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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`v.
`
`MEMORYWEB, LLC
`
`Patent Owner
`
`Patent No. 10,621,228
`
`Inter Partes Review No. IPR2022-00222
`
`
`
`PATENT OWNER’S REQUESTS FOR PRODUCTION
`
`
`
`MemoryWeb Ex. 2035
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`
`
`
`
`INSTRUCTIONS
`
`1.
`
`In producing documents or other information responsive to these
`
`Requests for Production (“RFPs”), Petitioner is to comply with the Federal Rules of
`
`Civil Procedure 26 and 34, the Board’s Scheduling Order, and any other Board Order
`
`in this proceeding, and the instructions in the Patent Trial and Appeal Board Practice
`
`Guide.
`
`2.
`
`For each Request, identify any responsive document that Petitioner is
`
`aware of but cannot product because it has been lost or destroyed or is no longer in
`
`Petitioner’s possession, custody, or control.
`
`3.
`
`If Petitioner believes the meaning of any term in any Request is unclear,
`
`Petitioner should assume a reasonable meaning, state what the assumed meaning is,
`
`and produce documents and things or provide information on the basis of that
`
`assumed meaning.
`
`4.
`
`For any document responsive to a Request that Petitioner withholds on
`
`the basis of privilege, Petitioner shall provide a privilege log identifying the
`
`document’s date, author(s), recipient(s), subject matter, and the basis of the asserted
`
`privilege.
`
` DEFINITIONS
`
`5.
`
`“Samsung” or “Petitioner” means Samsung Electronics Co., Ltd. and
`
`Samsung Electronics America, Inc. and all their current and former parents,
`
`
`
`1
`
`MemoryWeb Ex. 2035
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`
`
`subsidiaries, affiliates, predecessors, successors, employees, managers, officers,
`
`directors, partners, agents, representatives, attorneys, or anyone acting or purporting
`
`to act on its behalf or control.
`
`6.
`
`“MemoryWeb” or “Patent Owner” means MemoryWeb, LLC and all
`
`its current and former parents, subsidiaries, affiliates, predecessors, successors,
`
`employees, managers, officers, directors, partners, agents, representatives, attorneys,
`
`or anyone acting or purporting to act on its behalf or control.
`
`7.
`
`“Unified” means Unified Patents, LLC and all its current and former
`
`parents, subsidiaries, affiliates, predecessors, successors, employees, managers,
`
`officers, directors, partners, agents, representatives, attorneys, or anyone acting or
`
`purporting to act on its behalf or control.
`
`8.
`
`“Samsung IPR” means the inter partes review proceeding captioned as
`
`Samsung Electronics Co., Ltd. v. MemoryWeb, LLC, IPR2022-00222.
`
`9.
`
`“Unified IPR” means the inter partes review proceeding captioned as
`
`Unified Patents, LLC v. MemoryWeb, LLC, IPR2021-01413.
`
`10. The term “Communication” shall mean the transmittal of information,
`
`in the form of facts, ideas, inquiries, or otherwise.
`
` REQUESTS
`
`1.
`
`All Communications with Unified, or about Unified, relating to
`
`MemoryWeb, the ‘228 Patent, the Unified IPR, or the Samsung IPR.
`
`
`
`2
`
`MemoryWeb Ex. 2035
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`
`
`2.
`
`All agreements or contracts between Samsung and Unified, including
`
`Samsung’s membership agreement and any amendments, attachments, or add-ons
`
`thereto.
`
` /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
`
`
`
`
`
`Dated: June 30, 2023
`
`
`
`
`
`By:
`
`
`
`
`
`3
`
`MemoryWeb Ex. 2035
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
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