives,
`
`IPR2020-00019
`Fintiv EX 2028 Page 8
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-CV-372-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANT APPLE INC.’S FIRST SET OF
`INTERROGATORIES TO FINTIV, INC. (NOS. 1-16)
`
`Pursuant to Rules 26 and 33 of the Federal Rule of Civil Procedure, and the Local Rules
`
`of this Court, Defendant Apple Inc. (“Defendant” or “Apple”) in the above-captioned action
`
`requests that Plaintiff Fintiv, Inc. (“Plaintiff” or “Fintiv”) answer fully in writing and under oath
`
`the following interrogatories within 30 days from the date of service hereof.
`
`The following definitions apply to the instructions and interrogatories set forth below.
`
`DEFINITIONS
`
`1.
`
`2.
`
`The “Asserted Patent” or “The ’125 Patent” means U.S. Patent No. 8,843,125.
`
`The “Asserted Claims” means the claims of the Asserted Patent that Fintiv alleges
`
`have been infringed by Apple, individually and collectively as set forth in Fintiv’s Initial
`
`Disclosure of Asserted Claims, Accused Instrumentalities, and Infringement Contentions served
`
`on May 20, 2019.
`
`3.
`
`“Related Application Or Patent” means:
`
`IPR2020-00019
`Fintiv EX 2028 Page 9
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 6:18-CV-372-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANT APPLE INC.’S SECOND SET OF
`INTERROGATORIES TO FINTIV, INC. (NO. 17)
`
`Pursuant to Rules 26 and 33 of the Federal Rule of Civil Procedure, and the Local Rules
`
`of this Court, Defendant Apple Inc. (“Defendant” or “Apple”) in the above-captioned action
`
`requests that Plaintiff Fintiv, Inc. (“Plaintiff” or “Fintiv”) answer fully in writing and under oath
`
`the following interrogatories within 30 days from the date of service hereof.
`
`The following definitions apply to the instructions and interrogatories set forth below.
`
`DEFINITIONS
`
`1.
`
`2.
`
`The “Asserted Patent” or “The ’125 Patent” means U.S. Patent No. 8,843,125.
`
`The “Asserted Claims” means the claims of the Asserted Patent that Fintiv alleges
`
`have been infringed by Apple, individually and collectively as set forth in Fintiv’s Final
`
`Infringement Contentions served on January 17, 2020.
`
`3.
`
`“Related Application Or Patent” means:
`
`IPR2020-00019
`Fintiv EX 2028 Page 10
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-01238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.’S FIRST AMENDED AND SUPPLEMENTAL RESPONSES
`AND OBJECTIONS TO DEFENDANT APPLE INC.’S
`FIRST SET OF INTERROGATORIES TO FINTIV, INC. (NOS. 1, 3, 4, 5, 6, 8, 9, 11, 12,
`14 & 16)
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff, Fintiv, Inc.
`
`(“Fintiv” or “Plaintiff”) hereby provides its First Amended and Supplemental Responses to
`
`Defendant Apple Inc.’s (“Apple” or “Defendant”) First Set of Interrogatories to Fintiv (Nos. 1, 3,
`
`4, 5, 6, 8, 9, 11, 12, 14 & 16):
`
`GENERAL OBJECTIONS
`
`1.
`
`All General Objections are hereby incorporated into each specific response. Any
`
`objection or lack of objection to any portion of an interrogatory is not to be deemed an admission.
`
`2.
`
`Fintiv objects to each and every definition, instruction, and/or interrogatory to the
`
`extent that it purports to impose duties or obligations upon Fintiv in excess of or different from the
`
`rules and obligations imposed by the Federal Rules of Civil Procedure, the Local Rules for the
`
`Western District of Texas, and any other rules or applicable law.
`
`3.
`
`Fintiv objects to each and every definition, instruction, and/or interrogatory as
`
`IPR2020-00019
`Fintiv EX 2028 Page 11
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-cv-01238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, INC.\D SECOND SET OF INTERROGATORIES TO
`DEFENDANT APPLE INC.
`
`PLEASE TAKE NOTICE that, Rules 26 and 33 of the Federal Rules of Civil Procedure,
`
`and the Local Rules of this Court, Plaintiff Fintiv, Inc. (kG[PX]cXUUl ^a k=X]cXel), hereby requests
`
`that Defendant App[T @]R) %k;TUT]SP]cl ^a k8__[Tl& answer the following interrogatories in
`
`accordance with the Definitions and Instructions set forth below, in writing and under oath within
`
`thirty (30) days of service hereof. These interrogatories are continuing in character so as to require
`
`Apple to serve supplemental responses whenever it obtains different or additional information
`
`relating to these interrogatories, as required by Federal Rule of Civil Procedure 226(e).
`
`The following definitions and instructions shall apply to all requests herein.
`
`DEFINITIONS
`
`1.
`
`kApple'l k;TUT]SP]c'l kO^dl ^a kO^dal \TP]b P]S X]R[dSTb Defendant Apple Inc.,
`
`and all subsidiaries and affiliates thereof, all affiliates, related entities, parents, branches,
`
`subsidiaries, divisions, predecessors, successors, and assigns, and all present and past officers,
`
`directors, employees, agents, consultants, attorneys, accountants, administrators, representatives,
`
`IPR2020-00019
`Fintiv EX 2028 Page 12
`
`

`

`CONFIDENTIAL \ 3EE@C?7JD] 7J7D @?=J
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FINTIV, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`










`
`Civil Action No.: 1:19-cv-01238-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FINTIV, IN5']D FIRST SET OF REQUESTS FOR ADMISSION TO
`DEFENDANT APPLE INC.
`
`Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Plaintiff Fintiv, Inc.
`
`%lG\QY^dYVVm _b l=Y^dYfm& XUbURi bUaeUcdc dXQd ;UVU^TQ^d 8``\U @^S) %l;UVU^TQ^dm _b l8``\Um&
`
`respond to the following First Set of Requests for Admission separately and fully, in writing, under
`
`oath and within thirty (30) days of service of this request. These requests are continuing in
`
`character so as to require Apple to serve supplemental responses whenever it obtains different or
`
`additional information relating to these requests, as required by Federal Rule of Civil Procedure
`
`26(e).
`
`DEFINITIONS
`
`<QSX bUaeUcd Y^ G\QY^dYVVnc =Ybcd HUaeUcd V_b 8T]YccY_^c Yc ceRZUSd d_ Q^T Y^S_b`_bQdUc dXU
`
`following definitions:
`
`1.
`
`l8``\U'm l;UVU^TQ^d'm lO_em _b lO_ebm ]UQ^c Q^T Y^S\eTUc ;efendant Apple Inc.,
`
`and all subsidiaries and affiliates thereof, all affiliates, related entities, parents, branches,
`
`subsidiaries, divisions, predecessors, successors, and assigns, and all present and past officers,
`
`IPR2020-00019
`Fintiv EX 2028 Page 13
`
`

`

`
`
`Confidential - Attorneys' Eyes Only / Confidential - Outside Attorneys' Eyes Only - Source CodeConfidential - Attorneys' Eyes Only / Confidential - Outside Attorneys' Eyes Only - Source Code
`
`Page 1
`
`·1· · · · · ·IN THE UNITED STATES DISTRICT COURT
`·2· · · · · · FOR THE WESTERN DISTRICT OF TEXAS
`·3· · · · · · · · · · ·AUSTIN DIVISION
`·4
`·5· · FINTIV, INC.,
`·6· · · · · · ·Plaintiff,
`·7· · vs.· · · · · · · · · · · · · · · · Civil Action No.
`·8· · · · · · · · · · · · · · · · · · · 1:19-cv-01238-ADA
`·9· · APPLE INC.,
`10· · · · · · ·Defendant.
`· · ·__________________________________
`11
`12
`13· · · · · · · · VIDEOTAPED DEPOSITION OF
`14· · · · · · ·ONUR TACKIN, 30(B)(6), 30(B)(1)
`15· · · · · · · · · Menlo Park, California
`16· · · · · · · · Friday, February 14, 2020
`17· · · · · * CONFIDENTIAL ATTORNEYS' EYES ONLY *
`18· · ·* CONFIDENTIAL - OUTSIDE ATTORNEYS EYES ONLY -
`19· · · · · · · · · · · SOURCE CODE *
`20
`21
`22
`23· ·REPORTED BY:
`24· ·TAVIA MANNING, CSR No. 13294, CLR, CCRR, RPR
`25· ·JOB NO. 176648
`
`
`
`TSG Reporting - Worldwide· · 877-702-9580TSG Reporting - Worldwide· · 877-702-9580
`
`IPR2020-00019
`Fintiv EX 2028 Page 14
`
`

`

`HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
`
`Page 1
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE WESTERN DISTRICT OF TEXAS
` AUSTIN DIVISION
` ---oOo---
`
`FINTIV, INC.,
` Plaintiff,
`vs. No. 1:19-cv-01238-ADA
`APPLE INC.,
` Defendant.
`_________________________/
`
` HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
` VIDEOTAPED DEPOSITION OF MARSHAL ALLSHOUSE
` MENLO PARK, CALIFORNIA
` TUESDAY, FEBRUARY 25, 2020
`
`Stenographically Reported by:
`ANDREA M. IGNACIO, CSR, RPR, CRR, CCRR, CLR
`California CSR No. 9830
`Job No. 176650
`
`TSG Reporting - Worldwide (877) 702-9580
`
`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
`
`IPR2020-00019
`Fintiv EX 2028 Page 15
`
`

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