`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.,
`Petitioner
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`v.
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`MEMORYWEB, LLC
`Patent Owner
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`Patent No. 10,621,228
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`Inter Partes Review No. IPR2022-00031
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`PATENT OWNER’S REQUESTS FOR PRODUCTION
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`MemoryWeb Ex. 2043
`Apple, Inc. v. MemoryWeb, LLC - IPR 2022-00031
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`INSTRUCTIONS
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`1.
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`In producing documents or other information responsive to these
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`Requests for Production (“RFPs”), Petitioner is to comply with the Federal Rules of
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`Civil Procedure 26 and 34, the Board’s Scheduling Order, and any other Board Order
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`in this proceeding, and the instructions in the Patent Trial and Appeal Board Practice
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`Guide.
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`2.
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`For each Request, identify any responsive document that Petitioner is
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`aware of but cannot product because it has been lost or destroyed or is no longer in
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`Petitioner’s possession, custody, or control.
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`3.
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`If Petitioner believes the meaning of any term in any Request is unclear,
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`Petitioner should assume a reasonable meaning, state what the assumed meaning is,
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`and produce documents and things or provide information on the basis of that
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`assumed meaning.
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`4.
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`For any document responsive to a Request that Petitioner withholds on
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`the basis of privilege, Petitioner shall provide a privilege log identifying the
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`document’s date, author(s), recipient(s), subject matter, and the basis of the asserted
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`privilege.
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` DEFINITIONS
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`5.
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`“Apple” or “Petitioner” means Apple, Inc. and all its current and former
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`parents, subsidiaries, affiliates, predecessors, successors, employees, managers,
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`1
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`MemoryWeb Ex. 2043
`Apple, Inc. v. MemoryWeb, LLC - IPR 2022-00031
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`officers, directors, partners, agents, representatives, attorneys, or anyone acting or
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`purporting to act on its behalf or control.
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`6.
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`“MemoryWeb” or “Patent Owner” means MemoryWeb, LLC and all
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`its current and former parents, subsidiaries, affiliates, predecessors, successors,
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`employees, managers, officers, directors, partners, agents, representatives, attorneys,
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`or anyone acting or purporting to act on its behalf or control.
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`7.
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`“Unified” means Unified Patents, LLC and all its current and former
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`parents, subsidiaries, affiliates, predecessors, successors, employees, managers,
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`officers, directors, partners, agents, representatives, attorneys, or anyone acting or
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`purporting to act on its behalf or control.
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`8.
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`“Apple IPR” means the inter partes review proceeding captioned as
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`Apple, Inc. v. MemoryWeb, LLC, IPR2022-00031.
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`9.
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`“Unified IPR” means the inter partes review proceeding captioned as
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`Unified Patents, LLC v. MemoryWeb, LLC, IPR2021-01413.
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`10. The term “Communication” shall mean the transmittal of information,
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`in the form of facts, ideas, inquiries, or otherwise.
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` REQUESTS
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`1.
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`All Communications with Unified, or about Unified, relating to
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`MemoryWeb, the ‘228 Patent, the Unified IPR, or the Apple IPR.
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`2.
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`All agreements or contracts between Apple and Unified, including
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`2
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`MemoryWeb Ex. 2043
`Apple, Inc. v. MemoryWeb, LLC - IPR 2022-00031
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`Apple’s membership agreement and any amendments, attachments, or add-ons
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`thereto.
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` /Jennifer Hayes/
`Jennifer Hayes
`Reg. No. 50,845
`Nixon Peabody LLP
`300 South Grand Avenue,
`Suite 4100,
`Los Angeles, CA 90071-3151
`Tel. 213-629-6179
`Fax 866-781-9391
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`Dated: June 30, 2023
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`By:
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`3
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`MemoryWeb Ex. 2043
`Apple, Inc. v. MemoryWeb, LLC - IPR 2022-00031
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