AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
`
`UNITED STATES DISTRICT COURT
`for the
`
`Civil Action No.
`
`6:20-cv-00142-ADA
`
`Western Districtof Texas
`Waco Dvision
`
`UNM RAINFOREST INNOVATIONS
`)
`Plaintiff
`)
`V.
`)
`)
`)
`)
`
`
`ASUSTEK COMPUTERINC.
`Defendant
`
`(If the action is pending in another district, state where:
`)
`
`SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
`OR TO PERMIT INSPECTION OF PREMISESIN A CIVIL ACTION
`
`To: QUALCOMM INCORPORATED, 9600 N. Mopac Expwy., Suite 900, Austin, TX 78759
`c/o Prentice Hall Corp System, 211 E. 7th Street, Suite 620, Austin, TX 78701-3218
`ovProduction: YOU ARE COMMANDEDtoproduceat the time, date, and place set forth below the following
`documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
`material: See attached Exhibit A
`
`
`Place: walt Fair, PLLC, 1508 North Valley Mills Drive, Waco,_|Date and Time:
`
`TX 76710-4457 or via FTP, DropBox, ShareFile, or
`02/16/2021 9:00 am
` other electronic format
`
`0 Inspection ofPremises: YOU ARE COMMANDEDto permit entry onto the designated premises, land, or
`other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
`may inspect, measure, survey, photograph,test, or sample the property or any designated object or operation onit.
`
`The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
`45 (d) and(e), relating to your duty to respond to this subpoena andthe potential consequencesof not doing so, are
`attached.
`
`Date:
`
`01/26/2021
`
`CLERK OF COURT
`
`OR
`
`Signature ofClerk or Deputy Clerk
`
`William D. Ellerman
`
`Attorney’s signature
`
`The name, address, e-mail, and telephone number ofthe attorney representing (nameofparty) UNM Rainforest Innovations
`. who issuesor requests this subpoena,are:
`William D. Ellerman, SHORE CHAN LLP, 901 Main Street, Suite 3300, Dallas, TX 75202
`(214) 593-9121 wellerman@shorechan.com
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)
`
`Civil Action No.
`
`6:20-cv-00142-ADA
`
`PROOF OF SERVICE
`(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
`
`This subpoena for (name of individual and title, if any)
`was received by me on (date)
`.
`
`(cid:117) I served the subpoena by delivering a copy to the named person as follows:
`
`(cid:117) I returned the subpoena unexecuted because:
`
`on (date)
`
`; or
`
`Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
`tendered to the witness fees for one day’s attendance, and the mileage allowed by law, in the amount of
`$
`.
`
`My fees are $
`
`for travel and $
`
`for services, for a total of $
`
`0.00
`
`.
`
`.
`
`I declare under penalty of perjury that this information is true.
`
`Date:
`
`Additional information regarding attempted service, etc:
`
`Server’s signature
`
`Printed name and title
`
`Server’s address
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)
`
`Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)
`(c) Protecting a Person Subject to a Subpoena.
`(d) Duties in Responding to a Subpoena.
` (1) Avoiding Undue Burden or Expense; Sanctions. A party or
` (1) Producing Documents or Electronically Stored Information.
`These procedures apply to producing documents or electronically
`attorney responsible for issuing and serving a subpoena must take
`stored information:
`reasonable steps to avoid imposing undue burden or expense on a
` (A) Documents. A person responding to a subpoena to produce
`person subject to the subpoena. The issuing court must enforce this
`duty and impose an appropriate sanction — which may include lost
`documents must produce them as they are kept in the ordinary
`earnings and reasonable attorney’s fees — on a party or attorney
`course of business or must organize and label them to correspond to
`who fails to comply.
`the categories in the demand.
` (2) Command to Produce Materials or Permit Inspection.
` (B) Form for Producing Electronically Stored Information Not
` (A) Appearance Not Required. A person commanded to produce
`Specified. If a subpoena does not specify a form for producing
`documents, electronically stored information, or tangible things, or
`electronically stored information, the person responding must
`to permit the inspection of premises, need not appear in person at the
`produce it in a form or forms in which it is ordinarily maintained or
`place of production or inspection unless also commanded to appear
`in a reasonably usable form or forms.
` (C) Electronically Stored Information Produced in Only One
`for a deposition, hearing, or trial.
` (B) Objections. A person commanded to produce documents or
`Form. The person responding need not produce the same
`tangible things or to permit inspection may serve on the party or
`electronically stored information in more than one form.
`(D) Inaccessible Electronically Stored Information. The person
`attorney designated in the subpoena a written objection to
`inspecting, copying, testing or sampling any or all of the materials or
`responding need not provide discovery of electronically stored
`to inspecting the premises — or to producing electronically stored
`information from sources that the person identifies as not reasonably
`information in the form or forms requested. The objection must be
`accessible because of undue burden or cost. On motion to compel
`served before the earlier of the time specified for compliance or 14
`discovery or for a protective order, the person responding must show
`days after the subpoena is served. If an objection is made, the
`that the information is not reasonably accessible because of undue
`following rules apply:
`burden or cost. If that showing is made, the court may nonetheless
` (i) At any time, on notice to the commanded person, the serving
`order discovery from such sources if the requesting party shows
`good cause, considering the limitations of Rule 26(b)(2)(C). The
`party may move the issuing court for an order compelling production
`court may specify conditions for the discovery.
`or inspection.
` (2) Claiming Privilege or Protection.
` (ii) These acts may be required only as directed in the order, and
` (A) Information Withheld. A person withholding subpoenaed
`the order must protect a person who is neither a party nor a party’s
`officer from significant expense resulting from compliance.
`information under a claim that it is privileged or subject to
` (3) Quashing or Modifying a Subpoena.
`protection as trial-preparation material must:
` (i) expressly make the claim; and
` (A) When Required. On timely motion, the issuing court must
` (ii) describe the nature of the withheld documents,
`quash or modify a subpoena that:
` (i) fails to allow a reasonable time to comply;
`communications, or tangible things in a manner that, without
` (ii) requires a person who is neither a party nor a party’s officer
`revealing information itself privileged or protected, will enable the
`parties to assess the claim.
`to travel more than 100 miles from where that person resides, is
`(B) Information Produced. If information produced in response to a
`employed, or regularly transacts business in person — except that,
`subpoena is subject to a claim of privilege or of protection as trial-
`subject to Rule 45(c)(3)(B)(iii), the person may be commanded to
`preparation material, the person making the claim may notify any
`attend a trial by traveling from any such place within the state where
`party that received the information of the claim and the basis for it.
`the trial is held;
` (iii) requires disclosure of privileged or other protected matter, if
`After being notified, a party must promptly return, sequester, or
`destroy the specified information and any copies it has; must not use
`no exception or waiver applies; or
`or disclose the information until the claim is resolved; must take
` (iv) subjects a person to undue burden.
`reasonable steps to retrieve the information if the party disclosed it
` (B) When Permitted. To protect a person subject to or affected by
`before being notified; and may promptly present the information to
`a subpoena, the issuing court may, on motion, quash or modify the
`the court under seal for a determination of the claim. The person
`subpoena if it requires:
`who produced the information must preserve the information until
` (i) disclosing a trade secret or other confidential research,
`the claim is resolved.
`development, or commercial information;
` (ii) disclosing an unretained expert’s opinion or information that
`does not describe specific occurrences in dispute and results from
`the expert’s study that was not requested by a party; or
` (iii) a person who is neither a party nor a party’s officer to incur
`substantial expense to travel more than 100 miles to attend trial.
` (C) Specifying Conditions as an Alternative. In the circumstances
`described in Rule 45(c)(3)(B), the court may, instead of quashing or
`modifying a subpoena, order appearance or production under
`specified conditions if the serving party:
` (i) shows a substantial need for the testimony or material that
`cannot be otherwise met without undue hardship; and
` (ii) ensures that the subpoenaed person will be reasonably
`compensated.
`
`(e) Contempt. The issuing court may hold in contempt a person
`who, having been served, fails without adequate excuse to obey the
`subpoena. A nonparty’s failure to obey must be excused if the
`subpoena purports to require the nonparty to attend or produce at a
`place outside the limits of Rule 45(c)(3)(A)(ii).
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`EXHIBIT A
`
`I.
`
`DEFINITIONS
`
`1.
`
`The terms “Qualcomm,” “You,” and “Your” means QUALCOMM Incorporated,
`
`and/or all of its predecessors and successors (merged, acquired, or otherwise), partners, investors,
`
`corporate parents, affiliated companies or corporations, divisions, departments, direct or indirect
`
`subsidiaries, officers, directors, employees, principals, shareholders, agents, attorneys, servants,
`
`representatives, and all other persons acting, or purporting to act, on Your behalf whether directly
`
`or indirectly, including internal and outside counsel.
`
`2.
`
`The term “Asus” means AsusTeK Computer Inc. and/or any of its predecessors and
`
`successors (merged, acquired, or otherwise), partners, investors, corporate parents, affiliated
`
`companies or corporations, divisions, departments, direct or indirect subsidiaries, officers,
`
`directors, employees, principals, shareholders, agents, attorneys, servants, representatives, and all
`
`other persons acting, or purporting to act, on Asus’s behalf whether directly or indirectly, including
`
`internal and outside counsel.
`
`3.
`
`The term “Wi-Fi Alliance” means The Wi-Fi Alliance and/or all of its predecessors
`
`and successors (merged, acquired, or otherwise), partners, investors, corporate parents, affiliated
`
`companies or corporations, divisions, departments, direct or indirect subsidiaries, officers,
`
`directors, employees, principals, shareholders, members, agents, attorneys, servants,
`
`representatives, individual and corporate sponsors, contractors, and all other persons acting, or
`
`purporting to act, on its behalf whether directly or indirectly, including internal and outside
`
`counsel.
`
`4.
`
`The term “IEEE” means The Institute of Electrical and Electronics Engineers,
`
`Incorporated and/or all of its predecessors and successors (merged, acquired, or otherwise),
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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`

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`partners, investors, corporate parents, affiliated companies or corporations, divisions, departments,
`
`direct or indirect subsidiaries, officers, directors, employees, principals, shareholders, agents,
`
`attorneys, its servants, representatives, and all other persons acting, or purporting to act, on its
`
`behalf whether directly or indirectly, including internal and outside counsel.
`
`5.
`
`The term “UNM” means Plaintiff UNM Rainforest Innovations and/or all of its
`
`predecessors and successors (merged, acquired, or otherwise), partners, investors, corporate
`
`parents, affiliated companies or corporations, divisions, departments, direct or indirect
`
`subsidiaries, officers, directors, employees, principals, agents, attorneys, servants, representatives,
`
`and all other persons acting, or purporting to act, on its behalf whether directly or indirectly,
`
`including internal and outside counsel.
`
`6.
`
`The term “Document” is defined to be the broadest extent possible permitted by
`
`FED. R. CIV. P. 34(a) and applicable case law, and is construed to mean, without limitation, any
`
`written, printed, typed, stored, photographed, recorded or otherwise reproduced communication,
`
`compilation, or reproduction including computer or electronically generated or stored information
`
`or data, whether allegedly privileged or not. “Document” specifically includes correspondence,
`
`including, but not limited to, emails and letters. “Document” further specifically includes, without
`
`limitation, any computer disk, diskette, tape, card, or any other form of computer data storage,
`
`electronic data, or electronically stored information, existing or deleted files, metadata, data
`
`collected and stored through use of the Internet, including “bookmarks” and browser history
`
`identifying Web sites visited, voice-mail messages and identifying information (including
`
`information stored on cell phones and hand-held communication devices), digital photographs,
`
`charts, and graphs stored electronically, writings, drawings, graphs, chart photographs, sound
`
`recordings, images, and all other data or data compilations stored in any medium from which
`
`Ex. 2012 - IPR2021-00375
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`information can be obtained, however produced or reproduced, of any kind of description, whether
`
`sent or received, including original copies, non-identical copies, drafts and both sides thereof,
`
`regardless of their author of origin, or however denominated by the recipient of the Request.
`
`“Document” further specifically includes source code, which means, without limitation,
`
`documents containing or constituting human-readable programming language text that defines
`
`software, firmware, or electronic hardware descriptions. In all instances in which a document, or
`
`series of documents, has been prepared on a periodic basis (such as monthly, quarterly,
`
`semiannually, annually, etc.), the document reflecting each such period is requested.
`
`7.
`
`The term “Lawsuit” means the case styled as UNM Rainforest Innovations v.
`
`AsusTeK Computer Inc., No. 6:20-CV-00142-ADA, which is currently pending in the Waco
`
`Division of the United States District Court for the Western District of Texas.
`
`8.
`
`The term “Patents-in-Suit” means United States Patent Nos. 8,249,204, 8,265,096,
`
`and 8,565,326
`
`9.
`
`The term “Accused Qualcomm Products” means the following Asus products
`
`containing Qualcomm components: AC1750: RP-AC66; Lyra AC2200; Lyra Trio AC1750; ROG
`
`Strix Hero Edition; VivoBook 17; VivoBook S13; VivoBook S17; ZenBook 13; ZenBook 15;
`
`Prime X299-Delux; ROG Rampage VI Extreme; ROG Strix X299-E; ROG Phone; ROG Phone
`
`II; ROG Phone 3; ZenFone 3; ZenFone 3 Laser; ZenFone 4; ZenFone 5; ZenFone 6.
`
`10.
`
`The term “Wi-Fi Chips” means any semiconductor chips or other electronic
`
`components supplied to Asus for use in any Accused Qualcomm Product(s) and which facilitate
`
`wireless networking (“Wi-Fi”) functionality in those products. The term “Wi-Fi Chips” includes,
`
`but is not limited to, the following chips manufactured by Qualcomm, including any other model
`
`numbers by which they are referred to or known:
`
`Ex. 2012 - IPR2021-00375
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`.
`
`11.
`
`The term “802.11ac” means the IEEE 802.11ac-2013 wireless networking standard,
`
`which is sometimes referred to as “Wi-Fi 5,” and any drafts or amendments thereto.
`
`12.
`
`The term “802.11ax” means the IEEE 802.11ax wireless networking standard,
`
`which is sometimes also referred to as “Wi-Fi 6,” and any drafts or amendments thereto.
`
`13.
`
`The term “Prior Art” means any evidence qualifying as prior art to the Asserted
`
`Patents under 35 U.S.C. § 102 and/or 35 U.S.C. § 103.
`
`14.
`
`The term “Related to” or “Relating to” means, in whole or in part, directly or
`
`indirectly, relating to, referring to, describing, depicting, evidencing, concerning, connected with,
`
`commenting on, responding to, showing, supporting, analyzing, reflecting, or constituting. Use of
`
`this term includes any and all information whether past, present, or relating to the future.
`
`15.
`
`The terms “All” and “Each” are construed to include one another wherever such
`
`dual construction will serve to bring within the scope of the inquiry information, which otherwise
`
`may not fall within its scope.
`
`16.
`
`The connective terms “And” as well as “Or” are to be construed disjunctively as
`
`well as conjunctively as necessary in order to bring within the scope of the following requests all
`
`information which might otherwise be construed to be outside their scope.
`
`17.
`
`The singular includes the plural and the plural includes the singular so as to be all-
`
`inclusive.
`
`II.
`
`INSTRUCTIONS
`
`18.
`
`The Documents requested herein are to be produced at the location described in the
`
`subpoena or via a secure FTP site, Dropbox, Citrix Sharefile, or similar medium. In the alternative,
`
`Ex. 2012 - IPR2021-00375
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`

`the requested materials may be produced at the law offices of Walt Fair, PLLC, 1508 North Valley
`
`Mills Drive, Waco, Texas 76710-4457.
`
`19.
`
`UNM’s counsel seeks to minimize any burden on You. If You have any questions
`
`or concerns regarding these requests, you are encouraged to contact the following counsel: William
`
`Ellerman, wellerman@shorechan.com, (214) 593-9121.
`
`20.
`
`Each Request shall operate and be responded to independently and, unless
`
`otherwise indicated, no Request limits the scope of any other Request.
`
`21.
`
`If any of the materials requested herein are no longer in your possession, custody,
`
`or control, please identify each such requested document by date, type of document, person(s)
`
`from whom sent, person(s) to whom sent, person(s) receiving copies, and provide a summary of
`
`the pertinent contents.
`
`If any material responsive to these requests has been destroyed, please describe
`22.
`the content of such document, the location of any copies of such document, the date of such
`destruction, the name of the person who ordered or authorized such destruction, and the reason
`for such destruction.
`If any material responsive to these requests is objected to on the grounds of
`23.
`confidentiality to a third party, please provide a brief description of the document and the date
`appearing on that document, and identify the person(s) to whom the duty of confidentiality is
`owed.
`
`If You object to a Request or any portion of any Request on the ground that it
`24.
`calls for information protected by privilege or work product, produce all responsive, non-
`privileged documents and things for the remainder of the Request, and then provide for each
`such Request the following information relating to the withheld document or thing: (1) the date
`of creation; (2) author(s); (3) recipient(s); (4) a description that, without revealing information
`itself privileged or protected, will enable other parties to assess the claim, and will provide a
`
`Ex. 2012 - IPR2021-00375
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`brief general description of the document along with the basis for the privilege assertion; and (5)
`the basis on which the discovery is withheld (e.g. attorney-client privilege, work-product
`doctrine, or both).
`You are required to supplement your responses to these Requests under Federal
`25.
`Rule of Civil Procedure 26(e) as new information becomes available.
`
`III. DOCUMENTS TO BE PRODUCED
`
`1. Any and all documents relating to the Wi-Fi Chips, including but not limited to their
`
`technical specifications, their design into any Accused Qualcomm Products, and their usage in
`
`any Accused Qualcomm Products.
`
`2. Any and all documents relating to sales of the Wi-Fi Chips to Asus, including but not
`
`limited to financial summaries, sales reports, receipts, invoices, and purchase or sales contracts.
`
`3. Any and all documents showing the annual sales volume, in terms of units and gross sales
`
`of Wi-Fi Chips to Asus since January 1, 2018.
`
`4. All Documents sufficient to identify Your Enterprise Resource Planning (“ERP”) or
`
`Centralized Integrated Enterprise System (“CIES”) data management and retrieval systems (e.g.
`
`SAP), including Documents identifying any modules related to inventory management, sales and
`
`marketing, purchasing, finance and accounting, customer relationship management (“CRM”),
`
`engineering and production and supply chain management (“SCM”).
`
`5. Any and all documents relating to correspondence between engineers at Asus and
`
`Qualcomm relating to the Wi-Fi functionality of the Accused Qualcomm Products and/or the
`
`design and implementation of the Wi-Fi Chips into the Accused Qualcomm Products.
`
`6. Any and all documents relating to the specific model numbers of the Wi-Fi Chips, any
`
`explanations for the numbering conventions used in those model numbers, and/or any variations
`
`Ex. 2012 - IPR2021-00375
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`or alternative model numbers by which the Wi-Fi Chips are known (for instance, different
`
`internal designations given to the Wi-Fi Chips by Qualcomm, Asus, or any other OEM).
`
`7. Any and all documents relating to the identities of Qualcomm’s sales, marketing, or
`
`engineering personnel responsible for naming and cataloguing the Wi-Fi Chips.
`
`8. Any and all documents relating to the identities of Qualcomm’s personnel responsible for
`
`Qualcomm’s business relationship with Asus, including but not limited to that relationship as it
`
`pertains to the Wi-Fi Chips.
`
`9. Any and all documents relating to the involvement of any Qualcomm personnel in IEEE
`
`standard-setting, particularly with respect to 802.11ac and/or 802.11ax.
`
`10. Any and all documents relating to any communications between or among Qualcomm
`
`and IEEE and/or Wi-Fi Alliance regarding the functionality of the Wi-Fi Chips and/or their
`
`compliance with 802.11ac.
`
`11. Any and all documents relating to any internal communications within Qualcomm
`
`regarding the Wi-Fi Chips’ compliance with 802.11ac.
`
`12. Any and all documents relating to any communications between or among Qualcomm
`
`and IEEE and/or Wi-Fi Alliance regarding the functionality of the Wi-Fi Chips and/or their
`
`compliance with 802.11ax.
`
`13. Any and all documents relating to any internal communications within Qualcomm
`
`regarding the Wi-Fi Chips’ compliance with 802.11ax.
`
`14. Any and all documents relating to communications between or among Qualcomm and
`
`IEEE and/or Wi-Fi Alliance regarding the backward compatibility of 802.11ax with 802.11ac
`
`and/or any prior 802.11 series standards.
`
`Ex. 2012 - IPR2021-00375
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`15. Any and all documents relating to the benefits or advantages of 802.11ac over prior
`
`wireless networking standards.
`
`16. Any and all documents relating to the benefits or advantages of 802.11ax over prior
`
`wireless networking standards.
`
`17. Any and all documents relating to the differences between 802.11ac and 802.11ax.
`
`18. Any and all documents relating to the identities of any Qualcomm personnel who are
`
`involved in standard compliance, particularly with respect to 802.11ac and/or 802.11ax.
`
`19. Any and all documents relating to the processes, procedures, testing, certification, and/or
`
`methods of ensuring that the Wi-Fi Chips comply with 802.11ac.
`
`20. Any and all documents relating to the processes, procedures, testing, certification, and/or
`
`methods of ensuring that the Wi-Fi Chips comply with 802.11ax.
`
`21. Any and all documents related to comparisons of the Wi-Fi Chips’ designs to 802.11ac
`
`and/or 802.11ax.
`
`22. Any and all documents related to comparisons of the Wi-Fi Chips’ designs to the aspects
`
`that are necessary to comply with the Wi-Fi Alliance’s “Wi-Fi CERTIFIED™ AC,” or “Wi-Fi
`
`CERTIFIED™ 6” requirements.
`
`23. Any and all documents submitted to certification entities such as Wi-Fi Alliance
`
`pertaining to the Wi-Fi Chips.
`
`24. Any and all documents relating to certifications received from Wi-Fi Alliance or other
`
`certification entities pertaining to the Wi-Fi Chips, or any other responses received from such
`
`entities regarding the Wi-Fi Chips.
`
`25. Any and all documents relating to “Wi-Fi CERTIFIED™ Interoperability Certificates”
`
`for the Wi-Fi Chips.
`
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`26. Any and all documents relating to “Wi-Fi CERTIFIED™ ac” certificates for the Wi-Fi
`
`Chips.
`
`27. Any and all documents relating to “Wi-Fi CERTIFIED 6™” certificates for the Wi-Fi
`
`Chips.
`
`28. Any and all documents relating to Your status as a member of the Wi-Fi Alliance.
`
`29. Any and all documents relating to Your status as a “Sponsor Member” of the Wi-Fi
`
`Alliance.
`
`30. Any and all documents relating to monetary payments, contributions, or funding made or
`
`provided by You to the Wi-Fi Alliance within the last five (5) years.
`
`31. Any and all documents relating to the identities of any independent testing laboratories
`
`utilized by You to test and/or ensure that the Wi-Fi Chips are compliant with 802.11ac and/or
`
`802.11ax.
`
`32. Any and all documents relating to diagrams, drawings, schematics, layouts, architecture,
`
`or similar documents for the Wi-Fi Chips. Your response should include any and all associated
`
`information needed to interpret and identify structures featured on the documents produced.
`
`33. Any and all documents relating to manuals, white papers, datasheets, or other
`
`documentation that explains the functionality of the Wi-Fi Chips.
`
`34. Any and all documents relating to the methods by which the Wi-Fi Chips perform
`
`beamforming and sending channel feedback.
`
`35. Any and all documents relating to the methods by which the Wi-Fi Chips prepare
`
`feedback data from a received signal.
`
`36. Any and all documents relating to the frame structures formed and/or transmitted by the
`
`Wi-Fi Chips.
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`37. Any and all documents relating to the elements of the Wi-Fi Chips responsible for
`
`performing functions specified by each of 802.11ac, 802.11ax, 802.11n, and/or 802.11g.
`
`38. Any and all documents relating to the elements of the Wi-Fi Chips which combine
`
`differing portions of the frame structure prior to transmission.
`
`39. Any and all documents relating to how the Wi-Fi Chips implement error correction
`
`schemes.
`
`40. Any and all documents relating to how the Wi-Fi Chips use circular bit shifting when
`
`preparing a transmission.
`
`41. Any and all documents relating to the Lawsuit.
`
`42. Any and all documents relating to the Patents-in-Suit.
`
`43. Any and all documents relating to communications with Asus regarding the Lawsuit.
`
`44. Any and all documents relating to communications with Wi-Fi Alliance regarding the
`
`Lawsuit.
`
`45. Any and all documents relating to Your indemnification of Asus relating to the Lawsuit.
`
`46. Any and all documents relating to the use of Your Wi-Fi Chip designated as QCA6174A
`
`in Lite-On Technology Corporation’s product designated as WCBN3507A-ADG.
`
`47. Any and all documents relating to the use of Your Wi-Fi Chip designated as QCNFA35
`
`in AzureWave Technologies, Inc.’s product designated as AW-CB231NF.
`
`48. Any and all documents relating to the results of any Prior Art search directed to any
`
`Asserted Patents or any Prior Art reference You believe anticipates and/or, in combination with
`
`other Prior Art references, renders obvious any claim of the Asserted Patents.
`
`49. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Provisional Application No. 60/956,031 (“Talukdar”).
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`50. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Pub. No. 2007/0155387 A1 (“Li”).
`
`51. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Pub. No. 2007/0104174 A1 (“Nystrom”).
`
`52. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Patent No. 8,213,368 (“Hui”).
`
`53. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Pub. No. 2006/0114816 A1 (“Maltsev”).
`
`54. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of EP Patent App. No. EP 1 760 925 A2 (“Döttling”).
`
`55. Any and all documents relating to any analyses, either alone or in combination with other
`
`Prior Art references, of U.S. Pub. No. 2006/0018389 A1 (“Koorapaty”).
`
`
`
`Ex. 2012 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`